PB99-964102
EPA541-R99-041
1999
EPA Superfund
Record of Decision:
Joliet Army Ammunition Plant
Soil and Groundwater OUs
(MFG and LAP Areas)
Wilmington, IL
10/30/1998
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Joliet Army Ammunition Plant
Wilmington, Will County, Illinois
Record of Decision for the
Soil and Groundwater Operable Units on the
Manufacturing and Load-Assemble-Package Areas,
National Priority List Sites
October, 1998
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L * *
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Table of Contents
Page
List of Figures viii
List of Tables viii
List of Acronyms x
Glossary . xii
I. DECLARATION FOR THE RECORD OF DECISION D-l
II. DECISION SUMMARY
1 SITE NAME, LOCATION, AND DESCRIPTION 1-1
2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 3-1
4 SCOPE AND ROLE OF OPERABLE UNITS OR RESPONSE ACTIONS 4-1
4.1 SoilOU 4-1
4.2 Groundwater OU..... 4-1
4.3 Final and Interim Actions 4-1
5 SITE CHARACTERISTICS 5-1
5.1 SoilOU 5-1
5.1.1 SRU1, Explosives in Soil 5-1
5.1.1.1 Site LI (Group 61) 5-1
5.1.1.2 Site L7 (Group 1) 5-2
5.1.1.3 Site L8 (Group 2) . 5-3
5.1.1.4 Site L9 (Group 3) .5-3
5.1.1.5 Site L10 (Group 3A) 5-3
5.1.1.6 Site L14 (Group 4) 5-4
5.1.1.7 Site L16 (Group 6) 5-4
5.1.1.8 Site M2 (Explosive Burning Ground) 5-4
5.1.1.9 Site M3 (Flashing Grounds) 5-5
5.1.1.10 Site M5 (Tetryl Production Area) 5-5
5.1.1.11 Site M6 (TNT Ditch Complex) 5-6
5.1.1.12 Site M7 (Red Water Area) 5-8
5.1.2 SRU2, Metals in Soil : 5-8
5.1.2.1 Site L2 (Explosive Burning Grounds) 5-8
5.1.2.2 Site L3 (Demolition Area) 5-9
5.1.2.3 Site L5 (Salvage Yard) 5-10
5.1.2.4 Site LI 1 (Test Site) 5-10
JOAAP Record of Decision Soil & Groundwater OTJs - October, 1998 as. i
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5.1.2.5 Site L23A (Disposal Pit) 5_10
5.1-2.6 Site M3 (Flashing Grounds) Z.Z.Z 5^10
5.1.2.7 Site M4 (Lead Azide Area) ZZZZZZ.' 5!} 1 *
5-1.2.8 Site M12 (Sellite Manufacturing Area) 5_1 j
5-1-3 SRU3, Explosives and Metals in Soil 5_12
5-1.3-1 Site L2 (Explosive Burning Grounds) 5_12
5.1.3.2 Site L3 (Demolition Area) .ZZZZZ 5-12 *
5-1.3.3 Site M5 (Tetryl Production Area) 5"13
5-1.3.4 Site M6 (TNT Ditch Complex) /n
5.1.4 SRU4, PCBs in Soil 5~J4
5.1.4.1 Site LI (Group 61) ' " 5'J4
5-1.4.2 Site L5 (Salvage Yard) ' /14
5.1.4.3 Site L7 (Group 1) 5 15
5.1-4.4 Site L8 (Group 2) 5"]5
5.1.4.5 Site L9 (Group 3) Z" 5~15
5.1.4.6 Site L10 (Group 3A) 5"16
5.1.4.7 Site L17 (Group 7) ."ZZZ" 5~16
5.1.5 SRU5, Organics in Soil ZZ. 5~17
5.1.5.1 Site LI (Group 61) ZZZ 5*17
5.1.5.2 Site L5 (Salvage Yard) 5~,o
5.1.6 SRU6, Landfills ZZZZZ" 5-jg
5.1-6.1 Site L3 (Demolition Area) 5"19
5.1-6.2 Site L4 (Landfill Area) ZZ"". 5^9
5.1-6.3 Site Ml (Southern Ash Pile) ." 5'20
5-1.6.4 Site M9 (Northern Ash Pile) " 5 20
5.1.6.5 Site Ml 1 (Landfill) ' 5"21
5.1.6.6 Site M13 (Gravel Pit) ' ' 5"22
5.1.7 SRU7, Sulfur .'..'.ZZZZZZ.'".' '.". 5^22
5.1-7.1 Site M8 (Acid Manufacturing Area) !."""ZZZZ 5-22
5-1-7.2 Site M12 (Sellite Manufacturing Area) 5 23
5.1.8 SOU No Further Action Sites ZZZZZZZ"""."ZZ"" 5-23
5.2 Groundwater OU <- 74
5.2.1 GRU1, Explosives - LAP Area ZZZ.Z.Z.Z 5-24
5.2.1.1 Site LI (Group 61) ZZZZZ 5-24
5-2.1.2 Site L2 (Explosives Burning Grounds) 5-24
5-2.1.3 Site L3 (Demolition Area) 5 24
5.2.1.4 Site L14 (Group 4) Z!".'.'.'Z.'.""."'.'"Z.""Z""".'" 5-25
5.2.2 GRU2, Explosives and Other Contaminants - MFG Area 5.25
5-2.2.1 Site Ml (Southern Ash Pile) ZZ'"""ZZZ"ZZ 5-25
5-2.2.2 Site M5 (Tetryl Production Area) 5.26
5-2.2.3 Site M6 (TNT Ditch Complex) Z... 5"26 *
5.2.2.4 Site M7 (Red Water Area) ZZZZZZZZ."!""'" 5-26
5-2.2.5 Site M8 (Acid Manufacturing Area) 5 27
5.2.2.6 Site M13 (Gravel Pits) ."Z!!ZZZZZ".'I!ZZZ 5-27
5.2.3 GRU3, Volatile Organic Compounds-MFG Area... 5 2g *
5.2.3.1 Site M3 5"2g
5.2.3.2 SiteMIO ZZZZZ'ZZZZZ 5-28 —
5.2.4 GOU No Further Action Sites ZZZZ"Z"! '".'.". 5-29. ^B
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 „„ „
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6 SUMMARY OF SITE RISKS 6-1
6.1 Human Health Risk 6-1
6.1.1 Human Health Risk Assessment 6-1
6,1.2 Assessment of Risk to Prairie Workers 6-4
6.2 Ecological Risk Assessment 5.4
6.2.1 Ecological Risk Assessments Conducted 6-4
6.2.2 Protection of Ecological Resources 6-5
6.3 Remedial Action Objectives (RAOs) 6-5
6.4 Development of Remediation Goals (RGs) 6-6
6.5 Exceedances of RGs 6-6
6.6 No Further Action Sites 6-10
7 DESCRIPTION OF ALTERNATIVES 7-1
7.1 Soil Operable Unit.... _ -j.\
7.1.1 Common Soil Alternative Remedies 7-1
7.1.2 Common Soil Actions . 7_2
7.1.3 SRU1: Explosives in Soil 7.3
7.1.4 SRU2: Metals in Soil ."1"^1"Z!!."Z.".™! 7-5
7.1.5 SRU3: Explosives and Metals in Soil/Sediment 7-6
7.1.6 SRU4: PCBs in Soil "." .".".".""! 7-6
7.1.7 SRU5: Organics in Soil 7_g
7.1.8 SRU6: Landfills ; '"" 7.9
7.1.9 SRU7: Sulfur '""'_ .'[!""".'"!! 7-10
7.2 Groundwater Operable Unit 7_10
7.2.1 Common Groundwater Alternatives 7-10
7.2.2 Common Groundwater Actions 7-12
7.2.3 GRU1: Explosives in Groundwater- LAP Area 7-12
7.2.4 GRU2: Explosives and Other Contaminants in Groundwater - MFC Area 7-13
7-2.5 GRU3: Volatile Organic Compounds (VOCs) in Groundwater - Ml;(.i Area 7-14
8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVKS 8-1
8.1 Nine Evaluation Criteria g-1
3.2 Soil Operable Unit , g_2
8.2.1 SRU1: Explosives in Soil !.!!"."".'."."!"I1""1"1'.'."!!!!!!.'"!!""!!.' 8-2
8.2.1.1 Summary Evaluation of Alternatives for SRU1 8-4
3-2.2 SRU2: Metals in Soil ' ."^. 3.4
8.2.2.1 Summary Evaluation of Alternatives for SRU2..... 8-7
8.2.3 SRU3: Explosives and Metals in Soil 8-8
8-2.3.1 Summary Evaluation of Alternatives for SRU3 8-11
8.2.4 SRU4: PCBs in Soil 8-12
8-2.4.1 Summary Evaluation of Alternatives for SRU4 8-14
8.2.5 SRU5: Organics in Soil 8-15
8.2.5.1 Summary Evaluation of Alternatives for SRU5 8-17
8.2.6 SRU6: Landfills 's-17
8-2.6.1 Summary Evaluation of Alternatives for SRU6 8-20
8.2.7 SRU7: Sulfur '. ..L. 8-20
8-2.7.1 Summary Evaluation of Alternatives for SRU7..... 8-22
8.2.8 Summary of Selected Remedies for all SRUs 8-24
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 Revision 1 - {0/27/98 pg. Hi
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8.3 Groundwater Operable Unit 8-25
83.1 GRU1: Explosives in Groundwater - LAP Area 8-25
8.3.1.1 Summary Evaluation of Alternatives for GRU1 ., . 8-27
8.3.2 GRU2: Explosives and Other Contaminants in Groundwater - MFG Area 8-28
8.3.2.1 Summary Evaluation of Alternatives for GRU2 8-30
8.3.3 GRU3:Volatile Organic Compounds (VOCs) in Groundwater - MI-'G Area 8-32
8.3.3.1 Summary of Evaluation for GRU3 8-34
8.3.4 Summary of Selected Remedies for all GRUs 8-36
8.4 Cost Summary for Selected Remedies 8-36
9 SELECTED REMEDIES 9.1
9.1 Soil Operable Unit , 9.3
9.1.1 Common Soil OU Actions 9_2
9.1.1.1 Building Demolition ._ 9_2
9-1-1.2 Soil Excavati on, Transportation, and Confirmatory Sampl ing 9-2
9.1.1.3 Soil Preparation 9.3
9.1.1.4 Backfilling, Regrading, and Revegetating Excavated Areas 9-3
9.1.1.5 Soil Disposal ; 9.3
9-1-1-6 Institutional Controls -- Deed Restrictions on Land and Soils 9-4
9.1.2 SRU1: Explosives in Soil — Bioremediation 9.4
9.1.2.1 Bioremediation 9.5
9.1.2.2 Treatment Area Decommissioning 9.5
9.1.2.3 Remedial Time and Cost 9.5
9.1.3 SRU2: Metals in Soil -- Excavation and Disposal 9-6
9.1.3.1 Remedial Time and Cost 9_g
9.1.4 SRU3: Explosives and Metals in Soil «
Bioremediation and Disposal, and Excavation and Disposal 9-6
9.1-4.1 Treatment Determination 9.7
9.1.4.2 Remedial Time and Cost 9.7
9.1-5 SRU4: PCBs in Soil — Excavation/Incineration and Disposal 9-8
9.1.5.1 Soil Incineration or Disposal 9_g
9.1.5.2 Remedial Time and Cost 9.8
9-1.6 SRU5: Organics in Soil — Excavation and Disposal 9-8
9.1.6.1 Soil Disposal Z"Z"'"ZZ'Z 9-9
9.1.6.2 Remedial Time and Cost 9.9
9.1-7 SRU6: Landfills — Capping or Excavation and Disposal 9-9
9.1.7.1 Capping 9.9
9.1.7.2 Excavation and Disposal 9.9
9.1.7.3 Institutional Controls 9.10
9.1.7.4 Remedial Time and Cost 9_10
9.1-8 SRU7: Sulfur - Removal and Recycle or Disposal 9-10
9.1.8.1 Sulfur Recycle or Disposal 9_H
9.1-8.2 Institutional Controls 9_H
9.1.8.3 Remedial Time and Cost 9_11
9.2 Groundwater Operable Unit 9_11
9.2.1 Common Groundwater OU Actions 9_11
9.2.1.1 Groundwater Management Zone (GMZ) 9-11
9-2.1.2 Institutional Controls - Deed Restrictions on Groundwater Use 9-12
9.2.1.3 Site Inspections 9_13
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 Revision I -10/27/98 pg. iv
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9-2-1.4 Groundwater Monitoring o ,.,
9-2.1.5 Natural Attenuation Z.ZZ.ZZ.ZZ 9 14
9-2.1.6 Contingency Plan o ,.
9.2.2 GRUI .-Explosives in Groundwater -LAP Area -Limited Action 915
9.2.2.1 Establishment of GMZs.. _'"" "_"_' ^
9-2.2.2 Groundwater Monitoring •"" « ,5
9.2.2.3 Natural Attenuation o"16
t 9.2.2.4 Remedial Time and Cost 1ZZZZZ 9*16
9.2.3 GRU2: Explosives and Other Contaminants in Groundwater -MFC Area
— Limited Action g ,,
9-2.3.1 Establishment of GMZs ZZZZZ g'\j
9-2.3.2 Groundwater Monitoring g ,?
9-2.3.3 Remedial Time and Cost o ,R
9.2.4 GRU3: Volatile Organic Compounds (VOCs) in Groundwater -MFC! Area
— Limited Action ;._
9-2.4.1 Establishment of GMZs ZZZZZZZZZZZZZ 9 18
9.2.4.2 Groundwater Monitoring
9-2-4.3 Remedial Time and Cost g~
9.3 Institutional Controls
9-3.1 Notifications to Recorder's Office Q~,Q
9.3.2 Notifications to Land Owners of Access Easements and Restrictive Easements 9-19
y.3-3 Notifications to Will County of Restricted Use of Water 9 19
9.3.4 Re%new Authority of the USEPA and EEPA
....... -
9-3-5 Continuing Responsibilities of the Army. ............. . ....................... ................. " ........... 9
Non-Det ...................... ""
9-3.7 Easement
9-20
9-3-6 Non-Detrimental Use of the Property by the Army .......................... ...................... "" 9.20
..................... : .............. ~
.................
9-3-8 Enforcement of Restrictions ................ . ........ .. ............................ .......................... o 20
.................................................. .
10.1 Protection to Human Health and the Environment ..................................... i n"i
.............. ..... ............................ lo~l
10 STATUTORY DETERMINATIONS.
10.1 Protection to Human Health and the En
10.1.2 Groundwater OU '.' " ~
10.2 Compliance with Applicable or Relevant and Appropriate Requirements (A RARs)
and To-Be-Considered (TBC) Guidance. 10 2
10.2.1 Soils Operable Unit (OU) ZZZ...ZZZZZ 10-2
10.2 1.1 Chemical-specific ARARs and TBC Guidance for Soils and Sediment 10-2
i U.Z.I.2 Action-Specific ARARs for Soils OU 10_5
10.2.1.3 Location-specific ARARs and TBC Guidance for Soils OU ZZ" ZZ 10-12
10-2.2 Compliance with Applicable or Relevant and Appropriate Requirementsi (ARARs)
211(1 T°-Be-Considered (TBQ Guidance for Groundwater Operable Unit (OU) . 10-13
1U.2.2.1 Chemical-specific ARARs and TBC Guidance for Groundwater OU 10-13
10.2.2.2 Action-specific ARARs and TBC Guidance for Groundwater..... 10-14
10.2.2.3 Location-specific ARARs and TBC Guidance 10-i5
10.3 Cost Effectiveness
^ 10.3.1 SoilOU ZZZZZZZZZZZ in 15
10.3.2 Groundwater OU , Z.ZZZZZ lo"l6
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies
(or Resource Recovery Technologies) to the Maximum Extent Practicable 10-16
10A1 S°ilOU - .....ZZZZZ 10-16
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 Revision I - j.M 7/S& pg. V
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10.4.1.1 SRU1: Explosives in Soil 10-16
10.4.1.2 SRU2: Metals in Soil .'. 10-16
10.4.1.3 SRU3: Explosives and Metals in Soil 10-17
10.4.1.4 SRU4: PCBs in Soil ' iQ-17 6
10.4.1.5 SRU5: Organics in Soil 10-17
10.4.1.6 SRU6: Landfills '2 Z'Z 10-17
10.4.1.7 SRU7: Sulfur 10-18
10.4.2 Groundwater OU 10-18 *
10.4.2.1 GRU1: Explosives in Groundwater 10-18
. 10.4.2.2 GRU2: Explosives and Other Contaminants in Groundwater 10-18
10.4.2.3 GRU3: Volatile Organic Compounds in Groundwater 10-18
10.5 Preference for Treatment as a Principal Element 10-18
10.5.1 SoilOU 10_i8
10.5.2 Groundwater OU 10-19
11 DOCUMENTATION OF SIGNIFICANT CHANGES... 11-1
11.1 Documentation of Other Changes 11_1
12 REFERENCES ....12-1
HI. COMMUNITY PARTICIPATION RESPONSIVENESS
SUMMARY
^^_t
RS 0.1 Background on Community Involvement RS-2
RS 1 Objectives ........ RS-10
RS 1.1 Protect Human Health and the Environment RS-10
RS 1.2 Concern Over Selection of Remediation Goals RS-10
RS 1.3 Concerns Over Protection of the Midewin Tallgrass Prairie
and the Veteran's Cemetery Parcel RS-15
RS 2 Remediation Technology RS-16
RS 2.1 General Comments Supportive of the Selected Remedies RS-16
RS 2.2 Remedial Alternative Contingency Plans RS-16
RS 2.3 Preference for Excavation and Disposal Alternative RS-17
RS 2.4 Concerns Over Dependency on the Future Proposed Will County Landfill (WCLF) RS-18
RS2.5 Concerns Over Natural Attenuation RS-18
RS 2.6 Concern Regarding Issue Clarification RS-19
RS 3 Operational Issues RS-20
RS 3.1 Concerns Over RCRA Wastes RS-20
RS 3.2 Concerns About Deed Restrictions RS-20
RS3.3 Concerns for Stormwater Runoff RS-21
RS4 Monitoring __ RS-22
RS 4.1 Concerns About Groundwater Monitoring . RS-22 *
RS 4.2 Long-Term Monitoring ; RS-23
RS 4.3 Biomonitoring _ RS-23
RS 5 Implementation _ RS-24
JOAAPRecord of Decision Soil & Groundwater OUs - October, 1998 Revision 1 -JJO/27/98 pg.vi
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RS 5.1 Requests to Expedite Implementation of Remedy RS-24
RS 5.2 Request to Use Local Labor RS-25
RS 5.3 Request to Use Union Labor , RS-25
RS 5.4 Request to Prioritizing Remediation of Industrial Park Sites RS-25
RS 5.5 Concerns for Improving Tax Base . RS-25
RS 5.6 Concerns Over Remedy Implementation Schedule RS-26
RS 6 Other Issues _ RS-26
RS 6.1 Removal of UXOs .....' ..."Z!."Z1."ZZ." H.""'l" RS-26
RS 6.2 Sulfur Cleanup RS-26
RS 6.3 Concerns Over the Nature and Extent of Contamination RS-27
RS 6.4 Groundwater Plumes RS-27
RS 6.5 Miscellaneous Comments RS-28
APPENDIX
Appendix A: Summary of Reasonable Maximum Exposure (RME) Risk
Characterization (as Estimated in JOAAP Baseline Risk
Assessments)
Appendix B: Summary of Estimated Costs of Remedial Alternatives for
All SRUs and GRUs
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 Revision I -10/27/98 pg.vii
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List of Figures
Figure 1 Study Sites and Future Land Use Plan Figure Section at back of ROD
Figure 2 Geologic Cross Section, Joliet Army Ammunition Plant Figure Section
Figure 3 Soil Operable Unit, Summary of Remedial Actions .., Figure Section
Figure 4 Groundwater Unit, Summary of Remedial Actions Figure Section
List of Tables
Page
Table 4-1 Soil and Groundwater Remedial Units 4-2
Table 5-1 Sites and Subareas of SRU1 (Explosives in Soil) 5-2
Table 5-2 Exceedances of Remediation Goals (RGs) as a Function of Land
Use for Soils Found in SRU1 5-7
Table 5-3 Sites and Subareas of SRU2 (Metals in Soil) 5-8
Table 5-4 Exceedances of Remediation Goals (RGs) as a Function of Land
Use for Soils Found in SRU2 5-12
Table 5-5 Sites and Subareas of SRU3 (Explosives and Metals in Soil) .-. 5-12
Table 5-6 Exceedances of Remediation Goals (RGs) as a Function of Land
Use for Soils Found in SRU3 , 5-13
Table 5-7 Sites and Subareas of SRU4 (PCBs in Soil) 5-14
Table 5-8 Exceedances of Remediation Goals (RGs) as a Function of Land
Use for Soils Found in SRU4 , 5-16
Table 5-9 Sites and Subareas of SRU5 (Organics in Soil) 5-17
Table 5-10 Exceedances of Remediation Goals (RGs) as a Function of Land
Use for Soils Found in SRU5 5-18
Table 5-11 Sites and Subareas of SRU6 (Landfills)..... 5-19
Table 5-12 Exceedances of Remediation Goals (RGs) as a Function of Land
Use for Soils Found in SRU6 5-21
Table 5-13 Sites and Subareas of SRU7 (Sulfur) 5-23
Table 5-14 Exceedances of Remediation Goals (RGs) as a Function of Land
Use for Soils Found in SRU7 5-23
Table 5-15 Sites Overlying GRU1 (Explosives in Groundwater-LAP Area) 5-24
Table 5-16 Exceedances of Remediation Goals (RGs) as a Function of Land
Use for Groundwater Found in GRU1 5-25
Table 5-17 Sites Overlying GRU2 (Explosives and
Other Contaminants in Groundwater - MFG Area) 5-26
Table 5-18 Exceedances of Remediation Goals (RGs) as a Function of Land
Use for Groundwater Found in GRU2 5-27
Table 5-19 Site Overlying GRU3 VOCs in Groundwater - MFG Area 5-28
Table 5-20 Exceedances of Remediation Goals (RGs) as a Function of Land
Use for Groundwater Found in GRU3 5-29
Table 6-1 Summary from Baseline Risk Assessment of Sites
Where Risks Exceed 10"* and Hazard Indices Exceed 1.0 for
Recreational Users and Industrial Workers 6-3
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
Revision I -1(1/27/98 pg. viii
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Table 6-2 Soil, Sediment, and Groundwater Remedial Goals 6-7
Table 6-3 CERCLA No Further Action Sites -Soil 6-10
Table 6-4 CERCLA No Further Action Sites - Groundwater 6-13
Table 8-1 Evaluation of Remedial Alternatives for SRU1 (Explosives in Soil) 8-5
Table 8-2 Evaluation of Remedial Alternatives for SRU2 (Metals in Soil) 8-8
Table 8-3 Evaluation of Remedial Alternatives for SRU3 (Explosives and Metals in Soil) 8-11
Table 8-4 Evaluation of Remedial Alternatives for SRU4 (PCBs in Soil) 8-14
Table 8-5 Evaluation of Remedial Alternatives for SRU5 (Organics in Soil) 8-18
Table 8-6 Evaluation of Remedial Alternatives for SRU6 (Landfills) 8-21
Table 8-7 Evaluation of Remedial Alternatives for SRU7 (Sulfur) 8-23
Table 8-8 Summary of Recommended Remedial Alternatives
for All SRUs - LAP and MFG Areas 8-24
Table 8-9 Evaluation of Remedial Alternatives
for GRU1 (Explosives in Groundwater - LAP Area) 8-28
Table 8-10 Evaluation of Remedial Alternatives for GRU2
(Explosives and Other Contaminants in Groundwater - MFG Area) 8-31
Table 8-11 Evaluation of Remedial Alternatives for GRU3
(VOCs in Groundwater - MFG Area) 8-35
Table 8-12 Summary of Recommended Remedial Alternatives
for All GRUs—LAP and MFG Areas 8-36
Table 9-1 Selected Remedies and Costs of Clean up for SRUs/GRUs 9-1
Table 10-1 Water Quality Standards and TCLP Concentration Limits 10-3
Table RS-1 Responsiveness Summary: Proposed Plan Comments Cross-Referencc RS-4
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
pg.ix
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List of Acronyms
AEHA Army Environmental Hygiene Agency
AOP Ammonia Oxidation Plant
ARAR Applicable or Relevant and Appropriate Requirement
AST Above-Ground Storage Tank
SNA Base-Neutral-Acid, also referred to as semivolatiles
BRA Baseline Risk Assessment
BTAG Biological Technical Assistance Group
BTEX Benzene, Toluene, Ethylbenzene, and Xylenes
CAMU ,. Corrective Action Management Unit
CERCLA Comprehensive Environmental Response Compensation and Liability Act
COC Chemical of Concern
CY Cubic Yard
CFR Code of Federal Regulations
CHPPM Center for Health Promotion and Preventive Medicine
DNAPL Dense Non-Aqueous Phase Liquid
DNB Dinitrobenzene
DMT Dinitrotoluene
DQO Data Quality Objective
ERA Ecological Risk Assessment
FFA Federal Facility Agreement
POST Finding of Suitability to Transfer
FS Feasibility Study
GMZ Groundwater Management Zone
GOU Groundwater Operable Unit
GRU Groundwater Remedial Unit
HI Hazard Index
HMX High Melting Explosive
IAC Illinois Administrative Code
IEPA Illinois Environmental Protection Agency
IRP Installation Restoration Program
JOAAP Joliet Army Ammunition Plant
LAP Load-Assemble-Package Area
LDR Land Disposal Restriction
LNAPL Light Non-Aqueous Phase Liquid
LTTD Low-Temperature Thermal Desorption
MFG Manufacturing Area
MG Million gallons
MW Monitoring Well
Jlg/g Microgram per gram
j4.g/L Microgram per Liter
NA Not Applicable
NB Nitrobenzene
NC Chemical is not a Contaminant of Concern
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
PK- x
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NCP National Contingency Plan
NEPA National Environmental Policy Act
NFA No Further Action
NPDES National Pollutant Discharge Elimination System
NPL National Priority List
NT Nitrotoluene
PAH Polynuclear Aromatic Hydrocarbons
PCB Polychlorinated Biphenyl
PCE Tetrachlorethene (Perchloroethene)
PHI Phase I (of the Remedial Investigation)
PH2 Phase 2 (of the Remedial Investigation)
ppm Part Per Million
PP Proposed Plan
PRO Preliminary Remediation Goal
PVC Polyvinyl Chloride
RAB Restoration Advisory Board
RAG Risk Assessment Guidance
RAO Remedial Action Objective
RBC Risk-based Concentration
RCRA Resource Conservation and Recovery Act
RDX Royal Demolition Explosive
RG Remediation Goal
RI Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
SF Square foot
SOU Soil Operable Unit
SRU Soil Remedial Unit
TBC To Be Considered
TBE To be evaluated after the public review period
TCLP Toxicity Characteristic Leaching Procedure
TNB Trinitrobenzene
TNT Trinitrotoluene
TPH Total Petroleum Hydrocarbons
TSCA Toxic Substances Control Act
USAGE U.S. Army Corps of Engineers
USAEC U.S. Army Environmental Center
USATHAMA U.S. Army Toxic and Hazardous Materials Agency
USDA U.S. Department of Agriculture
USDA/FS U.S. Department of Agriculture, Forestry Service
USEPA U.S. Environmental Protection Agency
UST Underground Storage Tank
UV Ultraviolet
UXO Unexploded Ordnance
VOC Volatile Organic Compound
WCLF Will County Landfill
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
pg.xi
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GLOSSARY
Absorption
Adsorption
Air Stripping
Biodegradation
Bioreactor
Bioremediation
Carbon Adsorption
Chemical
Dehalogenation
Groundwater
GMZ
GOU
Incineration
Low Temperature
Thermal Desorption
PCBs
RCRA Hazardous
Wastes
Penetration of one substance into the inner structure of another.
A phenomenon where one substance is attracted to and held on the surface of
another.
Process where an air stream is used to remove relatively volatile dissolved
organic compounds.
A molecular degradation, or chemical breakdown, of an organic substance
resulting from metabolic action of living organisms (principally bacteria,
fungi, algae, or yeast).
A reactor where combined, attached and suspended biological growth exist to
biodegrade an organic substance.
Process where the biological microorganisms are used to biodegrade the
contaminants in soil and groundwater.
Process where contaminants are attracted and held on the surface of activated
carbon.
The addition of a chemical reagent to break the chemical structure of PCBs.
Water beneath the earth's surface between saturated soil and rock that
supplies wells and springs.
Groundwater Management Zone. A three-dimensional region within any
class of groundwater. The GMZ contains groundwater being managed to
mitigate impairment caused by the release of contaminants from a site.
Groundwater operable unit (GOU). GOUs consist of sites where
contaminated groundwater plumes were identified.
High temperature process to volatilize and/or combust organic constituents in
soils.
Process where the low temperature is used to remove organic compounds
from the contaminated media for subsequent collection and disposal.
Chemical compounds commonly used as heat exchange agents in
transformers.
Regulations for RCRA hazardous wastes are provided in 40 ( :i;R 260 through
272. Characteristic wastes (shown as Dxxx) exhibit the characteristics of
gnitability, corrosivity, reactivity, or toxicity. Listed wastes (shown as Fxxx,
Cxxx, Pxxx, or Uxxx) are process wastes that are regulated under 40 CFR.
The following characteristic and listed wastes have been identified as
potentially existing at JOAAP:
D003 Explosives category based on 40 CFR 261 .23 (6), (7) or (8)
D006 Wastes that exhibit or are expected to exhibit, the characteristic
of toxicity for cadmium based on extraction procedure (EP) in
SW846 Method 13 10.
D008 Wastes that exhibit or are expected to exhibit, the characteristic
of toxicity for lead based on extraction procedure (EP) in
SW846 Method 13 10.
D030 Wastes that have toxic characteristics (TC) for 2,4-Dinitro-
toluene based on the TCLP in SW846 Method 1311
K046 Wastewater treatment sludge from the manufacturing,
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
pg. xu
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RCRA Subtitle C
landfill
RCRA Subtitle D
landfill
Semivolatiies
SOU
Solidification/
Stabilization
Solvent Extraction
Special Wastes
TCLP
UV Oxidation
VOC
WCLF
formulation and loading of lead-based initialing compounds
K047 Pink/red water from TNT operations.
K048 Dissolved air floatation (DAF) float from the petroleum
refining industry.
Kl 1 1 product washwaters from the production of dinitrotoluene via
the nitration of toluene
U220 Toluene as a raw material or commercial chemical product
A hazardous waste landfill disposal facility
A non-hazardous solid waste landfill disposal facility
Carbon-containing compound which does not evaporate readily at ordinary
temperatures. Semivolatiies are also known as BNAs (Base-Neutral-Acids)
Soil Operable Unit (SOU). SOUs consist of sites where contaminated
soils, sediments, and debris were identified.
Process where the contaminants are physically or chemically bound and
stabilized to reduce mobility. Binding agents for inorganic contamination
include cements, lime, pozzolans, gypsum, and silicates. Binding agents for
organic contamination include epoxy, polyesters, asphalt, polyolefins and
urea-formaldehyde.
Process where solvent is used to remove and concentrate organic compounds.
Special wastes are defined under the Illinois Environmental Protection Act
as, "any industrial process waste, pollution control waste or hazardous waste
except as determined pursuant to Section 22.9 of this Act. "Special Waste"
also means potentially infection medical waste. [Section 3.45|
Toxicity Characteristic Leaching Procedure. The laboratory procedure used
to determine whether the toxic contaminants of concern leach from the waste
at unacceptable levels.
Ultra Violet Oxidation. Process where the chemical degradation of
contaminants is accomplished by adding a strong oxidizcr (e.g. ozone) and
passing water by UV lights.
Volatile Organic Compound. A carbon-containing compound which
evaporates readily at ordinary temperatures.
Will County Landfill (WCLF) This future proposed landfill will be a
permitted special waste landfill (as defined in Section 22.9 of the Illinois
Environmental Protection Act) and will also be a permitted RCRA Subtitle D
landfill.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
pg. xm
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DECLARATION FOR
THE RECORD OF DECISION
SITE NAME AND LOCATION
Joliet Army Ammunition Plant,
Soil and Jjroundwater Operable Units
Manufacturing and Load-Assemble-Package Areas
Wilmington, Will County, Illinois
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected final and interim remedies for the Joliet Army Ammunition
Plant (JOAAP), Soil and Groundwater Operable Units (SOU, GOU). These remedies are chosen in
accordance with the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 and
the National Contingency Plan (NCP). This decision is based on the administrative record file for this
site. The United States Environmental Protection Agency (USEPA) Region V and the Illinois
Environmental Protection Agency (IEPA) concur with the selected remedies. This document complies
with and satisfies the intent of the National Environmental Policy Act (NEPA) of 1969.
JOAAP has been addressed under the CERCLA program as two National Priority 1 .ist (NPL) sites, the
Manufacturing (MFG) Area and the Load-Assemble-Package (LAP) Area. The MR! and LAP Areas
were listed on the NPL on July 21, 1987 and March 31, 1989, respectively. This Record of Decision
(ROD) addresses the remediation of soil and groundwater in both the MFG and LAP Areas.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing
the response actions selected in this ROD, may present an imminent and substantial endangerment to
public health, welfare, or the environment.
INTERIM COMPONENT
Actions described within this document are considered interim related to soil remedial units (SRUs) 1, 2,
3, and 5 as applicable to USDA lands. A subsequent Final ROD is planned to address this interim
component. All other decisions within this document are considered final.
DESCRIPTION OF THE SELECTED REMEDIES
The OUs are divided into seven soil remedial units (SRUs), three groundwater remedial units (GRUs),
and two No Further Action (NFA) groups. The SOU is divided into six SRUs involving CERCLA-based
remediation, one SRU involving non-CERCLA removal action, and an eighth group involving the NFA
sites for soil. The soil in this eighth group has been determined to pose no threat to human health or the
environment. The GOU is divided into three GRUs involving CERCLA-based actions, and one group
including the NFA sites for groundwater. The groundwater in this latter group has been determined to
pose no threat to human health or the environment. The goal of the final cleanup of the SRUs and GRUs
is to protect human health and the environment by eliminating, reducing, or controlling hazards posed by
the site and to meet all applicable or relevant and appropriate requirements associated with the site. The
goal of the interim actions is to remove sources of groundwater contamination and/or to prevent the
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. D-l
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further migration of contamination. Overall, fifty-three (53) sites and three (3) subareas of these sites
were identified in the CERCLA program at JOAAP.
SRU1, Explosives in Soil, addresses an estimated 151,480 cubic yards (CY) of explosives-contaminated
soil. The selected remedy for SRU1 is Bioremediation (see Section 9.1.2). The major components of
this remedy include the excavation of soils and sediments contaminated with explosives above the
Remediation Goals (RGs), confirmatory sampling, and treatment of the soil using a biorernediation
process. The treated soil will be reused or properly disposed.
Some of the soils in SRU1 were contaminated by Resource Conservation and Recovery Act (RCRA)
listed hazardous wastes, and as such "contain" these wastes. The Army based its detailed analysis of
alternatives and selection of remedial technologies for these SRU1 soils on two determinations. First,
media, such as soils, at JOAAP that were contaminated with RCRA listed hazardous wastes, are not
themselves hazardous wastes unless they exhibit the characteristic for which the waste was listed.
Second, once media contaminated with RCRA listed hazardous wastes are treated to below RGs, are not
Toxic Characteristic Leaching Procedure (TCLP) hazardous wastes under RCRA, and do not exceed
RCRA Land Disposal Restriction (LDR) concentrations, the media are no longer a RCRA hazardous
waste.
SRU2, Metals in Soil, addresses an estimated 22,940 CY of soil contaminated with metals. The selected
remedy for SRU2 is Excavation and Disposal (see Section 9.1.3). This remedial action will include the
excavation of soil contaminated with metal concentrations above the RGs, confirmatory sampling, and
final disposal. The soil will be reused or properly disposed
SRU3, Explosives and Metals in Soil, addresses an estimated 33,120 CY of soil contaminated with
metals and explosives. The selected remedies for SRU3 are Bioremediation and Disposal and
Excavation and Disposal (see Section 9.1.4). The Army will treat all soils that are RCRA hazardous
waste based on explosives contamination in the soil. The Army may treat all other soils in SRU3. The
major components of the Bioremediation and Disposal remedy include the excavation of soil
contaminated with explosives and metals above RGs, confirmatory sampling, biorernediation process,
and, if necessary, solidification/stabilization process. The major components of the Excavation and
Disposal remedy include the excavation of soil contaminated with explosives and metals above the RGs,
confirmation sampling, and final disposal. The soil will be reused or properly disposed. The disposal
options for treated and untreated soils are presented in Section 9.1.1.5.
Some of the soils in SRU3 were contaminated by RCRA listed hazardous wastes, and as such "contain"
these wastes. The Army based its detailed analysis of alternatives and selection of remedial technologies
for these SRU3 soils on two determinations. First, media, such as soils, at JOAAP that were
contaminated with RCRA listed hazardous wastes, are not themselves hazardous wastes unless they
exhibit the characteristic for which the waste was listed. Second, once media contaminated with RCRA
listed hazardous wastes are treated to below RGs, are not TCLP hazardous wastes under RCRA, and do
not exceed RCRA LDR concentrations, the media are no longer a RCRA hazardous waste.
SRU4, Polychlorinated Biphenyls (PCBs) in Soil, addresses an estimated 3,416 CY of soil
contaminated with PCBs. The selected remedy for SRU4 is Excavation and Disposal (see Section 9.1.5).
This remedial action will include the excavation of soil contaminated with I'CBs above the RGs,
confirmatory sampling, and final disposal. Soils with PCB concentrations below 50 parts per million
(ppm) will be disposed at a permitted RCRA Subtitle D landfill, such as the future proposed Will County
Landfill (WCLF). Soils with PCB levels between 50 ppm and 500 ppm will be disposed in a Toxic
JOAAP Record of 'Decision Soil & Groundwater OUs - October, 1998 pg. D-2
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Substances Control Act (TSCA) permitted landfill. Soils with PCB levels greater than 500 ppm will be
disposed off-site in accordance with TSCA (e.g., incinerated at an off-site TSCA permitted incinerator).
SRU5, Organics in Soil, addresses an estimated 2,410 CY of soil contaminated with organic
compounds. The selected remedy for SRU5 is Excavation and Disposal (see Section 9.1.6). This
remedial action includes the excavation of organics-contaminated soil above the RGs, confirmatory
sampling, and disposal at a permitted RCRA Subtitle D landfill.
SRU6, Landfills, addresses six landfills or debris piles covering a total of approximately 120 acres. The
selected remedies for SRU6 are to cap three of the landfills (L3, Ml 1, Ml3) and to excavate and dispose
of the materials in the other three landfills (L4, Ml, M9) (see Section 9.1.7). The capping of three sites
will cover an estimated 98 acres. The excavation and disposal at the other three sites will include the
excavation of 366,000 CY of contaminated soil, waste segregation, and disposal. 1 Jazardous wastes, if
encountered, will be disposed at a permitted RCRA Subtitle C landfill, and non-hazardous wastes will'be
disposed at a permitted RCRA Subtitle D landfill. The remedy for the capped landfills in SRU6 will
result in hazardous substances remaining on-site above risk-based levels.
SRU7, Sulfur, involves two sites where an estimated 7,500 CY of sulfur has been found on and near the
surface. Since raw sulfur is not a regulated substance under CERCLA, the cleanup of these sites will be
conducted outside of the Army's CERCLA-based program. The cleanup action at this unit includes the
excavation and recycling or disposal of raw sulfur off-site (see Section 9.1.8).
Soil NFA sites include 28 sites and two subareas at JOAAP. These sites were suspected of having soil
contamination, but upon investigation or following a removal action, they have been found to contain
either no evidence of contamination, no contamination, or contamination at concentrations that do not
pose a threat to human health or the environment. These 28 sites and two subareas require no further
cleanup actions for soil (see Sections 5.1.8 and 6.6).
GRU1, Explosives in Groundwater, addresses an estimated 87 million gallons (MG) of groundwater
contaminated with explosives in the LAP area (see Section 9.2.2).
GRU2, Explosives and Other Contaminants in Groundwater, addresses an estimated 541 MG of
groundwater contaminated with explosives, volatile organic compounds (VOCs) and metals in the
MFG area (see Section 9.2.3).
GRU3, VOCs in Groundwater, addresses an estimated 3 MG of groundwater contaminated with VOCs
in the MFG area (see Section 9.2.4).
The selected remedy for each of the three GRUs is Limited Action including establishing Groundwater
Management Zones, deed and zoning restrictions, periodic site inspections, groundwater and surface
water monitoring, and natural attenuation. For the three GRUs, the selected remedies will result in
hazardous substances remaining on-site above risk-based levels until remediation is complete.
Groundwater NFA sites include 41 sites and three subareas at JOAAP. These sites were suspected of
having groundwater contamination, but upon investigation, have been found to contain either no
evidence of contamination, no contamination, or contamination at concentrations that do not pose a
threat to human health or the environment. These 45 sites and subareas require no further cleanup
actions for groundwater (see Sections 5.2.4 and 6.6).
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. D-3
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STATUTORY DETERMINATIONS
The selected remedial actions for all SRUs and GRUs will protect human health and the environment
comply with Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial actions, and are cost-effective. These remedies utilize permanent solutions and alternative
treatment technology to the maximum extent practicable. To the maximum extent practicable, they also
treat the principal threats posed by the contamination identified at the sites.
Because the remedies selected for the SRUs and GRUs will result in hazardous substances remaining on-
site above levels that allow-for unlimited use and unrestricted access, a review will be conducted within
five years after the commencement of remedial action to ensure that the remedies continue to provide
adequate protection of human health and the environment.
Because the actions within SRUs 1, 2, 3 and 5 for USDA lands are interim, the review of these lands and
the interim remedies will be ongoing as final remedial alternatives are developed.
r/—- ff- r~y OCT 9. 9 1QQfl
Raymond J. Fatz Date
Deputy Assistant Secretary of the Army
(Environment, Safety and Occupational Health)
OASA (IL&E)
Date
Director, Superfund Division
U.S. Environmental Protection Agency, Region V
l^^-
Mary A. Gade
Director
Illinois Environmental Protection Agency
JOAAP Record of Decision Soil & Groundwaler OUs - October, 1998 Revision 2 - IH/2K/9X
PS- D-4
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1 SITE NAME. LOCATION. AND DESCRIPTION
The JOAAP is a former U.S. Army munitions production facility located on approximately 36 square
miles (23,542 acres) of land in Will County, Illinois. The JOAAP is located approximately 17 miles
south of Joliet and is divided into two main functional areas (Figure 1): the LAP Area (to the east of
Route 53) and the MFG Area (to the west of Route 53). Each Area has been listed, by USEPA, on the
NPL as a CERCLA site.
The MFG Area, covering approximately 14 square miles (9,159 acres), is where the chemical constituent
of munitions, propellants and explosives were manufactured. The production facilities are located in the
northern part of the MFG Area. On the southern half of the MFG Area, there is an extensive explosives
storage facility. The LAP Area, covering approximately 22 square miles (14,383 acres), is where
munitions were loaded, assembled, and packaged for shipping. This area of JOAAP contains munitions
filling and assembly lines, storage areas, and a demilitarization area.
The JOAAP is located within the northern part of the extensive Central Lowlands physiographic
province, which is characterized by relatively flat topography and low relief. The most prominent
topographic feature at JOAAP is an approximately 50-foot-high escarpment that trends generally north-
south through the installation.
JOAAP lies within the fork of the confluence of the Des Plaines and Kankakee Rivers. Most of the LAP
area drains to the Kankakee River. The Grant Creek and the Prairie Creek drainage basins cover
approximately 70 percent of the installation, and the Jackson Creek drainage basin covers the remainder
of the JOAAP. Jackson and Grant creeks are tributaries of the Des Plaines River, whereas Prairie Creek
eventually discharges to the Kankakee River. Man-made ditches facilitate drainage to these creeks from
the sites.
The hydrogeology of the area is subdivided into four aquifer systems and major confining beds. As
depicted in Figure 2, from the uppermost downward, the aquifer systems arc (1) the glacial drift
(Pleistocene glacial deposits), (2) shallow bedrock (Silurian Dolomites), (3) (\imbrian-Ordovician
(sandstones and dolomites), and (4) Mount Simon (Cambrian sandstone).
Groundwater flow at the MFG Area is generally westward but is locally influenced by streams that are
incised into the glacial drift. Groundwater flow occurs in several aquifers beneath the site. The shallow
overburden aquifer is composed of glacial drift and is underlain by the Silurian Dolomite water-bearing
zone. Deeper bedrock aquifers are isolated from the shallow aquifer by low-permeability shale beds in
the Maquoketa Group.
Groundwater at the JOAAP has been determined to be both Class I and Class II. IliPA has classified the
glacial drift aquifer as Class II because its low yield does not supply usable quantities of groundwater.
The Silurian Dolomite is considered a Class I groundwater resource and it has a limited use in the vicinity
of JOAAP as a water source despite elevated levels of sulfate and iron.
In accordance with the Illinois Land Conservation Act of 1995, P.L. 104-106, Div. B, Title 2901-2932,
Feb 10, 1996, the Army will transfer JOAAP land to various Federal, local and state jurisdictions.
Approximately 19,100 acres will be transferred to the U.S. Department of Agriculture (USDA) for
establishing the Midewin National Tallgrass Prairie; 982 acres will be transferred to the Department of
Veterans Affairs to establish a Veterans Cemetery; and 455 acres will be transferred to Will County,
JOAAP Record of Decision-Soil & Groundwater Oils - October, 1998 pg. 1-1
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Illinois to establish the WCLF. Approximately 3,000 acres will be transferred to the State of Illinois to
establish two industrial parks. Figure 1 shows the proposed future land use plan for JOAAP.
Once potential hazards to human health and the environment are addressed and the property is found
smtable for transfer under Public Law 104-106 and CERCLA, the Army will prepare documentation for
transfer. To date, the Army has transferred 15,080 acres to the USDA and 982 acres to the Department of
Veterans Affairs.
[END OF SECTION]
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998 pg. 1-2
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2 SITE HTSTORY AND ENFORCEMENT ACTIVITIES
JOAAP was constructed during World War ll for the purpose of manufacturing, loading, assembling,
packing, and shipping bombs, projectiles, fuses, and supplementary charges. The production output at
JOAAP varied with the demand for munitions. Although the plant was used extensively during World
War II, in 1945 all production of explosives was halted, the sulfuric acid and ammonium nitrate plants
were leased out, and the remaining production facilities were put in layaway status. The installation was
reactivated during the Korean War, and again during the Vietnam War. Production at the plant gradually
decreased until it was stopped completely in 1977. Since then, various defense contractors under facility-
use contracts have utilized some areas of the installation. One such contract is still active and is expected
to expire in 1999.
Uniroyal Chemical Company, Inc operated the JOAAP as a government-owned, contract-operated
(GOCO) facility until 1993. In April 1993, the property was declared as excess by the Army and is now
being maintained by a small staff. The JOAAP is presently under liquidation status. The facility is not
capable of explosives production and is undergoing transfer of use to other agencies and organizations in
accordance with Public Law 104-106.
In 1978, the U.S. Army Environmental Center (USAEC, formerly the U.S. Army Toxic and Hazardous
Materials Agency or USATHAMA) conducted an Installation Assessment of JOAAP (USATHAMA,
1978), which consisted of records search and interviews with employees. This document reported that
environmental impacts might be present at former industrial areas and locations where waste disposal
activities occurred.
During 1981 and 1982, an Installation Restoration Survey was conducted (Donohue and Associates,
1982). This study included sampling soils, groundwater, surface water, and sediment, and identified the
presence of contamination at nine study areas at the MFG Area and nine study areas at the LAP Area.
Subsequently, a Phase II study was conducted in 1983 (Donohue and Associates, 1983) to gather
additional data on the previously sampled sites at the MFG and LAP Areas, and to evaluate the potential
for off-site impacts. This investigation also included an assessment of several parcels of land near the
edge of the MFG Area that JOAAP wanted to excess (sell). No off-site contamination was identified.
From 1983 through 1985, a remedial action was conducted by Uniroyal (JOAAP's operating contractor)
at the Red Water lagoon located at site M7. The purpose of this remedial action was to remove
contaminated surface water and sediment from the lagoon. Following the removal of contaminated
materials, a clay cap was installed over the lagoon. Pre- and post-remediation sampling documented the
conditions before and after the remediation (Donohue and Associates, 1983, 1985).
Between 1983 and 1985, the U.S. Army Environmental Hygiene Agency (AEHA; now U.S. Army Center
for Health Promotion and Preventive Medicine, CHPPM) performed groundwater sampling of selected
existing monitoring wells. The sampling and monitoring were performed as part of JOAAP's RCRA
groundwater monitoring program around a closed sanitary landfill located at site M13, and the Red Water
lagoon at site M7.
In November 1984, because of the presence of contamination, the MFG Area of JOAAP was proposed for
listing on the NPL by the USEPA based on the Hazard Ranking System (HRS) score 32.08. The LAP
Area was proposed for listing in April 1985 based on the HRS score 35.23. Final listing on the NPL took
place on July 21, 1987 for the MFG Area, and March 31, 1989 for the LAP Area.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 2-1
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During 1985 and 1986, additional groundwater and surface water samples were collected from previously
sampled locations at the MFG and LAP Areas. This data was presented in an assessment report in which
the feasibility and need for remediation of the study areas was discussed (Dames & Moore, 1986).
In 1989, the Army, the USEPA and the IEPA entered into a Federal Facilities Agreement (FFA) under
CERCLA Section 120 and RCRA Sections 6001, 3008(h), 3004(u), and 3004(v) (USEPA, 1989). The
purpose of this FFA was to ensure that environmental impacts at the site would be investigated and that
remedial actions would be taken to protect public health, welfare, and the environment.
Also during 1989, the U.S. Army Corps of Engineers (USAGE) made an investigation of underground
storage tanks (USTs) throughout the JOAAP (USAGE, 1989). One hundred seven USTs were identified
inventoried, and evaluated for possible leakage in accordance with USEPA regulations for existing USTs'
Most of the USTs were emptied and removed as of 1993.
From 1988 through 1993, Phase 1 and Phase 2 Remedial Investigations (RIs) were conducted at the MFG
Area (Dames & Moore, 1991, 1993). The RIs were performed to identify the type concentration and
extent of contamination throughout the MFG Area at JOAAP. A total of 18 study areas were identified
for investigation, including nine areas originally investigated during previous studies These reports were
amended by the Oleum Plant RI report (Dames & Moore, 1996) that was added as a potentially
contaminated area following the completion of the RI reports.
From 1991 through 1994, Phase 1 and Phase 2 RIs were conducted at the LAP Area for the same
purposes as the MFG Area investigations (Dames & Moore, 1993; 1994). A total of 35 study areas were
investigated, including nine sites investigated during the Installation Restoration Surveys at the LAP
Area.
The RI reports were supplemented by baseline risk assessments conducted to quantify the potential
human health risks posed by contamination identified at the study sites present at the MFG and LAP
Areas (Dames & Moore, 1994; 1995). The assessments included an environmental fate and transport
assessment, a toxicity assessment, an exposure assessment, and a risk characterization.
From 1993 through 1996, the U.S. Army CHPPM conducted an ecological risk assessment to evaluate the
potential for site contamination to be impacting ecological receptors. Findings indicated limited impacts
to terrestrial mammals, aquatic receptors, and avian species (birds). The results of these studies were
presented in a Phase 1 Ecological Risk Assessment Report (USACHPPM, 1994) and a Phase 2 Aquatic
Ecological Risk Assessment Report (USACHPPM, 1996). Potential risks posed to humans from
consuming deer tissue from JOAAP were also investigated and determined to be negligible
(USACHPPM, 1994)
Following the risk assessments, Preliminary Remediation Goals (PRGs) were established to identify the
specific cleanup to remediate the sites (OHM, 1996). The cleanup levels were developed to be protective
of human health and the environment.
In 1996 and 1997, the USAGE conducted four removal actions to prevent the migration of contaminants
from source areas. Wastes present in the oil pits located at study area L2 were excavated and disposed to
prevent the contaminants present in these wastes from migrating into the groundwater. During the same
time period, the Omaha District, Corps of Engineers, conducted a Removal Action along Prairie Creek at
site L3. This action involved stabilizing the stream bank to prevent the erosion of the bank that contained
buned debris and wastes. Also in 1996, the Louisville District Corps of Engineers conducted the removal ,
of the PCB switch boxes from the MFG Area. Soils around the switch boxes were sampled and
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 2-2
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subsequently removed if contamination was above RGs or if staining was noticeable. In 1997, an interim
Removal Action was performed at the southern ash pile (Ml). This project involved consolidating wastes
that had migrated from the pile and covering the pile with a geosynthetic liner to prevent leaching of
wastes from the pile. Also in 1997, the Louisville District, Corps of Engineers, conducted a Removal
Action at site L6. This action involved the excavation and disposal of organics- and I'CB-contaminated
soil to protect human health and the environment. This action also was intended to facilitate the transfer
of the land from the Army to Will County in accordance with Public Law 104-106 for establishing a
landfill.
Public Law 104-106 of the Fiscal Year 1996 Department of Defense Authorization Act legislated specific
terms relating to the conveyance of JOAAP to various entities. This law is the governing document for
the future land use at JOAAP. The majority of JOAAP is to be transferred to the U.S. Department of
Agriculture (USDA), with the U.S. Department of Veterans Affairs, Will County, and the State of Illinois
receiving the remainder of the property. Figure 1 identifies the planned future land use of JOAAP under
this law.
Since the volume of explosives-contaminated soil may have a direct bearing on the selected remediation
method, field screening soil sampling programs were conducted in 1995 to provide data to more
accurately estimate the volume of explosives-contaminated soils on the MFG and I .AP Areas. These
programs were supplemented by sampling to help characterize the types of wastes present, and the results
of the sampling programs were used in the Feasibility Studies (FSs) for the MFG and LAP Areas. The
purpose of the FSs was to identify and evaluate alternative remedies for mitigating the risks posed by
contamination at JOAAP. Separate FSs were prepared for the Groundwater and Soil Operable Units for
both the LAP (Dames & Moore, 1997) and MFG (OHM, 1997) Areas. Based on the information
gathered and presented in the FSs, the Army recommended, with USEPA and IKPA concurrence, the
preferred remedies for the contaminated soil and groundwater at JOAAP. The rationale behind the
selection of the remedies was released to the general public in the Proposed Plan for the Soil Operable
Unit and the Proposed Plan for the Groundwater Operable Unit (U.S. Army, 1997 a, h) and presented at a
public meeting on January 8, 1998.
Alliant Techsystems, Inc., under a facility-use contract to the U.S. Army currently uses a portion of LAP
area. Any contamination resulting from this activity will be remediated as required by the contract,
applicable laws and regulations.
Liquidation/demolition activities have been underway in the Manufacturing (MFG) Area. This action has
removed many property items and many buildings, and has potentially changed the extent of
contamination previously determined in the RI and FS reports. The remedies selected for the soil and
groundwater OUs will take into account any changes in conditions that are a result of the past and
ongoing liquidation/demolition activities.
[END OF SECTION]
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 2-3
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3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Army has made major documents concerning the CERCLA activities at JO A A I' available to the
public at three information repositories in the vicinity of the installation. These three repositories are
located at the JOAAP office, the Wilmington Public Library in Wilmington, and the Joliet Public Library
in Joliet.
The Proposed Plan for the Soil Operable Unit and the Proposed Plan for the Groundwater Operable Unit
were released to the public on December 12, 1997. The notice of availability of these documents was
published in the Joliet Herald News and the Wilmington Free Press newspapers on December 14, 1997.
A 30-day public comment period on both Proposed Plans extended from .December 12, 1997, through
January 15, 1998. In addition, a public meeting was held during the public comment period on Thursday,
January 8, 1998. At that meeting, representatives from the Army, USEPA, and 1EPA presented a
summary of the project and answered questions relating to the Proposed Plans. Written and oral
comments received at this meeting, as well as written comments received during the public comment
period, which are relevant to the Proposed Plans, were responded to in the Responsiveness Summary
section of this document.
The JOAAP Restoration Advisory Board (RAB) was established in December 1995 to facilitate
communication and coordination between community and governmental agencies related to the
restoration of the JOAAP. The RAB is intended to bring together members who reflect the diverse
interests within the local community. The RAB has held its regular monthly meetings at the Wilmington
City Council Chambers since January 1996. In 1996 and 1997, the JOAAP RAH held open forums,
discussed upcoming studies, took field trips to visit other RABs, provided input on the Proposed Plans
and ROD, and participated in deciding removal action projects conducted in 1997 and 1998. In July
1997, the RAB hosted a press tour of the JOAAP facility in order to promote information exchange
among the community and the installation. The event, sponsored by the JOAAP, was open to members of
the local and regional media and the public. Prior to the formation of the RAB, Technical Review
Committee meetings were held regularly to inform the public about the ongoing environmental studies in
accordance with JOAAP's Public Involvement Response Plan (Dames & Moore, 1990).
[END OF SECTION]
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 3-1
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jir
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4 SCOPE AND ROLE OF OPERABLE UNITS OR RESPONSE
ACTIONS
Past releases and disposal practices at JOAAP have resulted in soil and groundwater contamination with
explosives compounds, metals, organics, PCBs, sulfur, and inorganic hazardous and non-hazardous
debris. The goal of the overall cleanup activities at JOAAP is to eliminate or reduce the levels of
contaminants to concentrations that are protective to human health and the environment, such that no
adverse health effects or adverse ecological impacts will result from future uses of the JOAAP property.
The contaminated media identified at JOAAP were divided into two operable units (OUs) to aid in the
development, evaluation, and selection of remedies. The soil operable unit (SOU) consists of sites where
contaminated soils, sediments, and debris were identified. The groundwater operable unit (GOU) consists
of sites where contaminated groundwater plumes were identified. Based on the Risk Assessment studies,
surface waters studied at JOAAP have been determined to pose no risk to human health and the
environment and, therefore, are not addressed further. This ROD addresses both soil and groundwater
OUs.
4.1 SoilOU
Fifty-three (53) sites plus three (3) subareas were investigated within the SOU. Twenty-six sites were
found to require remedial action and were grouped into seven SRUs according to the type of
contamination discovered. These seven SRUs are summarized in Table 4-1 and described in more detail
in Section 5.1.
Figure 3 depicts the sites within each SRU. In some instances, different types of-contamination were
discovered at different locations within the site; therefore, the same study site may appear in more than
one SRU. Sites within the SRUs to be remediated are distinguished by whether they are on land
designated for the State of Illinois for industrial parks or on land currently managed by or intended for
the USDA for the Midewin National Tallgrass Prairie (USDA lands)(see Figures t and 3). This
distinction is needed to determine whether the selected remedial actions are considered interim or final
within this ROD (see Table 4.1). Twenty-five (25) sites and one subarea were found to require further
cleanup action. Twenty-eight (28) sites and two subareas of contaminated sites were found to require no
further cleanup action for soil under CERCLA. Refer to Sections 5.1.8 and 6.6 for more detailed
discussion of sites requiring no further cleanup actions.
4.2 Groundwater OU
Within the GOU, contaminated plumes were grouped into three GRUs according to the type of
contamination they contained and their geographic location. Figure 4 depicts these plumes and their
corresponding GRUs. The three GRUs are summarized in Table 4-1 and described in more detail in
Section 5.2. The groundwater under twelve (12) sites was found to require further cleanup action. Forty-
one (41) sites and three subareas of contaminated sites were found to require no further cleanup action for
groundwater under CERCLA. Refer to Sections 5.2.4 and 6.6for more detailed discussion of sites
requiring no further cleanup action.
4.3 Final and Interim Actions
This ROD presents final response actions for all groundwater, all industrial lands soils, and SRUs 4, 6,
and 7, as applicable, to USDA lands. The purpose of these final response actions is to protect human
health and the environment by cleaning up and preventing exposure to contaminants in soil and
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 4-1
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groundwater and to eliminate the potential for contaminated soils to be a continuing source of
groundwater contamination.
This ROD presents interim actions for SRUs 1, 2, 3, and 5 as applicable to USDA lands. The goal of the
interim actions is to remove sources of contamination to groundwater and/or to prevent the further
migration of contamination. Subsequent actions are planned to fully address the threats posed by the
conditions at SRUs 1, 2, 3, and 5 for USDA lands. The interim actions will be consistent with any
planned future remedial actions for USDA lands. The Army will present recommended final remedial
alternatives to the public in a proposed plan. The public will be provided an opportunity to comment on
the preferred alternative(s) prior to remedy selection. A final Record of Decision will be prepared in
accordance with the NCP.
Table 4-1; Soil and Groundwater Remedial Units
SRIIs
/GRUs
Description
Primary Contaminants of
Concern
Final Remedial
Action Sites
Interim Remedial
Action Sites
Soils Operable Unit
SRU1
SRU2
SRU3
SRU4
SRUS
SRU6
SRU7
Explosives
Metals
Explosives
and Metals
PCBs
Organics
Landfills
Sulfur
DNT, NT, TNB, TNT, HMX,
RDX, Tetryl
Arsenic, Beryllium, Lead,
Cadmium
DNT, TNT, RDX, Arsenic,
Beryllium, Lead
PCB1254.PCB 1260
Total Petroleum
Hydrocarbons
Hazardous and Non-
hazardous Wastes
Sulfur
L16,M5,M6,M7
Lll
M5,M6
L1,L5, L7, L8, L9,
L10, L17
L3,L4, M1.M9,
M11,M13
M8,M12
1J.L7, L8, L9, L10,
L14,M2,M3
1-2, L3, L5, L23A,
M3, M4, M12
1.2, L3
LI.L5
Groundwater Operable Unit
GRU1
GRU2
GRU3
Explosives
Explosives
and Other
Contaminants
VOC
DNT, TNB, TNT, RDX, NT
DNT, TNB, TNT, HMX,
RDX, NB, DNB, PCE, Iron,
Antimony, Cadmium
Benzene, Toluene
L1,L2, L3.L14
M1,M5,M6,M7,
M8.M13
M3, M10 (Western
and Central Tank
Farms)
Note: Sites beginning with letter "L" are in the LAP Area; with the letter "M" arc in the Manufacturing
Area
[END OF SECTION]
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
Pg. 4-2
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5 SITE CHARACTERISTICS
This section provides an overview of the site characterization of the MFG and LAP Areas, including the
nature and extent of soil and groundwater contamination. The information presented in this section has
been summarized from the RI and FS reports (Dames & Moore, 1997, OHM, 1997). Site numbers
represent study sites; Group numbers represent building clusters.
During the RIs, numerous samples were taken to determine the nature and extent of contamination of the
soils, sediments, surface water, and groundwater. Surface and subsurface soil samples were taken using
hand augers, drilling rigs and backhoes. The horizontal and vertical extent of contamination was analyzed
at each site. Surface water and sediment samples were taken to determine whether or not contaminants
had moved into, and remained in the sumps, drainage ditches, creeks, and lakes. Existing on-site wells
and shallow and deeper wells in the area of JOAAP were sampled. New wells were drilled, established,
and sampled. Groundwater probes were driven and sampled. Potential discharge points of groundwater
into surface waters were sampled. The findings of these investigations provided the basis for the extent of
soil contamination as shown in Figure 3 and the contaminant plumes shown in Figure 4. Detailed
descriptions of the sampling program and the discovered plumes may be found in the RI/FS reports. The
nature and extent of contamination found in each SRU and GRU is described below.
5.1 Soil OTJ
5.7.7 SRU1. Explosives in Sail
SRU1, Explosives in Soil, contains the majority of the contaminated soils at JOAAP and poses the
principal threat to human health and the environment if not remediated. Most of this contamination is
found at sites M5 and M6 where the explosives TNT, DNT, and Tetryl were manufactured. The
contamination is generally confined to the surface soils in the immediate vicinity of the production
buildings and drainage ditches that received contaminated wastewater during production. A total of 12
sites are grouped under this SRU, as shown in Table 5-1. Five of these sites are within the MFG Area and
seven are within the LAP Area, as shown in Figure 3. It should be noted that only certain subareas under
each site are included in this SRU and not the entire site. Table 5-1 lists the subareas and the estimated
volume of soil/sediment that needs to be remediated. Table 5-2 lists exceedances of Remedial Goals
(RGs) for sites included in SRU1.
5.1.1.1 Site LI (Group 61)
Site LI was constructed in 1941 as part of the initial operations of the installation to support World War II
efforts. This 80-acre site is centrally located in the northern portion of the LAP Area. Site LI was the
location of demilitarization and reclamation of various munitions. It was originally used for crystallizing
ammonium nitrates, but then extensively modified to function as a shell renovation and 1,3,5-
trinitrobenzene (TNB) recovery plant until 1945. In April 1946, the facility was reactivated to reclaim
TNT. Washout operations involving the larger munitions were performed outside Building 61-35, which
is located southeast of Building 61-4. The solids that settled in the sump were sent to Site L2 (Explosive
Burning Grounds), while the overflow from the sump (pink water) was discharged to an adjacent 4.3-acre
ridge-and-furrow system (or evaporating bed).
Historical aerial photos revealed that by 1952 two rectangular pits or lagoons were constructed southeast
of the ridge-and-furrow system on either side of drainage ditch that flows south from the ridge-and-
furrow system and empties into Prairie Creek.
JOAAP Record of Decision -Soil & Groundwater OUs - October, 1998 pg. 5-1
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Explosives contamination appears to be limited to the ridge-and-furrow system, the western lagoon south
of the evaporation beds, and south of the washout building and around the sump building. It has been
estimated that 85 percent of the 4.3-acre area is contaminated with explosives above RGs to a foot depth
(5,925 CY). The area requiring remedial action at the washout building and sump is limited to the stained
area and includes an estimated volume of 40 CY of contaminated surface soil, assuming the depth of
contamination above RGs extends to 1 foot. Subsurface soils were determined to be contaminated an
additional 2 feet in depth to the west side of the sump. Other contaminated materials include: subsurface
soil beside the sump building (45 CY), sump sediment (50 CY) and pipelines (5 CY). The total volume
of explosives-contaminated soil from Site LI areas requiring remedial action is approximately 6,065 CY.
