PB96-964419
EPA/ROD/R08-96/129
April 1997
EPA Superfund
Record of Decision:
Rocky Mountain Arsenal (US Army),
On-Post Site Operable Unit, Adams County, CO
6/11/1996
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U.S. ARMY
MATERIEL COMMAND
•PROGRAM MANAGER FOR
£ROCKY MOUNTAIN ARSENAL
—COMMITTED TO PROTECTION OF THE ENVIRONMENT—
Record of Decision
for the On-Post Operable Unit
Volume 1
Sections 1-11
Version 3.1
June 1996
Contract No. DAAA 05-92-D-0002
FOSTER WHEELER ENVIRONMENTAL CORPORATION
Montgomery Watson
International Dismantling & Machinery
Ageiss Environmental
Hazen Research
DataChem
BC Analytical
Requests for copies of this document should be referred
to the Program Manager for Rocky Mountain Arsenal
AMCPM Commerce City, Colorado 80022-1748
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TECHNICAL SUPPORT FOR
ROCKY MOUNTAIN ARSENAL
Record of Decision
for the On-Post Operable Unit
Volume 1
Sections 1-11
Version 3.1
June 1996
Contract No. DAAA 05-92-D-0002
Prepared by:
Foster Wheeler Environmental Corporation
Prepared for:
U.S. Army Program Manager's Office for the
Rocky Mountain Arsenal
This document is intended to comply with the National Environmental Policy Act of 1969.
The information and conclusions presented in this report represent the official position of the Department of the Army unless
expressly modified by a subsequent document. This report constitutes the relevant portion of the administrative record for this
CERCLA operable unit.
The use of trade names in this report does not constitute an official endorsement or approval of the use of such commercial
products. This report may not be cited for purposes of advertisement.
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Table of Contents
Table of Contents
Declaration D-1
Decision Summary
1.0 Site Name, Location, and Description 1-1
1.1 Environmental Setting , 1-1
1.1.1 Physiography 1-1
1.1.2 Climate 1-2
1.1.3 Existing Cultural Features 1-2
1.1.4 Cultural Resources 1-3
1.2 Geology 1-4
1.3 Hydrology 1-4
1.4 Biological Habitat , 1-5
2.0 Site History and Enforcement Activities 2-1
2.1 Production and Operational History 2-1
2.2 Waste Disposal Operations 2-3
2.3 Previous Investigations 2-4
2.4 Past and Ongoing Response Actions 2-5
2.5 History of Enforcement Activities 2-10
2.5.1 CERCLA Enforcement Activities 2-10
2.5.2 State Enforcement Activities 2-12
2.5.3 Conceptual Remedy 2-14
3.0 Highlights of Community Participation 3-1
4.0 Scope and Role of the On-Post Operable Unit 4-1
5.0 Summary of Site Characteristics 5-1
5.1 Sources of Contamination 5-1
5.2 Nature of Contamination 5-1
5.3 Contaminant Migration Pathways 5-1
5.4 Extent of Contamination 5-2
5.5 Potential Human and Environmental Exposure 5-8
6.0 Summary of Site Risks 6-1
6.1 Human Health Risk Characterization 6-1
6.1.1 Identification of Contaminants of Concern 6-2
6.1.2 Exposure Assessment 6-3
6.1.2.1 Characterization of Exposure Setting and Potentially Exposed Populations 6-3
6.1.2.2 Identification of Exposure Pathways 6-4
6.1.2.3 Estimation of Exposure Point Concentrations 6-5
6.1.2.4 Exposure Parameters 6-6
6.1.3 Toxicity Assessment 6-6
6.1.4 Risk Characterization 6-8
6.1.4.1 Calculation of PPL Vs 6-8
6.1.4.2 Determination of Carcinogenic and Noncarcinogenic Risks 6-10
6.2 Ecological Risk Characterization 6-14
6.2.1 Identification of Contaminants of Concern 6-15
6.2.2 Exposure Assessment 6-15
6.2.3 Toxicity Assessment.... 6-17
6.2.4 Risk Characterization 6-19
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6.2.4.1 Methods 6-19
6.2.4.2 Results 6-20
6.2.4.3 Continuing Biological Studies 6-22
6.3 Uncertainty Analysis 6-24
6.3.1 Human Health Risk Characterization 6-25
6.3.1.1 Chemical Database 6-25
6.3.12 Exposure Point Concentration 6-25
6.3.1.3 Land-Use and Exposure Scenarios 6-25
6.3.1.4 Human Health Toxicity Estimates 6-26
6.3.1.5 Exposure Parameters and PPLVs 6-26
6.3.1.6 Risk Estimates 6-27
6.3.2 Ecological Risk Characterization 6-28
6.3.2.1 Chemical Database 6-28
6.3.2.2 Exposure Pathways 6-28
6.3.2.3 Exposure Concentrations 6-28
6.3.2.4 Ecological Toxicity Estimates 6-29
6.3.2.5 Risk Estimates 6-30
6.3.2.6 Ecological Measurement Endpoints 6-30
6.4 Conclusions 6-31
7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed ...7-1
7.1 Summary of the Feasibility Study Process 7-1
7.1.1 Area of Contamination 7-2
7.1.2 Corrective Action Management Unit 7-3
7.1.3 Development of Criteria for Evaluating Soil Contamination 7-4
7.1.4 Soil Volume Modeling and Estimation 7-5
7.2 Remedial Alternatives for Groundwater 7-7
7.2.1 Description of Medium 7-7
7.2.2 Remedial Action Objectives 7-7
7.2.3 Description of Sitewide Remedial Alternatives for Groundwater 7-8
7.2.3.1 Alternative 1 -Boundary Systems 7-8
7.2.3.2 Alternative 2 - Boundary Systems/IRAs 7-11
7.2.3.3 Alternative 3 - Boundary Systems/IRAs/On-Post Dewatering 7-13
7.2.3.4 Alternative 4 - Boundary Systems/IRAs/Intercept Systems 7-14
7.3 Description of Sitewide Remedial Alternatives for Structures 7-15
7.3.1 Description of Medium 7-15
7.3.2 Remedial Action Objectives 7-15
7.3.3 Description of Sitewide Remedial Alternatives for Structures 7-16
7.3.3.1 Alternative 1 - Landfill/Cap in Place 7-18
7.3.3.2 Alternative 2 - Landfill/Consolidate 7-19
7.3.3.3 Alternative3-Landfill 7-19
7.4 Description of Sitewide Remedial Alternatives for Soil 7-20
7.4.1 Description of Medium 7-20
7.4.2 Remedial Action Objectives 7-20
7.4.3 Description of Sitewide Remedial Alternatives for Soil 7-20
7.4.3.1 Alternative 1-Caps/Covers 7-21
7.4.3.2 Alternative 2 - Landfill/Caps 7-22
7.4.3.3 Alternative 3 - Landfill 7-23
7.4.3.4 Alternative 4 - Consolidation/Caps/Treatment/Landfill 7-24
7.4.3.5 Alternative 5 - Caps/Treatment/Landfill 7-27
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Table of Contents
8.0 Comparative Analysis of Alternatives ... 8-1
8.1 Comparative Analysis of Alternatives for Groundwater 8-1
8.1.1 Overall Protection of Human Health and the Environment 8-1
8.1.2 Compliance with ARARs 8-2
8.1.3 Long-Term Effectiveness and Permanence 8-2
8.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment 8-3
8.1.5 Short-Term Effectiveness 8-3
8.1.6 Implementability 8-4
8.1.7 Cost 8-4
8.1.8 State Acceptance 8-4
8.1.9 Community Acceptance 8-4
8.1.10 Conclusions 8-5
8.2 Comparative Analysis of Alternatives for Structures 8-6
8.2.1 Overall Protection of Human Health and the Environment 8-6
8.2.2 Compliance with ARARs 8-6
8.2.3 Long-Term Effectiveness and Permanence 8-6
8.2.4 Reduction of Toxicity, Mobility, or Volume Through Treatment 8-7
8.2.5 Short-Term Effectiveness 8-7
8.2.6 Implementability 8-8
8.2.7 Cost 8-8
8.2.8 State Acceptance 8-8
8.2.9 Community Acceptance 8-9
8.2.10 Conclusions 8-9
8.3 Comparative Analysis of Alternatives for Soil 8-9
8.3.1 Overall Protection of Human Health and the Environment 8-10
8.3.2 Compliance with ARARs 8-10
8.3.3 Long-Term Effectiveness and Permanence .....8-11
8.3.4 Reduction of Toxicity, Mobility, or Volume Through Treatment 8-12
8.3.5 Short-Term Effectiveness 8-12
8.3.6 Implementability : 8-13
8.3.7 Cost 8-14
8.3.8 State Acceptance 8-14
8.3.9 Community Acceptance 8-14
8.3.10 Conclusions 8-15
9.0 Identification of the Selected Remedy 9-1
9.1 Groundwater Alternative 4 -Boundary Systems/IRAs/Intercept Systems 9-1
9.2 Structures Alternative 2 - Landfill/Consolidate 9-3
9.3 Soil Alternative 4 - Consolidation/Caps/Treatment/Landfill 9-3
9.4 Additional Components of the Selected Remedy 9-7
9.5 Remediation Goals and Standards 9-10
9.6 Cost of the Selected Remedy 9-10
9.7 Long-Term Operations 9-10
10.0 Statutory Determinations 10-1
10.1 Consistency with the Statutory Requirements of CERCLA hi Section 121 10-1
10.1.1 Protection of Human Health and the Environment 10-1
10.1.1.1 Groundwater 10-1
10.1.1.2 Structures 10-2
10.1.1.3 Soil 10-2
10.1.1.4 Additional Components of the Remedy 10-3
10.1.2 Compliance with ARARs 10-5
10.1.2.1 Chemical-Specific ARARs 10-5
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10.t.2.2 Location-Specific ARARs 10-6
10.1.2.3 Action-Specific ARARs 10-7
10.1.2.4 Other Requirements 10-7
10.1.3 Cost Effectiveness 10-7
10.1.4 Utilization of Permanent Solutions to the Maximum Extent Practicable 10-7
10.2 State and Community Acceptance 10-8
10.2.1 State Acceptance 10-8
10.2.2 Community Acceptance 10-8
10.3 Consistency with NCP 10-8
10.4 Consistency with NEPA 10-9
10.5 Summary 10-9
11.0 Documentation of Significant Changes 11-1
12.0 Responsiveness Summary 12-1
12.1 Introduction 12-1
12.2 History of Community Relations Activities 12-1
12.3 Responses to Comments 12-3
Glossary G-1
Bibliography B-1
Appendices
A Applicable or Relevant and Appropriate Requirements
B Agreement in Principle Regarding a Water Supply Between the Army, Shell, and SACWSD
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List of Figures
List of Figures
Figure
D-1 RMA Operable Units
1.0-1 RMA Site Map
2.3-1 Remedial Investigation/Endangerment Assessment/Feasibility Study Flow Diagram
2.4-1 RMA Interim Response Action Locations
2.4-2 Typical RMA Interim Response Action Process
5.4-1 RMA Soil Medium Groups
5.4-2 Potential Agent/UXO Presence Areas
5.4-3 Generalized Contaminant Plume Locations
6.1-1 Projected Land-Use Scenarios for RMA
6.1 -2 RMA Site Conceptual Model for Human Receptors
6.1-3 RMA Site Designations used in the HHRC
6.1-4 Total Site Cancer Risks for Biological Worker, Horizon 0
6.1 -5 Total Site Hazard Indices for Biological Worker, Horizon 0
6.1-6 Cancer Risk Summary for All Receptors Based on Site-Specific (C^up^) Results, Horizon 0
6.1-7 Hazard Index Summary for All Receptors Based on Site-Specific (C,^iUppCT) Results, Horizon 0
6.1-8 Map of Surficial Soil Incremental Cancer Risks for the Biological Worker
6.1-9 Human Health Carcinogenic Exceedance Areas, Horizon 0
6.1-10 Human Health Carcinogenic Exceedance Areas, Horizon 1
6.1-11 Human Health Noncarcinogenic Exceedance Areas, Horizon 0
6.1-12 Human Health Noncarcinogenic Exceedance Areas, Horizon 1
6.1-13 Human Health Exceedance Areas, Horizon 0
6.1-14 Human Health Exceedance Areas, Horizon 1
6.1-15 Acute Exceedance Sample Locations
6.2-1 RMA Site Conceptual Model for Ecological Receptors
6.2-2 Number of Trophic Boxes with Soil Hazard Indices Greater than 1.0 for AH COCs Combined Based
on the Shell Approach
6.2-3 Number of Trophic Boxes with Soil Hazard Indices Greater than 1.0 for Aldrin/Dieldrin, DDT/DDE,
and Endrin Combined Based on the Shell Approach
6.2-4 Aldrin/Dieldrin Hazard Quotient Map (HQ > 1) for the Great Homed Owl Trophic Box Based on
Exceedance of TRY and using the Army, EPA, and Shell Approaches
6.2-5 Aldrin/Dieldrin Hazard Quotient Map (HQ > 1) for the Small Mammal Trophic Box Based on
Exceedance of TRY and using Army, EPA, and Shell Approaches
6.2-6 Human Health and Biota Risk Areas
6.2-7 Pre-Remediation Risk Distribution using Army BMP for American Kestrel
6.2-8 Pre-Remediation Risk Distribution using EPA BMP for American Kestrel
6.2-9 Pre-Remediation Risk Distribution using Army BMF for Great Horned Owl
6.2-10 Pre-Remediation Risk Distribution using EPA BMF for Great Horned Owl
6.2-11 Residual Risk Distribution using Army BMF for American Kestrel
6.2-12 Residual Risk Distribution using EPA BMF for American Kestrel
6.2-13 Residual Risk Distribution using Army BMF for Great Horned Owl
6.2-14 Residual Risk Distribution using EPA BMF for Great Horned Owl
7.1-1 Human Health Exceedance Areas and Biota Risk Area
7.4-1 Caps/Covers Alternative
7.4-2 Landfill/Caps Alternative
7.4-3 Landfill Alternative
7.4-4 Consolidation/Caps/Treatment/Landfill Alternative
7.4-5 Caps/Treatment/Landfill Alternative
8.0-1 Cleanup Evaluation Criteria
9.1-1 Alternative 4: Continued Operation of Existing Boundary Systems and IRAs and Extraction from
Section 36 Bedrock Ridge
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Record of Decision for the On-Post Operable Unit
Figure
9.3-1 Selected Soil Remedy—Consolidation/Caps/Treatment/Landfill
9.3-2 Section 26 Excavation Areas and Cap/Cover Components
9.3-3 Section 36 Excavation Areas and Cap/Cover Components
9.3-4 South Plants Excavation Areas and Cover Components
9.3-5 Containment Systems for Exceedances Remaining in Place following Remediation
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List of Tables
List of Tables
Table
2.3-1 Inception and Completion Dates for Major RMA Documents
2.4-1 Summary of Past and Ongoing Response Actions
2.4-2 Media Potentially Impacted by Past and Ongoing Response Actions
3.0-1 Area Libraries Holding RMA Documentation
4.0-1 Description of the Remedy for the Off-Post Operable Unit
5.4-1 Primary Contaminant Concentrations in the North Boundary Plume Group
5.4-2 Primary Contaminant Concentrations in the Northwest Boundary Plume Group
5.4-3 Primary Contaminant Concentrations in the Western Plume Group
5.4-4 Primary Contaminant Concentrations in the Basin A Plume Group
5.4-5 Primary Contaminant Concentrations in the South Plants Plume Group
5.4-6 Inventory of Future Use, No Potential Exposure Medium Group
5.4-7 Inventory of No Future Use, Significant Contamination History Medium Group
5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
5.4-9 Inventory of No Future Use, Agent History Medium Group
5.4-10 Soil Exceedance Categories, Medium Groups, and Subgroups
5.4-11 Summary of Soil Medium Groups and Subgroups
5.4-12 Summary of Contaminant Concentrations Within the Soil Exceedance Volumes
6.1-1 Chemicals of Concern for the IEA/RC
6.1-2 Soil Horizons and Exposure Pathways Evaluated for the HHRC
6.1-3 Time-Dependent and Other Parameter Values
6.1 -4 Chemical-Specific Parameter Values
6.1-5 Summary of Data Sources for PPLV Direct and Indirect Equation Parameters
6.1-6 RME Estimates for Acute Exposure
6.1-7 RME Estimates for Subchronic Exposure
6.1-8 Carcinogenic Dose-Response Data
6.1-9 Chronic Noncarcinogenic Dose-Response Data
6.1-10 DT Values for Acute and Subchronic Exposure
6.1-11 Summary of Chronic Cumulative Direct Soil PPLVs for the 5th Percentile
6.1-12 Summary of Chronic Cumulative Direct Soil PPLVs for the 50th Percentile
6.1-13 Summary of 5th Percentile Direct Single-Pathway PPLVs for the Biological Worker
6.1-14 Summary of 5th Percentile Direct Single-Pathway PPLVs for the Recreational Visitor
6.1 -15 Summary of 5th Percentile Direct Single-Pathway PPLVs for the Regulated/Casual Visitor
6.1-16 Summary of 5th Percentile Direct Single-Pathway PPLVs for the Industrial Worker
6.1-17 Summary of 5th Percentile Direct Single-Pathway PPLVs for the Commercial Worker
6.1-18 Summary of Sites with C^ Values Exceeding 5th Percentile PPLVs in Horizon 0
6.1-19 Summary of Acute RME PPLVs for Cumulative Direct Soil Exposure Pathway
6.1 -20 Summary of Subchronic RME PPLVs for Cumulative Direct Soil Exposure Pathway
6.2-1 Mean BMP Calculated by Alternate Methods
6.2-2 ERC Model Input Parameter Values
6.2-3 Uncertainty Factor Protocol
6.2-4 Toxicity Threshold Values Selected for Representative Receptors (Trophic Boxes)
6.2-5 Toxicity Reference Value (Post-UF)
6.2-6 Post-Uncertainty MATC
6.2-7 HQs and His for Exposure through Aquatic Food Chains
6.3-1 Uncertainties Potentially Influencing Assigned Distributions for Soil Intake Parameters
6.3-2 Uncertainties Potentially Influencing Assigned Distributions for Time-Dependent Exposure
Parameters
6.3-3 Uncertainties Potentially Influencing Assigned Distributions for Chemical-Specific Parameters
7.1 -1 Description of Water Technologies
7.1-2 Description of Structures Technologies
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Table
7.1-3 Description of Soil Technologies
7.1-4 Site Evaluation Criteria and Principal Threat Criteria for Soil
7.1-5 Soil Exceedance Volumes by Medium Group
7.1-6 Soil Exceedance Areas by Medium Group
7.2-1 Description of Water Alternatives
7.2-2 Capital and O&M Costs for Water Alternatives
7.3-1 Description of Structures Alternatives
7.3-2 Capital and O&M Costs for Structures Alternatives
7.4-1 Description of Soil Alternatives
7.4-2 Capital and O&M Costs for Soil Alternatives
8.1-1 Comparative Analysis of Water Alternatives
8.2-1 Comparative Analysis of Structures Alternatives
8.3-1 Comparative Analysis of Soil Alternatives
9.1-1 CSRGs for the Northwest Boundary Containment System
9.1-2 CSRGs for the Irondale Containment System
9.1-3 CSRGs for the North Boundary Containment System
9.1-4 CSRGs for the Basin A Neck IRA Treatment System
9.3-1 Summary of the Selected Soil Remedy
9.3-2 Final Disposition of Soil Exceedance Volumes
9.3-3 Untreated Soil Exceedance Volumes Remaining in Place
9.3-4 Cap and Soil Cover Components
9.5-1 Remediation Goals and Standards for the On-Post Operable Unit
9.6-1 Total Estimated Cost for the Selected Remedy
10.1-1 Summary of Location-Specific ARARs for the Selected Alternatives
10.1 -2 Summary of Chemical-Specific ARARs for the Selected Alternatives
10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
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List of Acronyms and Abbreviations
List of Acronyms and Abbreviations
°F Degrees Fahrenheit
Hg Microgram
95% LCL 95 Percent Lower Confidence Limit
95% UCL 95 Percent Upper Confidence Limit
ACGIH American Conference of Governmental Industrial Hygienists
ACM Asbestos-Containing Material
AOC Area of Contamination
APEN Air Pollution Emission Notice
ARAR Applicable or Relevant and Appropriate Requirements
Army U.S. Army
ATM Atmospheres
ATSDR U.S. Agency for Toxic Substances and Disease Registry
BAF Bioaccumulation Factor
BAS Biological Advisory Subcommittee
BCHPD Bicycloheptadiene
BCRL Below Certified Reporting Limits
BCY Bank Cubic Yards
BOAT Best Demonstrated Available Technology
BMP Biomagnification Factor
BNA Bureau of National Affairs
bw Body Weight
CAC Citizens Against Contamination
CAMU Corrective Action Management Unit
CBSG Colorado Basic Standards for Groundwater
CBSM Colorado Basic Standards and Methodologies for Surface Water
CCR Code of Colorado Regulations
CDD CAMU Designation Document
CDPHE Colorado Department of Public Health and Environment
CERCLA Comprehensive Environmental Response, Compensation and Liability Act of 1980
CF&I Colorado Fuel and Iron
CFR Code of Federal Regulations
CFS Confined Flow System
CHWMA Colorado Hazardous Waste Management Act
cm Centimeter
cm2 Centimeter Squared
cm3 Centimeter Cubed
Cmax Maximum Contaminant Concentration
COC Contaminant of Concern
Conceptual
Remedy Agreement for a Conceptual Remedy for the Cleanup of the Rocky Mountain Arsenal
CPMS Chlorophenylmethylsulfide
CPMSO2 Chlorophenylmethylsulfone
Crep,me«n Arithmetic Mean of Contaminant Concentration
Crupper Arithmetic Mean of Contaminant Concentration, 95% Upper Confidence Limit
CSRG Containment System Remediation Goal
CWA Clean Water Act
DBCP Dibromochloropropane
DCPD Dicyclopentadiene
DDE Dichlorodiphenyldichloroethene
DDT Dichlorodiphenyltrichloroethane
DIMP Diisopropylmethyl Phosphonate
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DT Critical Toxicity Value
DW Exposure Frequency
EPA U.S. Environmental Protection Agency
ERC Ecological Risk Characterization
ESC Exposure Soil Concentration
FFA Federal Facility Agreement
FS Feasibility Study
FR Dietary Fraction
ft Foot/Feet
g/mole Gram Per Mole
GAC Granular Activated Carbon
GB Sarin
GC/MS Gas Chromatography/Mass Spectrometry
GIS Geographic Information System
gpm Gallons Per Minute
HCCPD Hexachlorocyclopentadiene
HCL Hydrogen Chloride
HD Distilled Mustard
HE High Explosive
HHEA Human Health Endangerment Assessment
HHRC Human Health Risk Characterization
HI Hazard Index
HQ Hazard Quotient
Hyman Julius Hyman and Company
ICS Irondale Containment System
IEA/RC Integrated Endangerment Assessment/Risk Characterization
IMPA Isopropyhnethyl Phosphonate
IRA Interim Response Action
JARDF Joint Administrative Record Document Facility
kg Kilogram
I Liter
LANL Light Nonaqueous Phase Liquid
Ib Pound
LDR Land Disposal Restriction
LNAPL Light Nonaqueous Phase Liquid
LOAEL Lowest Observed Adverse Effect Level
LOEL Lowest Observed Effect Level
m Meter
m3 Cubic Meter
MATC Maximum Allowable Tissue Concentration
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
mg Milligram
MMAG Medical Monitoring Advisory Group
mph Miles Per Hour
MSEC Mountain State Employer's Council, Inc.
NBCS North Boundary Containment System
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NDMA N-Nitrosodimethylamine
NEPA National Environmental Policy Act
NESHAPS National Emissions Standards for Hazardous Air Pollutants
NIOSH National Institute for Occupational Safety and Health
NOAEL No Observed Adverse Effect Level
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List of Acronyms and Abbreviations
NPL t National Priorities List
NRD Natural Resource Damage
NWBCS Northwest Boundary Containment System
O&M Operations and Maintenance
OCP Organochlorine Pesticide
OPHBG Organophosphorus Compounds, Agent Related
OPHP Organophosphorus Compounds, Pesticide Related
Organizations U.S. Army, Shell Oil Company, U.S. Environmental Protection Agency, U.S. Fish and
Wildlife, U.S. Agency for Toxic Substances and Disease Registry, and U.S. Department of
Justice
OSCH Organosulfur Compounds, Herbicide Related
OSCM Organosulfur Compounds, Mustard Related
OSHA Occupational Safety and Health Act
Parties U.S. Army, Shell Oil Company, U.S. Environmental Protection Agency, U.S. Fish and
Wildlife, and State of Colorado
PCB Polychlorinated Biphenyl
PAO Public Affairs Office
PMRMA Program Manager for Rocky Mountain Arsenal
ppb Part Per Billion
PPLV Preliminary Pollutant Limit Value
ppm Part Per Million
ppt Part Per Trillion
PSCo Public Service Company of Colorado
PVC . Polyvinyl Chloride
RAB Restoration Advisory Board
RAF Relative Absorption Factor
RAO Remedial Action Objective
RCRA Resource Conservation and Recovery Act
RF Radio Frequency
RfC Reference Concentration
RfD Reference Dose
RI Remedial Investigation
RMA Rocky Mountain Arsenal
RME Reasonable Maximum Exposure
ROD Record of Decision
SACWSD South Adams County Water and Sanitation District
SD Standard Deviation
SDWA Safe Drinking Water Act
sec Second
SEC Site Evaluation Criteria
SF Square Feet
SFS Supplemental Field Study
Shell Shell Oil Company
SHO Semivolatile Halogenated Organic
SHPO Colorado State Historical Preservation Office
SPPLV Single-Pathway Preliminary Pollutant Limit Value
SQI Submerged Quench Incinerator
SSAB Site-Specific Advisory Board
SVE Soil Vapor Extraction
SY Square Yards
TAG Technical Assistance Grant
TBC To-Be-Considered Criteria
TCE Trichloroethylene
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TCLP Toxicity Characteristic Leaching Procedure
TE Exposure Duration
TEGD Technical Enforcement Guidance Document
TM Exposure Time
TMV Toxicity, Mobility, or Volume
TRC Technical Review Committee
TRY Toxicity-Reference Value
TSCA Toxic Substances Control Act
TSGM Two-Step Geometric Mean
TX Crop Agent for "Wheat Rust"
UF Uncertainty Factor
UFS Unconfined Flow System
ug Microgram
USATHAMA U.S. Army for Toxic and Hazardous Materials Agency
USC United States Code
USFWS U.S. Fish and Wildlife Service
UTS Universal Treatment Standard
UXO Unexploded Ordnance
VAO Volatile Aromatic Organics
VHC Volatile Hydrocarbon Compound
VHO Volatile Halogenated Organics
VOC Volatile Organic Compound
VX Nerve Agent
WP White Phosporus
yr Year
xu
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Declaration
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Declaration
Declaration
Site Name and Location
Rocky Mountain Arsenal
On-Post Operable Unit
Commerce City, Adams County, Colorado
Statement of Basis and Purpose
This Record of Decision (ROD) presents the selected remedial action for the Rocky Mountain Arsenal (RMA)
On-Post Operable Unit in southern Adams County (east of Commerce City) Colorado. This remedy was
selected based on the administrative record for the On-Post Operable Unit and chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986, and, to the extent practicable, the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP).
U.S. Army (Army) regulations allow for the integration of the requirements of both the National Environmental
Policy Act (NEPA) and CERCLA into one document. This ROD is intended to comply with NEPA, except as
related to the acquisition of permanent replacement water supplies, and as related to connecting residences in
the Henderson, Colorado area to an existing domestic water system.
In accordance with federal law, the federal funding of the Army for implementation of the ROD is subject to
appropriations from Congress and other requirements of the Anti-Deficiency Act, 30 USC 1341, el seq. The
Army shall request, through the normal Army and U.S. Department of Defense budgetary processes, all funds
and authorizations necessary to meet the conditions of, and to implement, the final remedy.
The U.S. Environmental Protection Agency (EPA) and the state of Colorado concur on the selected remedy.
Assessment of the Site
RMA was established in 1942 by the Army to manufacture chemical warfare agents and incendiary munitions
for use in World War II. Following the war and through the early 1980s, the facilities continued to be used by
the Army. Beginning in 1946, some facilities were leased to private companies to manufacture industrial and
agricultural chemicals. Shell Oil Company (Shell), the principal lessee, primarily manufactured pesticides from
1952 to 1982. Common industrial and waste disposal practices used during these years resulted in
contamination of structures, soil, surface water, sediment, and groundwater.
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Record of Decision for the On-Post Operable Unit
One hundred eighty-one sites with varying degrees of contamination, ranging from areas of several hundred
acres with multiple contaminant detections at concentrations up to a few parts per hundred to isolated detections
of single analytes at a few parts per billion, were delineated during the Remedial Investigation (RI) Program at
RMA. Contamination was detected in soil, ditches, stream and lakebed sediments, sewers, groundwater,
surface water, biota, structures, and, to a much lesser extent, air. Less extensive or less concentrated sources
occur only sporadically within the relatively uncontaminated buffer zone along the boundaries of the site. The
most highly contaminated sites (those showing the highest concentrations and/or the greatest variety of
contaminants) are concentrated in the central manufacturing, transport, and waste disposal areas. The highest
contaminant concentrations tend to occur in soil within 5 ft of the ground surface, although exceptions are
noted, particularly at sites where burial trenches, disposal basins, or manufacturing complexes are located. In
general, contaminant distribution is significantly influenced by the physical and chemical properties of the
contaminants, the environmental media through which they are transported, and the characteristics of the
sources, i.e., former manufacturing and disposal practices.
Groundwater contaminant plumes predominantly consist of organic compounds and arsenic, fluoride, and
chloride. The organic compounds consist primarily of benzene, dibromochloropropane (DBCP),
diisopropylmethyl phosphonate (DIMP), n-nitrosodimethylamine (NDMA), organochlorine pesticides (OCPs),
and chlorinated solvents. In addition, elevated concentrations of sulfate are present at RMA's north boundary,
chiefly due to natural sources. The unconfined flow system is the principal migration route for groundwater
contaminants. The overall concentrations and configurations of the plumes suggest that the greatest
contaminant releases to the unconfined flow system have occurred from Basin A and the Lime Settling Basins,
the South Plants chemical sewer, South Plants tank farm and production area, the Army and Shell trenches in
Section 36, and the Former Basin F. Plumes emanating from the Motor Pool/Rail Yard and North Plants areas
are other sources of contaminant releases to the unconfined flow system.
Contaminant sources and pathways were identified to allow a quantitative assessment of the potential for
exposure to human and ecological receptors. Twenty-seven contaminants of concern (COCs) were identified
for evaluation in the human health risk characterization and 14 COCs were identified for the ecological risk
characterization. Most of the potential carcinogenic health risks for human receptors are caused by four
chemicals: aldrin, dieldrin, DBCP, and arsenic. Potential excess cancer risks for these chemicals exceed 1 in
10,000 (1 x Iff*) at some sites. Three chemicals, DBCP, aldrin, and arsenic, account for the majority of
noncarcinogenic human health risks (hazard indices exceeding 1.0). The highest estimated risks occur in the
central portions of RMA, coinciding with the former location of chemical processing and disposal areas (e.g.,
the South Plants manufacturing area, the disposal trenches and basins). The primary routes for exposure are
consumption, dermal contact, and inhalation. Land-use restrictions and health and safety requirements for site
workers and visitors, however, have minimized the potential for human exposure to contaminants on post.
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Declaration
Although it is believed that these COCs are inclusive of the contaminants representing the greatest potential for
risk, there are other contaminants that exist that may in the future become a concern (e.g., dioxin). In such an
instance, an evaluation of the contaminant with respect to the remedy selected, designed, or implemented will
be performed to ensure that the remedy remains protective of human health and the environment.