The explosive 2,4,6-TNT is considered to be a contaminant in the sump surface water. The presence of
the explosive 2,4,6-TNT in the sediment from the ditch indicates that runoff from the ridge-and-furrow
system may have periodically transported contaminants to Prairie Creek.
No RCRA hazardous wastes were identified at Site LI.
Table 5-1; Sites and Siihareas of SRU1 (Explosives in Saill
Sites
LI
L7
L8
L9
L10
L14
L16
M2
M3
M5
M6
Ml
Total
Subareas
Ridge and furrow system
Near Building 61-4 and Building 61-35 sump
Around and beneath buildings and sumps
Around and beneath buildings and sumps
Around and beneath buildings and sumps
Around and beneath buildings and sumps
Sediment in drainage ditch south of Building 3A-10
Soil near sump at Building 4-5
Soil at sump discharge near Building 6-32
The northern portion of the explosive burning ground and the
wetland separating M2 and Mil
Between primary burning pads and a dumping area/pad
Around and beneath buildings and ditches throughout the site
Around and beneath buildings and ditches throughout the site
Soil in the TNT Ditch and Red Water Area
Estimated
Volumes (CY)
5,925
140
1,850
400
1,500
915
745
420
85
1,600
400
12,000
121,000
4,500
151,480
5.7.7.2 Site L 7 (Group 1)
Site L7 is located in the southern portion of the LAP area. The basic processes and procedures involved
in LAP operations are similar for all ammunition items. Explosives were melted and loaded into a
projectile; process water containing explosives residue was discharged to sumps. The loaded projectiles
were then transferred to another building for final assembly. Solids collected in the sump were reportedly
sent to the Explosive Burning Grounds (Site L2) for disposal. Liquids from the sump were discharged to
a storm sewer, which ultimately discharged to Site L12 (Doyle Lake) from Sites L7, L8, and L10, or to
Prairie Creek from Site L9. According to JOAAP personnel, carbon treatment units were installed in each
melt-load building around 1976. Spent carbon units were disposed of at the Explosive Burning Grounds.
Explosives contaminants in soil at Site L7 include 2,4,6-TNT, and RDX. Levels of explosives, up to 1.5
percent, were identified in soil from red-stained areas adjacent to buildings throughout the site. The total
volume of affected soil for Site L7 is estimated to be approximately 1,850 CY.
JOAAP Record of Decision-Soil & Groundwater OVs - October, 1998
pg. 5-2
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No RCRA hazardous wastes were identified at Site L7.
5.7.1.3 Site L8 (Group 2)
Site L8 is centrally located in the LAP Area, cast of the intersection of Chicago and Central Roads. LAP
operations performed at the site included: melting and loading of Composition B into projectiles,
subsequent cleaning and washdown operations that produced pink-water, and discharge of this waste
water to external sumps and surface areas.
Explosives contaminants in soil at Site L8 include 2,4,6-TNT and 2,4-DNT. High levels of explosives, up
to 1.6 percent, were identified in soil from red-stained areas adjacent to buildings throughout the site. In
addition, high levels of explosives were detected beneath one washout building (2-40B). Detectable
concentrations of explosives occur in soils to a depth of 5 feet. The total volume of affected soil,
including areas beneath building foundations, is estimated to be approximately 400 CY. The volume of
raw TNT is estimated to be 1 CY. Additionally, a total of 15 CY of structural concrete in the sump areas
is estimated for disposal.
The only RCRA hazardous waste identified at Site L8 is raw TNT which is hazardous based on its
reactivity (waste code D003).
5.7. 7. 4 Site L9 (Group 3)
Site L9 is located in the central part of the LAP Area, 1 mile east of the intersection of Chicago and
Central Roads. Operations were similar to those described for Sites L7 and L8.
Explosives contaminants of concern for soil at Site L9 include 1,3,5-TNB and 2,4,6-TNT. High levels of
explosives, up to 4 percent, have been identified in soil from red-stained areas adjacent to buildings
throughout the site. High levels of RDX contamination occur in a few locations beyond stained areas and
are not as apparent as surrounding TNT contamination. The total volume of affected soil, including areas
beneath building foundations, is estimated to be approximately 1,500 CY. The volume of raw TNT is
estimated to be 1 CY. Additionally, a total of 15 CY of structural concrete in the sumps area is estimated
for disposal.
The only RCRA hazardous waste identified at Site L9 is raw TNT which is hazardous based on its
reactivity (waste code D003).
5.7.7.5 Site LI 0 (Group 3A)
Site L10 is located in the central part of the LAP Area, between Sites L7 and l.K. LAP operations
performed at Site L10 were similar to those described for Site L7.
Explosive contaminants of concern for soil at Site L10 are 2,4,6-TNT, 2,4-DNT, HMX, and RDX. High
levels of explosives, up to 13.8 percent, have been identified in surface soil from visually stained areas
adjacent to buildings and sumps throughout the site. High concentrations of RDX occur in some
locations where staining is absent and vegetation is present. Explosives were detected in heavily
contaminated surface areas, beneath the foundation of one sump building, 3A-53, and next to the manhole
near Building 3A-12. The total volume of affected soil at Site L10 is estimated to be 915 CY. Sediment
contamination is assumed to be near the southern end of the Site L10 where the small drainage ditch
flows into a tributary to Jordan Creek. The total volume of affected sediment at Site L10 is estimated to
be 745 CY. The volume of raw TNT is estimated to be 1 CY. Additionally, a total of 58 CY of structural
concrete in the sumps area is estimated for disposal.
JOAAPRecord of Decision -Soil & Groundwater OUs - October, 1998 pg. 5-3
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The only RCRA hazardous waste identified at Site LIO is raw TNT which is hazardous based on its
reactivity (waste code D003).
5.1.1.6 Site L14 (Group 4)
Site L14 is a 33-acre site located in the southwestern corner of the LAP Area, near Sites L15 through LI 9.
It was initially constructed to produce various types of fuses. Mercury fulminate, reportedly stored at Site
L14, was loaded into the fuses in the assembly line building (Building 4-14). After 1945, Building 4-14
was used for repackaging smokeless powder. According to JOAAP personnel, a sump north of Building
4-5 periodically overflowed resulting in soil contamination in this area.
Explosives contaminants of concern include 2,4,6-TNT, and RDX. The highest concentrations of
explosives (total concentrations of approximately 55,000 u,g/g) were detected in surface soil near the large
sump north of Building 4-5. Explosive concentrations decreased with depth, but were detectable in the
deepest samples collected (at 5 feet). Total explosives concentrations in soil samples from all other areas
at Site L14 were below Remediation Goals. The total volume of affected soil and sediment at Site L14 is
estimated to be 420 CY. Additionally, a total of 20 CY of structural concrete in the sump area is
estimated for disposal.
No RCRA hazardous wastes were identified at Site L14.
5.7.7.7 Site L16 (Group 6)
Site LI 6, a site of approximately 90 acres, is located in the southwestern corner of the LAP Area. Site
LI6 was initially constructed for the production of boosters for munitions. These sumps received
wastewater during production activities at Buildings 6-2, 6-4, and 6-32, which then discharged into
drainage ditches.
Explosives contaminants of concern include HMX, and RDX. High levels of RDX and HMX occur in
soil primarily in a drainage ditch north of Building 6-32; at the outfall of the sump. Other areas of
explosive contamination occur around the sump at Buildings 6-32, at entrances/exits to Building 6-2, and
along the tile flume extending west from the sump at Building 6-4. The total volume of affected soil and
sediment at Site LI 6 is estimated to be 85 CY. Additionally, a total of 5 CY of structural concrete in the
sumps area is estimated for disposal.
No RCRA hazardous wastes were identified at Site LI6.
5.1.1.8 Site M2 (Explosive Burning Ground)
Site M2 covers approximately 25 acres in the south central part of the MFG Area. Open burning of
explosive wastes was performed on a 4-acre burning pad until 1965. The burning pad consists of gravel
placed over the topsoil. Multiple areas of explosives-stained soil, absent of vegetation, are visible in the
northern portion of this site. Berms surround much of the burning pad area. A wetland area is present to
the north of the burning pad area and along the eastern boundary of M2.
More than 400 tons of suspected "red water ash" were encapsulated in an impermeable membrane and
buried at a shallow depth in the northern section of the explosives burning pad. The color, odor, texture,
and apparent solubility of the buried waste are indicative of potentially untreated explosives sludge.
Explosives contaminants of concern for soil at Site M2 include 1,3,5-TNB, 2,4,6-TNT, 2,4-DNT, and 2,6-
DNT. The volume of explosives-stained soil in M2 exceeding the RGs is estimated to be 830 CY. The
area of stressed vegetation in M2, without observable explosive, residue is estimated to represent an,
additional 500 CY of soil. Additionally, there is an estimated 270 CY of material in the "ash pillow."
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg. 5-4
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Soils at M2 may include the following RCRA characteristic waste: soil contaminated with TCLP
extractable 2,4-DNT (RCRA waste code D030).
5.1.1.9 Site M3 (Flashing Grounds)
Site M3 covers an area of approximately 66 acres located in the west central portion of the MFG Area
adjacent to Grant Creek. From 1942 until 1988, the principal activity in M3 was the flash burning of
equipment and demolition materials to remove explosives residues. The flash burning has been
performed at two primary locations within a 6-acre fenced area. An area of explosives-stained soil, where
trucks were washed after dumping explosives materials, is located between the primary burning pads and
a dumping area/pad.
Four additional burning pads, located to the south of the fenced area of M3, were identified in aerial
photographs. Each of these secondary burning pads in the central portion of M3 is estimated to be 2
acres.. Numerous craters, located adjacent to the burning pads, may be indicative of TNT block testing.
Later photographs indicate that the area containing these southernmost burning pads had been covered
with a layer of soil by 1953 but portions of the pads are still visible.
Explosives contaminants of concern for soil at Site M3 include 1,3,5-TNB, 2,4,6-TNT, and 2,4-DNT.
Based on the data collected in M2 and the non-intrusive nature of the flashing operation, the vertical
extent of explosives contamination that exceeds the RGs is assumed to be limited to one foot. The total
volume of explosives and TPH impacted soil is estimated to be 400 CY.
Soils at M3 may include the following RCRA characteristic wastes: soils contaminated with TCLP
extractable 2,4-DNT (RCRA waste code D030) and soils contaminated with TCLP extractable lead
(RCRA waste code D008).
5.1.1.10 Site MS (Tetryl Production Area)
M5 consists of approximately 244 acres located in the central portion of the MFG Area. The principal
activity in M5 was the production of tetryl. Tetryl was manufactured during World War II, the Korean
War, and again during the Vietnam War until 1973. The Tetryl Ditch (oriented from north to south)
bisects M5 with Production Lines 1 through 6 located west of the ditch and Productions Lines 7 through
12 constructed to the east of the ditch. Lines 1-6 were burned and removed. The Nitrating ("East-West")
Ditch lies immediately to the north of the nitrating buildings in the tetryl production lines.
Each of the 12 tetryl production lines consisted of four separate "houses," oriented north to south, for
nitrating, refining, wet storage ("lag-house") and drying. Wastewater from the tetryl manufacturing
processes in the nitrating and refining houses flowed into settling boxes located on the west side of the
buildings. Wastewater from the nitrating building was discharged into open drainage ditches that flowed
to the north into the Nitrating Ditch. The Nitrating Ditch drains into the Tetryl Ditch that ultimately
drains into Grant Creek to the south of the Tetryl Production Area. Tetryl is visible within the settling
boxes at the refining houses.
Wastewater from acid spills and daily floor cleaning was discharged from floor drains directly to the
settling boxes at the nitrating and refining houses. Additionally, dust traps were constructed outside of
the eastern doors of these buildings to collect tetryl residues.
The primary wastewater from the tetryl drying process was discharged to a settling box constructed
immediately to the west of each drying house. Tetryl is visible within these settling boxes for Production
Lines 7 through 12. A concrete weir was constructed in the Nitrating Ditch that formed a settling basin to
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 5-5
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the south of the acid recovery building for Tetryl Production Lines 7 through 12. Crystalline explosives
compounds are visible in the basin sediment where the wastewater from the APR building and the
nitrating buildings on Production Lines 10,11, and 12 collected.
Explosives contaminants of concern for soil at Site M5 include 1,3,5-TNB, 2,4,6-TNT, 2,4-DNT, tetryl,
and 2,6-DNT. Areas with tetryl contamination at levels greater than the RG include the entire 2,800-foot
length of the Nitrating Ditch to a depth of 5 feet. The Nitrating Ditch represents 3,100 CY of explosives-
contaminated soil. Tetryl concentrations above the RGs are also present at each of the 24 settling boxes
and associated culverts constructed in Tetryl Production Lines 7 through 12. These locations represent
approximately 500 CY of contaminated soil. Tetryl residues within the dust traps constructed at the
entrances to each of the nitrating and refining houses represent an additional 200 CY of contaminated
soil. Approximately 100 CY of tetryl-contaminated soil has been identified within a 3,200 square feet
area at the packing and shipping houses to the south of Tetryl Production Lines 7 through 12. Data
indicate that high concentrations of tetryl residues are limited to a depth of 1 foot. A similar volume of
contaminated soil appears to be present at the corresponding locations for the packing and shipping
houses to the south of former Tetryl Production Lines 1 through 6. Approximately 100 CY of tetryl-
contaminated soil has been identified adjacent to bulk storage tanks located to the southwest of the AFR
Building. A similar volume of contaminated soil appears to be present at the AFR Building location to
the north of former Tetryl Production Lines 1 through 6. The volume of tetryl-conlaminated soil at the
former building locations to the west of the Tetryl Ditch is estimated to be 8,000 CY. The total volume of
explosives-contaminated soils within M5 is estimated to be approximately 12,000 CY.
Soils at M5 may include the RCRA characteristic waste of TCLP-extractable lead (RCRA waste code
D008), as well as soils contaminated with explosives at concentrations greater than 10 percent indicating
they may be RCRA characteristic wastes based on their reactivity (RCRA waste code D003).
5.1.1.11 Site M6 (TNT Ditch Complex)
Site M6 covers approximately 271 acres, located in the central part of the MFG Area. During World War
II, the production of TNT and DNT were the major activities in M6. The TNT production lines were
again operated at full capacity for the Korean and Vietnam Wars. During each of the inter-war periods
the plant mission was changed to a research and development (R&D) role in which explosive compounds'
such as nitroxylenes, were produced. TNT production ceased in 1977.
Twelve parallel TNT "batch" production lines were initially constructed in the TNT Dilch Complex from
south to north. The principal buildings in each TNT production line were oriented east to west. The
batch production lines were constructed in pairs; each line began with a "mono-house," then a "bi-house "
followed by a "tri-house" for the nitration of toluene.
The TNT process wastewater from each tri-house and wash house, known as "red-water," was initially
discharged from wooden holding tanks to open clay-lined ditches that drained into the 9,100-foot-long
TNT Ditch." The original wastewater drainage system, specific to the wash houses, was replaced in
1965 by a system of wooden flumes constructed in the TNT Ditch. The wash house red water was then
diverted to the Red Water Area for treatment. The Red Water Area, M7, was constructed at the southern
end of the TNT Ditch Complex.
DNT-contaminated wastewater from the bi-houses and DNT sweating-and-graining buildings was
discharged via wooden settling tanks into open troughs and ditches that flowed directly into the
stormwater sewer system and discharged into the TNT Ditch. Wastewater discharged directly to the TNT
Ditch was not treated in the Red Water Area and flowed directly into Grant Creek.
JOAAP Record of Decision - Soil & Groundwater Oils - October, 1998
pg.
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Occasionally, operational problems developed during the nitrating processes. 'I o avoid potential
explosion hazards, the explosives batch in progress could be flooded in water stored in large wooden
"drowning" tubs. During the period from March 16, 1972 through September 14, 1974, there were more
than 30 recorded instances in which batches of explosives were drowned. The batch drownings primarily
occurred at the tri-houses during the final nitration step. Approximately 4,800 pounds of DNT "bi-oil,"
5,600 pounds of Oleum, and 2,800 pounds of nitric acid were released to the TNT Ditch with each event.
Similar drowning tubs were located at each bi-house.
Explosives contaminants of concern for soil at Site M6 include 1,3,5-TNB, 2,4,6-TNT, 2,4-DNT, 2,6-
DNT, 2-NT, and RDX. The areas of contamination exceeding clean up levels include soils adjacent'to
each of the TNT wash houses, bi-houses, tri-houses, between the wash houses and the TNT Ditch, at the
APR Buildings, and around the perimeter of the laboratory building. The total volume of soils and
sediment in M6 contaminated with explosives is estimated to be 121,000 CY.
Soils at M6 may include the following RCRA" characteristic wastes: soils contaminated with TCLP
extractable 2,4-DNT (RCRA waste code D030) and soils contaminated with TCLP extractable lead
(RCRA waste code D008). The soils at M6 may also contain RCRA-listed wastes i f contaminated with
redwater (RCRA waste code K047) and DNT production waste waters (RCRA waste code K111).
Table 5-2 Exceedances of Remediation Goals (ROs)
as a Function of Land TJse for Soil Found in SRIT?
Site
Explosives
1,3,5-TNB
2,4,6-TNT
2,4-DNT
2,6-DNT
HMX
RDX
Tetryl
MIDEWIN TALLGRASS PRAIRIE AREAS (USDA)
RG
180
290
13
13
10,000
78
7,400
Contaminated
Soil Volume
(CY) ,Total 13.895 "
LI L7 L8 L9 L10 L14
Maximum Concentration Exceeding Recreational I
3,900
22,000 1,500 16,000 180,000 44,000 13,000
16.7 110
17,000
85 22,900 77,000 42,000
6,065 1,850 400 1,500 1,660 420
M2
W-s (Mg/g)
2,610
72,300
522
139
1 ,600
M3
300
4,100
17.5
400
INDUSTRIAL PARK AREAS
Site
Explosives
1,3,5-TNB
2,4,6-TNT
2,4-DNT
2,6-DNT
2-NT
HMX
RDX
Tetryl
RG (ug/g)
100
190
8.4
8.4
10,000
10,000
52
4,100
Contaminated Soil Volume
(CY) ,Total
137.585 ("
L16
MS
Maximum Concentration
19,000
65,000
85
RGs (ug
120
16,000
25.5
20
224,000
12,000
M6
Exceeding
5/g)
600
482,000
86,709
2,540
18,500
1,400
121,000
M7
Industrial
1,100
190,000
1,700
90
76
4,500
Notes: (1) Total Contaminated Soil Volume for USDA and Industrial Park 151.480 CY.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
pg. 5-7
-------
5.1.1.12 Site M7 (Red Water Area)
Site M7 covers approximately 49 acres located in the central part of the MFC Area immediately to the
south of the TNT Ditch Complex. The TNT Ditch forms the eastern boundary of M7. Facilities within
M7 include three separate groups of storage tanks, pumping stations, evaporators, and incinerators.
Beginning in 1965, these facilities were used to treat wastewater (red water) containing explosives
residues and derivatives produced in the TNT manufacturing process. At that time, red water from the
TNT wash houses was diverted from the TNT Ditch into wooden flumes. The red water was collected in
storage tanks to the south of the TNT Ditch Complex. Overflow of untreated red water was stored in the
Red Water Lagoon, located in the northern portion of M7. This 3.3-acre lagoon, with a capacity of 4.1
million gallons, was remediated in 1985.
Explosives contaminants of concern for soil at Site M7 include 1,3,5-TNB, 2,4,6-TNT, 2,4-DNT, RDX,
and 2,6-DNT. The areas of contamination exceeding clean up levels include soils in the drainage areas
with stained soil located in the northwest portion of the Red Water Area. The total volume of explosive-
contaminated soil in M7 is estimated to be 4,500 CY.
Soils at the M7 site may be considered listed wastes if contaminated with red water (KCRA waste code
K047) and DNT production waste waters (RCRA waste code Kill).
5,1,2 SRU2. Metals in Soil
SRU2, Metals in Soil, contains sites where production, testing and waste disposal activities resulted in
metals contamination. Most of the metals found are confined to surface soils, and because they are not
readily leachable, have not caused groundwater contamination.
A total of eight sites are grouped under this SRU. Three of these sites are within the MFG Area and five
are within the LAP Area, as shown in Table 4-1 and Figure 3. It should be noted that only certain
subareas under each site are included in this SRU and not the entire site. Table 5-3 lists these subareas
and the estimated volume of soil/sediment that needs to be remediated. Table 5-4 lists exceedances of
Remedial Goals (RGs) for sites included in SRU2.
Table 5-3; Sites and Subareas of SRU2 (Metals in
Sites
L2
L3
L5
Lll
L23A
M3
M4
M12
Total
Subareas
Soils near popping furnaces
Soils east of demolition pits
Fire Training Area
Open storage area
Soils in target area
Soils in pit
Lead (and other metals) contaminated soil throughout the site
Lead contaminated soil around the former lead azide lagoon
Metal contaminated soil throughout the site
Volumes (CY)
4,440
10
175
1,070
445
3,300
5,600
4,200
3,700
22,940
5.1.2.1 Site L2 (Explosive Burning Grounds)
Site L2 is located in the west-central portion of the LAP Area, adjacent to Prairie Creek and Kemery
Lake. The operational area covers approximately 5 acres and consists of six cast-west pads, each
approximately 650 feet long and 50 feet wide, on which explosives and associated wastes from Sites L7
to L10, L14, and LI, were burned. Three north-south burning pads were also present cast of this area in
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
pg. 5-8
-------
1952 aerial photographs. These pads were subsequently reconfigured into one pad and the southern oil
pits were constructed on the southern portion of these pads. Several parallel, elevated burning pads were
constructed of gravel and fitted with electric igniters operated from a remote location. According to
JOAAP personnel, spent carbon from the carbon units used in the TNT/Composition B melt-load
processes was also incinerated on the burning pads. UXO, including fuzes and other items, have been
identified to be present on the burning pads.
t
Three popping furnaces, where small ammunition was detonated, were located at the southwest corner of
the site. During operations, metal waste from the furnaces was removed and sent to the Salvage Yard
(Site L5). The Explosive Burning Grounds also contained three solvent and oil disposal pits (each less
than 0.25 acre) located adjacent to the burning pads, which (according to JOAAP personnel) were
occasionally used to bum waste oil. These pits were remediated in 1996 as part of a removal action
conducted by the U.S. Army, and UXO were discovered to be buried in an area north of the burning pads.
The UXO were disposed of properly as part of the removal action, although a complete UXO sweep was
not performed and it is possible that additional UXO remain at the site in the vicinity of the removal
action. Drainage features include two ditches, which flow from the northern portion of the burning pads
to Kemery Lake, and a gully at the southwestern corner of the site, which receives runoff from the
popping furnace area and southern portions of the site.
It is estimated that an area approximately 200 feet square surrounding and including the popping furnaces
would require the remedial actions for arsenic, cadmium, and lead. Surface soil contaminated with
arsenic, cadmium, and lead has been estimated to extend to a depth of 1 foot representing a volume of
1,480 CY. Additionally, arsenic contamination in subsurface soils around the popping furnaces is
estimated to occur to a depth of 3 feet representing a volume of 2,960 CY.
Soils in the vicinity of the popping furnaces at Site L2 may be contaminated with RCRA characteristic
hazardous wastes for cadmium (RCRA waste code D006) and lead (RCRA waste code D008).
5.1.2.2 Site L3 (Demolition Area)
Site L3 is located directly southwest of the Explosive Burning Grounds, Site L2. Covering approximately
50 acres, Site L3 is bounded to the west by Prairie Creek, to the south by an unnamed tributary to Prairie
Creek, and to the east by Star Grove Cemetery. The principal operation conducted in this area was the
open burning of combustible refuse and munitions crates. An air curtain destructor, which facilitates
combustion while reducing paniculate emissions, was constructed at the site but never used. In addition,
uncontaminated solid waste and some potentially low-level explosives-contaminated solid waste from
JOAAP operations were burned in this area. A 1-acre fire training area is also located at the site.
The burning area consisted of U- and L-shaped bermed areas and a burning cage, which is a concrete pad
surrounded by a steel mesh cage used to contain the burning debris. During the RI-PH1, geophysical
techniques used to clear UXO from work areas indicated the presence of buried metallic debris in and
around the U- and L-shaped bermed areas. The fire training area consisted of a small depression enclosed
by an earthen berm, which contained burning and fire training areas. The demolition pits (less than 1
acre) were heavily vegetated, which suggests there has been no recent activity in this area.
The volume of soil requiring a remedial action at the fire training pit is assumed to include the top 6
inches of surface soil over the entire fire training area (approximately 75 by 125 feet) and totals an
estimated 175 CY. Soil in the area east of the demolition pits requiring a remedial action is estimated to
include an area 25 SF to a depth of 6 inches of surface soil, totaling 10 CY. A total of 185 CY of soil is
estimated to require a remedial action for lead.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 5-9
-------
No RCRA hazardous wastes are present at Site L3.
5.7.2.3 Site L5 (Salvage Yard)
Site L5 was used for salvage and open storage of miscellaneous materials from the installation. It is
located in the northwestern comer of the LAP Area along Hoff Road. Metal waste from the popping
furnaces at the Explosive Burning Grounds (Site L2) was reportedly sent to Site L5 when JOAAP was in
operation. The area of contamination at the site include a 1,000 SF oil spill area near Building 26-3 and a
500-foot-long shallow ditch excavated in 1974 that is located south of the spill area. This ditch was used
to store barrels of unknown substance(s). Other areas of contamination included several large piles of
railroad ties (approximately 1 acre), and a large junk pile (less than 1 acre).
Metal contamination in the former open storage areas is primarily limited to surface soil. The
concentration of lead in samples collected from the open storage area north of the junk pile, exceeds the
RGs. An estimated 1,070 CY of soil is considered for a remedial action based on an affected surface area
of 28,900 SF, and assuming contamination extends to a depth of 1 foot.
No RCRA hazardous wastes were identified in the open storage area at Site L5.
5.1.2.4 Site LI 1 (Test Site)
Site LI 1, covering approximately 33 acres, is located immediately south of Group I (Site L7). This area
was developed to test the firing velocities and impact effectiveness of various munitions within a secured
perimeter fence. Munitions were fired within this area into a downrange target area consisting of a coarse
gravel detonation pad constructed over native soil.
According to JOAAP personnel, UXO may exist at the Test Site because during normal operations,
approximately 10 ordnance per month failed to explode. UXO clearance activities performed during the
PHI field investigation did not detect any UXO, although numerous fragments were detected.
Arsenic was found at a level above its RGs in all soil samples from the target area. The area affected by
arsenic contamination, approximately 80 by 300 feet, is assumed to extend to a dcplh of 6 inches. The
total volume is estimated to be 445 CY.
No RCRA hazardous wastes were identified at Site LI 1.
5.7.2.5 Site L23A (Disposal Pit)
Historic aerial photo-interpretation from 1946 identified a small (less than 0.5 acre) disposal pit located in
the southwestern corner of Sites L23/L23A that is identified as Site L23A. It is not known what materials
were placed in this pit; however, aerial photos from 1952 indicated that disposal activities had ceased.
Lead was detected in soil samples from the pit at concentrations exceeding its RGs. The volume of lead-
contaminated soil is assumed to extend across the center of the disposal pit and the area north of the pit
(approximately 100 feet north-south by 150 feet east-west) to a depth of 6 feet. The total affected volume
of soil is estimated to be approximately 3,300 CY.
No RCRA hazardous wastes were identified at Site L23A.
5.7.2.6 Site M3 (Flashing Grounds)
Site M3 was described earlier in Section 5.1.1.9.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg. 5-10
-------
Approximately 150,000 of the 260,000 SF of topsoil within the 6-acre fenced area of M3 are estimated to
contain lead contamination concentrations above the RGs. The vertical extent of lead contamination is
nrTrSfn * £ ^ */, T™ dePth of ' foot based UP°" the non-inlrusive nature of flashing
operations. The volume of lead-contaminated soil in M3 exceeding the RGs is estimated to be 5,600 CY
Soils at Site M3 may contain RCRA characteristic hazardous wastes for TCLP extractable lead fRCRA
waste code D008) and TCLP extractable 2,4-DNT (RCRA waste code D030). (
5.7.2.7 Site M4 (Lead Azide Area)
Site M4 (Lead Azide Area) is located in the west central part of the MFC Area and covers approximately
136 acres. Lead azide, a primary initiating explosive, was produced in M4 from the early 1940s through
the Korean War and again during the Vietnam War from 1 966 into early 1 968.
The principal feature located in the western part of M4 was the Lead Azide Lagoon The Lead Azide
Lagooirwas used as a settling basin to store wastewater treatment sludge from the manufacturing and
formulation of lead-based initiating compound prior to neutralization and subsequent discharge to Grant
Creek. Any remaining lagoon sludge is classified as K046 hazardous waste.
The Lead Azide Lagoon covered an area of approximately 2,000 SF. In 1982, the production facility in
the central portion of M4 was demolished with the wreckage being burned within the Lead Azide Lagoon
At present, the only visible evidence of the lagoon is brick and concrete rubble in the surface soil,
Concentrations of lead greater than its clean up level were present in 14 of 20 soil samples analyzed from
M4; lead was detected in an area covering approximately 47,500 SF, and extending to a depth of 3 feet
l tie volume of lead-contaminated soil in M4 exceeding the RGs is estimated to be 4,200 CY.
™n™™»™ characteristic hazardous wastes for TCLP ex.ractable lead (RCRA
wase code D008) and RCRA listed hazardous wastes for lead wastewater treatment sludges (RCRA
WaSiC COClC -
5.1.2.8 Site Ml 2 (Settite Manufacturing Area)
M12 is located to the west of the TNT Ditch Complex in the northwestern portion of the MFC Area
Selhte was manufactured for use in the purification of crude TNT. Sellite consists of a solution of sodium
sulfite and sodium sulfate. M12 includes two sellite production units, a waste-water lagoon and
associated drainage ditches. b
No data was collected that directly identifies the vertical extent of lead contamination in M12. Based on
patterns of lead concentrations in samples collected in other areas within the Ml-G Area the lead
contamination m soils and sediments at the Sellite Manufacturing Area is presumed to be limited to a
S? °^ i mche]s- .^e depth of contamination is based on high concentrations of sulfate throughout
M12 and the insolubility of lead sulfate and other lead salts. The volume of lead-contaminated soil and
sediment m M12 exceeding the RGs is estimated to be 3,700 CY and includes both sediment in the
lagoon and soils in the ditches.
Soils at Site M12 may contain RCRA characteristic hazardous wastes for TCLP exlractable lead (RCRA
\Vcistc code J_/U(Jo).
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
PS- 5-11
-------
Table 5-4 Exceedances of Remediation Goals
as a Function of Land Use for Soils Found in
MIDEWIN TALLGRASS PRAIRIE AREAS (USDA)
Site
RG (ng/g)
Metals USDA
Arsenic 2 1
Beryllium 2
Cadmium 3,000
Lead 1,000
Contaminated Soil
Volume (CY) .Total
22.940
L2 L3 L5 LI1 L23A M3
Maximum Concentration Exceeding Recreational
86 58 26
3.76
5,800
12,000 2,250 2,300 4,340 49000
4,400 185 1,070 445 3,300 5600
M4
RGs ((.ig/g)
46
2.19
260,000
4,200
M12
3.48
2,510
3,700
& 1,3 SRU3. Explosives and Metals in Snil
SRU3, Explosives and Metals in Soil, contains sites where production and disposal activities released
both types of contaminants. Site L2, where explosives and munitions were burned, contains most of the
identified contaminated soils, although sites M5 and M6 may also have substantial amounts. A total of
four sites are grouped under this SRU. Two of these sites are within the LAP Area and two are within the
MFG Area, as shown in Figure 3. It should be noted that only certain subareas under each site are
included in this SRU and not the entire site. Table 5-5 lists the subareas and the volume of soil that needs
to be remediated. Table 5-6 lists exceedances of Remedial Goals (RGs) for sites included in SRU3.
5-5; Sites and Subareas of SRU3 (Explosives and Metals in Soill
Sites
L2
L3
MS
M6
Total
Subareas
Burning Pads
Bermed area
Lead (and other metals) contaminated soil throughout the
whole area of the site
Soil in the TNT Ditch
Volumes (CY)
16,350
1,070
3,700
12,000
33,120
5.1.3.1 Site L2 (Explosive Burning Grounds)
Site L2 was described in Section 5.1.2.1.
Analytical results of soil samples collected at site L2 indicate that the majority of the burning pads area
(approximately 206,500 SF) is contaminated with 2,6-DNT, RDX, arsenic and lead above RGs. The total
volume of soil at this site that exceeds RGs for explosives and lead is estimated to be 16,350 CY.
No RCRA hazardous wastes were identified in and around the burning pads at Site L2.
5.1.3.2 Site L3 (Demolition Area)
Site L3 was described in Section 5.1.2.2.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
PS- 5-12
-------
Results of sampling of site L3 indicated contamination of RDX and lead that exceed RGs in the western
portion of the bermed area with an approximate surface area of 170 SF from the western edge Since
samples from 2.5 feet m depth did not exceed RGs for explosives or metals, soil contamination over the
170-foot square area has been assumed to extend 1 foot below grade. The volume of explosives and
metals-contaminated soil within the bermed area of site L3 is estimated to be 1,070 CY In addition UXO
were identified in this area.
No RCRA hazardous wastes were identified at Site L3.
Table 5-6 Exceedances of Remediation Coals
as a Function of T.anfl Use for Soils Found in SRTT3
MIDEWIN TALLGRASS PRAIRIE AREAS
(USDA)
Sites
L2 L3
INDUSTRIAL PARK ARKAS
Sites
MS M6
Maximum Concentration Exceeding Industrial or Recreational RGs (uR/K)
Recreational RG
(ug/g) USDA
Explosives
1,3,5-TNB 180
2,4,6-TNT 290
2,4-DNT 13
2,6-DNT 13
RDX 78
Tetryl 7,400
Metals
Arsenic 2 1
Beryllium 2
Lead 1,000
Contaminated
Soil Volume
(CY).Total 33.120
300
1,100
17
15.4
2,400
96
2,050 1,120
Industrial RG
(Hg/g)
100
190
8.4
8.4
52
4,100
21
2
1,000
390 19,000
9.76 2,700
11.8
170,000
22
2.08 2.22
7,300 2.300
16'350 1,070 3,700 12,000
5.J.3.3 Site MS (Tetryl Production Area)
M5 was described in Section 5.1.1.10.
Results of sampling of site M5 indicated contamination of Tetryl, 2,4,6-TNT, 2,4-DNT, 2,6-DNT, lead
and beryllium that exceed RGs. The volume of explosives and metals contaminated soil throughout the
whole area of the site is 3,700 CY.
Soils at Site M5 may contain RCRA characteristic hazardous wastes for TCLP exlractable lead (RCRA
waste code D008).
5.7.3.4 Site M6 (TNTDitch Complex)
Site M6 was described in Section 5.1.1.11.
Results of sampling of site M6 indicated contamination of 2,4,6-TNT, 2,4-DNT, lead, arsenic, and
beryllium that exceed RGs. The volume of explosives and metals contaminated soil in the TNT Ditch is
V^i X . •
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
PS- 5-13
-------
Soils at Site M6 may contain RCRA characteristic hazardous wastes for TCLP extraclable lead (RCRA
waste code D008) and TCLP extractable 2,4-DNT (RCRA waste code D030).
5.1.4 SRU4. PCBs in Soil
SRU4, PCBs in Soil, consists of soils around transformers located in sites L7 to L10, and of soils beneath
a junk pile found at L5. Leakage and spills from the transformers caused the contamination.
A total of seven sites are grouped under this SRU. All of these sites are within the LAP Area, as shown
in Figure 3. It should be noted that only certain subareas under each site are included in this SRU and not
the entire site. Table 5-7 lists the subareas and the volume of soil/sediment that need to be remediated.
Table 5-8 lists exceedances of RGs for sites included in SRU4.
5.1.4.1 Site LI (Group 61)
Site LI was described in Section 5.1.1.1.
Two transformers removed in August 1990 from an area east of Building 61-4 were suspected to have
leaked oil containing PCBs onto site soil; the spill was subsequently cleaned up. However, based on the
subsurface detection of PCB 1260, a surface area of 20 by 35 feet surrounding the northern pole is
contaminated with PCBs above the RGs to a depth of 2 feet. Also, an area 10 feet square surrounding
sample location SC5 is contaminated with an additional 1.5 feet (3.5 feet below grade). A total volume of
approximately 60 CY of soil is estimated to be contaminated above clean up levels for surface and
subsurface soils.
No RCRA hazardous wastes were identified at Site LI. However, the soils contain PCBs, which are
regulated as TSCA hazardous substances.
Table 5-7; Sites and Suhareas of SRU4 fPCBs in Soli)
Sites
LI
L5
L7
L8
L9
L10
L17
Total
Subareas
Soil near transformer pole east of building 61-4
Junk pile (includes metals)
Soils around transformer pads
Soils around transformer pads
Soils around transformer pads
Soils around transformer pads
Sediment in drainage ditch
Volumes (CY)
60
1,965
338
102
317
534
100
3,416
5.1.4.2 Site L5 (Salvage Yard)
Site L5 was described in Section 5.1.2.3.
The junk pile at Site L5 occupies less than 1 acre in the southeast comer of the site. This area contains
concentrations of metals (arsenic and lead), PCBs, and TPH in soil at levels above clean up levels for
these constituents. The area of affected soils within and around the junk pile contaminated by metals,
PCBs, and TPH measures approximately 140 feet wide (north-south) and 200 feet long (east-west)
totaling 28,000 SF and includes a perimeter extending 25 feet out from the edge of the pile. The volume
JOAAP Record of Decision-Soil & Groundwater OUs - October, J 998
pg. 5-14
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of contaminated soil is estimated to be 1,040 CY, based on a depth of contamination of 1 foot throughout
the area. In addition, subsurface soils are assumed to be contaminated with PCBs to a depth of 5 feet
within the eastern end of the pile (an estimated area of 50 feet by 50 feet) giving additional volume of 370
CY. Of additional concern are items within the junk pile, which include scrap metal, pole transformers,
empty sodium hydroxide drums, refrigerators, and water heaters. The volume of this material is estimated
to be 555 CY. The total volume of contaminated soil at this site is estimated to be 1,965 CY.
RCRA hazardous wastes may be present in the area of the Junk Pile at Site L5 in the form of TCLP
extractable lead (RCRA waste code D008) and TCLP extractable cadmium (RCRA waste code D006).
The soils also contain PCBs, which are regulated as TSCA hazardous substances.
5.1.4.3 SiteL7(Group 1)
Site L7 was described in Section 5.1.1.2.
Six transformers, potentially containing askarel oil with PCBs, are also located at Site L7. Based on the
sampling results, the levels of PCBs in surface soil surrounding all six Site L7 transformers exceed the
RGs for PCBs in surface soil. PCB contamination has been assumed to extend to a maximum depth of 1
foot within most of the contaminated area based on the relatively low levels of PCBs present in samples
collected 15 feet from the transformer pads. Around the immediate edge (5 to 10 feet laterally) of the
transformer pad where PCB levels are highest in surface soil, PCB contamination above the clean up
levels has been conservatively assumed to extend to a depth of 2.5 feet, '['he total volume of
contaminated soil is estimated to be 338 CY.
No RCRA hazardous wastes were identified at Site L7. However, the soils contain PCBs, which are
regulated as TSCA hazardous substances.
5.1.4.4 Site L8 (Group 2)
Site L8 was described in Section 5.1.1.3.
Six transformers are located at Site L8. Based on sampling results, the levels of PCBs in surface soil
surrounding all six Site L8 transformers exceed the RGs for PCBs in surface soil. P( ?B contamination has
been assumed to extend to a maximum depth of 1 foot within contaminated areas near the transformer
pads, based on the relatively low levels of PCBs present in the samples. Approximately 94 CY of PCB-
contaminated soil are affected locally around six site L8 transformers. The remedial action will also
require the demolition of the six transformer pads, totaling 7.5 CY of concrete debris. The total volume
of contaminated soil at this site is estimated to be 102 CY.
No RCRA hazardous wastes were identified at Site L8. However, the soils contain PCBs, which are
regulated as TSCA hazardous substances.
5.7.4.5 Site L9 (Group 3)
Site L9 was described in Section 5.1.1.4.
Six transformers are located on-site. Because PCBs were detected around all transformer pads at sites L7,
L8, and LIO, which had similar operations to site L9, it has been assumed that soils around the site L9
pads also contain PCBs. An estimated volume of 310 CY has been assumed. This volume was calculated
by averaging the estimated volumes for sites L7, L8, and LIO. The confirmation sampling will be
conducted during the Remedial Design phase. The assumed PCB contamination will be confirmed during
the remedial design phase. The six transformer pads will also require remedial actions for their removal
(7.5 CY). The total volume of contaminated soil is estimated to be 317 CY.
JOAAPRecord of Decision -Soil& Groundwater OUs - October, 1998 ps. $.J5
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No RCRA hazardous wastes were identified at Site L9. However, the soils may contain PCBs, which
regulated as TSCA hazardous substances.
are
5.1.4.6 Site L10 (Group 3A)
Site L10 was described in Section 5.1.1.5.
Six transformers are also located on-site. Around 1987, one of the transformers in the northeastern part of
the site reportedly leaked approximately 4 gallons of PCB-containing oil (with concentrations of 41,000
ppm PCB) onto a concrete pad. "Oil dry" was placed on the concrete to remove the oil, and the pad was
wiped with cloth soaked in LIX, a solvent containing volatile organic compounds (VOCs).
Based on sampling results, the levels of PCBs in surface soil surrounding all six Site L10 transformers
exceed the RGs for PCBs in surface soil. Approximately 505 CY of PCB-contaminatcd soils are affected
locally around six Site L10 transformers. The remediation of this site will require the demolition of the
six transformer pads, totaling 7.5 CY of concrete debris and approximately 50 feet of asphalt road,
totaling 21 CY. The total volume of contaminated soil is estimated to be 534 CY.
No RCRA hazardous wastes were identified at Site L10. However, the soils contain PCBs, which are
regulated as TSCA hazardous substances.
Table 5-8 Exceedances nf Remediation Goals CR(ls\
as a Function of Land Use for Soils Fnnnd in SRII4
MIDEWIN TALLGRASS PRAIRIE AREAS (USDA)
Sites
Ll L5 L7 L8 L9 L10
INDUSTRIAL
PARK AREAS
Sites
L17
Maximum Concentration Exceeding Recreational and Industrial RGs Oig/g)
RG (ng/g)
USDA
Metals
Arsenic 21
Lead 1,000
Pest/PCBs
PCB 1
Special Parameters
TPH 2,500
Contaminated Soil
Volume
(CY),Total 3.416
31
4,700
25 73,400 532 40 Note(i) 16,000
2,590
60 1,965 338 102 317 534
R« (M8/g)
Incl. Park
21
1,000
1
2,500
1,640
100
Notes: (1) Confirmation sampling at Site L9 will be conducted during tht> KD phase.
5.1.4.7 Site LI 7 (Group 7)
Site LI7, a 90-acre site, is located in the southwestern corner of the LAP Area. It was initially
constructed for the production of boosters for munitions. After termination of loading operations in 1945
Site L17 was used for repacking of lead azide. A sump is located at the southern end of Building 7-4- and
a terra cotta flume drains to the west from the sump.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
Pg- 5-16
-------
PCBs, primarily localized in drainage ditch soils near a sewer outfall, are present to a depth of 5 feet.
Additionally, low concentrations of PCBs in surface soil/sediment extend at least 150 feet downstream.
The volume of soil/sediment containing PCBs in this ditch is estimated assuming that contamination is 5
feet deep in a 30-foot section at the head of the ditch, and 1 foot deep for another 100 feet. The ditch is
approximately 10 feet wide, and it is assumed that this width is similar to the lateral extent of PCB
contamination. The total volume of soil contaminated at concentrations above RGs is estimated to be 100
CY.
No RCRA hazardous wastes were identified at Site LI 1. However, the soils contain PCBs, which are
regulated as TSCA hazardous substances.
5.7.5 SRU5. Oreanics in Soil
SRU5, Organics in Soil, consists of sites LI (Group 61) and L5 (Salvage Yard) where petroleum products
were spilled. Both of these sites are within the LAP Area, as shown in Figure 3. It should be noted that
only certain subareas under each site are included in this SRU and not the entire site. Table 5-9 lists the
subareas and the volume of soil/sediment that needs to be remediated. Table 5-10 lists exceedances of
RGs for sites included in SRU5.
Table 5-9; Sites and Suhareas of SRTJ5 (Organics in Srih
Sites
LI
L5
Total
Subareas
Soil near above-ground storage tanks (ASTs) at
Building 61-1 and 61-2
Oil stain area
Drainage ditch
Soil below railroad ties
Volumes (CY)
1,275
30
555
550
2,410
5.7.5.7 Site LI (Group 61)
Site L1 was described in Section 5.1.1.1.
Field reconnaissance identified petroleum-stained soils near aboveground storage tank (AST) locations
west of Building 61-1 and north of Building 61-2. In the vicinity of the AST location at Building 61-1,
samples were collected at the surface and at depths of 2.5 and 5 feet. TPH was delected in all samples at
concentrations above the RGs. The surface area contaminated by TPH is estimated to be 2,500 SF and
contamination is assumed to extend to a depth of 10 feet. This volume of soil is estimated to be 925 CY.
In the vicinity of the ASTs located at Building 61-2, soils below the ASTs within the surrounding earthen
berm are heavily saturated with petroleum products and presumably are contaminated with TPH above
the cleanup levels. The hydrocarbon-stained soils are limited to the area within the earthen berm
surrounding the tanks, which is approximately 900 SF based on field measurements. Therefore, the
volume of soil north of Building 61-2 is estimated to be 350 CY assuming contamination extends to a
depth of approximately 10 feet below grade.
In summary, a total volume of 1,275 CY of soil is contaminated above the TPH RCJs at the two AST
locations of site LI.
No RCRA hazardous wastes were identified at Site LI.
JOAAP Record of Decision - Soil & Groundwater OVs - October, 1998
pg. 5-17
-------
5.1.5.2 Site L5 (Salvage Yard)
Site L5 was described in Section 5.1.2.3.
The 500-foot long shallow drainage ditch is an area at site L5 that contains concentrations of metals
(beryllium, lead, and arsenic) and organics (TPH) in soil at levels above clean up levels for these
constituents. The volume of contaminated soil in the ditch area is estimated to be 555 CY, assuming soils
in an area 25 feet wide and 500 feet long are contaminated to a depth of 1 foot and, an area 25 feet by 50
feet, are contaminated to 2 feet in depth.
The former oil spill area adjacent to Building 26-3 contains surface soils that exceed the TPH RGs. The
volume of TPH-contaminated soil in the oil spill area of site L5 is estimated to be 30 CY and is limited to
soils 1 foot in depth between Buildings 26-3 and 26-4.
The large piles of railroad ties are located over approximately 1 acre in the south-central section of site
L5. Soil samples collected within this area identified concentrations of benzo(a)pyrene above the RGs.
Based on the available data, the extent of organics contamination above RGs is assumed to be limited to
the western half of the area of the piles of railroad ties (an area of 300 feet by 100 feet) to a depth of 6
inches. This area represents a volume of approximately 550 CY.
The total volume of soil contaminated with organics at this site is estimated to be 1,135 CY. The
contaminants of concern found at Site L5 also include arsenic, beryllium, lead, and bcnzo(a)pyrene. The
maximum concentrations of these compounds exceeded the RGs levels.
No RCRA hazardous wastes were identified in the ditch and oil stain areas at Site L5.
Table 5-10 Exceedances of Remediation Goals (RC«)
as a Function of Land Use for Soils Found in SRTLS
MIDEWIN TALLGRASS PRAIRIE AREAS (USD A)
Site
B
Metals
Arsenic
Beryllium
Lead
Semivolatiles
Benzo(a)pyrene
Special Parameters
TPHs
Contaminated Soil
(CY) ,Total
LI L5
G (ug/g)
USDA
21
2
1,000
1.2
2,500
Volume
2.410
Maximum Concentration Exceeding
Recreational RGs (ug/g)
50
2.7
1,220
1.5
111,000 |(),000
1,275 1,135
5.1.6
Landfill*
SRU6 consists of six sites used for waste disposal during production and operation activities. Site L3 is a
demolition area that includes large quantities of buried waste materials in berms along Prairie Creek as
well as other features described earlier. Site L4 is an existing disposal area containing construction
debris. Sites Ml and M9 are constructed landfills that contain red water ash from the incineration of
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
pg. 5-18
-------
wastewater (red water) generated during TNT and DNT production. Both are classified as RCRA
hazardous waste sites that must be remediated. Site Mil is a large 70-acre former gravel pit that was
filled with construction debris and other materials. Site M13 contains an 8-acre former gravel pit that was
filled with a variety of non-hazardous industrial debris and wastes. Remediation is required at all the
above waste disposal sites to comply with current landfill regulations, to prevent human exposure to these
wastes, and to prevent potential migration of contaminants from these areas into the groundwater.
i
A total of six sites are grouped under this SRU. Four of these sites are within the MFG Area and two are
within the LAP Area, as shown in Figure 3. It should be noted that certain subareas under each site are
included in this SRU and not the entire site. Table 5-11 lists the subareas, the estimated areas that the
landfills cover, and the estimated volume of soil that needs to be remediated. Table 5-12 lists
exceedances of RGs for sites included in SRU6.
5. /. 6.1 Site L3 (Demolition Area)
Site L3 was described in Section 5.1.2.2.
The berms located along Prairie Creek are contaminated with lead, chlordane, 2,6-DNT and phosphate
above the RGs for these constituents. The berms are present within an area measuring approximately 800
feet along Prairie Creek and 300 feet wide in the northwest portion of site L3. The entire area between
Prairie Creek and the easternmost access road is presumed to be filled with metallic debris and other
wastes including UXO.
The extent of contamination in the berms along Prairie Creek appears to be related to the presence of fill
material. Several assumptions were made to calculate fill volumes. Average berm heights are estimated
to be 8 feet in the northern berms and 3 feet in the southern berms. The average depth of fill is estimated
at 3 feet below ground surface in the northern area and 2 feet below ground surface in the southern area.
The fill is believed to be deeper closer to Prairie Creek greater than 10 feet and pinches out east of the
burning cage. The estimated volume of the material is 35,000 CY.
Site L3 may contain unexploded ordnance which are classified as RCRA characteristic wastes (RCRA
waste code D003) because of their reactivity
Table 5-11: Sites and Subareas of SRU6 (Landfills)
Sites
L3
L4
Ml
M9
Mil
M13
Subareas
Burning areas (berms) along Prairie Creek
Landfill
The southern ash pile
The northern ash pile
Materials in the Landfill Area
Materials in former disposal area
Total
Area (Acres)
7.5
6.5
8.5
6.5
78
13
120
Volumes
«:v)
35,000
37,000
205,200
124,000
66,600
222,000
690,700
5.1.6.2 Site L4 (LandfillArea)
Site L4 is located southwest of the Demolition Area (Site L3), on the northern side of Prairie Creek. Two
former extraction pits excavated to bedrock are located in this area. The western extraction pit is partially
filled with construction waste and sanitary sewage, and the eastern pit has been flooded, by Prairie Creek.
JOAAP Record of Decision - Soil & Groundwater OVs - October, 1998
pg. 5-19
-------
Operating from the early 1940s (World War II) until the late 1960s, the landfill associated with the
western pit reportedly accepted various types of construction debris. In addition, 5-gallon pails
containing unknown substances were reportedly disposed of in the landfill. The final cover, reportedly
compacted clean fill, was placed in the 1970s.
Although this area is currently completely vegetated, several small sinkholes were observed where the fill
materials had collapsed. Based on the depth to bedrock in the area, the fill is not anticipated to be more
than 15 feet deep and may extend eastward to a small drainage ditch. No fill was identified in the
southwestern portion of the site, and the exposed bedrock south of the fill area defines the southern
boundary. Based on the real extent of the fill and estimated depth, it is calculated that the landfill
contains 37,000 CY of waste materials.
No RCRA hazardous waste was identified at Site L4.
5.1.6.3 Site Ml (Southern Ash Pile)
Site Ml is comprised of approximately 68 acres located in the southwestern part of the MFG Area The
Southern Ash Pile was used from 1965 through 1974 as a landfill for ash residues generated from the
incineration of wastewater produced in the TNT manufacturing processes. The "red water ash" in the
Southern Ash Pile is derived from K047-listed hazardous wastes. IEPA has notified ihe Army by letter
u-uu24' 1998> that SmCC thC 3Sh residues at M1 no Ion8er exh'bit the characteristic of reactivity (for
which they were listed), they are not hazardous wastes under the regulation at 35 IAC 721. 103(a)(2)(C).
The ash pile, measuring 800 feet by 450 feet, covers approximately 8 acres. The ash pile is 10 to 15 feet
high and is estimated to contain 205,200 cubic yards of material. Upon closure the ash pile was
originally covered with polyvinyl chloride (PVC) barriers, 12 inches of fill, and 6 inches of topsoil
However, as a result of erosion, the Southern Ash Pile was recapped in 1985 with an additional 12 inches
of clay and 6 inches of topsoil. Due to continuing erosion, additional repairs to the ash pile cap were
performed in 1993, and a temporary geosynthetic liner was installed in 1996 as part of a removal action
conducted by the U.S. Army.
No RCRA hazardous waste was identified at Site Ml.
5.1.6.4 Site M9 (Northern Ash Pile)
Site M9 is comprised of approximately 20 acres located at the top of an escarpment in the north-central
part of the MFG Area. The Northern Ash Pile was constructed during 1966 and 1967 as a landfill for ash
residues from the incineration of TNT manufacturing wastes. The red water ash in the Northern Ash Pile
is derived from K047-listed hazardous wastes. IEPA has notified the Army, by letter of July 24 1998
that since the ash residues at M9 no longer exhibit the characteristic of reactivity (for which they were
listed), they are hazardous wastes under the regulation at 35 IAC 721.103(a)(2)(C).
The ash pile measures more than 625 feet by 600 feet and covers approximately 5 acres. The ash pile is
i-L'n 15 feCt hlgh Wth 2 d°med t0p and Steep sides' The Northern Ash Pile is estimated to contain
124,000 cubic yards of material. Upon closure, the ash pile was originally covered witli PVC barriers, 12
inches of fill, and 6 inches of topsoil. However, as a result of erosion, the Northern Ash Pile was
recapped in 1985 with an additional 12 inches of clay and 6 inches of topsoil. Evidence of leaching from
the eastern, southern and western edges of the Northern Ash Pile has been observed during site
reconnaissance m the form of stressed vegetation. The presence of several collapsed features across the
ash pile have been documented, some of which have breached the clay cap and exposed ash material The
cap was repaired again by the U.S. Army in 1993.
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998 pg. 5.20
-------
No RCRA hazardous waste was identified at Site M9.
5.1.6.5 Site Mil (Landfill)
Site Mil is located to the east and south of the Explosive Burning Ground (M2) and covers
approximately 133 acres. While initially used as a source of gravel, this area was operated between 1952
and 1978 as an uncontrolled dump. Mil is divided into two sections by School House Road. The
Landfill is located on a ridge estimated to be 800 feet wide by 5,600 feet long and oriented northeast to
southwest. The ridge rises 10 to 15 feet above the surrounding low plain.
A variety of waste materials are contained in the landfill. The materials include asbestos, insulation, and
construction rubble. Numerous 55-gallon drums have also been identified, other debris includes creosote-
treated wood, paint cans and scrap metal. Similar materials are believed to be buried in the Ml 1 gravel
pit excavations. An area covered with asphalt tar is located in the central part of the southern portion of
Ml 1. A gravel pile, covered with a white residue, is also present in this part of the Landfill. Samples of
the waste detected concentrations of lead at levels exceeding the TCLP limits, indicating that some of the
wastes present would be classified as RCRA hazardous wastes. The estimated volume of the material is
66,600 CY.
RCRA characteristic hazardous wastes may be present at Site Mil in the form of TCLP-extractable lead
(RCRA waste code D008).
Table 5-12 Exceedances of Remediation Goals (RGs\
as a Function of Land Use for Soils Found in SRTJ6
MIDEWIN TALLGRASS PRAIRIE AREAS (USDA)
Sites
L3 L4 Ml Mil
INDUSTRIAL PARK AREAS
Sites
M9 M13
Maximum Concentration Exceeding Recreational and Industrial RGs (nK/g)
Recreational RG
(ug/g) USDA
Explosives
2,4-DNT 13
2,6-DNT 13
Metals
Arsenic 21
Lead 1,000
Pest/PCBs
Chlordane 6.6
Semivolatiles
Benzo(a)pyrene 1 .2
Special Parameters
Phosphate 456
Landfill Soil Volume
(CY),Total 623.200
Landfill Area
(acres), Total 120
24
30
2,740 3,380
6.9
2,000 880
Industrial
RG (ug/g)
8.4
8.4
21
1,000
4.4
0.78
456
10.9
22
35,000 37,000 205,200 N/A 124,000 222,000
' 7.5 6.5 8.5 78 6.5 13
JOAAP Record of Decision - Soil & Groundwatcr OUs - October, 1998
pg. 5-21
-------
5.1.6.6 Site Ml 3 (Gravel Pit)
Site M13 is located in the central portion of the MFG Area to the north of the Tetryl Production Area to
the east of the TNT Ditch Complex, and to the west of Acid Area 1. The Gravel Pits cover approximately
106 acres. J
Four potential disposal areas have been identified within M13. Each of the disposal areas in M13 has an
area of less than 12 acres. Plant records and aerial photographs indicate that landfill activities at the
Northern Gravel Pit began in 1966 and ceased in 1984. The topography in the vicinity of the Northern
Uravel Pit is flat. The Northern Gravel Pit contains scrap metal, creosote-treated railroad ties and
telephone poles, and a variety of construction and office debris. None of the other pits were identified as
containing wastes posing potential threats to human health or the environment.
Site related soil contaminants include beryllium, lead, and benzo(a)Pyrene. The material in the former
disposal area requiring remedial action is estimated to be 222,000 CY.
No RCRA hazardous wastes were identified at Site Ml 3.
5.7.7 SRU7.
SRU7, Sulfur, consists of areas where raw sulfur lies on the ground surface at sites M8 and M12 and
maybe impacting the environment. Raw sulfur was used to produce sulfuric acid and other chemicals
used in the production of explosives. The sulfur is spread over wide areas on the ground surface. The
removal of sulfur is not regulated under the CERCLA.
A total of two sites are grouped under this SRU. Both of these sites are within the MFG Area as shown
in figure 3. It should be noted that only certain subareas under each site are included in this SRU and not
? if"??/?' Table 5"13 hsts the subareas and the volume of raw sulfur that needs to be remediated
lable 5-14 lists exceedances of Remedial Goals (RGs) for sites included in SRU7.
5. 1. 7.1 Site M8 (Acid Manufacturing Area)
Site M8 covers an area of approximately 304 acres in the central portion of the MF( i Area. The shape of
M8 is an inverted "L" oriented lengthwise from north to south. M8 contains four areas in which nitric and
S2"™ W6re Produced and combined into various strength "mixes" for use in the manufacturing of
DNT, TNT, and tetryl. 6
Acid Area 3 is located in the northeast corner of M8. The production of Oleum, slrong nitric acid and
other acids used m the production of explosives was the principal activity in Acid Area 3 Acid Area 3
contains the Oleum Plant, the Northern Ammonia Oxidation Plant (AOP), and the Northern Acid Area.
The Oleum Plant is located in the northern portion of Acid Area 3. The southern half of the Oleum Plant
consists of concrete and brick pads for the receiving and storage of bulk sulfur. Raw sulfur is readily
apparent throughout this area and along the southern railroad spur. The areal extent of raw sulfur
contamination in the Oleum Plant is estimated to be 36,000 square feet. The volume of raw sulfur in the
Oleum Plant is estimated to be 6,100 CY.
No RCRA hazardous wastes were identified at Site M8.
JOAAP Record of Decision- Soil & Groundwater OUs - October, 1998 „„, 5.22
-------
Table 5-13: Sites and Subareas of SRU7 (Sulfur}
Sites
M8
M12
Total
Subareas
Sulfur present throughout the Oleum Plant
Sulfur in the wetland area and drainage ditch
immediately south of the lagoon
Volumes (CY)
6,100
1,400
7,500
5.7.7.2 Site Ml2 (Sellite Manufacturing Area)
Site M12 was described in Section 5.1.2.8.
The environmental impacts of raw sulfur on vegetation are observed at the wastewalor outfall located to
the north of the sellite manufacturing facility. The absence of vegetation in and immediately adjacent to
surface deposits of sulfur is also noted in the former lagoon located in the northeast portion of Ml2. The
volume of sulfate-contaminated soil is estimated to be 1,400 CY.
No RCRA hazardous wastes were identified atSiteM12.
Table 5-14 Exceedances of Remediation Goals rRGs^
as a Function of Land Use for Soils Found in SRU7
MIDEWIN TALLGRASS PRAIRIE AREAS
(USDA)
Sites
M12
INDUSTRIAL PARK AREAS
Sites
M8
Maximum Concentration Exceeding Recreational and Industrial RGs (ug/g)
Recreational
RG (ug/g)
Special Parameters
Sulfur n/a
Contaminated Soil Vol-
ume (CY),Total 7.500
Raw sulfur considered
a potential health
hazard
Industrial RG
(ug/g)
n/a
Raw sulfur considered
a potential health
hazard
1,400 6,100
5.1.8 SOU No Further Action Sites
Overall, 53 sites plus three subareas were identified under the CERCLA program at JOAAP. Twenty-
eight (28) sites plus one subarea suspected as having contaminated soil were investigated during the
RI/FS and determined to have either no historical evidence suggesting contamination potential, no
contamination, or contaminant concentrations that do not pose a threat to human health or the
environment. Soils at these sites exhibit no characteristic of hazardous wastes. IEPA and USEPA agree
that, under CERCLA requirements, no further cleanup actions are required for these sites. These sites,
and the reason for their designation for no further action, are presented in further detail in Section 6.6.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
pg. 5-23
-------
5.2 GrnundwaterOTI
5.2.1 GKJJ1. Explnaives-LAP
GRU1, Explosives in Groundwater, is entirely in the LAP Area and consists of separate plumes
emanating from sources in Sites LI, L2, L3, and L14 (Figure 4). Explosives are the only contaminants
tound in these plumes that could pose a risk to human health or the environment. The GRU1 plumes are
within the glacial drift aquifer for all sites. The plumes extend into the upper bedrock aquifer for Sites
LI 12 and L3 but not for Site L14 (Table 5-16). It should be noted that the plumes under each site are
included in this GRU and not necessarily the entire site. Table 5-17 lists exceedances of Remedial Goals
(RGs) for sites included in GRU1.
Table g-15: Sites Overlving GRTJ1 fExnlosivcs in Groundwatcr
-LAP Area)
Sites
LI
Subareas
Volumes (MG)
Groundwater related to the ridge-and-furrow area
69
L2
Groundwater downgradient of burning pad area
L3
Groundwater downgradient of burning cage
Groundwater downgradient of bermed area
10
LI4
Total
Groundwater downgradient of sumps at Bldg. 4-5
87
5.2.LI Site LI (Group 61)
Site LI was described in Section 5.1.1.1.
The contaminants detected at elevated levels in groundwater at Site LI are explosives (1 3 5-TNT 2 6-DNT
and RDX). Groundwater contamination at Site LI originates as a result of contaminant migration from
the ndge-and-furrow area, with the plume extending southward toward MW172 and MW173. Given the
relatively high concentrations of explosives in soil on-site, contaminant migration from soil to
groundwater may be occurring, although the majority of the groundwater contamination is attributed to
the infiltration of discharged liquids.
No RCRA hazardous wastes were identified in the groundwater at Site LI.
5.2.1.2 Site L2 (Explosives Burning Grounds)
Site L2 was described in Section 5.1.2.1.
Waste disposal activities at this site have resulted in a groundwater plume containing RI)X that appears to
emanate from the north/northeastern portion of the burning pad area.
No RCRA hazardous wastes were identified in the groundwater at Site L2.
5.2.1.3 Site L3 (Demolition Area)
Site L3 was described in Section 5.1.2.2.
There are two separate explosives-contaminated groundwater plumes that are of concern for site L3
groundwater downgradient of the burning cage and groundwater downgradient of the central bermed area'
The RJ investigations indicate that these two groundwater plumes are not connected. Groundwater
downgradient of the burning cage (MW410) was found to contain only RDX, at a concentration 222 2 ug/L -
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998
pg. 5-24
-------
The source of this contamination appears to be contaminated materials buried in the benrts along the creek.
RDX was detected in bedrock well MW412, located downgradient of the bermed area, at a concentration
77.9 ug/L.
No RCRA hazardous wastes were identified in the groundwater at Site L3.
Table 5-16 Exceedances of Remediation Goals fRGsl
as 3 Function of Land Use for Groundwater Found in GRTH
MIDEWIN TALLGRASS PRAIRIE AREAS (USDA)
Site
RG (ug/1)
Explosives USDA
1,3,5-TNB 5.1
2,4,6-TNT 9.5
2,4-DNT 0.42
2,6-DNT 0.42
RDX 2.6
Affected Aquifers
Contaminated Volume
(MG), Total £Z
LI L2 L3
Maximum Concentration Exceeding Risk Based
Employee RGs (ug/1)
1,300
1,900
2.01
8.54
56.50 640 77.90
GD,SB GD, SB GD, SB
69 4 12
L14
,Park
840
GD,SB
2
Key: GD glacial drift, shallow aquifer
SB shallow bedrock aquifer
5.2.2.4 Site LI4 (Group 4)
Site L14 was described in Section 5.1.1.6.
RDX is the primary explosive detected in groundwater at Site L14. The source of this contamination
appears to be overflows and leaks from the sump north of Building 4-5.
No RCRA hazardous wastes were identified in the groundwater at Site LI4.