Under current conditions, biota are the primary receptors of RMA contamination in surficial soil, lakebed
sediments, and surface water. Potential risk varies depending on the biomagnification factor (the ratio between
the concentration of a chemical in biota tissue to that in soil) used to calculate risk, the chemical or chemical
group being considered, and the receptor (trophic box) being considered. Differences among receptors for a
given chemical are partly due to differences in the toxicity threshold values that were used to calculate risk, and
especially due to differences in the exposure range size. Terrestrial areas where all trophic boxes are expected
to be at potential risk (based on cumulative risk from all of the biota COCs combined) are most of the central
sections of RMA, even though the specific receptors evidencing risk in one area may be different from those
evidencing risk elsewhere. Pesticides (especially aldrin and dieldrin) and metals (especially mercury, which
had been conservatively assumed to be present in its most toxic organic form, methyl mercury, but which was
later determined to be present primarily as inorganic mercury) are the primary biota COCs. The primary route
for biota exposure is ingestion. Consumption of contaminated prey is a concern at higher trophic levels due to
contaminants such as OCPs, which are known to bioaccumulate and biomagnify in the food chain.
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this ROD, may present an imminent and substantial endangerment to public health,
welfare, or the environment.
Scope and Role of the On-Post Operable Unit
The On-Post Operable Unit is one of two operable units at RMA (Figure D-l). The On-Post Operable Unit
addresses contamination within the fenced 27 square miles of RMA proper. The Off-Post Operable Unit
addresses contamination north and northwest of RMA.
The contaminated areas within the On-Post Operable Unit include approximately 3,000 acres of soil, 15
groundwater plumes, and 798 remaining structures. The most highly contaminated sites are located at South
Plants (i.e., Central Processing Area, Hex Pit, Buried M-l Pits, Chemical Sewers), Basins A and F, Lime
Basins, and the Army and Shell trenches. The primary contaminants found in soil and/or groundwater at these
sites are pesticides, solvents, heavy metals, and agent byproducts.
The purpose of the on-post remedial action is to implement remedies that eliminate, reduce, or control current
or future exposure to contaminated soil or structures; to reduce contaminant migration into the groundwater;
FOSTER ® WHEELER
ma/1525G.DOC FOtTER WHEELER ENVIRONMENTAL CORPORATION D-3
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Record of Decision for the On-Post Operable Unit
and to prevent contaminated groundwater from migrating off post. In addition, it addresses the arrangement for
provision of potable water to community residents through the South Adams County Water and Sanitation
District (SACWSD). The selected remedy described in this ROD will permanently address the threats to human
health and the environment using a combination of containment (as a principal element) and treatment
technologies to reduce the toxicity, mobility, or volume of contaminants in groundwater, structures, or soil;
comply with applicable or relevant and appropriate requirements (ARARs); and be cost effective.
Since 1975, the Army and Shell have undertaken 14 Interim Response Actions (IRAs) at RMA. Of these, eight
IRAs will be continued through incorporation with the selected on-post remedy. Continuing IRAs include
groundwater intercept and treatment north of RMA, groundwater intercept and treatment north of Basin F,
groundwater intercept and treatment in the Basin A Neck area, boundary systems operation, remediation of
other contamination sources (Motor Pool and Rail Yard groundwater treatment), asbestos removal, CERCLA
hazardous wastes, and chemical process-related activities. The IRAs were implemented in accordance with
Section XXII of the Federal Facility Agreement (FFA) to expedite the mitigation of contamination prior to the
selection of final remedial action. The FFA, which formalizes the framework for remediating RMA, was
signed by the Army, Shell, EPA, U.S. Fish and Wildlife Service (USFWS), U.S. Department of the Interior,
U.S. Department of Justice, and the U.S. Agency for Toxic Substances and Disease Registry (ATSDR) on
February 17, 1989. Actions requiring removal of material have been carried out in accordance with CERCLA
and its regulations and have been consistent with and contribute to the efficient performance of the final
response action for the On-Post and Off-Post Operable Units. Examples of early remedial actions include the
following:
• Constructing (from 1978 to 1984) and operating three boundary groundwater containment systems and
six other systems that currently treat more than 1 billion gallons of groundwater per year (more than
10 billion gallons to date)
• Excavating and storing in an engineered wastepile approximately 600,000 cubic yards of Basin F soil
and sludge, covering the remaining area of Basin F, and completing the on-site treatment of more than
11 million gallons of Basin F liquids in a specially designed incinerator
• Dismantling the hydrazine blending and storage facility and removing the debris to an off-post
hazardous waste landfill
• Installing a soil cover and slurry wall to reduce movement of contaminants from the Shell Trenches in
Section 36
More detailed information on the individual IRAs can be found in Section 2 of this ROD and in IRA-related
documentation at the Joint Administrative Record Document Facility.
The selected remedy for the On-Post Operable Unit, integrated with the IRAs and the selected remedy for the
Off-Post Operable Unit, will comprehensively address all contamination at RMA. If an IRA will not fully
address the threat posed by a release and further response is required, the Army will ensure the IRA will either
FOSTER gj WHEELER
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Declaration
be incorporated as part of the final response action or end to avoid duplication between the IRA and final
response action. The ROD for the On-Post Operable Unit will be the final response action at RMA.
Description of the Remedy
The selected remedy for the On-Post Operable Unit was developed based on the contaminated media present at
the site. The major components of the selected remedy for contaminated water, structures, and soil are
described below.
Water
The selected water alternative includes the following elements:
• Continued operation of the three RMA boundary groundwater containment and treatment systems, the
North Boundary Containment System (NBCS), the Northwest Boundary Containment System
(NWBCS), and Irondale Containment System (ICS), which treat groundwater to attain ARARs and
health-based remediation goals. These systems and the on-post groundwater IRA systems (Basin A
Neck, North of Basin F, Motor Pool, and Rail Yard) will continue to operate until shut-off criteria
specified in Section 9.1 of this ROD are met. ARARs for chloride and sulfate at the NBCS will be
achieved through natural attenuation as described in "Development of Chloride and Sulfate
Remediation Goals for the North Boundary Containment System at the Rocky Mountain Arsenal"
(MK 1996). Assessment of the chloride and sulfate concentrations will occur during the 5-year site
reviews.
• Installation of a new extraction system to intercept and contain a contaminated groundwater plume in
the northeast comer of Section 36 that will be treated at the Basin A Neck IRA system.
• Water levels in Lake Ladora, Lake Mary, and Lower Derby Lake will be maintained to support aquatic
ecosystems. The biological health of the ecosystems will continue to be monitored.
Lake-level maintenance or other means of hydraulic containment or plume control will be used to
prevent South Plants plumes from migrating into the lakes at concentrations exceeding Colorado Basic
Standards for Groundwater (CBSGs) in groundwater at the point of discharge. Groundwater
monitoring will be used to demonstrate compliance.
• Monitoring and assessment of MDMA contamination in support of potential design refinement/design
characterization to achieve remediation goals specified for boundary groundwater treatment systems.
Structures
The selected structures alternative includes the following elements:
• Demolition of structures with no planned future use in accordance with a refuge wildlife management
plan and salvage of metals where appropriate.
• Disposal of demolition debris from structures with significant contamination in the new on-post
hazardous waste landfill.
• Monitoring of all debris from structures associated with Army chemical agent manufacture and
treatment by caustic washing for all debris testing positive for the presence of agent followed by
disposal in die new on-post hazardous waste landfill.
• Disposal of debris from other structures under the Basin A cover.
• Disposal of process equipment structural debris contaminated with asbestos or polychlorinated
biphenyls (PCBs) in the new on-post TSCA-compliant (Toxic Substances Control Act) hazardous
waste landfill.
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Record of Decision for the On-Post Operable Unit
Soil
The selected soil alternative primarily contains soil with principal threat (1 x IO'3 excess cancer risk or hazard
index exceeding 1,000) and human health exceedances (1 x Iff4 or hazard index exceeding 1.0) and treats the
remaining principal threat soil. The selected soil alternative includes the following elements:
• Treatment of approximately 180,000 bank cubic yards (BCY) of soil at the Former Basin F site by in
situ solidification/stabilization.
• Treatment of approximately 1,000 BCY of materials from the Hex Pit by an innovative thermal
technology. Disposal of the remaining 2,300 BCY of soil in the on-post hazardous waste landfill.
Solidification/stabilization will become the selected remedy if all evaluation criteria for the innovative
thermal technology are not met.
• Excavation, solidification/stabilization, and disposal in the on-post hazardous waste landfill of
approximately 26,000 BCY of material from the Buried M-l Pits.
• Monitoring of excavated soil associated with Army chemical agent manufacture and treatment by
caustic washing for all excavated soil testing positive for the presence of agent followed by disposal in
the on-post hazardous waste landfill.
• Excavation, drying if necessary, and disposal of approximately 600,000 BCY of material from the
Basin F Wastepile in dedicated triple-lined cells in the on-post hazardous waste landfill.
• Excavation and disposal of approximately 54,000 BCY of material from the Section 36 Lime Basins in
a dedicated triple-lined cell in the on-post hazardous waste landfill.
• Off-post destruction (or on-post detonation if unstable) of any identified unexploded ordnance (UXO)
and excavation and disposal of UXO debris and associated soil in the on-post hazardous waste landfill.
• Containment using a soil cover or excavation and disposal of PCB-contaminated soil in the on-post
TSCA-compliant hazardous waste landfill
• Excavation and disposal of approximately 1.03 million BCY of contaminated soil exceeding the
human health site evaluation criteria (1 x 10"* excess cancer risk or hazard index exceeding 1.0) and
surface soil debris from remaining soil sites in the on-post hazardous waste landfill. These remaining
soil sites include the following: North Plants, Toxic Storage Yards, Lake Sediments, Surficial Soil,
Secondary Basins, Chemical Sewers, Sanitary Landfills, South Plants Central Processing Area, South
Plants Ditches, South Plants Balance of Areas, Buried Sediments, Sand Creek Lateral, Section 36
Balance of Areas, and Burial Trenches.
• Installation of slurry walls and RCRA-equivalent (Resource Conservation and Recovery Act) caps
with biota-intrusion barriers for the Army Complex Trenches and Shell Trenches, where
contamination will be left in place.
• Construction of a RCRA-equivalent cap over the Former Basin F site and soil covers with biota-
intrusion barriers over Basin A and the South Plants Central Processing Area.
• Excavation of 1.5 million BCY of soil posing a potential risk to biota and use as fill under the Basin A
and South Plants covers and Basin F cap.
• Construction of variable-thickness soil covers over the Secondary Basins, North Plants, South Plants
Balance of Areas, and Section 36 Balance of Areas.
Other
Additional components of the on-post remedy that contribute to protection of human health and the
environment are the following:
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Declaration
• Provision of $48.8 million held in trust to provide for the acquisition and delivery of 4,000 acre-feet of
potable water to SACWSD and the extension of water-distribution lines from an appropriate municipal
water supply distribution system to all existing well owners within the DIMP plume footprint north of
RMA as defined by the detection limit for DIMP of 0.392 parts per billion (ppb). In the future, owners
of any additional domestic wells, new or existing, found to have DIMP concentrations of 8 ppb (or
other relevant CBSG at the time) or greater will be connected to a water-distribution system or
provided a deep well or other permanent solution. The Army and Shell have reached an Agreement in
Principle with SACWSD, enclosed as Appendix B of this ROD, regarding this matter.
• National Environmental Policy Act - The Program Manager for Rocky Mountain Arsenal will
separately evaluate the potential impacts to the environment of both the acquisition of a replacement
water supply for SACWSD and for die extension of water-distribution lines.
• The Army and Shell will fund ATSDR to conduct an RMA Medical Monitoring Program in
coordination with the Colorado Department of Public Health and Environment. The primary goals of
the Medical Monitoring Program are to monitor any off-post impact on human health due to the
remediation and provide mechanisms for evaluation of human health on an individual and community
basis until such time as the soil remedy is completed. Elements of the program could include medical
monitoring, environmental monitoring, health/community education, or other tools. The program
design will be determined through an analysis of community needs, feasibility, and effectiveness.
• Trust Fund - During the formulation and selection of the remedy, members of the public and some
local governmental organizations expressed keen interest in the creation of a Trust Fund to help ensure
the long-term operation and maintenance of the remedy once the remedial structures and systems have
been installed. In response to this interest, the Parties (i.e., the Army, Shell, EPA, USFWS, and the
state of Colorado) have committed to good-faith best efforts to establish a Trust Fund for the operation
and maintenance of the remedy, including habitat and surficial soil. Such operation and maintenance
activities will include those related to the new hazardous waste landfill; the slurry walls, caps, and soil
and concrete covers; all existing groundwater pump-and-treat systems; the groundwater pump-and-
treat system to intercept the Section 36 Bedrock Ridge Plume; the maintenance of lake levels or other
means of hydraulic containment; all monitoring activities required for the remedy; design refinement
for areas that may pose a potential risk to biota as described in Section 9.4; and any revegetation and
habitat restoration required as a result of remediation.
These activities are estimated to cost approximately $5 million per year (in 1995 dollars). The
principal and interest from the Trust Fund would be used to cover these costs throughout the lifetime
of the remedial program.
The Parties recognize that establishment of such a Trust Fund may require special legislation and that
there are restrictions on the actions federal agencies can take with respect to proposing legislation and
supporting proposed legislation. In addition to the legislative approach, the Parties are also examining
possible options that may be adapted from trust funds involving federal funds that exist at other
remediation sites. Because of the uncertainty of possible legislative requirements and other options, the
precise terms of the Trust Fund cannot now be stated.
A trust fund group will be formed to develop a strategy to establish the Trust Fund. The strategy
group may include representatives of the Parties (subject to restrictions on federal agency
participation), local governments, affected communities, and other interested stakeholders, and will be
convened within 90 days of the signing of the ROD.
Notwithstanding these uncertainties, it is the intent of the Parties that if the Trust Fund is created it will
include the following:
- A clear statement that will contain the reasons for the creation of the Trust Fund and the purposes
to be served by it.
- A definite time for establishing and funding the Trust Fund, which the Parties believe could occur
as early as 2008, when the remedial structures and systems may have been installed.
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Record of Decision for the On-Post Operable Unit
- An appropriate means for competent and reliable management of the Trust Fund, including
appropriate criteria for disbursements from the Trust Fund to ensure that the money will be
properly used for the required purposes.
• Restrictions on land use or access are incorporated as part of this ROD. The Rocky Mountain Arsenal
National Wildlife Refuge Act of 1992 and the FFA restrict future land use and prohibit certain
activities such as agriculture, use of on-post groundwater as a drinking source, and consumption of
fish and game taken at RMA. Continued restrictions on land use or access are included as an integral
component of all on-post alternatives. Long-term management includes access restrictions to capped
and covered areas to ensure integrity of the containment systems.
• Continued operation of the existing CERCLA Wastewater Treatment Plant to support the remediation
activities.
• Stored, drummed waste identified in the waste-management element of the CERCLA Hazardous
Wastes IRA may be disposed in the on-post hazardous waste landfill in accordance with the Corrective
Action Management Unit Designation Document
• Continued monitoring as part of design refinement for the remediation of surficial soil and lake
sediments that may pose a potential risk to wildlife (see Section 6.2.4.3).
Summary of the Off-Post Remedy
The Off-Post Operable Unit addresses groundwater contamination north and northwest of RMA. A ROD for
this operable unit was issued on December 19, 1995. The selected remedies for both of the operable units,
integrated with the IRAs, will comprehensively address all contamination at RMA. The components of the
selected remedy for the Off-Post Operable Unit, presented below for informational purposes, are as follows:
• Continued operation of the Off-Post Groundwater Intercept and Treatment System.
• Natural attenuation of inorganic chloride and sulfate concentrations to meet remediation goals for
groundwater in a manner consistent with the on-post remedial action. •
• Continued operation of the NWBCS, NBCS, and ICS as specified in Section 7.2 of the ROD for the
On-Post Operable Unit.
• Improvements to the NBCS, ICS, NWBCS, and the Off-Post Groundwater Intercept and Treatment
System as necessary.
• Long-term groundwater monitoring (including monitoring after groundwater treatment has ceased) to
ensure continued compliance with the Containment System Remediation Goals (CSRGs).
• Five-year site reviews.
• Exposure control/provision of alternate water as detailed in the ROD for the Off-Post Operable Unit.
• Institutional controls, including deed restrictions on Shell-owned property, to prevent the use of
groundwater exceeding remediation goals.
• Closure of poorly constructed wells within the Off-Post Study Area (see Figure D-l) that could be
acting as migration pathways for contaminants found in the Arapahoe aquifer.
• Continuation of monitoring and completion of an assessment by the Army and Shell of the NDMA
plume by June 13,1996 using a 20 parts per trillion (ppt) method detection limit.
• Preparation of a study that supports design refinement for achieving NDMA remediation goals at the
RMA boundary. The study will use a 7.0 ppt preliminary remediation goal or a certified analytical
detection level readily available at a certified commercial laboratory (currently 33 ppt).
FOSTER ® WHEELER
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Declaration
•, Tilling and revegetation of approximately 160 acres in the southeast portion of Section 14 and the
southwest portion of Section 13 by the Army and Shell.
• Treatment of any contaminated extracted groundwater prior to discharge or reinjection so that it meets
CSRGs that meet or exceed the water quality standards established in the CBSGs and the Colorado
Basic Standards and Methodologies for Surface Water.
Statutory Determinations
The selected remedy is protective of human health and the environment, complies with federal and state
requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost effective.
The remedy uses permanent solutions and alternative treatment technologies to the maximum extent
practicable. Components of the selected remedy satisfy the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a principal element. The large volume of contaminated
soil present on the site precludes a remedy in which all contaminants could be excavated and cost effectively
treated.
Because this remedy will result in hazardous substances remaining at RMA above health-based levels, a review
will be conducted no less than every 5 years after commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environment and complies with applicable
regulations.
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Record of Decision for the On-Post Operable Unit
FOSTER ® WHEELER
D-10 KMTCnWHECtEHENVMONMCNTALeOMraflATIOM rm«/1525G.DOC
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' Henderson -S
North of RMA
Intercept Area
__-^Operable Unit
Off-Post
Study Area
North Boundarytton
23 I 24 ^
Inment System
19
Northwest Bounds
tainment
s
North of Basin
On-Post
Operable Unit
Basfn F |^ >
sin A Neck IRA
Treatnent Facility
Commerce
City
Motor Poof and Rail Yard
Plume Captu e IRAs
Lower
Derby
Lake
Figure D-1
RMA Operable Units
Rocky Mountain Arsenal
Prepared by Foster Wheeler Environmental Corporation
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Declaration
Signature Page
For U.S. Environmental Protection Agency
FredHansen
Deputy Administrator
Jack W. McGraw
'Acting Regional Administrator, Region Vm
For U.S. Army
Robert M. Walker
Assistant Secretary of the Army
(Installations, Logistics and Environment)
For State of Colorado
Roy R. f oner
Governor
Gail Schoettler
Lieutenant Governor
mttmSGDOC
i«ornw B »
D-ll
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Shell Oil Company
c/o Holme Roberts & Owen LLC
Suite 4100
1700 Lincoln
Denver, CO 80203
June 11, 1996
Environmental Protection Agency
Region Vffl
One Denver Place, 999 18th Street
Denver, Colorado 80202-2413
CERCLA Litigation Unit
Office of the Attorney General
1525 Sherman Street, 5th Floor
Denver, Colorado 80203
Re: Rocky Mountain Arsenal—On-Post ROD
Ladies and Gentlemen:
Shell Oil Company ("Shell") did not invoke dispute resolution on the draft final record of
decision for the On-Post Operable Unit of Rocky Mountain Arsenal (the "ROD") under the
Federal Facility Agreement dated effective February 17,1989 (the "FFA"), among the United
States Department of the Army, United States Environmental Protection Agency, United States
Department of the Interior, Agency for Toxic Substances and Disease Registry, United States
Department of Justice, and Shell. Pursuant to paragraph 25.7 of the FFA, Shell is therefore
deemed to have concurred in the draft final ROD:
Shell also does not object to the minor changes that have been made since the draft final
ROD was issued.
The final ROD is to be signed today. Shell confirms it will not challenge the final ROD
under paragraph 25.13 of the FFA.
This letter affirms Shell Oil Company's long standing commitment to a protective and
cost-effective remedy for Rocky Mountain Arsenal.
Very truly yours,
SHELL OIL COMPANY
Rand N. Shulman
Authorized Signatory
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Mountain-Prairie Region
MAILING ADDRESS: STREET LOCATION:
Post Office Box 25486
Denver Federal Center
Mail Stop 61170 Denver,Colorado80225
Post Office Box 25486 134 Union Blvd.
FWS/R6/RMA Denver Federal Center Lakewood, Colorado 80228
.)UN 1 1 1996
Raymond J. Fatz, Acting Deputy
Assistant Secretary of the Army
(Environment, Safety and Occupational Health)
OASA (I, L & E)
110 Army Pentagon
Washington. D.C. 20310-0110
Dear Mr. Fatz:
On behalf of the Fish and Wildlife Service I am pleased to endorse and support
the signing of this On Post Record of Decision for the remediation of the
Rocky Mountain Arsenal. This ROD represents the culmination of years of
effort and resolves many years of negotiations between the involved parties.
It also represents a major milestone in transitioning the Arsenal to the
Refuge as envisioned by Congress in the Rocky Mountain Arsenal National
Wildlife Refuge Act of 1992.
There are issues yet to be resolved. The Service remains concerned that the
Trust Fund becomes a reality, and it is essential that sufficient water is
obtained for maintaining the lakes and revegetating the disturbed areas. It
is my hope that the implementation of the ROD results in an expedient and
effective remedy to enable the Rocky Mountain Arsenal to become one of the
Nation's finest urban national wildlife refuges.
Sincerely,
Di rector
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Decision Summary
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1.0 Site Name, Location, and Description
1.0 Site Name, Location, and Description
The Rocky Mountain Arsenal (RMA) National Priorities List (NPL) site is comprised of two operable units,1 On
Post and Off Post. The On-Post Operable Unit is encompassed by the boundaries of RMA; it occupies 27 square
miles in southern Adams County, approximately 8 miles northeast of Denver (Figure 1.0-1). Areas bordering RMA
exhibit varied land use. To the north and east the land is primarily agricultural, except for Denver International
Airport, around which a great deal of business and residential activity is ongoing or scheduled. The southern
boundary is adjacent to the Denver residential, commercial, and industrial community of Montbello and to the
former Stapleton International Airport, and the western boundary is adjacent to Commerce City, where land use is
residential, commercial, and industrial.
Future land use for the On-Post Operable Unit is addressed in the Federal Facility Agreement (FFA), which was
signed by the U.S. Army (Army), U.S. Environmental Protection Agency (EPA), U.S. Agency for Toxic Substances
and Disease Registry (ATSDR), U.S. Fish and Wildlife Service (USFWS), U.S. Department of Justice, and Shell Oil
Company (Shell) in 1989 (these entities are collectively referred to as the Organizations) pursuant to Section 120 of
the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA). Among other
provisions, the FFA states that it is a goal of the signatories to make significant portions of the site available for
beneficial public use and requires the preservation of habitat to the extent required by the Endangered Species Act,
Migratory Bird Treaty Act, and Bald Eagle Protection Act. In October 1992, in conjunction with the future goal of
beneficial public use and in recognition of the unique urban wildlife resources provided by RMA, President George
Bush signed the Rocky Mountain Arsenal National Wildlife Refuge Act, making RMA a national wildlife refuge
following EPA certification that required response actions have been appropriately completed. Once the EPA
Administrator declares the site protective, ownership of the site will be transferred to USFWS.
Restrictions on land use at RMA or access to RMA are agreed to by the Army, EPA, USFWS, Shell, and state of
Colorado (Parties) and are included as part of this Record of Decision (ROD). The Rocky Mountain Arsenal
National Wildlife Refuge Act and the FFA restrict future land use, specify that the U.S. government shall retain
ownership of RMA, and prohibit certain activities such as agriculture, use of on-post groundwater as a drinking
source, and consumption offish and game taken at RMA.
1.1 Environmental Setting
1.1.1 Physiography
RMA is located at the western edge of the Colorado Plains, near the foothills of the Rocky Mountains. It occupies
an area of rolling terrain characterized by grasslands, shrublands, wetlands, aquatic habitats, and extensive weedy
areas, and it supports a variety of plant and wildlife species. The elevation above mean sea level ranges from
5,330 ft at the southeastern boundary to 5,130 ft at the northwestern boundary.
1 Items printed in bold face are included in the glossary.
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Regional surface drainage is toward the northwest into the South Platte River, which flows parallel to the northwest
boundary of RMA and eventually jobs the North Platte River in Nebraska. The land surface of RMA has largely
been shaped by fluvial processes associated with the South Platte River and its tributaries. Wind-borne deposits
cover the alluvial land surface in many areas, particularly in the southern and western portions of RMA.
1.1.2 Climate
According to the National Climatic Data Center records for Denver, the mean maximum temperatures range from
43°F in January to 88°F in July; mean minimum temperatures range from 16°F in January to 59°F in July.
Annual precipitation averages approximately 15 inches (water equivalent). Average monthly precipitation is
highest in May and lowest from December through February. The maximum precipitation events are heavy
localized thunderstorms that occur during late spring and summer. Tornadoes and severe hailstorms may occur in
association with intense thunderstorm activity. Snowfall normally occurs from September through May. The
average annual snowfall is 58 inches. Average monthly snowfall is highest in March, when snow also tends to have
the highest moisture content. Snow generally melts or sublimates rapidly at RMA and normally does not cover the
ground for extended periods.
The prevailing wind is from the south. In summer, the strongest winds are associated with thunderstorms. In other
seasons, the strongest winds are generally from the northwest quadrant and are downslope "chinook" winds. The
annual mean wind speed at RMA is approximately 9 mph, and the maximum hourly wind speed ranges from
approximately 33 mph to 38 mph. A maximum wind gust of approximately 70 mph has been recorded at RMA.
1.1.3 Existing Cultural Features
Most military and industrial activities at RMA occurred in three areas: North Plants, South Plants, and the Rail
Yard. Cultural features are generally associated with these areas. The primary roads at RMA form a grid that runs
along the township section lines.
Structures at RMA include buildings, foundations, basements, tanks and tank farms, process and nonprocess
equipment, pipelines, sewers, and other manmade items such as electrical substations. Most of these structures
(53 percent) are located in the South Plants area. Two smaller groupings of structures occur in Norm Plants
(12 percent) and in the Rail Yard (8 percent), and the rest (27 percent) occur as individual or small clusters
throughout the site.
There are six former disposal basins at RMA. Basin A was originally developed as an unlined evaporative basin for
disposal of aqueous waste from the production of mustard and lewisite. Basin B was used as a holding pond for
overflow from Basin A. Basins C, D, and E were created from natural depressions to hold overflow aqueous wastes
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from preexisting basins. Basin F, partially remediated under the Basin F Interim Response Action (IRA), was an
asphalt-lined evaporation basin. Other disposal sites include the Army and Shell Trenches and sanitary landfills.
Three boundary groundwater containment systems, the North, Northwest, and Irondale systems (NBCS, NWBCS,
and ICS, respectively), are present at RMA. These systems are designed to treat and to prevent the migration of
groundwater contamination to off-post areas. Each system consists of an array of extraction wells, water treatment
facilities, an array of injection wells, and, at the NBCS, recharge trenches.
There are also four internal groundwater treatment systems, the Motor Pool, Rail Yard, Basin F, and Basin A Neck
IRA systems. Extraction wells in the Motor Pool and Rail Yard IRA systems pump water to the ICS for treatment
prior to reinjection at the ICS. At the North of Basin F IRA, water is extracted and piped to the Basin A Neck IRA
system for treatment. The Basin A Neck IRA is a pump-and-treat system that intercepts and treats contamination in
groundwater as it moves northwest from Basin A. Water is reinjected at the Basin A Neck reinjection trenches.
1.1.4 Cultural Resources
Previous to Army operations at RMA, a patchwork of small irrigated farms occupied the southeastern and north-
central portions of the site and larger dryland farms and ranches occupied the northeastern portion. Lakes in the
southern portion are remnants of this agricultural past. Prior to 1850, the site was used by Native American tribes
indigenous to the area, such as the Cheyenne and Arapaho.
The Army is in the process of completing cultural resource surveys that will identify structures or sites that may be
protected under the National Historic Preservation Act (36 CFR 800) or the Archeological Resources Protection Act
(16 USC Section 469 a-1). To determine the extent of historical and prehistorical resources existing on the current
RMA site, several areas were investigated by different archeological teams. To bring all these studies together, as
well as to close any information gaps, a complete RMA-wide surface sweep was conducted. A final report
summarizing the results of this survey will be completed in summer 1996 prior to initiating on-post remedial
actions. Native American sites and farmsteads at RMA were investigated.
No National Historic Register nominations have been made as a result of these activities, but two potentially eligible
National Historic Districts were determined to exist, the North Plants manufacturing area and the South Plants
manufacturing area. Due to their significant contribution in the Cold War, particularly the North Plants area,
consultations were entered into with the Colorado State Historical Preservation Office (SHPO). Because
contamination and Chemical Weapons Convention issues require the destruction of these potentially eligible
districts, a Historic American Engineering Record of the districts is being prepared in advance of demolition, as is a
video history of former residents and workers at RMA. Current projects in South and North Plants are carried out
under an Interim Memorandum of Agreement between the Army, SHPO, and USFWS.
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1.2 Geology
RMA is located within the Denver Basin, an asymmetrical depression approximately 300 miles long and 200 miles
wide. The sedimentary rocks in the Denver Basin are more than 10,000 ft thick. Only the surficial soil,
unconsolidated alluvium, and Denver Formation units are of interest for remedial actions at RMA.
Virtually all of RMA is covered with unconsolidated alluvial and windblown sediments that may locally reach
thicknesses of 130 ft. Due to the nature of the alluvial deposition and erosion and the irregular bedrock surface on
which the alluvium lies, there is little lateral continuity in the alluvial units, and the spatial relationships between
them are complex. The thickest deposits of these alluvial sediments occur in paleochannels eroded into the
underlying Denver Formation, which consists of sandstones, siltstones, and claystones. The paleochannels, which
were incised in the bedrock surface and subsequently filled with alluvial deposits, influence regional groundwater
flow and the direction and rate of movement of groundwater plumes at RMA. The major paleochannels on post, the
First Creek and Irondale channels, direct regional groundwater flow to the north and north-northwest, respectively.
At RMA, the Denver Formation is exposed in only a few isolated outcrops. The unit ranges from approximately 200
to 500 ft in thickness, and is separated from the underlying Arapahoe Formation by a relatively impermeable
claystone interval 30 to 50 ft thick. The Arapahoe Formation consists of 400 to 700 ft of interbedded conglomerate,
sandstone, siltstone, and shale. The upper portion of the Arapahoe Formation consists predominately of 200 to
300 ft of blue to gray shale with some conglomerate and sandstone beds. The lower portion of the formation
consists primarily of sand, gravel, and conglomerate and is a source zone for many water-supply wells in the area.
1.3 Hydrology
Flow of surface water at RMA occurs through a network of streams, lakes, and canals. Four principal drainage
basins and three smaller subcatchments are recognized within RMA and include the First Creek, Irondale Gulch,
Sand Creek, and Second Creek drainage basins and the Basins A and F and Sand Creek Lateral subcatchments.
Streamflow at RMA is highly variable. Seasonal variations in stream discharge are generally greater than average
year-to-year variations and are strongly affected by the amount of urban runoff, released or diverted flow, and direct
precipitation. Streams at RMA are generally intermittent, and highest flows tend to occur during spring runoff and
during major storms. Water levels in the lakes are less variable than stream discharge and are regulated. Peak
storage volumes usually occur in spring or early summer.
Groundwater flow occurring within the alluvium and the uppermost weathered portion of the Denver Formation has
been designated as the unconfined flow system (UFS). Deeper water-bearing units within the Denver Formation,
which are designated as the confined flow system (CFS), are separated from the UFS by low-permeability confining
units. Depending on site-specific hydrological characteristics, varying degrees of hydraulic interchange are possible
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between surface water and groundwater and between the UFS and CFS. In general, analytical and hydraulic data
indicate little hydraulic interchange between the UFS and CFS.