&£2—GRU2, Explosives and Other Contaminants - MFC Area
GRU2, Explosives and Other Contaminants in Groundwater, is entirely in the MF
-------
Table 5-17 Sites Overlying GRU 2 (Explosives and Other Contaminants in On.mdwater - MFC
Area)
Sites
Ml
M5
M6
M7
M8
M13
Total
Subareas — — — — ^
Southern Ash Pile (explosives and antimony)
Tetryl Production Area (explosives)
TNT Ditch Complex (explosives and PCE)
Red Water Area (explosives and antimony)
Acid Manufacturing Area (explosives and PCE)
Gravel Pits (explosives, cadmium and antimony)
Volumes (MG)
62
96
96
96
96
96
542
5.2.2.2 Site MS (Tetryl Production Area)
Site M5 was described in Section 5.1.1.10.
Two samples from the MW207 contained 2,6-DNT and 2,4,6-TNT at the concentrations 5.53 jig/L and
16.7 U£/L, respectively. MW207 is located in the northern central part of Site M5, near junction of the
East-West Ditch and the Tetryl Ditch. Wastewaters discharged into those ditches are the suspected source
of the contamination. In addition to explosive contamination, iron was detected (42,000 u.g/1) above the
established background levels.
No RCRA hazardous wastes were identified in the groundwater at Site M5.
5.2.2.3 Site M6 (TNT Ditch Complex)
SiteM6 was described in Section 5.1.1.11.
Seven explosives (RDX, 2,4-DNT, 2,6-DNT, NB, 2-NT, 1,3,5-TNB, 2,4,6-TNT) were detected with
concentrations above the RGs in groundwater samples from this site.
The obvious source of explosives in groundwater is through percolation from the TNT Ditch. Other
sources are soil-impacted areas associated with the various production lines and the wastewater
discharges into various sewer lines. These sources probably continue to release explosives to the
groundwater. In addition to explosives, Tetrachloroethene (PCE) was detected (150 ug/L) in one sample
above the established Class II Illinois Groundwater Standard and appears to be derived from a release in
the former shop area of Site M6. Cadmium was detected in a sample taken from MW123 in 1982 at a
concentration (162 ug/L) higher than the Class II Illinois Groundwater Standard. It is uncertain if this
detection is representative of actual site conditions, which will be further assessed during the remedial
design.
No RCRA hazardous wastes were identified in the groundwater at Site M6.
5.2.2.4 Site M7 (Red Water Area)
Site M7 was described in Section 5.1.1.12.
Four explosives (RDX, 2,4-DNT, 2,6-DNT, 2,4,6-TNT) were detected in groundwater samples from this
site. The suspected source of the groundwater contamination in this area is release of wastewaters
containing explosives compounds.
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998
pg. 5-26
-------
No RCRA hazardous wastes were identified in the groundwater at Site M7.
Table 5-18 Exceedances of Remediation Goals (RGs)
as a Function of Land Use for Groundwater Found in GRII2
MIDEWIN TALLGRASS
PRAIRIE AREAS (USDA)
Sites
Ml
INDUSTRIAL PARK AREAS
MS
Maximum Concentration
RG (ug/I) USDA
Explosives
1,3,5-TNB 5.1
2,4,6-TNT 9.5
2,4-DNT 0.42
2,6-DNT 0.42
2-NT 1,000
MB 51
RDX 2.6
Metals
Antimony 24
Cadmium 50
Iron 5,000
Organics
letrachloroethene 25
Affected Aquifers
Contaminated Volume
(MG), Total 542
.608
3»
GD, SB
62
16.7
5.53
42,000
GD
96
M6
M7 M8
M13
Exceeding Class II RGs (ng/1)
240
2,600
3,200
2,700
21,000
81.8
52.7
162
150
GD, SB
96
9.5
200 9
70 0.53
46
31
48.000
GD, SB GD
96 96
15.5
12.9
126
39
38.7
56
GD
96
Key: UD glacial drift, shallow aquifer
SB shallow bedrock aquifer
5.2.2.5 Site M8 (Acid Manufacturing Area)
Site M8 was described in Section 5.1.6.1.
2,4-DNT was detected in two samples taken from the MW147 in concentrations 9 j.ig/1, and 5 u.g/L. 2,4-
DNT was also detected in a sample taken from the MW325 at a concentration of 0.531 u.g/L.
Groundwater impacted by explosives in the site M8 is mostly due to leaching of isolated "hot spots" that
have been largely depleted in the years since the facility was active. In addition to explosive
contamination, iron was detected (48,000 u,g/L) above the established background levels in a sample
collected from the MW107.
No RCRA hazardous wastes were identified in the groundwater at Site M8.
5.2.2.5 Site Ml3 (Gravel Pits)
Site M13 was described in Section 5.1.6.6.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
PS- 5-27
-------
Fifty-six samples of groundwater have been collected and analyzed for explosives. Of these, seven
samples contained detectable concentrations of four explosives (2,4,6-TNT, 2,6-DNT, 1,3,5-TNT 24-
DNT).
Concentrations of explosives in soil samples found along the TNT Ditch may be a source for the
explosives in the groundwater. In addition to the explosive contamination, antimony was detected in
MW322 at the concentration of 38.7 u,g/L. Also, cadmium was detected in the MW126 at the
concentration of 56 jig/L.
No RCRA hazardous wastes were identified in the groundwater at Site Ml3.
5*2*2.—GRU3. Volatile Organic Compounds- MFC Area
GRU3, VOCs in Groundwater, is entirely in the MFG Area and consists of separate toluene plumes
emanating from sources in the western and central sections of Site M10, the Toluene Tank Farms, and of
a benzene plume found at M3 (Figure 4). The toluene plumes at Site Ml0 are in the overburden (glacial
drift) aquifer of both the western and central tank farm sections of Site M10, and in the upper bedrock
aquifer of the western tank farm section of M10 (Table 5-20). The benzene plume at Site M3 is in the
upper bedrock aquifer. Table 5-21 lists exceedances of Remedial Goals (RGs) for sites included in
GRU3.
Table 5-19 Sites Overlving GRU3 VOCs in Groundwater-MFC Area
Sites
M3
M10
Total
Subareas
Flashing Grounds
Western and Central Toluene Tank Farms
Volume (MG)
o<" "~ ~
3
3
1991.
5.2.3.1 SiteMS
Site M3 is described in Section 5.1.1.9.
In 1991, twelve samples (including one duplicate) were taken from eleven monitoring wells at Site M3
and analyzed for VOCs (as well as explosives, anions, metals, and semi-volatile compounds). One well,
MW233, was found to contain benzene in excess of the Class I water quality standards. No other
detections of benzene occurred. No other VOCs were found in any M3 wells in concentrations exceeding
Class I standards. No other samples at M3 have been analyzed for VOCs before or since 1991. Sampling
and analysis will be performed to confirm whether or not benzene has degraded in the plume under Site
M3 since 1991.
No RCRA hazardous wastes were identified in the groundwater at Site M3.
5.2.3.2 Site Ml0
Site M10 in the northern portion of the MFG Area contains three toluene tank farms. Each of the tank
farms covers approximately 5 acres and was in use through 1976. Four ASTs, each with a capacity
exceeding 1 million gallons of toluene, were constructed in each tank farm. For the period during World
War II in which nitroxylenes were manufactured at the JOAAP, xylenes were stored in two of the three
tank farms. The specific tanks used for xylene storage are not known. In separate incidents in August
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 5-28
-------
1968 and July 1971, lightning destroyed the northwestern and southwestern ASTs in the Western Toluene
Tank Farm. An estimated 1.1 x 106 gallons of toluene were lost in each of the explosions and subsequent
fires. Spill records also indicate that an AST in the Central Toluene Tank Farm was struck by lightning in
June 1971. The tank was not destroyed; however, an unknown volume of toluene was lost.
Toluene was detected in two samples at the Central Toluene Farm in MW224 at the concentration 20,000
ug/L and 6,000 u,g/L, respectively. In the Western Toluene Tank Farm, toluene was detected in two
samples in MW220 at the concentration of 10,000 ug/L and 19,600 jig/L, respectively. The presence of
toluene in groundwater but absence in soil has been explained as the result of a high water table and thin
overburden creating a flushing mechanism for the overburden. The suspected source is from a spill from
two tanks ruptured after being struck by lightning.
No RCRA hazardous wastes were identified in the groundwater at Site M10, except for the toluene,
which was used as a raw material or commercial chemical product (RCRA waste code U220).
Table 5-20 Exceedances of Remediation Goals
as a Function of Land Use for Groundwater Found in GRTJ3
MIDEWIN TALLGRASS PRAIRIE AREAS (USDA)
Sites
M3
M10 Central
INDUSTRIAL PARK AREAS
Sites
M10 West
Maximum Concentration Exceeding Class I, Class II and Risk Based, Park Employee RGs (ug/1)
RG (ug/1) USDA
Volatile Organic Compo
Benzene 5
Toluene 2,500
Affected Aquifers
Contaminated Volume
(MG), Total _2
unds (VOCs)
15.8
SB
0
19,600
GD
1.5
RG (ug/1) IND. P
25
2,500
20,000
GD, SB
1.5
Key: GD glacial drift, shallow aquifer
SB shallow bedrock aquifer
5.2.4 GOU No Further Action Sites
Fifty-three (53) sites plus three (3) subareas suspected as having groundwater contamination were
investigated during the RI/FS and Risk Assessment process. The groundwater underlying 41 of these
sites and the three subareas was found to have no historical evidence suggesting contamination potential,
no contamination, or contaminant concentrations that do not pose a threat to human health or the
environment. IEPA and USEPA agree that, under CERCLA requirements, no further cleanup actions are
required for these sites. The groundwater underlying these NFA sites and subareas, and the reason for
their designation for no further action, are presented in further detail in Section 6.6.
[END OF SECTION]
JOAAP Record of Decision - Soil & Groundwater Oils - October, 1998
pg, 5-29
-------
-------
6 SUMMARY OF STTF
A human health and environmental risk assessment was performed for soils, surface water, sediments,
and groundwater at JOAAP. The objective of this assessment was to evaluate current and future
exposures associated with contaminated soils, sediment, surface water and groundwater at the sites in the
absence of remediation actions. The risk assessment analyzed the toxicity and degree of hazard posed by
site soil, sediment, surface water and groundwater contaminants. This assessment also described the
probable routes by which they come into human or ecological contact.
Risk assessment consists of evaluating the types and levels of contaminants present, the pathways by
which receptors could potentially be exposed to these contaminants, and the toxicity and/or
carcmogenicity of the contaminants. The Army conducted historical reviews, site inspections, and
remedial investigations to analyze the nature and extent of soil and groundwater contamination in both
the LAP and MFG Areas of the JOAAP. The Army also conducted environmental studies on the impacts
of contamination on plant and animal populations. Four reports, the "Baseline Risk Assessment"
(Dames & Moore, 1994), "Phase 1 Ecological Risk Assessment Report" (USACHPPM, 1994), "Phase 2
Aquatic Ecological Risk Assessment Report" (USACHPPM, 1996), and "Preliminary Remediation
Goals" (OHM, 1996) were developed. These reports include a quantitative estimate of the potential for
adverse health and ecological effects that may occur if no remedial actions were implemented at the
contaminated sites.
Data are available to form a conceptual model of the contaminated areas. The model considers the
sources of contamination, the manner in which the contaminants were released to the soil and
groundwater, and the distribution of the contaminants both in depth and in area extent. This conceptual
model was used to develop soil and groundwater remediation goals. The final RGs are the maximum
concentrations of contaminants that could remain on-site while resulting in risks within the USEPA's
acceptable range. Soil and groundwater that is contaminated in excess of these final RGs, therefore, may
pose a threat to human health that is higher than these acceptable risk levels.
Standard risk assessment assumptions and equations were used to perform the calculations needed to
derive soil and groundwater RGs.
6,1 Human Health Risk
£/• 7 Human Health Risk Assessment
Human health risk estimates were made for site-related contaminants that can cause cancer (carcinogens)
and for non-cancer causing compounds (non-carcinogens). The National Contingency Plan (NCP)
establishes acceptable levels of carcinogenic risk for Superfund sites as ranging from 1 in 10,000 (1x10'
*) to 1 in one million (1 x 10*) excess cancer cases. "Excess" means the number of cancer cases in
addition to those that would ordinarily occur in a population due to non-site-related factors. For non-
cancer causing compounds, a risk estimation known as the "hazard index" is used. Typically, hazard
indices below one (1.0) indicate that no adverse health effects are expected, and values above 1.0 are
indicative of possible adverse effects.
The human health risk assessments identified a total of 79 contaminants of concein in JOAAP soil and
sediment, 40 contaminants of concern in groundwater, and 45 contaminants of concern in surface water.
JOAAP Record of Decision - Soil & Groundwater OVs - October, 1998 pg, 6-1
-------
Explosives (primarily TNT, DMT, RDX, HMX, and tetryl) were the most prevalent contaminants of
concern in each of these media, although other contaminants (metals, pesticides, PCBs, and volatile and
semivolatile organic compounds) were also identified.
The planned use of JOAAP as outlined in Public Law 104-106, provided the basis for estimating the
extent and duration of exposure to the contaminants at JOAAP. People who were determined to be
potentially exposed to the contaminants at JOAAP include recreational park users and industrial workers.
The risk assessment also included assessment of a hypothetical residential exposure scenario for
comparison purposes. These persons were assumed to be exposed to contaminated soils, surface water,
and sediments either by dermal contact or by incidental ingestion. Exposure to groundwater was
assumed to be via dermal contact, ingestion of drinking water, and inhalation of vapors while showering.
Appendix A, provides the summaries of reasonable maximum exposure (RME) risk characterizations
done within the Baseline Risk Assessment studies at JOAAP.
Risks and hazards posed to receptors were calculated for each site at the MFG and LAP Areas. Table 6-1
identifies those sites and media where the calculated risk levels exceed 1 x 10"* or the hazard index
exceeds 1.0 for a recreational user and an industrial worker. Surface water was found to pose risks
exceeding 10'6 in the TNT Ditch located at Sites M6 and M7 because of the periodic run-off of
explosives contaminated soils into the surface water. Remediation of the soils and sediments in this
ditch will serve to prevent the run-off of explosives into the surface water and effectively reduce any
risk. The sediments that posed unacceptable risks and hazards are found in drainage ditches that are
often dry rather than sediments in streams, creeks, and lakes present at JOAAP, and are considered to be
similar to soils in terms of exposure pathways.
The risk assessment also modeled potential risks to consumers of fish caught in JOAAP streams, and
identified potential risks caused by the estimated presence of arsenic, beryllium, and explosives in the
fish tissue. Subsequently, as part of the Ecological Risk Assessment, fish samples were collected and
these analytes were not detected in the fish tissue. This indicates that the model did not represent actual
site conditions, and that the consumption of the fish does not pose a risk.
At sites where calculated risks or hazards exceeded the acceptable levels for future recreational park
users and industrial workers, remedial alternatives were developed. These remedial alternatives will be
implemented as final for all GRUs, for all industrial park SRUs and for certain SRUs on USDA lands in
order to reduce the risk to acceptable levels. These remedial alternatives are considered interim for the
remaining SRUs on USDA lands. Notable exceptions to this are sites Mil, Ml3, and L4, where risks
and hazards do not exceed the acceptable levels, but because these sites contain landfills, remediation is
required to comply with State regulations.
Based on information presented in the human health risk assessments, the principal threat to human
health results from potential exposure to explosives in soil. DNT is identified by USBPA as a probable
human carcinogen, and both TNT and RDX are identified by USEPA as possible human carcinogens.
Risks and hazards calculated for groundwater are based on the assumption that new wells are installed
into areas of contaminated groundwater and then used. This scenario is unlikely to occur because the
majority of the contaminated groundwater resides in the glacial drift aquifer that does not provide usable
quantities of groundwater and is not used as a water supply at JOAAP.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 6-2
-------
TABLE 6-1
Summary from Baseline Risk Assessment of Sites Where
JO6 and Hazard Indices Exceed 1.0 for Recreational Users and Industrial Workers
Site ID
M1
M2
M3
M4
MS
M6
M7
M8
M9
M10(a)
M11
M12
M13
M14
M15
M16
M17
M18
L1
L2(b)
L3
L4
L5
L6(c)
L8
L9
L10
L11
L12
L13
L14
L15
L16
L17
L18-L23
L23A
L24-L31
L32
L33-L35
Receptor
Recreational User
Recreational User
Recreational User
Recreational User
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial/Recreational
Recreational User
Recreational User
Industrial
Recreational User
Industrial
Industrial
Industrial
ndustrial
Recreational User
Recreational User
Recreational User
Recreational User
Recreational User
ndustrial
Recreational User
Recreational User
Recreational User
Recreational User
ndustrial
Recreational User
Recreational User
ecreational User
ecreational User
ndustrial
ndustrial
ecreational User
ecreational User
ecreational User
dustrial
ecreational User
Soil
Risk
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Hazard
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Groundwater
Risk
X
X
X
X
X
X
X
X
Hazard
X
X
X
X
X
X
X
Surface Water
Risk
X
X
(a) i ne central toluene tank farm is located in the industrial park
(b) Oil P ts at L2 were remediated during a removal action in 1996.
(c) Site L6 was remediated during a removal action in 1997
Hazard
Sediment
Risk
X
X
X
X
Hazard
X
X
JOAAP Record of Decision - Soil & Groundwater OVs - October, 1998
pg. 6-3
-------
ft/,? Assessment of Risk tn Prairie Workers
The risk of exposure to contaminants in soil for workers conducting prairie establishment and
maintenance activities on the property currently managed by, or intended for the USDA will be evaluated
consistent with USEPA current risk assessment guidance for Superfund. The Army, USEPA and IEPA
will conduct this evaluation of risks to prairie workers in consultation with the Secretary of Agriculture
and the Illinois Department of Natural Resources. This evaluation will exclude USDA properties
contained within SRUs 4, 6 and 7. After such evaluation, final soil RGs will be established.
Subsequently, volumes and areas requiring remedial action will be determined. Final remedial actions
for USDA soils will be selected in accordance with the NCP.
6.2 Ecological Risk Assessment
ft 2, 1 Ewheical Risk Assessments Conducted
In addition to the human health risk assessment, the Army conducted an ecological risk assessment
(ERA). The ERA documents are "Final Ecological Risk Assessment, Phase 1" (11/1/94), and "Final
Phase 2 Aquatic Ecological Risk Assessment" (1/2/97). The ERA process is designed to provide the
justification for performing remedial actions based upon risk to the environment, if unacceptable risks
exist or will exist in the foreseeable future. The ERA findings are described below.
Hazardous chemical substances were not found to significantly impact the aquatic components of the
JOAAP ecological system. Water quality, habitat, and the health of fish, crayfish, invertebrates, and
other aquatic organisms were examined in Grant, Jackson, Jordan, Prairie, and Spoil Bank Creeks. Fish
at JOAAP appear healthy and histopathological evidence found no contaminant-related toxic effects.
Tissue samples from fish and crayfish were analyzed for explosives (none detected), metals (zinc, iron
and barium detected, but below action levels), PCBs (none detected), and pesticides (trace 4,4'-DDE
detected at normal background levels). Surveys of the sediment macroinvc-rtebrates found no
biologically significant differences related to hazardous chemicals between the streams on JOAAP and
those off the installation. Water quality was degraded at one study area; however, the condition was not
linked to hazardous chemicals of concern.
Hazardous substances were not found to significantly impact the terrestrial components of the JOAAP
ecological system. Habitat, historical biological surveys, soil toxicity, and the health of small mammals
and deer were examined. Tissue samples from rodents and deer within the study areas were analyzed for
heavy metals and explosives. These tissues were found to not contain metals at concentrations above
those found in samples collected from the reference sites (i.e., background). Additionally, explosives
were found to not accumulate in these tissues. [Note: The deer tissue study was focussed on the
consumptability of the meat, not on the ecosystem impacts of the contaminants, if any, in the deer.] A
rodent biomarker study was conducted to compare rodents on JOAAP and off-site on the basis of bone
marrow micronucleus assays, histopathology, and hematology. The variations between on-site and off-
site rodents were found to be either statistically insignificant or unrelated to possible chemical exposure.
Safe soil concentrations for hazardous chemicals representing preliminary remediation goals (PRGs)
were developed for the protection of the Upland Sandpiper, a State-listed endangered species. Several
conservative assumptions were used to calculate the future and current use PRGs for this grassland bird.
For example, future use PRGs were based on increasing prairie remnant acreage at a portion of the
facility without first addressing the soil contamination at these areas. Under the future use scenario, for
the 5 out of 12 months that the species resides at JOAAP, 100% of the sandpipers' time was assumed to
be spent on-site. Uncertainties associated with the ecological PRGs include the lack of toxicity
JOAAP Record of Decision- Soil & Groundwater OUs - October, 1998 P8-6-4
-------
information on the effects of explosives on avian species and the use of data from other avian species for
the Upland Sandpiper. Only one avian study on the toxicity of polynuclear aromatic hydrocarbons
(PAHs), chrysene, was found. This toxicity value was applied to other PAHs of concern because of the
similar physiological mode of action of this chemical class. This technique introduces large uncertainty
to the PRGs provided for PAHs other than chrysene. Population surveys of the Upland Sandpiper
conducted by the Illinois Department of Conservation over several years beginning in 1983 indicate the
populations of these birds are relatively stable on 'JOAAP and represent some of the best biological
resources in northern Illinois. This is primarily due to the extensive acreage of grazed land and prairie
remnants at JOAAP that provide habitat for grassland bird species. The areas contaminated with
chemicals of concern at JOAAP represent a small percentage of the 23,542-acre installation and are areas
that were previously developed for industrial activities (contain buildings, roadways, parking lots,
railroad tracks, etc.) and currently do not provide desirable habitat for the Upland Sandpiper.
Soil toxicity tests conducted on field-collected soils at several JOAAP study sites ibund evidence of
excess toxicity for earthworm survival and growth, plant seed germination and growth, and soil
microrganisms. Some tests recorded toxicity due to metals and RDX, however, the greatest adverse
effects for all tests were found in soils with TNT contamination. The spatial scale where these toxic
effects are found is very small (less than 1%) relative to the entire JOAAP ecological system.
A survey of the endangered and threatened plant and animal species was conducted at the Joliet Army
Ammunition Plant and Joliet Training Area and completed in 1994 (Glass, 1994).
&2,2 Protection of Ecological Resources
The largest portion of contaminated soils is concentrated in land that is designated for industrial parks
under PL 104-106 and is not intended for ecosystem development.
Exposure levels for ecological resources that are protective of the environment and compatible with
development of the tallgrass prairie will be determined for the USDA lands. Exposure levels will
initially be established by a site-specific biological technical assistance group (STAG) that shall include,
at a minimum, representatives of the Army, USEPA, IEPA, USDA, Illinois Department of Natural
Resources, and Department of Interior/US Fish and Wildlife Service. The exposure levels established by
the BTAG shall be compared to the human health risk-based remediation goals established for the USDA
lands. Appropriate final remedial actions for USDA soils will be developed, evaluated and selected in
accordance with the NCP.
6.3 Remedial Action Objectives TRAOs)
The primary objective of the cleanup at JOAAP is to effectively mitigate, minimize threats to, and
provide adequate protection of human health and the environment. To meet this objective, the Army
developed remedial action objectives for the soil and groundwater OUs. The objectives of the final
remedial actions are summarized as:
1. Clean up contaminants to the site-specific and chemical-specific remediation goals (RGs);
2. Prevent human and environmental exposure to contamination at concentrations above the
RGs;
3. Eliminate soil contamination as a continuing source of groundwater contamination;
4. Prevent migration of contaminants; and
5. Actions will not leave behind any characteristically hazardous RCRA wastes, except those
contained within the capped landfills of SRU6.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 6-5
-------
The objectives of the interim remedial actions are summarized as:
1. Eliminate soil contamination as a continuing source of groundwater contamination; and
2. Prevent migration of contaminants.
6,4 Development nf Remediation Goals TROs)
Human health risk models and other appropriate USEPA and IEPA criteria were used to establish the
RGs for each of the 79 contaminants of concern identified in the soils, and for each of the 40
contaminants of concern identified in the groundwater. In conjunction with the human health and
ecological risk assessments, the RG values serve as threshold criteria for identifying sites that require
remedial action. The final RGs were established to develop concentrations of contaminants that provide
a "safe" level. For carcinogens, a "safe" level is defined as a concentration in soil or water that does not
pose a risk that exceeds the 1 x lO"6 level. For non-carcinogens, a "safe" level is defined.as a
concentration that does not pose a hazard that exceeds the 1.0 level.
Final RGs for soil were established for industrial land use (industrial parks, VA cemetery, WCLF)
scenarios. Ecological PRGs were not used in the development of final RGs for the industrial areas since
they were considered inappropriate given the future land use. Table 6-2 lists the final RGs for soil.
Interim soil RGs are presented for USDA lands in Table 6-2. Final soil RGs that are protective of human
health and the environment will be incorporated into the Final ROD for USDA lands for SRUs 1 2 3
and 5. ' '
Table 6-2 also presents the final RGs for groundwater. IEPA Class I and Class II groundwater standards
were used as the RGs for potable and industrial uses, respectively. When IEPA standards were not
available for a particular compound, risk-based concentrations (RBCs) were developed and used as the
RGs. The RBC calculations assumed that groundwater would be used by an industrial worker and used
the 1 x 10 level for carcinogens and 1.0 level for non-carcinogens.
The RGs for groundwater are dependent on the aquifer in which the contamination is present. If
contamination is present in the glacial till, the Illinois Class II groundwater quality .standards will be
used, and if contamination is present in the Silurian Dolomite, the Illinois Class 1 groundwater quality
standards will be used. Groundwater management zones (GMZs), as described in Section 9.2.1.1, will be
established around areas where groundwater is contaminated.
6.5 ExceedancesnfRf^s
The Army compared the concentrations of 79 contaminants of concern with their respective RGs (Table
6-2) and determined that 19 contaminants exceed RGs in soil. On the basis of this review, the Army
narrowed its focus to the cleanup of specific sites. RGs were used both for surface and subsurface soils
However, the Army reserves the right to work with USEPA and IEPA to perform risk management
review and address unknown conditions encountered during remedial actions. The same analysis
determined that 13 contaminants exceeded their respective RGs in the groundwater.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 „„, 6-6
-------
Table 6-2; Soil. Sediment, and Grnundwater Remedial Onak (HP/P iiP/Tf>
Contaminant
Soil-
USDA **{!)
Soil-
Industrial (l)
Class I (2)
Groundwater
Class II (3)
Groundwater
Explosives
1,3,5-TNB
1,3-DNB
2,4,6-TNP
2,4,6-TNT
2,4-DNT
2,6-DNT
2-NT
DNAP
HMX
NB
RDX
Tetryl (5)
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (+3)
Chromium (+6)
Cobalt
Copper
Iron
Lead (6)
Manganese
Mercury
Nickel
Selenium
Silver
rhallium
Vanadium
Zinc
180
370
7,400
290
13
13
10,000
7,400
10,000
1,800
78
7,400
100
200
4,100
190
8.4
8.4
10,000
4,100
10,000
1,000
52
4,100
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,000,000
1,500
5.7
260,000
2
3,000
110,000
11,000
220,000
150,000
1,000,000
1,000
450,000
1,100
74,000
18,000
18,000
290
26,000
1,000,000
1,000,000
820
3.8
140,000
2
1,700
13,000
1,600
120,000
82,000
610,000
1,000
150,000
610
41,000
10,000
10,000
160
14,000
610,000
NA
6
50
NC
NC
5
100
100
NC
NC
5,000
7.5
150
NC
NC
NC
50
NC
NC
5,000
NA
24
200
NC:
NC:
50
1,000
1,000
NC:
NC
5,000
100
10,000
NC:
NC
NC:
511
NC
NC:
10,000
Volatiles
1,1,1 -Trichloroethane
1 , 1 ,2-Trichloroethane
1, -Dichloroethane
1 ,2-Dichloroethane
1 ,2-Dichloroethene
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
200
5
700
5
70
1,000
50
3,500
25
200
KBC(4)
Groundwater
5.1
10
200
9.5
0.42
0.42
5,100
200
5,100
51
2.6
200
100,000
NA
NA
NC
NC
NA
NA
NC
NC
NC
NA
NA
NA
NC
NC
NC
NA
NC
NC
NA
NA
NA
NA
NA
NA
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
pg. 6-7
-------
Table 6-2: Snil,
water Remedial
Contaminant
ithylbenzene
etrachloroethene
Toluene
Trichloroethene
Xylenes
Semivolatile?
Soil-
USDA **(!)
\\ ,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2-Methylnaphthalene
2-Methylphenol
4-Methylphenol
|1,2.4-Trichlorobenzene
.ccnaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
3enzo(g,h,i)perylene
tenzo(b)fluoranthene
3enzo(k)fluoranthene
Benzyl alcohol
tis(2-ethylhexyl)phthalate
Butyl benzyl phthalate
Chrysene
Dibenz(a,h)anthracene
Dibenzofuran
Diethyl phthalate
)i-n-butyl phthalate
pi-n-octyl phthalate
[Fluoranthene
^luorene
lexachlorobenzene
Indenofl ,2,3-cd]pyrene
Naphthalene
Phenanthrene
Phenol
[Pyrene
NC
1,000
1,000
Soil-
Indiistrial (l)
NC
610 ,
NC
1,200
10,000
10,000
10,000
10,000
0,000 -
0,000
5.4
12
NC
1,000
NC
1,000
780
0.78
10,000
10,000
10,000
10,000
10,000
10,000
10,000.
10,000
10,000
7.8
10,000.0
10,000
10,000
10,000
NC
NC
NC
NC
NC
NC
NC
ISS I (2)
ndwater
NC
5
100
700
— -— • — ^-^^—
5
1,000
5
10,000
Class II (3)
Groundwater
NC
25
500
1,000
25
2,500
25
10,000
RBC (4)
Groundwater
NC
NA
NA
NA
NA
NA
NA
NA
°
1
10,000
8
78
NC
410
iNt^
NC
NC
NC
NC
NA
NC
NC
10,000
10,000
240
10,000
NC
NC
: 10,000
10,000
10,000
10,000
NC
NC
NC
NC
NA
NA
NC
NC
NC
NC
NC
NC
NC
NC
NA
NA
NC
NC
NC
NC
1 -
NC
NC
NC
NC
5,100
510
NC
NC
1N(_
NC
NC
NC
NC
NC
NC
NC
NC
NC
iNL, |
NC
NC
NC
NC
NC
NC
NC
NC
NC
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
pg. 6-8
-------
Table 6-2: Soil. Sediment, and Groundwater Remedial Goals ffig/g. jig/L^
Contaminant
Soil-
USDA **(!)
Soil-
Industrial (l)
Class I (2)
Groundwater
Class II (3)
Groundwater
Anions
Nitrate/Nitrite
Phosphate
Phosphorous
Sulfate
Pesticides. PCRs /
Chlordane
DDD
DDE
DDT
Dieldrin
Endrin
Heptachlor
Heptachlor epoxide
Isodrin
PCB 1254
PCB 1260
)rganics-Special
EPH
1,000,000
370,000
370,000
456
1,000,000
200,000
200,000
456
10,000
NC
NC
400,000
100,000
NC:
NC:
400,000
f7)
6.6
36
25
25
0.54
1,100
1.9
0.94
1,000
1
1
4.4
24
17
17
0.36
610
1.3
0.63
1,000
1
1
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC:
NC:
NC:
NC:
NC:
NC:
NC
NC:
NC
NC
NC:
RBCr-O
Groundwater
NA
NC
NC
NA
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
2,500
NC
NC
NC
Notes
** TJie gray-shaded cells indicate interim RGs
(1) The soil RGs for all contaminants except PCBs apply to both surface and xuhsurface soils.
(2) Illinois Groundwater Quality Standards for Class I Groundwater (35IAC 620.410)
(3) Illinois Groundwater Quality Standards for Class II Groundwater (351 A C 620.420)
(4) Risk-Based Concentration (RBC) for Groundwater based on USEPA commercial/industrial
exposure scenario as presented in PRG Report (OHM, 1996).
(5) Tfte USEPA, IEPA and the Army agreed to base the RG for tetryl on one of its primary
breakdown products, dinitroaminophenol (DNAP), because of concern over the reliability of the
risk-based value applied to tetryl at the time.
(6) The USEPA, IEPA and the Army agreed to revise the RGfor lead to 1.000 fw/g, over USEPA 's
screening level of 400 ug/g. This adjustment was made because exposure of children to the
lead-contaminated soils is substantially less frequent than could occur in a residential setting
and the decreased sensitivity of adults (including workers at the site) to the effects of lead.
(7) The cleanup goal for PCBs is 1 ug/g for surface soils (upper ten inches of soil) and 10 ug/g for
subsurface soils. These goals match those established under TSCA for non-restricted access
areas, and were agreed to by the USEPA, IEPA and the Army.
NC chemical is not a contaminant of concern in given media
NA Not available (for Class I and Class II Groundwater columns), or
• Not applicable (for RBC Groundwater column)
JOAAP Record of Decision-Soil & Groundwater OUs -October, 1998
PR- 6-9
-------
6.6 No Further Action Sites
Twenty-eight (28) sites and two subareas suspected as having contaminated soil were investigated during
the RI/FS and Risk Assessment process and found to have no evidence or contamination, no
contamination, or contamination at concentrations that do not pose a threat to human health or the
environment. IEPA and USEPA agree, under CERCLA requirements, no further cleanup actions are
required for these sites. Table 6-3 presents the No Further Action (NFA) sites for soil.
Groundwater underlying 41 sites and three subareas was found to have no evidence of contamination, no
contamination, or contamination at concentrations that do not pose a threat to human health or the
environment. IEPA and USEPA agree, under CERCLA requirements, no further cleanup actions are
required for the groundwater underlying these sites based on current information. Table 6-4 presents the
NFA sites for groundwater.
Table 6-3 CERCLA No Further Action Sites - Soil
Site
No.
L6
L12
L13
L15
L18
L19
L20
L21
L22
L23
Site
Description
Group 70
Doyle Lake
Group 68
Group 5
Group 8
Group 9
Group 20
Group 23
Group 25
Group 27
Which
Phase
Determined
No Action?
Removal
Action
FS
BRA
BRA
FS
FS
RI-PH1
RJ-PH1
RI-PH1
RI-PH1
Reason for NFA
Various COCs (TPH, PCBs, BNAs) were
detected at site in excess of RGs. Removal
action conducted at site to remove health and
environmental hazards.
COCs (explosives, pesticides, PCBs and
metals) detected in sediments, but exposure
pathway considered incomplete. Surface water
does not pose a risk for residents (based on
Jordan Creek analysis).
COCs (explosives) detected. Risk determined
to be within acceptable range for all scenarios
ncluding residential use.
COCs (TPHs, explosives) detected. Risk
determined to be within acceptable range for
all scenarios including residential use.
Depleted uranium cleanup conducted under
U.S. Nuclear Regulatory Commission license
at site. Closeout report prepared for
radionuclides.
Lead detected below background levels. No
other site-related contaminants identified
No site-related contamination identified at
Group 20.
No evidence to suspect soil contamination at
his sites. No soil sampling was conducted.
No evidence to suspect soil contamination at
his sites. No soil sampling was conducted.
COCs (metals, explosives) only detected in pit,
which was designated as 23A and continued in
Source of
Information
Removal Action
Report. 3/98
FS, <>/26/97, p.10-37
and 10-6
BRA, 2/3/95, p.7-63
BR A, 2/3/95, p.7-71
BRA, 2/3/95, p.7-82;
Alliant Techsystems,
9<>7
FS, 9/26/97, plO-42
RI-IM 11. 7/1/93 ,p.6-21
Rl-l'Hl,7/l/93,p.6-22
RI-l»m,7/l/93,p6-22
RI-I'1 11, 7/1/93, p6-22
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
pg. 6-10
-------
Site
No.
L24
L25
L26
L27
L28
L29
L30
L31
L32
L33
L34
L35
M6A
M10
M14
M15
Site
Description
Group 29
Group 62
Group 63
Group 64
Group 65
Group 66 .
Group 66A
Extraction Pits
Group 60
PVC Area
Former Burning
Area
Fill Area
TNT Blocking
Area
Toluene Tank
?arm
ormer Pond
ewage
reatment Plant
Which
Phase
Determined
No Action?
RI-PH1
RI-PH2
RI-PH1
RI-PH1
RI-PH1
RI-PH1
RI-PH1
RI-PH1
FS
BRA
BRA
RI-PH1
FS
RI-PH2
BRA
BRA
Reason for NFA
remedial action. No potential site-related
contaminants identified in other areas of L23.
No historical evidence of spills or areas of
concern identified at site 24.
No potential site-related contaminants
identified.
No potential site-related contaminants
identified.
No historical evidence of potential site-related
contaminants identified.
No historical evidence of potential site-related
contaminants identified. No soil samples
taken.
No historical evidence of releases or areas of
concern identified.
No historical evidence of releases or areas of
concern identified.
Soil samples analyzed for VOCs, BNAs,
pesticides/PCBs, metals and anions. No site-
related contaminants identified.
COCs (TPH, lead, zinc) are below RGs. HI
estimated to be below .01 for all scenarios
ncluding residential.
Explosives (2,4,6-TNT, RDX) detected, below
IGs. Cadmium above background level (but
well below RGs) in several samples. Both
carcinogenic risk and HI estimated well within
acceptable range for all scenarios, including
esidential.
COCs (metals, VOCs, BNAs) detected, but
well below RGs. HI estimated to be below .01
or all scenarios including residential.
Elevated metals concentrations found in
Kemery Lake sediment apparently not based
on activities at Site 35.
No samples taken within 6A. Three sets of
real soil clusters taken near perimeter of 6A
bowed no detections of explosives, VOCs.
VOCs (acetone, chloroform, toluene) detected
t concentrations that were too low (max of
.032 ug/g) to pose a threat to human health or
he environment.
COCs (BNAs, metals) detected. HI less than
.01 for all scenarios, including residential.
COCs (BNAs, metals, anions) were detected
elow RGs - except for arsenic which was
bund in one of four samples at 5. 1 ug/g
above RGs for industrial, but below probable
Source of
Information
RI-!>l!l,7/l/93,p 5-672
, and 6-23
RI-PH.2, 1 2/94, p 6- 14
R1-PII2, 1 2/94, p 6-23
Rl-Pm.7/l/93,p.p-711
and p.6.24
RI-PI II, 7/1/93, p.6-710
FS, 9/26/97, p 1-2
RI-PIII,7/l/93,p.5-711,
p.6-24
RI-PI 11,7/1/93^5-711,
p6-24
RI-Plll,7/l/93,p.5-717,
p 6-25
BRA, 2/3/95, p.9-7
FS, 9/26/97, p 10-42
RI-PHI,7/l/93,p.5-735,
p.6-25; BRA, 2/3/95,
p.7-92
Rl-Pm,7/l/93,p.5-742,
.6-26; BRA, 2/3/95,
.7-95. 9-7
Rl-Pm,7/l/93,p.5-781,
6-27
RI-PH2, 5/93, p.5-255,
S, 9/29/97, p.2-18
RI-PH2, 5/93, p.5-506,
.6-13
RA, 12/5/94, p. 3-55,
.9-26
R.1-PU2, 5/93,p.5-641;
RA. 12/5/94, p. 3-57
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
PS- 6-11
-------
Site
No.
•••••••••
•M^_^_^_
Xyfl/f
IVliO
M17
MIS
Site
Description
Motor Pool Area
Laundry Facility
Herbicide
torage
Which
Phase
Determined
No Action?
""•••— «»——w,^-»«
— — — — ^— — ^^_
RI-PH2
RI-PH2
RI-PH2
Reason for NFA
background levels]. His were less than 1.0 for
all scenarios, including residential. Maximum
carcinogenic risks for the site were estimated
to be 1.3E-5 for the residential and 2. 1E-6 for
industrial workers. These risks are less than
the less stringent acceptable limit (1E-4) [see
note 1, below]. M15 was thus considered to
require no further action.
COCs (BNA, pesticides, metals) were detected
at Ml 6. Site related contaminants and
potential risks at site considered low enough to
equire no further action.
No site related contaminants were detected at
M17.
No site related contaminants were detected at
W18.
Source of
Information
RI-PH2, 5/93, p.5-664,
p6-20
RI-PH2, 5/93, p. 5-673,
6-21
RJ-PH2, 5/93, p. 5-673,
6-21
Note: (1)
Key:
BNA
BRA
COC
FS
HI
RG
RI-PH1
RI-PH2
TPH
VOC
After the BRA, the carcinogenic risks at Ml 5 were recalculated because an improperly
high concentration of beryllium was used. Risks were found to be below l.OE-6 for all
scenarios under this recalculation.
Base-Neutral-Acids (Semivolatiles)
Baseline Risk Assessment
Contaminant of Concern
Feasibility Study
Hazard Index
Remedial Goal
Remedial Investigation, Phase 1
Remedial Investigation, Phase 2
Total Petroleum Hydrocarbon
Volatile Organic Compound
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
pg. 6-12
-------
Table 6-4 CERCLA No Further Action Sites - Groundwatc-r
Site No,
L4
L5
L6
L7
L8
L9
L10
Lll
L12
L13
L15
L16
Site
Description
Landfill Area
Salvage Yard
Group 70
Group 1
Group 2
3roup 3
3roup 3 A
rest Site
Doyle Lake
aroup 68
jroup 5
3roup 6
Which
Phase
Determine!
No Action?
PRO
PRO
PRO
RG
RG
^I-PH1
RG
U-PH1
U-PH1
U-PH1
U-PH1
U-PH1
Reason for NFA
COCs (VOCs, anions, metals)
detected in two wells at L4 are below
the RGs. Carcinogenic risks for
residential use is estimated at 2E-5;
31 is 1E-4. Groundwater is not
considered to pose a threat to human
lealth or the environment at L4.
COCs (VOCs, BNAs, anions, metals)
are below the RGs. The HI is
estimated to be 3.0 for a residential
use scenario. Hazards are due to
manganese found in the wells
screened in the glacial till, a Class II
aquifer, which is not capable of
yielding usable quantities of water.
COCs (VOCs, BNAs, anions, metals)
detected are below the RGs.
Carcinogenic risk (3E-4) and HI (1.0)
were based on a residential use
scenario. Risks and hazards were due
o arsenic found in a well screened in
he glacial till, a Class II aquifer,
which is not capable of yielding
usable quantities of water.
COCs (VOCs, BNAs, anions, metals)
detected at L7 are below the RGs. HI
0.01) was based on a residential use
cenario. The L7 groundwater is not
onsidered to pose a threat to human
lealth or the environment.
COCs are below the RGs and do not
pose a threat to human health or the
nvironment.
^0 contamination detected at site.
COCs are below the RGs and do not
>ose a threat to human health or the
nvironment.
^o contamination detected at site.
Mo contamination detected at site.
^Jo contamination detected at site.
^o contamination detected at site.
^Fo contamination detected at site.
Source of Information
RI-P1I1, 7/1/93, p. 5-273;
BRA, 2/3/95, p.9-4; PRG
document, 4/1/96
RI-PU 1,7/1/93, p. 5-219;
BRA, 2/3/95, p.9-4; PRG,
4/1/96
RI-PH 1,7/1/93, p. 5-335;
BRA, 2/.V95, p.9-5; PRG,
4/1/96
RI-PH 1,7/1/93, p. 5-367;
BRA, 2/3/95, p.9-5; PRG,
4/1/96
PRG, 4/1/96
RJ-P1 1 1,7/1/93, p5-451
PRG, 4/1/96
RI-PH 1,7/1/93, P6-15
RI-PHI. 7/1/93, P6-16
EU-PHl, 7/1/93, p6- 17
EU-PllI,7/l/93,p6-17,18
EU-PHl, 7/1/93, p6-17,18
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 Revision ] JO/27/98 pg. 6-13
-------
Site No.
[Which
Phase
Site betermmec
Description GVo Action?
LI 7 (Group 7
L18
L19
L20
L21
L22
L23
L23A
L24
L25
L26
proup 8
Group 9
Group 20
Group 23
Group 25
Group 27
1
Reason for NFA
Source of Information
RI-PH1 INo contamination detected at site. (RI-PH 1 7/1/93 p6-l 7 1 8
PRG bOGs are below the RGs and do not PRG, 4/1/96
pose a threat to human health or the
(environment. |
PRG
RI-PH1
RI-PH 1
RI-PH1
RI-PH1
Group 27 [RI-PH1
Group 29
Group 62
Group 63
L27 proup 64
L28
L29
L30
L31
L32
L33
L34
L35
M2
M4
/
M6A ]
f-
Group 65
Group 66
Group 66A
Extraction Pits
Group 60
PVC Area
Former Burning
\rea
-ill Area
explosive
Burning Ground
^ead Azide
^jea
W Blocking I
^rea
RI-PH 1
RI-PH1
RI-PH1
RI-PH1
RI-PH2
RI-PH 1
RI-PH 1
RI-PH 1
RI-PH 1
RI-PH 1
RI-PH1
EU-PH1
PRG
3RG
U-PH2 f
f
<.
i
(COCs are below the RGs and do not
pose a threat to human health or the
(environment.
No contamination detected at site.
No contamination detected at site.
No contamination detected at site.
No contamination detected at site.
No contamination detected at site.
No evidence of contamination, based
on historical review and site visit.
PRG, 4/1/96
RI-PH 1, 7/1/93, p6-21
RI-PI 11, 7/1/93, p6-22
EU-PHl, 7/1/93, p6-22
U-PI 11, 7/1/93, p6-22
U-PI11, 7/1/93, p6-22
RI-PH 1, 7/1/93, p6-23
No contamination detected at site. JRI-PI { 1 7/1/93, p6-23
No significant contamination found.
No site-related contaminants found.
COCs (1,3-DNB, anions, metals) are
selow RGs and do not pose a threat to
human health or the environment.
No evidence of contamination, based
on historical review and site visits.
No evidence of contamination, based
on historical review and site visits
No evidence of contamination, based
on historical review and site visits.
No evidence of contamination, based
on historical review and site visits.
No contamination detected at site.
RI-PH I, 7/1/93, p6-23
RI-PH 1, 7/1/93, p6-23
RI-PH 1, 7/1/93, p.5-709,
RI-PI 12, 1 2/5/94, p6- 14
RI-PI 11, 7/1/93, p6-24
RI-PI II, 7/1/93, p6-24
RI-PI II, 7/1/93, P6-25
RI-PI 11, 7/1/93, p6-25
U-PI!l,7/l/93,p6-25
No contamination detected at site. [RI-PI 1 1 , 7/ 1 /93 , p6-26
"to contamination detected at site.
^OCs are below the RGs and do not
Jose a threat to human health or the
mvironment.
-OCs are below the RGs and do not
)ose a threat to human health or the
mvironment.
'our monitoring wells (2 on M6A, 2
>n perimeter) installed and sampled.
X)Cs (metals, explosives) are below
tie RGs and do not pose a threat to
luman health or the environment.
U-PH1, 7/1/93, p6-26
PRG, 4/1/96
>RG, 4/1/96
U-PH2, 5/30/93
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 Revision 1--JII/27QS. pg. 6-14
-------
Site No.
M9
M10
Mil
M12
M14
M15
M16
M17
M18
Site
Description
Northern Ash
Pile
Eastern Toluene
lank Farms
Landfill
Sellite
Manufacturing
Area
Former Pond
Area
Sewage
Treatment Plant
Motor Pool
/\rea
Laundry
acility
-lerbicide
torage Area
Which
Phase
Determined
No Action?
PRO
PRO
PRO
PRO
RI-PH2
RI-PH2
RI-PH2
RI-PH2
*I-PH2
Reason for NFA
COCs are below the RGs and do not
pose a threat to human health or the
environment.
COCs are below the RGs and do not
pose a threat to human health or the
environment.
COCs are below the RGs and do not
pose a threat to human health or the
environment.
COCs are below the RGs and do not
pose a threat to human health or the
environment.
Based on the RI-PH2 finding of no
ontaminants identified.
Based on RI-PHl finding of no COCs
nd recommendation in RI PH2.
Based on RI-PHl finding of no COCs
nd recommendation in RI PH2.
Based on RI-PHl finding of no COCs
nd recommendation in RI PH2.
3ased on RI-PHl finding of no COCs
nd recommendation in RI PH2.
Source of Information
PRG, 4/1/96
PRG, 4/1/96
PRG, 4/1/96
PRG, 4/1/96
RI-PH2, 5/30/93, P6-18
RI-PHl, 7/1/93, p6-13,
RI-PH2, 5/30/93, p6-20
RI-PH2, 5/30/93, P6-20
RI-P1 12, 5/30/93, p6-21
RI-PH2, 5/30/93, p6-21
Key:
BNA Base-Neutral-Acids (Semivolatiles)
BRA Baseline Risk Assessment
COC Contaminant of Concern
FS Feasibility Study
HI Hazard Index
PRO Preliminary Remediation Goal
RG Remedial Goal
RI-PHl Remedial Investigation, Phase 1
RI-PH2 Remedial Investigation, Phase 2
TPH Total Petroleum Hydrocarbon
VOC Volatile Organic Compound
[END OF SECTION]
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 Revision I 10/27/98 pg. 6-15
-------
-------
7 DESCRIPTION OF ALTERNATIVES
The alternatives evaluated for the soil OU and the groundwater OU are described in this Section The soil
OU contains seven SRUs for which a total of 32 remedial alternatives were analyzed in detail The
groundwater OU contains three GRUs for which a total of 14 remedial alternatives were analyzed in
detail. Some of these alternatives are common among the SRUs and GRUs. In addition some
alternatives have several common remedial actions (e.g., soil excavation). These common alternatives or
actions are described once and referred to, when appropriate, under each SRU's or GRU's description
Exceptions from the general description are noted under each alternative's description .
7.1 Soil Operable Unit
7,1,1 Common Sail A (tentative
The No Action and the Institutional Controls alternatives are common to all SRUs.
7.1.1.1 Alternative 1 : No Action
Under this alternative, the U.S. Army would take no action to prevent exposure to contaminated soil The
NCP and CERCLA as amended by SARA require that the No Action alternative be evaluated to establish
a baseline for comparison of other alternatives, especially, in terms of cost and protection of human health
and the environment. This alternative would neither eliminate nor reduce the exposure of humans or the
environment to the contaminants of concern, and the existing risk to humans and the environment would
remain. There is no implementation time or cost associated with the No Action alternative because no
additional remedial activities are implemented.
7.1.1.2 Alternative 2: Institutional Controls
The Institutional Controls alternative was developed to provide actions that may be taken to limit human
exposure to the contaminated soil. This alternative is usually not effective at reducing the toxicity
mobility, or volume of contaminants, but it would reduce the probability of physical contact with the
contaminated soil, thereby reducing risk to human health. The Institutional Controls alternative involves
the following:
• Excavation that may cause plume migration or any other groundwater disturbance would be
prohibited. These restrictions would be included in deed or leasing agreements.
• Fences and signs would be placed around all currently unfenced sites and an inspection and
maintenance program of these fences and signs would be implemented.
• Risks associated with future land use would be specified in the deed, along with a calculation
method that utilizes all available and relevant data and follows currently acceptable USEPA
guidelines for human health risk assessments.
• Five-year review plan would be implemented. Five-year reviews are required by the NCP at all
sites where hazardous chemicals remain at the site above levels that allow for unlimited use and
unrestricted exposure. The review would present the analytical data and would include a
determination of whether additional remedial actions are required at the sites under this SRU.
Natural attenuation processes are considered part of this alternative. Natural attenuation processes
include biological degradation, dispersion, and dilution of contaminants. It should be noted that these
processes are not effective for the types and concentrations of contaminants in soils present in the SRUs
at JOAAP. Although this alternative would not result in the treatment of soil or the significant reduction
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998 pg. 7.1
-------
of contaminant concentration, the Institutional Controls alternative would limit potential human exposure
to the contaminants of concern, but would not mitigate localized environmental impacts.
7,1,2—Common Soil Actions
As previously mentioned, most of the alternatives have common operations. These actions are described
below and then referenced later under the description of each alternative. Any deviation from the general
description is noted under the description of each alternative.
7.1.2.1 Soil Excavation for Treatment or Disposal
Contaminated soil will be excavated from the various subareas within each site, loaded into trucks, and
transported to a central treatment area for stockpiling. Conventional earthmoving equipment would be
used for excavation. Soil excavation would continue until sampling confirms that concentration levels in
the soil are below RG levels. If necessary, excavated areas would be backfilled for safety reasons and to
avoid ponding of surface runoff with soil from an on-site borrow location. Some treated soil could also
be used as clean backfill at any on-site location that does not require structural fill. Depending upon the
time schedule for excavation, this may or may not be the same location from which the soil was removed.
Backfilled areas would be regraded to conform to the surrounding topography. Most of these backfilled
areas would be revegetated with plants consistent with the future use of the area.
7.1.2.2 Confirmatory Sampling
The limits of excavation will be determined primarily based on the RI/FS maps and data and by visual
observation of stained soil. These limits will be confirmed using field screening tests, in accordance with
a sampling plan approved by the USEPA and IEPA, with final confirmatory samples (of contaminants of
concern and TCLP analyses, as appropriate) analyzed at a laboratory.
7.1.2.3 Soil Transportation
It would be impractical and extremely expensive to establish a separate treatment area at each site in a
SRU. Therefore, a central treatment area would be established in the MFG Area to process and bio-treat
explosives contaminated soils because the majority of this contaminated soil is within the MFG Area.
Trucks would be used to haul the soil to the treatment area. Trucks transporting soil from the LAP Area
to the treatment area in the MFG Area may have to cross Illinois Route 53 and must comply with the
Regulations of Illinois Department of Transportation.
7.1.2.4 Soil Preparation for Treatment
After reaching the treatment area, contaminated soil would be stored in a stockpile area. Soil would be
blended and screened within the stockpile area, and any large stones, debris, and raw TNT will be
removed using a series of shaker/separator units. Blending of hot-spot soil with less contaminated soil
would be conducted, as necessary, to obtain a homogenized soil for feed into the treatment system.
Debris and large stones will be stockpiled for possible pressure washing and will be reused or properly
disposed. Any raw TNT will be removed and stockpiled for open burn/detonation or incineration at a
permitted facility, or processed to be blended back for treatment. All trucks used to transport soil will be
routed through a wheel wash prior to exiting the treatment area. Wash water from the trucks and from the
pressure wash operation will be containerized and used as makeup water in the treatment area or sent off-
site for disposal. If unexploded ordnance (UXO) is encountered, it will be screened and removed for
open burn/detonation or for off-site incineration at a permitted facility.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg. 7.2
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7.7.2.5 Soil Disposal
The Army will use the following options that exist for disposal of treated or untreated soils. Soils will be
tested as appropriate and in accordance with procedures approved by USEPA and IEPA to determine
whether the soils are RCRA hazardous wastes and whether RGs are exceeded. Based on the results of
these tests, the disposal options for the soils will be as follows:
1. All soils which are contaminated with RCRA hazardous wastes must be:
• Disposed at a RCRA Subtitle C facility, or
• Treated and disposed at a RCRA Subtitle C facility, or
• Treated and disposed at a RCRA Subtitle D facility or may be used as subgrade or
backfill, if the soils are not characteristically hazardous under RCRA. achieve RGs, and
do not exceed LDRs under RCRA.
2. AH soils which exceed RGs and are not RCRA hazardous waste must disposed as above or:
• Disposed at a RCRA Subtitle D facility, or
• Used as subgrade fill material in capped landfills at JOAAP."
3. All remaining soils can be disposed as above, or
• Reused (e.g., as backfill).
These options are available for all soils except the PCB-contaminated soils in SRU4. Applicable final
rule-making under RCRA may amend this section.
7.7.5 SRU1: Explosives in Soil
Five alternatives were evaluated in detail in this SRU:
1. No Action (Section 7.1.1.1);
2. Institutional Controls (Section 7.1.1.2);
3. Bioremediation;
4. On-site Incineration; and
5. Excavation and Disposal
7.1.3.1 Alternative 3: Bioremediation
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section 7.1.2.1)\
• Confirmatory Sampling (Section 7.1.2.2);
• Soil Transportation (Section 7.1.2.3);
• Soil Preparation for Treatment (Section 7.1.2.4);
• Bioremediation; and
• Soil Disposal (Section 7.1.2.5).
7.1.3.1.1 Bioremediation Process
There are several ex-situ bioremediation technologies that are capable of meeting or substantially
reducing concentrations of explosives below the RGs. Ex-situ bioremediation uses microorganisms under
controlled conditions to degrade explosives contaminants in excavated soil, sludge, and solids. The
microorganisms breakdown the explosives into non-toxic end products by using them as a food source.
The end products typically are carbon dioxide (CO2). Ex-situ bioremediation includes bioslurry phase
bioremediation, in which the soils are mixed in water to form a slurry, and solid-phase bioremediation, in
which the soils are placed in a cell or building and filled with added water and nutrients. Land farming
and composting are types of solid phase bioremediation. To develop objective data on these technologies,
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 7.3
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the Army is sponsoring a Biotechnology Demonstration at the JOAAP starting in spring of 1998 In this
demonstration, five vendors will each apply their technology to soils .mpLted'wuh explosive sin
addition, a large sample of JOAAP soils has been treated using bioslurry reactor and composting.
ihd. Jn31 ^"T °f b;°remediation technology will be made based on several evaluation factors
mcludmg cost technical feasibility, performance time, environmental acceptability, and reuse of the fina
S r W 1 PUrP°Se °f I™11*'1011' ^ C°St CStimate f°r Windr°w ^posting was used as the
echanon treatment process to be compared with other alternatives. This process has been proven
i" S° t°Per "; Conpostms is a treatment process where organic compounds are biologically
f .te?ns^nied by mes°Ph'lic and thermophilic microorganisms. The- composting process
dr mass trZf m ' T^ """"i ^ *" amendment or bulki"g agent to increase porosit^ enhance
air mass transfer into the system, and enhance the microbial population that degrades he contaminants
c^±°cTioCOmPOHS?? W°HUld indU<3e three maj°r StCpS: (3) 3mendment mat£rials ^ration Srdrow
construction, and (c) windrow operation.
7.7.3.2 Alternative 4: On-site Incineration
!upd"eprati°n 'Vhe USC °f Wgh teraPeratures ranging from 1,400 to 2,200°F to volatilise and combust in
actions! yg£n °r8amC comP°nents in contaminated soils. This alternative includes the following
• Soil Excavation for Treatment and Disposal (Section 7. 1.2. 1);
• Confirmatory Sampling (Section 7.1.2.2);
• Soil Transportation (Section 7.1.2. 3);
• Soil Preparation for Treatment (Section 7.1.2.4);
• Incinerating Contaminated Soil; and
• Disposal of Incinerated Soil (Sections 7.1.2.5 and 7.1.3.2.2).
7.1.3.2.1 Incineration Contaminated Soil
inol!uHoni0nHWOtUld C°nSiSt °f mobilizinS a ^nsportable thermal destruction unit with its associated air
de ernZJ T" "T^ ™* SPecific «W* of process (e.g., rotary kiln or other) would be
biddTDroc" Pemef , Slgn ^ thr°Ugh enginee™8 ^Sn and analysis and the 'competitive
s^^ti ,' t r n0mlal °Perati°n °f the incinerator' a trial bum would be performed to
satisfy the regulatory requirements for hazardous waste incineration (40 CFR 270 1 9 and 270 62) The
18 ^ bUm W°UuW ^ demonstrate ** incinerator's capability to thermally destroy 99.99
eXpl?S1VCS 1D ^/t11 '^ alS° t0 demonsfrate the Performance of the air pollution control
°f mCinerat0r W°Uld C°nSiSt °f 24 h°UrS/da at an ***™«* feed »te of
< , M °UrSay a an **™« ed »te o
of soil/hour. Normal operation of the incinerator would produce bottom ash (treated soil)
ST' y H" /TT f sc^bber/baghouse a^mbly, and gaseous emission from the stack
nerfon v ,- COndu?ted bfore> dunng> and at the conclusion of the incineration process. The
performance objective of this technology is that the final concentrations of explosives in treated soils
would meet the RG levels and comply with ARARs.
7. J. 3.2.2 Disposal of Incinerated Soil
Incinerator ash (bottom ash and fly ash) can not be used as clean fill. It must be disposed in a landfill that
15 I'5 'f^8!,1 lf Jt " non-hazardo-, or 35 IAC 724 if it is hazardous
, J W°Uld be dlSP°Sed 3t 3 RCRA Subpart D facility- II may be de^rable
Study {° '"vestigate appropriate amendments for the ash that will allow it to
coverina t n ft' 7" ^ "* °f ^ aS fl11 material f°r the exc:ivatt;d areas and *«
oovenng it with one foot of clean soil from an on-site borrow location. For the purpose of cost
evaluation, it was assumed that the ash would be disposed at a permitted landfill.
JOAAP Record of Decision - Soil & Gronndwater OUs - October, 1998 7.4
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7.1.3.3 Alternative 5: Excavation and Disposal
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section 7.1.2.1);
• Confirmatory Sampling (Section 7.1.2.2); and
• Soil Disposal (Section 7.1.2.5).
7.1.4 SRU2: Metals in Soil
Four alternatives were evaluated in detail in this SRU:
1. No Action (Section 7.1.1.1);
2. Institutional Controls (Section 7.1.1.2);
3. Stabilization/Solidification; and
4. Excavation and Disposal.
7.1.4.1 Alternative 3: Stabilization/Solidification
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section 7.1.2.1);
• Confirmatory Sampling (Section 7.1.2.2);
• Soil Transportation (Section 7.1.2.3);
• Soil Preparation for Treatment (Section 7.1.2.4);
• Solidification/stabilization of Contaminated Soil; and
• Soil Disposal (Section 7.1.2.5).
7.1.4.1.1 Solidification/Stabilization of Contaminated Soil
The Solidification/Stabilization process involves mixing the contaminated soil with binding agents to
reduce the mobility of the contaminants of concern (stabilization) and to improve I he soil handling and
physical characteristics of the soil (solidification). A wide variety of solidification/stabilization processes
are available, along with an array of additives that may enhance the process and the finished product.
Prior to the final design of the solidification/stabilization alternative, a treatability study would be
required. This study would select the most appropriate binders for the contaminants, and test these
binders to select the one, along with any additives, that provides the optimum solidified product. The
study can also provide details on the strength, durability, resistance to leaching, ami volume increase that
can be expected of the solidified waste. For cost estimate purposes, it has been assumed that Portland
cement and sodium silicate would be used as binding agents. The performance objectives of this
technology is to bind the contaminants in a matrix so that contaminants would not leach in concentrations
in excess of RGs and TCLP limits.
Binders and additives would be added to the soil in appropriate ratios based on the (rcalability study. Soil
and the binders/additives would then be thoroughly mixed in a mixer, poured into constructed forms (e.g.,
1-meter square blocks) and test forms, and allowed to cure until the desired hardness is achieved before
final disposal. Test forms would be analyzed using TCLP test and/or other tests to determine the
acceptability of the solidified/stabilized material. When confirmation is received that the solidified waste
meets all requirements, the solidified material will be stockpiled for subsequent transportation and
disposal.
7.1.4.2 Alternative 4: Excavation and Disposal
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section 7.1.2.1);
• Confirmatory sampling (Section 7.1.2); and
• Soil Disposal (Section 7.1.2.5).
JOAAPRecord of Decision -Soil & Groundwater OUs - October, 1998 pg. 7-5
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7.1.5 SRTJ3: Frpfpsives and Metals in Soil/Sediment
Five alternatives were evaluated in detail in this SRU:
1. No Action (Section 7.1.1.1);
2. Institutional Controls (Section 7.1.1.2);
3. Bioremediation and Disposal;
4. On-site Incineration; and
5. Excavation and Disposal.
7.1.5.1 Alternative 3: Bioremediation and Disposal
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section 7.1.2.1);
• Confirmatory Sampling (Section 7.1.2.2);
• Soil Transportation (Section 7.1.2.3);
• Soil Preparation for Treatment (Section 7.1.2.4);
• Bioremediating explosives contaminated soil (Section 7.1.3.1.1); and
• Soil Disposal (Section 7.1.2.5).
7.1.5.2 Alternative 4: On-site Incineration
Incineration is the use of high temperatures ranging from 1,400 to 2,200°F to volatilize and combust (in
the presence of oxygen) organic components in contaminated soils. This alternative includes the
following actions:
• Soil Excavation for Treatment or Disposal (Section 7.1.2.1);
• Confirmatory Sampling (Section 7.1.2.2);
• Soil Transportation (Section 7.1.2.3);
• Soil Preparation for Treatment (Section 7.1.2.4);
• Incinerating Contaminated soil (Section 7.1.3.2.1); and
• Disposal of Incinerated Soil (Sections 7.1.2.5 and 7.1.3.2.2).
7.1.5.3 Alternatives: Excavation and Disposal
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section 7.1.2.1);
• Confirmatory Sampling (Section 7.1.2.2); and
• Soil Disposal (Section 7.1.2.5).
7.1.6 SRU4: PCBs in Soil
Five alternatives were evaluated in detail in this SRU:
1. No Action (Section 7.1. J.I);
2. Institutional Controls (Section 7.1.1.2);
3. Chemical Dehalogenation;
4. On-site Low-temperature Thermal Desorption; and
5. Excavation/Incineration and Disposal.
7.1.6.1 Alternative 3: Chemical Dehalogenation
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section 7.1.2.1);
• Confirmatory Sampling (Section 7.1.2.2);
• Soil Transportation;
• Soil Preparation for Treatment (Section 7.1.2.4);
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg. 7.6
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• Chemical Dehalogenation of contaminated soil; and
• Disposal of Treated Soil (Section 7.1.6.1.3).
7.1.6.1.1 Soil Transportation
A centralized chemical dehalogenation treatment area would be established within the LAP area with
sufficient room to construct and operate treatment units and stockpile facilities. Trucks would haul the
soil to the treatment area on existing roads.
7.1.6.1.2 Chemical Dehalogenation
Several chemical dehalogenation processes are available for treating PCBs in soil. For cost estimating
purpose, the Galson Research Corporation (GRC) process is selected. This is a relatively new low-
temperature (230 - 320 °F) process that replaces the chlorine molecule in PCB with a glycol structure.
The process results in clean soil, although small quantities of glycol may remain in the soil. Glycol, a
biodegradable food additive, should rapidly degrade in the environment with no adverse effects. A
treatability study to demonstrate the effectiveness of this process would be required. To.comply with
TSCA regulations, permission from USEPA regional administrator will be required to use this technology
to treat soils with concentrations exceeding 500 ppm.
7.1.6.1.3 Disposal of Treated Soil
When confirmation is received that PCB levels are below RGs, the treated soil would be reused or
properly disposed.
7.1.6.2 Alternative 4: On-siteLow-temperature ThermalDesorption (LTTD)
This alternative includes the following actions:
• Soil Excavation for Treatment and Disposal (Section 7.1.2.1);
• Confirmatory Sampling (Section 7.1.2.2);
• Soil Transportation (Section 7.1.2.3);
• Soil Preparation for Treatment (Section 7.1.2.4);
• Soil Treatment Using an LTTD Unit; and
• Disposal of Treated Soil (Section 7.1.6.1.3).
7.1.6.2.1 Soil Treatment Using an LTTD-Unit
LTTD is a process that will remove PCBs from soil by heating and desorbing them Irom the soil particles.
The PCBs are not destroyed, they are condensed and collected for off-site disposal (most likely
incineration) at a permitted facility. The LTTD will require trial burns to assure that the operating
parameters are adequate to remove the PCBs and that pollution control devices arc adequate to prevent
releases of contaminants at levels above regulatory limits. To comply with TS< 'A, permission from
USEPA regional administrator will be required to use this technology to treat soils with concentrations
exceeding 500 ppm.
7.1.6.3 Alternative 5: Excavation/Incineration and Disposal
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section 7.1.2.1);
• Confirmatory Sampling (Section 7.1.2.2); and
• Off-site Incineration or Soil Disposal.
7.1.6.3.1 Off-site Incineration or Soil Disposal
Depending on confirmatory sampling results, this alternative is broken down into throe different steps:
JOAAP Record of Decision -Soil & Groundwater OUs - October, 1998 pg. 7-7
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w S0il T bel°W 5° Ppm' then the soil would be disP°sed at the future proposed
WCLF or at a permitted facility (estimated volume = 956 CY),
5° Ppm and 50° ppm' then the soil W««U be disposed in a
permitted landfill (estimated volume = 626 CY), and
tv,TQ^elS ^ grCateI tha" 5°° Ppm' then the soil'would be disposed off-site in accordance
wUh TSCA (e.g., treated off-site at a TSCA permitted incinerator) (estimated volume = 1,833
CY).
Excavated areas would be backfilled with clean fill obtained from an on-site borrow location and
revegetated with plants consistent with the future use of the area
7.1. 7 SRTK; Qreanics in
Six alternatives were evaluated in detail in this SRU:
1. No Action (Section 7. 1.1.1);
2. Institutional Controls (Section 7.1.1.2);
3. Bioremediation (Section 7.1.3.1) (Cenfralized treatment facility would be at a location within the
JL/vr Area);
4. Solvent Extraction;
5. On-site Low-temperature Thermal Desorption; and
6. Excavation and Disposal.
7.1. 7.1 Alternative 4: Solvent Extraction
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section 7. 1.2. 1);
• Confirmatory Sampling (Section 7.1.2.2);
• Soil Transportation;
• Soil Preparation for Treatment (Section 7. 1.2.4);
• Solvent Extraction ; and
• Soil Disposal (Section 7.1.2.5).
7. 1. 7. 1. 1 Soil Transportation
be impractical and expensive to establish separate solvent extraction treatment areas at each site
j. I estimating purposes, the treatment area is considered to be within site LI Trucks
would be used to haul the soil to the treatment area using the existing roads.
7. /. 7. 1.2 Solvent Extraction
nmeon procefses are available for Bating organics in soil. All of these systems
operate on the same basic principle. First, a solvent is used that extracts both water and organics from the
S " P * Phase 1S then separated from the S01ids- Then the water and the
or h - an e
S«7f r^ f Paratld;- Fmally' the contamina"ts are separated from the solvent and disposed at a
permitted facility. A treatabihty study will be required to develop operational parameters.
7.1. 7.2 Alternative 5: On-site Low-Temperature Thermal Desorption
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section in 7. 1.2. 1);
• Confirmatory Sampling (Section 7.1.2.2);
• Soil Transportation (Section 7.1.2.3);
• Soil Preparation for Treatment (Section 7.1.2.4);
• Soil Treatment Using a Low-Temperature Thermal Desorption Unit; and
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
7-8
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• Soil Disposal (Section 7.1.2.5).
7.1.7.2.1 Soil Treatment Using a Low-Temperature Thermal Desorption Unit;
LTTD is a process that will remove organics from soil by heating and desorbing them from the soil
particles. The organics are not destroyed, rather they are condensed and collected for off-site disposal
(most likely incineration) at a permitted facility. The LTTD will require trial burns to prove that the
operating parameters are adequate to remove the organics, and that pollution control devices are adequate
to prevent releases of contaminants at levels above regulatory limits.
7.1.7.3 Alternative 6: Excavation and Disposal
This alternative includes the following actions:
• Soil Excavation for Treatment or Disposal (Section 7.1.2.1);
• Confirmatory Sampling (Section 7.1.2.2); and
• Soil Disposal (Section 7.1.2.5).
7.1.8 SRU6: Landfills
Four alternatives were evaluated in detail in this SRU:
1. No Action (Section 7.1.1.1);
2. Institutional Controls (Section 7.1.1.2);
3. Capping; and
4. Excavation and Disposal.
7.1.8.1 Alternative 3: Capping
This alternative includes the following actions:
• Surface Regrading;
• Cap Construction; and
• Establishment of a Maintenance/Repair and Monitoring Program.
7.1.8.1.1 Surface Regrading
Existing landfill surfaces need to be filled, graded, and properly contoured prior to construction of the
cap. Grading may require fill soil from an on-site borrow location, appropriate untreated soil from
another SRU (e.g., SRU2), or the product of a treatment process. Conventional earth moving equipment
would be used for grading.
7.1.8.1.2 Cap Construction
This alternative involves the construction of RCRA Subtitle D caps over landfills containing non-
hazardous wastes (Ml3) and RCRA Subtitle C caps over landfills containing hazardous wastes (site Ml 1
and L3). These caps would be designed and constructed to minimize infiltration or precipitation and to
also prevent human exposure to contaminated materials in the landfills. The details of each cap would be
presented in the design phase; however, each cap would be constructed of different layers and graded to
prevent infiltration and establish proper grades and slopes for good run-off and erosion control. The top
layer will be revegetated with shallow-rooted vegetation that would be compatible with the intended land
use.
7.1.8.1.3 Establishment of Maintenance/Repair and Monitoring Program
A maintenance/repair and monitoring program would be required after capping and closing the landfills.
A maintenance/repair program would be established to maintain the caps and prolong their life span. The
monitoring program would be established to test and monitor the groundwater beneath and around the
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg. 7-9
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the landfiHs to,
7. 1.8.2 Alternative 4: Excavation and Disposal
This alternative includes the following actions:
• Landfill Excavation;
• Waste Testing and Segregation; and
• Waste Disposal.
7.1.8.2.1 Landfill Excavation
7.1.8.2.2 Waste Testing and Segregation
7. 1. 8.2. 3 Waste Disposal
7.7.9 SRTT7-
Three alternatives were evaluated in detail in this SRU-
1 . No Action (Section 7.1.1.1);
2. Institutional Controls (Section 7. 1.1.2); and
3. Removal and Recycle or Disposal.
7.1.9.1 Alternative 3: Removal and Recycle or Disposal
tesS! alUersfrdrth%SUrfaCe L" ^ ''reaS M8 and M12 W°uld be excavated ««1 "P-mted from
ecyc°ed The S S ? I ^ ' det^rmmed to have some commercial value and could be sold or
Howeve; ?the"aw stSr ^nT^^ ^ ^ invesli^ the Polity of selling sulfur
nuwcver, n me raw sullur has no commercial value, it would be disnoseH at Rrp A c,,i,r,o^ r»
a non-hazardous waste. The removal of sulfur is not regulated undtcERCLA "
7>? Groundwater Operable TTnif
Common Groundwater Alternatives
alte™tives are common to all GRUs The
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
7 10
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contaminated soil) removal within the soil OU. Each alternative will also experience natural attenuation
processes that will enhance the degradation rate of contaminated groundwater plumes.
7.2.7.7 Alternative 1: No Action
The No Action alternative means that no remedial activities would be performed in the GRU to reduce
impacts to contaminated groundwater. The inclusion of the No Action alternative is a requirement of
CERCLA and is used as a basis for comparison to other alternatives. The only changes that may occur to
the contaminant concentrations would be due to natural processes of attenuation such as adsorption of
chemicals onto soils, biodegradation, and dilution. These processes do not require implementation
activities. Natural attenuation is not monitored as part of the No Action alternative. Under the No Action
alternative, the effectiveness or ineffectiveness of natural attenuation cannot be determined.
7.2.1.2 Alternative 2: Limited Action
Under the Limited Action alternative, steps are taken to prevent or limit the likelihood of human
consumption or exposure to contaminated groundwater, and natural attenuation is used to lower the
concentrations of contaminants in the groundwater. The Limited Action alternative includes
establishment of a Groundwater Management Zone (GMZ), deed and zoning restrictions, periodic site
inspections, groundwater and surface water monitoring, and natural attenuation. This alternative also
includes contingency plans should the alternative prove ineffective.
Natural attenuation involves the use of natural processes such as biological degradation, sorption,
dispersion, and dilution to reduce the concentrations of contaminants in the plumes. Cleanup of
contaminated soil will also serve to eliminate the continuing source of groundwater contamination.
Natural attenuation may be enhanced by the use of plants whose root systems can be used to uptake
groundwater and remediate explosives. This process, called phytoremediation, is currently being studied
at JOAAP (Site LI), and the results of this study may be used to assess the effectiveness of this process
and the benefits of enhancing natural attenuation with this process. Results of this study will be available
for use during the RD phase.
GMZs are required by Illinois regulations to identify areas that do not meet drinking water standards until
cleanup activities are complete. GMZs would also be used to delineate the areas where restrictions on
groundwater use and uncontrolled soil excavation would be necessary to prevent human contact with
groundwater. The GMZs would comprise both the glacial drift and shallow bedrock aquifers, and would
cover the areas shown in Figure 4. The GMZs would be established with sufficient buffers to allow
groundwater wells to be installed outside their borders. These restrictions woukl be attached to land
deeds or leasing agreements.
A groundwater monitoring program would be implemented to track changes in concentration and detect
plume migration. Data from the monitoring program would be used in a groundwater model to predict
and anticipate the rate of contaminant reduction. The groundwater monitoring and modeling would
commence prior to the removal of contaminated soils in sites impacting groundwater in order to establish
baseline data for evaluating the effect of source removal on groundwater concentrations and the
effectiveness of natural attenuation. The groundwater data would be reviewed annually, and a five-year
assessment conducted to evaluate progress until RGs are achieved.
Once concentrations drop below the RGs, institutional controls would be modified so that additional
activities are allowed. If groundwater plumes migrate beyond the boundaries of the established GMZs,
groundwater is discharged to surface water at concentrations that exceed the water quality criteria
established for JOAAP at the boundaries of the GMZs, or the natural attenuation process proves -
ineffective, a contingency plan involving phytoremediation would be implemented. If phytoremediation
JOAAP Record of Decision - Soil & Groundwater OVs - October, 1998 pg. 7-11
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proves ineffective, then a contingency plan involving the pumping and treating of groundwater will be
implemented.
Common Groundwater Actions
As previously mentioned, some of the alternatives have common actions. These actions are described
below and then referenced later under the description of each alternative. Any deviations from the
general description are noted under the description o'f each alternative. These common actions are:
• Groundwater pumping;
• Treatment using Activated Carbon;
• Establishment of GMZs, deed and excavation restrictions, water monitoring and modeling; and
• Removal of metals by precipitation.
7.2.2.7 Groundwater pumping
The recovered groundwater from all sites will be extracted using wells or trenches and piped to an
aboveground holding tank sized for each site. Because of the high natural mineral content of the
groundwater, a pretreatment system will likely be required to prevent the deposition of minerals within
the treatment system that may result in reduced efficiency or clogging.
7.2.2.2 Treatment Using Activated Carbon
The effluent from the pretreatment would flow to one or more pairs of activated carbon units, where the
contaminants will be sorbed. The first-vessel within the unit is the primary cell, while the second vessel
serves as the polishing cell. Effluent from both cells would be sampled and analyzed for contaminants to
monitor breakthrough. Once the breakthrough is detected, spent carbon in the primary cell will be
replaced with virgin carbon while the polishing cell becomes the primary cell. After carbon is replaced,
this cell will be returned to operation serving as the polishing cell. A licensed contractor will periodically
replace spent carbon. The spent carbon will be transported off site for disposal at a permitted facility or
recycled. The treated water will be discharged to the local surface water or injected back into the aquifer.
7.2.2.3 Establishment of GMZs, deed and excavation restrictions, water monitoring and
modeling
Described as part of Alternative 2: Limited Action under Section 7.2. 1 .2.
7.2.2.4 Removal of Metals by Precipitation
The pH of the contaminated groundwater will be adjusted to above 1 1.0 by addition of lime. Metals will
then be removed by precipitation. Prior to disposal, the metal sludge will be dcwalered. The metal
sludge will be disposed at the appropriate landfill.
GRU1: Explosives in Groundwater - LAP
Three alternatives were evaluated in detail in this GRU:
1. No Action (Section 7.2.1. 1);
2. Limited Action (Section 7.2.1.2); and
3. Pump and Treat by Carbon Adsorption.
7.2.3.7 Alternative 3: Pump and Treat by Carbon Adsorption
This alternative includes the following actions:
• Groundwater Pumping (Section 7. 2. 2. 1) ;
• Treatment using Activated Carbon (Section 7.2.2.2);
• Discharge of Treated Water; and
JOAAP Record of Decision- Soil & Groundwater OUs - October, 1998 pg, 7.7 2
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• Establishment of GMZs, Deed and Excavation Restrictions, Water Monitoring and Modeling
(Section 7.2.2.3).
7.2.3.1.1 Discharge of Treated Water
Discharge to Prairie Creek was identified as the only technically feasible and implementable process
option for the discharge of treated water for GRU1. The injection and aquifer recharge options of treated
water were unfeasible due to the relatively low hydraulic conductivity of the LAP area soils.
2*2*4.—GRU2: Explosives and Other Contaminants in Groundwater - MFC fara
Five alternatives were evaluated in detail in this GRU:
1. No Action (Section 7.2.1.1);
2. Limited Action (Section 7.2.1.2);
3. Pump and Treat with Bioreactor;
4. Pump and Treat by Carbon Adsorption; and
5. Pump and Treat by UV Oxidation/Carbon Adsorption.
7.2.4.1 Alternatives: Pump and Treat with Bioreactor
This alternative includes the following actions:
• Groundwater Pumping (Section 7.2.2.1);
• Establishment of GMZs, Deed and Excavation Restrictions, Water Monitoring and Modeling
(Section 7.2.2.3);
• Removal of Metals by Precipitation (Section 7.2.2.4); and
• Treatment with Bioreactor
7.2.4.1.1 Treatment with Bioreactor
The effluent from the pretfeatment would be pumped through pipelines equipped with static mixers.
Sodium nitrate and molasses would be added into this line to serve, respectively, as the electron acceptor
and co-substrate during the anoxic biodegradation process. Powder activated carbon would be suspended
in the bioreactor and will sorb the organic compounds in the groundwater. Air would be introduced to the
system through a series of diffusers installed at the bottom of the bioreactor. A polymer would be added
to the effluent from the bioreactor to facilitate settling of the sludge and powdered activated carbon. The
solids in the settling tank would settle and recycle back to the system. The excess sludge would be
drummed and disposed. The treated water would be discharged to the local surface water or injected into
the aquifer.
7.2.4.2 Alternative 4: Pump and Treat by Carbon Adsorption
This alternative includes the following actions:
• Groundwater pumping (Section 7.2.2.1);
• Removal of metals by precipitation (Section 7.2.2.4);
• Treatment using Activated Carbon (Section 7.2.2.2); and
• Establishment of GMZs, deed and excavation restrictions, water monitoring and modeling
(Section 7.2.2.3).
7.2.4.3 Alternative 5: Pump and Treat by Ultra Violet (UV) Oxidation/Carbon Adsorption
This alternative includes the following actions:
• Groundwater Pumping (Section 7.2.2.1);
• Removal of Metals by Precipitation (Section 7.2.2.4);
• Treatment of Water by UV Oxidation;
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 7-13
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• Treatment of Water by Activated Carbon Prior to Discharge; and
• Establishment of GMZs, Deed and Excavation Restrictions, Water Monitoring and Modeling
(Section 7.2.2.3).
7.2.4.3.1 Treatment of Water with UV Oxidation
After pretreatment, water would be pumped to a UV oxidation reactor equipped with an H2O2 dosing
system. UV lamps would be used to provide the UV radiation that would split the H2O2 molecule,
producing the very reactive hydroxyl radicals needed for effective breakdown of the contaminants.
7.2.4.3.2 Treatment of Water by Activated Carbon Prior to Discharge
UV oxidation treatment of contaminated groundwater will remove up to 90 percent of explosives. A net
increase of TNB concentration will be expected due to the partial breakdown of TNT. The carbon
polishing cells will then remove this TNB along with the other residual contaminants. A pair or more of
carbon cells will be installed in series to further remove the contaminants from the groundwater before the
discharge. Once the breakthrough is detected, spent carbon in the primary cell will be replaced with
virgin carbon while the polishing cell becomes the primary cell. After carbon is replaced, this cell will be
returned to operation serving as the polishing cell. Periodic carbon replacement will be required. The
spent carbon will be transported off-site for disposal at a permitted facility or recycled. The treated water
will be discharged to the local surface water or injected into the aquifer.
7.2.5 ORU3: Volatile Organic Compounds (VOCs) in Groundwater - MFC Area
Six alternatives were evaluated in detail in this GRU:
1. No Action (Section 7.2. J.I);
2. Limited Action (Section 7.2.1.2);
3. In-Situ Bioremediation;
4. Pump and Treat by Air Stripping/Vapor-Phase Carbon Adsorption;
5. Pump and Treat by Carbon Adsorption; and
6. Pump and Treat by UV Oxidation.
7.2.5.7 Alternative 3: In-Situ Bioremediation
This alternative includes the following actions:
• Establishment of GMZs, Deed and Excavation Restrictions, Water Monitoring and Modeling
(Section 7.2.2.3); and
• In-situ Bioremediation.
7.2.5.1.1 In-Situ Bioremediation
In this alternative, an in-situ bioremediation process would treat the contaminated groundwater. To
achieve the natural biodegradation process, air or oxygen would be supplied by a scries of pumps and
injection wells to the contaminated aquifer using microbubbles to oxygenate the aquifer. If required,
nutrients would also be injected.
7.2.5.2 Alternative 4: Pump and Treat by Air Stripping/Vapor-Phase Carbon Adsorption
This alternative includes the following actions:
• Groundwater Pumping (Section 7.2.2.1);
• Treatment of Water with Air Stripping/vapor-phase Carbon Adsorption Treatment System;
• Establishment of GMZs, Deed and Excavation Restrictions, Water Monitoring and Modeling
(Section 7.2.2.3).
JOAAP Record of Decision - Soil & Groundwater Oils - October, 1998 pg. 7-14
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7.2.5.2. / Treatment of Water by Air Stripping/vapor-phase Carbon Adsorption Treatment System
The extracted contaminated groundwater would be pumped to an aboveground air stripping treatment
system for removal of the BTEX. The water would be pumped to an air-stripping tower. Air would be
blown into the tower countercurrently to the water flow. The BTEX in the water would then be
transferred to the a.r stream and exit for the top of the tower. A vapor-phase carbon cell will be used to
remove residual contaminants from the exit gas prior to atmospheric discharge. The effluent from the
carbon cell would be sampled to monitor breakthrough. Spent carbon would be transported off site for
disposal at an approved hazardous waste facility. The treated water would be discharged to the local
surface water or injected into the aquifer.
7.2.5.3 Alternative 5: Pump and Treat by Carbon Adsorption
This alternative includes the following actions:
• Groundwater Pumping (Section 7.2.2.1);
• Treatment Using Activated Carbon (Section 7.2.2.2); and
• Establishment of GMZs, Deed and Excavation Restrictions, Water Monitoring and Modeling
(Section 7.2.2.3).
7.2.5,4 Alternative 6: Pump and Treat by UV Oxidation
This alternative includes the following actions:
• Groundwater Pumping (Section 7.2.2.1);
• Treatment of Water by UV Oxidation (Section 7.2.4.3); and
• Establishment of GMZs, Deed and Excavation Restrictions, Water Monitoring and Modeling
(Section 7.2.2.3).
[END OF SECTION]
JOAAP Record ofDecision -Soil & Groundwater OUs - October, 1998 „« 7.75
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8 SUMMARY OF COMPARATIVE ANALYSTS OF ALTERNATIVES
This section evaluates and compares each of the alternatives described in Section 7.0 with respect to the
nine criteria used to assess remedial alternatives as outlined in Section 300.430(e) of the NCP.
8.1 Nine Evaluation Criteria
Section 300.430(e) of the NCP lists nine criteria by which each remedial unit alternative must be
assessed. The acceptability and performance of each alternative against the criteria is evaluated
individually so that relative strengths and weaknesses may be identified. The Threshold Criteria must be
satisfied in order for an alternative to be eligible for selection. The Balancing Criteria are used to weigh
major tradeoffs among alternatives. The Modifying Criteria are based on public comment received on the
Proposed Plan.
The remedial alternatives are evaluated against the following criteria for final actions. Similarly, the
remedial alternatives are evaluated against the following criteria for interim actions, recognizing that the
actions taken may not be the final actions.
Threshold Criteria
1. Overall Protection to the Human Health and the Environment addresses whether or not a remedy
provides adequate protection and describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls, or institutional controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements addresses whether or not a
remedy will meet all of the applicable or relevant and appropriate requirements of other Federal and
State environmental statutes and/or provide grounds for invoking a waiver.
Balancing Criteria
3. Long-term Effectiveness and Permanence refers to the magnitude of residual risk and the ability of a
remedy to maintain reliable protection of human health and the environment over time once the
cleanup goals have been met.
4. Reduction ofToxicity, Mobility, or Volume through Treatment is the anticipated performance of the
treatment technologies that may be employed in a remedy.
5. Short-term Effectiveness refers to the speed with which the remedy achieves protection, as well as the
remedy's potential to create adverse impacts on human health and the environment that may result
during the construction and implementation period.
6. Implementability is the technical and administrative feasibility of a remedy, including the availability
of materials and services needed to implement the chosen solution.
7. Cost includes total, capital, annual operation and maintenance, and site closeout costs. [Total costs are
discounted (at an annual rate of 7%) to net present value (NPV) in order to provide a standard basis of
comparison across alternatives. All other costs are shown in current year dollars relative to when they
occur. Calculation of NPV is in accordance with standard economic procedures. Tables 8-1 through
8-12 and the text show total costs (in NPV) for all SRUs and GRUs. Table 8-13 and Appendix B
provide more detailed breakdown of the component costs. All costs are rounded as appropriate.]
Modifying Criteria
8. State Acceptance indicates whether, based on its review of the RI/FS and Proposed Plan, the State
concurs with, opposes, or has no comment on the preferred alternative.
9. Community Acceptance is assessed following a review of the public commcnls received on the"
Proposed Plan.
JOAAP Record of Decision -Soil & Groundwater OUs - October, 1998 Revision 1 - JH/27/9$ pg. 8-1
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8,2 Soil Operable Unit
8.2.1 SRU1: Explosives in Sail
The alternatives evaluated for this SRU are:
Alternative 1: No Action
Alternative 2: Institutional Controls
Alternative 3: Bioremediation '
Alternative 4: On-site Incineration
Alternative 5: Excavation and Disposal
SRU1 includes both interim and final remedial actions. Following is a summary of the comparative
analysis of these alternatives.
Overall Protection to the Human Health and the Environment
Alternative 1 would not protect human health and the environment because no action would be taken to
eliminate, reduce or control exposure pathways. In addition, this alternative does not remove any soil,
which is a probable source for groundwater contamination. Therefore, Alternative 1 does not meet this
criterion.
Alternative 2 would provide some protection from contaminated soil by implementing restrictions such as
fencing around contaminated areas and deed restrictions on excavation within these contaminated areas.
Although these restrictions reduce access and potential exposure to contaminated areas, they do not
remove contaminated soil, which is the probable source of groundwater contamination. In addition,
natural attenuation processes in the Institutional Controls alternative are not effective for high
concentrations of explosives in soils. For theses reasons, Alternative 2 does not meet this criterion.
The remaining alternatives are considered to be protective to human health and the environment because
they eliminate or reduce the source by the removing the contaminated soil. The remedial actions reduce
the short- and long-term risks to ecological populations by reducing their exposure and uptake of
contamination via soil and food. Alternatives 3, 4 and 5 provide overall protection to human health and
the environment for final remedial actions by removing contaminated soil to meet RGs. In addition, these
alternatives eliminate or reduce the potential for contaminant migration. The risks are reduced by
treatment for Alternatives 3 and 4. The risks are reduced by engineering controls (disposal in a landfill)
for Alternative 5.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
With the exception of Alternatives 1 and 2, all the alternatives will comply with the ARARs. The
acceptable alternatives will either reduce exposure to contaminated soil, remove and treat soil, or remove
contaminated soil to a controlled location.
Long-term Effectiveness and Permanence
Alternatives 1 and 2 partially meet this criterion. These two alternatives will only slightly decrease the
risk to human health and the environment via natural attenuation. Deed restrictions and the risk
management strategies under Alternative 2 will also reduce the potential for human exposure. However,
under both alternatives, the continued presence and migration of the contaminants may pose future risk to
the environment.
Alternatives 3 and 4 provide the most permanent solution since contaminants are treated to meet RGs. It
should be noted that Alternative 5 would not be effective if the disposal landfill fails. However, the
landfill will be in compliance with RCRA and is designed to minimize the possibility of failure.
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998 Revision I - 10/27/98 pg. 8-2
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Residual risks associated with interim actions will be addressed with implementation of final remedial
action.
Reduction ofToxicity, Mobility, or Volume through Treatment
Alternatives 1 and 2 would not provide any active reduction of toxicity, mobility, or volume of the
contaminants because removal or treatment of the contaminated soil would not be components of these
two alternatives. Alternatives 3 and 4 permanently reduce the toxicity, mobility of contaminants by
removing and treating them. Therefore, these two alternatives fully meet this criterion. However, if
composting is implemented as the biological treatment process, the volume of treated material will'be
greater than the original volume of contaminated soil.
Alternative 5 partially meets this criterion. This alternative reduces the mobility of the contaminants by
removing the contaminated media from the site and containing them in a landfill. However, this
alternative is not preferable to the treatment alternatives because it does not satisfy the statutory
preference for treatment.
Short-term Effectiveness
Alternative 1 does not meet the RG criterion. Minimal site activities are performed under Alternative 2,
thus limiting the short term impact to workers. However, the rate of natural attenuation is likely to be
slow. Therefore, this alternative partially meets this criterion.
Since Alternatives 3 activities are conducted on-site, the community will not be subjected to any short-
term impacts due to the remedial actions. However, there is a potential for workers to physical hazard
exposure and a potential impact to the environment as a result of erosion during excavation activities.
Alternative 4 poses potential short-term impacts from the physical hazards associated with operating the
incinerator and air pollutant transport in case of air pollution control equipment failure. There is a
potential for workers' exposure and a potential short-term impact to the environment as a result of erosion
during excavation activities. Alternative 5 may have a short-term impact on the community and the
environment due the off-site transportation of contaminated soil and the possibility oHandfill failure.
Implementability
Alternatives 1 and 2 would be the most easily implemented. Alternative 1 would require no technical
action, and Alternative 2 would require minimal action. Implementation of Alternatives 3 and 4 would
mainly consist of excavation, treatment, and disposal. Alternative 5 would not require treatment.
Technically, no significant constraints are anticipated for implementing any of these three alternatives.
Administratively, there may be a long duration in meeting the necessary procedural requirements to
implement Alternative 4. In addition, implementation of Alternative 4 may involve extensive public
hearings and may face difficulty in gaining public acceptance.
Cost
The following estimated cost includes capital, operational, and maintenance for each alternatives. These
are present worth costs and are adjusted for the length of time to complete each alternative.
Alternative 1: No Action $ 0
Alternative 2: Institutional Controls $ 3,000,000
Alternatives: Bioremediation $ 39,300,000
Alternative 4: On-site Incineration $ 76,600,000
Alternatives: Excavation and Disposal $ 23,100,000
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 8-3
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State Acceptance
The State of Illinois concurs with the acceptability of Alternatives 3, 4, and 5 based on these alternatives
complying with the ARARs. The IEPA prefers Alternative 3: Bioremediation.
Community Acceptance
Comments received during the Public review period and from the January 8, 1998, Public Meeting were
transcribed and are included in the Responsiveness Summary of this document. Responses to these
comments are also included in the Responsiveness Summary. Generally, these comments were positive
in nature There is a concern and request from the community to expedite the remediation process In
general the community has a preference for treating the contamination and appears to concur with the
selected remedy.
8.2.1.1 Summary Evaluation of Alternatives for SRU1
Table 8-1 compares the alternatives considered for SRU1 with respect to the nine CERCLA evaluation
criteria. The No Action and Institutional Controls alternatives are not recommended because they would
not be protective of human health and the environment and would, therefore, not meet the threshold
criteria. These two alternatives do not remove a probable source for groundwater contamination In
addition, natural attenuation processes in the Institutional Controls alternative are not effective for high
concentrations of explosives in soils. The remaining three alternatives meet the threshold criteria for final
remedial actions. The U.S. Army selected Bioremediation as the recommended alternative for SRU1 for
the following reasons.
Bioremediation is recommended over Incineration because it is less expensive and Incineration may face
diliiculty in gaming public acceptance. Incineration may also require granting a waiver because of
existing air regulations. Although more expensive than Excavation and Disposal, Bioremediation is
recommended because it will treat the soils at JOAAP that pose the majority of the risk to human health
and the environment. This will also satisfy the regulatory preference of CERCLA for treatment over
disposal.
8.2.2 SRTJ2: Metals in
The alternatives evaluated for this SRU are:
Alternative 1 : No Action
Alternative 2: Institutional Controls
Alternative 3: Stabilization/Solidification
Alternative 4: Excavation and Disposal
SRU2 includes both interim and final remedial actions. Following is a summary of the comparative
analysis of these alternatives.
Overall Protection to the Human Health and the Environment
Alternative 1 would not protect human health and the environment because no action would be taken to
eliminate, reduce or control exposure pathways. Therefore, Alternative 1 does not meet this criterion.
Alternative 2 would provide some protection from contaminated soil by implementing restrictions such as
fencing around contaminated areas and deed restrictions on excavation within these contaminated areas
Although these restrictions reduce access and potential exposure to contaminated areas, they do not
remove contaminated soil or reduce its environmental effects. In addition, natural attenuation processes in
the Institutional Controls alternative are generally not effective for removing metals from soils
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg, g-4
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Table 8-1: Evaluation of Remedial Alternatives for SRIJ1 ^Explosives in Soil)
Remedial Alternative
Evaluation Criteria
Balancing
S S 5
o. X £
O X i
o
G
S
S
s g
.s
(2-5§
= > S
c SH
00
vi
>,
2
Modifying
8"
O
<
53
8-
1 . No Action
2. Institutional Controls
3. Bioremediation
4. On-site Incineration
5. Excavation and Disposal
O O
O O
o o
o
O
39,300
76,600
23,100
NA
NA
NA
Ranking Key: ^ Fully meets criteria ^^ Partially meets criteria
Notes: NA - Not addressed by public comments
Does not meet criteria
** - Threshold criterion 1 is applied fully for final remedial actions. It is applied to interim
remedial actions while recognizing that the interim actions taken may not be the final actions.
The remaining alternatives are considered to be protective to human health and the environment for final
remedial actions because they eliminate the source by removing the contaminated soil to meet RGs. The
remedial actions reduce the short- and long-term risks to ecological populations by reducing their
exposure and uptake of contamination via soil and food. Alternative 3 removes the contaminated soil and
treats the soils by immobilizing the metals prior to disposal in a permitted facility. Alternative 4 provides
overall protection to human health and the environment by removing the soil and disposing it in a landfill.
However, the contaminated soil is not subjected to any treatment.
Compliance with Applicable or Relevant and Appropriate Requirements
Alternatives 1 and 2 will not comply with the ARARs. Alternatives 1 and 2 do not alleviate the localized
impacts to the environment. Alternative 2 will not be protective of the environment in localized areas
where ecological impacts have been documented. Alternative 2 will also result in disposal of solid and
special wastes. Alternatives 3 and 4 will comply with the ARARs. These acceptable alternatives will
either remove and treat soil (Stabilization/Solidification) prior to landfill disposal, or simply remove the
contaminated soil and dispose of it in a permitted landfill (Excavation and Disposal).
Long-term Effectiveness and Permanence
Alternative 1 does not meet this criterion. Based on the existing metals concentrations and the proposed
land use, this alternative does not adequately reduce the long-term risk to human health. Alternative 2
partially meets this criterion. This alternative will probably not decrease the risk to human health and the
environment via natural attenuation, and the continued presence and migration of the contaminants may
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
PS- S-5
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S™?1"6 ?Sk I? ^ envj,r0nment H°Wever' deed restr^°ns and the risk management strategies under
Alternative 2 will reduce the potential for human exposure. •
For final remedial actions, Alternatives 3 and 4 provide permanent solutions by excavating the
?f u31 RGS ^ Sfndlnf * f°r treatmcnt °r disP°SaL Neither alternative will £
the landmi win be in compiiance with RCRA and <• ^^ *>
Residual risks associated with interim actions will be addressed with implementation of final remedial
ciciion*
Reduction ofToxicity, Mobility, or Volume through Treatment
Alternatives 1 and 2 would not provide any active reduction of toxicity, mobility, or volume of the
rwo^SL AT rem° ,°r *eatment of the Contaminated soil would not be components of these
two a ternatives. Alternatives 3 and 4 partially meet this criterion. Alternative 3 will immobilize but not
alter the concentrations of metals, thereby reducing only their mobility. Alternative 4 reduces the
rfarS A^f C0n,temman* ^ "moving the contaminated media from the site and containing them into
w™ AUemative 4 will produce less material needed to be placed in the landfill than Alternative 3.
However, Alternative 3 minimizes the potential for contaminant mobility if the landfill were to fail. '.
Short-term Effectiveness
frZ;,"0, T£dial 3Cti0nS are1imPlemented ™der Alternative 1, this alternative poses no short-term
impacts to the community, workers, or the environment. However, RGs will not be reached under this
AhemaaJrve ^TV T ™ ""f ** ^^^ Mi"imal Site activities are Performed u"der
Alternative 2 thus limiting the potential short term impacts to workers. However, the rate of natural
and wm require a long time to achieve RGs-
Since Alternative 3 activities are conducted on-site, the community will not be subjected to any short-
term impacts due to the remedial actions. However, there is a potential for workers exposure and a
/SSS v ShTCr? TPaCt ^ environment as a res«l' °f erosion during excavation activities.
Alternatives 3 and 4 may affect the community and the environment due the transportation of
contaminated soil and the possibility of landfill failure.
Implementabttity
Alternatives 1 .and 2 would be the most easily implemented. Alternative 1 would require no technical
action, and Alternative 2 would require minimal action. Implementation of Alternatives 3 and 4 would
mainly consist of excavation, treatment, and disposal. Technically, no significant constraints are
anticipated for implementing either of these two alternatives. Administratively, there may be a potential
long duration in meeting the necessary procedural requirements to implement both of these alternatives if
ner^l^nf ^ K°Uld n0t bC bUllt in time due t0 Pennittin8 delavs' However> an existing
permitted landfill could also be used to dispose of these wastes.
Alternative 4 provides an added benefit in that the soils could be determined suitable to be used as
subgrade material for the proposed on-site landfill caps in SRU6. This option would provide an
innovative and beneficial reuse of these soils that would not increase the project costs would be
protective to human health and the environment, and would not use up available space in the future
proposed WCLF.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg 8.6
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Cost
The following estimated cost includes capital, operation, and maintenance for all alternatives. These are
present worth costs and are adjusted for the length of time to complete each alternative.
Alternative 1: No Action $ 0
Alternative 2: Institutional Controls $ 300,000
Alternative 3: Stabilization/Solidification $ 6,700,000
Alternative 4: Excavation and Disposal $ 4,000,000
State Acceptance
The State of Illinois concurs with the acceptability of Alternatives 3 and 4 based on these alternatives
complying with the ARARs. The IEPA prefers Alternative 4: Excavation and Disposal.
Community Acceptance
Comments received during the Public review period and from the January 8, 1998, Public Meeting were
transcribed and are included in the Responsiveness Summary of this document. Responses to these
comments are also included in the Responsiveness Summary. Generally, these comments were positive
in nature. There is a concern and request from the community to expedite the remediation process. The
community appears to concur with the selected remedy.
8.2.2.1 Summary Evaluation of Alternatives for SRU2
Table 8-2 compares the alternatives considered for SRU2 with respect to the nine CI-RCLA evaluation
criteria. The No Action and Institutional Controls alternatives are not recommended because they would
not be protective to human health and the environment and they do not meet the threshold criteria. In
addition, natural attenuation processes in the Institutional Controls alternative are not effective for high
concentrations of metals in soils. Both Solidification/Stabilization and Excavation and Disposal
alternatives meet the threshold criteria for final remedial action sites. The U.S. Army selected Excavation
and Disposal as the recommended alternative for the following reasons:
• Illinois currently requires that solidified/stabilized materials must still be disposx-d in a landfill to
prevent exposure to the contaminants that, while bound in the treated material, are still present.
Therefore, even if Solidification/Stabilization was selected, the materials would still need to be
disposed in a landfill. In addition, the Solidification/Stabilization process typically increases the
volume of material that will need to be disposed. Excavation and Disposal will be less costly and,
when compared to the Solidification/Stabilization, will reduce the volume of material needed to be
placed in the landfill.
• The Excavation and Disposal alternative provides an added benefit because the soils may be suitable
for use as subgrade material for the proposed landfill caps in SRU6. This option would provide an
innovative and beneficial reuse of these soils that would not increase the project costs, would be
protective to human health and the environment, and would not use up available space in the future
proposed WCLF. Finally, the Excavation and Disposal alternative is relatively easier and faster to
implement.
JOAAP Record ofDecision -Soil & Groundwater OUs - October, 1998 pg. 8-7
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Table 3-2; Evaluation of Remedial Alternatives for SRTJ2 (Metals j
Remedial Alternative
•o
u
J
Threshold
H:
8«1
S 0 5
o. I E
1 S I
P g-l
<3
Evaluation Criteria
Balancing
S
5
"O O
SS|
01
S
tn
Modifying
VI
00
6
1. No Action
2. Institutional Controls
3. Stabilization/
Solidification
4. Excavation and Disposal
O O
• o
o
300
•
o
o
NA
NA
PariaHy meets criteria Q Docs not meet criteria
Ranking Key: 0 Fully meets criteria
Notes: NA- Not addressed by public comments
** - Threshold criterion 1 is applied fully for final remedial actions. It is applied to interim
_. — _— , .„ ^^r"*-" j""sjvi jutui IK/IICUIUI ui,nuru. 11 u applied w interim
remedial actions while recognizing that the interim actions taken may not he the final actions.
8.2.3 SRU3: Explosives and Metals in Soil
The alternatives evaluated for this SRU are:
Alternative 1:
Alternative 2:
Alternatives:
Alternative 4:
Alternative 5:
No Action
Institutional Controls
Bioremediation and Disposal
On-site Incineration
Excavation and Disposal
SRU3 includes both interim and final remedial actions. Following is a summary of the comparative
analysis of these alternatives.
Overall Protection to the Human Health and the Environment
Alternative 1 would not protect human health and the environment because no action would be taken to
eliminate, reduce or control exposure pathways. Therefore, Alternative 1 does not meet this criterion.
Alternative 2 would provide some protection from contaminated soil by implementing institutional
controls such as fencing around contaminated areas and deed restrictions on excavation within these
contaminated areas. Although these restrictions reduce access and potential exposure to contaminated
areas, they neither remove contaminated soil nor mitigate the potential for contaminant migration. In
addition, natural attenuation processes in the Institutional Controls alternative are not effective for high
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998
Pg. 8-8
-------
concentrations of explosives and metals in soils. For these reasons, Alternative 2 does not meet this
criterion.
The remaining alternatives are considered to be protective to human health and the environment because
they eliminate or reduce the source by removing contaminated soil. The remedial actions reduce the
short- and long-term risks to ecological populations by reducing their exposure and uptake of
contamination via soil and food. Alternatives 3,4 and 5 provide overall protection to human health and
the environment for final remedial actions by removing contaminated soil to meet RGs. In addition, these
alternatives eliminate or reduce the potential for contaminant migration. The risks are reduced by
treatment for Alternatives 3 and 4. The risks are reduced by engineering controls (disposal in a landfill)
for Alternative 5.
Compliance with Applicable or Relevant and Appropriate Requirements
With the exception of Alternatives 1 and 2, all the alternatives will comply with the ARARs. Alternatives
1 and 2 do not alleviate the localized impacts to the environment. Alternatives 3, 4, and 5 will adequately
protect human health and the environment and will also comply with ARARs based on appropriate
designs and implementation.
Long-term Effectiveness and Permanence
Based on the existing explosives and metals concentrations and the proposed land use, Alternative 1 does
not reduce the long-term risk to human health. In addition, the potential for contaminant migration may
pose a future risk to the environment. Therefore, Alternative 1 does not meet this criterion.
Alternative 2 partially meets this criterion. This alternative will slightly decrease the risk to human health
and the environment via natural attenuation. Deed restrictions and the risk management strategies under
this alternative will also reduce the potential for human exposure. However, the continued presence and
migration of the contaminants may pose future risk to the environment.
For final remedial actions, Alternatives 3, 4, and 5 eliminate the potential for future risks associated with
direct contact and contaminants migration by excavating contaminated media to meet RGs. Alternative 5
would not be effective if the landfill fails. However, the landfill will be in compliance with RCRA and is
designed to minimize the possibility of failure.
Residual risks associated with interim actions will be addressed with implementation of final remedial
action.
Reduction ofToxicity, Mobility, or Volume through Treatment
Alternatives 1 and 2 would not provide any active reduction of toxicity, mobility, or volume of the
contaminants because removal or treatment of the contaminated soil would not be components of these
two alternatives.
Alternatives 3 and 4 permanently reduce the toxicity, mobility, and volumes of explosives by removing
and treating them; however, Alternatives 3 and 4 reduce only the mobility and volumes of the metals.
These two alternatives fully meet this criterion.
Alternative 5 partially meets this criterion. This alternative reduces the mobility of the contaminants by
removing the contaminated media from the site and containing them into a landfill. However, this
alternative does not satisfy the statutory preference for treatment.
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998 Revision I -JO/2 7/98 pg. 8-9
-------
Short-term Effectiveness
Since no remedial actions are implemented under Alternative 1, this alternative poses no short-term
impacts to the community, workers, or the environment. However, RGs will not be reached under this
alternative. Alternative 1 does not meet this criterion. Minimal site activities are performed under Alter-
native 2, limiting short-term impacts to workers. However, the rate of natural attenuation is likely to be
slow and will require a long time to achieve RGs. Therefore, this alternative partially meets this criterion.
Alternatives 3 and 5 fully meet this criterion while Alternative 4 partially meets it. There is a potential for
workers' exposure and a potential short-term impact to the environment as a result of erosion during
excavation activities for these three alternatives. Alternatives 3, 4, and 5 may have short-term impacts on
the community, worker health, and the environment due the transportation of contaminated soil and the
possibility of landfill failure. Alternative 4 poses potential short-term impacts from the physical hazards
associated with operating the incinerator and pollutant transport in case of air pollution control equipment
failure.
Implementability
Alternatives 1 and 2 would be the most easily implemented. Alternative 1 would require no technical
action, and Alternative 2 would require minimal action. Implementation of Alternatives 3 and 4 would
mainly consist of excavation, treatment, and disposal. However, Alternative 5 would not require
treatment and is easily implemented. Technically, Alternatives 3 and 4 may not effectively reduce metals
concentrations, thus still requiring disposal of the treated materials in a permitted facility.
Administratively, there may be a potential long duration in meeting the necessary procedural
requirements to implement Alternative 4 (On-site Incineration). In addition, Alternative 4
implementation may involve extensive public hearings and may face difficulty in gaming public
acceptance.
Cost
The following estimated cost includes capital, operational, and maintenance for all alternatives. These are
present worth costs and are adjusted for the length of time to complete each alternative.
Alternative 1: No Action $ 0
Alternative 2: Institutional Controls $ 3000,000
Alternatives: Bioremediation and Disposal $ 4,000,000
Alternative 4: On-site Incineration $15,800,000
Alternatives: Excavation and Disposal $ 2,800,000
It should be noted that the cost estimate for Alternative 3 assumes the most expensive of the currently
available treatment options.
State Acceptance
The State of Illinois concurs with the acceptability of Alternatives 3, 4, and 5 based on these alternatives
complying with the ARARs. The IEPA prefers a combination of Alternatives 3 and 5.
Community Acceptance
Comments received during the Public review period and from the January 8, 1998, Public Meeting were
transcribed and are included in the Responsiveness Summary of this document. Responses to these
comments are also included in the Responsiveness Summary. Generally, these comments were positive
in nature. There is a concern and request from the community to expedite the remediation process. In
general, the community has a preference for treating the contamination and appears to concur with the
selected remedy.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 Revision 1 10/27/98 pg. 8-10
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8.2.3.1 Summary Evaluation of Alternatives for SRU3
Table 8-3 compares the alternatives considered for SRU3 with respect to the nine CHRCLA evaluation
criteria. The No Action and Institutional Controls alternatives are not recommended because they would
not be protective of human heath and the environment and they would not meet the threshold criteria. In
addition, natural attenuation processes in the Institutional Controls alternative are not effective for high
concentrations of explosives and metals in soils. The remaining three alternatives meet the threshold
criteria for final remedial actions. The U.S. Army selected both Excavation and Disposal and
Bioremediation and Disposal as the recommended alternatives for the following reasons.
Two alternatives were selected for this SRU because sites M5 and M6 might contain soil that exhibits
hazardous characteristics (i.e., explosives concentration > 100,000 ppm) or contains RCRA listed wastes,
and, therefore, these soils will require treatment for explosives prior to disposal in a landfill. Since soils
from both of these alternatives will be disposed in a landfill, just excavating and disposing non-hazardous
soil will be less costly and will reduce the volume of material needed to be placed in the landfill. The
selection of these two alternatives was recommended over Incineration because this approach is less
expensive and Incineration may face difficulty in gaining public acceptance. Incineration may also
require granting of a waiver because of existing air regulations.
Table 8-3: Evaluation of Remedial Alternatives for SRTJ3 (Explosives and Mc-tals in Soil)
Remedial Alternative
1 . No Action
2. Institutional Controls
3. Bioremediation and
Disposal
4. On-site Incineration
5. Excavation and Disposal
Total for Alternatives 3,5m
>
c
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o
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Evaluation Criteria
Threshold
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w B '- > 5 uj ^ S
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O NA
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Ranking Key:
Fully meets criteria
Partially meets criteria
Docs not meet criteria
Notes: NA — Not addressed by public comments
** ~ '-Threshold criterion 1 is applied fully for final remedial actions. It is applied to interim
remedial actions while recognizing that the interim actions taken may not be the final actions.
(1) Selection of Bioremediation (Alternative 3) will be based on the explosive contamination in the
soil. Costs for Alternative 3 and 5 are based on estimated volumes going to each disposal
alternative.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 Revision 1 - }J)/27/98 pg. 8-11
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8.2.4 SRU4: PCBs in Soil
The alternatives evaluated for this SRU are:
Alternative 1: No Action
Alternative 2: Institutional Controls
Alternative 3: Chemical Dehalogenation
Alternative 4: On-site Low-temperature Thermal Desorption (LTTD)
Alternative 5: Excavation/Incineration and Disposal
SRU4 includes only final remedial actions. Following is a summary of the comparative analysis of these
alternatives.
Overall Protection to the Human Health and the Environment
Alternative 1 would not protect human health and the environment because no action would be taken to
eliminate, reduce or control exposure pathways. Therefore, Alternative 1 does not meet this criterion.
Alternative 2 would provide some protection from Contaminated soil by implementing restrictions such as
fencing around contaminated areas and deed restrictions on excavation within these contaminated areas.
Although these restrictions reduce access and potential human exposure to contaminated areas, they do
not eliminate potential environmental impacts. In addition, natural attenuation processes in the
Institutional Controls alternative are not effective for high concentrations of PCBs in soils.
The remaining alternatives are considered to be protective to human health and the environment.
Alternatives 3 and 4 remove and treat the contaminated soils to levels below the RGs. Human health risk
and the potential for contaminant migration is eliminated through the excavation and treatment of
contaminated soil. Alternative 5 provides overall protection to human health and the environment by
removing the soil and disposing it in a permitted landfill. However, the contaminated soil is not subjected
to any treatment if PCB concentrations are below 500 ppm. Some limited potential for future impacts to
human health and the environment exist with this alternative in the event of a failure in the landfill
containment control.
Compliance with Applicable or Relevant and Appropriate Requirements
Alternatives 1 and 2 will not comply with the ARARs. While Alternative 2 docs reduce the exposure
pathways, it, as well as Alternative 1, may not be protective of the environment because PCBs may
potentially bioaccumulate in some ecological receptors. Alternatives 3, 4, and 5 will comply with the
ARARs. These acceptable alternatives will either remove and treat soil or remove contaminated soil to an
alternate controlled location. Alternatives 3 and 4 will require the USEPA Regional Administrator
approval to treat soils with concentrations above 500 ppm. Alternatives 3, 4, and 5 will adequately
protect human health and the environment.
Long-term Effectiveness and Permanence
Based on the existing PCB concentrations and the proposed land use, Alternative 1 does not reduce the
long-term risk to human health. In addition, the potential for contaminant migration may pose a future
risk to the environment. Therefore, Alternative 1 does not meet this criterion. Alternative 2 partially
meets this criterion. This alternative will slightly decrease the risk to human health and the environment
via natural attenuation, although natural attenuation does not effectively reduce PCB concentration. Deed
restrictions and the risk management strategies under this alternative will also reduce the potential for
human exposure. However, the continued presence and migration of the contaminants may pose future
risk to the environment.
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998 Revision 1 - 10/27/98 pg. 8-12
-------
Alternatives 3, 4, and 5 eliminate the potential for future risks associated with direct contact and
contaminants migration by excavating the contaminated media to levels below the RGs and sending it for
treatment or disposal.
Reduction ofToxicity, Mobility, or Volume through Treatment
Alternatives 1 and 2 would not provide any active reduction of toxicity, mobility, or volume of the
contaminants because removal or treatment of the contaminated soil would not be components of these
two alternatives. Alternatives 3, 4 and 5 permanently reduce the toxicity, mobility, and volumes of
contaminants by removing and treating or disposing them. Therefore, these three alternatives meet this
criterion.
Short-term Effectiveness
Since no remedial actions are implemented under Alternative 1, this alternative poses no short-term
impacts to the community, workers, or the environment. However, RGs will not be reached under this
alternative. Alternative 1 does not meet this criterion. Minimal site activities are performed under Alter-
native 2, limiting short-term impacts to workers. However, the rate of natural attenuation is likely to be
slow and will require a long time to achieve RGs. Therefore, this alternative partially meets this criterion.
Alternatives 3 and 4 partially meet this criterion while Alternative 5 fully meets it. Since Alternatives'3
and 4 activities are conducted on-site, the community will not be subjected to any short-term impacts due
to the remedial actions. However, there is a potential for workers' exposure. Alternative 3 and 4 could
have short-term impacts on the environment as a result of erosion during excavation activities.
Alternative 5 may have short-term impacts on the community, worker health, and the environment due
the transportation of contaminated soil for off-site disposal.
Implementability
Alternatives 1 and 2 would be readily implemented. Alternative 1 would require no technical action, and
Alternative 2 would require minimal action. Alternatives 3 and 5 would mainly consist of excavation,
treatment or disposal. These two alternatives fully meet this criterion. Alternative 4 would partially meet
this criterion. Technically, there may be some constraints for implementing, Alternatives 3 and 4.
Alternatives 3 and 4 would need treatability studies and USEPA Regional Administrator approval to treat
soils with concentrations above 500 ppm.
Cost
The following estimated cost includes capital, operational, and maintenance for all alternatives. These are
present worth costs and are adjusted for the length of time to complete each alternative.
Alternative 1: No Action $ 0
Alternative 2: Institutional Controls $ 8,000
Alternatives: Chemical Dehalogenation $4,100,000
Alternative 4: On-site LTTD $ 2,400,000
Alternatives: Excavation/Incineration and Disposal $1,400,000
State Acceptance
The State of Illinois concurs with the acceptability of Alternatives 3, 4 and 5 based on these alternatives
complying with the ARARs. The IEPA prefers Alternative 5: Excavation/Incineration and Disposal.
Community Acceptance
Comments received during the Public review period and from the January 8, 1998, Public Meeting were
transcribed and are included in the Responsiveness Summary of this document. Responses to these
comments are also included in the Responsiveness Summary. Generally, these comments were positive
in nature. There is a concern and request from the community to expedite the remediation process. In
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 8-13
-------
general, the community has a preference for treating the contamination and appears lo
selected remedy.
concur with the
8.2.4.1 Summary Evaluation of Alternatives for SRU4
Table 8-4 compares the alternatives considered for SRU4 with respect to the nine CERCLA evaluation
criteria. The threshold criteria could not be met by the No Action and Institutional Controls alternatives;
hence these two alternatives were not selected. In addition, natural attenuation processes in the
Institutional Controls alternative are not effective for high concentrations of PCB in soils. The U.S. Army
selected Excavation and Disposal as the recommended alternative for SRU4 for the following reasons.
The threshold criteria could be met by the recommended alternative, by Chemical Dehalogenation and by
On-site Low-temperature Thermal Desorption. Each would reduce the risk of direct contact with the
PCBs in the soil and debris. However, the implementability, short-term effectiveness, and cost of
Excavation and Disposal made it more attractive than other two alternatives.
Table $-4: Evaluation of Remedial Alternatives for SRTJ4 (PCBs in Soil)
Remedial Alternative
1. No Action
2. Institutional Controls
3. Chemical
Dehalogenation
4. On-site Low-temperature
Thermal Desorption
5. Excavation/ Incineration
and Disposal
u
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Ranking Key: Fully meets criteria ^ Partially meets criteria
Q__) Does not meet criteria
Notes: NA ..- Not addressed by public comments
** - All remedial actions are final for SRU4. Threshold criterion 1 is applied fully to these actions.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
pg. 8-14
-------
8,2.5 SRU5: Organic* in Soil
The alternatives evaluated for this SRU are:
Alternative 1: No Action
Alternative 2: Institutional Controls
Alternative 3: Bioremediation
Alternative 4: Solvent Extraction
Alternative 5: On-site Low-temperature Thermal Desorption (LTTD)
Alternative 6: Excavation and Disposal
SRU5 includes only interim remedial actions. Following is a summary of the comparative analysis of
these alternatives.
Overall Protection to the Human Health and the Environment
Alternative 1 would not protect human health and the environment because no action would be taken to
eliminate, reduce or control exposure pathways. Therefore, Alternative 1 does not meet this criterion.
Alternative 2 is considered protective to human health and the environment. This alternative would
provide protection of human health by implementing restrictions such as fencing around contaminated
areas and deed restrictions on excavation within these contaminated areas. Natural attenuation processes
can reduce the concentrations of organics in the soil, but risks to the environment may exist while these
processes occur.
The remaining alternatives are considered to be protective to human health and the environment because
they eliminate or reduce the source by removing contaminated soil. The remedial actions reduce the
short- and long-term risks to ecological populations by reducing their exposure and uptake of
contamination via soil and food. Human health risk and the potential for contaminant migration is
eliminated or reduced through the excavation of contaminated soil. The risks are reduced by treatment
for Alternatives 3, 4 and 5. The risks are reduced by engineering controls for Alternative 6.
Compliance with Applicable or Relevant and Appropriate Requirements
Alternative 1 will not comply with the ARARs. In Alternative 1 exposure pathways arc still present and
there still exists a potential for contaminant migration.
Alternatives 2, 3, 4, 5 and 6 will comply with the ARARs. These alternatives will restrict property
access, remove and treat soil, or remove contaminated soil to an alternate controlled location.
Alternatives 2, 3, 4, 5 and 6 will adequately protect human health and the environment.
Long-term Effectiveness and Permanence
Based on existing organic concentrations and proposed land use, Alternative 1 does not reduce the long-
term risk to human health. Although no measurable negative on the environment lias been identified to
date, the potential for contaminant migration may pose a future risk to the environment. Therefore,
Alternative 1 does not meet this criterion.
Alternative 2 partially meets this criterion. This alternative will slowly decrease the risk to human health
and the environment via natural attenuation. Deed restrictions and the risk management strategies under
this alternative will also reduce the potential for human exposure. However, the continued presence and
migration of the contaminants may pose risks to the environment until concentralions are lowered via
natural attenuation processes.
JOAAP Record ofDecision -Soil & Groundwater OUs - October, 1998 pg. 8-15
-------
Alternatives 3, 4 and 5 provide the most permanent solution since contaminants are treated to meet RGs
It should be noted that Alternative 6 would not be effective if the disposal landfill fails. However the
landfill will be in compliance with RCRA and is designed to minimize the possibility of failure.
Residual risks associated with interim actions will be addressed with implementation of final remedial
uCtion.
Seduction ofToxicity, Mobility, or Volume through Treatment
Alternatives 1 and 2 do not provide any active reduction of toxicity, mobility or volume of the
contaminants because removal or treatment of the contaminated soil would not be components of these
alternatives.
Alternatives 3, 4 and 5 permanently reduce the toxicity, mobility, and volumes of contaminants by
removing and treating them. Therefore, these three alternatives fully meet this criterion. Alternative 6
partially meets this criterion. This alternative removes the contaminated soil from the sites and transports
it to a landfill without any treatment. Therefore, the overall toxicity and volume will not be affected by
this alternative, but mobility will be reduced. .
Short-term Effectiveness
Since no remedial actions are implemented under Alternative 1, this alternative poses no short-term
impacts to the community, workers, or the environment. However, RGs will not be reached under this
alternative. Alternative 1 does not meet this criterion. Minimal site activities are performed under Alter-
native 2 limiting short-term impacts to workers. However, the rate of natural attenuation is likely to be
slow and will require a long time to achieve RGs. Therefore, this alternative partially meets this criterion.
Alternatives 34, 5, and 6 fully meet this criterion. Alternatives 3, 4, and 5 activities are conducted on-
site, therefore the community will not be subjected to any short-term impacts due to the remedial actions
However, for these three alternatives, there is a potential for workers' exposure and short-term impacts to
the environment as a result of erosion during excavation activities. Alternative 6 may have short-term
impacts on the community, worker health, and the environment due the transportation of contaminated
soil tor off-site disposal.
Implementability
Alternatives 1 and 2 would be the most easily implemented. Alternative 1 would require no technical
action, and Alternative 2 would require minimal action. Implementation of Alternatives 3 and 6 would
mamly consist of excavation, treatment or disposal. These two alternatives fully meet this criterion
Alternatives 4 and 5 partially meet this criterion. Technically, there may be some constraints for
implementing Alternatives 4 and 5, but no constraints are anticipated for Alternatives 3 and 6.
Cost
The following estimated cost includes capital, operational, and maintenance for all alternatives. These are
present worth costs and are adjusted for the length of time to complete each alternative.
Alternative 1:
Alternative 2:
Alternative 3:
Alternative 4:
Alternative 5:
Alternative 6:
No Action
Institutional Controls
Bioremediation
Solvent Extraction
On-site LTTD
Excavation and Disposal
$ 0
$ 100,000
$ 2,200,000
S 1,300,000
$ 1,800,000
$ 300,000
JOAAP Record of Decision- Soil & Groundwater OVs - October, 1998
pg. 8-16
-------
State Acceptance
The State of Illinois concurs with the acceptability of Alternatives 3, 4 and 6 based on these alternatives
complying with the ARARs. The IEPA prefers Alternative 6: Excavation and Disposal.
Community Acceptance
Comments received during the Public review period and from the January 8, 1998, Public Meeting were
transcribed and are included in the Responsiveness Summary of this document. Responses to these
comments are also included in the Responsiveness Summary. Generally, these comments were positive
in nature. There is a concern and request from the community to expedite the remediation process. The
community appears to concur with the selected remedy.
8.2.5.1 Summary Evaluation of Alternatives for SRU5
Table 8-5 compares the alternatives considered for SRU5 with respect to the nine CHRCLA evaluation
criteria. The threshold criteria could not be met by the No Action alternative, hence this alternative was
not selected. The Institutional Controls alternative was not selected because although this alternative met
the threshold criteria, its long- and short-term effectiveness, and its reduction in loxicity, mobility or
volume through treatment were only partially met. Natural attenuation processes in the Institutional
Controls alternative are not effective for high organics concentrations in the soils. The U.S. Army
selected Excavation and Disposal as the recommended alternative for SRU 5 for the following reasons.
The threshold criteria could be met by this alternative as well as by Bioremediation, Solvent Extraction,
and On-site Low-temperature Thermal Desorption. Each would reduce the risk of direct contact with the
organic compounds in the soil and debris. However, because Excavation and Disposal is easier to
implement, can be implemented in a quicker time frame, and has a lower cost, it was selected as the
recommended alternative.
8.2.6 SRU6: Landfills
The alternatives evaluated for this SRU are:
Alternative 1: No Action
Alternative 2: Institutional Controls
Alternative 3: Capping
Alternative 4: Excavation and Disposal
SRU6 includes only final remedial actions. Following is a summary of the comparative analysis of these
alternatives.
Overall Protection to the Human Health and the Environment
Alternatives 1 and 2 do not meet this criterion. These two alternatives do not adequately provide
protection to human health. Alternative 1 does not eliminate the potential for direct human contact with
contaminants and potential hazards at the sites. Alternative 2 minimizes human health risks by preventing
direct contact, but it does not eliminate the potential for contaminants migration.
Alternative 3 fully meets this criterion. This alternative is protective of human health and the
environment through containment of the waste and elimination of exposure routes. Alternative 4 fully
meets this criterion. This alternative provides immediate and permanent protection to human health and
the environment by removing the contaminated soil to a permitted landfill. Some minimal potential for
future impacts to human health and the environment exist in this option in the event of a failure of the
landfill containment structure.
JOAAP Record of Decision-Soil & GroundwaterOUs - October, 1998 pg. 8-17
-------
Table fl-5: Evaluation of Remedial Alternatives for SRU5 TOrganics in Soil)
Remedial Alternative
Threshold
"Si
1*1
III
a: ui
Evaluation Criteria
Balancing
tug
S
c
-
1
•
Modifying
i
Q.
§
a
t/j
<
>.
1. No Action
2. Institutional Controls
3. Biorcmediation
4. Solvent Extraction
5. On-site Low-Tcmpcraturc
Thermal Dcsorption
6. Excavation and Disposal
O O
O O
O
O
O
100
1,300
1,800
NA
NA
NA
NA
Fully meets criteria
Ranking Key:
Notes: NA- Not addressed by public comments
Partially meets criteria
Does not meet criteria
** - Threshold criterion 1 is applied fully for final remedial actions. It is applied to interim
remedial actions while recognizing that the interim actions taken may not be the final actions.
Compliance with Applicable or Relevant and Appropriate Requirements
Alternatives 1 and 2 will not comply with the ARARs. In Alternative 1, exposure pathways are still
present and there still exists a potential for contaminant migration. In Alternative 2, the potential for
contaminants migration will still be present In addition, neither of these alternatives comply with Illinois
State laws for landfill closure.
Alternatives 3 and 4 will comply with the ARARs. Alternatives 3 and 4 will adequately protect human
health and the environment.
Long-term Effectiveness and Permanence
Alternative 1 does not meet this criterion. Based on the existing contamination and the proposed land
use, Alternative 1 does not reduce the long-term risk to human health. In addition, the potential for
contaminant migration may pose future risks to the environment. Alternative 2 partially meets this
criterion. This alternative will slightly decrease the risk to human health by reducing the potential for
human exposure. However, the continued presence and migration of the contaminants may pose future
risk to the environment.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
pg. 8-18
-------
Alternative 3 fully meets this criterion. In Alternative 3, there is residual risk with the contaminants and
other hazards remaining on-site and contained by the caps. The caps reduce the human health risk and
environmental risk to acceptable levels. In addition the caps will prevent infiltration of precipitation that
may leach out contaminants from the landfills. Alternative 4 also fully meets this criterion. This
alternative excavates the contaminated media and eliminates the potential for future risks associated with
direct contact and contaminants migration by placing! the wastes in a permitted landfill.
Reduction ofToxicity, Mobility, or Volume through Treatment
Alternatives 1 and 2 would not provide any active reduction of toxicity, mobility, or volume of the
contaminants because removal or treatment of the contaminated soil would not be components of this
alternative.
Alternatives 3 and 4 partially meet this criterion. Alternative 3 reduces the mobility of contaminants, but
not the overall toxicity and volume. Alternative 4 removes the contaminated soil from the sites and
transports it to a landfill without any treatment. Therefore, the overall toxicity and volume of the wastes
will not be affected by this alternative, but their mobility will be reduced.
Short-term Effectiveness
Since ho remedial actions are implemented under Alternative 1, this alternative poses no short-term
impacts to the community, workers, or the environment. However, RGs will not be reached under this
alternative. Alternative 1 does not meet this criterion. Minimal site activities are performed under
Alternative 2, limiting the short-term impacts on workers. However, wastes will still be present in these
units. Therefore, this alternative partially meets this criterion.
Alternative 3 fully meets this criterion. Alternative 3 poses no short term impacts to the community
because all remedial activities will be occurring on-site. Worker health may be affected during the
excavation and regrading of the contaminated media. There is also a potential short-term impact to the
environment due to the erosion during the remedial activities.
Alternative 4 fully meets this criterion. Most of the activities in this alternative arc conducted on-site,
therefore the community, worker health, and the environment will be subjected to short term impacts due
to the excavation and transportation of contaminated soil for off-site disposal.