The UFS includes saturated portions of the unconsolidated materials overlying the Denver Formation, the weathered
upper portion of the Denver Formation, and, where the Denver Formation is missing near the South Platte River, the
weathered upper portion of the Arapahoe Formation. The CFS includes the deeper portions of the Denver
Formation and the underlying Arapahoe Formation. Water enters the UFS as infiltration of precipitation; seepage
from lakes, reservoirs, streams, canals, and buried pipelines; flow from upgradient regional flow; and flow from the
underlying CFS. Water is discharged from the UFS as seepage to lakes and streams, underflow to off-post areas
north and west of RMA, and downward flow into the CFS. The UFS may gain or lose water at various locations
and at different times of the year.
The CFS consists of strata within the Denver Formation collectively referred to as the Denver aquifer, where water
residing in permeable sandstone or fractured lignite is confined above and below by relatively impermeable shale or
claystone. Water enters the CFS primarily through regional updip flow and vertical flow from the overlying UFS.
Water is discharged from the CFS by lateral flow into the UFS (where the strata are transmissive) or by leakage to
the Arapahoe aquifer. The UFS is the principal migration route for groundwater contaminants at RMA. Some low-
level contamination is present in isolated portions of the CFS, but the spread of contamination has been minimal due
to the limited permeability and discontinuous nature of the water-bearing zones in the CFS. No contaminant
migration pathway has been identified for the CFS and no production wells at RMA currently obtain water from the
CFS.
1.4 Biological Habitat
RMA is situated within a temperate grassland region and is part of a broad transition zone between mountain and
plains habitats. Tall-grass species are common in moist areas and short-grass species prevail in dry areas. On-post
human activity has resulted in vegetation dominated by weedy species and early successional colonists typical for
the region. Currently, 88 percent of the RMA land surface is vegetated. Of this total, 41 percent supports early
successional plant communities and 19 percent supports crested wheatgrass, which was used in the 1930s and 1940s
to stabilize land susceptible to erosion. The remaining 28 percent supports shrubland, patches of yucca, riparian
woodlands, cattail marshes and other wetland types, locust and wild plum thickets, upland groves of deciduous
trees, and ornamental plantings. Each of these varied plant groups provides potential wildlife habitat.
Regional wildlife is dominated by species of prairie, steppe, and savanna communities. The wildlife species
inhabiting RMA are those found in similar habitats off post. RMA supports populations of deer, hawks, and eagles,
as well as numerous other mammals, birds, and other animals. In contrast to surrounding urban areas where these
species are hunted or are sensitive to human presence, RMA provides a relatively less disturbed habitat that is
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attractive to wildlife. Its large acreage of diverse open habitats interspersed with lakes, small wooded areas, and a
mixture of native grasses and tall weedy forbs, along with a lack of hunting pressure and disturbance, have
contributed to an abundance of many wildlife species. The abundance and availability of prey species attracts avian
and mammalian predators.
Twenty-six species of mammals have been observed at RMA, a number that includes all of the common mammals
that inhabit the prairie grasslands of the Colorado Front Range. One hundred seventy-six species of birds have been
observed at RMA, which is approximately 40 percent of all bird species recorded in the state of Colorado. The
species richness of RMA birds is high relative to that of the region. At least two regionally rare or declining species
(Cassin's sparrow and Brewer's sparrow) are relatively common breeding birds at RMA. Raptor population density
and species diversity are comparable with those at other sites in the region. Winter raptor populations, particularly
that of the bald eagle, are a primary attraction for the 20,000 to 30,000 visitors that come to -RMA during this
season.
Several species of reptiles and amphibians may be encountered in nearly every habitat type at RMA. Incidental
observation has recorded 61 percent (or 17) of the 28 species of reptiles and amphibians that could potentially occur
at RMA. The four lakes in the South Lakes area support aquatic communities, although aquatic insects appear to be
largely absent. •
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North Of RMA
Intercept Area
Legend
20
Section (1 section = 640
acres or 1 square mile)
Not to scale
Rocky Mountain Arsenal
Prepared by Foster Wheeler Environmental Corporation
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2.0 Site History and Enforcement Activities
2.0 Site History and Enforcement Activities
2.1 Production and Operational History
RMA was established by an act of Congress in 1942 to manufacture chemical warfare agents and agent-filled
munitions and to produce incendiary munitions for use in World War II. Initial facility building activities included
construction of the South Plants manufacturing complex, extension of railway systems onto RMA, construction of a
railway classification yard and service and maintenance facilities in Sections 3 and 4, modifications to preexisting
irrigation reservoirs (Lake Ladora, Lower Derby Lake) and construction of a new reservoir (Upper Derby Lake) to
supply the South Plants complex with process cooling water, and construction of three seepage ponds in a large
earthen depression in Section 36. Prior to 1942, the area was largely undeveloped ranchland and farmland.
The first major products produced at RMA were mustard gas, lewisite, and chlorine gas. From 1942 to 1943, the
Army manufactured Levinstein mustard in the South Plants. Lewisite was manufactured between April and
November 1943. Mustard and lewisite-filled munitions, as well as bulk product in 55-gaIlon drums, were stored in
"toxic storage yards" in Section 5,6, and 31.
Incendiary munitions were produced at RMA during and after World War II. They included 100-lb M-47 bombs
filled with napalm gel and 10-Ib M-74 bomblets filled with an incendiary mixture composed of magnesium dust,
sodium nitrate, and gasoline. These bomblets were assembled into 500-lb cluster bombs. Once filled, incendiary
and cluster bombs were stored in open storage areas and bunkers in Sections 5, 6, 7, and 8. Stockpiles of 10-lb, 6-
Ib, and 4-lb bomblets were tested in a munitions facility in Section 36. During the Korean War conflict munitions
filled with white phosphorus, artillery shells filled with* distilled mustard, and incendiary cluster bombs were
manufactured, and during the Vietnam conflict approximately 1.3 million white phosphorus grenades, 7.8 million
button bombs, 12.2 million microgravel units, and 7 million experimental sandwich button bombs were
manufactured at RMA.
During the 1950s and into the 1960s, obsolete and deteriorating World War II ordnance were demilitarized at RMA
by either draining and neutralizing the contents and burning the remains or by controlled detonation or open
burning. From 1957 to 1959, four areas in Sections 19,20,29, and 30 were used for surface detonation and burning
of more than twenty-two thousand 500-lb incendiary bombs. Between 1971 and 1973, 3,071 tons of obsolete
mustard agent were destroyed.
From 1950 to 1952, the Army designed and constructed the North Plants complex in Section 25 to manufacture the
nerve agent GB, also called Sarin. GB was manufactured in the North Plants from 1953 to 1957, the major site for
the free world's production of GB during this period. GB munitions were demilitarized in the early 1970s. One-ton
containers of bulk GB, bulk VX nerve agent, GB-filled bomb clusters, and GB-filled Weteye bombs were stored in
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toxic storage yards in Sections 5, 6, and 31. Diisopropylmethyl phosphonate (DIMP) is a byproduct of GB
manufacture.
Between 1962 and 1968, wheat was cultivated on nearly 600 acres in portions of Sections 23,24,25, and 26 for the
purpose of producing TX, a crop agent. TX is a plant pathogen commonly known as "wheat rust" that does not
affect animals or humans. In 1972, stockpiled TX was incinerated and the ash disposed in Section 19.
The Hydrazine Blending and Storage Facility, located just east of the South Plants in Section 1, was owned by the
U.S. Air Force and operated by the Army between 1961 and 1982. It was used to produce Aerozine SO, a rocket
fuel primarily used in the Titan and Delta missile operations.
Portions of the South Plants manufacturing complex were leased to private industry following World War II,
primarily for the production of pesticides. Nine companies conducted manufacturing or processing operations in
South Plants between 1946 and 1982, when all Army manufacturing and processing operations in South Plants
ceased. The two major lessees of facilities in South Plants were Julius Hyman and Company (Hyman) (1947-52)
and Shell Chemical Company (1952-82). Colorado Fuel and Iron (CF&I) also manufactured chlorinated benzenes,
chlorine, naphthalene, caustic, and dichlorodiphenyltrichloroethane (DDT) at South Plants between 1946 and 1948.
Hyman manufactured chlorinated pesticides including aldrin, dieldrin, and chlordahe. The company also
manufactured or brought to RMA feedstock chemicals used in manufacturing its commercial products. These
included hexachlorocyclopentadiene (HCCPD), bicycloheptadiene (BCHPD), dicyclopentadiene (DCPD),
cyclopentadiene, hydrogen peroxide, acetylene, and chlorine.
In 1942, the South Tank Farm was constructed in the northwest quarter of Section 1 in an area in the southern part
of South Plants as part of the initial construction at RMA. The South Tank Farm included 11 storage tank locations
that were used for storage of DCPD, crude BCHPD bottoms, isopropyl alcohol, sulfuric acid, D-D fumigant, and
dibromochloropropane (DBCP) by Hyman and Shell. In 1948, during the period when CF&I was leasing facilities
at South Plants, 100,000 gallons of benzene were spilled in an undisclosed location. In 1979, Shell detected
benzene in soil samples collected in the South Tank Farm area. Subsequent sampling under the Remedial
Investigation (RI) Program (see Section 2.3) revealed the presence of benzene, toluene, xylene, DCPD, and
BCHPD in groundwater in the area.
In 1952, Shell acquired the stock of Hyman, which continued as a lessor until 1954 when it was merged into Shell
Chemical Company. Following the merger, Shell leased and constructed additional facilities in South Plants. From
1952 to 1982, Shell produced chlorinated hydrocarbon insecticides, organophosphate insecticides, carbamate
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insecticides, herbicides, and soil fumigants. These products include Akton, aldrin, Azodrin, Bidrin, Bladex, Ciodrin,
Dibrom, dieldrin, endrin, ethyl parathion, Gardona, Landrin, methyl parathion, Nemagon (DBCP), Nudrin,
Phosdrin, Planavin, Pydrin, ravap, and Supona.
The process water system installed by the Army in 1942 circulated cooling waters from the South Lakes area of
South Plants through South Plants and back to the lakes. In May 1951, an accidental discharge of caustic soda into
the process water system at RMA occurred, resulting in a massive fish kill in Lake Ladora. Subsequently, samples
of surface water, surface foam, green algae, and sediment from Lake Ladora and Lake Mary were found to contain
concentrations of aldrin, dieldrin, Gardona, Bidrin, and heavy metals.
2.2 Waste Disposal Operations
Throughout the 1940s, 1950s, and 1960s solid wastes generated at RMA were disposed in Section 36, east of Basin
A. The Army's operations at RMA generated miscellaneous solid chemical wastes as well as potentially
contaminated tools, equipment, unwanted containers, rejected incendiaries, and empty munitions casings. These
materials were decontaminated with caustic or other appropriate decontaminants and the residue hauled to burning
pits for incineration.
The burn pits or trenches were normally 8 to 10 ft deep and 100 to 200 ft long, and were usually dug with earth-
moving equipment and draglines. Four to five tons of lumber were placed in the bottom of the pit and the potentially
contaminated materials were placed on top of the lumber. When the pit was full, additional wood was placed on top
of the materials, 300 to 500 gallons of fuel oil poured onto the heap, and the contents burned. Rejected lots of
napalm or M-47 incendiary bombs were sometimes used as fuel for the fire. After burning, the metal was tested to
determine whether it was free of contamination. If testing revealed the presence of contamination, the metal was
burned again. In 1957, several hundred tons of scrap metal were recovered from the burn pits and sold. In addition,
16 mustard-contaminated forklifts were retrieved and salvaged. After use, bum pits were backfilled with excavated
soil. In 1969, the Army halted decontamination of contaminated materials by open pit burning; contaminated
material was subsequently stored in contaminated equipment dumps, which began to increase substantially in size.
Open pit burning continued only for the purpose of destroying explosives, burster charges, rocket propellant, and
rocket motors.
In addition to the solid waste bum pits, the Army operated a number of sanitary landfills in Section 36 (north of
South Plants), in Section 4 (west of South Plants), and in Section 30 (northeast of North Plants). Although sanitary
landfills were generally used for disposal of uncontaminated wastes, contaminated wastes may have been
occasionally disposed at these sites.
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Beginning in 1942, most aqueous wastes from South Plants operations were treated with sodium hydroxide and
were discharged through the chemical sewer into the Basin A area. Aqueous waste from the chlorine plant at the
west end of South Plants was initially discharged into the Sand Creek Lateral, where it ultimately discharged into
First Creek in Section 25. However, the resulting dissolved solids levels in First Creek were considered too high, so
this waste stream was subsequently diverted into unimproved Basins D and E in Section 26. In 1946, overflow from
Basin A was channeled into Basin B and subsequently into Basins D and E. The locations of these source areas are
shown on Figure 1.0-1.
In 1953, the unlined basin network was upgraded to facilitate handling of all liquid wastes from both North Plants
and South Plants. Basin C was constructed to handle all liquid wastes from South Plants as well as overflow from
Basin A. Overflows from Basin C were in turn channeled into Basins D and E.
In a subsequent effort to consolidate aqueous wastes, and in response to complaints by nearby residents about
contaminated groundwater, the Army constructed Basin F in late 1956. Basin F was the only disposal basin at RMA
equipped with a catalytically blown asphalt liner to protect the substrate from infiltration by contaminated material
In 1951, Shell disposed of approximately 1,000 cubic yards of materials resulting from the production of HCCPD.
This tarry, chlorinated material was buried in thin-gauge caustic barrels and in bulk in an unlined pit in the South
Plants Central Processing Area. Although potential migration pathways exist, groundwater data indicate that these
wastes are immobile.
In 1961, the Army commenced what was hoped to be the final solution to RMA's chemical waste disposal problem.
An injection well was drilled 12,045 ft deep into Precambrian rocks beneath Basin F. Between March 8,1962, and
September 30, 1963, approximately 104 million gallons of treated effluent waste from Basin F were injected into
the deep disposal well at rates of 100 to 300 gallons per minute (gpm). A total of 165 million gallons of waste were
disposed using this method. Operations were suspended on February 20, 1966, due to growing suspicion that the
injection operations had caused an unusual series of earthquakes centered in the RMA area. The well was properly
plugged and abandoned on October 22,1985.
2.3 Previous Investigations
Since the early 1950s potential contamination of the flora and fauna at RMA and various aspects of the ecology of
these organisms have been studied. Initial studies were conducted in response to reports of wildlife mortality and
agricultural damage. By the late 1950s, complaints of groundwater pollution north of RMA began to surface. In
1974, the Colorado Department of Health (now the Colorado Department of Public Health and Environment, or
CDPHE) detected DIMP in a groundwater well north of RMA. Ecological investigations of broader scope were
conducted in support of on-post contamination assessments and restoration planning programs that began in the
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2.0 Site History and Enforcement Activities
1970s, and it was during the mid-1970s that the first ecological surveys were conducted. Some of these studies had
an RMA toxicological or ecological emphasis, while others were conducted at RMA in support of the proposed
Stapleton International Airport expansion onto RMA property and county-wide wildlife habitat planning. More
recent studies, initiated in the early 1980s, were performed in compliance with CERCLA and in support of active
litigation involving the United States, the state of Colorado, and Shell.
In 1974, the Army established a Contamination Control Program at RMA designed to ensure compliance with
federal environmental laws. Under the Contamination Control Program, a number of investigations were conducted
by the U.S. Army Toxic and Hazardous Materials Agency (USATHAMA) during the 1970s and early 1980s. The
results of these investigations indicated that the contamination at RMA was concentrated mainly in the alluvial
sediments and alluvial groundwater, with minor amounts of contamination in the Denver Formation. Based on this
information and personal interviews, a contamination control strategy was developed for RMA that was designed to
be consistent with pertinent state and federal statutes. In 1984, USATHAMA, under a separate division created
specifically to deal with the contamination at RMA, i.e., Program Manager for Rocky Mountain Arsenal (PMRMA),
initiated a series of investigations required under CERCLA, the RI/Feasibility Study (FS) and the Endangerment
Assessment. A flow diagram of activities that have been and are currently being conducted under these programs is
presented in Figure 2.3-1.
Six of the more recently conducted studies have direct relevance to the selection of the preferred remedial
alternatives. These include the following:
• Human Health Exposure Assessment for Rocky Mountain Arsenal (Ebasco 1990)
• Remedial Investigation Summary Report (Ebasco 1992a)
• Development and Screening of Alternatives Report (Ebasco 1992b)
• Human Health Exposure Assessment Addendum for Rocky Mountain Arsenal (Ebasco 1992c)
• Integrated Endangerment Assessment/Risk Characterization Report (Ebasco 1994)
• Detailed Analysis of Alternatives Report (Foster Wheeler Environmental 1995a)
The general time frame under which major RMA documents were completed is presented in Table 2.3-1. These and
other comprehensive documents regarding the remediation of RMA have been made available for public review at
the Joint Administrative Record Document Facility (JARDF), which is located at the west entrance to RMA at 72nd
Avenue and Quebec Street, and at eight area libraries (see Section 3).
2.4 Past and Ongoing Response Actions
Since 1975, the Army and Shell have undertaken numerous efforts to protect on- and off-post human health and the
environment by implementing early remedial actions and IRAs to begin the remedial actions at the most highly
contaminated sites. IRAs were undertaken at RMA in advance of the ROD to stop the spread of or eliminate
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contamination and to begin the actual remediation. A site investigation and alternative assessment was performed
for each IRA. All IRAs that require the removal of material are carried out in accordance with applicable laws and
regulations and are consistent with and contribute to the efficient performance of the preferred alternatives for the
On-Post and Off-Post Operable Units.
Fourteen IRAs have been completed by the Army and Shell or will be incorporated into the final remedy as follows:
• Groundwater Intercept and Treatment North of RMA - This IRA was undertaken to address groundwater
contamination that had migrated off post prior to installation of the boundary extraction and treatment
systems on post. A groundwater extraction and treatment system is now in place north of RMA for
treatment of DIMP, solvents, and pesticides. The IRA includes one extraction and reinjection system
located along Highway 2 between 96th Avenue and 104th Avenue and another near 108th Avenue and
Peoria. The extracted water is treated by granular activated carbon (GAC) to Containment System
Remediation Goals (CSRGs) for organics at a treatment plant located on Peoria and reinjected into the
aquifer. Construction of this IRA was completed in 1993; treatment of groundwater at the north boundary
is ongoing.
• Improvement of North Boundary Containment and Treatment System and Evaluation of Existing Boundary
Systems - The NBCS was originally designed to remove and treat contaminated water reaching the north
boundary. Groundwater is extracted, treated by GAC, and reinjected into the ground. The primary
contaminants at this location are chloroform, dieldrin, DIMP, DCPD, and organosulfur compounds. The
original system consisted of extraction wells, a 6,740-ft slurry wall, a recharge sump, filters to remove
particles from water, three large (20,000 Ib) carbon adsorbers to treat organic contaminants to CSRGs from
groundwater, and reinjection wells. Groundwater is treated at a rate of 220 to 300 gpm. Operational
improvements were implemented as part of the IRA and the reinjection system for treated water was
improved by addition of recharge trenches along the entire portion of the extraction well system and the
slurry wall. Construction of the improvements to the NBCS was completed in 1993; treatment of
groundwater is ongoing.
The NWBCS was designed to remove and treat contaminated groundwater migrating toward the northwest
boundary. The original system included an extraction system, GAC treatment, and a reinjection system as
well as a slurry wall to control contaminant migration. The system has been improved under two different
IRAs, the Short-Term Improvements and the Long-Term Improvements IRAs. The slurry wall, which
originally measured 1,425 ft, was extended by 665 ft under the Short-Term Improvements IRA. Five
extraction wells were added to the original 15 extraction wells, and the number of reinjection wells was
increased from 21 to 25. The IRA modifications increased the amount of water treated in the NWBCS from
approximately 900,000 to 1.4 million gallons per day. The Long-Term Improvements IRA involved the
addition of seven monitoring wells, one extraction well, and an expansion of the monitoring program for
the system. Groundwater is treated to CSRGs for organic contaminants. Construction of the
improvements to the NWBCS was completed in 1993.
The ICS was designed to remove and treat contaminated groundwater migrating toward the western
boundary. The original system included two parallel rows of extraction wells, one row of reinjection
(recharge) wells, and GAC treatment. This system was designed to treat a DBCP plume migrating from the
Rail Yard. The system was improved during the IRA by installing four extraction wells approximately
2,000 ft upstream from the original system, adding nine new recharge wells adjacent to the original system,
and converting three of the original extraction wells to recharge wells. Groundwater is treated to CSRGs
for organic contaminants. Construction of the improvements was completed in 1991.
• Groundwater Intercept and Treatment North of Basin F - The purpose of the Basin F Groundwater IRA
was to intercept and remove contaminated groundwater migrating from the Basin F area toward the
northern boundary. The IRA involves extraction, treatment to CSRGs, and reinjection of groundwater.
Water is extracted from a well north of Basin F at a rate of 1 to 4 gpm (approximately 1 million gallons per
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2.0 Site History and Enforcement Activities
year). The extracted water is piped to a treatment system located at Basin A Neck for removal of volatile
contaminants (solvents) by ah- stripping, and the remaining contaminants, such as pesticides, by GAC.
Treated water is reinjected in recharge trenches at the Basin A Neck area. Construction of this IRA was
completed in 1990; treatment of ground water is ongoing.
• Closure of Abandoned Wells - At numerous locations throughout RMA, old or deteriorating farm wells
and unused on-post wells have been located and cemented closed. This IRA was completed in 1990.
• Groundwater Intercept and Treatment System in the Basin A Neck Area - The Basin A Neck IRA was
designed to capture and contain contaminated groundwater migrating from the Basin A area. The IRA
consists of extraction wells for removal of groundwater from the aquifer, a slurry wall to minimize
migration of contaminated groundwater, a treatment system, and a reinjection system consisting of several
recharge trenches. Approximately 12 to 20 gpm (5 to 10 million gallons per year) of groundwater are
extracted and treated to CSRGs by GAC at the Basin A Neck IRA treatment system. The contaminants
removed from water include solvents and pesticides. Construction of the Basin A Neck system was
completed in 1990; treatment of groundwater is ongoing.
• Basin F Liquids, Sludges, and Soil .Remediation - This IRA has included transfer of the basin liquids and
decontamination water into temporary storage tanks and a lined, covered surface impoundment (Pond A);
construction of a 16-acre lined waste storage pile with a leachate collection system; excavation of 600,000
cubic yards of Basin F soil and placement into the wastepile; and incineration of the stored liquids by
Submerged Quench Incineration (SQI). This IRA was completed in two phases. The first phase, which
involved the containment of the sludges/soil, was completed in 1989. The SQI system, which became
operational in May 1993, was shut down in July 1995 following the completion of the treatment of
approximately 11 million gallons of waste liquids. The SQI, storage tanks, and pond were closed in
accordance with a CDPHE closure plan. The tank farm and pond areas were clean closed to specific
closure performance standards for contaminants in the Basin F liquid. The SQI was demolished, and some
of the process equipment was salvaged. All field and administrative closure activities were completed by
May 30,1996.
• Building 1727 Sump Liquid - Liquid in the Building 1727 sump was treated by activated alumina and
GAC to remove contaminants that included arsenic and DIMP. This IRA eliminated any remaining threat
of liquid release from the sump; it was completed in 1989.
• Closure of the Hydrazine Facility - This facility was used as a depot to receive, blend, store, and distribute
hydrazine fuels. Wastewater stored at the facility was treated on post at the SQI facility, the structures
demolished, and the debris removed. Uncontaminated materials at the site were salvaged for recycling and
reuse, and contaminated materials were disposed at an off-post permitted hazardous waste landfill. The
area encompassing the former facility was regraded and revegetated following demolition and debris
removal. This IRA was completed hi 1992.
• Fugitive Dust Control - In 1991, the Army completed the reapplication of a dust suppressant (Dusdown
70) in Basin A as part of this IRA. Hydro-seeder trucks were used to spray a nontoxic, water-based dust
suppressant
• Sewer Remediation - As part of this IRA, sanitary sewer manholes were plugged to eliminate the transport
of contaminated groundwater that may have entered the sewer system via cracks or loose connections.
This IRA was completed in 1992.
• Asbestos Removal - This IRA is part of the Army's ongoing survey of asbestos on post, including removal
and disposal activities. The survey and removal of friable asbestos from occupied buildings were com-
pleted in December 1989. The Asbestos IRA activities continue as part of the final structures remediation.
• Remediation of Other Contamination Sources - Under this IRA, the following contamination sources have
or are being minimized or eliminated:
- Motor Pool - A groundwater extraction system was constructed to remove trichloroethylene (TCE) in
groundwater in the Motor Pool area. Because the low levels of TCE present in this water can be
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effectively treated by GAC, the water is piped to the ICS for treatment. The amount of water extracted
from the Motor Pool area is approximately 100 gpm. A soil vapor extraction (SVE) system was also
constructed to draw vapors containing volatile contaminants from the soil. Extracted vapors are sent
first to a separation tank to remove the water vapor and then to a treatment system where the volatile
contaminants are treated. Soil vapor extraction was conducted at the Motor Pool area between July and
December 1991 to remediate TCE-contaminated soil. Two vapor extraction wells as well as four
clusters of soil gas monitoring wells were installed. The Motor Pool groundwater extraction system is
currently operational.
- Rail Yard - This IRA was conducted to assess a potential DBCP problem in this area and introduce
cleanup measures if necessary. It was decided that groundwater removal would be necessary, but that
adequate treatment could be provided at the ICS at the western boundary of RMA. The Rail Yard IRA
extraction system consists of a row of five wells that extract approximately 230 gpm of groundwater
containing low levels of DBCP. The water is piped to the ICS where DBCP is removed by GAC. Two
additional wells further downgradient act as a backup system. Treatment is currently ongoing.
- Lime Settling Basins - Workers constructed a soil cover over the Lime Settling Basins area to isolate
the basins from the ground surface and minimize the amount of rainwater seeping into the basins. The
construction of the cover was completed in 1993.
- South Tank Farm Plume - The South Tank Farm consists of 11 tanks used for storage of alcohol,
BCHPD bottoms, DCPD, D-D soil fumigant, and sulfuric acid. Records indicate benzene was also
used or stored in this area. The South Tank Farm Plume, located between South Plants and the South
Lakes area, consists of two separate groundwater plumes extending toward the lakes, one of which
consists of light nonaqueous phase liquids (LNAPLs). The IRA alternative consisted of continued
groundwater monitoring to verify that no additional action was necessary due to the natural
degradation of the contaminants. Alternative assessment activities were completed in 1994.
In 1991, an SVE field demonstration, which included collection and analysis of soil, LNAPL, SVE
offgas, and soil gas samples, was designed for specific application to the South Tank Farm Plume. The
resulting data were used to evaluate the performance, effectiveness, and operating parameters for an
SVE system in the area of the plume. Based on the results of the demonstration, it would take more
than 10 years for the SVE process to remove the majority of the mass of contaminants that would
remain after LNAPL recovery was no longer feasible.
- Army Trenches - Soil samples collected from representative trenches showed elevated concentrations
of TCP metals and relatively low concentrations of arsenic, mercury, and many organic contaminants,
including members of all the analyte groups except pesticide-related organophosphorous compounds
and organonitrogen compounds. A large variety of tentatively identified compounds were also
detected in the trench soil. High concentrations of some organic contaminants exist in groundwater in
portions of this area. The IRA alternative consisted of continued groundwater monitoring in this area.
Alternative assessment activities were completed in 1994.
- Shell Trenches - Under this IRA, the trenches were covered with a soil cover and revegetated. A slurry
wall that surrounds the trench area was constructed to reduce the lateral movement of contaminants
away from the trenches. Construction of this IRA was completed in 1991.
• CERCLA Hazardous Wastes - The initial action was pretreatment of CERCLA liquid wastes. This IRA
was later expanded to include identification, storage, and disposal of a variety of CERCLA wastes. The
initial action and expanded elements are as follows:
- Wastewater Treatment Plant — A wastewater treatment plant was constructed by 1992 under the first
phase of the CERCLA Liquid Waste IRA. This facility is currently used to treat wastewater generated
from laboratory operations, field sampling, decontamination, and other sources such as equipment
washing. Several treatment technologies are used at the CERCLA Wastewater Treatment Plant
including activated GAC, advanced oxidation using ultraviolet light, air stripping, chemical
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2.0 Site History and Enforcement Activities
precipitation, and activated alumina adsorption. It is expected that this facility will be used to treat
similar wastewater streams during remediation.
- Waste Management - This element identified both off- and on-post landfilling as options to dispose
hazardous waste that has been or will be placed in storage areas at RMA and that has not been
addressed in another IRA. Waste streams currently being managed include RI/FS wastes; IRA wastes;
miscellaneous wastes from vehicles, grounds, and building maintenance; and items found on post
- Polychlorinated Biphenyls (PCBs) - The purpose of this element was to inventory and sample PCB-
contaminated equipment followed by remediation off post. This IRA included characterization of spill
sites (i.e., soil and structures) associated with PCB contamination and is ongoing. PCB contamination
not addressed hi this IRA will be addressed as part of the final remedy.
- Waste Storage - This element included analysis of an on-post facility for temporary management of
solids that are bulk hazardous wastes. These wastes primarily consist of contaminated soil and
building debris. Analysis resulted in the decision to dispose wastes in the on-post hazardous waste
landfill when it becomes available.
• Chemical Process-Related Activities - Agent-related and nonagent-related process equipment and piping
located in North Plants and South Plants is being sampled, decontaminated, and dismantled under this
IRA. Although much of the equipment in these areas has already been removed and recycled, process-
related equipment not remediated as part of this IRA will be disposed in the new on-post hazardous waste
landfill. Asbestos-removal activities as required for equipment removal will continue as part of the final
response action at RMA.
A summary of the actions undertaken in each IRA, including the status of the IRA, is presented in Table 2.4-1, and
the locations at which the actions were taken are presented in Figure 2.4-1. The procedure for IRA implementation
is set forth in Section XXII of the FFA. The typical IRA process that applies to most RMA IRAs is outlined in
Figure 2.4-2. For a variety of technical reasons, a slightly different process was used for the following IRAs:
Improvements of the North Boundary Containment System and Evaluation of all Existing Boundary Containment
Systems; Closure of Abandoned Wells; Basin F Liquids, Sludges, and Soil Remediation; and Fugitive Dust Control
(PMRMA 1988). The environmental media potentially affected by the implementation of the various IRAs are listed
in Table 2.4-2. Reports generated for these IRAs (Technical Plans, Alternatives Assessment Reports, Decision
Documents, Implementation Documents, and Operational Reports) can be accessed through the JARDF.
In addition, two other response actions were undertaken at RMA: waste disposal operations at the deep injection
well and the construction of the Klein treatment plant. The deep injection well was drilled 12,045 ft deep into
Precambrian rocks beneath Basin F as a solution to RMA's chemical waste disposal problem. As described hi
Section 2.2, 165 million gallons of waste were disposed in this well, but operations were suspended and the well
plugged when it was suspected that the injection of the wastes was causing an unusual series of earthquakes. The
Klein treatment plant (located in Section 33) was constructed in the mid-1980s to treat off-post groundwater to the
west of RMA that was primarily contaminated by chlorinated solvents. (It was subsequently determined that this
contamination originated primarily from non-RMA sources.)
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2.5 History of Enforcement Activities
2.5.1 CERCLA Enforcement Activities
On December 6, 1982, the EPA, Army, Shell, and Colorado Department of Health (now CDPHE) entered into a
Memorandum of Agreement outlining joint participation in the Army's study of decontamination at RMA.
Although the Parties followed the process outlined in the Memorandum of Agreement until 1986, they also pursued
litigation with respect to issues relating to legal authority over RMA remediation efforts, payment of natural
resource damages (NRDs), and reimbursement of costs expended for cleanup activities (response costs).
United States v. Shell Oil Company, Civil Action No. 83-C-2379
On December 9,1983, the United States filed this action in federal court to recover NRDs caused by the release of
Shell's contaminants at RMA and to recover from Shell a portion of the costs expended by the United States for
RMA cleanup efforts.
This case was consolidated with the state's case against the United States and Shell (discussed below) by the Court
on March 26,1985. On November 15,1985, the Court ruled that the United States and Shell were liable parties at
RMA, subject to certain defenses. The Parties filed a joint stipulation setting forth the factual bases for the United
States' and Shell's liability on November 18,1985.
On February 1, 1988, the United States and Shell lodged a proposed consent decree with the Court to resolve the
litigation between those two parties. The proposed consent decree set forth the process to be utilized to select and
implement cleanup decisions for RMA, subject to public comments. The United States and Shell moved for entry of
a modified consent decree on June 7, 1988, following the receipt of public comments. This version of the modified
consent decree was never entered by the Court.
In February 1989, the Army and Shell, along with EPA, USFWS, ATSDR, and U.S. Department of Justice,
executed the FFA, an interagency agreement and administrative order on consent that embodied the terms of the
modified consent decree. The state did not agree with parts of the FFA and did not become a signatory. The state
has remained actively involved in RMA remediation efforts and participated in informal dispute under the FFA.
The United States and Shell also executed a Settlement Agreement that set out a process to deal with financial issues
between them, such as the allocation and payment of response costs or NRDs.
Under the Settlement Agreement, the United States and Shell share "allocable costs" relating to RMA remediation to
different degrees based on the cumulative total of those costs. Allocable costs are defined in the Settlement
Agreement. For the first $500 million of allocable costs, the United States and Shell are equally responsible. For
the next $200 million, the United States is responsible for 65 percent of allocable costs and Shell is responsible for
35 percent of those costs. For allocable costs over $700 million, the United States is responsible for 80 percent of
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2.0 Site History and Enforcement Activities
allocable costs and Shell is responsible for 20 percent of those costs. The United States and Shell are also separately
responsible for all costs with respect to Army-only or Shell-only response actions, respectively, which are described
in exhibits to the Settlement Agreement. This case was resolved by entry of a modified proposed consent decree on
February 12,1993.
EPA, Army, Department of Interior, and Shell have established a process for resolving disputes that arise at RMA
concerning CERCLA cleanup actions. This dispute resolution process is set forth in the FFA (EPA et al. 1989).
The state of Colorado became a party to the FFA dispute resolution process on June 13, 1995, when it signed, along
with the above entities, the Agreement for a Conceptual Remedy for the Cleanup of the Rocky Mountain Arsenal
(Conceptual Remedy). The only provisions of the FFA that shall be binding upon the state are those relating to
dispute resolution.
The state declares its intention to utilize the FFA dispute-resolution process in a good-faith effort to resolve all
issues informally. For any issues not subject to dispute resolution under the FFA, and for those issues over which
the state has independent authority pursuant to United States v. State of Colorado and the Colorado Department of
Health, Civil Action No. 89-C-1646, 990 F. 2d 1565 (10th Cir. 1993), cert, denied 114 S. Ct. 922 (1994), the state
reserves any rights and authorities it may have.
State of Colorado v. United States and Shell Oil Company, Civil Action No. 83-C-2386
On December 9,1983, the state of Colorado filed an action in federal court seeking NRDs from the Army and Shell
under CERCLA for injury to the state's natural resources. On November 25, 1985, the state added a claim against
the Army and Shell for response costs the state had expended at RMA pursuant to CERCLA.
On March 14, 1989, pursuant to a partial settlement of the state's response cost claim, the Army and Shell each
agreed to pay the state $1 million to cover state costs at RMA through December 31,1988.
The state then requested reimbursement for costs it had incurred from January 1, 1989 to June 30, 1992. The Court
ruled on several legal issues relating to these response costs on November 17, 1994. (State of Colorado v. United
States and Shell Oil Company, 867 F. Supp. 948 [D. Colo. 1994].) The Court found that the state's costs expended
to enforce its hazardous waste laws could be reimbursed to the state under CERCLA if the cost met the CERCLA
definition of response costs. The Court also held that the Army and Shell were responsible for interest from the date
response costs were incurred because the state had previously demanded payment. The Court also held that the
Army and Shell were responsible for interest on response costs incurred after February 7, 1989, the date that the
state made a specific dollar amount demand for response costs, at the time these costs were incurred. Interest for
response costs incurred before February 7,1989 was held to begin to accrue on February 7,1989.
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On January 31, 1995, the Parties entered into a partial settlement under which the Army and Shell paid the state
$4.8 million for response costs from January 1,1989 through June 30,1992.
On February 9, 1995, the Court placed the NRD portion of the state's case against the United States and Shell on
administrative closure pending remedial selection. However, the portion of this litigation with respect to subsequent
response costs remains open. In September 1995, the state made a demand for payment of response costs to the
Army and Shell for the period of July 1,1992 to June 30,1994.
2.5.2 State Enforcement Activities
State of Colorado v. Department of the Army, Civil Action No. 86-C-2524
In 1974, the Colorado Department of Health (now CDPHE) detected DIMP and DCPD hi the groundwater aquifer
north of RMA. On April 7,1975, CDPHE issued three administrative orders to the Army and/or Shell with respect
to this contamination. These orders cited violations of the Colorado Water Quality Control Act and directed Shell
and/or the Army to immediately stop the off-post discharge of DIMP and DCPD in surface and subsurface water.
On October 1, 1986, CDPHE issued a final modified closure plan for Basin F pursuant to the Colorado Hazardous
Waste Management'Act (CHWMA) and its implementing regulations. CHWMA is the state-delegated RCRA
program. The closure plan became effective on October 2,1986. On November 14, 1986, the state filed an action
against the Army in state court. On December 15, 1986, the case was removed to the U. S. District Court for
Colorado. The state's original complaint alleged violations of the CHWMA groundwater monitoring regulations.
On October 14, 1987, the Army notified CDPHE, based on EPA' s listing of RMA (excluding Basin F) and the
proposed listing of Basin F on the NPL on July 22,1987, Basin F and the RMA were no longer subject to CHWMA
jurisdiction. The Army stated its intent to implement a cleanup for Basin F pursuant to its authority under
CERCLA.
On December 4, 1987, the state was granted leave to amend its complaint to add claims alleging a failure to close
Basin F in accordance with the closure plan issued under CHWMA and alleging the Army's failure to pay fees due
under CHWMA.
On February 24, 1989, the Court, in a memorandum opinion denying the United States' motion to dismiss the
state's complaint, stated that CERCLA was intended to operate independently of and in addition to RCRA and held
that CHWMA enforcement was not precluded by CERCLA in the circumstances then presented (State of Colorado
v. Department of the Army, 707 F. Supp. 1562, 1569-70 [D. Colo. 1989]). The Court further ruled that the state's
CHWMA regulations pertaining to groundwater monitoring and closure of hazardous waste units were within the
waiver of federal sovereign immunity in Resource Conservation and Recovery Act (RCRA). Based, in part, on
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2.0 Site History and Enforcement Activities
EPA's subsequent listing of Basin F on the NPL, the United States filed a motion for reconsideration of the Court's
February 24th order on March 6, 1989. The Court did not rule on this motion. The remaining aspects of the case
were dismissed without prejudice on September 4, 1991 as a result of subsequent developments in other RMA
cases.
United States v. State of Colorado and the Colorado Department of Health, Civil Action No. 89-C-1646
Following inspections of the Basin F site in May and June of 1989, CDPHE issued a compliance order against the
Army, citing 42 violations of CHWMA and its implementing regulations regarding hazardous waste management.
The compliance order was amended twice. A final amended compliance order was issued on September 1, 1989,
with a stated effective date of September 22,1989.
On September 22, 1989, the United States filed suit in federal court, United States v. State of Colorado and the
Colorado Department of Health, Civil Action No. 89-C-1646, seeking a judgment that CDPHE had no authority to
enforce the final amended compliance order and that the United States was not liable for civil penalties under RCRA
or CHWMA.
On August 14, 1991, the Court ruled in the United States' favor and enjoined the state from taking any action to
enforce the final amended compliance order or to impose civil penalties against the United States. The state
appealed this ruling in regards to its enforcement authority to the Tenth Circuit Court of Appeals on October 11,
1991.
On April 6, 1993, the Tenth Circuit ruled that RMA is a facility subject to interim status requirements pursuant to
CHWMA and its implementing regulations and that the state has the authority to enforce its federally-delegated
hazardous waste program at RMA.
On June 30, 1993, the Tenth Circuit issued an amended opinion and denied the United States' petition for rehearing.
(United States v. State of Colorado and the Colorado Department of Health, 990 F. 2d 1565 [10th Cir. 1993].) The
amended opinion acknowledges that "final disposition of the solids remaining under the Basin F cap and in the
wastepile will be determined as part of the remedial action for which a final record of decision will be issued." The
opinion also reiterates that the state has authority to enforce CHWMA at RMA by holding that "the Army is
obligated to comply with RCRA/CHWMA regulations applicable to interim status facilities pending closure of
Basin F pursuant to an approved closure plan" (Id. at 1512 n. 11, 1582 n. 22). On July 8, 1993, the mandate was
issued for the Tenth Circuit decision and the case was remanded to the District court.
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On November 17, 1993, the United States petitioned the Supreme Court of the United States to review the decision
of the Tenth Circuit. The Supreme Court denied the United States' petition on January 24, 1994 (114 S. Ct. 922
[1994]).
On June 30, 1994, the United States and the state of Colorado entered into a consent decree resolving remaining
litigation issues. The consent decree required the Army to submit closure plans for Basin F and the Basin F
Wastepile for CDPHE approval.
United States v. Colorado Water Quality Control Commission, Civil Action No. 94-C-491
On December 27,1993, the Colorado Water Quality Control Commission, after a public hearing, issued a Notice of
Final Adoption, setting a groundwater standard for DIMP at 8 parts per billion (ppb). The United States filed a
lawsuit in federal court on March 2, 1994 challenging the state's DIMP standard. On May 5, 1995, the Court
granted the state's motion to dismiss the complaint. The Court relied on the abstention doctrine, under which
federal courts decline to review matters concerning state agency action where such review would interfere with state
programs pertaining to matters of local concern. On May 18, 1995, the United States filed a motion for amendment
and reconsideration of the May 5th decision. The Court has not ruled on this motion.
2.5.3 Conceptual Remedy
As required by CERCLA, and in accordance with the FFA, the Army's selection of a preferred alternative was
based on the RI, the Exposure Assessment and Integrated Endangerment Assessment/Risk Characterization, FS, and
other scientific and technical information. As part of the remedial process, the Parties engaged in an extensive
series of meetings over a 6-month period regarding the remediation of RMA. Interested citizens and representatives
of city and county agencies, collectively called the Stakeholders, also participated in discussions about potential
remedial approaches. These stakeholder meetings, along with information obtained in the previously described
process, provided the basis for negotiations among the Parties that culminated in the Conceptual Remedy, which
was signed by the Parties on June 13, 1995. The Detailed Analysis of Alternatives report incorporates the elements
of the Conceptual Remedy and became the basis for the Proposed Plan for the Rocky Mountain Arsenal On-Post
Operable Unit (Foster Wheeler Environmental 1995b). The Proposed Plan was submitted for public comment on
October 16,1995, and was the subject of a public meeting on November 18,1995.
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Treatability
Studies
Technology
Inventory and
Screening
v On-Poat
' Remedial
Investigation
Development of,
L Remedial Action
Objectives/ Selection
•: of Representative
r Process Options
T
Development and
Screening of
' - Alternatives
Detailed Analysis
of Alternatives /
Selection of
: Preferred
*" Alternatives
Proposed Plan /
~< Record of
Decision
Remedial Design
Remedial Action
> Exposure/
Toxiclty
, Assessments
Risk
Characterization /
Integrated,
| Endangerment
Assessment
B Completed Activity
| Currant Activity
Q Future Activity
RMA ROD 6.96jb
Figure 2.3-1
Remedial Investigation /
Endangerment Assessment /
Feasibility Study Flow Diagram
Rocky Mountain Arsenal
Prepared by Foster Wheeler Environmental Corporation
-------
North of RMA
Intercept Areo
0
3
£
£
3
*
©
CERCIA Wostewoft
Treatment Facility
Hydrozm. Blending
and Storage FocJity
0 RMA-Wid.
RMA-Wde
© RMA-Wde
Legend
Off—Poet Groundwoter Intercept
and Treatment System North of RMA
Improvement of North Boundary
System and Evaluation of Existing
Boundary Systems
Groundwater Intercept and Treatment
System North of Basin F
vi)
© Closure of Abandoned Wells
© Groundwater Intercept and Treatment
System in the Basin A Neck Area
© Basin F Liquids, Sludges, and Soil
Remediation
© Building 1727 Sump liquid
© Closure of the Hydrazlne Facility
© Fugitive Dust Control
@ Sewer Remediation
(M) Asbestos Removal
@ Remediation of Other
Contamination Sources
@ CERCLA Hazardous Wastes
© Chemical Process-
Related Activities
I
s
Prepared for
Offin
-------
Identification of proposed
Interim Response Action
Army initiates Assessment I
Army selects initial
draft ARARs
Army conducts Assessment
Army transmits draft
assessment /ARARs to
Organizations and State
Comment period
Army transmits Final
Assessment to
Organizations and State
that includes responses
to comments
Army prepares Proposed
Decision Document
Army transmits Draft
Proposed Decision
Document to Organizations
and State for public comment
Comment period
Army transmits comments;
prepares Draft Final Decision
Document; transmits to
Organizations and State
Design work
\
r
Lead Party issues
Implementation Document
No
^
/*
/ Reso
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Table 2.3-1 Inception and Completion Dates for Major RMA Documents
Page 1 of 1
Document
Start Date
Finish Date1
Remedial Investigation
Human Health Exposure Assessment
Human Health Exposure Assessment Addendum
October 1984
October 1986
August 1990
Integrated Endangerment Assessment/Risk Characterization
Human Health Risk Characterization May 1990
Ecological Risk Characterization October 1987
Development and Screening of Alternatives February 1989
Detailed Analysis of Alternatives January 1993
Proposed Plan July 1995
January 1992
September 1990
December 1992
September 1992
July 1994
December 1992
October 1995
October 1995
Finish date indicates the date the final version of the document was submitted to the administrative record for public review.
ma/154gG.DOC
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Table 2.4-1 Summary of Past and Ongoing Response Actions
Page 1 of 2
Response Action
Objective
Status/Completion'
Interim Response Actions
1. Groundwater Intercept and
Treatment System North of RMA
Capture and treat contaminated groundwater
plumes north of RMA.
2. Improvement of the North Boundary Evaluate and improve, as necessary, the
Containment and Treatment System operation of the boundary containment and
and Evaluation of Existing Boundary treatment systems.
Systems
3. Groundwater Intercept and Capture and treat contaminated groundwater
Treatment System North of Basin F north of the Basin F area closer to its source.
Construction completed
1993; treatment is
ongoing.
Construction completed
1993; treatment is
ongoing.
Construction completed
1990; treatment is
ongoing.
4. Closure of Abandoned Wells
5. Groundwater Intercept and
Treatment System in the Basin A
Neck Area
6. Basin F Liquids, Sludges, and Soil
Remediation
Identify, locate, examine, and properly close Completed 1990.
old or unused wells at RMA to prevent
vertical migration of contamination between
aquifers.
7. Building 1727 Sump Liquid
8. Closure of the Hydrazine Facility
9. Fugitive Dust Control
10. Sewer Remediation
11. Asbestos Removal
12. Remediation of Other Contamination
Sources
• Motor Pool
• Rail Yard
• Lime Settling Basins
• South Tank Farm Plume
• Army Trenches
• Shell Trenches
Capture and treat shallow contaminated
groundwater from Basin A closer to the
source area.
Construct wastepile and cap that minimize
the potential for infiltration of contaminants
to groundwater and the potential for volatile
emissions; reduce the potential impact of
Basin F on wildlife; and incinerate Basin F
liquids.
Treat contaminated liquid in the sump.
Treat the wastewater stored at this facility
and demolish the aboveground structures.
Minimize the amount of windblown
contaminated dust.
Plug the RMA sanitary sewers so that they
cannot transport contaminated groundwater.
Remove and dispose of friable asbestos in
RMA structures where any potential for
human exposure exists.
Minimize or eliminate releases from selected
contamination sources.
Construction completed
1990; treatment is
ongoing.
Containment of
sludges/soil completed in
1989; incineration of
liquids completed 1995.
Completed 1989.
Completed 1992.
Application completed
1991; reapplication as
required by final
response action.
Completed 1992.
Action is ongoing as part
of ROD implementation.
Action is ongoing as part
of ROD implementation.
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Table 2.4-1 Summary of Past and Ongoing Response Actions
Page 2 of 2
Response Action
Objective
Status/Completion'
13. CERCLA Hazardous Wastes
• Wastewater Treatment Facility
• Waste Management
• Polychlorinated Biphenyls
• Waste Storage
14. Chemical Process-Related Activities
• Agent Equipment and Tanks
• Nonagent Equipment and Tanks
• Underground Storage Tanks
Other Response Actions
1. Klein Treatment Plant
2. Deep Injection Well Closure
Construct and operate a facility to treat
wastewater resulting from response actions;
identify disposal options for hazardous
wastes; inventory, sample, and remediate
PCB-contaminated structures and soil;
analyze temporary management of bulk
hazardous wastes.
Remove and dispose of contaminated
process-related equipment from
manufacturing areas.
Construct and operate a facility to treat
chlorinated-solvent contaminated
groundwater extracted by SACWSD wells
west of RMA.
Properly seal and abandon deep injection
well adjacent to Basin F.
Construction of treatment
plant completed 1992;
liquid treatment and
waste management is
ongoing; PCB
remediation is ongoing as
part of ROD
implementation; waste
storage analysis
completed.
Action is ongoing as part
of ROD implementation.
Construction of treatment
plant completed 1989;
water treatment is
ongoing.
Completed in 1985.
All ongoing actions are incorporated as part of the final response action.
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Table 2.4-2 Media Potentially Impacted by Past and Ongoing Response Actions Page 1 of 1
Response Action
Interim Response Actions
Groundwater Intercept and Treatment System North of RMA
Improvement of the North Boundary System and Evaluation of
all Existing Boundary Systems
Groundwater Intercept and Treatment System North of Basin F
Closure of Abandoned Wells at RMA
Groundwater Intercept and Treatment System in the Basin A
Neck Area
Basin F Liquids, Sludges, and Soil Remediation
Building 1727 Sump Liquid
Closure of the Hydrazine Facility
Fugitive Dust Control
Sewer Remediation
Asbestos Removal
Remediation of Other Contamination Sources
• Motor Pool
• Rail Yard
• Lime Settling Basins
• South Tank Farm Plume
• Army Trenches
• Shell Trenches
CERCLA Hazardous Wastes
• Wastewater Treatment Facility
• Waste Management
• Polychlorinated Biphenyls
• Waste Storage
Chemical Process-Related Activities
• Agent Equipment and Tanks
• Nonagent Equipment and Tanks
• Underground Storage Tanks
Other Response Actions
Klein Treatment Plant
Deep Injection Well Closure
Soil
X
X
X
X
X
X
X
X
X
X
X
X
Water
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Structures Air
X
X
X X
X
X X
X X
X
X X
X
X
X X
X X
X X
Biota
X
X
X
X
X
X
X
X
X
X
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3.0 Highlights of Community Participation
3.0 Highlights of Community Participation
The Department of Defense has long recognized that successful environmental restoration projects require the input
of interested community residents. To that end, the Army began developing its Community Involvement Program
in 1984 as the first environmental investigations were initiated. The Community Involvement Program has one
primary objective: inform and involve the public with regard to site studies, proposed technologies, and ongoing
remediation projects. A comprehensive Community Relations Plan was first developed in May 1990 to provide a
road map for public involvement, which was further revised in May 1995. The Army has accomplished the public
involvement objectives by conducting one-on-one sessions and informal group meetings, soliciting input using
surveys and questionnaires, and pursuing phone contacts to identify interested citizens and organizations, assess
public perceptions of the issues, and determine appropriate mechanisms for engaging in two-way communication.
In addition, the Army has made available to the public the comprehensive documentation generated during the
remediation process at the JARDF and eight area libraries (Table 3.0-1).
Educational outreach efforts included developing several publications that describe current investigations and
available remedial technologies, making literature regarding the on-post remediation available to the public, and
conducting more than 20 open houses and public meetings. In 1990, a joint Public Affairs Office (PAD)
Subcommittee of the RMA Committee was formed to pool the skills and resources of public information specialists
from all the Parties. The majority of fact sheets and training materials were developed by this subcommittee.
An example of a current publication is "Update," which has been distributed to approximately 125,000 households
within a 10-mile radius of the installation on a quarterly basis since 1990. The focus of Update is to highlight a
single, significant issue of the remediation during the preceding quarter. Past Update topics have included the
various technologies considered to manage the Basin F liquid, the building of the SQI, the test-bum results of the
SQI, and the release of the Proposed Plan for the On-Post Operable Unit. Along with lead stories on similar topics,
the publication has also described opportunities for public involvement, including the schedules for public meetings,
workshops, and tours. The Army has also published a tri-fold brochure, called "RMA Public Outreach," focusing
on public outreach programs since 1994. Various topics discussed in this quarterly pamphlet include RMA
technical information and history, wildlife viewing tour schedules, educational programs, and recycling programs.
Since 1988 all the Parties have made extensive efforts to ensure that the public is kept informed on all aspects of the
cleanup program. More than 100 fact sheets about topics ranging from historical information to site remediation
have been developed and made available to the public. All educational materials were developed and coordinated
with all the Parties. In addition, ATSDR has provided public health information and support, including health
consultation related to the Basin F IRA, a Public Health Assessment of RMA, and other health-related studies.
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The Army held one of its largest public open houses in January 1994, following the release and distribution of the
draft Detailed Analysis of Alternatives report for the On-Post Operable Unit. The purpose of the event was to
provide the public one-on-one experience with federal, state, and local professionals who could explain in simple
terms the views of their organizations regarding the various aspects of the remediation. It was vital to the success of
the open house that the organizations, although not in total agreement with the technologies being proposed for the
final remedy, were available to present their respective opinions.
Regulatory agencies represented at the event were EPA, CDPHE, and Tri-County Health Department. The two
responsible parties, the Army and Shell, were also present. Members of USFWS were also available to express their
opinions on the various proposed remedies from the standpoint of habitat preservation. Each organization created
displays that described the organization's position and staffed these displays with experts available to answer
questions from the public. Videos were shown that detailed, in easy-to-understand terms, the various technologies
outlined in the draft Detailed Analysis of Alternatives report.
As part of the open house, the Army offered site tours of RMA to the 1,000 citizens who attended. The tours, which
were accompanied by technical experts who explained the ongoing remedial operations, provided visitors with a
better understanding of the size of the installation and the .degree of contamination at various locations as well as its
potential as a national wildlife refuge. The Army and USFWS cooperate in implementing and supporting
community involvement activities regarding wildlife/habitat during remediation. Remediation activities will take
into account RMA's end use as a national wildlife refuge, which fulfills the provision of the FFA that states it is a
goal of the Organizations to make significant portions of the site available for beneficial public use. In October
1992, in conjunction with the future goal of beneficial public use and in recognition of the unique urban wildlife
resources provided by RMA, President George Bush signed the Rocky Mountain Arsenal National Wildlife Refuge
Act, making RMA a national wildlife refuge following EPA certification that required response actions have been
appropriately completed.
Prior to April 1994, various public meetings and workshops were coordinated with interested citizens through a
Technical Review Committee (TRC), which was established under FFA and CERCLA guidelines. The committee,
established at RMA in 1989, was comprised of representatives from local health and regulatory agencies,
community residents, and the local government. In November 1993, the TRC opened its meetings to the public.
In April 1994, the Department of Defense directed military installations involved in environmental remediation to
transition the TRCs into Restoration Advisory Boards (RABs). The RAB at RMA serves as a forum to exchange
information and establish open dialog among the communities, regulatory agencies, the Army, and Shell. In less
than 1 year, the RAB modified how public input was obtained and incorporated into the CERCLA process for
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3.0 Highlights of Community Participation
selecting a remedy for RMA. For example, one of the primary changes included making the JARDF more user-
friendly. Millions of pages of documents relating to RMA history, mission, remediation, and wildlife were made
available to the public via a computerized optical disk system. Citizens may access volumes of research material on
literally any subject relating to RMA simply by keying in a word or series of words. The system then allows users
to select a specific document or page of a document for further review. The JARDF allows users to photocopy up to
100 pages of RMA-related material at no charge.
The Site-Specific Advisory Board (SSAB) of RMA was formed with the assistance of EPA and CDPHE in 1994.
Although the RAB is the officially recognized citizen advisory board for RMA, the SSAB serves as another forum
for community concerns. Many of the members serving on the SSAB also serve on the RAB. More information on
the SSAB can be obtained from CDPHE at (303) 692-3327.
A Technical Assistance Grant (TAG) was awarded to Citizens Against Contamination (CAC) by EPA in 1990.
CAC was formed in 1985 and has been monitoring all aspects of the remediation at RMA and has provided a crucial
role for public participation in the decision-making process. The TAG has provided funds to CAC so that an
outside consultant could be hired to assist with the interpretation of technical information. In 1995, an additional
$50,000 grant was awarded to CAC for continued technical assistance.
Members of the public and local authorities participated in an extensive series of meetings during 1994-95
regarding the remediation of RMA. These meetings provided the basis for negotiations among the Parties that led to
the Conceptual Remedy in June 1995 and the Detailed Analysis of Alternatives report and Proposed Plan in October
1995.
The Proposed Plan was released for public review on October 16, 1995. On November 18, 1995 the Parties held a
public meeting, attended by approximately 50 members of the public, to obtain public comment on the Proposed
Plan. As a result of requests at this meeting, the period for submitting written comments on the plan was extended
1 month, concluding on January 19,1996.
The Army also regularly issues press releases and provides access to hotlines that relate up-to-date information
about remedial operations, and publishes brochures on selected topics, environment/wildlife tours, and school
programs. Army representatives and public outreach specialists from EPA, USFWS, Shell, and CDPHE also visit
area libraries, schools, and grocery stores and distribute flyers and brochures regarding the public meetings, the
remediation process, and recreational activities available at RMA. The PAO Subcommittee has also established an
active speaker's bureau program that serves as a focal point to communicate with civic organizations. RMA has
also established an Internet World Wide Web home page (http://www.pmrma-www.army.mil).
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Table 3.0-1 Area Libraries Holding RMA Documentation
Page 1 of 1
Library
RMA Joint Administrative Record Document
Facility1
Adams County Library
Brighton Branch
Aurora Public Library
Commerce City Public Library
Denver Public Library
EPA Library
Lakewood Public Library
Montbello Public Library
Park Hill Library2
Address
Building 135, Room 16
72nd Avenue and Quebec Street
Commerce City, CO 80022
575 S. Eighth Avenue
Brighton, CO 80601
14949 East Alameda Drive
Aurora, CO 80012
7185 Monaco Street
Commerce City, CO 80022
10 West 14th Avenue Parkway
Denver, CO 80204
999 18th Street, Suite 500
Denver, CO 80202
10200 West 20th Avenue
Lakewood, CO 802 15
12955 Albrook Drive
Denver, CO 80239
4705 Montview
Denver, CO 80207
Telephone Number
(303)289-0362
(303)659-2572
(303)340-2290
(303)287-0063
(303) 640-6200
(303)312-6937
(303)232-9507
(303) 373-0767
(303)331-4063
1 The entire administrative record is accessible through the JARDF.
2 Only the Proposed Plan, Detailed Analysis of Alternatives report, and ROD can be found at Park Hill Library.
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4.0 Scope and Role of the On-Post Operable Unit
4.0 Scope and Role of the On-Post Operable Unit
The On-Post Operable Unit is one of two operable units at RMA (Figure 1.0-1). The On-Post Operable Unit
addresses contamination within the fenced 27 square miles of RMA proper. The contaminated areas include
approximately 3,000 acres of soil, 15 groundwater plumes, and 798 remaining structures. The most highly
contaminated sites are located at South Plants (Central Processing Area, Hex Pit, Buried M-l Pits, Chemical
Sewers), Basins A and F, Lime Basins, and the Army and Shell disposal trenches. The primary contaminants at
these sites are pesticides, solvents, heavy metals, and agent byproducts, which are found in soil and/or
groundwater. The soil in these areas poses a principal threat to human and ecological receptors! The potential
exposure pathways through which a threat would be posed to humans are identified in Section 6.1 and for
wildlife in Section 6.2.
At RMA, groundwater contamination is moving principally to the north and northwest, but it is intercepted
before it flows off post by the boundary groundwater treatment systems west, northwest, and north of the major
source areas. At these systems, the groundwater is treated to established CSRGs (see Section 9). Ongoing
monitoring of n-nitrosodimethylamine (MDMA) will be used in support of design refinement for the
groundwater treatment systems. Possible ingestion or dermal contact with the groundwater is not a threat to
human health on post because the use of groundwater for domestic purposes is restricted by the FFA.
Nonpotable uses of on-post groundwater were not anticipated and risk was therefore not considered in the
human health risk characterization portion of the Integrated Endangerment Assessment/Risk Characterization
for such uses. A risk evaluation would be performed prior to any future nonpotable use to ensure that such use
would be protective of human health and the environment.
The purpose of the on-post remedial action is to prevent current or future excessive exposure to contaminated
soil or structures, to reduce contaminant migration into the groundwater, and to treat contaminated groundwater
at the boundary to meet remediation goals. Remedial measures for on-post groundwater will augment the soil
remedy and facilitate long-term remediation of groundwater. In addition, it addresses the arrangement for
provision of potable water to the South Adams County Water and Sanitation District (SACWSD). The selected
remedy described in this ROD will permanently address the threats to human health and the environment by
using a combination of containment (as a principal element) and treatment technologies to reduce the toxicity,
mobility, or volume of contaminants in groundwater, structures, or soil; comply with applicable or relevant and
appropriate requirements (ARARs); and be cost effective.
The Off-Post Operable Unit addresses contamination in the groundwater north and northwest of RMA. The
area impacted by this contamination is referred to as the Off-Post Study Area (see Figure 1.0-1). The final
ROD for the Off-Post Operable Unit was issued in December 1995, the major components of which are
summarized in Table 4.0-1.
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Record of Decision for the On-Post Operable Unit
The selected remedy for the On-Post Operable Unit, integrated with the IRAs and the selected remedy for the
Off-Post Operable Unit, will comprehensively address all contamination at RMA. The ROD for the On-Post
Operable Unit will be the final response action at RMA.
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Table 4.0-1 Description of the Remedy for the Off-Post Operable Unit Page 1 of 1
Component Description •
1 Continued operation of the Off-Post Groundwater Intercept and Treatment System.
2 Natural attenuation of inorganic chloride and sulfate concentrations to meet remediation goals
for groundwater in a manner consistent with the on-post remedial action.
3 Continued operation of the NWBCS, NBCS, and ICS as specified in Section 12 of the ROD for
the On-Post Operable Unit.
4 Improvements to the NBCS, ICS, NWBCS, and the Off-Post Groundwater Intercept and
Treatment System as necessary.
5 Long-term groundwater monitoring (including monitoring after groundwater treatment has
ceased) to ensure continued compliance with the CSRGs.
6 Five-year site reviews.
7 Exposure control/provision of alternate water as detailed in the ROD for the Off-Post Operable
Unit.
8 Institutional controls, including deed restrictions on Shell-owned property, to prevent the use of
groundwater exceeding remediation goals.
9 Closure of poorly constructed wells within the Off-Post Study Area that could be acting as
migration pathways for contaminants found in the Arapahoe aquifer.
10 Continuation of monitoring and completion of an assessment by the Army and Shell of the
NDMA plume by June 13, 1996 using a 20 ppt method detection limit.
11 Preparation of a study that supports design refinement for achieving NDMA remediation goals
at the RMA boundary. The study will use a 7.0 ppt preliminary remediation goal or a certified
analytical detection level readily available at a certified commercial laboratory (currently 33
ppt).
12 Tilling and revegetation of approximately 160 acres in the southeast portion of Section 14 and
the southwest portion of Section 13 by the Army and Shell.
13 Treatment of any contaminated extracted groundwater prior to discharge or reinjection so that it
meets the CSRGs that meet or exceed the water quality standards established in the CBSGs and
CBSMs.
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5.0 Summary of Site Characteristics
5.0 Summary of Site Characteristics
This section provides a general overview of site characteristics at RMA. More detailed information regarding the
environmental setting, nature and extent of the contamination, contaminant fate and transport, and other special
investigations associated with the RI Program can be found in the Remedial Investigation Summary Report and
references therein.