Implementability
Alternatives 1 and 2 would be the most easily implemented. Alternative 1 would require no technical
action, and Alternative 2 would require minimal action. Alternatives 3 would mainly consists of
regrading. Alternative 4 would mainly consist of excavation and disposal. These two alternatives fully
meet this criterion. There are no technical constraints for meeting this criterion.
Cost
The following estimated cost includes capital, operational, and maintenance for all alternatives. These are
present worth costs and are adjusted for the length of time to complete each alternative.
Alternative 1: No Action $ 0
Alternative 2: Institutional Controls $ 3,000,000
Alternatives: Capping $19,900,000
Alternative 4: Excavation and Disposal $12,100,000
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg. 8-19
-------
State Acceptance
The State of Illinois concurs with the acceptability of Alternatives 3 and 4 based on these alternatives
complying with the ARARs. The IEPA prefers the combination of Alternative 3 and 4.
Community Acceptance
Comments received during the Public review period and from the January 8, 1998 Public Meeting were
transcribed and are included in the Responsiveness Summary of this document. Responses to these
comments are also included in the Responsiveness Summary. Generally, these comments were positive
in nature. There is a concern and request from the community to expedite the remediation process The
community appears to concur with the selected remedy.
8.2.6.1 Summary Evaluation of Alternatives for SRU6
Table 8-6 compares the alternatives considered for SRU6 with respect to the nine CI-RCLA evaluation
criteria. The threshold criteria could not be met by the No Action and Institutional Controls alternatives
because they neither prevent human exposure to the waste nor reduce potential waste migration, therefore
these two alternatives were not selected. Additionally, natural attenuation processes in the Institutional
Controls alternative are not effective at treating materials buried in the landfills The U S Army
T?0^,1"^111*1 CappinS of the ^ndfills in L3, Mil and M13; and Excavation and Disposal of soils in
LA, Ml and M9 would best serve the cleanup requirements of the sites in SRU6.
The threshold criteria are met by this combination of actions. These recommended alternatives would be
expensive; however, they would reduce the risks of direct contact with human and the environment
Because the potential presence of UXO poses workers safety issues, Capping rather than Excavation and
Disposal is the recommended alternative for L3. Although the landfill in site L4 could be capped the
recommended alternative is Excavation and Disposal because this landfill is in a flood plain. The reasons
why the sites in Ml and M9 are being excavated and disposed of are:
• Three previous attempts to cap these landfills failed,
• Disposal provides a more effective containment than Capping, and
• The ash at M1 may be in direct contact with groundwater and a continuing source of groundwater
contamination.
The Army is seeking ways and means for beneficial reuse of the ash from sites Ml and M9.
8.2.7 SRU7: Sulfur
The alternatives evaluated for this SRU are:
Alternative 1: No Action
Alternative 2: Institutional Controls
Alternative 3: Removal and Recycling or Disposal
The removal of sulfur is not regulated under CERCLA. SRU7 includes only final remedial actions
Following is a summary of the comparative analysis of these alternatives.
Overall Protection to the Human Health and the Environment
Alternatives 1 and 2 do not meet this criterion. Alternative 1 does not eliminate the potential for direct
human contact with contaminants and potential hazards at the sites. Alternative 2 minimizes human
health risks by preventing direct contact. Both of these alternatives do not provide any protection to the
environment. Alternative 3 fully meets this criterion. This alternative provides immediate and permanent
protection to human health and the environment by removing the sulfur.
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998
pg. 8-20
-------
Table 8-6; Evaluation of Remedial Alternatives for SRTJ6 landfills)
Remedial Alternative
1 . No Action
2. Institutional Controls
3. Capping (Sites L3, Ml 1
and M 13)'
4. Excavation and Disposal
(Sites L4, Ml andM9)2
S
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u
1
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Evaluation Criteria
Threshold
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Ranking Key:
Fully meets criteria
Partially meets criteria
Does not meet criteria
Notes: NA - Not addressed by public comments
** -All remedial actions are final for SRU6. Threshold criterion 1 is applied fully to these actions,
1) Sites L3 and Ml 3 proposed for Subtitle D cap. Site Mil proposed for Subtitle C cap.
2) Sites L4. Ml. and M9 proposed for excavation and disposal in WCLF or other permitted
solid waste landfill off-site.
Compliance with Applicable or Relevant and Appropriate Requirements
Alternative 1 will not comply with the ARARs. In Alternative 1 exposure pathways arc still present and
there still exists a potential for contaminant migration. Alternative 2 fully meets this criterion. The
potential for contaminants migration will still be present; however human exposure will be eliminated.
Alternative 3 will comply with the ARARs. Alternative 3 will adequately protect human health and the
environment. In addition, this alternative includes a possibility for the reuse or recycle of sulfur.
Long-term Effectiveness and Permanence
Alternative 1 does not meet this criterion. Based on the existing contamination and the proposed land
use, Alternative 1 does not reduce the long-term risk to human health. In addition, the potential for
contaminant migration may pose future risks to the environment.
Alternative 2 partially meets this criterion. This alternative will slightly decrease the risk to human health
and will somewhat be effective at reducing the potential for human exposure. However, the continued
presence and migration of the contaminants may pose future risk to the environment. Alternative 3 fully
meets this criterion. This alternative excavates the contaminated media and eliminates the potential for
future risks associated with direct contact and contaminants migration.
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998
pg. 8-21
-------
Reduction ofToxicity, Mobility, or Volume through Treatment
Alternatives 1 and 2 do not provide any active reduction of toxicity, mobility, or volume of the
contaminants because removal or treatment of the contaminated soil would not be components of these
alternatives.
Alternative 3 fully meets this criterion. Alternative 3 removes the sulfur from the sites and transports it to
a landfill without any treatment or for reuse/recycle. Therefore, the overall toxicity, mobility, and volume
will not be affected by this alternative if the ultimate disposal is in a landfill. However, there will be a
great reduction in toxicity, mobility, and volume if the sulfur is reused or recycled.
Short-term Effectiveness
Since no remedial actions are implemented under Alternative 1, this alternative poses no short-term
impacts to the community, workers, or the environment. However, RGs will not be reached under this
alternative. Alternative I does not meet this criterion. Minimal site activities are performed under
Alternative 2, limiting short-term impacts to workers. However, the rate of natural attenuation to achieve
RGs is likely to be slow. Therefore, this alternative partially meets this criterion.
Alternative 3 fully meets this criterion. Most of the activities in this alternative arc conducted on-site-
therefore the community, worker health, and the environment will be subjected to minimal short-term
impacts due to the excavation and the transportation of sulfur for off-site disposal.
Implementability
Alternatives 1 and 2 would be the most easily implemented. Alternative 1 would require no technical
action, and Alternative 2 would require minimal action. Implementation of Alternatives 3 would mainly
consist of excavation and disposal. This alternative fully meets this criterion. There are neither technical
nor administrative constraints for meeting this criterion.
Cost
The following estimated cost includes capital, operational, and maintenance for all alternatives. These are
present worth costs and are adjusted for the length of time to complete each alternative.
Alternative 1: No Action
Alternative 2: Institutional Controls
Alternative 3: Removal and Recycle or Disposal
$ 0
$ 100,000
$ 200,000
State Acceptance
The IEPA concurs with the acceptability of and prefers Alternative 3 based on this alternative complying
with the ARARs.
Community Acceptance
Comments received during the Public review period and from the January 8, 1998, Public Meeting were
transcribed and are included in the Responsiveness Summary of this document. Responses to these
comments are also included in the Responsiveness Summary. Generally, these comments were positive
in nature. There is a concern and request from the community to expedite the remediation process. The
community appears to concur with the selected remedy.
8.2.7.1 Summary Evaluation of Alternatives for SRU7
Table 8-7 compares the alternatives considered for SRU7 with respect to the nine CERCLA evaluation
criteria. The threshold criteria could not be met by the No Action and Institutional Controls alternatives
JOAAP Record of Decision-Soil & Groundwater OVs - October, 1998
pg. 8-22
-------
selected
be
n I ** "** * ** environment< ^fore these two alternatives were not
?°n Pr°CeSSf m th£ Institutional Contro* alternative may be determined not to
^^^ of sulfur Present- In Addition, these two alternatives do not remove a
or, r1" ^°fU"dwa*r C0n*minati0n' ™6 U'S- ^y Selected direc< Removal and either
or Recycling of the sulfur as the recommended alternative for SRU7.
m^.pr°vide aij in"°vative and beneficial reuse of the sulfur and would not increase
costs. In addition, this alternative would be protective to human health and the environment and
would not use up space m the future proposed WCLF.
Table 8-7: Evaluation of Remedial Alfornatives for Sl^T?
Remedial Alternative
1 . No Action
2. Institutional Controls
3. Removal/Recycle-'
Disposal
n
c
0
<
•8
8
CO
t/
— — — — — — . _
Threshold
vt
a:
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. g i . 5
g "S S S
- ~ 1 .2
2 S.I 1-
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0 = 5 6
— CN
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Evaluation Criteria
5a/a/ic//jg
8 S
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!=S £'5^ >S i= "
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O NA
O NA
• •
Ranking Key:
Fully meets criteria ^ Partially niceis criteria
(^ Does not meet criteria
Notes: NA - Not addressed by public comments
**-AU remedial actions are final for SRU6. Threshold criterion 1 is applied fully ,„ these actions.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998
pg. 8-23
-------
8.2,8 Summary of Selected Remedies for all ,
Table 8-8 presents a summary evaluation of selected remedies for each SRU. The total estimated net
present worth of remedial actions for the SOU is $84,000,000.
: Sumipary of Recommended Remedial Alternatives for All SR^Is LAP and
MFC Areas
Remedial Alternative
Threshold
•
.
S 5 §
O. = §
O S
|
.£
8
n
1
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Evaluation Criteria
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f
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=
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a
n.
o
U
Biore mediation
Excavation and Disposal
Biorcmediation and
Disposal, and Excavation
and Disposal
Excavation/Incineration
and Disposal
Excavation and Disposal
tapping or Excavation and
disposal
Removal/Recycle/Disposal
39,300
300
32.000
200
,.'
otal of All SRUs
84,000
Ranking Key:
Fully meets criteria
Partially meets criteria
Does not meet criteria
JOAAP Record ofDecision- Soil & Groundwater OUs - October, 1998
Pg- 8-24
-------
8.3 Groundwater Operable Unit
There are currently no human or ecological receptors of the groundwater within the CJRU1, GRU2, and
GRU3, and therefore no pathway and no exposure scenario. .
All groundwater-related remedial actions and evaluations are considered final in this ROD.
— GRU1: Explosives in Groundwater - LAP Area
The alternatives evaluated for this GRU are:
Alternative 1 : No Action
Alternative 2: Limited Action
Alternative 3: Pump and Treat by Carbon Adsorption
Following is a summary of the comparative analysis of these alternatives.
Overall Protection to the Human Health and the Environment
Alternative 1 does not provide adequate overall protection of human health, because complete pathways
for groundwater exposure at any of the sites may exist. Alternative 2 protects human health and the
environment through the use of GMZs and deed restrictions as well as by providing groundwater and
surface water quality data that can be used to evaluate the rate of natural attenuation. This long-term
monitoring data will allow risk-based decisions to be made regarding current and future use of the sites,
as well as indicate the current status and any trends in contaminant concentrations as a result of natural
degradation and dispersion processes. Alternative 3 protects human health and the environment through
the use of GMZs and deed restrictions. By recovering and treating groundwater, Alternative 3 reduces the
overall risk associated with all the sites in the event that exposure pathways for groundwater are
completed. This alternative is therefore protective of human health and the environment, both currently
and in the future.
Compliance with Applicable or Relevant and Appropriate Requirements
Alternative 2 and Alternative 3 will comply with the ARARs. Because RGs are exceeded and no
corrective actions are included under Alternative 1, this alternative violates 35 IAC 620.
Long-term Effectiveness and Permanence
Alternative 1 partially meets this criterion. Groundwater currently poses no risk (o human health at
GRU1 because of the lack of complete exposure pathways. However, there are no controls implemented
under this alternative, so the adequacy and reliability of controls cannot be evaluated.
Alternatives 2 and 3 fully meet the long-term effectiveness and performance criteria. The Limited Action
is part of a groundwater management program that permits a periodic and reliable check on contaminant
movement and characteristics. This alternative will monitor contaminant natural attenuation on a regular
basis. As a result, appropriate action can be taken if necessary. Alternately, the scope of monitoring can
be reduced as natural processes reduce contaminant concentrations.
Alternative 3 reduces the concentration of contaminants more rapidly to the RGs than Alternative 2. The
controls are considered reliable and adequate for the protection of human health and (lie environment.
Reduction ofToxicity, Mobility, or Volume through Treatment
Alternative 1 does not reduce the toxicity, mobility, or volume of contaminants or contaminated media.
The concentration of explosives in groundwater will decrease naturally, provided that the source is
removed. However, the rate of this decrease cannot be accurately predicted.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 8-25
-------
Alternative 2 will decrease the toxicity of explosives by lowering their concentrations via physical
processes such as dilution and dispersion. Natural attenuation may reduce the mobility through the
adsorption of contaminants to the soil and rock. Limited Action alternative may also decrease the volume
of explosives through destructive processes such as biodegradation or biotic transformation. Enhancing
these processes with phytoremediation may also reduce the toxicity and mobility of contaminants at some
sites if this process is found to be effective.
Alternative 3 will reduce the toxicity and volume of contaminants in groundwater by removing
contaminated groundwater. The extraction of groundwater will encourage nearby groundwater to flow to
the extraction wells or trenches, limiting the mobility of the contaminants and discouraging further
migration or discharge to nearby streams.
Short-term Effectiveness
Alternative 1 partially meets this criterion. Because no remedial actions are taken under this alternative,
there are no short-term impacts on community or worker health or the environment from the construction
or implementation activities. RGs will be achieved by this alternative via the mechanisms-of natural
attenuation, dilution, and dispersion. The time to reach the RGs can not be accurately estimated.
Alternative 2 will have minimal short-term impacts oil worker or community health or on the
environment. RGs will be achieved by this alternative via the mechanisms of natural attenuation. The
time to reach the RGs varies for different sites and is dependent upon initial contaminant concentrations
and the hydrogeological characteristics of the aquifers.
Alternative 3 will cause minimal impacts on the community. Because implementation of carbon
adsorption treatment potentially involves off-site transportation of contaminated waste, its
implementation may present a short-term impact to the community in the event of a release. The time to
reach the RGs varies for different sites, although this alternative will achieve RCis more quickly than
Alternative 2.
Implementabttity
Alternative 1 is readily implementable. No construction-related implementation considerations are
associated with the No Action alternative. No permits or other specific administrative/regulatory
approvals are needed with the No Action alternative.
Implementation of Alternative 2 requires construction of monitoring wells. The installation of new
monitoring wells is easily implemented. Most wells are already installed and long-term monitoring is
routine and does not affect other remedial actions that may occur on-site. The technology requirements
for monitoring are low and involve widely adopted standard industry practices. Continued use of the
wells for periodic sampling will pose no institutional or regulatory problems. Establishment of the GMZs
would require the lEPA's approval. Fencing and warning signs are readily available, and deed
restrictions require filing of required paperwork and forms.
Implementation of the Alternative 3 will require some construction activities, especially at Site LI. The
potential difficulty in operation of the carbon adsorption system may be related to the relatively high
levels of minerals found in the groundwater of the region. Several minerals may precipitate and clog the
carbon filters. It is also likely that Alternative 3 will have to rely on natural attenuation to achieve RGs
because pump and treatment technologies usually lose their effectiveness prior to achieving RGs.
JOAAP Record of'Decision -Soil & Groundwater OUs - October, 1998 pg. $-26
-------
Cost
The following estimated cost includes capital, operational, and maintenance for all alternatives. These are
present worth costs and are adjusted for the length of time to complete each alternative.
Alternative 1: No Action $ ()
Alternative 2: Limited Action $ 530000
Alternative 3: Pump and Treat by Carbon Adsorption $ 3,800^000
State Acceptance
ThfuI?P^?^UrS W'th the accePtability of and prefers Alternative 2 based on this alternative complying
with the ARARs.
Community Acceptance
Comments received during the Public review period and from the January 8, 1998 Public Meeting were
transcribed and are included in the Responsiveness Summary of this document. Responses to these
comments are also included in the Responsiveness Summary. Generally, these comments were positive
in nature There is a concern and request from the community to expedite the remediation process. In
general, the community appears to concur with the selected remedy.
8.3 J.I Summary Evaluation of Alternatives for GRU1
Table 8-9 compares the alternatives considered for GRU1 with respect to the nine CKRCLA evaluation
cntena. The detailed analysis of alternatives for the GRU1 determined that the No Action alternative will
not comply with the Illinois groundwater regulations. If no action is taken, the potential remains for
undetected migration of and human exposure to contaminated groundwater. The threshold criteria would
be met by the Limited Action alternative or the Pump and Treat by Carbon Adsorption alternative. Each
will reduce the risk of direct contact with the contaminants in the groundwater of GRU1. All alternatives
will benefit by the treatment or removal of contaminated soil that is the primary source for continuing
groundwater contamination.
The Limited Action is the recommended alternative for the following reasons. First the actual risk of
direct exposure to the shallow groundwater is very limited in GRU1 because most of the contamination
resides in the glacial drift aquifer that is not used as a water supply source. In addition, data and modeling
indicates that the plumes will not migrate and pose risks to human health or the environment. It is also
likely that the Pump and Treat by Carbon Adsorption alternative would need to rely on natural
attenuation. This is because the low yield of the glacial drift aquifer makes it difficult to effectively
withdraw groundwater. Case histories have shown that such systems lose their effectiveness prior to
reaching RGs. In light of these reasons, the higher cost of the Pump and Treat by (:arbon Adsorption
alternative over the Limited Action alternative does not appear to be justified, given that the Limited
Action alternative will achieve the RGs.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 8-27
-------
Remedial Alternative
t. No Action
2. Limited Action
3. Pump and Treat with
Carbon Adsorption
Selected Alternative
V
Threshold
1. Overall Protection of
Human Health and the
finvironment
2. Compliance with ARARs
0 0
gmauvca mi VTI^UJ IJkXplOSlVeS ir| t^ff
LAP Ar?3)
rmndwarer-
Evaluation Criteria
Balancing
s a
CT • *"* C
| £ c£ g w II
|| i°j^ § g so
it in i i as
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8. State Acceptance
9. Community Acceptance
O NA
• o
A r~\
Ranking Key: ^ Fully meets criteria Q Partially mcc,s criteria
(^_^) Does not meet criteria
//ores.- NA - Not addressed by public comments
All remedial actions are final for GRU1.
GRU2; Explosives and Other Contaminants in Groundwater - MFC
The alternatives evaluated for this GRU are:
Alternative 1:
Alternative 2:
Alternative 3:
Alternative 4:
Alternative 5:
No Action
Limited Action
Pump and Treat with Bioreactor
Pump and Treat by Carbon Adsorption
Pump and Treat by UV Oxidation/Carbon Adsorption
Following is a summary of the comparative analysis of these alternatives.
Overall Protection to the Human Health and the Environment
Alternative 1 does not meet this criterion. The potential pathways for human exposure are ingestion by
industrial workers and exposure of construction workers during intrusive work, and the presence of
groundwater above the ground surface at certain locations of M6.
Alternative 2 will provide protection of human health by restricting use and possible contact with affected
groundwater. The process of natural attenuation will be closely monitored through the GMZ program to
ensure achievement of the RGs.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
pg. 8-28
-------
Alternatives 3, 4, and 5 will be effective in providing protection to human health and the environment.
They provide for removal of contaminated groundwater and subsequent treatment to destroy the
contaminants. This will result in the attainment of the RGs and hence protection to human health and the
environment. Alternatives 3,4, and 5 also provide protection to human health and the environment
through the use of GMZs and deed restrictions.
i
Compliance with Applicable or Relevant and Appropriate Requirements
Alternative 1 will not comply with the chemical-specific ARARs since reduction of the contaminant
concentrations to the RGs through natural attenuation may not occur, even if it does occur, in a reasonable
length of time.
Alternative 2 will comply with action- and location-specific ARARs, since minimal intrusive field
activities will be undertaken during the construction offences and installation of monitoring wells. There
are no Federal or State regulations specifying cleanup levels for explosives in groundwater. Alternative
3,4, and 5 will comply with the ARARs.
Long-term Effectiveness and Permanence
Alternative 1 will not result in the reduction of the contaminants concentrations except through natural
attenuation. Because there are no measures that will limit exposure or monitor potential off-site
migration, the No Action alternative will not be effective in preventing potential impact of the
constituents to human health and the environment.
Alternative 2 assumes that the removal or remediation of sources will be performed. Following the
remediation, the long-term risks associated with continued contamination in the underlying groundwater
will be minimized. Residual contamination will be monitored through a long-term program under the
GMZs. A reduction of contaminant levels in the groundwater will occur via natural attenuation
processes. Alternative 3, 4, and 5 will provide long-term protection of human health and the environment
because they actively remove the groundwater and treat the contaminants. These processes are
irreversible and represent a high degree of permanence.
Reduction ofToxicity, Mobility, or Volume through Treatment
Alternative 1 does not reduce the toxicity, mobility, or volume of contaminants or contaminated media.
The concentration of explosives in groundwater will decrease naturally, provided that the source is
removed. However, the rate of this decrease cannot be accurately predicted.
Alternative 2 will decrease the toxicity of explosives by lowering their concentrations via physical
processes such as dilution and dispersion. Natural attenuation may reduce the mobility through the
adsorption of contaminants to the soil and rock. Limited Action alternative may also decrease the volume
of explosives through destructive processes such as biodegradation or biotic transformation. Enhancing
these processes with phytoremediation may also reduce the toxicity and mobility of contaminants at some
sites if this process is found to be effective.
Alternative 3, 4, and 5 will result in a significant reduction in the toxicity, mobility and volume of the
contaminated groundwater.
Short-term Effectiveness
Alternative 1 will not create additional environmental impact. The pathways for human exposure will
remain the same. Because no remedial activities will be undertaken, there will be no short-term impacts
associated with construction or other site activities.
JOAAPRecord of Decision -Soil& Groundwater OUs - October, 1998 pg. 8-29
-------
Alternative 2 will result in no additional environmental impact. Since the area is proposed for industrial
use, potential exists for human exposure to the contaminated water in the wetland area of M6. Because
Limited Action alternative will be undertaken, there will be minimal short-term impacts to remedial
workers during the construction and implementation period.
Alternative 3, 4, and 5 will result in short-term exposure of workers to the contaminated groundwater.
Another short-term impact may be posed to the community and the environment during the transportation
of spent carbon. There may be minimal short-term impacts to industrial workers during the construction
phase for Alternative 3.
Implementability
Alternative 1 alternative is readily implementable. There are no technologies to be employed in this
alternative. Alternative 2 is easily implementable. Existing monitoring wells will be used for sampling
and the installation of new monitoring wells will involve conventional techniques. listablishment of the
GMZs would require the lEPA's approval. Fencing and warning signs are readily available, and deed
restrictions require filling of required paperwork and forms.
Alternative 3 is not a widely used technology and it does not have an established record of successful full-
scale application. Design of the system will require some specialized engineering skills and treatabiliry
and pilot studies will be needed to ensure attainment of anticipated performance.
Alternative 4 and 5 are fairly easy to implement. The only practical physical problem that may be
encountered in construction is common to any system of centralized groundwater treatment. Existing
structures and piping may present problems in laying out a system or collection lines, and the construction
of over two miles of collection trenches may pose operational difficulties.
Cost
The following estimated cost includes capital, operational, and maintenance for all alternatives. These are
present worth costs and are adjusted for the length of time to complete each alternative.
Alternative 1 : No Action $ Q
Alternative 2: Limited Action $ 3,300,000
Alternatives: Pump and Treat with Bioreactor $ I3,700,'o00
Alternative 4: Pump and Treat by Carbon Adsorption $ 1 6,500,000
Alternative 5: Pump and Treat by UV Oxidation/Carbon Adsorption $
State Acceptance
The IEPA concurs with the acceptability of and prefers Alternative 2 based on this alternative complying
with the ARARs.
Community Acceptance
Comments received during the Public review period and from the January 8, 1998, Public Meeting were
transcribed and are included in the Responsiveness Summary of this document. Responses to these
comments are also included in the Responsiveness Summary. Generally, these comments were positive
in nature. There is a concern and request from the community to expedite the remediation process. In
general, the community appears to concur with the selected remedy.
8.3.2.1 Summary Evaluation of Alternatives for GRU2
Table 8-10 compares the alternatives considered for GRU2 with respect to the nine CBR.CLA evaluation
criteria. The No Action alternative will not comply with the Illinois groundwater regulations and it does
JOAAP Record ofDecision -Soil & Groundwater OUs - October, 1998 Pg. 8-30
-------
not meet the threshold criteria. The threshold criteria will be met by each of the other alternatives All
alternatives would also benefit from the removal of contaminated soil because this action will remove the
primary source for continuing ground water contamination.
Limited Action is the recommended alternative because most of the contamination resides in the glacial
drift aquifer that is not used as a water supply. In addition, the groundwater pumping system required for
the other alternatives might be difficult to design, construct, and operate. This system may also not be
able to effectively withdraw groundwater from the glacial drift aquifer because of its low permeability
Therefore, these alternatives would also have to rely on natural attenuation to achieve RGs Testing
groundwater monitoring, and modeling data show that the plumes will not migrate and pose risks to
human health and the environment; therefore, the Limited Action alternative provides a more cost
effective means of achieving the RGs as opposed to any of the pump and treatment alternatives
$-]Q: Evaluation of Remedial Alternatives for GRU2
Contaminants in firnnjidwater - MFC
dOth
Remedial Alternative
Threshold
|1
u jr
2.
2
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s s
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1 . No Action
2. Limited Action
3. Pump and Treat with
Bioreactor
4. Pump and Treat with
Carbon Adsorption
5. Pump and Treat with
UV Oxidation/ Carbon
Adsorption
O O
o
Q Q
0
3,300
13,700
16,500
16.400
o
Ranking Key: ^ Fully meets criteria ^ Panially meets criteria
(____) Does not meet criteria
Notes: NA - Not addressed by public comments
All remedial actions are final for GRU2.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
pg. 8-31
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GRUStVolatile Oreanic Compounds (VOCs\ in Groundwater - MFC Area
The alternatives evaluated for this GRU are: *
Alternative 1: No Action
Alternative 2: Limited Action
Alternative 3: In-Situ Bioremediation
Alternative 4: Pump and Treat by. Air Stripping/Vapor-Phase Carbon Adsorption ' "*
Alternative 5: Pump and Treat by Carbon Adsorption
Alternative 6: Pump and Treat by UV Oxidation
Following is a summary of the comparative analysis of these alternatives.
Overall Protection to the Human Health and the Environment
Alternative 1 does not protect the environment from existing contamination that affects the quality of the
shallow groundwater. Alternative 2 will provide protection of human health by restricting use and
possible contact with contaminated groundwater. Natural attenuation, including biodegradation by
indigenous microorganisms, of the benzene and toluene is likely to take place. This alternative will entail
close monitoring of these processes, thereby providing adequate means of environment protection.
Alternatives 3, 4, 5, and 6 will be quite effective in providing protection to human health and the
environment. They involve the removal and treatment of the contaminated groundwater. This will result
in a reduction of benzene and toluene to the RGs, thus attaining protection of the environment as well.
Alternatives 3, 4, 5, and 6 also provide the protection to human health and the environment through the
use of GMZs and deed restrictions.
Compliance with Applicable or Relevant and Appropriate Requirements
Alternative 1 does not comply with chemical-specific ARARs. The benzene and toluene concentration in
the groundwater is currently above the regulatory levels for drinking water standards. Compliance with
the action- and location-specific ARARs will not be a relevant criterion since no remedial action will take
place.
Alternative 2 will be implemented in a way that will comply with the action- and location-specific
ARARs. Through natural attenuation, compliance with the chemical-specific ARARs is expected over
time. Alternatives 3, 4, 5, and 6 will comply with chemical-, location-, and action-specific ARARs.
Long-term Effectiveness and Permanence
Alternative 1 will not reduce the levels of contamination nor will the alternative prevent contamination
from continuing to migrate. Natural attenuation of constituents over time is the only protection provided
under this alternative.
Alternative 2 will be effective in attaining the RGs through placement of deed restrictions and
implementing close monitoring of natural attenuation processes in the GMZs. This alternative will also
reduce the levels of contamination by the process of natural attenuation.
Alternatives 3,4, 5, and 6 will provide a high level of long-term effectiveness. A long-term groundwater
monitoring program will be implemented to ensure continued protection of human health and the
environment during implementation.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg. 8-32
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Reduction ofToxicity, Mobility, or Volume through Treatment
Alternative 1 will reduce toxicity, mobility, and volume of the groundwater contamination. Since'no
treatment technology is applied with this alternative, the only mechanism that would result in a reduction
of toxicity, mobility, or volume of benzene and toluene contaminated groundwater is natural attenuation.
Intrinsic biodegradation of benzene and toluene has been well documented, therefore, it is anticipated to
satisfy this criterion over time. However, there will be no monitoring and there will be no way to assess
the effectiveness of this alternative.
Alternative 2 will partially satisfy this criterion. Since no treatment technology is applied with this
alternative, the mechanism that will result in a reduction of toxicity, mobility, and volume of benzene and
toluene, is via natural attenuation, including biodegradation. These processes are monitored during the
implementation of this alternative.
Alternatives 3, 4, 5, and 6 will result in the reduction of benzene and toluene concentrations in the
groundwater. Once treated, the groundwater remediation is considered complete because the treatment
process is irreversible.
Short-term Effectiveness
Alternative 1 will partially satisfy this criterion. This alternative will not reduce or remove the toluene
concentration in a short period of time. Under the No Action alternative no remedial actions will be
implemented, therefore, there are no short-term implementation impacts associated with this alternative.
Alternative 2 will fully satisfy this criterion. There will be minimal short-term impacts to human health
and the environment during the remedial action because limited actions will involve only construction of
fences and monitoring wells and the associated monitoring and management activities.
Alternatives 3, 4, 5, and 6 will result in short-term exposure of workers to the contaminated groundwater.
However, because limited construction activities and relatively short duration are required, there is very
little short-term impact to workers.
Implementability
Alternatives 1 and 2 are readily implementable. There are no technologies to be employed in these
alternatives. In Alternative 2, establishment of the GMZs would require the lEPA's approval. Fencing
and warning signs are readily available, and deed restrictions require filling of required paperwork and
forms. Alternatives 3, 4, 5, and 6 are easy to implement. The required equipment can be procured from
the commercial manufactures. Construction of the necessary systems will require conventional
technology. However, the low permeability of the alluvial till will limit the effectiveness of injecting air
or pumping water.
Cost
The following estimated cost includes capital, operational, and maintenance for all alternatives. These are
present worth costs and are adjusted for the length of time to complete each alternative.
Alternative 1: No Action $ 0
Alternative 2: Limited Action $ 700,000
Alternatives: In-Situ Bioremediation $2,100,000
Alternative 4: Pump and Treat with Air Stripping/
Vapor-Phase Carbon Adsorption $2,100,000
Alternatives.- Pump and Treat with Carbon Adsorption $2,100,000
Alternative 6: Pump and Treat with UV Oxidation $ 2,400,000
JOAAP Record of Decision - Soil & Groundwater Oils - October, 1998 pg. 8-33
-------
State Acceptance
The IEPA concurs with the acceptability of and prefers Alternative 2 based on this alternative complying
with the ARARs. . 6
Community Acceptance
Comments received during the Public review period and from the January 8, 1998, Public Meeting were
transcribed and are included in the Responsiveness Summary of this document. Responses to these
comments are also included in the Responsiveness Summary. Generally, these comments were positive
in nature. There is a concern and request from the community to expedite the remediation process. In
general, the community appears to concur with the selected remedy.
8.3.3.1 Summary of Evaluation for GRUB
Table 8-11 compares the alternatives considered for GRU3 with respect to the nine CIZRCLA evaluation
catena. The No Action alternative was not recommended because it will not comply with Illinois
groundwater regulations and does not meet the threshold criteria.
Limited Action is the recommended alternative because the low permeability of the glacial drift will make
injection of air and pumping of water difficult and limit the effectiveness of Alternative 3 through 6 In
addition, case studies demonstrate that natural attenuation would likely be required to achieve RGs under
Alternative 3 through 6 because these systems lose their effectiveness over time. Existing modeling data
show that two plumes will not migrate and pose risks to human health and the environment. Therefore
the Limited Action alternative provides a more cost-effective means of achieving the RGs as opposed to
the other alternatives.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg, s-34
-------
Table 8-11: Evaluation of Remedial Alternatives for GRU3 fVOCs in Groundwater
MEGArea)
Remedial Alternative
1 . No Action
2. Limited Action
3. In-Situ Biorcmediation
4. Pump and Treat with
Air Stripping/ Vapor-
Phase Carbon
Adsorption
5. Pump and Treat with
Carbon Adsorption
6. Pump and Treat with
UV Oxidation
Evaluation Criteria
Threshold
O " u
lie !
s s'i I
CD m tij cj
o o
Balancing
ill
(- o 5
'c o H
i
Q e
r*
"-
.
2-io<>
•
Modifying
Ranking Key:
8
a
&
I
"
<
o
O
NA
Fully meets criteria ^pi Panially meets criteria
Does not meet criteria
Notes: NA - Not addressed by public comments
All remedial actions are final for GRU3.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 Revision J.-J 0/27/98 pg. 8-35
-------
8,3.4 Summary of Selected Remedies for all GRUs
I Table 8-12 presents a summary evaluation of selected remedies for each of the tlircc GRUs. The net
present cost value of remedial actions for the GOU is estimated to be $ 4,530,000.
Table 8-12: Summary of Recommended Remedial Alternatives for All CRT Is—LAP and
MFC Areas
Remedial Alternative
Limited Action
Limited Action
Limited Action
Total of All GRUs
D
O
1
2
3
Evaluation Criteria
Threshold
s.
*~ — c2
.11 1
1? f *?
— ~ c .2
"g S £ -E.
0 C "> ~
> => e 5
O = ta o
—
H Be
S r? g ^
1 « "1 = 1 1 - g
S=y :2oS S — S
ag ^>S ta -o 2
S S o v^j; g « " g
i* "if 6 1 SS
11 ill 1 J 15
r-i ^ ^ o r~"
• d • •
• W • • 3,00
• 0^0
4,530
Modifying
o
c
H.
K o
c "
ra <
5- .£>
3 o
in U
od CK
A r^
•
• ®
Ranking Key:
Fully meets criteria
(_ ) Does not meet criteria
Partially meets criteria
8.4 Cost Summary for Selected Remedies
Table 8-13 provides component costs (capital, annual operation and maintenance, and site closeout costs)
for each selected remedy. The component costs are discounted (at 7% per year) and aggregated to
provide total costs (in NPV). The years shown in Table 8-13 are used in the economic analyses of the
projects. They are the projected years _from initial implementation of remedial design through the
completion of a remedial action - except in the case where a remedial action may take more than 30
years. In that case, 30 years is used as a standard economic projection horizon.
Appendix B provides similarly detailed cost breakdowns for all remedial alternatives considered in this
ROD, not just for the selected alternatives.
JOAAP Record of Decision-SoU & Groundwater OUs - October, 1998 Revision 1 - l/?/27/gj? no; 8-36
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TABLE 8-13; Summary of Estimated Costs of Selected Remedial Alternatives for All SRUs and GRUs
§
a.
8
'
I
I
ft..
f
§
o
I
Oo
vi
Remedial Usit
and Sites
SRUI: Explosives
SRU2: Metals
SRU3: Explosives and
Metals
SRU4: PCBs
SRU5: Organics
SRU6: Landfills
SRU7: Sulfur
GRU1: Explosives
-- LAP Area
GRU2: Explosives and
Other Contaminants --
MFC Area
GRU3: Volatile Organic
Compounds — MFG Area
Total SRUs
Total GRUs
Grand Total
Selected
Alternative?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
JOAAP Area/
Alternative Specific Sites
3: Biorcmcdiation All SRUI
4: Excavation and Disposal All SRU2
3: Biorcmcdiation MFC SRU3
5: Excavation and Disposal LAP SRU3
5: iixcavation/incincralion and
Disposal A1ISRU4
6: Excavation and Disposal All SRUS
3: Capping L3, M1I.M13
4: Excavation and Disposal L4, M 1 , M9
3: Rcmovc/Recycic/Disposal All SRU7
2: Limited Action AIIGRUI
2: Limited Action All GRU2
2: Limited Action A!IGRb'3
Volume Total Cos
(CYorMG) (NPV)
151,480 S 39,300,000
22,940 $ 4,000,000
13,500 $ 4,000,000
17,420 $ 2,800,000
3,416 $ 1,400,000
2,410 $ 300,000
323,600 $ 19,900,000
366,200 $ 12,100,000
7,500 3 200,000
87 $ 530,000
542 $ 3,300,000
3 $ 700,000
908,466 CY S 84,000,000
632 MG $ 4.530.000
$ 88,530,000
Yrs
(I)
3
1
3
1
1
1
30
1
1
30
30
30
Comnonent Costs (in current vear value] •;
$ 13,800,000 $ 9,400,000 $ 900000
$ 4,000,000 $ - S
$ 1,300,000 $ 1,000,000 $ 96,000
$ 2,800,000 $ $
$ 1,400,000 $ $
$ 300,000 S - $
$ 17,200,000 $ 220,000 $ 80,000
S 12,100,000 $ - $
$ 200,000 $ $
$ 50,000 $ 40,000 $
$ 900,000 $ 190,000 $ 14000
S 70,000 S 50.000 S 30000
S 53,000,000 S 11.000,000
$ 1.020.000 $ 280.000 SeeNoic(l)
$ 54,020,000 S 11,280,000
Notes: (I) Years show the estimated time to complete from the first year of implementation through completion of operations and maintenance
Maximum of 30 years is shown for purpose of the economic analysis presented in table. Time to reach RGs may exceed the 30 years shown
(2) Summary of component costs is appropriate only if all have been discounted to same year values (such as present year values).
-------
[END OF SECTION]
•4-
JOAAP Record of Decision - Soil & Groundwater O Us - October, 1998 Revision / -j 0/27/98
pg. 8-38
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9 SELECTED REMEDIES
Based upon consideration of the requirements of CERCLA, the detailed evaluation of alternatives, and
public comments, the Army, with the concurrence of the USEPA and IEPA, has selected the following
remedies for the seven soil remedial units and three gr.oundwater remedial units.
Table 9-1; Selected Remedies and Costs of Clean up for SRUs/nm r«.
Sites
SRU1: Explosives in Soil
SRU2: Metals in Soil
SRU3: Explosives and Metals in Soil
SRU4: PCBsinSoil
SRU5: Organics in Soil
SRU6: Landfills
SRU7: Sulfur
GRU1: Explosives in Groundwater LAP
Area
GRU2: Explosives and Other
Contaminants in Groundwater MFG Area
GRU3: Volatile Organic Compounds
(VOCs) in Groundwater MFG Area
Grand Total Costs
Selected Remedy
Bioremediation
Excavation and Disposal
Bioremediation and Disposal, and
Excavation and Disposal
Excavation/Incineration and
Disposal
Excavation and Disposal
Capping and Excavation and
Disposal
Removal and Recycle or Disposal
Limited Action
Limited Action
Limited Action
Soil Remedial Units
Groundwater Remedial Units
Remedial Units Total
Costs of Clean up
$ 39,300,000
$ 4,000,000
$ 6,800,000
$ 1,400,000
$ 300,000
$ 32,000,000
$ 200,000
$ 530,000
$ 3,300,000
$ 700,000
$ 84,000,000
$ 4r530rOO()
$ 88,530,000
These selected alternatives include the design and implementation of several remedial actions. The
primary objective of the final remedial actions is to effectively mitigate, minimize threats to, and provide
adequate protection of human health and the environment. To meet this objective, the Army developed
remedial action objectives (RAOs) for the Soil and Groundwater OUs. These RAOs for final actions are
summarized as:
I. Clean up contaminants to the site-specific and chemical-specific remediation goals (RGs);
2. Prevent human and environmental exposure to contamination at concentrations above the
RGs;
3. Eliminate soil contamination as a continuing source of groundwater contamination;
4. Prevent migration of contaminants; and
5. Actions will not leave behind any RCRA characteristic wastes, except those contained within
the capped landfills of SRU6.
The objectives of the interim remedial actions are summarized as:
1. Eliminate soil contamination as a continuing source of groundwater contamination;
2. Prevent migration of contaminants;
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
pg. 9-1
-------
The implementation time to reach these goals will vary between each SRU/GRU and will be given later in
this section This time estimate includes the treatment system design and review, and system construction
and/or imp ementation. Long term monitoring is not a part of this estimate. Although this section
presents details of the selected remedy, some changes with the USEPA and IEPA approval may be made
based on the remedial design and construction process.
°^ectjves: The selected ^medial action alternatives are expected to be able to meet the
stated RAOs. To do this, they must perform properly, must be protective of human health and the
wT£T r^ ™Stp°mPiy 7? a" aPPIicable AKA*5- Technology-specific performance objectives
will be specified in the Remedial Design Phase.
Some of the selected alternatives have common remedial actions; therefore, rather than repeating the
description of these remedial actions under each section, these common actions will be described first for
the soil SRUs and then for the groundwater GRUs before referring to these actions under each SRU and
oKU description.
9.1 Soil Operable Unit
2JLJ. — Common Soil OU Actinns
The selected remedies for the soil treatment contain several common actions. Exceptions will be noted as
the common elements are described. With the exception of capping, all the selected remedies include
excavation, treatment, or disposal of soil containing contaminant concentrations above the RGs
Following is a description of the common actions that are included in the selected remedy.
9.1. 1.1 Building Demolition
Where appropriate, some existing building components and structures may need to be demolished prior to
excavating contaminated soil. The RI/FS identifies these buildings. These buildings may be removed
and salvaged as part of the ongoing liquidation contract for JOAAP. If building debris cannot be
salvaged, it will be disposed at the future proposed WCLF or at an existing permitted facility The
disturbance to soil will be minimized during building demolition activities.
9.1.1.2 Soil Excavation, Transportation, and Confirmatory Sampling
Contaminated soil will be excavated from the various subareas within each site, loaded into dump trucks
and transported to either a central treatment area (or treatment areas) for stockpiling (if treatment is part
of the remedy) or for disposal. These trucks must comply with the Illinois Department of Transportation
Regulations if the trucks travel on State roads. Conventional earthmoving equipment will be used for
excavation. Soil excavation will continue until confirmatory sampling confirms that concentration levels
in the sou meet RGs.
The limits of excavation will be determined primarily based on the RI/FS maps/data and by visual
observation of stained soil. These limits will be confirmed with approval from the USEPA and IEPA
using field screen tests, with final confirmatory samples (including both COC and TCLP trsts as
appropriate) analyzed by a laboratory.
If unexploded ordnance (UXO) is encountered, it will be screened and removed for open bum/detonation
or for off-site incineration at a permitted facility. If raw TNT is encountered, it will be processed for
treatment or disposal at a permitted off-site facility, processed to be blended back for treatment at JOAAP
or turned over to the Bureau of Alcohol, Tobacco and Firearms (for reuse in training)
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 „„ g_2
-------
9.1.1.3 Soil Preparation
This action is common to all alternatives where active treatment occurs. After reaching the treatment
area, contaminated soil will be stored in a stockpile area. Soil will be screened and blended within the
stockpile area. Blending of hot-spot soil with less contaminated soil will be conducted to homogenize the
soil for feed into the treatment system. Debris and large stones will be removed using a series of
shaker/separator units. Debris and large stones will be stockpiled for possible pressure washing and will
be reused or properly disposed. UXO or raw TNT encountered in soil preparation will be handled as
described in Section 9.1.1.2.
All trucks used to transport soil will be routed through a wheel wash prior to exiting the treatment area.
Wash water from the trucks and from the pressure wash operation will be containerized and used as
makeup water in the treatment process or containerized for off-site disposal.
If the selected remedy does not involve active treatment (e.g., Excavation and Disposal), excavated soil
will not be transported to a treatment area. Soil will be excavated and may be screened by a mobile
screener/separator for debris and large stones prior to transportation. UXO and raw TNT will be handled
as mentioned earlier.
9.1.1.4 Backfilling, Regrading, and Revegetating Excavated Areas
Excavated areas will be backfilled as required for safety, to prevent ponding, and to promote surface
drainage. The source of the backfill soil will be from an on-site borrow location. Some treated soil can
also be used as clean backfill at any on-site location that does not require structural fill. Depending upon
the time schedule for excavation, this may or may not be the same location from which the soil was
removed. Backfilled areas will be regraded to conform to the surrounding topography. Most of these
backfilled areas will be revegetated with plants consistent with the future land use. For those areas
designated to become part of the Midewin National Tallgrass Prairie, backfilling and reseeding of
excavated areas and identifying sources of borrow will be done in consultation with USDA/FS. Surface
water runoff from remedial action sites will be monitored at specified points to ensure compliance with
NPDES and Illinois water quality standards.
The substantive requirements of ARARs relating to jurisdictional wetlands will be met during the
remedial design and remedial action phases.
9.1.1.5 Soil Disposal
The Army will use the following options that exist for disposal of treated or untreated soils. Soils will be
tested as appropriate and in accordance with procedures approved by USEPA arid 1HPA to determine
whether the soils are RCRA hazardous wastes and whether RGs are exceeded. Based on the results of
these tests, the disposal options for the soils will be as follows:
1. All soils which are contaminated with RCRA hazardous wastes must be:
• Disposed at a RCRA Subtitle C facility, or
• Treated and disposed at a RCRA Subtitle C facility, or
• Treated and disposed at a RCRA Subtitle D facility or may be used as subgrade or
backfill, if the soils are not characteristically hazardous under RCRA, achieve RGs, and
do not exceed LDRs under RCRA.
2. All soils which exceed RGs and are not RCRA hazardous waste must disposed as above or:
• Disposed at a RCRA Subtitle D facility, or
• Used as subgrade fill material, in capped landfills at JOAAP.
3. All remaining soils can be disposed as above, or
• Reused (e.g., as backfill)
JOAAP Record of Decision Soil & Groundwater Oils - October, 1998 Pg. 9-3
-------
These options are available for all soils except the PCB-contaminated soils in SRU4. Applicable final
rule-making under RCRA may amend this section.
9.1,1.6 Institutional Controls — Deed Restrictions on Land and Soils
Deed restrictions have been developed or are being developed separately from this Record of Decision by
the Army, USEPA, IEPA and the future land users. 'These deed restrictions will run with the land until
removed by mutual agreement of the Army, USEPA, IEPA and the current landowner. The deed
restrictions will be recorded with the Will County Recorder (302 N. Chicago Street, Joliet, IL 60432).
Section 120(h)(3) of CERCLA defines precise requirements for the contents of deeds for property to be
transferred from the Federal government, in which, hazardous or toxic substances were stored for greater
than a year, or were released into the environment. Specifically, it states that: "in the case of any real
property owned by the United States on which any hazardous substance was stored for one year or more,
known to have been released, or disposed of, each deed entered into for the transfer of such property by
the United States to any other person or entity shall contain—(A) to the extent such information is
available on the basis of a complete search of agency files—(i) a notice of the type and quantity of such
hazardous substances, (ii) notice of the time at which such storage, release, or disposal took place, and
(iii) a description of the remedial action taken, if any, and (B) a covenant warranting that—(i) all remedial
action necessary to protect human health and the environment with respect to any such substance
remaining on the property has been taken before the date of such transfer, and (ii) any additional remedial
action found to be necessary after the date of such transfer shall be conducted by the United States; and
(C) a clause granting the United States access to the property in any case in which remedial action or
corrective action is found to be necessary after the date of such transfer.
The objectives of these deed restrictions is to protect human health and the environment by (i) ensuring
that land use is consistent with the requirements of PL104-106, and (ii) maintaining the integrity of the
landfill caps at sites L3, Mil and M16 where caps have been placed. The restrictions that will be
recorded to meet these objectives include but may not be limited to the following:
Land in the areas designated for industrial park can not be used for residential use. Land
designated for the USDA can not be used for industrial or residential use.
Section 9.3 addresses related institutional controls involving notification, enforcement, access and non-
detrimental use. Section 9.2.1.2 addresses deed restrictions placed on groundwater use.
9.1.2 SRU1: Explosives in Soil -> Bioremediation
Described below are the remediation actions under the Bioremediation remedy and the estimated
treatment time and cost associated with this remedy. Some of the remedial actions were described in the
common action section above and are only listed below. The Bioremediation remedy includes:
• Building Demolition (Section 9.1.1.1)\
• Soil Excavation, Transportation, and Confirmatory Sampling (Section 9.1.1.2);
• Soil Preparation (Section 9.1.1.3);
• Bioremediation;
• Backfilling, Regrading, and Revegetating Excavated Areas (Section 9.1.1.4);
• Soil Disposal (Section 9.1.1.5);
• Treatment Area Decommissioning;
• Institutional Controls -Deed Restrictions on Land and Soils (Section 9.1.1.6).
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 9-4
-------
Remedial actions at Sites L16, M5, M6 and M7 for SRU1 are considered final. Remedial actions at Sites
LI, L7, L8, L9, L10, L14, M2 and M3 for SRU1 are considered interim.
During remedial design or remedial action, the Army will determine the extent of explosives
contamination associated with storm sewer lines at Sites L7 through L10. Contamination above the RGs
will be excavated and treated.
Some of the soils in SRU1 were contaminated by Resource Conservation and Recovery Act (RCRA)
listed hazardous wastes, and as such "contain" these wastes. The Army based its detailed analysis of
alternatives and selection of remedial technologies for these SRU1 soils on two determinations First
media, such as soils, at JOAAP that were contaminated with RCRA listed hazardous wastes are not
themselves hazardous wastes unless they exhibit the characteristic for which the waste was listed
Second, once media contaminated with RCRA listed hazardous wastes are treated to below Remediation
Goals (RGs), are not Toxic Characteristic Leaching Procedure (TCLP) hazardous wastes under RCRA
and do not exceed RCRA Land Disposal Restriction (LDR) concentrations, the media is no longer a
RCRA hazardous waste.
9.1.2.1 Bioremediation
Approximately 151,480 cubic yards of explosive-contaminated soil will be treated using a Bioremediation
treatment process. There are several bioremediation technologies that are capable of meeting and
substantially exceeding the RGs. A technology demonstration project is underway to select the most
appropriate technology for treating the JOAAP soil on the basis of cost, technical feasibility,
environmental acceptability, and utility of the final treated material. For the purpose of cost estimate,'
windrow composting was selected as the bioremediation treatment process. This process has been proven
on a full-scale operation. Composting is a treatment process where organic compounds are biologically
degraded or transformed by mesophilic and thermophilic microorganisms. The composting process
consists of mixing the waste material with an amendment or bulking agent to increase porosity, enhance
air mass transfer into the system, and enhance the microbial population that degrades the explosives.
Windrow composting will include three major steps: a) amendment materials preparation, b) windrow
construction, and c) windrow operation. The bioremediation alternative is expected to treat the soil and
reduce the explosive levels to below RGs. Based on the results of the kinetic evaluation performed for
the UMDA study m 1991, over 99.5 percent reduction of explosives concentration can be achieved by
using bioremediation.
One central treatment area is assumed to be constructed and soil from the different sites transported to
that area. This treatment area will include a contaminated soil stockpile area, preparation area, treatment
processes area, and a treated soil stockpile area. Run-off from rain and from the treatment itself will be
controlled to prevent any contamination due to the treatment operation. Treated soil will be backfilled in
excavated areas.
The USEPA and IEPA will approve the bioremediation technology selected. The plans developed by the
Army or its contractors to monitor and evaluate the bioremediation remedy will be subject to review and
approval by the USEPA and IEPA.
Post-treatment testing will be performed to ensure soil contaminant levels meet RGs.
9.1.2.2 Treatment Area Decommissioning
When the treatment of contaminated soil is completed, the treatment area and associated facilities will be
disassembled, decontaminated, and salvaged. Any parts of the treatment facility that can not be salvaged
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg, 9.5
-------
or are not desired by the future owner will be disposed in the future proposed WCLF or at an existing
permitted facility as construction debris. Any treatment residuals will also be sampled and reused or
properly disposed. K
9.1.2.3 Remedial Time and Cost
Once approval of the recommended alternative is received and funding obtained, the estimated time
required for completion of cleanup activities at SRU1, using the assumptions of the FS conceptual
designs, are:
• One ( 1 ) year for engineering design and treatment facility construction
• Three (3) years for excavation, treatment and disposal
Upon completion of the final remedial actions, no further cleanup action will be required for SRU1.
W°rth °f Capital and annual costs of the bioremediation remedy is estimated to be
' t0tal Capital COSt is $14'400.°00, and the total annual cost is $9,000 000. Based on the
RI/FS data, an estimated 15 1,480 cubic yards of soil will be treated.
9'J>3 _ SRU2: Metals in Soil -> Excavation and Disposal
Described below are the remedial actions under the Excavation and Disposal remedy and the treatment
time and cost associated with this remedy. Some of the remedial actions were described in the common
action section above and are only listed below. The Excavation and Disposal remedy will include:
• Soil Excavation, Transportation, and Confirmatory Sampling (Section 9. 1. 1.2);
• Soil Preparation (Section 9. 1. 1.3);
• Backfilling, Regrading, and Revegetating Excavated Areas (Section 9.1.1.4);
• Soil Disposal (Section 9. 1. 1.5); and
• Institutional Controls - Deed Restrictions on Land and Soils (Section 9.1.1.6).
Remedial actions at Site LI 1 for SRU2 are considered final. Remedial actions at Sites I 2 L3 L5 L23A
M3.M4 and Ml 2 for SRU2 are considered interim. '
Approximately 22,940 cubic yards of metal-contaminated soil will be excavated and disposed No raw
TNT is expected to be present in the soil. Soils potentially containing UXO will be located, and the UXO
removed and stockpiled for open bum/detonation or incineration at a permitted facility off-site
Otherwise, soil will not be screened; it will be excavated and disposed as specified in Section 9.1.1.5.
9.1.3.1 Remedial Time and Cost
The estimated completion time for remediating SRU2 is one (1) year including engineering design
excavation and disposal. Upon completion of the final remediation, no further cleanup actions will be
required for SRU2. The total estimated present worth of capital and annual costs of the Excavation and
Disposal remedy isS4,000,000.
9.1.4 SRU3: Explosives and Metals in Soil -* Bioremediation and Disposal, and Excavation
and Disposal
Described below are the remediation actions for the Bioremediation and Disposal, and Excavation and
Disposal remedies and the treatment time and cost associated with both remedies. Some of the remedial
actions were described in the common action section above and are only listed below The two remedies
will include:
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pgf 0.4
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• Soil Excavation, Transportation, and Confirmatory Sampling (Section 9.1.1.2);
• Soil Preparation (Section 9.1.1.3);
• Treatment Determination;
• BioremediationflSectfo/z 9.1.2.1);
• Backfilling, Regrading and Revegetating (Section 9.1.1.4);
• Soil Disposal (Section 9.1.1.5);
• Treatment Area Decommissioning (Section 9.1.2.3); and
• Institutional Controls - Deed Restrictions on Land and Soils (Section 9.1.1.6).
Remedial actions at Sites M5 and M6 for SRU3 are considered final. Remedial actions at Sites L2 and
L3 for SRU3 are considered interim.
Some of the soils in SRU3 were contaminated by RCRA listed hazardous wastes, and as such "contain"
these wastes. The Army based its detailed analysis of alternatives and selection of remedial technologies
for these SRU3 soils on two determinations. First, media at JOAAP were contaminated with RCRA
listed hazardous wastes, are not themselves hazardous wastes unless they exhibit the characteristic for
which the waste was listed. Second, once media contaminated with RCRA listed hazardous wastes are
treated to below RGs, are not TCLP hazardous wastes under RCRA, and do not exceed RCRA LDR
concentrations, the media is no longer a RCRA hazardous waste.
9.1.4.1 Treatment Determination.
Approximately 15,700 cubic yards of explosive- and metal-contaminated soil will be excavated from sites
M5 and M6 and approximately 17,420 cubic yards of explosive- and metals-contaminated soil will be
excavated from sites L2 and L3. The Army will determine whether or not these soils should be treated
prior to disposal, based on metal concentrations and explosive characteristics and concentrations in the
soil The following decision rules will be followed in this treatment determination for soils containing
both explosives and metals contamination:
I. The Army will treat all soils that are RCRA hazardous waste bnscd on explosives
contamination in the soil. (An example is soils with explosives concentrations (> 100,000
ppm) so high that they are reactive).
2. The Army may treat all other soils. Treatment will be attractive if it improves the disposal
options (such as allowing for disposal in a RCRA Subtitle D permitted landfill instead of a
RCRA Subtitle C permitted landfill).
Applicable final rule-making under RCRA may amend this section.
9.1.4.2 Remedial Time and Cost
The estimated time required for remediating SRU3 is:
• One (l)year for engineering design.
• One (1) year for the process time to be coordinated with designing time of SRU1.
• One (l)year to Bioremediate and Dispose approximately 15,700 cubic yards of soil.
• One (1) year for the Excavation and Disposal of approximately 17,420 cubic yards of soil not
requiring bioremediaton. (This step may run concurrently with either of prior two steps.)
JOAAP Record of Decision Soil & GroundwaterOUs - October, 1998 PR. 9-7
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The total present worth of capital and annual costs of the Bioremediation and Disposal remedy at sites M5
and M6 is estimated to be $4,000,000. The present worth of capital and annual costs of the Excavation
and Disposal remedy at sites L2 and L3 is estimated to be $2,800,000.
9.L5 SRU4: PCBs in Soil -> Excavation/Incineration and Disposal
Described below are the remediation actions under the Excavation/Incineration and Disposal remedy and
the treatment time and cost associated with this remedy. Some of the remedial actions were described in
the common action section above and are only listed below. The Excavation/Incineration and Disposal
remedy will include:
• Structure Demolition (Section 9.1.1.1);
• Soil Excavation, Transportation, and Confirmatory Sampling (Section 9.1.1.2);
• Backfilling, Regrading, and Revegetating Excavated Areas (Section 9.LL4};
• Soil Incineration or Disposal; and
• Institutional Controls -Deed Restrictions on Land and Soils (Section 9.1.1.6).
Remedial actions at all sites for SRU4 are considered final.
9.1.5.1 Soil Incineration or Disposal
Approximately 3,500 cubic yards of PCB-contaminated soil will be excavated and disposed. No raw
TNT or UXO is expected to be present in the soil. Depending on confirmatory sampling results, there are
three different disposal options:
• If PCB levels in soil are below 50 ppm, then the soil will be disposed at RCRA Subtitle D
permitted facility. The volume of soil with PCBs below 50 ppm concentrations is estimated to be
approximately 1,000 cubic yards.
• If PCB levels in the soil are between 50 ppm and 500 ppm, then the soil will be disposed at a
TSCA permitted landfill. The volume of soil with such PCB concentrations is estimated to be
650 cubic yards.
• If PCB levels are greater than 500 ppm, then the soil will be disposed off-sile in accordance with
TSCA (e.g., treated off-site at a TSCA permitted incinerator). The volume of soil with such PCB
concentrations is estimated to be 1,850 cubic yards.
9.1.5.2 Remedial Time and Cost
The estimated time required for remediating SRU4is one year. The total present worth of capital and
annual costs of the Excavation/Incineration and Disposal remedy is estimated to be $ 1,400,000.
9.1.6 SRU5: Oreanics in Soil -> Excavation and Disposal
Described below are the remediation actions under the Excavation and Disposal remedy and the treatment
time and cost associated with this remedy. Some of the remedial actions were described in the common
action section above and are only listed below. The Excavation and Disposal remedy will include:
• Structure Demolition (Section 9.1.1.1);
• Soil Excavation, Transportation, and Confirmatory Sampling (Section 9.1.l.2)\
• Backfilling, Regrading, and Revegetating Excavated Areas (Section 9.1.1.4)\
• Soil Disposal (Section 9.1.1.5); and
• Institutional Controls - Deed Restrictions on Land and Soils (Section 9.1.1. (>).
Remedial actions at Sites LI and L5 for SRU5 are considered interim.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 9.3
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9.1.6.1 Soil Disposal
Approximately 2,410 cubic yards of organics-contaminated soil consisting mostly of non-hazardous total
petroleum hydrocarbons will be excavated and hauled for disposal. O raw TNT or UXO is expected to be
present in the soil.
9.1.6.2 Remedial Time and Cost
The estimated time required for remediating SRU5 is one year.
The total present worth of capital and annual costs of the Excavation and Disposal of approximately 2,410
cubic yards of organic contaminated soil is estimated to be $300,000.
9.1.7 SRU6: Landfills -> Capping or Excavation and Disposal
Described below are the remediation actions for the Capping or Excavation and Disposal remedies and
the treatment time and costs associated with both remedies. Some of the remedial actions were described
in the common action section above and are only listed below. The two remedies will include:
• Soil Excavation, Transportation, and Confirmatory Sampling (Section 9.]. 1.2);
• Capping;
• Excavation and Disposal; and
• Institutional Controls.
Remedial actions at all sites for SRU6 are considered final.
Prior to implementation of this remedy, the Army will continue to maintain existing landfills Ml and M9.
9.1.7.1 Capping
The landfills in sites L3, Mil, and Ml3 will be capped. These landfill surfaces will be regraded and
smoothed before the construction of the caps. Regrading may require fill soil from an on-site borrow
location, the product of a treatment process (SRU1, SRU3), or suitable soils from the SRU2 disposal
activities.
RCRA Subtitle D caps will be constructed over M13 landfills because these landfills contain non-
hazardous wastes. RCRA Subtitle C caps will be constructed over the L3 and Ml 1 landfills because they
contain hazardous wastes.
9.1.7.2 Excavation and Disposal
The landfills in sites L4, Ml, and M9 will be excavated and disposed. Landfill materials will be
excavated using conventional earthmoving equipment. Excavated areas will be graded and vegetated to
be compatible with the intended land use. If necessary, excavated areas will be backfilled from an on-site
borrow location. Excavated material will be tested prior to final disposal.
Based upon testing, excavated material will be classified and segregated as hazardous, non-hazardous, or
recyclable. Based upon classification, lined trucks will transport the waste for ultimate disposal. If waste
is considered hazardous then it will be disposed at a RCRA Subtitle C landfill, disposed. The inert ash at
Ml and M9 is not a RCRA hazardous waste and may be disposed in a solid waste facility or otherwise
offered for reuse. The Army is pursuing the option for reuse of the inert ash from sites M1 and M9.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 9-9
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9.1.7.3 Institutional Controls
For the capped landfills, maintenance/repair and monitoring program will be required after capping and
closing the landfills. A maintenance/repair program will be established to maintain the caps and prolong
their life span. The monitoring program will be established to test and monitor if any contaminants are
migrating from the landfills into the groundwater beneath and around the landfills. This program will be
implemented m accordance with the IEPA requirements for closed landfills. The monitoring and
maintenance programs will be reviewed and approved by the USEPA and IEPA.
Legal restrictions on uncontrolled excavation and land use to minimize human contact with landfill
materials will be specified in the deed for the landfills that will be capped on-site (L3, M11, and M13) In
addition, site M9, which will be excavated and disposed, and site Ml, will also have some legal and
excavation restrictions because it falls within the boundaries of a GMZ. Excavation that may cause
plume migration or any other groundwater disturbance, especially well installation, will be restricted at
these sites. These restrictions will be in the deed or leasing agreements.
9.1.7.4 Remedial Time and Cost
The estimated time required for remediating of the landfill in SRU6are:
• Three to four years for capping landfills in sites L3. Mil, and M13 based on construction
materials available from other cleanup actions at JOAAP.
• One year for Excavation and Disposal of landfills in sites L4, M1, and M9.
Upon completion of the excavation and disposal of the landfills in sites L4, Ml and M9 no further
A "Si?*011 ,WI" be rCqUired f°r thCSe SitCS- Up°n comPletion of Capping the landfills in sites L3, Ml 1
ana MU, a long-term monitoring program will be implemented in accordance with the IEPA
requirements for closed landfills. '
The total present worth of capital and annual costs of the Capping L3, Ml 1, and M13 landfills based on
D?Jo TfV8 A ^? '0°,°i;,o?e PreSem W°rth °f C3pital and annual costs of thc Excavation and
Disposal of the L4, Ml, and M9 based on FS volumes is $12,100,000.
9.1.8 SRU7: Sulfur -> Removal and Recycle or Disposal
Described below are the remediation actions under the Removal and Recycle or Disposal remedy and the
treatment time and cost associated with this remedy. Some of the remedial actions were described in the
°f SUlfUf 'S "Ot reSuIated under
The Excavation and Disposal remedy will include:
• Soil Excavation, Transportation, and Confirmatory Sampling (Section 9. 1. 1.2);
• Backfilling, Regrading, and Revegetating Excavated Areas (Section 9.1.1.4);
• Sulfur Recycle or Disposal; and
• Institutional Controls.
Remedial actions at all sites for SRU7 are considered final.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 „„ g_1
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9.1.8.1 Sulfur Recycle or Disposal
Approximately 7,500 cubic yards of raw sulfur will be excavated and hauled for recycling or disposal.
The raw sulfur found on the surface and upper layers of soil in study areas M8 and M 12 will be scraped
and separated from the soils at the site. The sulfur may have some commercial salvage value.. The U.S.
Armyis investigating the possibility of reuse of sulfur. However, if it is found that this sulfur has no
commercial value, it will be disposed at the future proposed WCLF or at an existing permitted facility as
a non-hazardous waste.
9.1.8.2 Institutional Controls
Legal restrictions on uncontrolled excavation and land use to minimize human contact with contaminated
soil/sediment will be specified in the deed for sites M8 and M12 because these sites fall within a GMZ.
Although" the GMZ will be established mainly for explosives and not for sulfur, institutional controls will
still apply to these two sites. Excavation that may cause plume migration or any other groundwater
disturbance, especially well installation, will be restricted at these sites. These restrictions will be in the
deed or leasing agreements.
9.1.8.3 Remedial Time and Cost
The estimated time required for raw sulfur removal and disposal associated with SRU7 is less than one
year..
The total present worth of capital costs of the Excavation and Disposal of 7,500 cubic yards of sulfur is
$200,000.
9.2 Groundwater Operable Unit
Remedial actions at all sites for the Groundwater Operable Unit are considered final.
Common Groundwater OU Actions
The limited action remedy for groundwater combines source removal of overlying contaminated soils;
institutional controls to prevent exposure to potentially contaminated groundwater; and monitored natural
attenuation to lower contaminant levels in groundwater to below the RGs. Institutional controls are
required because levels of some contaminants in groundwater exceed safe levels for human consumption,
and may exceed those levels for several decades. One of the primary institutional control mechanisms is
the establishment of Groundwater Management Zones surrounding each of the GRUs in accordance with
Illinois Code 35 IAC 620.250. Another primary component of the institutional controls is the imposition
of site-specific deed and zoning restrictions. This selected remedy also includes contingency plans should
the remedy prove ineffective. Following is a description of the common actions that are included in the
selected remedy.
9.2.1.1 Groundwater Management Zone (GMZ)
GMZs are three-dimensional regions containing groundwater being managed to mitigate impairment in
accordance with Illinois Code 35 IAC 620.250. The GMZs will comprise both the glacial drift and
shallow bedrock aquifers. The GMZs will be surveyed as depicted in Figure 4. Any future modification
of the GMZ boundaries will be by mutual agreement between the Army, USEPA and I EPA.
Groundwater monitoring wells located inside and/or at the borders of each GMZs will monitor the
contaminated plumes. If groundwater migrating outside the GMZs is contaminated in excess of the RGs,
then appropriate contingency actions will be taken.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 9-11
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Deed restrictions, as described in Section 9.2.1.2. address limitations on actions and on the use of
groundwater within of the GMZs.
GMZs, shown in Figure 4, were established around areas where either Illinois' Class I or Class II water
quality standards are not met. The majority of GMZs at JOAAP surround areas that do not meet the less
stringent Class II standards. Only one GMZ - that surrounding Site M3, where benzene was detected in
monitoring well MW233 in 1991 - has been established for an area that meets Class II standards but does
not meet Class I standards.
9.2.1.2 Institutional Controls - Deed Restrictions on Groundwater Use
Deed restrictions have been developed or are being developed separately from this Record of Decision by
the Army USEPA, IEPA and the future land users - the Joliet Arsenal Development Authority (JADA)
and the US Department of Agriculture (USDA). These deed restrictions cover limited areas of the lands
to be used for industrial parks and for the Midewin Tallgrass Prairie.
These deed restrictions will run with the land until removed by mutual agreement of the Army, USEPA
JSv, xf"^ °Urrent landowner- Th6 deed restrictions will be recorded with the Will County Recorder
(302 N. Chicago Street, Joliet, IL 60432). Section 120(h)(3) of CERCLA defines precise requirements
for the contents of deeds for property to be transferred from the Federal government, in which, hazardous
or toxic substances were stored for greater than a year, or were released into the environment
Specifically, it states that: "in the case of any real property owned by the United States on which any
hazardous substance was stored for one year or more, known to have been released, or disposed each
deed entered into for the transfer of such property by the United States to any other person or entity" shall
contain—
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9.2.1.3 Site Inspections
The Army will perform periodic inspections at the same time as the sampling effort to examine the
condition of wells and to verify compliance with deed restrictions.
9.2.1.4 Groan dwater Monitoring
Natural Attenuation Models will be developed for the three GRUs during the remedial design phase of the
project to refine predictions on the rate of contaminant reduction and the ultimate time required for
contaminant levels in groundwater to be lowered to below the RGs. An integral component of the Natural
Attenuation Models will be an extensive groundwater monitoring program. It is anticipated that two to
three comprehensive rounds of groundwater sampling and analyses will be required to establish and
calibrate the model at each GRU, and that routine periodic sampling and chemical analysis of
groundwater will be required while contaminant levels in groundwater exceed the RGs. The exact
number of wells to be sampled, the frequency, duration and list of analytical parameters will be
established during the remedial design. All details of the sampling, chemical and statistical analyses
employed in the groundwater monitoring program will be mutually agreed upon by the Army, the USEPA
and the IEPA. At a minimum, all results will be reviewed and evaluated every five years by the Army,
USEPA and IEPA to assure satisfactory progress of the selected Limited Action remedy toward
achievement of the RGs.
The groundwater monitoring program will be developed by the Army during the Remedial Design phase.
It will be reviewed and approved by USEPA and IEPA prior to implementation.
Monitoring wells will be located to assure no groundwater exits the GMZ at concentrations above the
RGs. Although precise details remain to be defined in design of the natural attenuation model and
remedy, the monitoring will include an array of wells situated in three distinct general types of areas. The
first area will be within the plume or area of contamination. These wells will be used to assess and
monitor the rate of reduction of contaminants within each plume, and serve as the primary basis for
evaluating the effectiveness of the limited action remedy. Surface water will be monitored to track
exfiltration at locations where there is a critical groundwater to surface water interface. Surface water
downstream of these locations will be monitored to assure compliance with the .surface water quality
criteria as shown in Table 10.1.
The second area of well placements will be at locations downgradient of a plume and between the plume
and the GMZ boundary. The purpose of these wells will be to provide early warning to prevent
groundwater with concentrations of contaminants above the RGs from reaching the compliance point.
These wells will also add information regarding the mechanisms driving the natural attenuation process
and will help serve as a basis for determining the effectiveness of the natural attenuation.
The third area of well placements will be around the perimeter of the GMZ. The wells will serve as
compliance points and will be preferentially located down gradient of the plume. The purpose of these
wells is to assure compliance with the conditional requirements of a groundwater management zone.
Groundwater monitoring will continue until contaminant concentrations in groundwater are reduced to
meet the RGs. The monitoring plan will utilize existing groundwater monitoring wells to the maximum
extent practicable, and new monitoring wells will be located as needed to calibrate and operate the natural
attenuation model. Changes proposed for the monitoring program will require concurrence from both the
USEPA and the IEPA.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg.9-23
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9.2.1.5 Natural Attenuation
The concept of natural attenuation is the basis for adopting a passive remediation approach to impacted
sites. It has emerged as a feasible remediation strategy due to the recognition that intrinsic biological,
physical/chemical processes such as biological degradation, sorption, dispersion, and dilution, are
constantly in operation. Under specific conditions, contaminants left in place in soil or groundwater
undergo natural attenuation that reduces the contaminant concentrations to acceptable levels. Benzene
.and toluene are known to be readily biodegradable by indigenous microorganisms. There are numerous
successful studies on remediating petroleum-contaminated sites (where these two compounds are the
predominant components of the impacted media) using in-situ biodegradation technology. Field
application of biodegradation of explosives has been shown to be possible based on several laboratory
studies.
Published literature indicates that explosives can be effectively biodegraded anacrobically. Under
anaerobic conditions, explosives such as TNT, are shown to be initially reduced to
monoaminonitrotoluenes and subsequently to diaminonitrotoluenes. These diaminonitrotoluenes are
further biologically transformed to organic acid end products, or become irreversibly bound to clays or
humic materials in soils.
9.2.1.6 Contingency Plan
GMZs are established in accordance with 35 IL Adm. Code 620 under the requirement that corrective
actions are implemented to clean up the groundwater. The Army is initially implementing the required
corrective actions in two ways at JOAAP. First, the Army will undertake source removal with the
planned remediation of contaminated soils that have contributed to the plumes. Second, the Army will
utilize the limited action remedy of monitored natural attenuation to degrade the contaminant levels in the
plumes to RG levels or below
Within fifteen (15) months of signature of the ROD, the Army shall develop a scientific and defensible
groundwater model of contaminant reduction assuming implementation of the limited action remedy. The
model will predict contaminant reduction for the available contingency options.
Due to predicted length of time, (20-340 years) for the limited action remedies to lower groundwater
contaminant levels to below the RGs in the three GRUs, a plan is needed to assure the selected remedy
will ultimately mitigate risk to human health or the environment. Significant effort will be made during
the remedial design to develop a natural attenuation model to refine the prediction of the rate of
degradation and more precisely determine the ultimate duration of the limited action remedy for
groundwater. No later than five (5) years after completion of source removal, the Army shall deliver to
USEPA and IEPA a report summarizing the efforts it has made to refine its prediction of the rate of
degradation and more precisely determine the ultimate duration of the limited action remedy for
groundwater. That report will present the specific information, data, and analysis needed to describe the
effectiveness of monitored natural attenuation in reducing contaminant concentrations. The information
provided in the report will include a description of the status of the deed restrictions, GMZs, monitoring
program implementation, and groundwater modeling. It will also provide the analytical parameters and
trends observed in the contamination found in each GMZ in accordance with the framework specified in
the groundwater monitoring plan. The Army shall submit a similar report to the USEPA and IEPA every
five (5) years after the submission of the first report. All reports shall include a description of the
effectiveness of monitored natural attenuation in reducing contaminant concentrations in the GRUs since
the submission of the previous report and since the date of execution of the ROD.
This initial report will also include a scientific and defensible review of the impact which available
contingency options would have on the limited action remedy time frames. If the Army, USEPA and
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 9-14
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IEPA determine that the limited action remedy time frames are unacceptable, alternative remedial actions
will be developed and implemented in accordance with the NCP. The USEPA and IEPA reserve the right
to require the Army to review available contingency options at any time during the remediation process.
Until RGs are met, the Army will evaluate phytoremediation and other emerging technologies that are
applicable to the degradation of explosives in groundwater as a potential means of accelerating or
enhancing the natural attenuation remedy.
9.2.2 GRU1: Explosives in Groundwater -LAP Area -> Limited Action
Described below are the remediation actions under the Limited Action remedy selected for this GRU.
Most of the remedial actions were described in general terms in Section 9.2.1. Following is a detailed
description of the remedy specific to GRU 1. The Limited Action includes:
• Establishment of GMZs;
• Source Removal (see relevant SRU sections);
• Institutional Controls - Deed Restrictions on Groundwater Use (Section 9.2.1.2);
• Site Inspections (Section 9.2.1.3);
• Groundwater and Surface Monitoring ;
• Natural Attenuation; and
• Contingency Plan Implementation, if necessary (Section 9.2.1.6).
9.2.2.1 Establishment of GMZs
GMZs will be established under this alternative at each of the four sites included in GRU1. The area of
the different GMZs is illustrated in Figure 4. The horizontal extent of the GMZs is shown on Figure 4.
The vertical extent of the GMZs is between 100 and 200 feet - from the ground surface to the bottom of
the Silurian Dolomite Aquifer (also known as the Shallow Bedrock Aquifer). Although groundwater
contamination has only been identified in the glacial till at Site L14, because the glacial till is
hydraulically connected with the Silurian Dolomite, the GMZ at this site also extends to the base of the
dolomite.
9.2.2.2 Groundwater Monitoring
A groundwater monitoring program will be established for GRU1 plumes. This program is intended to
provide the details necessary to more accurately predict the rate of natural attenuation, and to evaluate the
success of this alternative. All groundwater samples are assumed to be collected semi-annually from
existing wells and proposed wells. All samples will be analyzed for explosives. Surface water samples
will be collected in accordance with the NPDES permit, and to comply with the Illinois Water Quality
Standards as listed in Table 10-1 of this ROD. No sediment sampling is proposed because the RI
determined that sediments in Prairie Creek were not contaminated.
The first round of groundwater and surface water sampling and analysis will include the additional
parameters: dissolved oxygen, redox potential, pH and alkalinity, electron receptors (dissolved nitrate,
iron, sulfate, and carbon dioxide), inorganic nutrients (ammonium, total phosphate, sulfate, and nitrate),
temperature and total organic carbon. These data will be used to evaluate whether biological mechanisms
are a significant factor in the degradation of explosives.
Data collected during the long-term monitoring period will be compiled, reviewed, and reevaluated every
5 years in accordance with 35 IAC 620.250. When it is determined by the Army and approved by
USEPA and IEPA that the contaminant concentrations have reached the RGs, or it is determined that the
remaining contaminant concentrations do not pose a risk to human health or the environment, the
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 9-15
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monitoring program can be concluded. At that time, the Army will document to 1 1- PA and USEPA the
completion of the remedial action in accordance with 35 IAC 620.250(c), and the GMZ will expire.
Monitoring is assumed to continue for at least 30 years at Sites LI, L3, and L14; and lor 20 years at Site
L2. Die length of time for monitoring is calculated based on assumptions of affected area and estimated
groundwater velocities. Groundwater data and modeling will be used to more accurately predict duration
of the monitoring program. The actual frequency, duration, and analytical parameters may change with
h < - n«- a' ™
program should be evaluated every 5 years to ensure that it meets the data needs and program objectives.
9.2.2.3 Natural Attenuation
Natural attenuation at the GRU1 sites will involve the use of natural attenuation processes to reduce
explosives concentration to the RGs. These processes include a wide variety of physical, chemical or
S?1^ r"55? ^ aCt ^thOUt hUman intervention and may ™lude dispersion, dilution, adsorption,
biodegradation, and chemical or biological stabilization or destruction. The actual processes that occur a
each site will vary based on the physical, chemical, and biological characteristics of the soil, groundwater
ana suriace site conditions. '
At Sites LI and L2, there is some evidence to suggest that biodegradation of explosives may be occurring
TreemS f ™tl0n '" the, Wetlands area where g™ndwater is discharged to Prairie Creek, and vif
Treemediation as groundwater passes through the root zone of wooded areas. These processes have
rf^l f^T ^,eXP VES (Phytoremediation) and other contaminants (Treemediation ™), and a
USEPA S At^ °t T%CXa? rT, u"^"15 °f ""^ * Site L1 i§ bdng condu<*ed by the U.S. Army and
*hJr ^1 ? ^ ! ' blol°8ical Processes are expected to be less significant because of the
absence of trees and wetlands. Physical and chemical attenuation processes are likely providing the
predominant attenuation mechanisms at these sites. Source removal will decreas-e the potential for
groundwater quality degradation, and will enhance the natural attenuation process. Should the site studies
at Slte L1 show promise' this technology ™* be i
9.2.2.4 Remedial Time and Cost
The estimated time required for completion of the Limited Action remedy for GRU 1 assumption that the
SoTearstr Sit T, 'Jo"""* *? ^ RGs' ^ ^^^ remediation times are 20 years for Site L2,
!h Jv nf i ^ ' ^ f°r Slt£ LH' 3nd 34° years for Site LL Recent data «athered as part of a
study of natural attenuation of explosives being conducted at Site LI indicates that these estimates may be
overly conservative and that the actual time required may be two to four order of magnitude less The
time frame estimates will be adjusted as part of the monitoring program and modeling effort..' The
estimated net present worth cost of the Limited Action remedy for GRU1 is $530,000.
^M — GRU2: Explosives and Other Cnntaminanta in Groundwater -MFC Area -> Limited
Action ~ ~ ~ ~ — -
Described below are the remediation actions under the Limited Action remedy selected for this GRU
Most of the remedial actions were described in general terms in Section 9.2.1. Following is a detailed
description of the remedy specific to GRU2. The Limited Action includes:
• Establishment of GMZs;
• Source Removal (see relevant SRU sections);
• Institutional Controls - Deed Restrictions on Groundwater Use (Section 9.2. 1 ->) •
• Site Inspections (Section 9.2. 1.3) ;
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 „„ 9_16
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• Groundwater Monitoring ;
• Natural Attenuation (Section 9.2.1.5); and
• Contingency Plan Implementation, if necessary (Section 9.2.1.6).
9.2.3.1 Establishment of GMZs
Two GMZs will be established in GRU2. One is associated with the explosives and metals plume under
site Ml (Southern Ash Pile), and the other with explosives plumes in the northern part of the
manufacturing area. The horizontal extent of these GMZs is shown on Figure 4. The GMZ extends to the
bottom of the Silurian Dolomite Aquifer (also known as the Shallow Bedrock Aquifer), a vertical distance
of from 100 to 200 feet below ground surface
9.2.3.2 Groundwater Monitoring
The objective of the groundwater monitoring program is to determine the rate of natural attenuation and..
to evaluate the effectiveness of the remedy. During the groundwater monitoring program, groundwater
quality data will be collected that will confirm the absence of off-site migration or vertical groundwater
migration into deeper formations. The groundwater data will also be used to evaluate temporal changes
in constituent concentrations.
The GMZ encompassing sites M5, M6, M7, M8, and M13 is approximately 575 acres and extends
vertically from the ground surface to the bottom of the Silurian Dolomite. The Army will develop, with
USEPA and IEPA approval, the long-term groundwater monitoring program during the remedial design
phase that will document at a minimum: number of wells, location of wells, and the chemicals of concern
to be monitored. These wells will be sampled and analyzed for explosives, metals and VOCs semi-"
annually throughout the duration of the groundwater monitoring program. In addition, a well pair, one
overburden and one shallow bedrock, will be installed downgradient of Explosive and PCE Plume (see
Figure 4). During the Remedial Design, it may be necessary to install additional wells to complete the
groundwater monitoring program. These new wells will be sampled and analyzed for explosives, metals
and VOCs at the same frequency. These wells will be used to monitor natural attenuation. Groundwater ;
elevations will also be measured during each sampling event to determined hydraulic gradient.
The GMZ in Ml is approximately 61 acres and extends vertically from the ground surface to the bottom
of the Silurian Dolomite. The Army will develop, with USEPA and IEPA approval, a groundwater
monitoring program during the remedial design phase that will document at a minimum: number of wells,
location of wells, and the chemicals of concern to be monitored. These wells will be sampled and
analyzed for explosives and metals semi-annually for the first 5 years and annually for the remainder of
the monitoring program. MW107 and MW231 will be sampled and analyzed for metals at the same
frequency. In addition, a well pair, one overburden and one shallow bedrock, will be installed
downgradient of the Ml Plume (see Figure 4). These new wells will be sampled and analyzed for
explosives and metals at the same frequency. Data collected from these wells will be used to monitor and
evaluate natural attenuation. Groundwater elevations will also be measured during each sampling event
for plume migration information.
Data collected during the monitoring period will be compiled and reviewed every 5 years. When it is
determined by the Army and approved by USEPA and IEPA that the contaminant concentrations have
reached the RGs, or that the remaining constituent concentrations will not pose any adverse effect on
human health and the environment, the monitoring will be concluded. A remedial action closure report
documenting attainment of RGs will be submitted to the USEPA and IEPA for review and approval. This
document will describe baseline contaminant levels, target remediation goals, trends in contaminant
concentration, and the achievement of the remediation goals. Once the RGs have been reached, the Army
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg.9-17
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will document to IEPA and USEPA the completion of the remedial action in accordance with 35 IAC
620.250(c), and the Limited Action remedy will expire.
9.2.3.3 Remedial Time and Cost
The estimated time for completion of the Limited Action remedy for GRU2 is 50 years Recent data
gathered as part of a natural attenuation study at Site LI indicate that the time required to achieve RGs
may be less than estimated. Monitoring data and modeling efforts conducted as part of this alternative
will be used to refine the treatment time estimate. The estimated net present worth cost of the Limited
Action remedy is $3,300,000.
GRU3: Volatile Organic Compounds (VOCs) in Groundwater -MFC Area -> Limited
Action
Described below are the remediation actions under the Limited Action remedy selected for this GRU
Most of the remedial actions were described in general terms in Section 9.2.1. Following is a detailed
description of the remedy specific to GRU3. The Limited Action will include:
• Establishment of GMZs;
• Source Removal (see relevant SRU sections);
• Institutional Controls - Deed Restrictions on Groundwater Use (Section 9.2. 1 2) •
• Site Inspections (Section 9.2. 1. 3);
• Groundwater Monitoring ;
• Natural Attenuation (Section 9.2.1.5); and
• Contingency Plan Implementation, if necessary (Section 9.2. 1. 6).
9.2.4.1 Establishment of GMZs
With USEPA and IEPA approval, the Army will establish two GMZs: one in the Western Toluene Tank
Farm and the other m the Central Toluene Farm. The area of the GMZs in M10 is approximately 5 acres
each and is a part of the GMZ that will be established for GRU3 (Figure 4). The horizontal extent of the
GMZs is shown on Figure 4. The vertical extent of the GMZs is 100 to 200 feet below ground surface to
the bottom of the Silurian Dolomite Aquifer (also known as the Shallow Bedrock Aquifer).
A special case GMZ, designated as GMZ I because of exceedance of Class I water quality standards has
been established around Site M3 (Figure 4). This will remain until the Army, USEPA and IEPA have
evidence that the benzene contamination detected in MW33 has degraded below the Class I standard (5
v
9.2.4.2 Groundwater Monitoring
The long-term groundwater monitoring program will be established during the remedial design phase and
will document at a minimum: number of wells, location of wells, and the chemicals of concern to be
monitored. These wells will be analyzed semi-annually for BTEX throughout the duration of the
groundwater monitoring program. In addition, a well pair, one overburden and one shallow bedrock, will
be installed m the Central Toluene Tank Farm to monitor the migration of contaminated groundwater
This well pair will also be monitored for BTEX concentrations at the same frequency. These wells will
monitor plume migration. During Remedial Design, it may be necessary to install additional wells to
complete the monitoring program. Existing wells at M3 will be sampled for VOCs.
Data collected during the monitoring period will be compiled and reviewed every 5 years from estimated
?ToXar Pen°d Until the RGS 3re reached' When il is determined by the Army and approved by the
USEPA and IEPA that the contaminant concentration have reached the RGs, or that the remaining
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 ppf o.jg
-------
constituent concentrations will not pose any adverse effect on human health and the environment, the
monitoring will be concluded. The Army will document the completion of the remedial action in
accordance with 35 IAC 620.250(c), and the GMZ will expire.
9.2.4.3 Remedial Time and Cost
The estimated time for completion of the Limited Action remedy for GRU3 is50 years. Recent data
gathered as part of a natural attenuation study of explosives contaminated groundwater at Site LI indicate
that the time required to achieve RGs may be less than estimated. Monitoring data and modeling efforts
conducted as part of this alternative will be used to refine the treatment time estimate. The estimated net
present worth cost of the Limited Action remedy is $700,000.
9.3 Institutional Controls
Institutional controls are intended to protect human health and the environment. They include the
controls described below as well as deed restrictions, as described in Sections 9.1.1.6 and 9.2.1.2.
&3J—Notifications to Recorder's Office
The Army will file with the Recorder's Office or Registry Office or other appropriate office, within 90
days of approval of the ROD, a USEPA approved notice to all successors in title that:
(i) the property is part of the JOAAP Site,
(ii) the Army, USEPA and IEPA selected remedies for the JOAAP Site in October 1998,as
specified within this Record of Decision,
(iii) the Army entered into a Federal Facility Agreement (FFA) with the USEPA Region V
and the State of Illinois on June 9, 1989 requiring implementation of the remedy by the
Army. This FFA is under CERCLA Section 120, in the matter of: "The U.S. Department
of Defense, The Army, Joliet Army Ammunition Plant, Elwood, Illinois."
(iv) Copies of the FFA and ROD are located at the Joliet and Wilmington Public libraries and
also at the USEPA Region 5 Headquarters.
The Army will provide to USEPA a copy of this notice within 30 days of its filing.
2*2*2.—Notifications to Land Owners of Access Easements and Restrictive Easements
At least 30 days prior to any transfer of real estate located within JOAAP site, the Grantor shall provide
the Grantee with a copy of the FFA and the ROD. Any deed, lease, license, permit, or casement from the
Army shall contain language that the Grantee received copies of the FFA and the ROD at least 30 days
prior to the conveyance of the respective interest in the property located within the JOAAP site. At least
30 days prior to such conveyance or transfer, the Army shall give written notice to USEPA and the IEPA
of the proposed conveyance or transfer including the name and address of the Grantee. The deeds shall
be properly recorded in the recorder's office and copies submitted to USEPA as discussed in Section
9.3.1.
9,&3 Notifications to mil County of Restricted Use of Water
The Army will notify the Will County Health Department, Environmental Division (501 Ella Avenue
Joliet, IL 60433) that: '
• the groundwater contained in the glacial till and shallow bedrock does not meet Class II
(industrial) water quality standards for all GMZs except that at Site M3
• the groundwater contained in the glacial till and shallow bedrock below Site M3 does not
meet Class I (potable) water quality standards
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 9-19
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• the water supply wells placed anywhere within the JOAAP should be tested at least for the
contaminants of concern at JOAAP before use for whatever purpose.
9,3,4 Review Authority of the USKPA and TKPA
USEPA and 1EPA retain the right to review and approve the environmental deed restriction language in
the Army's transfer of JOAAP land.
•*,
2*3*3. — Continuing Respnnsihjlities of (fa Aw*y
In the event of any conveyance, the Army's obligations under this ROD and the FFA, including but not
limited to, its obligation to provide or secure access, pursuant to Section XXI of the FFA, or institutional
controls, as well as to abide by such institutional controls, shall continue to be met by the Army In no
event shall the conveyance of a property interest release or otherwise affect the liability of the Army to
comply with all provisions of the FFA or the ROD, absent the prior written consent of USEPA, Region 5.
9,3, 6 Non-Detrimental Use of the Property hy the Army
Commencing on the date the ROD is signed, the Army shall refrain from using the JOAAP site, or such
other property in any manner that would interfere with or adversely affect the integrity or protectiveness
of the remedial measures to be implemented pursuant to this ROD. The restrictions on the use of the
KnSaiTS * Td ^ SeCti°nS 9'U-6 3nd 9'2-1'2 and as SPecified in the deed restrictions negotiated
separately from this document.
9.3.7
mFp ?5 'SI"*31!- easfment' """^ witl1 the land> that grants a right of access for the Army, the
UbEPA and the J.EPA for the purpose of conducting any activity related to this ROD and the FFA
including, but not limited to the following activities:
a) Monitoring the work;
b) Verifying any data or information submitted to the United States or the State;
c) Conducting investigations relating to contamination at or near the Site;
d) Obtaining samples;
e) Assessing the need for, planning, or implementing additional response actions at or near
the Site;
f) Implementing the work pursuant to the conditions set forth in the FFA and the ROD-
g) Inspecting and copying records, operating logs, contracts, or other documents maintained
or generated by the Army or their agents, consistent with the FFA's section on Access-
n) Assessmg the Army's compliance with the FFA and the ROD; and
i) Determining whether the Site or other property subject to this ROD is being used in a
manner that is prohibited or restricted or that may need to be prohibited or restricted bv
or pursuant to, the FFA or the ROD. '
The Army shall retain this easement and this "retained" easement shall be clearly identified in all
documents pertaining to the property that is part of the JOAAP sites (this includes property designated for
no further action), including the Findings of Suitability of Transfer (FOSTs), contracts of sale or for the
translerence of the property, and deeds used to transfer the property.
9,3,8 Enforcement of Restrictions
The Army shall retain the right to enforce the land/water use restrictions (Deed Restrictions) or other
restrictions that are placed on the JOAAP sites. This right shall be stated in all documents/including
deeds used to transfer any of the property that is the part of the JOAAP sites (this includes propert?
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg 9.20
-------
designated for no further action), FOSTs, contracts of sale or for the transference of the property, and
leases concerning the property.
The deeds used to transfer any of the property from the JOAAP sites (including property designated for
no further action, as appropriate) shall provide for the enforcement by the United States of the land/water
use restrictions listed in the ROD and/or the FOSTs, or other restrictions the USEPA, IEPA and Army
determine are necessary to implement, ensure noninterference with, or ensure protectiveness of the
remedial measures to be performed pursuant to the ROD and FFA.
The Army shall be entitled to enforce the terms of the Deed Restrictions or other restrictions by resort to
specific performance or legal process against all Grantees of the property that is part of the JOAAP sites
(including the property designated for no further action) and their successors and assigns. AH reasonable
costs and expenses of the Army, including, but not limited to attorney's, fees, incurred in any such
enforcement action shall be borne by the Grantee or its successor in interest to the property.
[END OF SECTION]
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 9-21
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10 STATUTORY DETERMINATIONS
Executive Order 12580 (January 23, 1987) delegates the authority for carrying out the requirements of
CERCLA Sections 104(a), (b), and (c)(4) (42 U.S.C. 9604 (a), (b), (c)(4) and 121 (42 U.S.G. 9621) to the
Department of Defense, to be exercised consistent with Section 120 (42 U.S.C. 9620) of the Act.
Therefore, under its legal authorities, the Army's primary responsibility is to undertake remedial actions
that achieve adequate protection of human health and the environment.
In addition, Section 121 of CERCLA establishes several other statutory requirements and preferences.
These requirements specify that when complete, the final remedial actions must comply with applicable
or relevant and appropriate environmental standards established under Federal and State environmental
laws unless a statutory waiver is justified. The final remedies also must be cost effective and utilize
permanent solutions and alternative treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a preference for remedies that employ
treatment that permanently and significantly reduce the toxicity, mobility, or volume of hazardous
substances as their principal element. The following sections discuss how the selected remedies are
consistent with these statutory requirements.
10.1 Protection to Human Health and the Environment
10.1.1 SoilOU
All the selected remedies, with the exception of capping, will remove or treat the contaminated soil from
the sites and subareas. The removed soil will either be treated or disposed of in permitted facilities. The
presumptive remedy was selected for three of the landfills in SRU6; these landfills will be capped. The
final remedies selected for the soil OU will be protective to current and future users of these sites, and
both final and interim remedies will prevent or minimize direct exposure of groundwater to the
contaminated soil and minimize the leaching of contaminants from soil to groundwater. The selected
final remedies will reduce the carcinogenic risks to fall within the USEPA's acceptable risk range of 10"4
to 10"6; in addition, the Hazard Index for non-carcinogens will be reduced to less than one. There are no
short-term threats associated with the selected remedies that can not be easily controlled, and there are no
adverse cross-media impacts. The cross-media impacts are actually positive in nature because by treating
the soil, in most cases the source of groundwater contamination is removed.
70.7.2 Groundwater OU
The selected remedy for the three GRUs is Limited Action. This remedy by itself will not include active
remedial actions; however, combined with contaminated soil removal and treatment, the Limited Action
remedy will reduce and control potential risk to human health and the environment. After coupling the
Limited Action remedy with soil removal, treatment, or disposal and natural attenuation, it is expected
that groundwater contamination will decrease to levels below the risk-based RGs. This remedy will
reduce the carcinogenic risks to fall within the USEPA's acceptable risk range of 10"4 to 10"6. In addition,
the Hazard Index for non-carcinogens will be reduced to less than one. No unacceptable short-term risk
or cross-media adverse impacts will be caused by implementation of the selected remedy.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 10-1
-------
10.2 Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs) and To-Be-Considered rTRr> Guidance
10,2,1 Soils Operable Unit mm
The selected remedies will comply with all Federal and any more stringent State ARARs. The major
ARARs that will be attained by the components of the selected remedies are list below. The list of
ARARs below is intended to be comprehensive; additional ARARs may be identified during remedial
design and remedial action with USEPA and IEPA approval.
10.2.1.1 Chemical-specific ARARs and TBC Guidance for Soils and Sediment
ARARs and TBCs necessary for protection must be attained for hazardous substances, pollutants or
contaminants remaining on-site at the completion of the final remedial actions. There are no federal laws
providing maximum allowable residual levels for the chemicals of concern in shallow soils. Likewise for
sites listed on the National Priority List, such as JOAAP [40 C.F.R. Part 300 (1997)], the State of Illinois
has no promulgated enforceable standards for chemicals of concern in soil. Therefore, the following
approaches were used to derive remediation goals for the final COCs (as in Table 6-2):
• Explosives, Metals, PAHs. a-Chlordane, Phosphate
Industrial scenario - USEPA Region 3 Risk-Based Concentrations (RBCs). TBC guidance for
remediation of soil and sediment at JOAAP.
• PCBs
Cleanup standards established under USEPA's PCS Spill Cleanup Policy [40 C.F.R. 761.120(1997)
for nonrestricted access areas is 10 mg/kg; for all surface soil is 1 mg/kg (upper 10 inches of soil) -
TBC guidance values agreed upon for the PCBs in the soil at SRU4 by the IEPA and USEPA Region
• Lead
Remediation goal for industrial scenario is 1,000 mg/kg - TBC guidance value agreed upon by the
IEPA and USEPA Region 5, taking into consideration frequency of exposure and USEPA's historic
approaches.
• Illinois Surface Water Quality Standards
Table 10.1 shows surface water and soil standards that will be applied to within the Soils OU for the
chemicals of concern at JOAAP. The Illinois Water Quality Standards will be applicable for waters
coming off of SRUs. These may either be applied at compliance points as established for the NPDES
permit at JOAAP or at compliance points as agreed by the Army, USEPA and IEPA during the
remedial design phase.
• RCRA Listed, Characteristic and Special Wastes
In order to address the relationship between RCRA and CERCLA cleanup/remediation requirements
the Army, USEPA and IEPA have agreed to the following:
If a media contaminated with a listed or characteristic hazardous waste is treated to the
remediation goals specified in the ROD for the facility, the LDRs specified in 35 IAC 728, and no
longer exhibits any characteristic of a hazardous waste, the media would not contain a RCRA
listed or characteristic hazardous waste. However, unless the treatment method actually
destroyed or removed the contaminants of concern from the media, the treated media might still
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. jo-2
-------
be considered a special waste and, therefore, subject to the special waste regulations at 35 IAC
808 through 815. (letter from C. Grigalauski, IEPA, to A. Holz, JOAAP, dated July 24, 1998). '
Special wastes are defined under the Illinois Environmental Protection Act as, "any industrial process
waste, pollution control waste or hazardous waste except as determined pursuant to Section 22.9 of
[the] Act. Special waste also means potentially infection medical waste."
Special waste permits are required to transport special waste, including hazardous waste, that is
generated and/or disposed of in Illinois. A permit is vehicle-specific and a copy of the approved
permit must be carried in each permitted vehicle. Transporters carrying special waste through the
state that is not generated nor disposed of in Illinois are not required to have the Illinois special waste
hauling permit, although the load must be accompanied by the proper manifest.
TCLP Limits
The RCRA TCLP (Toxicity Characteristic Leachate Procedure) limits will be used in addition to the
RGs to test soils at JOAAP. The TCLP tests will, as necessary, be conducted on (a) soils left at a site,
(b) soils to be treated, and (c) soils coming out of treatment. If treated soils fail TCLP, they must be
either stabilized and disposed at a permitted RCRA Subtitle D landfill (WCLF) or disposed at a
RCRA Subtitle C facility off-site. If pre-treatment TCLP tests indicate that the soils will fail TCLP
even after treatment and the soils are not RCRA hazardous wastes based on explosives contamination,
then the Army will dispose the soils at a RCRA Subtitle C facility directly without treatment. The
Army at its option and with the approval of the USEPA and IEPA may also treat those soils that fail
TCLP so that they may be disposed at WCLF or other landfill as appropriate.
Table 10.1; Water Quality Standards and TCLP Concentration
Contaminant
Water Quality Standards (ug/L)
TCLP Extract Concentration
Limits (mg/L)
Explosives
1,3,5-TNB
1,3-DNB
2,4,6-TNP
2,4,6-TNT
2,4-DNT
2,6-DNT
2-NT
DNAP
HMX
NB
RDX
Tetryl
15
4
700
75
330
150
62
400
260
8,000
500
NA
NA
NA
NA
NA
0.13
NA
NA
NA
NA
2.0
NA
NA
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (+3)
NA
610
160
5,000
NA
2.3
440
NA
NA
5
100
- NA
1
5
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
pg. 10-3
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Uobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
ihaJIiuni
Vanadium
Zinc
Water Quality Standards (ng/L)
1
N/
2'
1,001
&
1,00(
1.2
l.OOC
l.OOC
5
2(
NA
l.OOC
TCLP Extract Concentration
Limits (mg/L)
5
NA
> NA
NA
5
> NA
! 0.2
NA
1
5
NA
NA
NA
Volatiles
1,1,1 -Trichloroethane
1 , 1 ,2-Trichloroethane
1 , 1 -Dichloroethane
1,2-DichIoroethane
1 ,2-JJichloroethene
Acetone
Benzene
Chlorobenzene
Ethylbenzene
retrachloroethene
loluene
Prichloroethene
Xylenes
39(
NA
2,000
4,500
1,100
120,000
420
79
17
150
650
NA
110
NA
NA
NA
0.5
NA
NA
0.5
100
NA
0.7
NA
0.5
NA
Semivolatiles
l ,2-JDichlorobenzene
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
2-tJhIoronaphthalene
2-Methylnaphthalene
2-Methylphenol
4-MethyIphenol
1 ,2,4-Trichlorobenzene
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(g,h,I)perylene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzyl alcohol
17
200
62C
3C
12
37C
12C
72
62
NA
35,000
0.1
0.1
NA
0.1
1
80
NA
NA
7.5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
pg. 10-4
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Contaminant
Bis(2-ethylhexyl)phthalate
Butyl benzyl phthalate
Chrysene
Dibenz(a,h)anthracene
Dibenzofuran
Diethyl phthalate
Di-n-butyl phthalate
Di-n-octyl phthalate
Fluoranthene
Fluorene
Hexachlorobenzene
Indenof 1 ,2,3-cd]pyrene
Naphthalene
Phenanthrene
Phenol
Pyrene
Water Quality Standards (ug/L)
NA
23
10
0.01
12
NA
NA
NA
120
NA
4,500
0.00025
68
3.7
NA
3,500
TCLP Extract Concentration
Limits (mg/L)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.13
NA
NA
NA
NA
NA
Anions
Nitrate/Nitrite
Phosphate
Phosphorous
Sulfate
NA
50
50
500,000
NA
NA
NA
NA
PCBs
Chlordane
DDD
DDE
DDT
Dieldrin
Endrin
Heptachlor
Heptachlor epoxide
Isodrin
PCB 1254
PCB 1260
NA
NA
NA
0.00019
0.000045
0.033
0.000068
NA
0.1
0.00001
0.00001
0.03
NA
NA
NA
NA
0.02
0.008
0.008
NA
NA
NA
Organics-Special
IPH
NA
NA
10.2.1.2 Action-Specific ARARs for Soils OV
10.2.1.2.1 ARARs for Specific Activities Common to. all Soil Remediation Units (SRUs)
Fugitive dust emissions
For emissions associated with building demolition, soil extraction, soil preparation, composting, and
transportation, the following requirements will be ARARs:
JOAAP Record ofDecision -Soil & Groundwater OUs - October, 1998
pg. 10-5
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• 35 111. Admin. Code 201.141, Prohibition of Air Pollution - applicable to actions that threaten "or
allow the discharge or emission of any contaminant into the environment which causes or tends to
cause air pollution in the State of Illinois or which violates or prevents the attainment or maintenance
of any applicable ambient air quality standard.
• 35 111. Admin. Code 212.301, Fugitive Paniculate Matter - applicable if fugitive dust emissions are
produced from the remedial activities conducted pursuant to each remedy. This section prohibits the
emission of fugitive particulate. matter from any process, including material handling or storage
activity, that is visible by an observer looking generally toward the zenith at a point beyond the
property line of the source.
• 35 111. Admin. Code 212.314, Exception for Excess Wind Speed - applicable if wind speed is greater
than 40.2 km/hr (25 mph).
• 35 111. Admin. Code 212.315, Covering for Vehicles - applicable if vehicles are utilized pursuant to
any remedy to transport excavated soil to central treatment areas or off-site for disposal.
Investigation-derived waste
• USEPA OSWER Publication 9345.3-03FS (January 1992) - TBC Guidance, for IDW produced for
confirmatory or other sampling procedures.
Institutional controls
• The following will be applicable to each soil remedy: 35 111. Admin. Code 724.216, Survey Plaf and
40 C.F.R. §300.430(a)(l)(iii)(D). '
* Substantive portions of 35 111. Adm. Code 742 Subpart J will be followed for institutional controls to
be placed on the property (35 111. Adm. Code 742.1000) and for issuance of No Further Remediation
Letters, Restrictive Covenants, Deed Restrictions and Negative Easements, and Local Ordinances (35
111. Admin. Code 742.1005, 742.1010, and 742.1015.)
Storm water discharges
• For storm water discharges from either composting or excavation activities, the substantive
requirements of the Illinois NPDES permit program (35 111. Admin. Code 309) will be applicable.
For excavation activities, the substantive requirements of the Illinois general permit for Construction
Site Activities (NPDES Permit No. ILR10) will be followed. For composting activities involving
non-hazardous contaminated soil, the substantive requirements of the Illinois General NPDES Permit
for Industrial Storm Water (NPDES Permit No. ILROO) will be followed. JOAAP currently has a
valid NPDES permit and the JOAAP will comply with it.
UXO/TNT
If UXO is found, it will be screened, removed and stockpiled for either open burn/detonation on-site or
off-site incineration at a permitted facility. Raw TNT may be transported off-site for disposal.
• For on-site Open Burning/Open Detonation of UXO, the substantive requirements set forth in the
following sections will be applicable to open burn/open detonation activities during implementation
of this remedial alternative: 35 111. Admin. Code 724.701, Environmental Performance Standards; 35
111. Admin. Code 724.702, Monitoring, Analysis, Inspection, Response, Reporting and Corrective
Action; and 35 111. Admin. Code 724.703, Post-closure Care.
• If raw TNT is transported off-site for disposal and meets the definition of a hazardous waste or for
off-site incineration of UXO, the following requirements will be applicable: 35 III. Admin. Code
722.111, Hazardous Waste Determination; 35 111. Admin. Code 722.112, USEPA Identification
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 ng. JO-6
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Numbers; 35 111. Admin. Code 722.120, General Requirements; 35 111. Admin. Code 722.121,
Acquisition of Manifests; 35 111. Admin. Code 722.122, Number of Copies; 35 111. Admin. Code
722.123, Use of the Manifest; 35 111. Admin. Code 722.130, Packaging; 35 111. Admin. Code 722.131,
Labeling; 35 111. Admin. Code 722.132, Marking; 35 111. Admin. Code 722.133, Placarding; 35 111.
Admin. Code 722.140, Record keeping; 35 111. Admin. Code 722.141, Annual Reporting; 35 111.
Admin. Code 722.142, Exception Reporting; 35 111. Admin. Code 722.143, Additional Reporting; 35
111. Admin. Code 728.107, Waste Analysis and Record keeping; and 35 111. Admin. Code 728.109,
Special Rules for Characteristic Wastes and Illinois Department of Transportation Regulations: 92 111.
Admin. Code 171; 92 111. Admin. Code 172; 92 111. Admin. Code 173; and 92 111. Admin. Code 177.
In addition, the UXO/TNT will be classified as a special waste; therefore, the following special waste
regulations relating to manifesting and transport will be applicable: 35 111. Admin. Code 808.121,
Generator Obligations; 35 III. Admin. Code 808.240, Special Waste Classes; 35 III. Admin. Code
808.241, Default Classification of Special Wastes; 35 111. Admin. Code 808.242, Special Handling Waste;
35 111. Admin. Code 808.243, Wastes Categorized by Source; 35 111. Admin. Code 808.244, Wastes
Categorized by Characteristics; 35 111. Admin. Code 808.245, Classification of Wastes; 35 111. Admin.
Code 808 Subpart D, Request for Waste Classification; 35 111. Admin. Code 808 Subpart H, Categorical
and Characteristic Wastes; and 35 111. Admin. Code 808 Appendix A, Assignment of Special Waste to
Classes; and 35 111. Admin. Code 808 Appendix B, Toxicity Hazard; 35 111. Admin. Code 809 Subpart B,
Special Waste Hauling Permits; Subpart C, Delivery and Acceptance; Subpart D, Vehicle Numbers and
Symbols; Subpart E, Manifests, Records and Reporting; Subpart F, Duration of Permits... and; Subpart G,
Emergency Contingencies for Spills.
Wash water
Wash water from trucks and the pressure wash operation will be containerized and either used as makeup
water in the treatment process or containerized for off-site disposal.
• If wash water meets the definition of a hazardous waste, then the following requirements associated
with containers will be applicable to this remedial alternative: 35 111. Admin. Code 722.134,
Accumulation Time, 35 111. Admin. Code 724.271, Condition of Containers; 35 111. Admin. Code
724.272, Compatibility of Waste With Container; 35 111. Admin. Code 724.273, Management of
Containers; 35 111. Admin. Code 724.275, Containment; and 35 111. Admin. Code 724.278, Closure.
• If the wash water meets the definition of a hazardous waste and is transported off-site for disposal,
then the following requirements will be applicable to this remedial alternative: 35 111. Admin. Code
722.111, Hazardous Waste Determination; 35 111. Admin. Code 722.112, USIiPA Identification
Numbers; 35 111. Admin. Code 722.120, General Requirements; 35 111. Admin. Code 722.121,
Acquisition of Manifests; 35 111. Admin. Code 722.122, Number of Copies; 35 111. Admin. Code
722.123, Use of the Manifest; 35 111. Admin. Code 722.130, Packaging; 35 111. Admin. Code 722.131,
Labeling; 35 111. Admin. Code 722.132, Marking; 35 111. Admin. Code 722.133, Placarding; 35 111.
Admin. Code 722.140, Recordkeeping; 35 111. Admin. Code 722.141, Annual Repotting; 35 111.
Admin. Code 722.142, Exception Reporting; 35 111. Admin. Code 722.143, Additional Reporting; 35
111. Admin. Code 728.107, Waste Analysis and Recordkeeping; and 35 111. Admin. Code 728.109,
Special Rules for Characteristic Wastes and Illinois Department of Transportation Regulations: 92 111.
Admin. Code 171; 92 111. Admin. Code 172; 92 111. Admin. Code 173; and 92 111. Admin. Code 177.
• Irrespective of the hazardous waste determination, the washwater will be considered a special waste,
thus, the following requirements will be applicable: 35 111. Admin. Code 808.121, Generator
Obligations; 35 111. Admin. Code 808.240, Special Waste Classes; 35 111. Admin. Code 808.241,
Default Classification of Special Wastes; 35 111. Admin. Code 808.242, Special Handling Waste; 35
III. Admin. Code 808.243, Wastes Categorized by Source; 35 111. Admin. Code 808.244, Wastes
Categorized by Characteristics; 35 111. Admin. Code 808.245, Classification of Wastes; 35 111. Admin.
Code 808 Subpart D, Request for Waste Classification; 35 111. Admin. Code 808 Subpart H,
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 10-7
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Categorical and Characteristic Wastes; and 35 III. Admin. Code 808 Appendix A, Assignment of
Special Waste to Classes; and 35 111. Admin. Code 808 Appendix B, Toxicity Hazard; 35 III. Admin.
Code 809 Subpart B, Special Waste Hauling Permits; Subpart C, Delivery and Acceptance; Subpart
D, Vehicle Numbers and Symbols; Subpart E, Manifests, Records and Reporting; Subpart F, Duration
of Permits and; Subpart G, Emergency Contingencies for Spills.
Transportation requirements for RCRA hazardous waste
For all transportation of RCRA hazardous waste using state roads from the excavated areas to a central
treatment area, the following Illinois Department of Transportation Regulations will be applicable: 92 111.
Admin. Code 171; 92 111. Admin. Code 172; 92 HI. Admin. Code 173; and 92 111. Admin. Code 177.
10.2.1.2.2 Land Disposal Restrictions: SRU1, SRU2, SRU3, SRU4 and SRU6
• Land disposal restrictions are triggered when RCRA hazardous contaminated soil is excavated from
one unit, which in this case is deemed to be a landfill, and placed into another land-based unit (i.e., if
the soil is later used for backfill at a different area or disposed of offsite at a RCRA Subtitle C or at
the WCLF or other permitted facility after treatment). If land disposal restrictions are triggered, then
the following substantive requirements will be applicable: 35 111. Admin. Code 728.101, Purpose,
Scope and Applicability; 35 111. Admin. Code 728.103, Dilution Prohibited as a Substitute for
Treatment; 35 111. Admin. Code 728.107, Waste Analysis and Record keeping; and 35 111. Admin.
Code 728.109, Special Rules for Characteristic Wastes.
• For the waste codes D003, D006, D008, K046, K047, Kl 111, and any other wastes codes identified
during excavation, the following corresponding sections of Illinois hazardous waste regulations,
which prohibit land disposal of specifically identified wastes, will be applicable: 35 111. Admin.
Code 728.133, Waste Specific Prohibitions: First Third Wastes; 35 111. Admin. Code 728.134, Waste
Specific Prohibitions - Second Third Wastes; 35 111. Admin. Code 728.135, Waste Specific
Prohibitions - Third Third Wastes; 35 111. Admin. Code 728.136, Waste Specific Prohibitions - Newly
Listed Wastes, and 35 111. Admin. Code 728.139 Statutory Prohibitions.
• C.F.R. 268.39(c)(1997), which provides additional waste specific prohibitions, will be applicable.
(Illinois has no equivalent state regulations.)
• If each identified waste meets individually assigned treatment standards, then the wastes may be land
disposed. For the waste codes D003, D006, D008, K046, K047, Kl 111, and any other wastes codes
identified during excavation, the corresponding specific regulations from the following treatment
standards regulations will be applicable: 35 III. Admin. Code 728.140, Applicability of Treatment
Standards; 35 111. Admin. Code 728.141, Treatment Standards expressed as Concentrations in Waste;
35 111. Admin. Code 728.142, Treatment Standards Expressed as Specified Technologies; 35 111!
Admin. Code 728.143, Treatment Standards expressed as Waste Concentrations; 35 III. Admin. Code
728.144, Adjustment of Treatment Standards; 35 111. Admin. Code 728.145, Treatment Standards for
Hazardous Debris; 35 111. Admin. Code 728.148, Universal Treatment Standards, 35 111. Admin.
Code 728.150, Prohibitions on Storage of Restricted Wastes, 35 111. Admin. Code 728.Appendix J,
Record keeping, Notification, and Certification Requirements (for any waste going off-site to a
RCRA Subtitle C landfill, administrative as well as substantive requirements will be applicable); 35
111. Admin. Code 728.Table T, Treatment Standards for Hazardous Wastes, and 35 111. Admin. Code
728.Table U, Universal Treatment Standards.
• "If a media contaminated with a listed or characteristic hazardous waste is treated to the remediation
goals specified in the ROD for the facility, the LDRs specified in 35 IAC 728, and no longer exhibits
any characteristic of a hazardous waste, the media would not contain a RCRA listed or characteristic
hazardous waste. However, unless the treatment method actually destroyed or removed the
contaminants of concern from the media, the treated media might still be considered a special waste
and, therefore, subject to the special waste regulations at 35IAC 808 through 815."
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. JO-8
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"Since the treated residues of K047, which exist in the North and South red water ash landfills [Sites
Ml and M9] at JOAAP, no longer exhibit the characteristic of reactivity, they are not hazardous
wastes under the regulation at 35 IAC 721.103(a)(2)(C)." [from letter from C. Grigalauski, IEPA to
A. Holz, JOAAP, dated July 24, 1998]
10.2.1.2.3 ARARs for Bioremediation : SRU1 and SRU3 (bioremediation alternative)
Note that ARARs are provided for the remedial activity of composting. If an alternate bioremediation
technology is utilized under this alternative, the ARARs for the alternate technology, if different from
those presented in these sections, will be identified and submitted to the USEPA and IEPA for review and
approval prior to implementation of the remedy. Composting will be accomplished in remediation piles or
in a containment building.
• If the Hazardous Contaminated Media Rule is finalized and adopted by Illinois prior to remediation,
compostingt of RCRA hazardous waste could be accomplished though remediation piles, the piles
would be considered as remediation piles under proposed 40 CFR 260.10 and proposed 40 CFR
264.544. These requirements would be applicable when Illinois adopts this rule.
• If composting is accomplished in a containment building, then the following Illinois requirements
will be applicable to the containment building which treats RCRA hazardous waste: 35 111. Admin.
Code 724.113, General Waste Analysis; 35 111. Admin. Code 724.114, Security, 35 111. Admin. Code
724.1100, Applicability; 35 III. Admin. Code 724.1101, Design and Operating Standards; 35 111.
Admin. Code 724.1102, Closure and Post-closure Care; 35 111. Admin. Code 724.211, Closure
Performance Standard; and 35 111. Admin. Code 724.214, Disposal or Decontamination of Equipment,
Structures and Soils.
10.2.1.2.4 ARARs for Transportation and Disposal of Hazardous Waste at a Subtitle C Facility: SRU2
SRU3,andSRU6 '
Under one of the disposal options for SRU2 , SRU3, and SRU6, and portions of SRU2 (under both
disposal options), excavated hazardous contaminated soil would be disposed offsite at a RCRA Subtitle C
facility. For transportation of the contaminated soil off-site to the RCRA Subtitle C facility the following
regulations will be applicable: 35 111. Admin. Code 722.134, Accumulation Time, 35 111. Admin. Code
724.271, Condition of Containers; 35 111. Admin. Code 724.272, Compatibility of Waste With Container;
35 111. Admin. Code 724.273, Management of Containers; 35 111. Admin. Code 724.275, Containment;
and 35 111. Admin. Code 724.278, Closure, 35 111. Admin. Code 722.111, Hazardous Waste
Determination; 35 111. Admin. Code 722.112, USEPA Identification Numbers; 35 III. Admin. Code
722.120, General Requirements; 35 111. Admin. Code 722.121, Acquisition of Manifests; 35 111. Admin.
Code 722.122, Number of Copies; 35 111. Admin. Code 722.123, Use of the Manifest; 35 111. Admin. Code
722.130, Packaging; 35 111. Admin. Code 722.131, Labeling; 35 111. Admin. Code 722.132, Marking; 35
111. Admin. Code 722.133, Placarding; 35 111. Admin. Code 722.140, Record keeping; 35 111. Admin. Code
722.141, Annual Reporting; 35 111. Admin. Code 722.142, Exception Reporting; 35 111. Admin. Code
722.143, Additional Reporting; 35 111. Admin. Code 728.107, Waste Analysis and Record keeping; and
35 111. Admin. Code 728.109, Special Rules for Characteristic Wastes and Illinois Department of
Transportation Regulations: 92 111. Admin. Code 171; 92 111. Admin. Code 172; 92 III. Admin. Code 173-
and 92 111. Admin. Code 177.
In addition, the hazardous waste will be classified as a special waste; therefore, the following special
waste regulations relating to manifesting and transport will be applicable: 35 111. Admin. Code 808.121,
Generator Obligations; 35 111. Admin. Code 808.240, Special Waste Classes; 35 III. Admin. Code
808.241, Default Classification of Special Wastes; 35 111. Admin. Code 808.242, Special Handling Waste;
35 111. Admin. Code 808.243, Wastes Categorized by Source; 35 111. Admin. Code 808.244, Wastes
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 10-9
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Categorized by Characteristics; 35 111. Admin. Code 808.245, Classification of Wastes; 35 111. Admin
Code 808 Subpart D, Request for Waste Classification; 35 111. Admin. Code 808 Subpart H, Categorical
and Characteristic Wastes; and 35 111. Admin. Code 808 Appendix A, Assignment of Special Waste to
Classes; and 35 111. Admin. Code 808 Appendix B, Toxicity Hazard; 35 111. Admin. Code 809 Subpart B,
Special Waste Hauling Permits; Subpart C, Delivery and Acceptance; Subpart D, Vehicle Numbers and
Symbols; Subpart E, Manifests, Records and Reporting; Subpart F, Duration of Permits... and; Subpart G
Emergency Contingencies for Spills.
10.2.1.2.5 ARARs for Transportation and Disposal of Soil, Stones, and Debris to a Permitted RCRA
Subtitle D Landfill
Excavated non-hazardous soil, soil with PCB levels less than 50 ppm, or hazardous soil treated to remove
any hazardous characteristic and which meets LDRs may be transported and disposed off-site at a
permitted RCRA Subtitle D landfill (WCLF or other permitted facility). In addition, any part of the
bioremediation treatment area (SRU1 and SRU3) or associated buildings at the SRU's which are
demolished for remediation, which cannot be salvaged will be disposed at WCLF or other permitted
facility. Debris and large stones segregated from the excavated soil will be reused or properly disposed.
• For all non-hazardous soil, stones, and debris disposed of at WCLF or other permitted facility, the
applicable criteria of 415 ILCS 5/22.48 for non-special waste certification will be met. 'ihe
soil/stones/debris will be exempted from the requirements for a special waste using the generator
certification process contained in 415 ILCS 5/22.48.
• For the treated soil sent to WCLF or other permitted facility, the hazardous waste will be treated to
remove any characteristic and meet LDRs; thus, will no longer be considered a hazardous waste. For
this treated hazardous waste, 35 111. Admin. Code 721.103 will be applicable. The soil may still be
classified as a special waste; therefore, the following special waste regulations relating to manifesting
and transport will be applicable: 35 111. Admin. Code 808.121, Generator Obligations; 35 III. Admin.
Code 808.240, Special Waste Classes; 35 111. Admin. Code 808.241, Default Classification of Special
Wastes; 35 111. Admin. Code 808.242, Special Handling Waste; 35 111. Admin. Code 808.243, Wastes
Categorized by Source; 35 111. Admin. Code 808.244, Wastes Categorized by Characteristics; 35 111.
Admin. Code 808.245, Classification of Wastes; 35 111. Admin. Code 808 Subpart D, Request for
Waste Classification; 35 111. Admin. Code 808 Subpart H, Categorical and Characteristic Wastes; and
35 111. Admin. Code 808 Appendix A, Assignment of Special Waste to Classes; and 35 111. Admin.
Code 808 Appendix B, Toxicity Hazard; 35 111. Admin. Code 809 Subpart B, Special Waste Hauling
Permits; Subpart C, Delivery and Acceptance; Subpart D, Vehicle Numbers and Symbols; Subpart E,
Manifests, Records and Reporting; Subpart F, Duration of Permits and; Subpart G, Emergency
Contingencies for Spills.
10.2.1.2.6 ARARs for Use of Non-Hazardous Soil Below RGs or Bioremediated Below RGs as Backfill-
SRU1, SRU2, SRU3, and SRU5
Under one of the disposal options for SRU1, SRU2, SRU3, and SRU5,the non-hazardous soil below RGs
or non-hazardous soil bioremediated to RGs will be used as backfill or as subgrade. No environmental
requirements have been identified to regulate the backfill and the subgrade of non-hazardous soil below
RGs.
10.2.1.2.7 Additional ARARs Specific to SRU3: Explosives and Metals in Soil (Bioremediation and
Disposal without Treatment Alternatives)
Solidification/Stabilization prior to disposal at WCLF or other permitted facility
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg. 10-10
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• If soils are determined to be hazardous and are treated by stabilization/solidification on-site, then the
following requirements will be applicable to the treatment unit : 35 111. Admin. Code 724.292,
Design and Installation of New Tank Systems or Components; 35 111. Admin. Code 724.293,'
Containment and Detection of Releases; 35 111. Admin. Code 724.294 General Operating
Requirements; 35 111. Admin. Code 724.295, Inspections; 35 111. Admin. Code 724.297, Closure and
Post-Closure Care; 35 111. Admin. Code 724.211, Closure Performance Standard; and 35 111. Admin.
Code 724.214, Disposal or Decontamination of Equipment, Structures and Soils.
10.2.1.2.8 Additional ARARs Specific to SRU4: PCBs in Soil
Disposal at a TSCA reflated landfill
• The following will be applicable to disposal at a TSCA regulated landfill: 40 CFR 761.65( c),
Storage for Disposal; 40 CFR 761.60(d), 40 C.F.R. § 761.60(a)(4) (1997), Disposal Requirements; 40
C.F.R. § 761.75 (1997), Chemical Waste Landfills (PCB contaminated soil must be sent to a USEPA
approved chemical waste landfill, i.e., landfill must be in compliance with this section); 40 C.F.R. §
761.202 (1997), USEPA Identification numbers; 40 C.F.R. § 761.205(1997), Notification of PCB
waste activity (USEPA Form 7710-53); 40 C.F.R. § 761.207(1997), The manifest - general
requirements; 40 C.F.R. § 761.208(1997), Use of the manifest; 40 C.F.R. § 761.209(1997),
Retention of manifest records; 40 C.F.R. 761.215(1997), Exception reporting; and 40 C.F.R. §
761.218(1997), Certificate of Disposal and Illinois Department of Transportation Regulations: 92 111.
Admin. Code 171; 92 111. Admin. Code 172; 92 III. Admin. Code 173; and 92 111. Admin. Code 177.
• For any portions of the waste, which are also contaminated with RCRA characteristic waste, in
addition to the ARARs identified above, the ARARs identified for transportation to a RCRA Subtitle
C landfill listed in Section 10.2.1.2.4 will also be applicable for disposal at a TSCA/RCRA regulated
landfill.
Off-site incineration - including transportation
• The following will be applicable to the remedial actions involving off-site incineration of PCB
contaminated soil: 40 CFR 761.65 ( c), Storage for Disposal; 40 CFR 761.60(d), Spills; 40 CFR
761.79, Decontamination., 40 C.F.R. § 761.60(a)(4) (1997), Disposal Requirements; 40 C.F.R. §
761.70 (1997), Incineration (PCB contaminated soil must be sent to an USEPA-approved incinerator,
i.e., incinerator must be in compliance with this section); 40 C.F.R. § 761.202 (1997), USEPA
Identification numbers; 40 C.F.R. § 761.205(1997), Notification of PCB waste activity (USEPA
Form 7710-53); 40 C.F.R. § 761.207(1997), The manifest - general requirements; 40 C.F.R. §
761.208(1997), Use of the manifest; 40 C.F.R. § 761.209(1997), Retention of manifest records; 40
C.F.R. § 761.215(1997), Exception reporting; and 40 C.F.R. § 761.218(1997), Certificate of Disposal
and Illinois Department of Transportation Regulations: 92 111. Admin. Code 171; 92 III. Admin Code
172; 92 111. Admin. Code 173; and 92 111. Admin. Code 177.
• For any portions of the waste, which are also contaminated with RCRA characteristic waste, in
addition to the ARARs identified above, the ARARs identified for transportation to a RCRA Subtitle
C landfill listed in Section 10.2.1.2.4 will also be applicable for transportation of the mixed waste to
a TSCA/RCRA regulated incinerator.
10.2.1.2.9 Additional ARARs Specific to SRU6: Landfills
Subtitle D caps
22. The applicable requirements associated with the placement of Subtitle D caps over the landfills
are as follows: 35 111. Admin. Code 807.305, Cover; 35 111. Admin. Code 807.312, Air Pollution;
35 111. Admin. Code 807.313, Water Pollution; 35 111. Admin. Code 807.318, Completion or
Closure Requirements; and 35 111. Admin. Code 807.502, Closure Performance Standard, 35 IAC
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg. 10-11
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811.110, Closure; 35 IAC 811.111, Post-closure Maintenance; 35 IAC 811.308, Leachate
Collection System; 35 IAC 811.314, Final Cover System; and 35 IAC 811.319, Groundwater
Monitoring Programs.
Subtitle C caps - including closure, postclosure. and groundwater monitoring
• The relevant and appropriate requirements associated with closure and post-closure care are as
follows: 35 111. Admin. Code 724.410, Closure and Postclosure Care; 35 111. Admin. Code 724.211,
Closure Performance Standard; 35 HI. Admin. Code 724.214, Disposal or Decontamination of
Equipment, Structures and Soils; and 35 111. Admin. Code 724.217, Post-Closure Care and Use of
Property, 35 111. Admin. Code 811.110, Closure, 35 111. Admin. Code 811.811, Postclosure
Maintenance, 35 IAC 724.216, Survey Plat; 35 IAC 724 219 Post-Closure Notices.
• The relevant and appropriate requirements associate with groundwater monitoring activities are as
follows: 35 111. Admin. Code 724.190, Applicability; 35 111. Admin. Code 724.197, General
Groundwater Monitoring Requirements; 35 111. Admin. Code 724.200, Corrective Action Program;
and 35 111. Admin. Code 724.201, Corrective Action for Solid Waste Management Units.
10.2.1.2.10SRU7: Sulfur (Preferred Alternative: Removal and Recycle or Disposal)
No environmental requirements have been identified to regulate the removal, recycling or disposal of the
raw sulfur, other than the requirements common to all the SRUs and discussed in Section 10.2.1.2.1.
10.2.1.3 Location-specific ARARs and TBC Guidance for Soils OU
• Executive Order 11988, entitled "Floodplain Management", May 24, 1977; 40 C.F.R. 6.302(b)( 1997);
40 C.F.R. 6 Appendix A(1997) - Applicable for protection of floodplains during remedial actions at
Site L4, SRU 6.
• Executive Order 11990, entitled "Protection of Wetlands", May 24, 1977; 40 C.F.R. 6.302(a)(1997);
40 C.F.R. 6 Appendix A(1997) - Applicable for the avoidance and minimization of adverse impacts
to wetlands during remedial actions at Site L4, SRU 6.
• Rivers & Harbors Act of 1899, Section 10. Section 10 permit required for structures or work in or
affecting navigable waters. 33 USC 403, 33 CFR 320-330. - Applicable.
• Clean Water Act Section 404; 40 C.F.R. 230(1997); 33 C.F.R. 320-330(1997) - Applicable
requirement to prohibit discharge of dredged or fill material into wetlands without a permit.
• Pertinent portions of the Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661 et seq.);
Clean Water Act Section 404,40 C.F.R. 230, and 33 C.F.R. 320-330(1997) - Applicable requirement
for federal agencies to take into consideration the effect that water-related remedial actions will have
on fish and wildlife and take action to prevent loss or damage to these resources. Consultation with
either the Fish and Wildlife Service or the State to develop measures to protect potentially affected
wildlife is recommended.
• The following statutory and regulatory sections are applicable for the protection of the Upland
Sandpiper (Bartramia longicauda), federal-listed endangered bird and state-listed endangered bird of
Illinois: 16 USC 1531 et seq., 50 CFR 200, 50 CFR 402, Section 10/3 of the Illinois Endangered
Species Act (520 ILCS 10/3), Possession, transportation, sale or disposition of animal or animal
product unlawful; Section 10/7 (520 ILCS 10/7), Listing of endangered or threatened species-
dehsting; ,17 111. Admin. Code 1010.30, Official List, adopted by the Illinois Endangered Species
Protection Board as the Official List of Endangered and Threatened Fauna of Illinois; pertinent
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998 pg. 10-12
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portions of 17 111. Admin. Code 1070, Possession of Specimens or Products of endangered or
threatened species.