The Army initiated the RI Program in 1984 to define the nature and extent of contamination in soil, water,
structures, air, and biota at RMA to a degree sufficient to permit an assessment of contaminant migration and •
exposure to human and ecological receptors and selection of viable remediation options for RMA.
5.1 Sources of Contamination
Contaminants were introduced into the RMA environment beginning in the early 1940s by disposal of liquid waste
in open basins, solid waste burial in trenches, accidental spills of feedstock and product chemicals, leakage from
sewer and process water systems, emissions from air stacks, and use of commercial chemical products during
normal facility operation. The most highly contaminated sites are located at South Plants, Basins A and F, and the
Army and Shell disposal trenches in Section 36. Other contaminated sites include storage areas, maintenance areas,
and sewer lines. Over time contaminants have migrated from the soil and sediments to groundwater at RMA.
5.2 Nature of Contamination
More than 600 chemicals have been associated with activities at RMA since it was first established. However, on
the basis of risk and frequency of use, the RI focused on about 70 chemicals. Of these, the principal contaminants
are organochlorine pesticides (OCPs), metals (including arsenic and mercury), agent-degradation products and
manufacturing byproducts (e.g., DIMP), DBCP, and chlorinated and aromatic solvents. Contamination in soil,
sediment, and groundwater includes relatively mobile and soluble compounds (e.g., solvents) and less soluble
contaminants, principally OCPs and arsenic. This range of contaminants exhibits a great variability in
environmental mobility and persistence. OCPs are less mobile than the other contaminants present and are more
persistent, tending to associate with soil and sediment and to biomagnify in the food chain. Conversely, a solvent
or DIMP migrates more readily into the groundwater and can spread more rapidly in groundwater plumes.
However, the relative contributions of various sources to groundwater plumes are often difficult to ascertain as
contaminants within a groundwater plume can rarely be unequivocally associated with a specific source.
5.3 Contaminant Migration Pathways
Chemicals have historically migrated from source areas through the unsaturated zone, unconfined and confined flow
systems, surface water, and wind-borne pathways. These pathways are briefly described as follows:
• Unsaturated Zone - This is the usual pathway by which contaminants enter the aquifer. Contaminants
migrate through the unsaturated zone to the aquifer most readily when it is thin and/or highly permeable.
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Record of Decision for the On-Post Operable Unit
The unsaturated zone is relatively thin beneath Basin A, the Lime Settling Basins, the Section 36 disposal
trenches, and the north-central portion of South Plants.
• Unconfined Flow System - This is a major groundwater migration pathway that has transported
contamination in shallow groundwater to the north and west from source areas.
• Confined Flow System - This pathway generally consists of fine-grained discontinuous, permeable sand
lenses and lignites, separated by low-permeability siltstones and claystones, of the Denver Formation.
Detections of contaminants in this pathway generally correspond with contaminant plumes in the overlying
UFS, but the contamination is much less widespread and at much lower concentrations. In many cases,
detections are suspected to be related to faulty well installation rather than actual migration into this zone.
Transport of contaminants along this pathway is much slower than in the UFS.
• Surface Water - Historically, this was a major contaminant transport pathway, contributing to the spread of
contaminants in basins, ditches, lakes, ponds, and land at RMA. Use of the disposal ditches has been
discontinued. Runoff from major storm events or snow melt is expected to transport low concentrations of
contaminants present in surficial soil, although the efficiency of this mechanism is limited for most areas.
• Windblown - Windblown transport of residual contamination from various sources is responsible for broad
areas of low-level surficial soil contamination within RMA boundaries adjacent to the major source areas.
In the past, human and ecological receptors have potentially been exposed to contaminants via these pathways. The
surface water pathway has been greatly reduced by discontinuing use of the liquid waste disposal and process water
networks. IRAs have been designed to reduce and control the threats to off-post receptors, and land-use restrictions
have minimized risks to humans on post. IRAs have also been designed to isolate ecological receptors from the
most toxic sources. However, some of the major sources continue to pose a risk to ecological receptors and to
humans (although access restrictions and health and safety practices prevent site workers and visitors from coming
into contact with these sources).
5.4 Extent of Contamination
One hundred eighty-one sites with varying degrees of contamination, ranging from areas of several hundred acres
with multiple contaminant detections at concentrations up to a few parts per hundred to isolated detections of single
analytes at a few parts per billion, were delineated during the RI and subsequent studies. During the FS, these sites
were combined into groups of sites containing similar contaminant types and distributions, as shown in Figure
5.4-1. In addition, areas of RMA potentially containing Army chemical agent or unexploded ordnance (UXO)
were delineated, as shown in Figure 5.4-2. Summary discussions of the contaminant concentrations and
distributions, along with analytical results in tabular format, can be found in the Remedial Investigation Summary
Report and subsequent studies referenced in the Detailed Analysis of Alternatives report.
Contamination was detected in soil, ditches, stream and lakebed sediments, sewers, groundwater, surface water,
biota, structures, and, to a much lesser extent, air. Less extensive and less concentrated contamination occurs only
sporadically within the relatively uncontaminated buffer zone along the boundaries. The most highly contaminated
sites (those showing the highest concentrations and/or the greatest variety of contaminants) are concentrated in the
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5.0 Summary of Site Characteristics
central six sections (square miles) of RMA (Sections 1,2,25,26, 35, and 36) within which the manufacturing and
waste disposal areas are located.
A number of sites at RMA that posed a potential risk to human health and the environment have been initially
addressed by the implementation of IRAs. Additional actions at these sites and the other contaminated sites that
remain will be undertaken as specified in mis ROD, thereby reducing the risks to human health and the
environment. Current conditions for air, wildlife, water, structures, and soil are described below.
Air
The Army is currently monitoring the ambient air at strategic locations at RMA. No ambient air contamination
related to RMA has been consistently detected, and air quality at RMA is generally better than that of the
surrounding Denver metropolitan area.
Wildlife
Elevated contaminant concentrations have been detected in some wildlife at RMA. Adverse impacts, including
death, have been identified for individuals of species feeding or residing in certain highly contaminated areas at
RMA. USFWS, through the ongoing biomonitoring program, is studying the wildlife populations at RMA for
health effects by analyzing tissue samples, conducting bioassays, and recording animal observations such as
reproduction, survival, and mortality. The Parties, represented by the Biological Assessment Subcommittee (BAS),
are working together with USFWS to ensure that the study of potential effects is designed to consider actual
exposures for the individuals sampled. The potential for additional unacceptable levels of exposure to biota on
RMA is being evaluated for support of design refinement by Phase I of the Supplemental Field Study (SFS) (see
Section 6.2.4.3).
Groundwater
The regional groundwater flow direction at RMA is northwest toward the South Platte River. High groundwater flow
volumes and velocities at RMA are associated with thick, permeable sand and gravel deposits of the Platte River
Valley, which occur along the Western Tier (e.g., Sections 4,9, and 33) of RMA, and with similar deposits along First
Creek. The saturated portion of these alluvial sediments is generally thicker and coarser grained than alluvial sediments
in the central portion of RMA. Groundwater flow velocities and volume in the central portion of RMA are one or more
orders of magnitude less than in the Western Tier or First Creek areas because groundwater in the central portion flows
through predominantly thin, fine-grained alluvium and low-permeability bedrock. Superimposed on the regional
groundwater flow system is a large groundwater mound centered over a bedrock topographic high beneath the South
Plants. Groundwater in this area flows radially away from the South Plants mound and eventually flows towards the
Western Tier or the northern boundary.
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Because RMA is located in a semiarid environment, the amount of annual groundwater recharge from precipitation is
low (precipitation is approximately 15 inches per year). Sources of manmade recharge have historically contributed to
the groundwater mound in South Plants. These manmade sources include leaking potable and process water systems
(used for fire protection), sanitary and storm sewer systems, infiltration of steam plant cooling water discharged to
ditches, and infiltration of precipitation mat ponds in depressions and ditches adjacent to buildings and roadways. The
amount of recharge from these manmade sources is decreasing and eventually will be eliminated when remediation
activities are completed. The sanitary and chemical sewers systems were closed in 1992 and the steam plant in South
Plants is no longer in operation. Since mat time, measurements indicate that groundwater elevations in South Plants
have decreased several feet It is currently believed that the decrease in water levels is the result, in part, of the
reduction in manmade recharge; however, some of the decreases in water levels may be due to drought. In the long
term, water levels in the mound area are expected to decrease as a result of eliminating manmade recharge.
To develop and evaluate remedial alternatives, the 15 groundwater contaminant plumes identified at RMA were
grouped into 5 plume groups, primarily based on location (Figure 5.4-3). The five plume groups are as follows:
• North Boundary Plume Group
• Northwest Boundary Plume Group
• Western Plume Group
• Basin A Plume Group
• South Plants Plume Group
The North Boundary Plume Group includes the Basins C and F Plume and the North Plants Plume (Figure 5.4-3). The
NBCS extracts and treats these plumes as they approach the northern boundary of RMA. The Basins C and F Plume
flows primarily within alluvial-filled paleochannels and to a lesser extent through weathered bedrock. The North Plants
Plume flows primarily within sandy alluvial material. The primary contaminants in the Basins C and F Plume are
chloroform, benzene, atrarine, dieldrin, DIMP, TCE, DBCP, and DDT. The plume also has high levels of inorganics
such as fluoride, chloride, and sulfate. The primary contaminant in the North Plants Plume is DIMP. Sulfate is present
at high concentrations (chiefly due to natural sources) in the First Creek aquifer. Concentration ranges for these
primary contaminants are presented in Table 5.4-1.
The Northwest Boundary Plume Group includes the Basin A Neck Plume and the Sand Creek Lateral Plumes. The
existing NWBCS (Figure 5.4-3) was installed to intercept and treat these plumes at Ihe RMA boundary. The Basin A
Neck Plume extends from Basin A in Section 36 to the northwest boundary of RMA. The Sand Creek Lateral Plumes
appear to originate in the vicinity of the Sand Creek Lateral in the western portion of Section 35 and merge with the
Basin A Neck Plume. The primary organic contaminants in these plumes are dieldrin, chloroform, and DIMP. The
Basin A Neck Plume also has high levels of chloride, fluoride, and sulfate. However, dieldrin is the only compound
FOSTER ® WHEELER
5-4 FOmn WHEELER ENVIRONMENTAL COHKMATION nni\l 489G.DOC
-------
5.0 Summary of Site Characteristics
that is present at levels requiring treatment at the boundary. Contaminant concentration ranges for the primary
contaminants in this plume group are presented in Table 5.4-2.
The Western, Motor Pool, and Rail Yard Plumes are collectively defined as the Western Plume Group. The Motor Pool
and Rail Yard Plumes are treated by the ICS and those portions of the Western Plume mat extend off post
(downgradient) are extracted by the SACWSD water supply wells and treated at the Klein treatment plant The plumes
occur primarily within thick alluvial-terrace deposits. The primary contaminants in these plumes are TCE in the Motor
Pool Plume; 1,1-dichloroethylene, 1,1,1-trichloroethane, and TCE in the Western Plume; and DBCP in the Rail Yard
Plume. The concentrations of these primary contaminants are shown in Table 5.4-3.
The Basin A Plume Group includes the Basin A Plume, the South Plants North Plume, and the Section 36 Bedrock
Ridge Plumes. Contaminated groundwater flow in the South Plants North and Basin A Plumes occurs principally
within saturated alluvium, with lesser flow through the underlying weathered bedrock. However, in the Section 36
Bedrock Ridge area, the water table generally lies below the alluvium and groundwater flows predominantly within
weathered bedrock. The major contaminants detected in all the Basin A Plume Group are chloroform, methylene
chloride, DIMP, TCE, DBCP, and benzene. Additionally, aldrin, dieldrin, and chlordane are also major contaminants
in the South Plants North and Basin A Plumes. The concentrations of these contaminants are presented in Table 5.4-4.
The South Plants Plume Group includes the South Plants Southeast, Southwest, North Source, and the South Tank
Farm Plumes. Groundwater in these plumes flows principally within the weathered, upper portion of the Denver
Formation. Small portions of the South Plants North Source and South Plants Southeast Plumes also flow within areas
of thin, saturated alluvium. Continued monitoring of groundwater adjacent to Lake Ladora and Lower Derby Lake will
make it possible to assess migration of contaminants toward the lakes. The primary contaminant in the South Tank
Farm Plume is benzene. The major contaminants in the other plumes in the South Plants Plume Group include
chloroform, carbon tetrachloride, TCE, tetrachloroethylene, benzene, aldrin, dieldrin, and DBCP. Contaminant
concentrations for these contaminants are presented in Table 5.4-5.
Structures
The structures medium encompasses a wide variety of structural types and materials including all aboveground
structures, buildings, foundations, basements, tanks (including underground storage tanks), process and nonprocess
equipment (including bone yards), aboveground chemical and nonchemical pipelines, asbestos-containing material
(ACM), equipment and materials contaminated with PCBs, and other miscellaneous manmade objects placed at
RMA since it was acquired by the Army in May 1942. The structures medium also includes a few houses and bams
constructed before 1942 that still exist at RMA.
FOSTER E? WHEELER
rma\1489G.DOC FOSTER WHEELER ENVIRONMENTAL CORPORATION 5-5
-------
Record of Decision for the On-Post Operable Unit
During the FS,' the use history information was used to categorize structures in terms of their potential for
contamination. Detailed use histories of structures at RMA were gathered based on plant operational records,
official Army and Shell histories, and depositions from operational personnel. The histories of each structure were
summarized in the Task 24 Structures Survey Report (Ebasco 1988). For example, the history of a structure
involved with chemical production would include the chemicals produced, the years of operation, and any spills,
exposures, or accidents that occurred there. Similarly, the history of a structure used for nonproduction activities
would include the type of use, such as staff housing or administration, and any chemical spills or accidents that may
have occurred there.
There are 798 structures currently standing at RMA. In order to efficiently evaluate cleanup alternatives, structures
with similar use histories and potential for contamination were placed in one of four groups. One of the four groups
is identified as "Future Use," meaning that the use history indicates the structures are uncontaminated, and they
have some usefulness at the conclusion of remedial activities. The other three groups are identified as "No Future
Use," meaning that they are not needed following remediation and that their use history indicates the structures may
be contaminated. Many of these structures must be removed to access the underlying contaminated soil. These
three groups are further distinguished by the relative severity of the potential contamination associated with their
use histories. The four structures medium groups, and the number of structures included in the groups, are as
follows:
• Future Use, No Potential Exposure (Future Use Group) - 48 structures
• No Future Use, Significant Contamination History (Significant Contamination History Group) - 49
structures
• No Future Use, Other Contamination History (Other Contamination History Group) - 631 structures
• No Future Use, Agent History (Agent History Group) - 70 structures
Tables 5.4-6 through 5.4-9 present an inventory of the structures included in each medium group. Refinement of
the Future Use structures inventory will be completed during remedial design.
Soil
The soil medium consists of unsaturated soil, bedrock, fill material, process water lines, chemical and sanitary sewer
lines, lake sediments, and soil/waste/debris mixtures. The term "soil," used for convenience in this document, refers
to any of these materials. A total of 178 potentially contaminated soil sites were investigated during the RI, and three
sites were added during the FS as a result of additional IRA and RI investigative efforts. Of the 181 sites investigated,
114 were determined to require further evaluation in the FS based on the site evaluation criteria (SEC) as described in
Section 7.1.3, on potential agent or UXO presence, or on the potential risk to biota as described in Section 6.2. These
114 sites are organized into four exceedance categories as follows:
• Potential UXO Presence - Potential presence of UXO identified as the only risk
• Potential Agent Presence - Potential presence of Army chemical agent identified as the only risk
FOSTER® WHEELER
5-6 POSTER WHEELER ENVIRONMENTAL CORPORATION rma\1489G.DOC
-------
5.0 Summary of Site Characteristics
• Biota Risk - Potential risk only to biota based on the evaluations presented in the Integrated Endangerment
Assessment/Risk Characterization report
• Human Health Exceedance - Exceedance of human health SEC, although portions of these sites may also
potentially contain UXO, potentially contain agent, and/or pose potential risks to biota
The sites were further organized into IS medium groups, which are groups of sites within each exceedance category
that are similar in site type and contamination patterns (e.g., sanitary landfills with metallic debris and rubbish). Eight
of these medium groups were divided into subgroups based on chemical or physical variation between the sites within a
group.
The site, characteristics mat were used to develop medium groups and subgroups fall into nine general criteria, which
are described as follows:
• Depth of Contaminated Soil - This criterion is evaluated because the depth of contamination may limit the
suitability of particular remedial technologies. For example, technologies such as surface beating are
effective only for volatile contaminants at shallow depths.
• Driver Contaminants - The types of contaminants that comprise the exceedance volumes influence the
evaluation of alternatives. One treatment technology may provide effective remediation for all
contaminants detected at the site. In some cases, however, a primary remedial technology is developed for
the most prevalent contaminants) and a secondary treatment system or systems are used for the remainder
of the contamination.
• Depth to Groundwater - Thickness of the unsaturated zone varies across RMA, and treatment technologies
may require a minimum thickness for installation and function of the system. For example, in situ
vitrification and RF heating require a minimum unsaturated soil thickness to operate.
• Major Soil Type - The total of 10 soil units that have been identified at RMA were divided into four soil types
based on texture, clay content, and soil permeability for the purpose of evaluating subgroups. Soil types may
increase or reduce treatment effectiveness. For example, soil venting is more effective on a sandy loam than
on a clay loam due to the increased porosity and permeability of a sandy unit.
• Soil/Groundwater Interactions - Soil/groundwater interactions are evaluated at each site to assess the potential
impacts of soil alternatives on groundwater alternatives.
• IRAs - Sites at which IRAs have been or are being performed (see Section 2.4) may not need further
remediation if the IRA is determined to provide long-term protection of human health and the environment.
• Site Configuration - Site shapes vary and are categorized as either square to oblate or extremely narrow. The
shape of a site can affect the selection of an alternative. For example, extremely narrow sites, such as ditches,
are not favorable locations for access controls like habitat modifications.
• Agent/UXO Presence - Agent and/or UXO along with human health contaminants of concern (COCs) or
contaminants that pose potential risk to biota may be present at some of the sites. Sites are identified that
potentially contain agent and/or UXO based on historical usage of the site as presented in the Remedial
Investigation Summary Report. Additional FS data-collection programs have been performed to further
define the extent of agent contamination.
• Site Type/Usage - Each site was evaluated for site type or usage and eight categories were developed in the
Remedial Investigation Summary Report. The site type/usage categories include surface soil/windblown;
ordnance testing and disposal; spills/isolated; lake sediments, ditches, and ponds; basins or lagoons; buildings,
equipment, and storage; sewer systems; and buried waste.
FOSTER © WHEELER
nna\1489G.DOC ForreR WHEELER ENVIRONMENTAL CORPORATION 5-7
-------
Record of Decision for the On-Post Operable Unit
The exceedance categories, medium groups, and subgroups that were developed based on these criteria are listed in
Table 5.4-10; the medium group and subgroup characteristics are described in Table 5.4-11. The contaminant
concentrations (range and average) detected for each medium group and subgroup within the soil exceedance volumes
defined by the SEC are listed in Table 5.4-12. The exceedance volumes represent only those parts of a site that exceed
the SEC; therefore, the listed ranges and average concentrations are higher man the data for each site as a whole (see
Section 6).
5.5 Potential Human and Environmental Exposure
Contaminant sources and pathways are identified to allow an assessment, described in Section 6, of the potential for
exposure and risk to human health or the environment. In summary, most of the potential human health risks are
caused by four chemicals, aldrin, dieldrin, DBCP, and arsenic. The highest estimated risks are limited to the central
portions of RMA, coinciding with the former location of chemical processing and disposal areas (e.g., South Plants,
the disposal trenches and basins). The primary routes for potential exposure are consumption, dermal contact, and
inhalation. Some of the sites pose a risk to wildlife and could pose a risk to site workers and visitors. However, in
these heavily contaminated areas, public access is carefully restricted and workers follow prudent health and safety
procedures. IRAs have reduced some of the potential risks associated with these sites; however, risks still remain
and the reduction of those risks to acceptable levels (see Section 6) is addressed by this ROD.
Under current conditions, biota are the primary receptors of RMA contamination in surficial soil, lakebed
sediments, and surface water. Because of this, significant wildlife management practices have been implemented to
attract wildlife to uncontaminated areas of RMA and also to eliminate wildlife from contaminated areas. Most of
the potential biota risks are caused by pesticides and metals. The primary route for biota exposure is ingestion.
Consumption of contaminated prey is a concern at higher trophic levels due to contaminants such as OCPs, which
are known to bioaccumulate and biomagnify in the food chain.
FOSTER JjJ WHEELER
5-8 RWTER WHEELER ENVIRONMENTAL CORPORATION ima\1489G.DOC
-------
Legend
~—-" RMA Boundary
SAP Site Boundary1
Munitions Tasting
Ag«nt Storage $ North PJonts
s M < Toxic Storoge Yards
Lake Sediments
|[ Surflclol Soil
Ditches/Drainage Areas
[ | Basin A
nan.tn r 5 Former Basin F
Basin F J Bajin F Was,epne
f^ Secondary Basins
m Sewer Systems
wff,u,a < Complex Trenches
Mjm Disposal Trenches < Shell Trenches
-------
Legend
RMA Boundary
SAR Sit* Boundary1
Potential Agent and UXO Area
Potential UXO Area
Potential Agent Area
Section Number
'Study Area Report (set Remedial
Investigation Summary Report,
Ebasco 1992o).
-N-
(t
1500 0 1500 3000 Feet
Prepared for: U.S. Army Program Manager for
Rocky Mountain Arsenal
Figure 5.4-2
Potential Agent/UXO Presence Areas
Foster Wheeler Environmental Corporation
June 1996
-------
Bosin F
Groundwatar
IRA
North Boundary
Containment System
Northwest Boundary / ,
Contoinment Systein I
Motor Pool and
Rail Yard Plume
Capture IRAs
LEGEND
North Boundary Plume Group
Basins C and F Plume
North Plants Plume
Northwest Boundary Plume Group
(Outlined In blue: . )
Basin A Neck Plume
Sand Creek Lateral Plumes
Western Plume Group
Western Plume
(Outlined in yellow: )
Motor Pool Plume
Rail Yard Plume
Basin A Plume Group
South Plants North Plume
Basin A Plume
Section 36 Bedrock Ridge Plume
South Plants Plume Group
South Plants North Source Plume
South Plants Southeast Plume
South Plants Southwest Plume
South Tank Form Plume
•^^™ Groundwoter Control System
Colored portions of plumes indicate summed
total organic concentrations above 100 ug/l.
Generalized Contaminant Plum* Locations'
-------
Table 5.4-1 Primary Contaminant Concentrations in the North Boundary
Plume Group1'2
Analyte
North Plants Plume
DIMP
Sulfate
Basins C and F Plume
Chloroform
Trichlorethylene
Benzene
Dieldrin
DIMP
DDT
Atrazine
DBCP
Chloride
Fluoride
Sulfate
Minimum
Concentration
(HE/1)
O.39
8,600
<0.5
<0.5
O.5
O.05
O.2
O.049
O.51
O.06
7,200
180
<180
1 The reported concentrations are based on data from first quarter
2 Concentrations are reported with two significant figures.
•* Tba t\irr\_rt'0n *»*»nwiAtrii" m^oti /TCf3K^"\ iiroc tirtt/i tt\ ^almilivf-a nlnrrti
Maximum
Concentration
3,900
1,800,000
85,000
790
460
440
64,000
27
1,800
71
32,000,0000
500,000
10,000,000
1989 through second quarter 1994.
ft smnnatttmti/\** a« ra*>n I*AP T*t +Vin fife<+ ,
Page 1 of 1
TSGM3
44
600,000
8.5
1.6
1.8
0.46
210
0.11
5.4
0.21
1,000,000
4,100
660,000
mean of all samples for each individual well was calculated, and in the second step, the geometric mean for all wells within
the identified plume was calculated.
nna\1572G
-------
Table 5.4-2 Primary Contaminant Concentrations in the Northwest Boundary
Plume Group1-2
Page 1 of 1
Analyte
Basin A Neck Plume
Chloroform
Dieldrin
DIMP
Chloride
Fluoride
Sulfate
Sand Creek Lateral Section 35 Plume
Chloroform
Dieldrin
Sand Creek Lateral Section 27 Plume
Chloroform
Dieldrin
DIMP
1 The reported concentrations are based on
^ fAn^pntMtinnc ar#> w»T%nrti»H with twn dor
Minimum
Concentration
<0.5
<0.05
<0.39
30,000
1,100
190,000
<0.5
<0.05
18
0.50
0.81
data from first quarter
lifirant fionrpc
Maximum
Concentration
(HE/1)
30
3.5
5,900
1,900,000
6,200
2,400,000
4.5
0.10
22
2.6
3.2
1989 through second quarter 1994.
TSGM3
(ug/1)
3.4
0.14
66
670,000
2,600
630,000
0.96
0.032
20
1.1
1.8
The two-step geometric mean (TSGM) was used to calculate plume concentration averages. In the first step, the geometric
mean of all samples for each individual well was calculated, and in the second step, the geometric mean for all wells within
the identified plume was calculated.
nna\1570G
-------
Table 5.4-3 Primary Contaminant Concentrations In the Western Plume Group1-2 Page 1 of 1
Minimum Maximum
Concentration Concentration TSGM3
Analyte (ng/l) (ug/l) ftig/l) TSGM3'4
Western Plume
1,1,1-Trichloroethane <0.76 100 4.0 4.3
1,1-Dichloroethylene <1.7 48 3.6 3.7
TCE <0.56 55 5.8 4.0
Motor Pool Plume
TCE <0.49 180 3.0 1.1
Rail Yard Plume
DBCP 1.1 29 13 1.0
1 The reported concentrations are based on data from first quarter 1989 through second quarter 1994.
2 Concentrations are reported with two significant figures.
3 The two-step geometric mean (TSGM) was used to calculate plume concentration averages. In the first step, the geometric
mean of all samples for each individual well was calculated, and in the second step, the geometric mean for all wells within
the identified plume was calculated.
4 These data were estimated using third quarter 1994 through fourth quarter 1995 data.
nna\1571G
-------
Table 5.4-4 Primary Contaminant Concentrations in the Basin A Plume Group1'2 Page 1 of 1
Analyte
Basin A Plume
Chloroform
TCE
Methylene chloride
Benzene
DIMP
Aldrin
Dieldrin
Chlordane
DBCP
Section 36 Bedrock Ridge Plume
Chloroform
TCE
Tetrachloroethylene
Methylene chloride
Benzene
DBCP
South Plants North Plume
Chloroform
TCE
Methylene chloride
Benzene
Aldrin
Dieldrin
Chlordane
DBCP
1 The reported concentrations are based on
2 f"Y»nf»i»ntratirtnc ar^ r^nnrtpH with twrt citm
Minimum
Concentration
<0.5
<0.56
<2.5
<1.1
<0.2
<0.05
<0.05
<0.095
<0.13
<0.5
2.2
1.1
<1.0
<1.0
<0.13
<0.5
<0.56
<2.5
<1.1
0.05
<0.046
<0.095
<0.13
data from first quarter
itfirnnt fieilr^c
Maximum
Concentration
100,000
8,200
910,000
39,000
29,000
9.5
19
120
10,000
23,000
3,000
14,000
910,000
890
120
2,900,000
6,200
34,000
100,000
300
65
460
480
1989 through second quarter 1994.
TSGM3
180
26
50
52
60
0.080
0.17
0.11
9.7
56
98
370
50
5.8
0.24
180
6.2
39
24
0.21
0.20
0.56
0.90
The two-step geometric mean (TSGM) was used to calculate plume concentration averages. In the first step, the geometric
mean of all samples for each individual well was calculated, and in the second step, the geometric mean for all wells within
the identified plume was calculated.
rma\1573G
-------
Table 5.4-5 Primary Contaminant Concentrations in the South Plants
Plume Group1-2
Analyte
South Tank Farm Plume
Benzene
South Plants Southwest Plume
Chloroform
Carbon Tetrachloride
TCE
Tetrachloroethylene
Benzene
Dieldrin
DBCP
South Plants Southeast Plume
Chloroform
Carbon Tetrachloride
TCE
Tetrachloroethyene
Benzene
Aldrin
Dieldrin
DBCP
South Plants North Source
Chloroform
TCE
Tetrachloroethylene
Methylene chloride
Benzene
Aldrin
Dieldrin
Chlordane
DBCP
' The reported concentrations are
2 Concentrations are reported with
3 Thf> tiirs\_ct«n n*nm»tnn moan STC
Minimum
Concentration
("g/1)
<1.0
14
<0.99
<0.56
<0.75
<1.1
0.092
<0.13
400
30
2.5
<0.75
9.9
<0.05
<0.05
<0.195
1.6
<1.31
<0.75
<2.5
2.2
O.083
<0.05
<0.095
<0.13
based on data from first quarter
two significant figures.
?f*XX\ iirao iie»/4 t/\ rolmitotA nlumi
Maximum
Concentration
(Hg/0
1,500,000
420
200
8.6
23.7
220
15
0.93
45,000
1,500
710
440
8,100
310
32
1,900
500,000
1,500
950
3,800
82,000
71
110
29
3,200
1989 through second quarter 1994.
• ^nn/*f»rttratJnn a«r**>aA*e> T«\ 4\+m fi*ft ,
Page 1 of 1
TSGM3
(ng/0
1,200
71
9.0
2.1
4.6
1.6
0.27
0.11
2,500
140
22
17
230
0.17
0.23
22
1,400
18
60
14
390
0.44
0.35
0.21
4.7
mean of all samples for each individual well was calculated, and in the second step, the geometric mean for all wells within
the identified plume was calculated.
RMAM574
-------
Table 5.4-6 Inventory of Future Use, No Potential Exposure Medium Group
Page 1 of 2
Place
#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
Structure
Number
0105
0111
0112
0120
0121
0124
0128
0129
0130
0133
0135
0143
0145
0211
0312
0361
0369
0370
0371
0372
0383
0385
0386
0387
0551
0552
0618
0619
0702
NN0501
NN0903
SS 0370
Bank Volume Size Shell USFWS Cleanup
Description of Structure (BCY) (SF) Section Use Use1 Treaty Use
Bus Shelter
RMA Administration, Hqs, Offices
Communication Headquarters
Facilities Maintenance Headquarters
Change House
Maintenance Garage
Mission Support Contractor
Administrative Record Facility
Chemistry Laboratory
Sewage Lift Station
Guardhouse
West Gate Guardhouse
South Gate Guardhouse
Gas Meter House
Fire Station Headquarters
Primary Electrical Substation
Lower Derby Valve Gate
Restroom
Water Pumping Station
Million Gallon Reservoir (Potable)
Community Club
Water Pump Station
Water Pump Station
Water Pump Station
Elevated Storage Tank, South Plants
Valve Pit
Warehouse
Warehouse
Bald Eagle Observation Structure
Abandoned School-fdn & wall
VORTAC Station
Substation-lT-150'W of C
770
290
23
46
21
860
54
20
820
530
340
14
14
14
620
55
5,300
5,200
45
110
39,000
2,300
15,380
5,000
6,900
13,200
38,400
17,500
180
170
240
12,000
380
49
1,800
21,000
6,100
140
140
140
310
110,000
110,000
1,300
1,000
33
35
35
35
35
35
35
35
35
35
04
04
11
02
36
02
01
02
02
02
02
04
04
04
01
01
03
03
05
05
09
03
Short-Term
Long-Term
Long-Term
Long-Term
Long-Term
Long-Term
Long-Term
Long-Term
Long-Term
Long-Term
Long-Term
Long-Term
Short-Term
Long-Term
Long-Term
Long-Term
Short-Term
Long-Term
Long-Term
Long-Term
Long-Term
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup and Beyond
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Added After Pipe Runs
Task 24 & Tanks
Not in T-24
NotinT-24
Not in T-24
Not in T-24
Not in T-24
Not in T-24
NotinT-24
NotinT-24
NotinT-24
NotinT-24
Tanks/Pipes
NotinT-24
ima\l575G.XLS,Future Use
-------
Table 5.4-6 Inventory of Future Use, No Potential Exposure Medium Group
Page 2 of 2
Place
#
33.