• Pertinent portions of 17 111. Admin. Code 1075, Consultation Procedures for Assessing Impacts of
Agency Actions on Endangered and Threatened and Natural Areas, are TBC guidance for remedial
activities at JOAPP.
• If any migratory birds impacted, Migratory Bird Treaty Act of 1 9 1 8, 1 6 USC 703-7 1 1 is applicable.
]Q,2,2 Compliance with Am>licable or Relevant and Appropriate Requirements (ARARs) and To-Be-
Considered (TBC) Guidance for Groundwater Operable Unit
10.2.2. 1 Chemical-specific ARARs and TBC Guidance for Groundwater OU
Groundwater
The State of Illinois has established groundwater classifications as well as standards for groundwater,
which are implemented by regulations promulgated at 35 111. Adm. Code 620. Groundwater in the
shallow bedrock aquifer is classified as Class I groundwater (35 II. Adm. Code 620.210 and groundwater
in the uppermost or overburden aquifer (glacial drift aquifer) is classified as Class II groundwater (35 Jl.
Adm. Code 620.220). Groundwater Management Zones (GMZs) will be established to provide protection
for both aquifers. In addition, the SDWA MCLs are relevant and appropriate requirements for the
remediation of the Class I groundwater in the shallow bedrock aquifer at JOAAP. Requirements
associated with the GMZs are as follows:
• 35 111. Adm. Code 620.450 - Applicable requirement that, upon completion of a corrective action, the
standards for such released chemical constituents are either (1) the standards specified in 35 II. Adm.
Code 620.410 and 35 II. Adm. Code 620.420 for concentrations of chemical constituents in Classes I
and II groundwater, respectively; or (2) the concentration determined by groundwater monitoring for
such constituent and the exceedance has been minimized to the extent practicable, and beneficial use
appropriate for that class has been returned; and any threats to human health and environment have
been minimized.
• 35 111. Adm. Code 620.450(a) - Applicable groundwater restoration standards lor any chemical
constituents in groundwater within the Groundwater Management Zone prior to completion of a
corrective action as described in 35 II. Adm. Code 620.250(a).
• 35 111. Adm. Code 620.505(a.)(4.) - Applicable for a Groundwater Management Zone; compliance
with standards is determined as specified in the corrective action process
• 35 111. Adm. Code 620.505(a.)(5.) - Applicable: compliance with standards will be determined at any
point at which groundwater monitoring is conducted using a monitoring well that meets the
conditions of 620.505(a.)(5.D.).
• 35 II. Adm. Code 620.1 15 - Applicable: a prohibition against violations of the Illinois Environmental
Protection Act (S.H.A. 415 ILCS 5/12. Acts Prohibited) and the Illinois Groundwater Protection Act
(S.H.A. 415 ILCS 55/1 - 55/9).
In addition, due to the direct hydrological connection between groundwater and the surface water bodies
at JOAAP (Prairie Creek, Jackson Creek, and Grant Creek), protection of these surface water bodies must
be considered. The appropriate CWA and Illinois Water Quality Standards at 40 CFR Part 13 1 and 35 II.
Adm. Code 302, Subparts B and D for the chemical constituents of concern in groundwater, based on the
use class designations of the affected water bodies, will be met in the surface water bodies downstream of
the hydrological connection with the groundwater.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 10-13
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ARARs and TBCs necessary for protection must be attained for hazardous substances, pollutants or
contaminants remaining on-site at the completion of the remedial actions.
10.2.2.1.1 GRU1: Explosives in Groundwater
• TBC guidance: values calculated based on EPA and IEPA guidance (see Section 102 1 1 for
references) for explosives - 2,4-dinitrotoluene (0.02ug/L); 2,6- dinitrotoluene (0.31 ug/L); 135-
tnmtrobenzene (0.35ug/L); 2,4,6-trinitrotoluene (3.5 ug/L); RDX (2 ug/L); HMX (260 ug/L); :
10.2.2.1.1 GRU2: Explosives and Other Contaminants in Groundwater
• 35 II Adm. Code 620.410 (1997) - At completion of the remedy, applicable standards for Class I
groundwater in the shallow bedrock aquifer; 40 CFR Part 141.62 (1997) - At completion of the
remedy Relevant and Appropriate Maximum Contaminant Levels for groundwater in the shallow
DearocK aquiter:
-for Class I groundwater for metals: antimony (6 ug/L); cadmium (5 ug/L); iron (5,000 ug/L)
-for Class I groundwater for sulfates (400,000 ug/L);
-for Class I groundwater for perchloroethene (5 ug/L); toluene (1000 ug/L); and 12-
dichloroethane (5 ug/L). r-o ,
• 35 II. Adm. Code 620.420 (1997) - At completion of the remedy, applicable standards for Class II
groundwater in the uppermost or overburden aquifer (glacial drift aquifer):
-for Class II groundwater for metals: antimony (24 ug/L); cadmium (50 ug/L); and iron (5000
-for Class II groundwater for sulfates (400,000
-for Class II groundwater for perchloroethene (25 ug/L); toluene (2500 ug/L); and 12-
dichloroethane (25 ug/L).
TBC 8"idance: values calculated based on IEPA guidance for explosives at completion of the
remedial action , - 2,4-dinitrotoluene (0.02 ug/L); 2,6- dinitrotoluene (0.31 ug/L); 1,3,5-trinitrobenzene
0.35 ug/L); 2 4 6-tnmtrotoluene (3.5 ug/L); RDX (2 ug/L); 2-nitrotoluene (70 ug/L); nitrobenzene
3.5 u/ -
.
(3.5 ug/L); and 1,3-dimtrobenzene (0.7 ug/L).
1 0.2.2. 1 .3 GRU3: Volatile Organic Compounds in Groundwater
L5 ILHAd?1' C°du 6l°-f,10 (1"7) ' At comPletion of the remedy, applicable standard for Class I
groundwater in the shallow bedrock aquifer; 40 CFR Part 141.62 (1997) - At completion of the
Appr°priate Maximum Contaminant Level for groundwater in the shallow
-for Class I groundwater for toluene (1000 ug/L)
* 35 II Adm. Code 620.420 (1997) - At completion of the remedy, applicable standard for Class II
groundwater m the uppermost or overburden aquifer (glacial drift aquifer):
-for Class II groundwater for toluene (2500 ug/L).
10.2.2.2 Action-specific ARARs and TBC Guidance for Groundwater
• 35 II. Adm. Code 620.250 - Applicable to the establishment of a Groundwater Management Zone to
mitigate impairment caused by release of contaminants
• 35 111 Adm. Code 620.405 - Applicable prohibition against the release of any contaminant to
groundwater during remedial activities at JOAAP.
• 35 III. Adm. Code 620.5 10 - Applicable requirements for monitoring and sampling.
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
pg. 10-14
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• Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action, and Underground
Storage Tank Sites, USEPA OSWER Directive 9200.4-17, November 1997 - TBC guidance for use
of monitored natural attenuation at GRUs at JOAAP.
Substantive portions of 35 111. Adm. Code 742 Subpart J - will be followed for institutional controls to be
placed on the property (35 III. Adm. Code 742.1000) and for issuance of No Further Remediation Letters,
Restrictive Covenants, Deed Restrictions and Negative Easements, and Local Ordinances. (35 111 Admin
Code 742.1005, 742.1010, and 742.1015.)
10.2.2.3 Location-specific ARARs and TBC Guidance for Groundwater
• Executive Order 11988, entitled "Floodplain Management", May 24, 1977; 40 C.F.R. 6.302(b)(1997);
40 C.F.R. 6 Appendix A(1997) - Applicable for protection of floodplains during remedial actions at
Site L4, SRU 6.
• Executive Order 11990, entitled "Protection of Wetlands", May 24, 1977; 40 C.F.R. 6.302(a)(1997);
40 C.F.R. 6 Appendix A(1997) - Applicable for the avoidance and minimization of adverse impacts
to wetlands during remedial actions at Site L4, SRU 6.
• Rivers & Harbors Act of 1899, Section 10. Section 10 permit required for structures or work in or
affecting navigable waters. 33 USC 403, 33 CFR 320-330. Applicable.
• Clean Water Act Section 404; 40 C.F.R. 230(1997); 33 C.F.R. 320-330(1997) - Applicable
requirement to prohibit discharge of dredged or fill material into wetlands without a permit.
• Pertinent portions of the Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661 et seq.);
Clean Water Act Section 404, 40 C.F.R. 230, and 33 C.F.R. 320-330(1997) - Applicable requirement
for federal agencies to take into consideration the effect that water-related remedial actions will have
on fish and wildlife and take action to prevent loss or damage to these resources. Consultation with
the U.S. Fish and Wildlife Service and the State of Illinois to develop measures to protect potentially
affected wildlife is recommended.
• The following statutory and regulatory sections are applicable for the protection of the Upland
Sandpiper (Bartramia longicauda), state-listed endangered bird of Illinois: Section 10/3 of the
Illinois Endangered Species Act (520 ILCS 10/3), Possession, transportation, sale or disposition of
animal or animal product unlawful; Section 10/7 (520 ILCS 10/7), Listing of endangered or
threatened species-delisting; 17 III. Admin. Code 1010.30, Official List, adopted by the Illinois
Endangered Species Protection Board as the Official List of Endangered and Threatened Fauna of
Illinois; pertinent portions of 17 111. Admin. Code 1070, Possession of Specimens of Products of
endangered or threatened species.
• If any migratory birds impacted, Migratory Bird Treaty Act of 1918, 16 USC 703-711 is applicable.
Pertinent portions of 17 111. Admin. Code 1075, Consultation Procedures for Assessing Impacts of
Agency Actions on Endangered and Threatened and Natural Areas, are TBC guidance for remedial
activities at JOAAP.
10.3 Cost Effectiveness
10.3.1 SoilOTJ
The selected final and interim remedies for the SOU provide overall effectiveness proportionate to its
costs. Although other remedies have lower or higher costs, the selected remedies were chosen because
they have the best cost/benefit ratio. After balancing short- and long-term effectiveness and permanence,
reduction in toxicity, mobility or volume of contaminant, and implementability to the overall cost of the
selected remedies, the ratio of these criteria to cost is the best for the selected remedies compared to the
other remedies. The overall net present worth cost of capital and operational and maintenance cost for the
SOU remedies is estimated to be $84,000,000.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 10-15
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10.3.2 Groundwater Of!
™LSaeleHCtted remedy f°r the G°U PrOVideS En °Vera11 effectiveness proportionate to its costs. When
toTP of i7°re exf nsiveuremedies> the selected remedy (Limited Action) for all the GRUs was found
to be generally as effechve but definitely easier to implement. The major problem with using a Ze
aggressive remedy ,s that it would require pumping the groundwater out of the glacier drift aqutffr wWch
has a very low groundwater yield. The overall net present worth cost of coital and operational and
maintenance cost for theGOU remedy is estimated to be $4,530,000. operational and
Extent^PracticahlP Kppmrv ethnologies) fp_J]ie_
rr, USEPA> 3nd the IEPA have dete"n^d that the selected final and interim remedies
[nPa S TaXlmUm CX?nt 1° WWch Pennanent sol*ions and treatment technologies cTr TblSzed
ma cost-effective manner for the JOAAP soil and groundwater OUs. The Army the USEPA and the
3n the -vrent aid co
ARARs. In addition, the Army, the USEPA, and the IEPA have determined that these selected
%Pr?f±c^f 1 1" °f *ade0{& b£tWeen the five balancin* criteria whScS
statutory preference for treatment as a principal element and State and community acceptance.
10.4.L1 SRU1: Explosives in SoU
The selected final and interim remedies, Bioremediation, provide the best balance among the five
fn erim aVnedS ^ ^^ *** eVaIUati°n ^^ BaSed °n available -formation, Th" dec ed
RAO? Of fhe dTt C Pemianent S°IUti0nS t0 the maXimum extent Practicable, and satisfy the
RAOs. Of the five statutory catena met, reduction in toxicity, mobility, and volume and long-term
effectiveness and permanence were the most critical in the selection process. g
T InCTati°n beCHUSe h fS 1CSS CXpensive and 'numeration may face
exar r A,eP, • InCmeration m^ also ™W™ 8«nting a waiver because of
reCoZ, H ?f , l?°USh m°re exPensive than Excavation and Disposal, Bioremediation is
recommended because it will treat the soils at JOAAP that pose the majority of the rsk to human health
disposal enVir°nment- ^ Wil1 also sati^ the «««ta«y Preference of CERCLA for treatoent over
10.4.1.2 SRU2: Metals in Soil
fo^SafteCr^-vnal anf iTl?im remCC!!eS' Excavation and DisP°<*l, P^ide the best balance among the
four alternatives evaluated against the nine evaluation criteria. Based on available information he
"
w,"?™1 ^ mu°XiCity' m°bi!ity' 3nd V°lume' and ^-effectiveness
were the most critical m the selection process. By choosing Excavation and Disposal, this alternative will
be less costly and when compared to the Solidification/Stabilization, will reduce the volume TirTteria
in SRU6.
ntn mav « * °n-se '" caps n SRU6.
is option may allow the soil to be used as fill for on-site landfill caps that would not increase project
not use up a
JOAAP Record of Decision-Soil & Groundwater OUs - October, 1998
pg. 10-16
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10.4.1.3 SRU3: Explosives and Metals in Soil
The selected final and interim remedies, Bioremediation and Disposal and Excavation and Disposal,
provide the best balance among the five alternatives evaluated against the nine evaluation criteria. Based
on available information, the selected remedies utilize permanent solutions to the maximum extent
practicable, and satisfy the RAOs. Two alternatives were selected for this SRU because sites M5 and M6
might contain soil that exhibit hazardous characteristics (i.e., explosives concentration > 100,000 ppm) or
contain RCRA-listed wastes, and therefore these soils will require treatment for explosives prior to
disposal in a landfill. Since soils from both of these alternatives may be disposed in a landfill, just
excavating and disposing of non-hazardous soils will be less costly and will represent a smaller volume of
material to be placed in the landfill than treating soil. The selection of these two alternatives was
recommended over Incineration because this approach is less expensive and Incineration may face
difficulty in gaining public acceptance. Incineration may also require granting of a waiver because of
existing air regulations.
10.4.1.4 SRU4: PCBs in Soil
The selected final remedy, Excavation/Incineration and Disposal, provides the best balance among the
five alternatives evaluated against the nine evaluation criteria. Based on available information, the
selected remedy utilizes permanent solutions to the maximum extent practicable, and satisfies the RAOs.
Of the five statutory criteria met, implementability and cost-effectiveness were the most critical in the
selection process. The threshold criteria could be met by the recommended alternative, by Chemical
Dehalogenation and by On-site Low-temperature Thermal Desorption (LTTD). Each would reduce the
risk of direct contact with the PCBs in the soil and debris. However, the implementability, short-term
effectiveness, and State acceptability of Excavation and Disposal make it more attractive than Chemical
Dehalogenation and LTTD.
10.4.1.5 SRU5: Organics in Soil
The selected final and interim remedies, Excavation and Disposal, provide the best balance among the six
alternatives evaluated against the nine evaluation criteria. Based on available information, the selected
final and interim remedies utilize permanent solutions to the maximum extent practicable, and satisfy the
RAOs. Of the five statutory criteria met, implementability and cost-effectiveness were the most critical in
the selection process. The threshold criteria could be met by this alternative and by Bioremediation,
Solvent Extraction, and On-site Low-temperature Thermal Desorption. Each would reduce the risk of
direct contact with the organic compounds in the soil and debris. However, Excavation and Disposal is
easier to implement, can be implemented in a quicker time frame, and has a lower cost.
10.4.1.6 SRU6: Landfills
The selected final remedies, Capping and Excavation and Disposal, provide the best balance among the
four alternatives evaluated against the nine evaluation criteria. Based on available information, the
selected final remedies utilize permanent solutions to the maximum extent practicable, and satisfy the
RAOs. Of the five statutory criteria met, reduction in toxicity, mobility, and volume, and long-term
effectiveness and permanence were the most critical in the selection process.
The U.S. Army determined that Capping of the landfills in L3, Mil and M13 and Excavation and
Disposal of soils in L4, Ml and M9 would best serve the cleanup requirements of the sites in SRU6.
These recommended alternatives would be expensive, however, they would reduce the risks of direct
contact with human and the environment. Because the potential presence of UXO poses workers safety
issues, Capping rather than Excavation and Disposal was selected for L3.
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 10-17
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10.4.1.7 SRU7:Sulfur
The selected final remedy, Removal and Recycle or Disposal, provides the best balance among the three
alternatives evaluated against the nine evaluation criteria. Based on available information, the selected
remedy utilizes permanent solutions to the maximum extent practicable, protects human health and the
environment, and satisfies the RAOs. Of the five statutory criteria met, reduction in toxicity, mobility,
and volume, and long-term effectiveness and permanence were the most critical in the selection process!
This selected remedy may provide an innovative and beneficial resource recovery of the sulfur and would
not increase project costs.
10.4.2 Groundwater OU
10.4.2.1 GRU1: Explosives in Groundwater
The selected final remedy, Limited Action, provides the best balance among the three alternatives
evaluated against the nine evaluation criteria. Based on available information, the selected remedy
utilizes permanent solutions to the maximum extent practicable, protects human health and the
environment, and satisfies the RAOs. Of the five statutory criteria met, long-term effectiveness and
permanence, implementability, and cost-effectiveness were the most critical in the selection process. This
remedy relies on the treatment or removal of contaminated soil that is the primary source for continuing
groundwater contamination.
10.4.2.2 GRU2: Explosives and Other Contaminants in Groundwater
The selected final remedy, Limited Action, provides the best balance among the five alternatives
evaluated against the nine evaluation criteria. Based on available information, the selected remedy
utilizes permanent solutions to the maximum extent practicable, protects human health and the
environment, and satisfies the RAOs. Of the five statutory criteria met, implementability and cost-
effectiveness were the most critical in the selection process. This remedy relies on the treatment or
removal of contaminated soil that is the primary source for continuing groundwater contamination.
10.4.2.3 GRU3: Volatile Organic Compounds in Groundwater
The selected final remedy, Limited Action, provides the best balance among the six alternatives evaluated
against the nine evaluation criteria. Based on available information, the selected remedy utilizes
permanent solutions to the maximum extent practicable, protects human health and the environment, and
satisfies the RAOs. Of the five statutory criteria met, implementability and cost-effectiveness were the
most critical in the selection process. This remedy relies on the treatment or removal of contaminated soil
that is the primary source of continuing groundwater contamination.
10.5 Preference for Treatment as a Principal Element
70.5.7 Soil OU
The selected final and interim remedies meet the NCP's expectations to treat principal threat wastes and
contain low level threats. Investigations conducted at the site yielded an estimated lotal of approximately
912,000 cubic yards of soil contaminated above the remediation goals requiring cleanup. The
contaminants found at the highest concentrations at JOAAP, or the principal threat wastes, are explosives
in soil. Treatment (bioremediation) is selected for SRUI and SRU3, which represents approximately
185,000 cubic yards of explosives contaminated soil. Containment alternatives (excavation and on-site or
off-site disposal) were selected for approximately 718,000 cubic yards of contaminated soil which do not
pose a principal threat. The final and interim remedies selected for the Soil OU represents a good balance
between containment and treatment.
JOAAP Record of Decision - Soil & Groundwater OVs - October, 1998 pgf jo-18
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10.5.2 Groundwater OU
The preference for active treatment of groundwater as a principal element in the selected final remedy is
not generally met. Some treatment due to natural attenuation processes will occur within the three GRUs.
In addition, removal and treatment or disposal, of the contaminated soil will eliminate or reduce a major
source of groundwater contamination. Therefore, if groundwater is only considered, then the preference
for treatment as a principal element is not met. However, when considering that part of the groundwater
remedy is soil treatment then the preference for active treatment as a principal element of the selected
remedy for the JOAAP area is met. It should also be noted that active treatment of groundwater might not
be extremely implementable. Any active treatment of the groundwater OU will require the withdrawal of
groundwater from or the injection of nutrient into the glacier drift aquifer, which has a very low
groundwater injection/withdrawal yield. The low permeability of the glacial drift aquifer will make
nutrient injection or water pumping difficult and limit the effectiveness of the active treatment.
Currently, there are no human or ecological receptors of the groundwater. These aquifers are not being
used. The deed restrictions and the establishment of GMZs will ensure that no pathway, contact or
exposure routes will be created.
[END OF SECTION]
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 pg. 10-19
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11 DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plans for the Soil and Groundwaier OUs at the JOAAP were issued for public comment on
December 12, 1997. The soil Proposed Plan identified preferred alternatives for each of seven SRUs as
well as 29 No Further Action sites with respect to soil at the JOAAP. The groundwater Proposed Plan
identified preferred alternatives for three GRUs as well as 42 No Further Action sites with respect to
groundwater at the JOAAP. A public meeting on both Proposed Plans was held on January 8, 1998. The
public comment period ended on January 15, 1998. Forty-two sets of written comments were received as
well as 28 formal oral comments.
As a result of comments received from USDA during finalization of the ROD regarding the
protectiveness of the remedies, the Army, USEPA and IEPA have determined the actions proposed for
SRUs 1, 2, 3 and 5 on USDA lands will be interim actions. All other actions are considered final actions.
Upon review of the comments, it was determined that no other significant changes to the remedies, as
originally identified in both Proposed Plans, were necessary.
11.1 Documentation of Other Changes
There are some minor differences in the information presented in the Feasibility Studies, and the
Proposed Plans, on which this Record of Decision is based. These differences resulted from new
information and from corrections of calculation errors discovered in the cost tables. These differences are
summarized as follows:
• An additional GMZ surrounding Site M3 has been established as shown in Figure 4. This GMZ
was added because benzene, detected in monitoring well MW233 in 1991, meets Class II
standards but does not meet Class I standards.
• Following publication of the Proposed Plan, the Army, USEPA and IEPA determined that the
contingency action for each GRU need not necessarily be pump and treat of the contaminated
groundwater. Rather, if and when the need for a contingency action is identified, the Army will
evaluate and recommend remedial action(s) that must then be approved by the USEPA and IEPA
in accordance with the NCP.
• The cost of the Excavation and Disposal remedy for SRU3 has been recalculated because of an
arithmetic error. It is estimated to be $2,800,000. As a result of this change, the estimated total
cost of SRU3 increased from $4,400,000 to $6,800,000.
• The Army will evaluate the risk to prairie workers from exposure to soil contamination at
JOAAP. See Section 6.1.2 for details.
• A site-specific JOAAP Biological Technical Assistance Group (BTAG) will be formed to
establish exposure levels for ecological resources. See Section 6.2.2 for details.
• IEPA has sent the following clarifications on several issues related to RCRA hazardous wastes:
"If a media contaminated with a listed or characteristic hazardous waste is treated to the
remediation goals specified in the ROD for the facility, the LDRs specified in 35 IAC
728, and no longer exhibits any characteristic of a hazardous waste, the media would not
contain a RCRA listed or characteristic hazardous waste. However, unless the treatment
method actually destroyed or removed the contaminants of concern from the media, the
treated media might still be considered a special waste and, therefore, subject to the
special waste regulations at 35 IAC 808 through 815.
Since the treated residues of K047, which exist in the North and South red water ash
landfills [Sites Ml and M9] at JOAAP, no longer exhibit the characteristic of reactivity, "
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 11-1
-------
they are not hazardous wastes under the regulation at 35 IAC 721.103(a)(2)(C) " [letter
from C. Grigalauski, IEPA, to A. Holz, JOAAP, dated July 24, 1998}
Due to this clarification, delisting of the redwater ash prior to disposal, as presented in the
Proposed Plan, is no longer necessary.
[END OF SECTION]
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
pg. 11-2
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JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. J2-1
-------
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Will County. Illinois.
U.S. Army Environmental Center (USAEC, formerly the Toxic and Hazardous Materials Agency
(USATHAMA), 1978. Installation Assessment of Joliet Armv Ammunition Plant Office of the Project
Manager for Chemical Demilitarization and Installation Restoration; record Evaluation Report No. 128,
Aberdeen Proving Ground, Maryland, September, 1978.
U.S. Army Environmental Hygiene Agency (AEHA), 1990. Storm Water Outfall Evaluations. Joliet
Armv Ammunition Plant. Joliet. Illinois, Wastewater Management Consultation No. 32-24-0029-90.
U.S. Army, U.S. Environmental Protection Agency (USEPA), and Illinois EPA (IEPA), 1989. Federal
Facility Agreement for Joliet Armv Ammunition Plant. F.lwood. Illinois.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. 12-2
-------
U.S. Army Center for Health Promotion and Preventive Medicine (USACHPPM formerly U S Army
Environmental Hygiene Agency, AEHA), 1994. Final Ecological Risk Assessment. Joli'et' Army
Ammunition Plant. Volume. 1 Phay» ] November 1, 1994! "
USCHPPM (formerly AEHA), 1994. Health Risk Assessment for Consumption of Deer
Liver from .Tohet Armv Ammunition Plant. Jn1ietr
USCHPPM, 1996. Final. Phase 2 Aquatic F.™l0?ica] Risk Assessment No, 32-EE-14?n.Q3. Joliet A
Ammunition Plant. Joliet. Illinois. 14-17 June
U.S. Army Corps of Engineers (USAGE), 1989. Joliet AAP. Joliet. Illinois: Tnve.stigaiinn anH F.va1,.at.-»n
Ot Underground Storage Tanks, prepared for USAGE, Huntsville, Alabama by USAGE, Omaha
Nebraska, September, 1989.
USEPA, December 1991, Risk Assessment Guidance for Superfimd Volume T. Publication 9285 701B
December 1 99 1 and Volume U, EPA/540/1-89/00 1 .
89/wi^ Mar°h 1989' RJSk Assgssmgnt Guidance for Sunerfiind Vnliim« TT Publication EPA/540/1-
USEPA, July 1989, Guidance on Preparing Snnerfund Decision Documents: The Propnsed Plan. The
Record of Decision. Explanation of Significant Differences. The Record of Decision Amendment
Publication EPA/540/G-89/007.
[END OF SECTION]
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg, 22-3
-------
-------
COMMUNITY PARTICIPATION RESPONSIVENESS SUMMARY
Joliet Army Ammunition Plant
Record of Decision
RS 0 Overview
The Proposed Plan for the Soils Operable Unit and the Proposed Plan for the Groundwater Operable
Unit were released on December 12, 1997. Copies of the Proposed Plans were mailed to those persons
who had expressed an interest. Copies were also made available at the information repositories (at
JOAAP, the Wilmington Public Library and the Joliet Public Library).
In accordance with Section 117, of the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) of 1980, 42 U.S.C. Section 9617, the U.S. Army held a public comment period
from December 12,1997 to January 15,1998, a period of thirty-four days. A public meeting was held on
January 8, 1998 at the Wilmington City Council Chamber. Over one hundred persons attended the
meeting. At that meeting, the U.S. Army presented the Proposed Plans and responded to questions from
the floor. In addition, and in a separate room, formal oral comments were recorded for inclusion in the
docket.
Notifications were placed in the two primary local newspapers concerning the Proposed Plans, public
comment period and the public meeting.
The Restoration Advisory Board was briefed on the Proposed Plans on December 9, 1997, met again for
discussion on the issues on January 7, 1998, and met a third time on January 22, 1998 to further discuss
and to vote on the proposals. Per prior arrangement, the Army agreed to receive comments from the
RAB following their meeting on January 22, 1998.
The purpose of this Responsiveness Summary is to document the Army's responses to comments
received during the public comment period. These comments were considered prior to selection of the
final remedy for soil and groundwater contamination at the Joliet Army Ammunition Plant. The remedy
is documented in The U.S. Army's Record of Decision, with concurrence from Illinois EPA (IEPA) and
USEPA.
Seventy-one sets of comments were received: 42 were written, 29 were recorded and transcribed oral
statements. A total of 217 issues were raised by the 71 commenters. The comments were evaluated and
subdivided by subject matter into the following six major groups and 26 subgroups.
1. Objectives (13/217 = 6%) Dependency on WCLF
Protect Human Health and the Environment Natural Attenuation
Remediation Goals Issue Clarification
Protection of the Prairie and the VA Cemetery
3. Operational Issues (12/217 = 6%)
2. Remediation Technology (48/217= 22%) RCRA Wastes
General Support Deed Restrictions
Remedial Alternative Contingency Plans Stormwater Runoff
Preference to Excavate and Dispose
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. RS - 1
-------
4. Monitoring (11/217 = 5%)
Groundwater Monitoring
Monitoring: LTM
Monitoring: Biomonitoring
5. Implementation (107/217 = 49%)
Expedite Implementation
Use Local Labor
Use Union Labor
Emphasize Industrial Park
Improve Tax Base
Schedule
6. Other Issues (26/217 = 12%)
Removal of UXOs
Sulfur Cleanup
Presentation: Nature and Extent
Groundwater Plumes
Various Other Comments
Comments and Responses Summarized bv
The categorization and cross-referencing of comments from the seventy-one (71) commenters is
summarized in Table RS-1. The comments are discussed and responded to according to these groupings
within Sections RS 1 through RS 7 of this Responsiveness Summary. In cases where single comments
were made regarding an issue the comment or portions of it are directly quoted. In cases where multiple
comments were made by different commenters, a representative summary of the comment is given.
Citations for individual commenters are shown in brackets at the end of a specific comment or issue
statement. The citations are in the form [mm.xxj, where "mm" identifies the commenter and "xx"
identifies the paragraph in which the comment was made.
fiSJLJ Background on Community Involvement
The high interest in implementation issues (49 %) focused on three primary concerns: remediate the site
quickly; use local or union labor in performing remedial actions; and improvement of the tax base.
These comments are important to the local citizens and labor pool. The Army has heard these concerns,
is sensitive to them and will address them within remedial action implementation. These concerns do not
have an impact on the choice of remedial alternatives - only on the implementation.
Six of the commenters who requested expedited action or use of local labor also requested that
excavation and disposal be used instead of bioremediation. [3.3, 11.3, 32.2, 47.8, 52.5, 53.1 and 53.3]
There appears to be two underlying reasons for this request. First is the belief that more money would
come into the local economy with excavation and disposal than with bioremediation activities. Second is
the belief that excavation and disposal would be completed sooner and thus allow an earlier transfer of
the JOAAP property to the industrial parks (and its other designated uses) and creation of jobs for the
local economy. It is the Army's position that while these are important objectives, they do not outweigh
the primary objectives of the remedial actions at JOAAP - protection of human health and the
environment - and, thus, these are insufficient reason for changing the choice of remedial alternatives.
Incidentally, neither of the underlying beliefs by those recommending excavation and disposal over
bioremediation is necessarily true. Because soil is moved at least twice in centralized bioremediation,
there is more labor involved in this alternative than in the excavation and disposal. Furthermore, because
of the probable two or more year lead time to open WCLF, bioremediation may be able to begin earlier
and to finish at nearly the same time as excavation and disposal.
A private contractor presented an unsolicited proposal, within the comments [34], to excavate,
stabilize/solidify and dispose explosives-contaminated soils. The Army can not accept this proposal
outside of normal Federal Acquisition Regulations. However it should be noted that in its Feasibility
Studies, the Army did evaluate options similar to those proposed. On the basis of those Feasibility"
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
pg.RS-2
-------
Studies, bioremediation was selected as a proven technology for degrading explosives contamination
within soils. In so doing, bioremediation will protect human health and the environment and will comply
with the statutory preference for treatment to permanently reduce toxicity, mobility and volume. The
commenter's proposal therefore was considered, but did not warrant a change in the Army's planned
approach. Fifteen (15) commenters stated general approval of the selected remedies. [1.1 and 1.2, 2.1,
5.1, 6.1 and 6.2, 7.1, 8.1 and 8.6, 14.1, 15.1, 26.2, 35.1, 38.2-38.6, 39.2,40.1.1,42.2, and 49.1]
Thirteen commenters requested (i) consideration of remediation goals that were more protective of the
environment, [4.3-4.7, 34.5, 71.5] (ii) that a biomonitoring program be incorporated into the remedial
actions, [7.4] and/or (iii) that the Army provide more information about the impact of natural attenuation
on soils and groundwater containing contamination below the accepted RGs. [7.2, 8.2, 22.2, 23&24.G1,
24.4, 34.4, 40.2, 41.1, 71.1] The Army believes that the final RGs established for protection of human
health are also adequately protective of the environment. Studies conducted at JOAAP have
demonstrated a healthy ecosystem even with contaminated "hot spots" in place. A site-specific JOAAP
Biological Technical Assistance Group (BTAG) will be formed to establish exposure levels for
ecological resources that are protective of the environment and compatible with development of the
tallgrass prairie. The Army, USEPA and IEPA will consider the advise of the BTAG as they evaluate the
need for a biomonitoring plan and for further study of natural attenuation.
Other comments concerned issues that modify specific aspects of the recommended remedial actions,
procedures followed by the Army in developing the planned approach, or the presentation of the
information within the ROD.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg.RS-3
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JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
pg.RS-4
-------
[SJYENESS SUMMARY: Propped Plan Tnmmpnt Cross %fmn™f pc , n(
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JOAAP Record of Decision Soil & Groundwater O Us - October, J 998
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RS 1 Objectives
Eleven commenters expressed concern with the objectives of the proposed remedial actions related to the
following three categories: (1) the protection of human health and the environment, (2) the choice of
remediation goals (RGs), and (3) the protection of the land for the designated users (Midewin Tallgrass
Prairie and VA Cemetery).
B&JLJ—Protect Human Health and the Environment:
Two commenters commented on this topic. [17.2, and 34.1] One commenter noted, "While this site must
be cleaned up before the developers are allowed to proceed with their proposed intermodal transport
facility, the Army has the responsibility of insuring the safety of disposal methods and environmental
impact regarding both air and water quality." [17.2]
Response: The Army has evaluated remedies and costs and intends to cleanup JOAAP in a manner that
is safe, environmentally protective and cost effective prior to property transfer. The Army has the
responsibility to restore the lands of JOAAP to conditions that are protective of human health and the
environment. Public Law 104-106 precludes transfer of contaminated sites to future users.
RS 1.2 Concern Over Selection of Remediation Coal^;
There are seven comments related to concerns over selection of remediation goals [4.3-4 7 74 10 1
24.2,34.1-34.2.1, and 34.5,41.1, 71.5, 71.7, and 71.8] The concerns of these commenters follow: '
*• Jonn RogTKr; Acting Field Supervisor: United States Department of the Interior; Fish And Wildlife
Service; stated:
"We do not believe that these PRGs for soil, sediment, and groundwater, which are based only on
human health studies, are protective of the environment. More specifically, we do not believe that
the PRGs are protective of the ecological assessment endpoints listed in the February 6, 1996,
Department of the Army Memorandum, "Summary of the Ecological Risk Assessment Program at
Joliet Army Ammunition Plant, Illinois." In general, the human health based PRGs greatly exceed
toxicity reference values for soil, sediment, and water. These reference values are from site-specific
toxicity tests performed at JOAAP and from other studies. The table below compares several of the
PRGs with toxicity reference values. The contaminants selected for this table are for example
purposes and are not the only contaminants that exceed toxicity reference values.
Contaminant PRO Reference Value
2,4,6-TNT 290 mg/kg 7-19 mg/kg (lowest observed effects concentration
(LOEC) plant, earthworm, bacterium)
40-150 mg/kg (LOEC earthworms)
5 mg/L (LOEC plant)
30 mg/kg (LOEC plant)
Tetryl 7,400 mg/kg 25 mg/kg (LOEC plant)
Lead 1,000 mg/kg 250 mg/kg (severe effect level (SEL) sediment
invertebrates)
185 mg/kg (upland sandpiper)
Zinc i,000,000 mg/kg 820 mg/kg (SEL sediment invertebrates)
105 mg/kg (upland sandpipers)
Anthracene 10,000 mg/kg 370 mg/kg (SEL sediment invertebrates)
7 mg/kg (upland sandpiper) [4.3]
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. us -10
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"It is readily apparent from this comparison that human health based PRGs cannot be relied upon-to
be protective of the environment. These PRGs, therefore, are not appropriate as remediation goals or
for screening sites for no further action. [4.4]
"We suggest that remediation goals be adopted which are protective of the assessment endpoints
listed in the February 6, 1996, Department of the Army Memorandum: "Summary of the Ecological
Risk Assessment Program at Joliet Army Ammunition Plant, Illinois." [4.5]
"When environmental PRGs are calculated we suggest that they be submitted to the USEPA Region
V Biological Technical Assistance Group (BTAG) for independent review. [4.6]
"The future use of this site for wildlife management makes it imperative that contaminants be
remediated to levels which do not cause ecological harm by limiting the productivity of this area. If
ecologically based PRGs are not calculated then background levels should be used as PRGs." [4.7]
Response: In 1996, the Army, working in close coordination with USEPA and IEPA, determined that
human health-based PRGs would be acceptable surrogates for ecological PRGs. This determination is
documented in detail in Appendix D of the JOAAP Preliminary Remediation Goals Final Report (April
1996). This position was supported, conditionally, by USEPA and IEPA in their letter of March J, 1996
pending the development of scientifically rigorous information.
In developing the PRGs, the Army. USEPA and IEPA considered the environmental and ecological
impacts at JOAAP. To determine the ecological impacts the Army performed a series of field
investigations in order to determine actual effects on the flora and fauna of JOAAP. On the basis of
those studies, the following conclusions were made:
• The Joliet ecological system, as a whole, is outstanding, even with contamination remaining on-
site. This is documented with the Survey of the Endangered and Threatonc-d Plant and Animal
Species of the JOAAP and Joliet Training Area. Will C.nuntv and with plant uptake studies as
documented in Appendix D of the JOAAP PRGs Final Report, April 1996.
• Studies were conducted to determine and quantify the extent that explosives contamination in
soils adversely affect the health of the plant and soil organisms (as determined by biomass). In
these cross-correlation studies of contaminant levels and biomass, only TNT was found to have a
statistically significant correlation. Even in that case, however, the differences in biomass found
between the Low Effect Level (90 mg/kg) and the Potential Cleanup Goal (190 and 290 mg/kg)
are statistically indeterminate. The major impact on biomass is found in moving from the high
concentration of TNT (> 1,000 mg/kg) to PRG range.
• As documented in Section 5 of the February 6, 1996 memorandum, soil organisms (earthworms,
microbes and plant communities) are the only sector of the ecosystem that show any impact.
That impact is highly localized, considered de minimis by the Army, and expected to be
addressed with remediation to the proposed levels. As USEPA, Region V noted, "although
precise numbers are not available, it is evident that human health based /remedial goals] for
TNT and its degradation products are well below levels that inhibit plant growth and therefore
are [indirectly] protective of ecological receptors. " (USEPA, Region V, Letter of 12/7/95)
JOAAP Record of Decision Soil & GroundwaterOUs - October, 1998 pg.RS-11
-------
The areas where contamination is the heaviest. Manufacturing Area sites MS, M6. will be transferred to
the State of Illinois for use as an industrial park. The Army, USEPA and IEPA concur that it is not
necessary or advisable to clean up to ecologically-based RGs for the areas that will be used for
industrial parks or for the Will County Landfill.
Based on comments received from various organizations and individuals during the public comment
period and the development of the ROD, the Army. USEPA and IEPA have agreed to select actions
proposed for SRUs 1, 2, 3 and J for USDA soils as interim actions. Exposure levels for ecological
receptors will be determined that are protective of the environment and compatible with the development
of the tallgrass prairie for USDA lands. A site-specific Biological Technical Assistance Group (BTAG)
will be established and will advise the Army, USEPA and IEPA on this subject. Final cleanup actions
will be selected in accordance with the NCP.
2. Charles Grigalauski, IEPA, commented: "Please refer to the March 1, 1996 letter from the U. S.
EPA and me on the subject of preliminary remediation goals (PRGs). The position of the Agency
has not changed on this matter. I support the January 13, 1998 U.S. EPA comment # 2 regarding a
biomonitoring program including efforts by the Illinois Department of Natural Resources and the
U.S. Forest Service." [7.4]
Response: The referenced letter stated,
"We accept the use of human health based risks as a surrogate for ecological risk-based standards
with the following provisions:
That, between now and the signing of the Record of Decision,
1. No data becomes available that would permit the development of scientifically rigorous
ecological cleanup levels for TNT, tetryl or RDX.
2. The on-going research at the Waterways Experimental Station, Argonne National Laboratory,
USEPA's Environmental Research Laboratory at Athens, GA., Georgia Tech., Rice University,
Louisiana State University, the University of Iowa and other research supported by the Army
continues to support the efficacy of phytoremediation and produces evidence that
phytoremediation by prairie grasses at levels below 290 mg/kg TNT occurs. " fpg. 2]
The Army, USEPA and IEPA have agreed that a biomonitoring program is not necessary at this time
since final actions for SRUs I. 2, 3, and 5 for USDA soils are not being selected at this time.
3. Rob WatSOn. RCRA/CERCLA Coordinator, TF.PAJ
"The document discusses the remedial action objectives in terms of risk to human health and the
environment. The RAOs must also indicate whether excavation of hazardous wastes (or soil which
exhibits a characteristic of a hazardous waste) is also a remediation goal. Because the PRO
concentrations are very high relative to the TCLP limits, the Agency is concerned that a remedial
action based solely on risk could leave behind soils which exhibit a characteristic of a hazardous
waste. This has a direct effect on the ARARs for the remedial action.
Specifically, if soil/waste which exhibit a characteristic of a hazardous waste, or is listed hazardous
waste, will be left at the site, after the remediation is complete, the RCRA closure and post-closure
requirements would be considered both relevant and appropriate and therefore ARARs.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. RS -12
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Therefore, in order to properly evaluate the remedial alternatives and verify compliance with
ARARs, the document must clearly indicate which of the following is a remedial objective:
"a. Wastes and contaminated media which exhibit a characteristic of a hazardous waste or is
listed hazardous waste, will be removed or treated to non-hazardous levels or
"b. Wastes and contaminated media which exhibit a characteristic of a hazardous waste or
are listed hazardous wastes will be left in place.
"Cadmium is a good example of the above concern. The risk based PRGs for cadmium are 3,000
mg/kg for an industrial scenario and 1,700 mg/kg for residential. However, the TCLP limit for
cadmium is 1.0 mg/1. The preferred remedy in SRU 2: Metals in Soils, is excavation of soils with
metal concentrations above the PRGs and off-site disposal. No institutional controls are identified as
part of this remedy. Therefore, cleaning up to the PRGs could easily leave behind soils which
exhibit a characteristic of a hazardous waste. If this occurred, the remedy would not comply with the
ARARs. Examples of two LAP sites where this may occur are the soils near the popping furnaces in
L2 and soils from the junkyard in L5.
"Conversely, if clean up to the PRGs will also remove soils that exhibit a characteristic of a
hazardous waste, or if studies have shown that the remedy will not leave hazardous waste behind,
this would be a positive addition to the description of the proposed remediation goals." [10.1]
Response: A remedial action objective has been included in the ROD that: "Actions will not leave
behind any RCRA characteristic wastes, except those contained within the capped landfills of
SRU6. " (see Section 6.3) To this end, the Army will conduct TCLP analyses on random confirmatory
samples in accordance with the remedial design to ensure that there are no characteristic wastes
remaining at each site. Specific listed wastes expected at each site are shown in the tables of Section 5
of this ROD. SRU2 characteristic wastes will be excavated and disposed at a RCRA Subtitle C landfill.
SRU1 and SRU3 soils containing characteristic or listed wastes will be tested after treatment to
determine if the characteristic for which they were listed is still exhibited. If so. these treated materials
will be excavated and disposed at a RCRA Subtitle C landfill off-site; if not, they will be disposed at
WCLF or used as backfill
4. Diana Mally of the USEPA requested that the Army define the performance objectives of the
groundwater remedies within the ROD. [24.2]
Response; The performance objectives for the selected groundwater remedial action (Limited Action)
are to:
(1) Achieve the groundwater cleanup to the RGs through source removal and natural
attenuation.
(2) Ensure that human and animal exposure to contaminated groundwater is restricted
or minimized while groundwater cleanup is occurring. [This will be done through the
establishment ofGMZs, deed restrictions, notifications to the future JO A AP landowners,
and other institutional controls.]
(3) In cases where human or animal exposure to contaminated groundwater may occur,
to ensure that appropriate steps are taken to minimize the risk to these receptors. [The Army
will monitor ground and surface at agreed compliance points to ensure that contam inated
water is not migrating outside of the GMZ. Landowners within the GMZ must comply with
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg.RS-13
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any and all applicable laws regarding the management, discharge, disposal, or treatment of
contaminated groundwater.J
5. Stephen K. Davis, Manager, Remediation Projects, Illinois Waste Management and Research Center
commented on:
• The presentation of information in the Proposed Plans concerning the determination of
ecological PRGs. [34.1]
• Whether Simini, et al study data was incorporated into the development of PRGs at JOAAP
[34.2]
• Whether PRGs for TNT (190 to 290 mg/kg) are protective of ecological receptors. [Mr. Davis
requested the Army provide additional justification in the Proposed Plan indicating how this
protection will be accomplished. [34.2.1]
• If ecological investigations have been conducted to determine that the proposed PRGs are
protective of avian receptors, it is suggested that this information be included in the proposed
plans. [34.5]
Respwse: As a general note, the Proposed Plan is intended to give general and summary information of
findings as a basis for presenting the recommended remedial actions. It is an explanatory document for
the general public and does not provide detailed scientific data and technical discussions. Those
discussions may be found in the documents held in the Administrative Record and Information
Repositories. In addition, unless significant changes in data or the selected remedy occur, the Proposed
Plan is not reissued for further review. The ROD and the Responsiveness Summary are the means by
which specific outstanding issues are addressed.
The final actions in this ROD which are related to land formerly used for manufacturing activities and
intended for future use as industrial parks are based on human-health final RGs and not for ecological
receptors (see Section 6.4)
The actions selected in this RODfor those areas to be managed for the protection and restoration of
ecological resources are interim actions, which will be followed by final actions providing overall
protection to human health and the environment.
6. The Restoration Advisory Board commented on the following:
"The Soils Operable Unit proposes to treat explosives contaminated soils to levels less than the
Preliminary Remedial Goals (PRGs) and rely on phytoremediation to further reduce concentrations
to levels that are protective of all biological receptors. No Observable Effect Levels of explosives in
soils have been observed to be lower than the PRGs for a number of species including earthworms.
The RAB believes that there is a great deal of evidence that phytoremediation will reduce explosives
contamination to less than 10 ppm which should protect all species but this has not been definitely
demonstrated. The RAB recommends that the Army establish a monitoring program to demonstrate
that this additional reduction is occurring. This program should be coordinated with the existing
environmental monitoring program being operated by the Illinois Department of Conservation and
the United States Forest Service." [41.1]
Response: The Army asserts that the No Observable Effect Level is not the appropriate goal for
environmental protection. The Army does agree that it would be advantageous to gain a better
understanding of whether natural attenuation or biodegradation continue to degrade the explosives left
on-site to levels below the RGs. Studies underway at the USEPA/Athens laboratory and the Army Corps
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. RS -14
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of Engineers' Waterways Experimental Station are expected to demonstrate the effectiveness of
degradation of residual explosives by natural attenuation. The Army is not proposing a soil monitoring
plan to demonstrate natural attenuation or phytoremediation at this time.
7. The USEPA National Remedy Review Board had the following 3 comments relative to remediation
goals:
• The Army should revise the PRGs for PCBs and lead to be consistent with USEPA guidance,
future land use, and the ecological risk assessment for the site. [71.5]
• USEPA risk assessment guidance states that if key toxicity data are not in USEPA's
Integrated Risk Information System (IRIS), Regions should consult the Health Effects
Assessment Summary Tables (HEAST). If this information is not in the HEAST or the
documents referenced in it, Regions should consult with USEPA's Superfund Health Risk
Assessment Technical Support Center in Cincinnati, OH. Since a reference dose for Tetryl
(trinitrophenylmethylnitramine) is in the HEAST and has been used by Regions and States at
other sites, the Army should clarify its rationale for selecting a more conservative Tetryl
reference dose for use at JAAP. [71.7]
• The Board is concerned that exposure assumptions used in the Army's maintenance worker
exposure scenario to calculate the PRGs for the manufacturing and load-assemble-package
areas may be too conservative, given the expected future land use (Midewin National
Tallgrass Prairie). [71.8]
Response:
• Tfie cleanup levels used for PCB spills in soils are based on USEPA 's criteria under the
Toxic Substances Control Act (TSCA; 40 CFR 761.120). An RG of I ppm will be used for all
surface soils (upper 10 inches of soil).
• For tetryl, a toxicity value was available from HEAST. However, there was concern among
the project managers that the HEAST value for tetryl was not well founded. This concern
was compounded by the fact that picric acid (2,4,6-trinitrophenol, a.k.a. TNP) and/or
picramic acid (2-amino-2,4-dinitrophenol; a.k.a. dinitroaminophenol: a.k.a. DNAP) are
degradation products of tetryl and the Army did not have analytical data from the site on the
concentrations of these two analytes. Therefore, USEPA's Superfund Technical Support
Center (STSC) provided provisional RfD's for these two acids. These RJD's were derived by
STSC using 2,4-dinitrophenol as a surrogate. The Army, USEPA and I EPA then decided
that the lower of the PRGs established for these acids should be used for tetryl. They
decided this decision because remediation of the parent compound (i.e.. tetryl) to a given
concentration would limit the daughter products (i.e., picric or picramic acid) to no greater
than that concentration as well.
• The exposure scenarios are differentiated for industrial park areas and tallgrass prairie
areas. The industrial worker scenario is used for the industrial park areas. Less
conservative park user scenarios are used for the tallgrass prairie areax.
,3 — Concerns Over Protection of the Midewin Tallgrass Prairie and
Veteran's Cemetery Parcel;
Three commenters requested that the Army take steps necessary to anticipate and provide environmental
safeguards to protect the Midewin National Tallgrass Prairie, the National Veteran's Cemetery, and the
environment from harm. [1.3, 5.3, and 6.3] Deed restrictions were cited as a specific environmental
safeguard that could be implemented.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. RS -15
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Response: The Army's responsibility in this action is to clean up contamination and to transfer the
Pr°Perty to the next landowners in a condition that is suitable for the intended future uses in accordance
with Public Law 104-106. Deed restrictions will be placed on groundwater use within the groundwater
^ra,na,8f,TntI^e and °H any excavatinS activities in the proposed capped landfills that are left in place
(L3. Mil and MlB). These deed restrictions are described in Section 9.2.1.2 and Appendix A The Army
is not responsible for restricting the use of the land by future landowners outside the stated deed
restrictions.
RS 2 Remediation Technology
Forty-eight comments from the 71 commenters addressed issues concerning the selection of remediation
technologies. The issues were divided into six groups as follows.
HS.2J—General Comments Supportive of the Selected Remedies?
Fifteen comments stated support for the proposed plans and the remedies recommended fl 1 1221
5.1, 5.2 6.1, 6.2, 7.1, 8.1, 8.6, 14.1, 15.1, 26.2, 35.1, 38.2-38.6, 39.2, 40.1.1, 42.2, and 49.1]' Examples
are as follows:
"The "Proposed Plan for the Soils Operable Unit" appears to be comprehensive and based on an
approach that seems reasonable and acceptable. As presented, the process that was used to evaluate
each of the remedial alternatives for the cleanup of each of the Soil Remedial Units (SRUS) appears
to be solidly based. It is my desire that the Army not deviate from this approach." [1.1]
"The recommended "proposed remedial alternative" that was chosen for each SRU (Soil Remedial
Unit) appears to be the best choice for remediation in each case. It is my desire that the Army will
proceed to cleanup the Joliet Arsenal using recommended-remedial alternatives as presented." [1.2]
Response: The Army has so noted.
HS.2.2—Remedial Alternative Contingency Plans:
f^e" c°mmenters C0mmented on this issue- t8-5' 12.1, 12.2, 13.2, 22.3, 23&24.G2, 23.3, 29.1, 38 6
40.2, 47.8, 50.2, 50.6, and 71.1] One commenter in two comments asked whether contingency plans
were considered for the groundwater alternatives (Limited Action) and for those SRUs using
bioremedmtion.[12.2, and 13.2] For groundwater remediation, the commenter noted:
"In each case Alternative 2: Limited Action is the proposed action. According to this recommended
action, there would be annual groundwater tests with a 5-year assessment until the PRGs are reached
It is also stated that if this Alternative (Natural attenuation) is proved ineffective the contingency
plan would be implemented, i.e., the Alternative(s) to Pump and Treat. How many years will it take
before it is determined to be an effective or ineffective treatment? According to the estimated
timeframes it may take 20 to 340 years to reach PRGs." [12.1]
For soils remediation, the commenter noted:
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
pg. RS . 16
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"We understand that bioremediation is a broad term encompassing several different methods of
treatment based on site-specific needs, however, if it is determined that this treatment method is
unsuccessful, based an expected timeframes and results, what contingency plan would be
implemented?" [13.2]
Diana Mally of the USEPA recommended that the Army provide a better discussion of the role of
phytoremediation in mitigating the residual levels of explosives contamination in soils. [23&24.G2]
Response: Groundwater: Contingency plans for the limited action alternative will be developed during
the remedial design. The key parameters of that plan will be specified within the framework of the ROD.
The likely timeframefor making a determination on the effectiveness of natural attenuation is 10 to 15
years.
Soils: Bioremediation has been proven effective in cleaning up explosives-contaminated soils at other
sites, including Umatilla Army Depot, where soil contamination levels and volumes were similar to those
faced at JOAAP. The Army is not relying solely on these other cases to ensure the effectiveness of
biroremediation. The Army is currently conducting a comparative analysis of several bioremediation
processes to assist in selecting the most cost-effective and performance-effective processes. Because
JOAAP soils will be used, in this study, the findings will be directly pertinent to this site. If these tests
show that none of the bioremediation alternatives will treat the explosives components of the soil
contamination to at or below the RGs, the Army will resort to the excavation and disposal alternative.
This alternative, while less costly than bioremediation, is less desirable because it does not meet the
statutory preference to permanently reduce toxicity, mobility or volume through treatment. When there
are fundamental changes proposed to the ROD (e.g.. from bioremediation to excavation and disposal),
the Army shall prepare a ROD amendment that is subject to the public participation and documentation
procedures (specified in CERCLA Section 117). and to review and approval by USEPA and IEPA.
RS2,3—Preference for Excavation and Disposal Alternative:
Seven commenters prefer to excavate and dispose contaminated soils rather than treatment by
bioremediation. [11.2, 29.3, 32.2, 33.8.1, 50.3, 52.5, and 62.3] This change would affect the soils in
SRUI and SRU3. Another commenter suggested that excavation and disposal should be used on Site L3
(SRU6) rather than leaving contaminated soil and UXO on-site.[43.3]
Response: The Army, in cooperation with the USEPA and IEPA, carefully considered the possibility of
excavation and disposal to address soil contamination in SRUI (explosives in soils) and SRU3
(explosives and metals in soils). Excavation and disposal would have been less expensive than
bioremediation. However, excavation and disposal would not provide permanent treatment of the soils,
whereas bioremediation would treat the explosives. In addition, Sites MS and M6 of SRU3 contain
RCRA hazardous wastes and could not be disposed without either treatment or delis ting.
The Army, USEPA and IEPA considered excavating and disposing the contaminated materials at Site L3,
as opposed to capping the site. However, the additional environmental protection that could be gained
from excavating and disposing this material was outweighed by the additional risk posed to the
remediation workers at the site. The Army, therefore, recommends this site be capped.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. RS -17
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ver Dependency on the
Landfill fWr-Tfy);
faftf! this issue< [13-lj and I8-M83] One commenter asked how dependent
is the success of those SRUs using excavation and disposal (SRUs 2, 3 4 5 6 and 7) on the
± llShmentfth\WCLF fr°m thC Standp°int * tin*; and costs. [13.1]' i' 'second clmenfe
Coun* Landfin and suggested that
°"^ fl" /0r ^^ *»«"***»" JOAAP. as legislated in PL
^ diS°Sal landjllls- Since "'<-' A™y »M not be
t WCLF is the cost of transportation/trucking. If,
aa n , ~ h0teVer rm ~ **™>** I"*™* delations
are available off-site. The change to an alternative landfill will increase the costs to tie government but
mil not make the plan technically infeasible nor Will require a change the selected remedies
RS 2,5 Concerns Over Natural
u 1 attenuation ««l Phytoremediation. [7.2, 8.2, 22.2,
, 24.3-24.5, 34.4, 40.2, 41.1, and 71.1] The issues raised were:
1. That phreatic trees be used to enhance the natural attenuation of explosives in groundwater One of
Hiecornmenter recommended a fuller discussion of phytoremediation in the ROD.[22.2, 24.5, 34.4,
2. That phytoremediation will further degrade residual explosives left in soils once RGs are met To
confirm this anticipated effect, a biomonitoring program was encouraged [411]
A °f M°nit0red Natural Attenuation at
10n 3nd Vnde^ound Stora8e Tank Sites (OSWER Directive
.n S,peCifin *6 R°D the Criteria' or fri^ers' that ^ «gnal unacceptable
belvT, th S f remedlCS 3nd indiCatC Wh£n t0 ^Pl^ent contingency measures. EPA
believes the friggers of unacceptable remedy performance include migration of the groundwater
plumes beyond the boundaries of the established Groundwater Management Zones- (GMZs) and
discharge of groundwater to surface water such that the water quality criteria for the faci ity prepared
by the Illinois EPA in April 1997 would be exceeded." [24.3]
Response'
1. An investigation of phytoremediation at JOAAP is being conducted by the VSEPA - Athens The
tnL PS °f EnZ™ers/Wate™*ys Experimental Station is also studying natural attenuation of
7e ZSr5T ^ ^ JOAAP- ™e ^^ °ftheSe ^sti^ons Will be used to determine
1 L{^1 ^ °f in\plementatlon P^toremediation to enhance the biodegradation (natural
attenuation) of groundwater contaminants under conditions found at JOAAP.
The Army USEPA and IEPA will consider the value of implementing a biomonitoring plan when
proposing final actions for those portions of the installation to be managed as a tallgrass prairie
The requirements of the USEPA Interim Final Rule on Use of Monitored Natural Attenuation have
been reviewed and incorporated into the ROD.
Contingency plans covering unacceptable performance of the limited action alternatives, have been
incorporated into the ROD as requested. See Section 9.2.1. 6 for further detail.
3.
4.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998
pg.RS-18
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RS2t6—Concern Regarding Issue Clarification!
Four commenters requested more information on the remedial action technology selection [22 1
23&24.G3, 23.5, and 23.6,43.4, and 71.6]
1. "Considering that the contaminated percentages of soils and groundwater are about the same, why
isn't the cleanup effort for the groundwater more extensive?" [22.1 ]
2. USEPA requested that more detail be provided on the remedy selection within the ROD [23&24.G3]
3. One commenter recommended that the Army consider containment rather than treatment of that
contamination that did not pose a principal threat. [23.5]
4. One commenter noted that the text should clarify whether solidification/stabilization would be used
in cases where soils fail TCLP even after treatment. [23.6]
5. One commenter was concerned over the potential for the excavation of soils to expose less fertile
subsoils or to create a wetland. [43.4]
6. The USEPA National Remedy Review Board requested that the Army explain its rationale for
addressing subsurface soils. [71.6]
Response:
1. The soil cleanup costs will be much greater because a more active cleanup is proposed for the soils.
The more extensive cleanup effort for soil is justified by the greater probability of exposure to
contaminated soil than contaminated groundwater at the JOAAP. There are currently no human or
ecological receptors of the contaminated groundwater at JOAAP - there is no pathway for exposure
and no contact. The institutional controls (particularly the deed restrictions and GMZs) are
intended to ensure that no pathway will be created.
2. More detail on the selection criteria, including the tables depicting the relative merit of each
alternative by the nine CERCLA criteria, have been added to Section 9.
3. Explosives-contaminated soils constitute the principal threat for SRU1 and SRU3. where treatment is
selected over containment options. The Army, in consultation with the Remedial Project Managers
from USEPA and IEPA, decided treatment would be preferable in those cases because it provided
permanent reduction of toxicity and thus removed a potential long-term liability. Containment
options (excavation and on-site or off-site disposal landfills) were selected for those soils that
represent low level threat wastes.
4. Solidification/stabilization may be used to treat those soils that fail TCLP prior to disposal in WCLF.
The commenter is correct that solidification/stabilization would not be necessary for disposal of soils
in a RCRA Subtitle Cfacility. The determination of which facility to use (WCLF or a RCRA Subtitle
C landfill) will be made during the remedial design and remedial action phases.
5. SRUl and SRU3 soils that come out of biotreatmenl and that can be used as cover or fill, will
probably be used as such. The remedial design phase of action is where site restoration will be
specified to ensure that the area is properly revegetated and no new unintended wetlands are
produced.
6. No differentiation of RGs by depth was agreed upon by the Army, USEPA and IEPA. It was
recognized that potential exposure will be reduced as depth increases. However, it was also noted
both (a) that contaminated subsurface soils could be a continuing source of groundwater
contamination, and (b) that disruption of soils and ground surface levels during remedial action may
bring contaminated soils to the surface at JOAAP. For these reasons, the conservative approach of
not reducing RGs with depth was accepted by the Army, USEPA and IEPA.
JOAAP Record of Decision Soil & Groundwater OVs - October, 1998 pg. RS - 19
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RS 3 Operational
Twelve comments from the 71 commenters addressed issues relating to operation of the remedial
actions. These comments were grouped as follows:
BS.2J _ Concerns Over RCR/V Wastes:
Three commenters raised issues related to the handling of RCRA wastes. [7.3, 10 1 and 23 1] Since
Bioremediation is the Proposed Alternative for several of the SRUs, the Army must determine if the
treatment residuals are either listed or characteristic hazardous wastes under the Resource Conservation
and Recovery Act or the Illinois Environmental Protection Act.
ReWBS£: The Army will determine with USEPA and IEPA approval if treatment residuals of the
bioremediation process are hazardous wastes under RCRA and the Illinois Environmental Protection
Act. The Army has petitioned IEPA for delisting of listed wastes based on the reduction of the hazardous
characteristic. Likewise, characteristic wastes will no longer be considered hazardous, once they lose
their characteristics.
S 3.2 — Concerns About Pppri Restrictions;
Eight commenters expressed concerns about deed restrictions. [2.2, 5.3, 8.4, 14.3, 15.2 and 15 3 244
37.1, and 38.6]. The first issue covered limitation on the use of groundwater in order to avoid migVation
of a contaminated plume. The second issue covered restriction on the use of the property, particularly by
the industrial park developers). The third issue, by a single commenter, requested clarification of the
role of deed restrictions in the selected remedial action for groundwater RUs. Representative statements
on these issues follow:
1 . "The Army Corps of Engineers/EPA must restrict activities that will affect the groundwater flow and
gradients at the site. These activities would include large-scale excavation activities such as landfill
excavations, quarries, etc. Smaller scale excavations such as footings for a building would not be
expected to affect gradients, however, larger excavations would. By not restricting large scale
excavations, the monitoring and assessment plans for the Limited Action Alternative are not
systematic, well-controlled, or consistent with implementation of the natural attenuation alternative
Finally, large scale excavations have a greater chance of encountering groundwater and thus not
limiting exposure to contaminants as much as possible." [2.2]
2. One commenter requested that the Army "provide environmental safeguards and impose deed
restrictions as might be necessary to protect from harm the Midewin National Tallgrass Prairie the
National Veteran's Cemetery, and the environment in general." [5.3]
3. The IEPA noted that "Deed restrictions and other administrative controls will be needed to prohibit
current and future landowners from using contaminated groundwater from the portions of the facility
where groundwater contamination currently exists or is reasonably expected to exist in the future
These controls would remain until that point in time when Remedial Action Objectives (RAO's) for
groundwater are achieved." [8.4]
4. "It would appear that any withdrawal of groundwater within the proposed Groundwater Management
Zone and from the drift/dolomite would change the groundwater gradient; and therefore, the rate and
direction of groundwater flow. A change in groundwater velocity or direction in this zone could
disrupt the planned natural attenuation remedy. Why aren't restrictions being placed on any and all
dewatenng efforts in this zone? Restrictions on groundwater wells alone will not prevent other
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 „„ KS-20
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dewatering procedures, such as the dewatering of excavations, field tile and lateral drainage systems,
etc. from disrupting the gradient." [37.1, similar comment by 38.6]
5. "We ask the Army to consider a deed restriction on the property to be conveyed to Transport
Development Group. The legislation that authorizes this transfer of land includes a provision that
allows the Army to place restrictions on the property to "protect the interests of the United States."
Those "interests" we urge you to consider protecting are those of our veterans and of our shared
prairie heritage. The Sierra Club, along with many concerned, believes a deed restriction on the part
of the Army would be appropriate action." [14.3, 15.2 and 15.3]
6. "Identify in the ROD that the establishment GMZs or deed restrictions, will be taken as an interim
action, and that the final response action will consist of periodic site inspections, groundwater and
surface water monitoring, and natural attenuation." [24.4]
Response:
1. Deed restrictions are being negotiated between the Army and the future landowners, with the USEPA
and IEPA participating to ensure that appropriate environmental safeguards are established. See
ROD Sections 9.1.1.6. 9.2.1.2 and 9.3 for further detail.
2. See preceding response # /.
3. See preceding response # 1.
4. The groundwater deed restrictions that are being placed in groundwater management zones are
intended to restrict the movement and extraction of contaminated groundwater. The Army will
monitor the location and concentrations of contaminated plumes. If actions such as large
excavations do create flow of that groundwater outside of the GMZs, the Army will be responsible
for implementing a suitable control or treatment program for that groundwater. Deed restrictions
on groundwater use are presented in Section 9.2.1.2.
5. We share your concern for the proper use and environment for the Tallgrass Prairie lands and the
Veterans' Cemetery. However, under this ROD, the Army can not place deed restrictions that are
unrelated to its CERCLA remedial actions.
6. Detailed description of the selected alternatives of Limited Action for each of the GRUs is provided
in Section 9.2 of the ROD. Because the GMZs and deed restrictions will be in place for the same
period of time as the other components of the program (periodic site inspections, groundwater and
surface water monitoring and natural attenuation), it did not seem correct to label these interim
actions.
RS3.3 Concerns for Stormwater Runoff:
One commenter noted:
"Surface, water runoff controls will need to be in place during implementation of remedial actions.