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
Structure
Number Description of Structure
SS 0371 Substation-lOT-N of 371
SS 0385 Substation-3T-N of 385
SS 0386 Substation-3T-N of 386
SS 0387 Substation-3T-W of 387
SS0619 Substation-4T-Nof619
Z-28 Trailer
Z-3 Trailer
Z-38 Trailer
Z-39 Trailer
Z-40 Trailer
Z-41 Trailer
Z-42 Trailer
Z-58 Trailer
Z-68 Trailer
Z-69 Trailer
Z-70 Trailer
Bank Volume Size
(BCY) (SF) Section
02
04
04
04
03
23
35
04
04
25
25
25
35
35
35
04
Shell USFWS
Use Use1 Treaty
Long-Term
Long-Term
. Long-Term
Long-Term
Short-Term
Cleanup
Use
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Added After Pipe Runs
Task 24 & Tanks
-
Not in T-24
Not in T-24
Not in T-24
Not in T-24
Not in T-24
Not in T-24
Not in T-24
Not in T-24
Not in T-24
Not in T-24
Not in T-24
1 These buildings may be reevaluated for potential historic preservation or future use. The Rocky Mountain Arsenal National Wildlife Refuge Act states that "transfer shall be made without cost
to the Secretary of the Interior and shall include such improvements on property as the Secretary of the Interior may request in writing for refuge management purposes."
nna\157SG.XLS,Fuhire Us«
-------
Table 5.4-7 Inventory of No Future Use, Significant Contamination History Medium Group
Page 1 of 2
Place
#
I
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
Structure
Number
0242
0243
0247
0251
0342
0411
0411 A
0424A
0424C
0451
0471
0473
0475
0502
0503
0505
0507
0515
0515A
0521
0521 A
0523
0523C
0523D
0523E
0523F
0523G
0525
0526
0532
0533
0534
Description of Structure
Chlorine Production/US Mint Storage
Chlorine Production Compressor Bldg
Salt Storage Building & foundation
Chlorine Evaporator/Storage
Warehouse/M74 I. B. Storage
SM & SD Manufacturing/Storage
Steam Meter House
Mustard Scrubber-foundation
Aldrin Filter Building-foundation
Warehouse/Production Filling
TC Reactor/Pesticide Production
TC Drum Loading/Pesticide Packaging
Railroad Car Wanner Shed
West Chemical Metering Pump
East Chemical Metering Pump
DET Pretreatment Feed Pump House
DET Separator Pumphouse
CP/DDT/Pesticide Production
Nudrin/Endrin Storage
Acetylene Compressor/Pesticide Mfg.
Refrigeration/DCPD Cracking
AT Mfg. BIdg./Igniter Tube Filling
Arsenic Trioxide Dry Storage Silo
Arsenic Trioxide Dry Storage Silo
Arsenic Trioxide Dry Storage Silo
Arsenic Trioxide Dry Storage Silo
Arsenic Trioxide Dry Storage Silo
Product Development Lab/Nudrin Mfg.
Pesticide Filter-foundation
Pesticide Storage/Warehouse
Flammable Materials Storehouse
Pumphouse/Storage
Bank Volume
(BCY)
3,100
1,000
1,100
1,100
1,000
1,500
6
10
16
900
580
86
180
41
37
30
41
1,600
202
220
36
300
71
96
96
96
96
380
26
1,100
19
330
Size
(SF)
42,000
9,200
58,000
23,000
13,000
16,000
72
720
750
11,000
"5,100
1,900
980
700
290
510
520
15,000
1,900
1,100
320
4,000
210
360
360
360
360
8,100
900
12,000
130
930
Section
02
02
02
02
02
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Shell USFWS Cleanup Added After Pipe Runs
Use Use1 Treaty Use Task 24 & Tanks
Leased
Leased
Leased
Leased
Owned
Owned
Owned
Owned
Leased
Owned
Leased
Owned
Leased
Leased
Leased
Leased
Leased
Leased
Leased
Leased
Leased
rnia\IS75G.XLS,Significant
-------
Table 5.4-7 Inventory of No Future Use, Significant Contamination History Medium Group
Page 2 of 2
Place
#
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
Structure
Number
0534A
0534B
0542
0544
0561
0571
057 IB
0616
0624
0627
0631
0643
0646
0724
0741
0834
0884
Description of Structure
Drum Storage/Field Shop/Office
Planavin Manufacture
Drummed Product Storage/Gen.Storage
Heavy Equipment Maintenance Shop
BCH Unit Control House
Vent Gas Burner
Tank Room/HCCPD Drum Storage
Warehouse
Repair/Salvage/Surplus Facility
Vehicle Maintenance Shop
Railcar Maintenance/Roundhouse
Flammable Materials Storehouse
Rodent Control Building-foundation
Incinerator/Electostatic Preciptator
Refrigeration Building
Incinerator
Igloo Storage
Bank Volume
(BCY)
250
470
1,000
180
170
140
130
910
850
620
350
55
5
460
880
120
210
Size
(SF)
2,700
13,000
11,000
3,300
1,600
520
2,600
11,000
24,000
16,000
4,500
400
840
2,600
6,300
3,800
1,600
Section
01
01
01
01
01
01
01
03
04
04
04
03
04
01
01
36
06
Shell USFWS Cleanup Added After
Use Use1 Treaty Use Task 24
Owned
Owned
Owned
Owned
Owned
Short-Term
Cleanup
Short-Term Cleanup
Cleanup
Owned
Pipe Runs
& Tanks
1 These buildings may be reevaluated for potential historic preservation or future use. The Rocky Mountain Arsenal National Wildlife Refuge Act states that "transfer shall be made without cost
to the Secretary of the Interior and shall include such improvements on property as the Secretary of the Interior may request in writing for refuge management purposes."
rniaM 575G.XLS,Significant
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 1 of 20
Place
#
I
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
Structure
Number
0112A
OH2B
0114
0116
0132
0136
0137
0148
0169B
0176
0213
0241
0244
0245
0246
0248
0249
0252
0253
0254
0255
0256
0282
0286
0287
0291
0295
0296
0307
0309
0311
0313A
Description of Structure
Emergency Generator Plant
BBQ-Nofll2
Security Incinerator
Bus Stop Shelter
Shell/MKE Field Headquarters
Garage-to 134-foundation
Garage-to 131-foundation
Storage/Pass Office-NW of 166
Gas Station House-fdn-S of 150
5-Unit Garage & Unused Apt-foundation
Calibration Facility/X Ray Lab
Administration/Lab/Change House
3 Liquid Chlorine Tank Saddles
Substation Building
HC1 Production Facility
Brine Treatment Plant-foundation
Brine Storage & Pump House-foundation
Cell Liquor Storage-foundation
50% NaOH Storage-foundation
Caustic Fusion Plant/Drum Storage
Fuel Oil Pump Station & 2 tank pads
Fuel Oil Tank-SE corner of 254
Guard Statkm-foundation-NW of NN0102
Guard Station-SE of 557-foundation
Guard Tower-foundation
Guard Station-foundatn-735'W of 362
Guard Tower-SE of 1 12-foundation
Guard Tower-foundation
Potable Water Valve & Meter Pit
Maintainence/Storage-S of 545
Stems-Rogers Office/Sample Storage
Sewage Pump Station
Bank Vol
(BCY)
35
2
8
4
3
3
1
4
24
680
290
30
23
56 .
180
260
29
36
1,200
23
6
7
6
6
6
6
6
11
10
350
3
Size Shell USFWS Cleanup Added After Pipe Runs
(SF) Section Use Use1 Treaty Use Task 24 & Tanks
240
16
34
140
130
130
410
100
1,500
4,600
3,000
200
210
1,600
4,200
9,300
2,900
4,500
16,000
300
65
64
64
64
64
64
64
130
420
4,400
38
35 Cleanup
35
35
01
35 Cleanup Not in T-24
35
35
34
34
03
02
02
02
02
02
02
02
02
02
02 Leased
02 Leased
02
01
01
01
02
02
02
36 Cleanup and Beyond
01
02 Cleanup
01
rnia\IJ75G.XLS,Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 2 of 20
Place
#
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
Structure
Number
0314
03 ISA
0316
0316
0316A
0317A
0318
0321
032 1C
0321D
0322
0322A
0323
0324
0325
0326
0327
0328
0328A
0329
0331
0332
0333
0334
0335
0336
0337
0338
0339
0340
0341
034 1 A
Description of Structure
Fixed Laundry Service Building
Steam Meter Pit-W of 3 1 5
Plants Dispensary/Clinic
Wood Shed- W of 727
Morrison-Kmidsen/Change House
Pipe Shop/Grease Pit
Boiler Plant-Central Gas Heat Plant
Pumphouse
Fuel Oil Pumphouse
Coal Sampling Building
Tractor Storage Shed
Ash (Coal) Storage Silo-Hopper
Coal Hopper Structure
Electrical Power Plant
Power Plant Pumphouse & Spray Pond
Cafeteria-foundation
Goop Mixing and Filling Building
Toilet House
Gasoline Pump Building
Phosgene Filling Warehouse
Warehouse
Warehouse
Warehouse
Warehouse
General Purpose Warehouse
Locker Room/Change House
Storage Magazine
Storage Magazine
Magazine
Change House
Condensate Pump House
Bank Vol
(BCY)
770
7
240
2
340
48
6,000
37
38
30
34
350
6
3,100
720
29
2,300
15
46
1,000
1,000
980
980
990
990
57
12
14
14
1,000
15
Size Shell USFWS
(SF) Section Use Use1
8,600
100
3,200
100
5,100
2,600
56,000
580
480
340
410
500
160
12,000
15,000
1,600
16,000
130
400
12,000
12,000
1 1,000
11,000
11,000
11,000
590
54
54
54
12,000
160
01
01
01 Leased
01 Leased
01 Owned
01
35
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
Cleanup Added After Pipe Runs
Treaty Use Task 24 & Tanks
Cleanup
Cleanup Not in T-24
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
rnia\l575G.XLS,Oti«!r
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 3 of 20
Place
#
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
Structure
Number
034 IB
0343
0343A
0344
0345
0346
0347
0351
0352
0352A
0353
0354
0355
0356
0362
0364
0365
0368
0372A
0373
0373B
0374
0378
0379
0381
0382
0383A
0391
0392
0393
0394
0395
Description of Structure
Sewage Lift Station-covered pit
Manuf. Bldg.-PreClustering Warehous
Flammable Materials Storehouse
Mfg Assembly/Warehouse
Mfg Assembly/Storage/Warehouse
Warehouse
Warehouse/Chemical Storage
Change House
Open Storage-foundation
Quonset Storage
Open Storage-foundation
Warehouse
Warehouse
Warehouse
Warehouse
Sewage Lift Station-SE of 354
Explosive Blending Building
Swimming Pool & Filter House
Chlorinator Station
Officer's Quarters
Garage-to 373
Water Treatment Plant-W o'Lr Derby-fdn
Chlorinating Station (on airport)
Chlorinating Station
Chlorinating Station
Officer's Club Storage
Sewage Disposal & Treatment Plant
Sewage Lift Station
Sewage Lift Station
West Gate Sewage Treatment Plant
Toxic Yard Sewage Plant-NW of 867B
Bank Vol
(BCY)
8
1,000
29
1,200
1,000
920
1,900
920
250
19
760
1,000
1,000
1,000
4,000
21
490
640
56
130
42
110
16
20
7
16
88
46
46
3
7
Size Shell USFWS Cleanup Added After Pipe Runs
(SF) Section Use Use1 Treaty Use Task 24 & Tanks
71
11,000
240
11,000
1 1,000
11,000
27,000
9,000
12,000
970
13,000
12,000
13,000
13,000
59,000
85
3,200
1,900
380
1,100
720
890
150
210
56
82
1,100
260
260
140
88
02
02
02
02
02
02 Cleanup
02 Leased Cleanup
02
02
02
02
02
02
02
02 Cleanup
02
02
02
02 Long-Term Cleanup
02 Long-Term
02
02
10 Cleanup
03 Cleanup
02 Cleanup Not in T-24
03
02
24
34 Cleanup
34 Cleanup
33
06
rma\l575G.XLS,Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 4 of 20
Place
#
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
Structure
Number
0409
0413
0413A
0415
0432
0434
0435
0459
0459A
0459B
0459C
0461
0464
0471B
0471C
0472
0472A
0474
0504
0506
0508
0509
0510
0511
0511 A
0512A
0514C
0514D
0514E
0516B
0518A
0519
Description of Structure
Condensate Pump House
WP Storage/SM Storage
Phossy Water Tank-W of 4 1 3
Caustic Makeup Tank-foundation
Sand Blasting Pad/Change House-fdn
West Gas Holder
East Gas Holder
Acetylene Generator Building
Lime Slurry Pumphouse
Lime Slurry Pumphouse
Small Building-N of 459
Tank Farm Pumphouse
Sample Building
Electrical Vault
TC Refrigeration
TC Refrigeration
Lunchroom/Maintainence Equipmt Stor
Electrical Control House
DET Emergency Diesel Generator
DET Control House
DET Copper Sulfate Treatment
DET Methyl Cl Compressor/Liquifier
Methyl Isocyanate Refrigeration
Chlorinated Paraffin Mfg./Storage
Chlorinated Paraffin/Change House
Flammable Solvent Storage Shed
Pump House
Refrigeration Compressor
Monomethylamine Dilution Control
Misc Electrical Equipment Storage
Emergency Fire Protection Generator
Hydrogen Peroxide Storage
Bank Vol
(BCY)
4
670
120
79
180
730
720
229
24
36
6
51
2
9
66
110
24
16
31
68
160
69
28
2,500
160
7
t
13
4
34
22
82
Size
(SF)
130
5,500
290
9,200
3,200
81
170
140
430
55
160
730
1,200
320
80
330
830
4,700
430
300
23,000
1,700
250
96
200
92
210
290
290
Section
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Shell USFWS
Use Use1 Treaty
Leased
Leased
Leased
Owned
Owned
Owned
Leased
Owned
Owned
Leased
Owned
Leased
Owned
Owned
Owned
Owned
Owned
Leased
Leased
Owned
Owned
Owned
Owned
Owned
Owned
Owned
Cleanup Added After Pipe Runs
Use Task 24 & Tanks
Tanks/Pipes
Tanks/Pipes
Cleanup
ima\IS7SG.XLS.Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 5 of 20
Place
#
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
Structure
Number
0519A
0520
052 IB
052 1C
0522
0522A
0522B
0523A
0524
0525A
0527
0529
0531
0534C
0534D
0538A
0539
0541 A
0543
0543A
0543B
0545
0546
0548
0549
0550
0553
0555
0557
0561A
0571 A
0605
Description of Structure
Hydrogen Peroxide Pumphouse
Sample Pump/pH Probes Storehouse
Compressor House/Maintainence
Lunchroom/Field Foreman Office
WP Cup Filling/Acetylene Mfg
Phossy Water Tank
Change House/Administration Bldg
WP Storage Tank House
WP Filling Building-fiidatn
Refrig Compressor/Electrical Vault
Change House/Quonset Hut
NaOH Make Up/Azodrin Support Struct
Warehouse
Emergency Generator/Electric Vault
Emergency Generator
Compressor Building
Electrical Substation Builiding
Magazine
Maintainence Shops/Instrument Lab
Steam Meter Pit
Facilities Engineers
Paint Shop
Sewage Lift Station
Water Pumping Station
Reservoir and Cooling Tower
Lift Station
Vault
Guardhouse/Gas Mask Training(TW-14)
Salvage Yard Storage/Maintenance
Acetylene Compressor-foundation
Electrical Vault
Flammable Materials Storehouse
Bank Vol
(BCY)
4
1
93
41
890
17
420
140
27
31
16
87
970
27
46
67
17
9
2,000
12
590
22
12
370
630
6
8
5
51
400
21
2
Size
(SF) Section
160
36
670
640
9,400
112
5,100
1,500
1,400
440
1,000
750
11,000
210
440
690
430
88
25,000
93
8,700
800
72
2,300
4,500
280
64
210
1,000
5,000
85
170
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
03
Shell USFWS Cleanup Added After Pipe Runs
Use Use1 Treaty Use Task 24 & Tanks
Owned
Owned
Owned
Owned
Tanks/Pipes
Owned
Leased
Leased
Owned
Owned
Cleanup
Cleanup
Cleanup
Owned
Owned
rma\l575G.XLS,Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 6 of 20
Place
it
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
Structure
Number
0606
0607
0608
0611
0612
0613
0614
0615
0617
0621
0621A
0622
0623
0625
0626
0626C
0627B
0629
0629E
0630
0631 A
0632
0633
0633A
0633B
0634
0635
0639
0641
0644
0644A
0647A
Description of Structure
Flammable Materials Storehouse-fdn
Flammable Materials Storehouse
Flammable Materials Storehouse
Data Processing Building
Courier Building
Management Information Systems
Warehouse
Warehouse
Warehouse
Property Disposal/Salvage Ofice
Truck Scale Platform
Paint Shop/General Storage
Carpenter Shop/Hobby Shop/Auto Shop
Warehouse
Machine and Welding Shop-foundation
Heavy Equipment Shop-foundation
Flammable Materials Storehouse
Service Station
Service Station Shelter
Gas Meter House
Flammable Materials Storehouse
Gas-Fired Heating Plant
Cafeteria/Bug Lab/Movie Theatre
Laboratory/Storehouse
Hazardous Materials Storage
Flammable Materials Storehouse
Admin Offices-Rocky Mtn Railcar
Lumber Storage
Warehouse-foundation
NCO Quarters-foundation
Garage/Storage-foundation
Motor Pool Dispatch Office
BankVol Size Shell USFWS . Cleanup Added After Pipe Runs
(BCY) (SF) Section Use Use1 Treaty Use Task 24 & Tanks
1
2
2
440
240
480
920
920
920
890
56
160
230
870
100
10
5
44
35
37
5
420
130
56
140
58
48
94
95
17
1
35
170
210
210
4,600
5,100
6,500
11,000
11,000
11,000
19,000
740
1,700
4,200
11,000
6,000
580
240
290
25
240
240
1,400
2,500
680
640
400
590
4,500
900
1,400
40
1,000
03
03
03
04 Short-Term
04 Short-Term
04 Short-Term
03
03
03
04
04
04
04
04
04
04
04
04
04
03
04
04 Short-Term
04
04
04
04
03
04
03
03
03
04
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
ima\1575G.XLS,Othet
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 7 of 20
Place
#
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224 .
Structure
Number
0647B
0647C
0647D
0648
0670
0673
0679
0680
0684
0685
0688
0727
0729
0731
0732
0733A
0733B
0733C
0733D
0733E
0733F
0735
0743
0743A
0744
0745
0746
0748
0751
0752
0752A
0753
Description of Structure
Motor Pool Vehicle Storage
Motor Pool Vehicle Storage
Motor Pool Vehicle Storage
Road Oil Pump and Boiler House
Railcar Scale House
Warehouse/Can Scouring-foundation
Radio Range B-foundation
Guard Tower-E of 644, N of 675-fhdn
Guard Tower-SE of 673-foundation
Guard Tower-E of 6 1 5-foundation
Facilities Maintenance
General Purpose Warehouse
Reserve Center/Office/Change House
Army Reserve Warehouse/Ml 9 Bomb Rew
Magazine
Magazine
Magazine
Magazine
General Purpose Magazine
General Purpose Magazine
Foamite/Oil Product Storage
RMA Laboratory/Change House/Office
Chemical Sewer Lift Station
Gasoline/Benzol Pumphouse
Fire Fighting Manifolds for 745ABC
Gasoline Unloading Rack
Flammable Materials Storehouse
Paint and Process Shop
Carpenter Shop/Storage
Lumber Storage
Steam Fitter Maintenance/Storage
Bank Vol
(BCY)
100
29
29
56
2
62
2
6
6
6
98
1,600
770
3,900
34
34
34
58
65
69
37
360
4
78
21
2
49
640
610
110
52
Size Shell USFWS Cleanup Added After Pipe Runs
(SF) Section Use Use1 Treaty Use Task 24 & Tanks
9,600
3,000
3,000
350
88
780
49
64
64
64
3,600
23,000
12,000
47,000
400
400
400
400
400
400
440
5,400
36
760
24
1
400
5,500
4,900
1,000
1,000
04 Short-Term
04 Short-Term
04 Short-Term
04
03 Cleanup Not in T-24
03 Cleanup
10
09
03
03
03
01 Owned Cleanup *
01 Leased . Cleanup
01
01
01
01
01
01
01
01
01
01
01
01
or
01 Leased
01
01
01
01
01
ma\IS75G.XLS,Othef
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 8 of 20
Place
#
225
226
227
228
229
230
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
Structure
Number
0754
0765
0784
0787
0801
0808
0809
0810
0825
0831
0831 A
0833
0836
0840
0841
0851
0853
0854
0863
0864
0865
0866
0867A
0867B
0871A
087 IB
0871C
087 ID
0872A
0872B
0872C
0872D
Description of Structure
Lumber Storage
Potable Water Purificaton
Guard Station-SE of 742-foundation
Warehouse
Radio Relay Station-N of 1726
No Bdry Groundwater Treatment Plant
Irondale Groundwater Treatment Sys.
NW Bndry Groundwater Treatment Bldg
Basin A Neck Treatment Bldg.
Technical Escort/Officer's Quarters
Garage/Storage Shed
Lumber Storage Shed
Air Force Seismic Monitoring
Air Monitoring Station
CO Public Service Co Meter House
Pistol Range House
Observation Pit/Mortar Range
Concrete Wall
Target Range House
General Storehouse
Warehouse
Toxic Yard Office & Change House
Toxic Yard Metal and Wood Shop
Flammable Materials Storehouse
Magazine
Magazine
Magazine
Magazine
Magazine
Magazine
Magazine
Magazine
BankVol Size Shell USFWS Cleanup Added After Pipe Runs
(BCY) (SF) Section Use Use1 Treaty Use Task 24 & Tanks
49
6
480
12
650
320
490
120
27
82
590
82
6
94
12
5
10
41
140
67
13
66
66
66
86
86
86
86
86
840
64
9,600
180
3,900
3,000
3,100
1,100
360
580
7,100
200
250
2,000
200
260
400
1,000
2,400
1,600
190
600
600
600
800
800
800
800
800
01
01
01
06
25
23
33
27
35
35
35
35
24
25
12
19"
30
26
12
06
06
06
06
06
06
06
06
06
06
06
06
06
Cleanup Not in T-24
Long-Term Cleanup Use
Cleanup
Cleanup Use
Cleanup
Cleanup
Cleanup Not in T-24
Cleanup
Cleanup
Cleanup Not in T-24
Cleanup and Beyond
Long-Term
Cleanup
Long-Term
Long-Term
rma\l57SG.XLS,Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 9 of 20
Place
#
257
258
259
260
261
262
263
264 ,
265
266
267
268
269
270
271
272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
288
Structure
Number
0873A
0873B
0873C
0874A
0874B
0874C
0874D
1403
1404
1405
1502
1504A
1505A
1507
1508
1509
1510
1510A
1512
1611A
1618
1619
1622
1701
1704
1705
1706
1707
1710
1711
1712
1713
Description of Structure
Magazine
Magazine
Magazine
Magazine
Magazine
Magazine
Magazine
2-HF Storage Tanks & Unloading Dock
Carbon Tetrachloride Storage Tank
Hydrochloride Acid Storage Tanks
Unloading Dock-Isopropanol Storage
Monitoring Shed
Sentry Station
Methanol Storage Tank
TBA Storage Tank
Isopropanol Dehydration Unit
Fuel Oil Tank
Fire Apparatus Buildng/Foam Storage
Sentry Station/Gate House
Sentry Station
General Storehouse-N of North Plant
Administration Building-N o*N Plant
General Storehouse-N of North Plant
Warehouse
Compressed Air Plant
Instruction Building/Cafeteria
Sentry Station/Gatehouse
Cooling Tower
Clinic and Administration Building
Gas Meter House
Gas Heating Plant
Standby Generator Plant
Bank Vol
(BCY)
86
86
86
86
86
86
86
83
83
83
83
7
2
83
84
76
1,200
16
18
4
36
8
34
2,300
1,400
250
44
560
920
6
320
100
Size Shell USFWS Cleanup Added After Pipe Runs
(SF) Section Use Use1 Treaty Use Task 24 &. Tanks
800
800
800
800
800
800
800
220
85
400
130
130
84
1,000
320
970
26,000
9,100
4,000
360
2,800
15,000
170
2,300
2,500
06 '
06
06
06
06
06
06
25
25
25
25
25
25
25
25
25 Treaty
25
25
25 Treaty
25
25
25
25
25 Treaty Cleanup
25 Treaty
25 Treaty
25 Long-Term Treaty
25 Treaty
25 Cleanup
25 Cleanup
25
25 Treaty Cleanup
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
ma\l575G.XLS,Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 10 of 20
Place
ft
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
312
313
314
315
316
317
318
319
320
Structure
Number
1715
1717
1718
1719
1726
1728
1730
1734
NN0101
NN0102
NN0103
NN0104
NN010S
NN0106
NN0107
NN0108
NN0109
NN0110
NN0111
NN0112
NN0113
NN0114
NN0115
NN0116
NN0117
NN0201
NN0202
NN0204
NN0205
NN0300
NN0301
NN0302
Description of Structure
Chlorinating Station
Valve Pit & Chlorinating Station
Electrical Distribution System
Elevated Process Water Tank, North Plants
Potable Water Tank
Guardhouse
Change House
Valve Gate-W side of Upper Derby
Foundation-N of 534B
Bathroom-Nof533
Flare Tower-N of 571B, NW of 571
Gas Meter House-SW of 508
Fertil & Waste Loadng Fac-N of 728
Metal Shed-W of 733B
Metal Shed-W of 733C
Guard Station-NE of 732
Metal Shed-S of 521B
Three Metal Incinerator-NW of 541
Stack Observation Station-E of 527
2 Metal Sheds-S of 474 SS
Wooden Hut-SW of 461
Flare Tower-N of Lime Pond
Long Metal Shed-S of 544
2Sheds-SWof557
Concrete Silo-NW of 254
Brick Structure-E of SS 361
Coal Hopper foundation-N of 334
Brick Valve House-S of 321B
MetalShed-Nof618
Metal Shed-N of 618
BankVol
(BCY)
11
24
13
270
69
13
48
20
19
3
17
5
78
1
1
1
3
150
12
27
2
17
47
4
350
15
38
27
1
1
Size Shell USFWS Cleanup Added After Pipe Runs
(SF) Section Use Use1 Treaty Use Task 24 & Tanks
120
260
130
110
470
49
750
120
660
200
99
310
310
64
80
440
280
250
22
660
6,000
130
1,300
140
1,100
150
410
410
25 Cleanup Not in T-24
25 Cleanup
25 Cleanup
25 Cleanup
25 Short-Term Cleanup Tanks/Pipes
25 Tanks/Pipes
31
31 Long-Term
01 Long-Term
01
01
01 Owned
01
01
01
01
01
01
01 Owned
01
01
01
01 Owned
01
01
02
02
02
02
03 Cleanup Not in T-24
03
03
rm»\157SG.XLS,OOiCT
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 11 of 20
Place
#
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
Structure
Number
NN0303
NN0304
NN0601
NN0602
NN0603
NN0902
NN1208
NN1209
NN12IO
NN1211
NN1212
NN1213
NN2001
NN2002
NN22
NN23
NN2301
NN24
NN2401
NN2402
NN2403
NN2404
NN2405
NN2501
NN2502
NN2503
NN2601
NN2602
NN28
NN3001
NN3002
NN3101
Description of Structure
Metal Shed-N of 619
Metal Shed-N of 619
Loading Dock-W of 866
Long Metal Shed-W of 865
Metal Shed-E of 867A
Survey Tower-N of Post Office
Brick Structure-900'SW of 846
Concrete Bunker- 1 1 GO'S of 846
Concrete Bunker- 1250'S of 846
Concrete Bunker-1300'S of 846
Concrete Bunker-1350'S of 846
AMSA/QMS Maintenance Shop-N of 841
Antenna Installation- 1/2 mi N o'9th
Tank Pad-N of 9th, 2/3 mi E of F St
36 GW Wells-NW Boundary Treatment
36 GW Wells-N Boundary Treatment
Abandoned Water Purification Plant
56 GW Wells-N Boundary Treatment
Concrete Structure-E of Bog
Wooden Shed-N of Trickling Filters
2 Trickling Filters-S of 391
ImhoffTank-Sof391
Antenna Installation-N of 836
Shed-NWofl618
Gas Pump & Pad-NE of 1618
Pumping Station-S of 1510
Decon Pad/Tank-NE of Basin F
Valve gate-N end of Reservoir C
2 GW Wells-Irondale Treatment
Metal Shed-E of 853
Metal Shed-E of 853
Metal Shed-N of 1734
Bank Vol
(BCY)
1
1
150
1
1
1
9
14
10
14
6
780
17
14
60
3
7
1,800
410
12
8
32
4
58
19
1
1
1
Size Shell USFWS Cleanup Added After Pipe Runs
(SF) Section Use Use1 Treaty Use Task 24 & Tanks
2,400
1,900
11,000
3,500
510
140
81
68
56
68
64
10,000
44
380
1,600
25
170
17,000
2,800
44
300
950
72
2,300
56
580
580
80
03
03
06
06
06
09 Cleanup
12
12
12
12
12
12
20
20 Cleanup
22
23
23
24
24
24
24
24
24
25
25
25
26
26
28
30
30
31
ttna\!575G.XLS,OthCT
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 12 of 20
Place
#
353
354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
380
381
382
383
384
Structure
Number
NN3102
NN3103
NN3104
NN3105
NN3106
NN3107
NN3108
NN3109
NN33
NN3501
NN3601
NN3602
NN3603
NN3604 .
NN3605
NNT0101
NNT0103
NNT0105
NNT0106
NNT0107
NNT0110
NNT01 1 1
NNT0201
PR01
PR02
PR04
PR25
PR36
SS 0100
SS0101
SS0102
SS 0103
Description of Structure
3 Sets Shed Siding-1 100'SE of 1735
Storage Bldg-Toxic Storage Yard
Shack- W of Berms-Toxic Storage Yard
Shed-NW End of Berms-Toxic Storg Yd
Shed-NE End Berms-Toxic Storage Yd
Antenna Station-Toxic Storage Yard
Shed-SW End of 1st Berm-Toxic Yard
Shed-SE End of 1st Berm-Toxic Yard
45 GW Wells-Irondale Treatment
3 Communications Antenna Pits
Incinerator-500'NE of 834
Incinerator- 1000'SE of 834
Metal Shed-NW of 725
Metal Shed-SW of 725
Metal Shed-SE of 725
Vertical Tank-TFOlOl
Vertical Tank-TF0106
Horizontal Tank-TF0108
Vertical Tank-TF0109
Horizontal Tank-E of 47 1C
Horizontal Tank-E of 536
Vertical Tank-TF0105
Undrground Oil Tank w/DCPD-W of 321
Pipe Runs in Section 1
Pipe Runs in Section 2
Pipe Runs in Section 4
Pipe Runs in Section 25
Pipe Runs in Section 36
Substation- IT-SON of 866
Substation-2T-200"NE of 866
Substation-lT-500'W of 867A
Substation- 1 T-7001 W of 865
BankVol Size Shell USFWS
(BCY) (SF) Section Use Use1 Treaty
2,400
1
1
1
2
4
1
2
6
30
6
4
6
2
21
1
1
2
1
1
5
1
2,000
520
100
820
470
59,000
1,500
70
110
4,000
32
110
4,000
48
350
100
140
200
200
31
31
31
31
31
31
31
31
33
35
36
36
36
36
36
01
01
01
01
01
01
01
02
01
02
04
25
36
06
06
06
06
Cleanup Added After Pipe Runs
Use Task 24 & Tanks
-
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
im»\l575G.XLS,Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 13 of 20
Place
#
385
386
387
388
389
390
391
392
393
394
395
396
397
398
399
400
401
402
403
404
405
406
407
408
409
410
411
412
413
414
415
416
Structure
Number
SS0104
SS0105
SS01U
SS0112
SS0121
SS0141
SS0176
SS0213
SS 0232
SS 0243
SS 0245
SS0311
SS0312
SS0312A
SS0313
SS 03 13-2
SS0314
SS0315
SS0316
SS0316A
SS0317
SS0321
SS0321A
SS 0321B
SS 0325
SS 0327
SS 0328
SS 0330
SS 0335
SS 0342
SS 0344
SS 0355
Description of Structure
Substation-lT-400'N of 872A
Substation- 1T-NE of 867A
Substation-2T-N side 1 1 1
Substation-lT-150'S of 1 12
Substation- 1T-NW comer of section
Substation-3T-E of 141
Substation-lT-W of Staff Quarters
Substation-3T-SE of 213
Substation-3T-SWof254
Substation- 1T-W of 243
Substation-3T-S of 245
Substation- 1T-S of 311
Substation- 1 T-S of 3 1 2
Substation-lT-NE of 312
Substation-3T-Wof313
Substation-3T-Wof313
Substation-3T-NWof314
Substation-3T-SWof3l5
Substation- 1 T-S of 3 1 6
Substation-3T-S of 3 16A
Substation-lT-NW of 433
Substation-6T-S of 321
Substation-3T-SW of 242
Substation-lT-SE of 242
Substation-14T-berween 325 & 3 1 1
Substation-3T-W of 332
Substation-3T-N of 328
Substation-lT-SWof337
Substation-3T-S of 336
Substation-3T-ENE of 342
Substation-5T-E of 344
Substation-3T-E of 356
BankVol Size Shell USFWS Cleanup Added After Pipe Runs
(BCY) (SF) Section Use Use1 Treaty Use Task 24 & Tanks
06
06
35
02 Short-Term
03
04
03
02 Short-Term
02
02
02
02
01
36
01
01
01
01
01
01
01
02
02
02
02
02
02
02
02
02
02
02
ima\1575G.XLS,Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 14 of 20
Place
#
417
418
419
420
421
422
423
424
425
426
427
428
429
430
431
432
433
434
435
436
437
438
439
440
441
442
443
444
445
446
447
448
Structure
Number
SS 0361
SS 0362
SS 0363
SS 0365
SS 0368
SS0371A
SS0371B
SS 0378
SS 0379
SS 0383
SS 0391
SS 0392
SS 0393
SS0411
SS 0422
SS0451
SS 0461
SS0464
SS 0474
SS0510
SS0512
SS0514
SS0515
SS0516
SS0517
SS0517A
SS0517B
SS0521
SS0523
SS 0525A
SS 0527
SS 0528
Description of Structure
Primary Substation-68T-SE of 1 12
Substation-3T-N of 362
Substation-3T-N of 362
Substation-3T-N of 365
Substation-lT-1/4 mi SSE of 351
Substation- 1T-S of 372
Substation- 1T-N of SS 371
Substation- IT-N of 378
Substation-lT-SE of 379
Substation-3T-Eof383
Substation-3T-SE of 391
Substation-2T-W of 392
Substation-2T-S of 393
Substation-3T-NE of 4 1 1
Substation-3T-W of 422
Substation- 1T-SE of 413
Substation-2T-S of 459
Substation-2T-SE of 464
Substation-7T-Wof472
Substation-3T-SE of 510
Substation-3T-NW of 5 17
Substation-3T-200'E of 561
Substation-6T-NW of 5 15
Substation-3T-Wof519
Substation-2T-NWof517
Substation-3T-N of 512
Substation-3T-S W corner of 5 1 7
Substation-3T-SW of 521
Substation-3T-S of 803
Substation-lT-SWof525
Substation- 1T-S of 527
Substation- 1T-S of 529
BankVol Size Shell USFWS Cleanup Added After Pipe Runs
(BCY) (SF) Section Use Use1 Treaty Use Task 24 & Tanks
02
02
02
02
01
02 Short-Term
02 Short-Term
03 Short-Term
03 Short-Term
02 Short-Term
24
34 Short-Term
34 Short-Term
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
26
01
01
01
rma\1575G.XLS,Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 15 of 20
Place
#
449
450
451
452
453
454
455
456
457
458
459
460
461
462
463
464
465
466
467
468
469
470
471
472
473
474
475
476
477
478
479
480
Structure
Number
SS 0529
SS0531
SS 0534
SS 0539
SS 0541
SS 0543
SS 0548
SS 0548A
SS 0556
SS0571
SS 0575
SS 0575A
SS0611
SS 0612
SS0613
SS0614
SS0616
SS0618
SS 0618-2
SS 0622
SS 0624
SS 0625
SS 0627
SS 0627A
SS 0629
SS0631
SS0632
SS 0633
SS 0634
SS 0635
SS0647
SS 0673
Description of Structure
Substation-3T-S of 540
Substation-lT-Wof531
Substation-3T-200'N of 534A
Substation-2T-SE of 537
Substation-3T-Wof541
Substation-5T-Wof543
Substation-lT-Nof548
Substation-lT-101'W of 548
Substation- 1T-N of 541
Substation-3T-75'W of 504A
Substation- 1T-N of 504
Substation- 1T-N of 505
Substation-3T-Sof611
Substation-lT-E of 612
Substation-3T-NW of 613
Substation-lT-Wof614
Substation-3T-N of 614
Substation-3T-N of 6 1 8
Substation-lT-W of 618
Substation- 1 T-NE of 62 1
Substation-3T-E of 624
Substation- 1T-E of 624
Substation-3T-E of 627
Substation- 1T-E of SS 627
Substation-3T-NE of 629
Substation-3T-N of 63 1
Substation-lT-NE of 632
Substation-3T-S of 633
Substation-3T-SE of 634
Substation-lT-Wof635
Substation-lT-E of 647A
Substation-lT-1200'NNE of 619
BankVol Size Shell USFWS Cleanup Added After Pipe Runs
(BCY) (SF) Section Use Use1 Treaty Use Task 24 & Tanks
01
01
01
01
01
01
01
01
01
01
01
01
04 Short-Term
04 Short-Term
04 Short-Term
03
03
03
03
04
04
04
04 Short-Term
04 Short-Term
04
04
04 Short-Term
04
04
03
03
03 Short-Term
mia\1575G.XLS,Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 16 of 20
Place
#
481
482
483
484
485
486
487
488
489
490
491
492
493
494
495
496
497
498
499
500
501
502
503
504
505
506
507
508
509
510
511
512
Structure
Number
SS 0725
SS 0726
SS 0727
SS0728
SS 0729
SS 0732
SS 0742
SS 0747
SS0755
SS 0756
SS0757
SS0780
SS0781
SS 0782
SS 0791-2
SS 0806D
SS 0806G
SS 0808ABC
SS 0808D
SS 0808E
SS 0808F
SS 0808G
SS 0808H
SS 08081
SS 0808K
SS 0808L
SS 0809
SS 0809A
SS0809B
SS 0809C
SS 0809D
SS 0809E
Description of Structure
Substation-3T-S of SS 726
Substation-3T-200'S of 725
Substation- 1T-W side of 727
Substation-3T-E of 728
Substation-6T-E of 729
Substation-6T-S of 732
Substation-6T-N of 742
Substation- IT-75'S of 729
Substation-3T-S of 868C
Substation-lT-W of 868C
Substation- 1T-S of 463D
Substation-lT-N of T 1505
Substation- 1T-NE of T 1507
Substation-lT-N of 732
Substation-lT-E of 145
Substation-lT-SE of 806
Substation- 1T-0.25 mi SW of 9 & D
Substation-3T-NE of 808
Substation-lT-0.3 mi SW of 808
Substation- 1T-0.2 mi SW of 808
Substation-lT-427'SSE of 808
Substation-lT-800'SE of 808
Substation- 1T-0.36 mi ESE of 808
Substation- 1T-0.49 mi ESE of 808
Substation- 1T-0.68 mi ESE of 808
Substation- 1T-0.65 mi E of 808
Substation-3T-S of 809
Substation-3T-300'SW of 809
Substation-3T-200'W of 809
Substation-3T-400'N of 809
Substation-3T-700*NE of 809
Substation-3T-500'E of 809
BankVol Size Shell USFWS Cleanup Added After Pipe Runs
(BCY) (SF) Section Use Use' Treaty Use Task 24 & Tanks
36
36
01
01
01
01
01
01
01
01
01
01
01
01
11
26
26
23
23
23
24
24
24
24
24
24
33
33
33
33
33
33
ima\l575G.XLS,Othcr
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 17 of 20
Place
#
513
514
515
516
517
518
519
520
521
522
523
524
525
526
527
528
529
530
531
532
533
534
535
536
537
538
539
540
541
542
543
544
Structure
Number
SS 0809F
SS0831
SS0831E
SS 0832
SS 0836
SS 1402
SS 1403
SS 1404
SS 1501
SS 1505
SS 1506
SS 1510
SS 1601-1
SS 1601-2
SS 1602
SS 1603
SS 1605
SS 1606-1
SS 1606-2
SS 1607
SS 1609
SS1611
SS1611AB
SS 1614
SS 1616
SS 1701
SS 1702
SS 1703
SS 1704-1
SS 1704-2
SS 1704-3
SS 1706
Description of Structure
Substation-3T-0.2 mi S of 809
Substation-3T-200'S of 8th & D St
Substation- 1T-538'SSE of 8th & D St
Substation- 1T-300'E of 159
Substation-3T-S of 836
Substation-3T-150'W of 1601/1701
Substation-3T-S of 1701
Substation-3T-130'S of 1501
Substation-7T-SE of 1501
Substation-3T-E of 1505
Substation-2T-NW corner of 1506
Substation-2T-150'W of 1601
Substation- 1T-E of 1601
Substation- 1 T-E of 1 60 1
Substation-2T-100'SE of 1606
Substation-ST-lOO-NE of 1602
Substation-lT-between 1605 & 1608
Substation-3T-100'E of 1606
Substation-lT-lOOm of 1606
Substation-3T- 1 OO'E of 1 607
Substation-lT-150'NE of 1609
Substation-lT-Eofl611
Substation-2T-S of 161 1
Substation-2T-NE o'1615
Substation-2T-NE of 1616
Substation-3T-lOO'E of 1701
Substation-2T-W of 1702
Substation-lT-S of 1703
Substation-3T-E of 1704
Substation-2T-E of 1704
Substation-3T-Eofl704
Substation- 1T-N of 1706
BankVol Size Shell USFWS Cleanup Added After Pipe Runs
(BCY) (SF) Section Use Use1 Treaty Use Task 24 & Tanks
33
35
36
34
24
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25 Long-Term
25
ma\1575G.XLS,Other
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 18 of 20
Place
#
545
546
547
548
549
550
551
552
553
554
555
556
557
558
559
560
561
562
563
564
565
566
567
568
569
570
571
572
573
574
575
576
Structure
Number Description of Structure
SS 1 707 Substation- 1 T-S of 1 704
SS 1710 Substation-3T-100'E of 1710
SS 171 1 Substation-3T-100'E of 1706
SS1724 Substation-3T-200'Nofl706
SS 1730 Substation-2T-NW of 1730
SS 173 1 Substation-lT-200'NW of 1730
SS 1 732 Substation- 1 T-N W corner of section
SS 1735 Substation-3T-E of 1736
SS 1736 Substation-2T-200'Sof 1736
SS 6C Substation- 1 T-S W corner of section
SS 7215 Substation- IT-fenced railcar area
SS7C Substation-lT-112'ESE7th&C
SS AL338 Substation- 1T-SE corner of section
SSAWL021 Substation-lT-Sofpoolrd
SS CPR 1 Rectifier-lR-130'SSE of 254
SSCPR10 Rectifier-lR-Sof742A
SSCPR2 Rectifier-lR-Wof313
SSCPR3 Rectifjer-lR-146'Wof326
SS CPR 4 Rectifier-lR-E of 352A
SS CPR 5 Rectifier- 1 R-with SS 5 14
SS CPR 6 Rectifier-lR-with SS 515
SS CPR 7 Rectifier-lR-NE of SS 411
SSCPR8 Rectifier-lR-Wof433
SSCPR9 Rectifier-lR-Wof542
SS F182 Substation-lT-500'W of T 1512
SSFL842 Substation-lT-Nofl618
SS GA Substation-lT-0.1 mi N of 732
SSH-1 Substation-2T-SEof319
SS LDLA Substation-lT-W of Lower Derby
SSNN2201 Substation-lT-640'NNWof8IO
SS NN2202 Substation-lT-960'NNW of 810
SS NN2203 Substation-lT-1260-NW of 810
BankVol Size Shell USFWS Cleanup Added After Pipe Runs
(BCY) (SF) Section Use Use1 Treaty Use Task 24 & Tanks
25
25
25
25
31
31
31
31
31
02
36
02
31
02
02
01
01
02
02
01
01
01
01
01
36
25
36
01
01
22
22
22
ma\157SO.XLS,OUier
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 19 of 20
Place Structure
# Number
577 SSNN2204
578 SS NN2205
579 SSNN2206
580 SS NN2207
581 SSNN2208
582 SS NN2209
583 SSNN2210
584 SSNN2211
585 SSNN2301
586 SS NN2501
587 SSNN2601
588 SSNN2701
589 SS PSCOST
590 SS PT56/57
591 SS SB A
592 SS SWIM
593 SS WR
594 T 0026
595 T0064
596 T0065
597 T0075
598 T0076
599 T0078
600 T0139
601 T0190
602 T0289
603 T 1040
604 T1128
605 T1129
606 T1132
607 T1133
608 T1140
Description of Structure
Substation-lT-1600'NW of 810
Substation-lT-2050-NW of 810
Substation-lT-2500'NW of 810
Substation- 1 T-8001 WNW of 8 1 0
Substation-lT-1 100'WNW of 810
Substation- 1 T- 1 350' WNW of 8 1 0
Substation-lT-1670'WNW of 810
Substation- 1T-2370'WNW of 810
Substation-3T-200*N of 808
Substation- 1T-SE comer of 1602
Substation- 1 T-S of 806
Substatkm-3T-W of 810
Substation- IT- 1/8 mi S of 7th on C
Substation-2T-NE of 510
Substation-3T-SE side of 834
Substation-lT-W of pool/on C
Substation- IT-600'NE of 732
Horizontal Tank-TF0107
Horizontal Tank-TF0107
Vertical Tank-TF0103
Vertical Tank-TF0103
Vertical Tank-TF0103
Vertical Tank-TF0103
Horizontal Tank-TF0107
Horizontal Tank-TFOl07
Air Receiver/Surge Tank-NE of 5 1 6
Vertical Tank-TF0107
Methanol Tank-TF0104
MMAATank-TF0104
Trimethylphosphite(TMP) Tank-TF0103
MMA Tank-TF0104
Chloroform Tank-TF0104
Bank Vol Size
(BCY) (SF)
1
1
31
1
1
1
1
3
1
1
1
1
1
1
1
Shell USFWS Cleanup
Section Use Use1 Treaty Use
22
22
22
22
22
22
22
22
23
25
26
27
02
01
36
02
36
01 Owned
01 Owned
01
01
01
01
01
01
01
01 Owned
01
01
01
01
01
Added After Pipe Runs
Task 24 & Tanks
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
rtna\1575G.XLS,Oflier
-------
Table 5.4-8 Inventory of No Future Use, Other Contamination History Medium Group
Page 20 of 20
Place
#
609
610
611
612
613
614
615
616
617
618
619
620
621
622
623
624
625
626
627
628
629
630
631
Structure
Number
T1146
T1147
T1168
T1178
T1216
T1324
T1327
T1340
T1392
T1463
T1570
T1606
T1973
TF0107
TF2501
TW-13
V1064
V1214
V1220
V1250
V1253
V1267
V1270
Description of Structure
Dicetene Tank-TFOl 10
Dicetene Tank-TFOl 10
Brine Storage Tank-SB corner 528
Acetone Storage Tank-TFOl 03
Mother Liquor/Dinitro Tank-TFOl 02
Brine Storage Tank-TF0103
Vertical Tank-TF0103
Crystal, Acetone Tank-TFOl 02
Vertical Tank-E of 512
Vertical Tank-TF0104
Vertical Tank-TF0105
Horizontal Tank-TF0109
Vertical Tank-TF0103
Tank Farm-W & S of 514A
Tank Farm-W of 1704
Open Storage-foundation-N of 161 1
Vertical Tank-TF0109
Vertical Tank-TF0106
Vertical Tank-TFOl 06
Horizontal Tank-TFOl 04
Horizontal Tank-TF0104
Surge Vessel-TF0105
Horizontal Tank-TFOl 05
Bank Vol
(BCY)
2
2
5
1
6
1
17
16
5
2
5
5
2
110
25
120
1
2
6
1
1
2
1
Size Shell USFWS Cleanup
(SF) Section Use Use1 Treaty Use
01
01
01
01
01
01
01
01
01
01
01 Owned
01
01
01
25
5,800 25
01
01
01
01
01
01
01
Added After Pipe Runs
Task 24 & Tanks
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
Tanks/Pipes
1 These buildings may be reevaluated for potential historic preservation or future use. The Rocky Mountain Arsenal National Wildlife Refuge Act states that "transfer shall be made without cost
to the Secretary of the Interior and shall include such improvements on property as the Secretary of the Interior may request in writing for refuge management purposes."
rnia\l57JG.XLS,OthCT
-------
Table 5.4-9 Inventory of No Future Use, Agent History Medium Group
Page 1 of 3
Place
#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
Structure
Number
0313
0315
0319
0414
0416
0417
0422
0426
0427
0428
0429
0512
0514
0514A
0516
0517
0528
0536
0537
0538
0540
0541
0725
0726
0728
0742
0742A
0785
0786
0788
0791
0792
Bank Volume
Description of Structure (BCY)
Laboratory
Warehouse-Laundry
Magazine/Flammable Material Storage
Mustard Scrubber Unit-foundation
H/Dichlor Disposal Reactor-foundatn
H/Dichlor Decon Pit-foundation
H Manufacture/Aldrin Production
Mustard Disposal Reactor-foundation
Decontamination Pit-fdn
Incinerator
H Brine Mixing/Pesticide Mfg.
Filling/Pesticide Production
Lewisite/HD/Pesticide Production
L/M-1 Storage/Dowtherm Boiler
Lewisite Distillation/Pest. Prod.
Offices/Change House/Laboratory
HD Burning/Pesticide Manufacture
Ammo.Dem.Facility/Crude Mustard Sto.
Thaw House
Ton Container Reconditioning Plant
Ton Container Renovation Plant
Warehouse/WP Filling
Bomb Testing Station
Bomb Test Building
HD Filling/Pesticide Storage/Wareh.
Warehouse
Tank House
Warehouse
Warehouse
Warehouse
Warehouse
Drum Storage Warehouse
1,000
1,000
52
79
79
79
2,100
59
4
6
15
610
3,200
110
1,400
1,300
380
990
2,300
1,200
330
770
99
40
1,400
4,800
330
1,400
480
480
480
440
Size
(SF)
10,000
10,000
400
310
300
280
23,000
1,600
80
56
560
3,800
27,000
1,700
13,000
18,000
2,200
4,100
16,000
15,000
4,900
11,000
460
430
21,000
49,000
1,300
29,000
9,600
9,600
9,600
9,600
Section
01'
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
36
36
01
01
01
06
06
06
31
31
Shell
Use
Leased
Leased
Leased
Leased
Leased
Leased
Leased
Leased
Leased
USFWS Cleanup Added After Pipe Runs
Use1 Treaty Use Task 24 & Tanks
••
Treaty
Treaty
Treaty
Treaty
Treaty
Cleanup
Treaty Cleanup
Treaty
Long-Term
Long-Term Cleanup
Long-Term Cleanup
Cleanup
Cleanup
rma\1575G.XLS,Agent
-------
Table 5.4-9 Inventory of No Future Use, Agent History Medium Group
Page 2 of 3
Place
#
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
Structure
Number
0793
0794
0795
0796
0797
0798
0881
0882
0883
0885
0886
1501
1503A
1503B
1503C
1504
1506
1601
I601A
1602
1603A
1603B
1605
1606
1607
1608
1609
1610
1611
1613
1614
1615
Description of Structure
Drum Storage Warehouse
Drum Storage Warehouse
Drum Storage Warehouse
Warehouse
Drum Storage Warehouse
Drum Storage Warehouse
Igloo Storage
Igloo Storage
Igloo Storage
Igloo Storage
Igloo Storage
GB Manufacturing/Demil. Building
Scrubber Facility- 1 503 A/B/C= 1503
Scrubber Facility- 1503=1 503 A/B/C
Scrubber Facility- 1503= 1503 A/B/C
200-ft Steel Stack
GB Storage
GB Filling
Ammunitions Demilitarization Facility
Paint Storage
Scrubber Facility
Scrubber System- 1603=1 603 A/B
Munitions Storage Igloo
Cluster Assembly Buildinge
Warehouse
Munitions Storage Igloo
Munitions Storage Igloo
Munitions Storage Igloo
Demilitarization Facility
Explosive Unpacking Building
Warehouse
Warehouse
Bank Volume
(BCY)
470
520
480
480
480
480
210
210
210
210
210
9,000
440
88
79
630
1,900
7,700
670
620
89
89
150
14,000
1,700
150
150
150
3,100
77
260
170
Size
(SF)
9,600
9,600
9,600
9,600
9,600
9,600
,600
,600
,600
,600
,600
81,000
580
580
580
710
9,000
69,000
2,800
2,200
580
580
1,000
60,000
26,000
1,000
1,000
1,000
32,000
750
7,800
4,000
Section
31
31
31
31
31
31
06
06
06
06
06
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
Shell USFWS
Use Use1 Treaty
Long-Term
Long-Term
Treaty
Treaty
Treaty
Treaty
Treaty
Treaty
Treaty
Treaty
Treaty
Treaty
Treaty
Treaty
Treaty
Cleanup Added After Pipe Runs
Use Task 24 & Tanks
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
Cleanup
m>a\l575G.XLS,Agem
-------
Table 5.4-9 Inventory of No Future Use, Agent History Medium Group
Page 3 of 3
Place
#
65
66
67
68
69
70
Structure
Number
1616
1702
1703
1727
1735
T0027
Description of Structure
Warehouse
Weld Shop
Spray Dryer Facility
Industrial Waste Sewer
Loading Dock
Vertical Tank-TF0107
Bank Volume
(BCY)
85
49
2,700
36
670
1
Size
(SF)
4,000
2,400
28,000
700
11,000
Shell
Section Use
25
25
25
25
31
01
USFWS Cleanup Added After
Use1 Treaty Use Task 24
Treaty
Treaty
Treaty
Pipe Runs
& Tanks
Tanks/Pipes
1 These buildings may be reevaluated for potential historic preservation or future use. The Rocky Mountain Arsenal National Wildlife Refuge Act states that "transfer shall be made without cost
to the Secretary of the Interior and shall include such improvements on property as the Secretary of the Interior may request in writing for refuge management purposes."
nna\l575G.XLS,Agent
-------
Table 5,4-10 Soil Exceedance Categories, Medium Groups, and Subgroups Page 1 of 1
Human Health Exceedance Category
Basin A Medium Group
Basin F Medium Group
Basin F Wastepile Subgroup
Former Basin F Subgroup
Secondary Basins Medium Group
Sewer Systems Medium Group
Chemical Sewers Subgroup
Sanitary/Process Water Sewers Subgroup
Disposal Trenches Medium Group
Complex Trenches Subgroup
Shell Trenches Subgroup
Hex Pit Subgroup
Sanitary Landfills Medium Group
Lime Basins Medium Group
Section 36 Lime Basins Subgroup
Buried M-l Pits Subgroup
South Plants Medium Group
South Plants Central Processing Area Subgroup
South Plants Ditches Subgroup
South Plants Balance of Areas Subgroup
Buried Sediments/Ditches Medium Group
Buried Sediments Subgroup
Sand Creek Lateral Subgroup
Undifferentiated Medium Group
Section 36 Balance of Areas Subgroup
Burial Trenches Subgroup
Biota Exceedance Category
Surficial Soil Medium Group
Lake Sediments Medium Group
Ditches/Drainage Areas Medium Group
Potential Agent Presence Category
Agent Storage Medium Group
North Plants Subgroup
Toxic Storage Yards Subgroup
Potential UXO Presence Category
Munitions Testing Medium Group
nna/1406G.DOC
-------
Table 5.4-11 Summary of Soil Medium Groups and Subgroups
Page 1 of 4
Medium Groups Subgroup Description
Munitions
Testing
Agent Storage
North
Plants
Toxic
Storage
Yards
Lake Sediments —
Surficial Soil —
Ditches/Drainage
Areas
This group is comprised of sites having similar histories and uses. The
sites, considered potential HE-filled UXO presence areas and predominantly
located in the eastern portions of RMA, were used for testing or destruction
of nonchemical munitions. These sites typically contain slag, debris, and
potential UXO in the uppermost 1 ft of soil and therefore present physical
hazards. The mortar impact area hi Section 30 may contain UXO at depths
as deep as 6 ft. COC concentrations were not detected above human health
SEC at any of the sites.
Sites in this subgroup have potential agent presence but do not contain
human health exceedances except as isolated detections. They are located
in the North Plants GB manufacturing area. These sites are presumed to
contain agent based on use histories and detections of agent breakdown
products. Isolated detections of arsenic exceed the human health SEC.
Portions of the sites in this subgroup potentially pose risks to biota.
Sites in this subgroup (including the New and Old Toxic Storage Yards)
are located in the storage areas hi the eastern portion of RMA and are
considered to potentially contain agent based on use histories and detections
of agent breakdown products. However, sampling has not indicated the
presence of agent at these sites. The Old Toxic Storage Yards were
retained as sites presumed to contain agent. Isolated detections of
chloroacetic acid and arsenic exceed the human health SEC.
Sites within this medium group include sediments from lakes located in the
southern portion of RMA and sediments from the North Bog. They were
grouped together based on the potential risk they present to ecological
receptors. Contamination has resulted from the influx of suspended solid-
or dissolved-phase contaminants transported to the lakes by surface water
or groundwater. Isolated exceedances of human health SEC include
chlordane and chromium and acute exceedances of aldrin and dieldrin.
Water is not currently allowed to pond in Upper Derby Lake, and portions
of Upper Derby Lake contain soil that poses a potential risk to biota.
This medium group consists of areas of shallow soil contamination
(including Basin F Exterior) posing risk to biota that are not included as
sites in other medium groups/subgroups. Portions of this group contain
OCPs above human health SEC. This group also contains the pistol and
rifle ranges.
Exceedance sites within this medium group have various disposal and
release histories and contain low levels of contaminants, primarily OCPs,
that pose risks to biota.
tma/15SlG
-------
Table 5.4-11 Summary of Soil Medium Groups and Subgroups
Page 2 of 4
Medium Groups Subgroup Description
Basin A — This medium group is comprised of two sites within the Basin A
high-water line. Basin A contains soil and sediment that were
contaminated by organic and inorganic chemicals from manufacturing
wastewater discharged to the basin. The medium group is also
characterized by the potential presence of agent and agent-filled UXO.
Agent was detected in the southern portion of Basin A. COCs detected
above the human health SEC include primarily OCPs; soil near the center
of the basin exceeds the principal threat criteria.
Basin F Basin F This subgroup consists of the Basin F Wastepile that was formed as a result
Wastepile of the Basin F IRA. The IRA has included incineration of Basin F liquids
in the SQI, excavation of Basin F soil from below the original asphalt liner
and the final grading, capping, and revegetation of the excavated area. The
Basin F Wastepile consists of excavated sediment and soil that are
contaminated with organic compounds, arsenic, and metals at
concentrations exceeding human health SEC and principal threat criteria.
The total concentrations of organics are inferred to be on the order of
1,000 to 10,000 ppm. This material also contains elevated levels of salts
due to the high chloride content in the wastewater stored in the former
Basin F.
Former The former Basin F site consists of the former basin area, including the
Basin F area beneath the Basin F Wastepile. Basin F received wastewaters through
the chemical sewer system, and the site is expected to contain somewhat
elevated levels of salts due to the high chloride content in the wastewater.
COCs remaining in the soil exceeding human health SEC include OCPs
and chloroacetic acid; large portions of the former basin exceed principal
threat criteria. The Basin F IRA included the installation of a soil cover.
Secondary Basins — Sites within this subgroup consist of four liquid disposal basins (Basins B,
C, D, and E) that collected overflow water from Basin A and the former
deep disposal well. These sites are expected to contain somewhat elevated
levels of salts that are a result of the storage of wastewater with high
chloride content. COCs detected in the soil above human health SEC
include OCPs, although the majority of contamination potentially poses
risks to biota only.
Sewer Systems Sanitary/ Sites within this subgroup consist of sanitary and process water sewers.
Process Soil around these sewer lines does not exceed human health SEC and does
Sewers not pose risks to biota based on the depth of the sewer lines; however,
these sewer lines potentially serve as conduits for the migration of
groundwater contamination.
Chemical Sites within this subgroup consist of chemical sewers. COCs in the soil
Sewers exceeding human health SEC and principal threat criteria in portions of
South Plants include OCPs, volatile organics, and chloroacetic acid. These
sewers are further characterized by the potential presence of agent.
ma/lSJlG
-------
Table 5.4-11 Summary of Soil Medium Groups and Subgroups
Page 3 of 4
Medium Groups Subgroup Description
Disposal Complex This subgroup is characterized by trenches or pits that were filled with
Trenches Trenches trash and manufacturing/military wastes. Wastes are suspected to consist of
drums of solid and liquid material, wood, glass, metal, laboratory and
manufacturing equipment, and miscellaneous material. This subgroup is
further characterized by the potential presence of agent and agent-filled
UXO.
Shell This subgroup is characterized by trenches or pits that were filled with
Trenches trash and manufacturing/military wastes in the area of the Shell Trenches.
Wastes are suspected to consist of drums of solid and liquid material. IRA
activities at this site have consisted of the placement of a soil cap across
the entire site and a vertical barrier surrounding the site.
Hex Pit This site was historically used for disposal of hex bottoms, a tarry,
chlorinated wastestream resulting from the production of HCCPD. The soil
at this site is contaminated with these resinous materials. This material was
buried in thin-gauge caustic barrels and in bulk.
Sanitary Landfills — This medium group consists of sanitary landfills and inferred trenches that
are predominantly located in the eastern and western portion of RMA.
These sites contain trash and rubbish, but are not anticipated to contain
drums of hazardous material, agent, or UXO.
Lime Basins Section 36 The Section 36 Lime Basins, used for the neutralization of process wastes
Lime related to agent production, are characterized by soil/sludge mixtures with
Basins high pH levels and the potential presence of agent. COCs in the
soil/sludge exceeding human health SEC include primarily OCPs; low-level
inorganic contamination is also present. IRA activities at this site involved
placing a soil cover across the entire site.
M-l Pits The Buried M-l Pits, used for the neutralization of process wastes related
to agent production, are characterized by soil/sludge mixtures with high pH
levels and the potential presence of agent. COCs in the soil/sludge
exceeding human health SEC and principal threat criteria primarily consist
of arsenic and mercury. This subgroup is distinguished by percentage
levels of arsenic and mercury.
rma/1551G
-------
Table 5.4-11 Summary of Soil Medium Groups and Subgroups
Page 4 of 4
Medium Groups Subgroup Description
South Plants South This subgroup consists of the main processing area within the South Plants.
Plants Contamination has resulted from manufacture, storage, and disposal of
Central chemicals and from the demilitarization of agent-filled ordnance. A wide
Processing range of COCs in the soil exceeding human health SEC and principal threat
Area criteria include volatiles, OCPs, and arsenic. The soil in this area
potentially contains agent.
South This subgroup consists of the drainage ditches within South Plants.
Plants Contamination has resulted from manufacture, storage, and disposal of
Ditches chemicals and from the demilitarization of agent-filled ordnance. COCs in
the soil exceeding human health SEC and principal threat criteria include
primarily OCPs. Also, contaminated soil in these ditches potentially poses
risk to biota.
South The remainder of the sites within South Plants were placed in this
Plants subgroup. Contamination at these sites has resulted from manufacture,
Balance of storage, and disposal of chemicals and from the demilitarization of agent-
Areas filled ordnance, and from windblown dispersion of contaminants from the
Central Processing Area. COCs in the soil exceeding the human health
SEC and principal threat criteria primarily consist of OCPs and ICP metals.