The substantive requirements of discharge criteria, for what would otherwise be required by a
National Pollutant Discharge Elimination System permit, should be in the Record of Decision or not
later than remedy implementation. This would apply to all contaminants of concern at the facility."
[7.8]
Response: Section 10.2.1.1 of the ROD discusses the requirements for surface water runoff controls at
the site during remedial action implementation. Section 9.1.1.4 discusses the steps that will be taken.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg.RS-21
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RS 4 Monitoring
Overall, eleven comments from the 71 commenters addressed issues related to the" monitoring programs
that would be implemented with the remedial actions. These comments were grouped around three
issues as follows.
RS4.3—Concerns About Grnundwater Monitoring:
Five commenters commented on this issue. [8.3 and 8.7, 9.2, 24.1, 38.6, and 40.1.2]
1. "It can be assumed that a comprehensive groundwater monitoring system will be an integral part of
the remedy for the Groundwater Operable Unit at the facility. Surface and groundwater sampling
locations, sampling frequencies, parameters analyzed, etc., must be agreed upon during the remedial
design phase of the project." [8.3]
2. "Based on recent discussions with the Army, a round of comprehensive groundwater sampling will
occur in 1998 to establish a baseline of groundwater quality data. This would include inspection of
monitoring wells to assure physical integrity, establishing top of casing elevations for each well,
measurement of water depth from the top of casing, and sampling and analysis for agreed upon
parameters based on past records." [8.7]
3. "To be in compliance with ARARS, groundwater sampling must occur at least semi-annually."[9.2]
4. "The ROD should specify that performance monitoring will be undertaken to evaluate the
effectiveness of the groundwater remedies and to ensure the continued protection of human health
and the environment. The ROD should state the monitoring program, to be developed during the
Remedial Design, shall specify the location, frequency, and type of samples and measurements
necessary to evaluate remedy performance." [24.1]
5. "I am also concerned about groundwater contaminants in Loading Area One and how they may
affect Prairie Creek in the future. Will there be an ongoing monitoring program that looks at this site
on a regular basis? If the contaminants (plume) are shown to be moving and could possibly affect
Prairie Creek will the recommendation for cleanup at this site be changed?" [38.61
6. "The RAB recommends that the monitoring program include intermediate degradation products and
other measurements that can contribute to the understanding of this process in addition to the
tracking of the primary contaminants." [40.1.2]
Response:
L Agreed. A comprehensive groundwater-monitoring plan will be developed as part of the remedial
design process. See ROD Section 9.2.1.4 for further detail.
2. Correct. As part of the remedial design, the groundwater sampling and monitoring well inspections
that are planned for 1998.
3. Samples from groundwater monitoring wells will be collected semi-annually. See ROD Section
9.2.1.4 for further detail.
4. Performance monitoring is planned. A comprehensive groundwater-monitoring plan will be
developed as part of the monitoring design process and will include consideration of all parameters
including location, frequency, and type of samples and measurements. The key parameters of that
plan will be specified within the framework of the ROD.
5. The Army will monitor the locations of the groundwater plumes until the time when RGs are met.
Tlie migration of a GRU1 plume to Prairie Creek seems to be unlikely given the hydrogeology of the
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pa RS-22
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area and the fact that this has not happened in the 30 to JO years to date. If, however, they do
migrate and surface water quality criteria are exceeded at the GMZ boundary, appropriate actions
will be taken.
6. The Army recognizes that the natural attenuation and biodegradation processes are not fully
understood. A groundwater monitoring program that tracks contaminant levels (and that may in
part answer these questions) will be incorporated into the Limited Action alternative.
RS4.2 Long-Term Monitoring;
Two commenters commented on this issue. [ 13.3, and 41.1]
1. One commenter stated: "Landfills; where capping is the proposed action, I anticipate the Army has a
commitment to the long term monitoring and maintenance of the sites to ensure no future problems
of contamination. Please address the long-term plans for these sites." [13.3]
2. The RAB recommended that, "the Army establish a monitoring program to demonstrate that this
additional reduction [from natural attenuation or phytoremediation] is occurring" [41.1]
Response:
1. The Army will perform long term monitoring and maintenance of capped landfills as is required by
RCRA.
2. Ongoing monitoring will be conducted on groundwater plumes (see ROD Sections 7.2.1.2, 9.2.1.4
and 9.2.1.5). This monitoring program enables the Army to analyze and evaluate the effectiveness of
natural attenuation on the contaminant concentrations in groundwater. Studies of natural
attenuation and/or phytoremediation have been conducted or are underway by USEPA/Athens
Laboratory and by the Army Corps of Engineers/Waterways Experiment Station. At this time, the
Army is not proposing additional soil quality monitoring programs to demonstrate the effectiveness
of natural attenuation or phytoremediation.
RS 4.3 Biomonitoring:
Four commenters suggested the need for a biomonitoring program, [7.4, 23.2, 34.3, and 71.4] as follows:
1. "A biomonitoring plan should be implemented as a component of the soils remedy for those areas of
the facility to be managed for the protection and restoration of habitat. The monitoring program
should verify that human health preliminary remedial goals will allow for the recovery of a diverse
ecosystem, and should monitor the effects of the remedial actions and the potential residual risk.
The-Army's biomonitoring program should be coordinated with ongoing efforts, including efforts by
the Illinois Department of Conservation and the U.S. Forest Service." [23.2 & 7.4]
2. "Based on the fact that PRGs currently noted in the proposed plans were developed for JOAAP using
primarily a human health risk based scenario, how does the Army intend to continue evaluating
ecological risks at the site through various ecological investigations (data gathering) to ensure that
the suggested remedies are protective of all Illinois trust resources? Does the Army intend to
evaluate ecological exposures and the performance of the proposed remedies with regard to those
ecological receptors at that mandated five-year remedy review process?" [34.3]
3. "The [NRRB] recognizes the difficulty in establishing ecological risk-based preliminary remediation
goals (PRGs) for explosives at this site. Army should consider monitoring to verify that the human
health PRGs used for the prairie ultimately achieve the desired ecological endpoints." [71.4]
JOAAP Record of Decision Soil & Groundwater OVs - October, 1998 pg. RS - 23
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Response:
1. The actions selected in this ROD for those areas to be managed for the protection and restoration of
ecological resources are interim actions. The monitoring program will be considered when selecting
the final remedy or these areas.
2. See preceding response #/.
3. See preceding response #7.
RS 5 Implementation
Overall, 107 comments from the 71 commenters addressed issues related to the implementation of the
remedial action. These were primarily focussed on the desire to implement and complete the cleanup
quickly; on the desire that local and/or union labor be used to help perform the remedial actions; on the
advantage the land transfer would have for the local community tax base; and on the desire that the Army
prioritize the cleanup of the industrial park areas.
The implementation issues tended to be grouped together and addressed jointly. A typical comment is:
"As a concerned citizen of Will County, I have worked and lived around the Arsenal property for
40 years. It has been vacant for 20 years or more. It is time for the government to speed up the
clean up of the Arsenal and return it to the tax roles so the people of Elwood & Wilmington can
reserve tax relief for schools. It needs to be developed now. The people of Will County need the
jobs now not 4 to 6 years down the line." [30.1]
Those who commented on implementation typically did not comment on other issues. However, eight
expressed a preference for the selection of excavation and disposal over bioremediation - because they
believed it could be done quicker or it could create more jobs for truckers and equipment operators
[11.3, 29.2, 32.2 and 32.3, 47.2, 47.3, 47.8, 50.2 and 50.3, 52.3 and 52.5, 53.1 and 53.3, and 67.2 and
67.4] Several also expressed frustration at past problems with the JOAAP [48 4 and 48 5 519 51 10
and 51.32, and 65.2 and 65.3] > • . • ,
The six groups of issues concerning implementation were addressed as follows.
5J — Requests to Expedite Implementation of Remedy;
Thirty-three commenters requested that the Army move quickly to clean up the site [3.2 and 3 3 113
and 1 1.5, 16.4, 19.1, 21.1, 25.1, 27.1, 30.1, 31.1, 32.2, 33.8.3, 36.1, 44.1, 45.1 and 45.2, 46.1, 47.2 'so 9
52.2, 53.1, 54.1, 55.1, 56.3, 57.1, 58.2, 59.1, 61.3, 63.3, 65.3, 66.1, 67.4, 68.2, 69.2, and 70.5] Three
other commenters requested that the Army not speed up their schedule in a way that would put the basic
objectives, protection of human health and the environment, at risk. [17.2, 38.3, and 42.2]
Response: The Army shares concern of many and is working to clean up and prepare the properties for
transfer as expeditiously as possible within the constraints of its legal obligations and funding. The
Army must ensure that it first meets its responsibility to protect human health and the environment from
the risks posed by contamination currently on-site.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 «». RS - 24
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The Army estimates that the industrial park parcels that are contaminated may be transferred sooner by
using bioremediation than by Excavation and Disposal. This is because of the long time it normally
takes to get landfills approved, permitted, designed and operating.
HS5.2 Request to TJse Local T.ahnr;
Twenty-three commenters requested that local labor be used in implementing the planned remedial
actions. [16.2, 19.1, 27.1, 28.1, 30.1, 32.1 and 32.5, 36.1, 46.2, 47.8, 49.6, 52.5, 53 3 54.1, 55 1 562
58.2, 60.3, 64.2, 65.2, 66.2, 67.4, 69.2, and 70.5] ' ' '
Response: With the proposed remediation, jobs will be created for a variety of remediation workers at
the JOAAP. The Army will follow proper contracting procedures and use fair labor practices in its
award of contracts and subcontractors for remediation at JOAAP.
Bioremediation will require two to three times more earth moving than simple excavation and disposal.
Soils must first be moved to a treatment facility, then be moved within the facility during the treatment
process, then moved to their final destination as backfill or landfill material.
HS 5.3—Request to Use Union T.ahnr;
Eight commenters requested specifically that union labor be used in performing the remedial action at
the site. [11.4, 25.1, 32.1, 36.2, 56.4, 58.2, 59.1, and 68.3] Many other implementation commenters were
union members who presumably intended that their request for the use of local labor to also mean union
labor.
Response: The Army will follow proper contracting procedures and use fair labor practices in its award
of contracts and subcontracts for remediation at JOAAP.
RS5,4—Request to Prioritising Remediation of Industrial Park Sites;
Twelve commenters requested that the Army prioritize the cleanup of the Industrial Park areas for early
transfer to the State. [3.4, 16.3, 21.1, 29.2, 31.2, 32.4, 44.1, 45.1, 47.6, 48.7-48.10, 49.4 and 49.5, and
Re$ponae: The Army intends to transfer 1,900 acres to the State of Illinois in 1998 for development of the
Industrial Parks. The transfer of the remaining 1.200 acres to the State must await the proper cleanup of
the contaminated soils found in those areas. The Army intends to transfer the Will County Landfill
property in 1998. The Army has transferred approximately 15,080 acres to the USDA (Forest Service)
and 980 acres to the Veterans Administration. The Army is working to ensure that these transfers be
done quickly and properly.
RS5t5—Concerns for Improving Tax Base:
-> Twenty-six commenters expressed the hope that the transfer be done soon in order to improve the tax
base on which community improvements will depend. [3.5, 19.1, 20.2 and 20.3, 211 25 1 27 1 28 1
29.2, 30.1, 31.1, 32.1, 36.1, 44.1, 45.1, 46.2, 47.6, 48.7-48.10, 49.6, 53.2, 56.3, 57.1,' 61.3,' 62.4 63 3'
68.3, and 70.3]
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg.RS-25
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Response: The Army appreciates the concerns for the health and growth of the community and believes
that the actions recommended will best meet these needs over the long run The Army is planning to
remediate the sites as soon as possible within budgetary and regulatory constraints to facilitate transfer
of the property.
6 — Concerns Over Remedy Implementation Schedule:
Five commenters commented on what the schedule would be for remedial action
implementation. [7.5, 33.8.3, 35.2, 38.2, and 39.3] One commenter asked whether the Army
intends to provide schedules within the ROD, and if not, where and when would it provide these
[7.5].
Response: Estimated timeframes for implementation of the remedial actions will be provided within the
ROD in similar detail to that provided within the Proposed Plans. The Army will submit detailed
schedules for implementation of remedial actions following completion of the ROD. in accordance with
the requirements of the JOAAP Federal Facility Agreement (FFA, Section XII).
RS 6 Other Issues
Overall, twenty six comments from the 71 commenters addressed issues not covered in the general
groupings discussed above. The following five sets of issues were addressed.
RS6.1 Removal of IJXOs!
Five commenters expressed concern about unexploded ordnance (UXO) remaining on-site at the JOAAP
and asked what actions were planned for this UXO. [1.4, 5.4, 7.7, 14.2, and 34.6]
Response: UXO is suspected or known to exist at sites L2, L3, Lll, L34 and portions ofL16 and L2L
77ie UXO will be located and either removed or buried on-site under a safe protective cover. UXO
removal actions are scheduled to occur during 1998 as part of a non-CERCLA project.
RS 6.2 Sulfur Cleanup:
Three commenters raised issues relating to the cleanup of sulfur in SRU7. [7.6, 23.8, and 71.9]
1. "I support the Army efforts to address sulfur contaminated soil, which is the most likely cause of
sulfate concentrations exceeding State water quality criteria in certain portions of the Manufacturing
Area." [7.6]
2. "SRU7 - The CERCLA may not require taking action to address sulfur-contaminated soil, although
EPA supports the Army's Plans to do so. The Army should clarify in the ROD their rationale for the
planned soil removal." [23.8]
3. "CERCLA may not require the removal of sulfur-contaminated soil as a hazardous substance in Soil
Remediation Unit (SRU) 7, although the Board supports the Army's plans to do so. The Army should
clarify in its decision document their rationale for the planned soil removal." [7 1 .9]
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg.RS-26
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Response:
1. The planned removal of the ash piles, as noted, should have a positive effect on the sulfate
concentrations in the surface waters in contact with those piles.
2. SRU7 - cleanup of sulfur is being handled as a removal action outside of the remedial action
process. This will be noted in the ROD, but an expanded explanation of the rationale for sulfur
cleanup is provided in Section 8.2. 7 of the ROD.
3 . The Army has decided to remove the raw sulfur from sites M8 and Ml 2 for two reasons. First, raw
sulfur can be toxic when ingested and should therefore be removed. Second, the raw sulfur may be a
source ofsulfates that have been observed downstream - removal of the raw sulfur will remove this
potential contaminant source.
6.3 — Concerns Over the Nature and Extent of Contamination?
Three commenters asked questions relative to the nature and extent of contamination [23 4 34 1 1 and
50.7 and 50.8] as follows. ' ' '
1. "Describe in the ROD that the majority of explosive contamination in soil is found near the surface
or one to two feet deep and that deeper subsurface contamination represents a small percentage of the
overall volume of contaminated soil." [23.4]
2. "It should be noted that the area of concern may contain nearly 235 acres of contaminated material.
Although the areal extent of the contamination may appear to be insignificant compared to the
overall size of JAAP (nearly 23,000 acres), it is important to keep in perspective that even a 235-acre
"Superfund" site is a very large site. The argument that only a small percentage (less than 1%) of the
total acres at JAAP is actually contaminated should not be a deciding factor by which a remedy is
chosen," [34. 1]
3. "I'm not sure that the government, on their testing, has said exactly how much soil is there. It's an
estimate, only. [50.7] What happens if the soil doubles or triples, and what will happen to the budget
that's in place now. Will it expand or will it go on for more years and no development." [50.8]
Response:
1. Site-specific descriptions of contaminants, volumes and RCRA waste classifications (if any) are
given in Section 5 for each remedial unit.
2. The acreage of contaminated surface soils will be reduced to zero with remediation. The use of the
1% figure in the Proposed Plan was to point out that only a small total area of the JOAAP was
contaminated and in need of remediation. It was not to minimize the importance of cleaning up that
contamination. It also was not a deciding factor by which remedies were chosen.
3. The Army has sampled extensively to determine the types, locations and depths of contamination in
the MFC and LAP Areas. By the very nature of sampling, there is likely to be some changes in the
total contaminated volumes once actual remediation begins. The probability of these volumes
doubling for the facility as a whole is extremely small. If the soil volumes increase substantially,
costs will rise and remediation times may rise too. As information becomes available, the Army will
modify its remedial action budget requests, if necessary, to accommodate the changes in volumes
and other conditions that are encountered
RS6,4 _ Groundwater Plumes:
Two commenters asked three questions related to the groundwater plumes, [40.3 and 40.4, and 71.2] as
follows. o
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg.RS-27
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1. "One of the plumes between study areas M6 and M8 contains perchlorethylene (PCE), a chlorinated
compound known to be very persistent in groundwater, as the primary contaminant. Although PCE
can be dechlorinated under certain relatively rare conditions there is no evidence that these
conditions exist at JOAAP. Therefore, the only natural attenuation mechanisms to reduce
concentrations are adsorption and dispersion. Although these mechanisms may eventually reduce
concentrations to legal limits, they do not destroy the compound or reduce its toxicity. Furthermore,
there is no proposal for source removal at this plume. Natural attenuation may be acceptable at this
plume because there are no groundwater uses at risk but it is far less desirable. Alternates such as air
sparging and phytoremediation are very effective at removing volatile compounds such as PCE from
shallow groundwater. The RAB recommends that the Army seriously consider these alternatives for
this plume during remedial design. Additional work is required to identify the source or sources of
this plume and determine if LNAPLs or DNAPLs exist." [40.3]
2. "The Central Tank Farm contains a small toluene plume. Toluene is the first of the BTEX
compounds to biologically degrade in groundwater, therefore this plume should not exist after 20
years unless there is an ongoing source. The Army should look for the possible existence of LNAPLs
at this plume." [40.4]
3. "Program experience at other sites indicates that toluene tank farms are often associated with light
non-aqueous phase liquid (LNAPL) ground water contamination problems. Since the JAAP has such
a tank farm, the Army should ensure that their investigations have evaluated the potential for
subsurface LNAPL contamination in this area. This is especially important since the Army's
preferred alternative relies heavily on monitored natural attenuation to address GW contamination in
this area." [7 1.2]
Response:
1. M6 and M8 PCE plumes have been considered by the Army. Past sampling data results have been
inconclusive on these plumes. The current nature of this plume will be better determined with
additional groundwater sampling to be conducted in 1998 during the remedial design. Should
source removal and/or a treatment program be seen to be necessary, such actions will be taken.
2. As with the PCE plume, the current condition of the toluene plume at the Central Tank Farm will be
determined in 1998 during the remedial design. It is correct that the degradation should have
occurred within the 20 years since this contamination probably was released into the groundwater.
During the groundwater monitoring program, the Army will sample groundwater in the area of the
tank farms to determine if any free product LNAPLs remain at the site. As with the PCE, should
source removal and/or a treatment program be seen to be necessary, such actions wilt be taken.
3. Toluene was detected above the RGs at two wells (MW-224 and MW-220) near the tank farms.
Given that these tanks have been empty for 25 years it is not surprising that the toluene has degraded
or volatilized. One well, MW-224 has shown almost a complete disappearance of toluene from a
high of 20.000 pg/L (7/16/88) to a level of 1 jug/L at the most recent sampling event (1995). Further
sampling of the wells will be conducted in 1998 and as part of the limited action remedy. This
monitoring of the wells in this area will determine whether or not the concentrations are dropping.
As part of this groundwater monitoring program, the Army will test for LNAPL free product in the
area of the tank farms.
Miscellaneous Comments:
Thirteen comments were received that were not easily grouped with the sets shown above. [21.1, 32.3,
33.1.7 and 33.1.8, 34.7-34.10, 43.3, 48.2-48.6, 50.4 and 50.5, 51.2-51.32, 60.3, 62.6 67 2 and 67 3* 70 V
and 71.3 and 71. 10] ' '
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. RS - 28
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1. Hunting" "I would also like to see part of the land opened up for hunting as it was in the past"
[21.1]
2- Private Sector Remediation of Site: What is "the Army's willingness to cooperate with the
developers who are ready and willing to invest their dollars to provide jobs and economic
development that will provide much needed tax revenue, and possibly save the taxpayers millions of
dollars." [32.3], and
A private contractor requested "that the Army review and respond to [its] new Alternate Soils
Remediation Plan prior to the Army's final decision. By working together, we can meet the goals of
the legislation for the community of Elwood, and surrounding communities, to provide the jobs and
economic development consistent with that legislation." [33.1.8]
3- Use of Land after Transfer: "TDG would ... like to inform the Army that it has a Pre-Annexation
Agreement, approved by the Village of Elwood, with special use permits, i.e., rock quarry, landfill,
cement plant, asphalt plant and all industrial applications, including an intermodal rail facility "
[33.1.7]
4- Ajmv Role as Natural Resources Trustee: One commenter had the following comments and
questions concerning the Army's role as natural resources trustee for the JOAAP property.
"As the lead federal resource manager and trustee as designated under federal executive order 12580,
when did the Department of Defense or the Army notify federal, state and or tribal trustees as
required under 40 CFR 300.410, that there was an interest in coordinating assessments, evaluations
and investigations, and engaging in planning activities at JAAP? Who at the state level was this
notification sent to?" [34.7]
"Have various natural resource trustees, such as other federal, state and tribal entities, been involved
in the problem formulation phase of the ecological risk assessment including various data collecting
activities? It would be helpful for these groups to be identified in the proposed plans." (#34.8)
"When was the natural resource restoration plan developed for JAAP? Will this plan be included as
part of the administrative record?" [34.9]
"If baseline conditions were evaluated prior to developing the proposed plans, how did the Army
integrate 43 CFR I 1.1 4(e) as part of this review? How have the differences between remediation
goals and natural resource restoration been evaluated with regard to baseline conditions and how
explosive COCs may be a factor of concern?" [34.10]
5- Potential Contamination of Prairie Creek: "The materials in L3 are contributing to documented
groundwater contamination in the area adjacent to the Creek, and the contaminants could end up in
the Creek." [43.3]
6- Concerns Over Army Past Actions: Eight commenters expressed frustrations at past actions by the
Army. As an example, one commenter noted: "I'm well-aware of the historical perspective of the
Arsenal property being taken by the government and the feeling and frustration of the people of
Elwood that something very valuable to them was taken with little or no say so on their part." [48.4]
7- Studies and Costs: "They [the Army} have literally sat at this meeting saying they have spent six
years studying bugs that can correct this. Totally unacceptable. The bureaucracy of getting this done
has taken years and years and years with no tax revenue to these two communities at all. They have
left a big mess here." [67.2 & 67.3]
Response:
1. Hunting: The Department of Agriculture will be the future landowner for where hunting could
occur. Whether or not they allow hunting is their decision and is beyond the control of the Army.
This comment is better addressed to the future landowner of the property.
2- Private Sector Remediation of Site: The Army is responsible for environmental clean up to a level,
that is protective of human health and the environment, to a level that is appropriate to the future
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg.RS-29
-------
intended land use and. in accordance with Federal Acquisition Regulations and contracting
procedure.
3> ££g Q.f Land (?/?er Tmnafer: The Pre-Annexation Agreement is outside of the scope of the Army's
concerns. The use of the land, for rock quarry and other excavations, will be consistent with the
limitations put within the deed restrictions.
4- Armv Role, as Natural Resources Trust??- The remediation of contamination at JOAAP is a
CERCLA-based action. The actions conducted Bunder this CERCLA program are consistent with the
requirements of natural resources trustee, but they are not subject to the same procedures and
policies.
- The actions have been conducted in cooperation with both USEPA and IEPA. Other agencies
were notified of the Proposed Plans both with the legal notices placed in two local wide distribution
papers, and with direct mailings (to those who have expressed an interest).
- No natural resource restoration plan was developed for this CERCLA action, nor is one necessary.
- No baseline conditions were developed for purposes of comparative evaluation of natural
resources restoration with remediation goals.
— The Army will support as necessary the JOAAP BTAG in its evaluation of the exposure levels of
ecological resources to contaminants at JOAAP.
5- Potential Contamination of Prairie Creek: Studies of surface water contamination have been
conducted over the full course of investigations at JOAAP. Sampling and analysis data shows, no
exceedances of water quality standards in Prairie Creek.
6- Concerns Over Past Actionx: JOAAP served an essential purpose to the United States in its years of
munitions production. Not all actions of its history and operations were positive to all people. The
concerns of the local communities is noted. This comment is beyond the scope of this ROD.
7- C°"cern Over Study. Time and Costs: Being placed on USEPA 's National Priorities List means that
the Army must follow the requirements of the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA) and means that USEPA oversees the remediation of the
Army's Joliet AAP contaminated sites. Once the site was placed on the NPL the process took two
directions: the Remedial Investigation (RI) and the Feasibility Study (FS). The RI Site
Characterization identified what kind and how much contamination is at the site. It involved
collecting and analyzing many samples to measure contaminant concentration!; in soil, surface
water, sediments, and groundwater for both the MFG Area and the LAP Area. This phase also
included extensive field investigations to identify ways contaminants could potentially move away
from the site - through surface water, groundwater, soil, or the food chain; and routes by which
humans might come in contact with the contaminants - by ingestion. inhalation, or absorption
through skin. These findings were used in a Risk Assessment where an evaluation of risks posed to
human health and the environment by the site in its present, unremediated state was made.
Depending on the results of the Risk Assessment, the Army RI/FS team, along with USEPA and IEPA
had to decide that no farther cleanup action is needed at the site, or site work proceeds to the next
phase: developing screening, and evaluating of remedial alternatives. All the above stages have
taken a long time, (17 years) and are a costly process. This was a large, complex site that required a
large amount of data gathering and analysis to determine the nature and extent of contamination and
the most cost effective, environmentally acceptable and safe means of cleaning up the site prior to
transfer to future owners. The Army and regulators took the mandated CERCLA law approach and
the most expedient effort in defining the full extent of the contamination at the site, understanding the
risks posed, and determining the most appropriate means of remediation.
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg, jus - 30
-------
[END OF SECTION]
JOAAP Record of Decision Soil & Groundwater OUs - October, 1998 pg. RS- 31
-------
-------
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SUMMARY Of REMHMAL ACTIVITIES
OR*1" 1W<_ PECWr C- KCISICii.
-------
APPENDIX A
Summary of RME Risk Characterization
3$ Estimated in JOAAP Baseline Risk Assessn^pts
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 Revision 1 - 10/27/98 Appendix A
-------
••¥* If
-------
SUMMARY OF RME RISK CHARACTERIZATION
AS ESTIMATED IN .TOA AP BASRTJNF, RISK
(From BRAs conducted for MFG Area (12/94) and LAP Area (2/95))
Silt LaMJise. Receptors Media Subarea
[ML-4 i -.- JSediment ""i """
ML..;.... | .".""""~.jKurface"Water~"1 "~"
Ml [ ^Security'WoTkef" 1s~diT"""T 1
M] i t ~ "^ — • 4
ML..L I ISurfa'ce Water 1"
ML.4 ..[... '_"_".""" "~"JA£" 1
Ml iFuture • Maintenance Workers 'SoTf • ~
Ml I ! • CArli'mlnf >~"
ML.4 iZZ"~ZZZ"T"~ZJAsir""""""~~"r" -
Ml l [Construction Worker |Soil >
ML..L-. [ !s~ed7inent 1 "
ML-4 | iGroundwater !
SM.L..U-. .....: IXsh . "j "
W. L ! Resident isoif ~ ""•
Ml j. ! iGroundwater j "
MI ! i TJUh" " — n.
.—_--._i.____________-i_j____^_ _ (/ASH |
M1 i !Resildent(chfldy "" iSurfeceWater 1 """""
M? [ [Security Worker jSoiT 1 "" ""
!M2 [Future i Maintenance Workers "jSofl " 1 ""
^2 ! 'Construction Worker ]Soi! ^
M_._4_ : iGroundwater I
M2 i_ i industrial Worker :Soil '
M?— L [Resident ISoil ! "
^2 : , iGroundwater !
^3 !_ _ -Security Worker !iSofl " 1
^[3. ..[Future ; Maintenance Workers" JSoiT " ~"j" "
^.3_._ [ _ [Construction Worker' jSoil 1
Ii....{. ! iGroundwater ! "
M3 ! ilndustrialWorker ;SoiV "• — — -
.. ' '• iGroundwater !
Ml..!.... L. jSoil SHotspot
MI..I L.....:Z; "" " isedSSiiri"'""i
M4 ;Future iSecurity Worker ""ISoff ~ ' "
Ml..}. i JSoil IHotspot
Ml..!.... ___„:„,_._ jSe'dfrSe'm 1~ ' — "
M4 : ; Maintenance Workers 'Soil "* "
M1.4_ ; JSoil JHotspot
Ml..!. ! -Sediment :
M4 : ; Construction Worker ;Soil ^
M1..L ..I JSoil IHotspot
M1.4 „.„[.. . iSediment;"" j "
M4 [ i Industrial Worker ;SoiI "i
M1..L 1 JSoil JHotspot
ill..! ...J iSedunent""""""; ""
M4 : [Resident "•" " ]s"oil 1 "
M1.4_. [ iSoii JHotspot
M4 : 1 iSedimeiit ! " 1"
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a,b
a,b
a, b, c
a,b, c
a, b, c
a, b, c
a, b, c
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-------
SUIVIMARY OF RME RISK CHARACTERIZATION
AS ESTIMATED IN JOAAP BASELINE RISK ASSESSMENTS
(From BRAs conducted for MFC Area (12/94) and LAP Area (2/95))
^ LafllLUsfi EiSSmtS Media Subarea Pathway laiaLRJsk Inde*
*:i5...L .. ;. , . jSediment 1
^5...! , £zzzzr77TZ:MzzzziiLZ"~" "~
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M--L..L t?™.1?1" jsoif IEWD
™..-t • jSediment <
vlS [Future ! Maintenance Workers ""isoif lEWD
^5 [ ! Industrial" Worker Is'oi'f " 'EWD
.M.5 j. j {Sediment j
MS [ [Construction Worker Is'oil " ^EWD "
MS •. : is'oii ITL "
.„„..•. • iSedimem ;
flil? — L i IGroundwater ]
M.5_4 -Resident IsoiT IEWD
M-5.-t • :Soii ITL
™ — J.. J. -Groundwater !
MS ! [Resident (child)" iSurfa'ce'Water 1
M.$-4 j.Z'.'.'Z."."" ISoiT "lother
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M.5-4 i!7!Z." iSoi'l' ibther "
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M6 jFuture iMaintenance Workers """""'SoiT" "«TOTD —
515 *.. ; ;Sediment j
...-.«-t,.,_, „.__„,. i. 'oCuinieiit 'HotsDot
k *£ t -•--...---.. „ „., __ _j ( v~i**,*
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„. I. j iGroundwater >SP
yw j. .......jlf!dM.s.tI??[)X9**"r" Isoff ITNTD" "
.„. [, !. , ;S~ediment I
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2.4E-(J5;S ; 1.6E+00
3.2E-05iS_j_ 5.1E+00
6.5E-05[ J^ 9.8E+01
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JOAAP Record of Decision Soil Groundwater OUs - October, 1998
Appendix A (RME Risks) pg. A-2
-------
SUMMARY OF RME RTSK rHARACTFRT7 ATTO]M
AS ESTIMATED IN JOAAP BASF.T.TNE RISK
(From BRAs conducted for MFG Area (12/94) and LAP Area (2/95))
Site Land Use Receptors
M6 i :
M6 j I"" "" -"
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WO ! :
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M6 ; " * " —
M6 ;' '; " '
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M7 } Current : Maintenance Workers
M7 ["" f
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|M7 [ :Security"WoVkef "
M7 f r
M7 iFuture .'Maintenance Workers "
M7 :
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M7 f " !" " "
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jSoil jOther
jSediment | "
.JSediment JHotspot
IGroundwater iNP "
;Groundwater IMP
iGroundwater ;SP "
iSurface Water ]
..iSoiJ. JOSTA
jSofl_ [" jTNTD """""
JSediment ; ""
jSurface Water JSIP
Isoii ITNTD "
•Sediment ]
!Soi_I_ _ ; JOSTA
ISediment |
]So'.L..""]!~ ^ "jTNTD
J?°il....Z.l~^j™Tp;Hotspo"ts
jSediment ;
jGroundwater !
jSediment 1
jsoii ITNT'O """ "
iSediment 1
: Ground water |
.Surface Water ^sYp
.J 1 ;
;Sediment ,'SAD
..JSediment JNAD/AP"
iSediment ;TJC"
jSurface Water ISAD
"""jSurface'Water IT/C" ""
.Sediment ISAD
iSediment ""1NAD/AP""
iSediment ;SAD
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~? — j. I JSediment 1sAD~ '
MS j ; | •]". :
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I.9E-04IS ! 2.5E+01
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} 3E-02: ' 1 3E+02
9.7E-06^ j 2.3E-02
"6.3E-06r""! "2."9E-b"l
I.4E-05! i 2.6E+00
'•5?:P.8.L I i.'E-oi
1 .7E-08""T""3!i6E-04
l).iE-06\"^ "2.2E-02
1 5E-09; "'"' I 9E-04
I.4E-06|^ j_ 2.6E-01
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7 OF.ft?' ->- 1 <[P m
2.7E-04[ J^ 4.8E+OI
" 3 .2E-07 f " t " "S.6E-03
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2.5E-07["T""6riE-br
7 4E-051 -""l" 6E+02I
I.2E-077 7 3.2E-02
1 .8'n-04: ! 3.2E+01"
2.IE-07|^ j_ 3.7E-03
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3.'5E'-047"T"3".1E+06|
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2.3E-05iS : I.6E-b"3
4.<)E-06!TT "-"-"
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2.6E-08;f ;
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4 .511-06 1 S"7 "TeE-M
9.4H-07[T J_
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JOAAP Record of Decision Soil Groundwater OUs - October, 1998
Appendix A (RME Risks) pg. A-3
-------
SUMMARY OF RME RISK CHARACTERIZATION
AS ESTIMATED IN .TOAAP BASELINE RISK
(From BRAs conducted for MFC Area (12/94) and LAP Area (2/95))
Ste LandJlsc Bs^r* Medi, Subarea pa,h™« TlrtalpMr "^
|.M.? — } ..j.S.?d!ment JSAD
j«?—L -... iSediment iNAD/AP
£}f»4 1 jsedi?H?i:i;;;;"]TJc — •-
I*!!...; i .„ , iGroundwater ;
M?...-. il?d.H£riarw«ker' IsoiT 1
M.l — L . ....!.. jSediment IsAD ~
M8__; | ' : f----- -
M5...L i JSediment iNAD/AP
Mf j. i?_<:.si.de.nt -'Soil "i "
M?...;. J ^Sediment ";SAD~
J-J----4 [ j?.e.diO!?9L^ INAD/AP"
^? — 1 i JSediment -TJC
~?..,j. , i... jGroundwater 1
.™.§ j. -i?-c.™?n! ffJl'JdJL j Surface Water !SAD
M.?...i. , • ;S~urface~Watef ^NAD'/AP"
I™?...) : i Surface Water IfjC ""
i-?— ; ; {Surface Water 1
Ufft 1 , 1 1
—•—»••— — . _.i j/\sn i
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M.? j. {Construction Worker' Is'oiT ""' " —
MO • t" --• - •;-.-•; ---•! —
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M9 ! {Resident (child) 1Suiface"Water 1""
m?..L?uJP.r5. JConstruction Worker iGroundwater JWTF
^.i94 j /"l"Tril7\7LGro«jidwateT ]CTF ~
'** ; : iGroundwater -CTF
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Vlll [ ! " | - — "j
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M'.LL : " jSedrme'm i - -
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M" ' {Resident (child) ;S~urfa~ce~Water"""'1' "" "
"uffo "*""""•" f -. 1-™ ;r j
i-ilr..;... .,,,....,...: iSediment |
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. iU?__!fraure {Mamtenance Workers ;Soii ] "
Ml?..! ""i"""".""""""""""""," jSediment ]'"" "
.M.!?4 |c-°5!Sy?!i.°?.^orker Isoii I ""
.M.i?..j. ... ,....-.., {Sedirnenr "1""
M.!?..l i. ^Groundwafer 1
MI2 ? [Industrial Worker" """IsoiT 1 "
v.!?.lziz:."±zzzz;; \s*i^r j -
M.12 L [Resident "isoif 1
a,b
"a7b"
""]a"b"
.........
-—..-..
.........
""a;b"
a,b"
.-....„.
""alb"
-----
a,b"
""dreVf
"""h"
h""
—....-
a,b
.__a,b
a,b
..........
a,b
a, b
_ _a, b"
d
"~d"
'd",V,"f
"dieVf"
__a,b _
-----
.........
"]_d
a,b
""""h"
a,b
[lib]"
..........
"aib"""
-..-.....
"a7b""
"?:JJ~"
-----
I. IE-OS;
^ 2.3E;06!'
""T.5"E-b5[
"^3\)JjCte[
""2.9E-p5[
3.4E-07:
"""f.'SE-OSi'
f..
"-4-
-v--f-
-:-;-[-
I.2I--09.'
"f.2i;-jo["
7."lE-07T""
1 .5E-09
— :."..). —
---• — —
— —
6.9E-03
""l"9E-"df
""TiE-os
""""6.2E-04
"""OE-M
""4.6E-03
""TfE-p"i
'"TfE-'df
"]_TSE-03
S.2E-03
""T7E-03
"TOE-05
-:
--
"2.5E-04
6.0E-04
"7"5E-04
8.9E+06
"V.2E+01"
_J.5E-04
_"2"9E-0]
"6"6E-05
"L4E-OI
"i"5E-02
1.4E-02
~6X)E-~d3
1.1E-04
9.2E-04
j"lE-05
[?[OE-i)3
'8J2E-03"
"2^6E-p"i
"l?4E-03
T2E-02
T.GE-Q2
JOAAP Record of Decision Soil Groundwater OUs - October, 1998
Appendix A (RME Risks) pg. A-4
-------
SUMMARY OF RME RISK CHARACTERIZATION
AS ESTIMATED IN JOAAP BASELINE RISK ASSESSMENTS
(From BRAs conducted for MFC Area (12/94) and LAP Area (2/95))
Hazard
SitS Land Use Receptors Media Subarea
M12 . j iSediment ;
M12__j_ _; _ iGroundwater j
MI2 F iResfdent(chiid) " ISurface'Water 1 " """
M13 [Future : iGroundwater :
M13 . ; iGroundwater ;
Mil.-.- {Security Worker ;S~oil "|
W14__[Future (Maintenance Workers " Is'oiT ]
M14 i iConstruction Worker .'Soil 1
MJ4 : [Resident IsoiT 1 "
MI'S":"" ; " 1"" 1 -
M15 j. ! ISediment ]ND
M15 i [ • iSediment !SD
M15 j I i Surface Water 'ND
M154 i jSurface Water ;SD
Mil [ ^Security Worker IsoiT 1 """
M15 i : iSediment iND
M15__j_ ! _ _ _ jSediment ;SD
Vll5__[Future i Maintenance Workers jSoil "i "
M.l^ .I : ISediment iND
Ml?..l._ i JSediment JSD
M'5 i iConstruction Worker iSoii 1 "
M15 i. i ISediment iND
.¥_!.?_-!. L- iSediment JSD
M15 ; ilndus'triaf "Worker" jSoif " 1
Mil f • "V~ ~ "1 —
M15 i j iSediment iND
Ml?..; : • iSediment |SD
vI15 : ;Resident ]SoiI ^
Mil i : ' — -r— - - — |
M15 ! ! iSediment ;ND
MJ_?4 ; jSediment JSD
v!15 : 'Resident (child) " ISurface'Water IND '"
M15 i : iSurface Water iSD
MFC ^Future IConstruction Worker IGroundwater ;Parcel3
MpG : ; Resident iGroundwater !Parcel"3
I!!??.-!.?.".?.6.".?. i.?i!tI.9°n?H.nlers, jSurface Water : Jackson Creek
MFC [Future [Fisherman ""jSurface'Water Ijackson'Creek
.¥.?94 ^Resident (child) 'Surface Water jJackson Creek
MFC iCurrent ?Fish Consumers i Surface Water""""! Grant'Creek
M.??4?iltu-re. iri?!?-6™?.1!.... JSurface Water jGrant Creek
MpG : iResident(chiid) iSurfa'ce'Water jOrant'Creek
rl jFuture ifndustriaf Worker •' 1 """
-1 ! iConstruction Worker "j ""•
-1 i iResident 1 " 1 """
LI i ; Hunter i ;
-' i iResident iGroundwater j
L2 ^Current ;Security Worker ISoii iBurning Pad
„. ' ! 1 i Popping Furnace
t?. -L i : ,'OilPits
L2 ^ ftlfPffr..... j jBurning Pad
L? L. - ! . ., . .. i jPopping Furnace
Pathway
a.b
d.e.f
„„.
d
d,e, f
a,b
a,b
-—„„..
—.„....
a,b"
a, b
------
a,b
a.b
h
"h"
—...„.-
a,b
a.b
-—....-.
..........
a,b
a,b
—-.„...
a.b
a,b
.........
a.b
a, b
a.b
.....„„.
a.b
a,b
a,b
—.-.....
h
d
d.e. f
g
h
h
h
-— h— --
a, b, c
a,b, c
a, b, c
a, b, c
a.b, c
a, b, c
a, b, c
a, b, c
a, b, c
a, b, c
lulalRisk
•
T'ToiW'
. - ,
— i
.. .......v4.
•• i-
2.1E-06[S
8.4E-09"if
K:7E-06i
2^211-09!
3.1E-09:
1.1E-08T
*
4.6E-08:
' 2.1E-b"6[s"
"8.4E-b9;f
8.7E-06[
S.OE-06[
" l.()E-b"6fs"
(i ()H-09;f
1.3H-OSTS"
5.01i-08:T
.
5 2E-05,_
' 1 2f:-07i""
- - i
-?'!£§-
5.3E-07;
7.'JE-06[ ^
IE-07_!__ ^
4F.-06i
2K-07:
2E-07:
.Ui-041
'.' i— -
Index
8.5E-02
"""T4E-03
5.1E-05
^ .9E-02
.6E-05
.6E-06
""" "4E-03
.5E-03
^ _7.9E-q3
l.OE-03
5.7E-02
1.4E-05
i.l"E-"d5
"T2E-05
5.5E-06
3.0E-04
""7J9E-03
l.OE-03
5.7E-02
""6"7E-"di
7.8E-03
5.6E-01
"""5JE-05
6.9E-04
3.8E-02
5.1E-03
2.8E-01
"TfE~-03
1.1E-03
3.2E-01
"4j"E-03
3.3E-03
"i~.6E-Qi.
4E-02
""7E+00
""SE+bO
""2E+df
1E+00
~"4E+02
2E-02
1E-03
4E-02
6E-01
""~3E-b"i
JOAAP Record of Decision Soil Groundwater OUs - October, 1998
lK A (RME Risks) pg. A-S
-------
SUMMARV Off RME RTSK rH4RACTFRT7
A$ ESTIMATED IN TOAAP BASELINE RTSK ASSESSMENTS
(From BRAs conducted for MFC Area (12/94) and LAP Area (2/95))
jtltc Land Usq Receptors
jHururc flndustrial"Worker" ""
[Construction Worker"
Subarfa
jOiI_Pits
j Burning Pad
- J£°PP_'?_8 Furnace
£alhHag Total Risk
^TbTc~J IE-p2|
..9ub"'"c"i ""2E-05T
Hazard
index
j lE+pq
' • 3E+00
2E-Q5
I >v^iiriu> i
(.......,.iReYfd'e'm
iResident (child)'
iGroundwater
{Surface Water
{Burning Pad
j Popping "Furnace
IpilPits
I Burning Pad
jPopping'Furnace
"jpif pits" ""
^Burning Pad
lOifp'its '
a, b, c :
_ a, b~,T ~'! 6E-02J
_a,b7c"^""""2"E-05;'
a, b, c
7E-01
-. j. 1 — j ! Northeast Area 1 a be :
«-...{..„ j. 1 ;BermedArea ! a b c •
Lo {Future .'Industrial Worker ; 1 i :- '-
^ . .. j _ j ^ a> (j, c ;
.. f 1 1 JNortheast Area ] "a,"b","c" 7
-z- — !• k- j. iBermedArea ~""t""a"b"c""1"
tf • iConstruction Worker ] 1 i j- >-
.:::>ML
'""9E;p6r
j_ 5E-03
- , —--^-.-03
"T"""5E-Of
""T"""8E-01
_!Resid"ent
! Hunter
•Resident
jGroundwater
'Northeast Area
jBermed Area ]
I Northeast Area j
jBermed Area ;
.jBermed Area Pl"urrie"""r
•Bum CageTliime t"
a, b, c
a, b, c
a, b, c
a, b, c
a,b,c
a, b, c
a, b", c
"d,e",T
d.e, f
2.E-05;
~""I"E-(M["
""8'E-05J""
3E+00
"5E-06
lE-f
2E-6_i
8E-qf
2E"-0
}£m i.V.".™:".! [Security Worker
L4 ^Future "jfridusuiafworker"
t4. '• [Construction Worker
iL4 ! ^Resident "
tf J,... 'Hunter
-4 ! jResTd'ent
L5 [Current [Security Worker
LS fFuture " [fridustriaf Worker
L5 • r
t? !. iConstruction Worker
L5 : [Res'id'e'nt
t?....L.... i
L5 ! iHunter
LS ! [
LS ! iResident ""
L6 iCurrent jSecurity Worker
j_S_oil_ j
1 •!
4 - j...
iGroundwater j
...JSoil I
J iJunkPile
1 1
....] jJunkPile
— -•!-- - -j
J j
j IJunk Pile
, _
....j jiunic Pile
IGroundwater 1
j a, b, c
.-j...?i.b.«.?...l
..!— ?i.b...?..4
j a, b, c :
j a, b, c 1
-!...?:bl?...i
! a, b, c ;
I a, b, c •
— ' :- ->•
• a, b, c ;
! a, b, c !
* a b c '
i a, b, c T
: d,e. f ;
! a, b, c ;
2E-08^ j_
....•?E:?^}..JL
2E-06| ;
2~E-05: j_
7E-07r"T
.^"'M3!"!
!E-b"li :
3E-01 [ !
3'E-Ol i i
6E "bl"' — ^
_2_E-p2[.' i
2E-06: |
4E-04
.. 8E-02
2E-bT
2E-01
fE-02
l"E-04
IE-02
3E-02
3E+0(
~~_~6E+OQ
7E"M)C
"""VpiKf
4E-01
""9E-01
"" 3E-H)6
2E-04
LO
J6
'£
J6
t§L
L6~
L6"
L6"
— L- i — - J IPCB'Spiil" Areas }'"a'b~c""\
....^H1^.1?...... .i!1}?".3.?1'?1 Worker | "i ""T"a"~b'"""T
—\ i i iPCBSpm'Arear |""a^b""c""'
...i.. JConstruction Worker ; ] .—---.— -4.
-4— — 1^£»-™
i
».k«......_.H
;;i;~;;
i
IHunter
iResident
[Resident (chTld)'
, ___
j
iGroundwater
jSurface Water
i —
J
|P_CB]5piFfAfea
— , —
,*
b,c
bVc"
h~"
_ ,_*_
J
--i
~T
*.i^~\j\jt
""j'E'-iMi"
""4"E-b4"["
^ i"E-bpi"
il^-UJ
" 6E-OS
"""7E-05
""6E-09
' _
;
I.
r-
; ic-u<*
T"""2E-02
"i "3&-02
"I.."1I-PJ"
J_
|
-I
-r
4.C.~\J 1
"""5E-03
"""8E-03
'""SE-05
JOAAP Record of Decision Soil Groundwater OUs - October, 1998
Appendix A (RME Risks) pg. A-6
-------
SUMMARY OF RME RISK CHARACTERIZATION
AS ESTIMATED IN JOAAP BASELINE RISK ASSESSMENTS
(From BRAs conducted for MFC Area (12/94) and LAP Area (2/95))
T
Site Land Use Receptors Media Subarea
L7 'Current 'Security Worker iSoil " !
L7 ; Future ; Industrial" Worker ; • ;
L7 ! ! Construction Worker ! !
L7 ; [Resident ! , i
LI \ 'Hunter ; • 1 ""
L7 [ ! Resident ! Ground water !
L7 . .Resident (child) ISurface Water !
L8 ! Current : Security Worker iSoil i
L8 [Future [Industrial Worker ; !
L8 ; : Construction Worker • !
L8 ! [Resident ; ;
L8 [ [Hunter i 1
L8 ; {Resident jGroundwater j
L8 ! (Resident (child) ISurface Water }
L9 [Current : Security Worker iSoil •
w f i - - 1 laidfrST"
L9 [ !. ! !Bidg.3-5A
L9 .Future ifndustrial Worker ! !
L9 ! . ; . 1 !B"fdg.3^4
L9 L ' i '• !BIdg.3-5~A
L9 t [Construction Worker ! !
L9 . i ;Resid~em *~" '" '" '" \ '
IQL..L i . . ! . IBidg.3^4
yL-4 ! j jBfdg.3-5A
L9 | [Hunter " """ ! "" 1
L9 1 ; i iBl"dg.3-4
t?— 4 { „ \ iBld"g.3-5A
L9 i {Resident (child) • Surface Water ;
L9 : ! Hunter iSediment !
L10 i Current : Security Worker 'Soil :
L1° ! ! ! tHotspot
L10~ [ .Industrial Worker ! i
L10 ; ; ; iliotspot
L10 ; Future i Construction Worker ; ]
Lib" i IResid'ent ; !
Lib ; j : jHotspot
Lib" ; ! Hunter ] ]
L1° [ ! iHotspot
L10 [Groundwater '.Resident | |
Lib" : Surface Wate | Resfd'ent (child) ] ]
Lll ]Current ^Security Worker iSoil i
LI 1 iFuture i industrial [Worker • ;
LI 1 [ [Construction WorVer ! !
LI] i i Resident ' :
Lll i 'Hunter ] 1 "
L13 [Current ! Security Worker iSoil !
LI 3 [Future ; Industrial Worker j j
L13 i iConstruction Worker i ;
LI 3 : 1 Resident 1 !
L13 i jHunter j 1
LI4 [Current [Security Worker ISoil i
L14 • i ! ;Hotspot
LH : JindustriafWorker ] ]
L14 [ . | • ! iHotspot
LI4 [Future [Construction Worker ' '
Pathway
a, b,c
a, b, c
a, b, c
a, b, c
a, b, c
d,e,f
h
a, b, c
a, b, c
a, b, c
a, b,c
a, b, c
de,f
h"
a,b
a,b
a,b
a,b
a,b
a,b
a,b
a,b
a,b
a, b
a,"b
a,b
a,b
h
a,b
a, b, c
a, b, c
a, b, c
a, b, c
a, b, c
a, b, c
a, b, c
a, b, c
a,b,c
d,e, f
h
a,b,c
a, b, c
a,b,c
a, b, c
a, b, c
a,b
a,b
a,b "
a.b
a,b
a,b,c
a, b, c
a, b, c
a, b, c
a, b, c
Total Risk
4E-06'
8E-b4"i
8E-05!
2E-03I
lE-04i
1E-071
4E-07i
lE-04i
IE-OS:
2E-04:
2E-05:
.. !
7E-08;"
6E-071
IE-06:
IE-06;
KE-OS;
2E-04:
2E-04!
2E-05i
7"E-04!
2"E-03!
2E-03:
2"E-bsr
5E-05i
5E-05!
3"E-07:
2E-08;
lli-05i
4E-067
2E-03!
5E-04;
2E-04:
6E-03'
5E-03;
3E-04;
2E-04i
IE-OS;
-••j&OTT"1
7E-08.'
9E-06:
IE-OS:
8E-05[
- 2E-b6t"4
7E-10!
8E-08'
3E-08";
7E-071
2E-"08;
IE-06;
7E-06
1E-04:
9E-04!
4E-05;
Hazard
Index
: 3E-OS
3E-03
3E-02
3E-02
^ 8E-04
1E-02
3E-02
4E-05
5E-03
IE-02
4E-02
1E-03
2E+00
3E-02
8E-02
5E-02
3E-01
9E+00
6E+00
3E+0!
4E-HH
r 7E+bi
SE+O:
2E+02
2E+00
1E-HX)
8E-KX)
lE-b"i
3E-Oj
2E-02
fE-bi
2E-KJO
1E+01
5E+00
1E+01
1E+02
5E-01
4E+00
9E-KK)
7E-03
9E-04
2E-01
4E-01
5E-01
3E-02
IE-OS
1E-03
6E-03
9E-03
3E-04
4E-02
2E-01
5E+00
3E+01
2E+01
JOAAP Record of Decision Soil Grouniiwater OUs - October, 199S
Appendix A (RME Risks) pg. A-7
-------
SUMMARY OF RME RISK CHARACTERIZATION
AS ESTIMATED IN JOAAP BASELINE RISK ASSESSMENTS
(From BRAs conducted for MFC Area (12/94) and LAP Area (2/95))
Site Land Use Receptors Media SMharca
L14 i .Resident ! i
.y£._i •' i iHotspot
L14 I "Hunter" " ] " 1 "
tJi_4 |. t ' iHotspot
!:J4...j •?.^s.i.d.?nt.. .... . ~ •Groundwater |
L14 { ike'sidem (child)""" ISufface'Watef 1 "
rJA.-LfH.'H.1!?.. [Industrial Worker ] ] " ""
;15___[ ___ -Construction Worker j " 1
-15 • -Resident i 1
US"- -Humer ''} """" ] "
L16 "Current -Security Worker iSoil 1
Lie"",' ifndusrriafWorker" 1 1 "
yJLj. i L iHotspot
.16 sFuture [Construction Worker : •
LI 6 !_ [Resident : ;
y.6-4 1 , . ! JHotspot
L16 : -Hunter ""j 1 """
y£..L ; i IHotspot.
L16 | :Re~s~id~ent(ch'iId)~ iSufface Water 1
r..'...l i ; JHotspot
.17 | -Industrial Worker ! i "
.......i i. : ;Hotspot
L17 [Future JConstruction Worker 1 } ~~:"
LI 7 ; jResident - i
:l?...l ,.• • _ jHotspot
.17 'w !Hunter V 1 " "'
tJ ?...'r •.... { iHotspot
L17 ; :Resident (child) """"]Surfa"ce"Water ]
.23 ! iConstruclion Worker " 1 1
L23 • [Resid'ent 1 ;
L23":" -HGnter " 1
-32]__|^Fimire ifndustriafWorker ~j " 1 ""'
•32 : [Construction Worker 1 "1
L32" [ :Resi"d"ent i 1
L32 : ;Hunter 1 "' "I"'" "
]33__^Fuoire_ ifndustriafWorker ""1 } "
J3 ; ; Construction Worker i ]
L33__J ___ JResident : :
J3 • -Hunter i 1"
:?5-4?.H!S!P..... ifndustriafWorker" 1 " j
J4 j jConstruction Worker ; •
I5.4""[ [Resident 1 T~~ " ""
L34"": IHuiiter 1 ', "
SW rCurrent 'Fisherman [Surface Water : Jordan Creek
§w...l i ! IPrairie Creek
Pathway
a, b, c
a, b, c
a, b, c
h""
a,b
"JjijL'.
""?•?"
a, b, c
a, b, c
a, b", c
a, b, c
a, b, c
a, b, c
a, b~, c"
a, b, c
a, b, c
a, b, c
"aibVc"
a, b, c
a, b, c
a, b, c
a, b, c
d, e,f
d,e, f
a,b
a.b
..........
a.b
—..„...
a, b
""arb""
..........
a,b
a,b
a, b
..........
.„„..-..
...........
a,b
-Jf-
.-.„..—.
..........
g h
g.h
Iota. Bisk
IE-03 i
8E-03i
3E-04!
2E-68:"
4E-IO;
""" "sE-bsT
~"~ "2E-b8T
4E-b7"i"
"lE-bsT"
2E-06!
IE-OS!"
""3E-b4T"
IE-03!
•JE-b3r
IE-02[_
4E-04[
""4E-08!""
5E-06!
' "TE-b3i "
2E:02[__
3Eb3;"
4E-02T
...3?:S?.L
. . ,
. . •
-------
SUMMARV OF RME RISK CHARACTERIZATION
AS ESTIMATED IN .TOAAP BASELINE RISK ASSESSMENTS
(From BRAs conducted for MFC Area (12/94) and LAP Area (2/95))
Site
sw
sw""
sw
sw"""
sw""
^^^^^^
Land Use Receptors
._ ___ iConsumerofFish
.---.____, — --—-!._.. .»___,_
Media Subarea
jKemery Lake
j Jordan Creek
IPrairie Creek
_ 'Kemery Lake
^Jord'an Creek
jPrairie Creek
IKemeryLake
Pathway Total Risk
_.__g,h ; 2E-05
— -]l-!!!lZ[XI:?H--"
i___^ ^E;04i_
---JjJi.]T^^2"E}08[[^
g,"h : 6E-06:
Hazard
Index
6E-01
^~jE-bi
' 2E-HW
2E+00
lE-Ol"
"9E-b"f
"SE-Ol"
NOTES;
Scenarios and risk calculations are as they were estimated in Baseline Risk Assessments of
1994 (MFC Area) and 1995 (LAP Area).
KEXi
Exposure Pathways
a
b
c
d
e
f
g
h
Subareas
blank
CTF
EWD
UP
NAD/AP
ND
NP
OSTA
Other
SAD
SD
SIP
SP
TJC
TL
TNTD
WTF
Ingestion of soil
Inhalation of soil as dust
Dermal absorption of contaminants in soil
Ingestion of groundwater
Inhalation of volatiles emitted from groundwater during showering
Dermal absorption of contaminants in groundwater during showering
Ingestion of surface water
Dermal absorption of contaminants in surface water
Consumption offish that have bioconcentrated contaminants from surface water
Blank locations in "SUBAREA" column refer to the entire site.
Central Tank Farm (M10)
East-West Ditch (M5)
Middle Plume (M8)
Northern Acid Ditch and Acid Ponds (MS)
North Ditch (Ml5)
Mortem Plume (MS)
Open Storage Tank M(M7)
Areas other than TNT Ditch (M6)
Southern Acid Ditch (MS)
South Ditch (MI5)
Small Intermittent Pond (M7)
Southern Plume (MS)
Tributaries to Jackson Creek (M8)
Tetryl Line (MS)
TNT Ditch (M6 and M7)
Western Tank Farm (M 10)
Risk Calculation (last three columns)
denotes that either a slope factor or RfD is not available.
S The oral and inhalation slope factors for benzo(a)pyrene are used as surrogates for all B2 PAHs
T The toxic equivalent factors were applied to B2 PAHs to develop individual slope factors relative to
faenzo(a)pyrene because the surrogate approach resulted in risks between IE - 03 and 1E-06.
JOAAP Record of Decision Soil Groundwater OUs - October, 1998
Appendix A (RME Risks) pg. A-9
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APPENDIX B
Summary of Estimated Costs nf
Remedial Alternatives for All SRTJs and GRUs
JOAAP Record of Decision - Soil & Groundwater OUs - October, 1998 Revision 1 - 10/27/98 Appendix B
-------
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Summary of Estimated Costs of Remedial Alternatives for All SRUs and GRUs
PS-1 qf "2
Remedial Unit
and Sites
SRU!: Explosives
L!,L7,L8,L9,L10,
L14,L16,M2,M3,M5,
M6, M7
SRU2: Metals
L2,L3,L5,LI1,L23A,
M3,M4,M12
SRU3: Explosives and
Metals
L2,L3,M5,M6
L1,L5,L7,L8,L9,L10,
LI7
L1.L5
L3,L4,M1,M9,M11,
M13
M8.M12
Selected
Alternative?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
JOAAP Area /
Alternative Specific Sites
2: Institutional Controls All SRU 1
3: Bioremediation A11SRU1
4: On-site Incineration All SRU 1
5: Excavation and Disposal A11SRU1
2: Institutional Controls All SRU2
3: Stabilization/Solidification All SRU2
4: Excavation and Disposal All SRU2
2: Institutional Controls A11SRU3
3: Bioremediation MFC SRU3 only
4: On-site Incineration A11SRU3
5: Excavation and Disposal LAP SRU3 only
3: Chemical Dehalogenation All SRU4
4: Low Temperature Thermal
Oesorptton All SRU4
5: Excavation/Incineration and
Disposal AH SRU4
3: Bioremediation All SRUS
4: Solvent Extraction L5 Drainage Ditch
5: Low Temperature Thermal
Desorption All SRUS
6: Excavation and Disposal All SRUS
3: Capping LAP-L3
3: Capping MFC -Mil
3: Capping MFG-M13
4: Excavation and Disposal LAP - L4
4: Excavation and Disposal MFC -Ml
4: Excavation and Disposal MFC - M9
Subtotal for Landfill Remedies All SRU6
3: Remove/Recycle/Disposal AIISRU7
Volume Total Cos
(CYorMG) (NPV)
151,480 $ 3,000,000
151,480 $ 39,300,000
151,480 $ 76,600,000
151,480 $ 23,100,000
22,940 $ 300,000
22,940 $ 6,700,000
22,940 $ 4,000,000
30,920 $ 300,000
13,500 S 4,000,000
30,920 S 15,800,000
17,420 $ 2,800,000
3,416 $ 8,000
3,416 $ 4,100,000
3,416 $ 2,400,000
3,416 $ 1,400,000
2,410 $ 100,000
2,410 $ 2,200,000
555 $ 1,300,000
2,410 $ 1,800,000
2,410 $ 300,000
689,800 $ 3,000,000
35,000 $ 500,000
66,600 $ 16,600,000
222,000 $ 2,800,000
37,000 S 1,200,000
205,200 $ 6,800,000
124,000 S 4,100,000
689,800 S 32,000,000
7,500 $ 100,000
7,500 $ 200,000
Years
(2)
30
1
30
1
1
30
1
2
1
30
I
1
1
30
1
1
1
1
30
30
30
30
1
1
1
1/30
30
1
Capital Annual O&M SiteCIoseout
$ 1,500,000 $ 130,000 $ 20,000
$ 13,800,000 S 9,400,000 $ 900,000
$ 10,000,000 $ 34,800,000 $ 4,100,000
S 23,100,000 $ - $
$ 200,000 $ 10,000 S 2,000
S 6,700,000 $ - $
S 4,000,000 S $
$ 100,000 $ 10,000 $ 2,000
S 1,300,000 $ 1,000,000 $ 96,000
$ 2,000,000 $ 7,200,000 $ 870,000
S 2,800,000 $ - S
S 5,000 $ 2,000 $
$ 4,100,000 $ - $
$ 2,400,000 $ - $
$ 1,400,000 S - $
S 100,000 S 300 S
$ 2,200,000 $ $
$ 1,300,000 $ - $
$ 1,800,000 $ - $
$ 300,000 S $
$ 800,000 S 180,000 $ 48,000
S 600,000 S 3,000 S
S 14,200,000 $ 186,000 $ 71,000
S 2,400,000 S 31,000 S 12,000
S 1,200,000 $ - $
S 6,800,000 S - S
S 4.100,000 $ S
S 29,000,000 S 200,000 S 100,000
$ 100,000 $ 300 $
S 200,000 $ $
JOAAP Record of Decision - Soil Groundwater OUs~ October, 1998
Revision 1 - JO/27/98
pg. B-l
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Summary of Estimated Costs of Remedial Alternatives for All SRUs and GRUs (com.)
pg,2of2
Remedial Unit
and Sites
GRUI: Explosives
-LAP Area
L1.L2, L3, L14
Other Contaminants -
MFC Area
M1,M5,M6,M7,M8,
M13
GRU3: Volatile Organic
Compounds -MFC
Area
M3.M 10 (Western and
Central Tank Farms)
Total SRUs
Total GRUs
Grand Total
Alternative?
Yes
Yes
Yes
JOAAP Area /
Alternative Specific Sites
2: Limited Action All GRUI
3: Pump and Treat with Carbon
Adsorption All GRUI
2: Limited Action AIIGRU2
3: Pump and Treat with Bioreactor AH GRU2
4: Pump and Treat with Carbon
Adsorption All GRU2
5: Pump and Treat with UV
Oxidation / Carbon Adsorption All GRU2
2: Limited Action A11GRU3
3: In-Situ Bioremediation A11GRU3
4: Pump and Treat with Air
Stripping/ Vapor Phase AH GRU3
5: Pump and Treat with Carbon
Adsorption All GRU3
6: Pump and Treat with UV
Oxidation / Carbon Adsorption All GRU3
Selected Remedial Alternatives SRUs
Selected Remedial Alternatives GRUs
Selected Remedial Alternatives SRUs and GRUs
Volume Total Cost
(CYorMC) (NPV)
87 S 530,000
87 $ 3,800,000
542 $ 3,300,000
542 $ 13,700,000
542 $ 16,500,000
542 $ 1(5,400,000
3 S 700,000
3 $ 2,100,000
3 S 2,100,000
3 $ 2,100,000
3 $ 2,400,000
908,466 CY $ 84,000,000
632 MG $ 4.530.000
$ 88,530.000
Years
(2)
30
30
30
30
30
30
30
8
8
8
8
Component Costs (in current year value)
Capital Annual O&M Site Closeou!
S 50,000 S 40,000 S ' -
$ 1,100,000 S 300,000 $
S 900,000 S 190,000 $ 14,000
S 8,100,000 $ 400,000 $
$ 5,500,000 $ 700,000 $
$ 7,800,000 $ 700,000 S
S 70,000 $ 50,000 $ 30,000
$ 1,000,000 $ 200,000 $ 100,000
$ 1,400,000 $ 100,000 $ 100,000
$ 1,400,000 $ 100,000 $ 100,000
$ 1,600,000 S 100,000 $ 100,000
$ 53,000,000 5 11,000,000
$ 1.020.000 S 280.000 See Noted)
$ 54,020,000 $ 11,280,000
Notes: (1) Selected remedial alternatives are highlighted in bold font.
(2) Years show the estimated time to complete from the first year of implementation through completion of operations and maintenance.
Maximum of 30 years is shown for purpose of the economic analysis presented in table. Time to reach RGs may exceed the 30 years shown.
(3) Summary of component costs is appropriate only if all have been discounted to same year values (such as present year values).
JOAAP Record of Decision - Soil Groundwater OUs - October, 1998
AAPl
Revision 1 -10/27/98 *^ pg. B-2
x.
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