Most of the contaminated soil in the balance of South Plants potentially
poses risks to biota. This subgroup is also characterized by the potential
presence of high explosives-filled UXO and agent.
Buried Buried This subgroup consists of two sites that contain contaminated sediments
Sediments/ Sediments that were dredged from the adjacent lakes (Lake Ladora and Derby lakes),
Ditches deposited in unlined ditches at their current locations, and covered with
clean soil. COCs exceeding human health SEC include OCPs.
Sand This subgroup consists of the northern and southern segments of the Sand
Creek Creek Lateral that transported runoff from the South Plants Central
Lateral Processing Area during storm events and snowmelt, and of the drainage
ditches used to transport water to and from the Secondary Basins and to
drain the South Plants and North Plants process areas. COCs in the soil
exceeding Human Health SEC primarily consist of OCPs.
Undifferentiated Section 36 Sites within this subgroup are located in the southern area of Section 36.
Balance of They do not have unique site-type characteristics or contamination patterns.
Areas COCs in the soil exceeding human health SEC include OCPs and
chloroacetic acid. This subgroup is also characterized by the potential
presence of agent and agent-filled UXO.
Burial Sites within this subgroup consist of trenches that are located in Sections
Trenches 30 and 32 related to munitions testing and disposal. COCs in the soil
exceeding human health SEC include chromium and lead. The sites are
also characterized by the potential presence of HE-filled UXO.
ima/\55\G
-------
Table 5.4-12 Summary of Contaminant Concentrations Within the Soil
Exceedance Volumes
Page 1 of 8
Medium Group/
Subgroup
North Plants
Human Health
Biota
Toxic Storage Yards
Human Health
Biota
Lake Sediments
Human Health
Biota
Surficial Soil
Human Health
Biota
Contaminants
of Concern
Arsenic
Dieldrin
Endrin
Arsenic
Mercury
Chloroacetic
Acid
Arsenic
Arsenic
Mercury
Aldrin
Dieldrin
Chlordane
Aldrin
Dieldrin
Chlordane
DDE
DDT
Mercury
Arsenic
Aldrin
Dieldrin
Lead (firing
ranges)
Aldrin
Dieldrin
Endrin
Range of
Concentrations Within
Exceedance Volume1
(ppm)
312-10,000
0.01-2.9
0.003-0.09
2.8-260
0.05-2.9
80-134
270-^,000
BCRL-140
BCRL-30
BCRL-31
BCRL-3.4
BCRL-57
BCRL-2.7
BCRL-2.9
BCRL-9.3
BCRL-1.3
BCRL-3.0
BCRL-18
BCRL-16
0.048-390
0.001-560
Not Available
BCRL-3.0
BCRL-3.5
BCRL-13
Average
Concentration Within
Exceedance Volume'
(ppm)
2,800
0.13
0.01
41
0.32
115
1,600
3.6
0.15
11.8
0.7
1.8
0.060
0.069
0.056
0.018
0.35
0.43
0.69
17
27
Not Available
0.016
0.057
0.039
Exceedance
Depth
(ft)2
1
1
6
1
3
1
1
1
nnaU558G
-------
Table 5.4-12 Summary of Contaminant Concentrations Within the Soil
Exceedance Volumes
Page 2 of 8
Medium Group/
Subgroup
Ditches/Drainage
Area
Biota
Basin A
Human Health
Biota
Basin F Wastepile
Human Health3
Contaminants
of Concern
Aldrin
Dieldrin
Endrin
DDE
DDT
Arsenic
Mercury
Aldrin
Dieldrin
Endrin
Isodrin
Chlordane
Arsenic
Chromium
DDT
DDE
Mercury
Aldrin
Dieldrin
Endrin
Arsenic
Mercury
DDT
DDE
Aldrin
Dieldrin
Endrin
Isodrin
Chloroacetic
Acid
1,2-
Dichloroethane
DCPD
Range of
Concentrations Within
Exceedance Volume'
(ppm)
BCRL-0.094
BCRL-2.2
BCRL-2
BCRL-0.78
BCRL-0.32
BCRL-50
BCRL-1.9
BCRL-720
BCRL-2,600
BCRL-3,200
BCRL-160
BCRL-2,900
BCRL-28,000
BCRL-98
BCRL-105
BCRJL-21
BCRL-1 1,000
BCRL-1.9
BCRL-3.6
BCRL-3.0
BCRL-230
BCRL-54
BCRL-0.73
BCRL-0.71
0.1-3,100
0.1-700
92-900
3.16-3,000
110-760
3,4-110
1,500-2,000
Average
Concentration Within
Exceedance Volume1
(ppm)
0.005
0.27
0.053
0.027
0.01
6.6
0.16
42
150
110
9
100
350
13
3
1.4
140
0.04
0.53
0.10
25
0.67
0.01
0.01
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Exceedance
Depth
(ft)2
1
8
1
NA
nna\1558G
-------
Table 5.4-12 Summary of Contaminant Concentrations Within the Soil
Exceedance Volumes
Page 3 of 8
Medium Group/
Subgroup
Former Basin F
Human Health
Secondary Basins
Human Health
Biota
Chemical Sewers
Human Health
Contaminants
of Concern
Aldrin
Dieldrin
Endrin
Isodrin
Chloroacetic
Acid
DCPD
Aldrin
Dieldrin
Chlordane
Endrin
Chromium4
Arsenic
Mercury
Aldrin
Dieldrin
Endrin
DDE
Arsenic
Mercury
Aldrin
Dieldrin
Isodrin
DDT
Chloroacetic
Acid
DBCP
HCCPD
Carbon
Tetrachloride
Chloroform
Arsenic
Range of
Concentrations Within
Exceedance Volume1
(ppm)
BCRL-2,900
BCRL-1,100
BCRL-710
BCRL-10,000
BCRL-7,000
BCRL-20,000
BCRL-180
BCRL-120
BCRL-3.0
BCRL-8.4
BCRL-120
BCRL-140
BCRL-1.6
BCRL-2.7
BCRL-3.4
BCRL-0.57
BCRL-1.0
BCRL-56
BCRL-0.23
BCRL-20,000
BCRL-200
BCRL-1,000
BCRL-500
BCRL-230
BCRL-32,000
BCRL-4,000
BCRL-200
BCRL-400
BCRL-740
Average
Concentration Within
Exceedance Volume1
(ppm)
260
130
47
360
960
670
21.6
28.2
0.68
2.1
—
9.8
0.17
0.08
0.69
0.07
0.006
10
0.086
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Exceedance
Depth
(ft)2
10
1
1
10
rma\1558G
-------
Table 5.4-12 Summary of Contaminant Concentrations Within the Soil
Exceedance Volumes
Page 4 of 8
Medium Group/ Contaminants
Subgroup of Concern
Complex Trenches5
Human Health Aldrin
Isodrin
Chlordane
DBCP
Chromium
Lead
Mercury
Arsenic
Biota Aldrin
Dieldrin
Endrin
DDE
DDT
Arsenic
Mercury
Shell Trenches'
Human Health Aldrin
Dieldrin
Endrin
Isodrin
Chlordane
DBCP
HCCPD
Hex Pit5
Human Health Aldrin
Dieldrin
Endrin
Isodrin
Chlordane
HCCPD
Range of
Concentrations Within
Exceedance Volume1
(ppm)
BCRL-40
BCRL-27
BCRL-150
BCRL-6.7
BCRL-5,200
BCRL-10,000
BCRL-860
BCRL-4,500
BCRL-0.19
BCRL-3
BCRL-4.7
BCRL-2.9
BCRL-0.18
BCRL-98
BCRL-70
BCRL-1,000
BCRL-500
BCRL-^00
BCRL-1,000
BCRL-70
BCRL-700
BCRL-40,000
BCRL-1,000
BCRL-500
BCRL-^00
BCRL-1,000
BCRL-70
BCRL-10,000
Average
Concentration Within
Exceedance Volume1
(ppm)
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Exceedance
Depth
(ft)2
14
1
10
10
rma\1558G
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Table 5.4-12 Summary of Contaminant Concentrations Within the Soil
Exceedance Volumes
Page 5 of 8
Medium Group/
Subgroup
Sanitary Landfills
Human Health
Biota
Section 36 Lime
Basins
Human Health
Buried M-l Pits
Human Health
Contaminants
of Concern
Aldrin
Dieldrin
Endrin
Isodrin
Chlordane
DDT
Chromium
Lead
Cadmium
Aldrin
Dieldrin
DDE
DDT
Endrin
Arsenic
Mercury
Aldrin
Dieldrin
Endrin
Isodrin
Chlordane
DDE
DDT
Arsenic
Mercury
Aldrin
Dieldrin
Isodrin
HCCPD
DCPD
Cadmium
Arsenic
Mercury
Range of
Concentrations Within
Exceedance Volume1
(ppm)
BCRL-420
BCRL-300
BCRL-38
BCRL-27
BCRL-3.1
BCRL-61
BCRL-1,800
BCRL-8,600
BCRL-1,100
BCRL-3.2
BCRL-2.6
BCRL-5.6
BCRL-61
BCRL-20
BCRL-120
BCRL-3.5
BCRL-1,700
BCRL-780
BCRL-400
BCRL-400
BCRL-240
BCRL-13
BCRL-2.6
BCRL-900
BCRL-56
BCRL-27
BCRL-36
BCRL-7.1
BCRL-1,300
BCRL-7,800
BCRL-2,400
27-100,000
1.3-83,000
Average
Concentration Within Exceedance
Exceedance Volume1 Depth
(ppm) (ft)2
2.5 12
3.0
0.31
0.16
0.02
0.44
18
65
5.8
0.09 1
0.17
0.19
1.3
0.39
5.5
0.11
190 10
90
41
48
25
1.9
0.06
100
5.4
0.55 10
0.82
0.099
44
195
320
17,000
4,300
rma\155BG
-------
Table 5.4-12 Summary of Contaminant Concentrations Within the Soil
Exceedance Volumes
Page 6 of 8
Medium Group/
Subgroup
South Plants Central
Human Health
Biota
South Plants Ditches
Human Health
Biota
Contaminants
of Concern
Processing Area
Aldrin
Dieldrin
Endrin
Isodrin
Chlordane
Chloroacetic
Acid
DDT
HCCPD
DBCP
Carbon
Tetrachloride
Chloroform
DCPD
Arsenic
Cadmium
Chromium
Lead
Mercury
Aldrin
Dieldrin
Endrin
DDE
DDT
Arsenic
Mercury
Aldrin
Dieldrin
Isodrin
Chlordane
Chromium
Endrin
DDE
DDT
Arsenic
Mercury
Aldrin
Dieldrin
Endrin
DDE
DDT
Mercury
Range of
Concentrations Within
Exceedance Volume1
(ppm)
BCRL-1 5,000
BCRL-6,300
BCRL-3,700
BCRL-300
BCRL-1 ,500
BCRL-350
BCRL-300
BCRL-5,300
BCRL-14,000
BCRL-140
BCRL-40,000
BCRL-970
BCRL-14,000
BCRL-540
BCRL-280
BCRL-7,100
BCRL-1 7,000
BCRL-3.4
BCRL-3.4
BCRL-1 .2
BCRL-1 .6
BCRL-8.6
BCRL-289
BCRL-56
0.60-4,400
0.71-805
BCRL-23
BCRL-6.3
BCRL-62
BCRL-3.4
BCRL-2.1
BCRL-1 0
BCRL-^.l
BCRL-15
BCRL-2.3
BCRL-2.7
BCRL-0.31
BCRL-3.2
BCRL-0.81
BCRL-2.5
Average
Concentration Within Exceedance
Exceedance Volume' Depth
(ppm) (ft)2
580 10
210
67
19
15
13
7.5
28
275
1.9
580
6.7
230
5.1
20
310
300
0.19 1
0.73
0.029
0.023
0.03
11
2.04
270 5
58
2.3
0.4
12
0.17
0.20
0.4
0.42
0.30
0.11 1
0.69
0.038
0.12
0.047
0.10
nna\1558G
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Table 5.4-12 Summary of Contaminant Concentrations Within the Soil
Exceedance Volumes
Page 7 of 8
Medium Group/
Subgroup
South Plants Balance
Human Health
Biota
Buried Sediments
Human Health
Sand Creek Lateral
Human Health
Biota
Contaminants
of Concern
of Areas
Aldrin
Dieldrin
Endrin
Isodrin
Chlordane
DDE
DDT
HCCPD
Chromium
Lead
Mercury
Aldrin
Dieldrin
Endrin
DDE
DDT
Arsenic
Mercury
Dieldrin
Chlordane
Aldrin
Dieldrin
Isodrin
Chlordane
Chloroacetic
Acid
Chromium
Lead
DDE
DDT
Aldrin
Dieldrin
Endrin
DDE
DDT
Arsenic
Mercury
Range of
Concentrations Within
Exceedance Volume'
(ppm)
BCRL-6,900
0.67-1,500
BCRL-46
BCRL-390
BCRL-370
BCRL-9.7
BCRL-140
BCRL-2,000
BCRL-2,200
BCRL-4,900
BCRL-8,600
BCRL-3.5
BCRL-3.6
BCRL-1.17
BCRL-1.02
BCRL-1.7
BCRL-180
BCRL-41
26.1-53
BCRL-8.9
BCRL-400
BCRL-140
BCRL-4.0
BCRL-9.7
230
BRCL-490
BCRL-2,000
BCRL-4.7
BCRL-6.0
BCRL-3.7
BCRL-3.6
BCRL-3.8
BCRL-4.7
BCRL-6.0
BCRL-190
BCRL-2.3
Average
Concentration Within Exceedance
Exceedance Volume' Depth
(ppm) (ft)2
14 10
33
1.6
18
4.2
0.53
1.4
23
62
340
500
0.037 1
0.32
0.011
0.006
0.15
0.73
0.065
40 10
0.8
27.8 2
18.5
0.24
0.42
Not Applicable
180
800
0.04
1.0
0.30 1
0.44
0.087
0.095
0.10
5.8
0.13
nna\1558G
-------
Table 5.4-12 .Summary of Contaminant Concentrations Within the Soil
Exceedance Volumes
Page 8 of 8
Medium Group/ Contaminants
Subgroup of Concern
Section 36 Balance of Areas
Human Health Aldrin
Dieldrin
Endrin
Isodrin
Chlordane
Chloroacetic
Acid
DDE
DDT
Arsenic
Mercury
Biota Aldrin
Dieldrin
Endrin
Chlordane
DDE
DDT
Arsenic
Mercury
Burial Trenches
Human Health Chromium
Lead
Range of
Concentrations Within
Exceedance Volume1
(ppm)
BCRL-120
BCRL-140
BCRL-46
BCRL-37
BCRL-140
BCRL-320
BCRL-1.8
BCRL-23
BCRL-16
BCRL-50
BCRL-2.2
BCRL-3.5
BCRL-3.1
BCRL-11
BCRL-1.6
BCRL-8.6
BCRU-39
BCRL-56
BCRL-39
BCRL-3,400
Average
Concentration Within
Exceedance Volume1
(ppm)
11
24
5.3
1.6
2.2
52
0.10
0.20
2.4
0.46
0.061
0.010
0.12
0.84
0.010
0.028
3.85
0.5
20
190
Exceedance
Depth
(ft)2
10
1
10
Concentrations listed are based on the samples present within the respective exceedance volumes only. For modeled sites,
the range and average represent estimated contaminant concentrations for the modeled exceedance volume. See Section 7.1.4
for more discussion on soil contaminant modeling.
Human health exceedance depths represent the maximum depth of any detected human health exceedances.
Concentrations inferred from remedial investigations sampling at Former Basin F prior to interim response action.
Present above human health SEC in one sample in NCSA-4a.
Concentrations for these sites represent samples taken throughout the site. Limited information is available for soil
concentrations within the disposal trenches proper.
rma\1558G
-------
6.0 Summary of Site Risks
6.0 Summary of Site Risks
A risk assessment is a scientific procedure used to estimate the potential adverse effects on human health and
the environment from exposure to chemicals. At a CERCLA site, a baseline risk assessment is prepared and
serves as the basis for evaluating risks posed from contamination if no remedial actions are taken. The
resulting level of risk is called the baseline risk, i.e., an estimate of risk that might exist if no remediation or
institutional controls were applied at a site. At RMA, a risk assessment called the Integrated Endangennent
Assessment/Risk Characterization (IEA/RC) was performed and used as the baseline risk assessment. In this
instance, the IEA/RC defined baseline to include the completion of the soil-related IRAs (e.g., Basin F, Lime
Basins) and enforcement of the FFA's use restrictions. The FT A prohibits residential development; potable use
of groundwater and surface water; agricultural activities for the purpose of raising livestock, crops, or
vegetables; and the consumption offish and game taken from RMA. Therefore, these uses were not considered
during the IEA/RC. The relevant IRAs (Table 2.4-1) were implemented in accordance with the FFA to
prioritize the selection of some of the more highly contaminated sites for remedial action and reduce or
eliminate the risk for exposure to contaminated soil prior to the selection of the final remedial action. The risk
assessment methodology used during the IEA/RC was initiated prior to the publication of EPA risk assessment
guidance (OERR-EPA 1989). However, this methodology does incorporate the exposure assumptions and
toxicity assessment methods specified in EPA guidance and fulfills EPA's requirement of estimating risk based
on a reasonable maximum exposure (RME).
The IEA/RC was the result of a progressive series of endangerment assessment analyses initiated by the Biota
RI (ESE 1989), the Human Health Exposure Assessment (HHEA), and the HHEA Addendum. These initial
evaluations served as screening assessments for the protection of human health and preliminary estimations of
biota risk, and provided the basic building blocks of the IEA/RC report, which is divided into two evaluations,
the Human Health Risk Characterization (HHRC) and the Ecological Risk Characterization (ERC). Both of
these evaluations are summarized in the final report.
The general methodology of the risk assessment process involves the following steps: identify the COCs,
perform the exposure and toxicity assessments, and perform the risk characterization. The more than 50,000
groundwater, surface water, sediment, soil, air, and biota samples collected during the past decade were used to
evaluate which chemicals were of concern to human health and the environment and to develop the risk
assessment.
*
6.1 Human Health Risk Characterization
Soil at RMA is the primary medium by which humans can be exposed to contamination on post, due to land-use
restrictions and/or limitations on the uses of other environmental media specified in the FFA and the Rocky
FOSTER © WHEELER
nna\1490G.DOC FOSTER WHEELER ENVIRONMENTAL CORPORATION 6-\
-------
Record of Decision for the On-Post Operable Unit
Mountain Arsenal National Wildlife Refuge Act of 1992. Remedial measures for on-post groundwater will
augment the soil remedy and facilitate long-term remediation of groundwater. Risk-based criteria for groundwater
established by the ROD for the Off-Post Operable Unit are used for the on-post boundary treatment systems.
The objectives of the HHRC were to develop risk-based soil criteria protective of people who might visit or
work at RMA, evaluate the uncertainty associated with these criteria, characterize the potential risks to these
people, and evaluate where these risks exist at RMA to guide the remedial decisions. Two types of health
effects were evaluated, potential cancer (carcinogenic) risks and potential health effects other than cancer. The
context for interpreting cancer risk estimates is provided by EPA in CERCLA regulations and guidance:
Acceptable exposure levels for a carcinogenic compound are those levels that result in an increased cancer risk
between 1 in 10,000 (or 1 x 10"4) and 1 in 1,000,000 (or 1 x 10*). These estimated carcinogenic risks are
usually termed "excess lifetime cancer risks," which means there is an increased chance of an individual
developing cancer over 30 years of exposure over a 70-year life span to the carcinogenic chemicals in "excess"
of the normal cancer rate. (The normal cancer rate determined by the American Cancer Society is about one in
three persons.)
Noncancer (noncarcinogenic) risk estimates are expressed in terms of a hazard index (HI) for chronic,
subchronic, and acute exposure durations. A concern for adverse health effects may occur when an HI value,
the sum of chemical-specific hazard quotients (HQs), exceeds 1.0. However, the value of any given HI does
not provide an estimate of the probability of any adverse effects that may occur (unlike a cancer risk estimate).
An HI of 1.0 represents the highest level of chronic exposure that is unlikely to result in adverse effects. For
values of HI greater than 1.0, the potential for adverse effects to occur increases as the HI value increases.
6.1.1 Identification of Contaminants of Concern
Contaminants in the RI and Endangerment Assessment programs were selected as target analytes if they
satisfied all of the following criteria:
• Quantities handled or disposed at RMA
• Acute toxicity and carcinogenic potential
• Persistence in the environment
• Identification as a breakdown product from Army surety agents
• The presence of the chemical in other monitoring or investigatory programs ongoing at RMA
A total of 64 contaminants were identified as target analytes from a list of more than 650 chemical constituents.
These target contaminants were subsequently evaluated in the HHEA report. The HHEA served as a basis for
identifying COCs that would become the focus of a more detailed evaluation of risk during the IEA/RC.
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Based on the evaluation conducted during the HHEA, 27 soil COCs were ultimately selected for evaluation in
the HHRC (Table 6.1-1). These chemicals, which are expected to contribute the majority of projected risks at
RMA, were identified based on pre-established selection criteria as follows:
1. Include all COCs designated as Category A (Exposure Index > 10) in the HHEA.
2. Include all COCs with carcinogenic weight of evidence classifications designations A or B.
3. Include all COCs with carcinogenic weight of evidence classification designation C and potency
factors.
4. Consider treatability to exclude chemicals from the COC list.
5. Consider isolated detections to exclude chemicals.
6. Include all COCs listed on the Land Ban Disposal Restriction List.
7. Include all COCs with RCRA soil criteria.
8. Consider the state's request to include DIMP and isopropylmethyl phosphonate (IMPA). (DIMP and
IMP A are predominantly groundwater contaminants and were therefore not included on the final COC
list.)
9. Group by chemical class to reduce COCs.
10. Consider frequency of detection.
11. Consider essential nutrients.
12. Consider concentration and toxicity.
13. Consider historical information.
14. Consider special exposure routes.
15. Consider Army agent degradation products.
16. Consider co-occurrence with other COCs to exclude chemicals.
17. Consider bioconcentration, mobility, and persistence.
IS. Consider detections in laboratory blanks in comparison to concentrations detected on site.
(Fluoroacetic acid, which was considered a COC in drafts of the IEA/RC report, was removed as a
COC in this analysis because on-post detections of this chemical were similar in concentration to
detections in laboratory blanks.)
6.1.2 Exposure Assessment
The objective of the human health exposure assessment is to estimate the type and magnitude of exposure to
COCs by human populations through the characterization of the exposure setting (i.e., potential land uses) and
current and future potentially exposed populations, identification of exposure pathways, and estimation of the
exposure point concentrations.
6.1.2.1 Characterization of Exposure Setting and Potentially Exposed Populations
The identification of potentially exposed populations at RMA required consideration of potential site land uses.
The FFA indicates the Parties' goal that significant portions of RMA will be available for open space for public
benefit, including, but not limited to, wildlife habitat(s) and park(s). By the enactment of the Rocky Mountain
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Arsenal National Wildlife Refuge Act of 1992, future land-use options will involve an open space scenario
dominated by the formation of a nature preserve and wildlife refuge that includes parks and recreational areas.
Given the land-use projections identified above, two land-use options were identified that formed the basis for
defining target receptor populations: open space, which includes nature preserve, wildlife refuge, and recreational
park scenarios, and economic development, which includes commercial and industrial scenarios. Following
passage of the Rocky Mountain Arsenal National Wildlife Refuge Act, economic development would only apply
in limited areas along the western boundary of RMA. Based on the open space land-use projection, three receptor
populations were evaluated in the HHRC, biological workers, regulated/casual visitors, and recreational visitors.
Based on the economic development land-use projection, two worker populations, industrial and commercial
workers, were selected for evaluation. Figure 6.1-1 is a diagram showing the land-use scenarios and the potentially
exposed populations associated with them. For both open space and economic development land-use options, risks
were calculated assuming that exposure would occur at a given site or, in the case of the boring-by-boring analysis,
at an individual soil boring.
6.1.2.2 Identification of Exposure Pathways
An exposure pathway describes the course a chemical or physical agent takes from the contaminant source to
the exposed receptor. A complete exposure pathway includes a source area, a means of transport in the
environment, an exposure point, and a receptor. At RMA, direct and indirect exposure pathways were
evaluated. The direct pathways included ingesting contaminated soil (ingestion), coming into contact with
contaminated soil (dermal absorption), or breathing contaminated dust particles (inhalation). The indirect
pathways included inhalation of contaminated vapors in open areas (e.g., during work performed outdoors) and
enclosed spaces (e.g., in basements). Dermal contact with metals in soil was not evaluated for any receptor
population due to negligible contaminant absorption through this exposure pathway.
The five potentially exposed populations/subpopulations and their respective current and future exposure
pathways included the following:
• Biological Worker, e.g., a wildlife biologist working on the refuge - All direct pathways and open
space vapor inhalation
• Regulated/Casual Visitor, e.g., someone (adult or child) visiting the wildlife refuge - All direct
pathways and open space vapor inhalation
• Recreational Visitor, e.g., someone (adult or child) jogging or playing on areas of the wildlife refuge -
All direct pathways and open space vapor inhalation
• Commercial Worker, e.g., a person working inside a building on the wildlife refuge - All direct
pathway and enclosed space vapor inhalation
• Industrial Worker, e.g., a person working outside and potentially exposed to soil - All direct and
indirect pathways
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Figure 6.1-2 depicts the potential exposure pathways for each human receptor population and Table 6.1-2 lists
the soil horizons (soil depth interval) for each exposure pathway evaluated.
6.1.2.3 Estimation of Exposure Point Concentrations
The chemical concentration to which an individual could be exposed is known as the exposure point
concentration. To characterize potential chronic (long-term risk, i.e., 7 to 70 years) human health risks at
RMA, both location-specific (i.e., 178 discrete sites on RMA) and sample-specific (boring-by-boring) risks
were quantified. The complete data set used for the estimation of these exposure point concentrations was
issued on computer diskettes and distributed with the IEA/RC report.
Human health risks were estimated for the location-specific analysis using representative contaminant
concentrations calculated for each of the 178 sites evaluated in the HHRC. The concentration term used to
estimate exposure was calculated by several different methods to give a range of potential risks. A mean
exposure concentration term (C^,mat) was calculated as the simple arithmetic mean of the samples as
representative of a potential average exposure for each of the 178 locations. (This method is no longer
recommended by EPA.) The 95 percent upper confidence limit (95% UCL) on the site sample arithmetic mean
(Crupper)was calculated to establish the RME risks. The 95% UCL was calculated in accordance with EPA
guidance (OSWER-EPA 1992) and this represents EPA's preferred method to calculate concentration terms.
For the location-specific analysis, concentrations based on composited samples (i.e., samples collected from
borings from the 0-ft to 1-ft interval mixed with samples from a deeper interval). These concentrations were
estimated by doubling the concentration detected in the 0-ft to 1-ft interval, using the conservative assumption
of 50 percent dilution by clean soil collected from the deeper samples. Concentrations reported for samples that
were not composited (i.e., samples collected from the 0-ft to 1-ft interval and analyzed without the addition of
deeper soil) were not doubled because these concentrations were not potentially diluted by deeper, clean soil.
For the boring-by-boring analysis, potential risks were evaluated using the maximum contaminant
concentration (Cmix) at a given boring for a specific depth interval or at a given surficial soil sample location.
Surficial soil sample results were included in the boring-by-boring analysis to supplement results from the
deeper sample intervals. The objective of the surficial soil sampling program was to identify any contamination
that may have occurred as a result of windblown contamination from source areas using composited samples
from randomly selected sample locations at the 0-inch to 2-inch depth interval. Because the samples were
composited from within this one interval, the effects of dilution caused by mixing soil from deeper intervals
was avoided. The inclusion of these results in the boring-by-boring analysis are intended to offer insight into
the variability of contamination at RMA and facilitate the identification of contaminant hot spots. The use of
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analytical results from composited samples may have reduced the overall conservatism of the boring-by-boring
analysis, which assumes that cumulative chronic exposures would occur at any individual boring location and at
the specific depths where the maximum concentration occurred. However, the surficial soil results do
supplement the subsurface boring evaluation, and may be more relevant to the evaluation of direct contact
exposure risks for some receptors (e.g., visitor populations) than corresponding results for deeper soil intervals.
6.1.2.4 Exposure Parameters
Exposure parameters are combined with chemical-specific exposure point concentrations and toxicity data to
characterize each of the five potential routes of human exposure to COCs at RMA. Some exposure parameters,
such as body weight and frequency of exposure, are applicable to all exposure pathways. Other parameters,
however, such as soil ingestion rate and molecular difrusivity, are used only for specific exposure routes. The
probabilistic analysis developed for the IEA/RC assumes chronic exposures (greater than 7 years). However,
potential risks associated with shorter-term exposures (i.e., acute exposures occurring on a single day or
subchronic exposures lasting more than 1 day but less than 7 years) were calculated during the HHEA using
deterministic methods (i.e., using fixed exposure parameters).
The exposure parameters used in mis evaluation are fixed or probabilistic (Tables 6.1-3 through 6.1-5).
Probabilistic parameters are characterized by a distribution of values, while the fixed parameters are represented
by a single value. Probability distributions and the fixed numerical estimates are defined based on an extensive
literature search and data review. A detailed description of the individual exposure parameters and the
development of their specific distributions is contained in Appendix B of the IEA/RC report. The deterministic
exposure parameters used for the development of the acute and subchronic preliminary pollutant limit values
(PPLVs) are presented in Tables 6.1-6 and 6.1-7, respectively. A detailed description of these parameters is
provided in the HHEA Addendum report.
6.1.3 Toxicity Assessment
The objective of the toxicity assessment is to derive toxicological criteria that can be used in the calculation of
potential risk from exposure to COCs in terms of carcinogenic and noncarcinogenic effects.
Carcinogenic effects result, or are suspected to result, in the development of different types of cancer. EPA
assumes a nonthreshold mechanism for carcinogens; accordingly, any amount of exposure to a carcinogenic
chemical is assumed to have a potential for producing a carcinogenic response in the exposed individual. EPA
has a carcinogenic-classification system that uses weight of evidence to classify the likelihood that a chemical is
a human carcinogen. The classifications are as follows:
A Human Carcinogen
Bl Probable human carcinogen; limited human data are available
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B2 Probably human carcinogen; sufficient evidence in animals and inadequate or no evidence in humans
C Possible human carcinogen
D Not classified as to human carcinogen
E Evidence of noncarcinogenicity for humans
Carcinogenic toxicity values used in the HHRC were developed by the EPA Cancer Assessment Group and
obtained from EPA-derived sources that include the Integrated Risk Information System database and the
Health Effects Summary Table. These values are based on cancer slope factors. Slope factors are chemical-
specific, experimentally derived potency values that are used to calculate the risk of cancer resulting from
exposure to carcinogenic chemicals. A higher value implies a more potent carcinogen. Slope factors and
carcinogenic doses based on a 1 x 10"* excess cancer risk for the COCs are summarized in Table 6.1-8 for both
oral and inhalation routes.
Noncarcinogenic effects, or any health impact other than cancer, may result from short-term (i.e., acute and
subchronic), or long-term (chronic) exposures. For most noncarcinogenic effects, protective mechanisms
within an individual are assumed to exist that must be overcome before there is an adverse effect. The level
above which effects may occur is called a threshold level. In developing dose-response values for
noncarcinogenic effects, i.e., the reference dose (RfD), EPA's goal is to identify the highest no observed
adverse effect level (NOAEL), the upper bound of the tolerance range (generally regarded as safe), or the
lowest observed adverse effect level (LOAEL) from well-designed human or animal studies. In general, the
RfD is an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily exposure to the human
population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects
during a lifetime. To account for uncertainty associated with the toxicity studies, uncertainty factors (UFs) are
incorporated to adjust this level. The RfDs for COCs at RMA are summarized in Table 6.1-9 for both the oral
and inhalation exposure routes for chronic exposures. (Acute and subchronic exposures from RMA media were
evaluated in the HHEA Addendum report.)
The chronic reference doses listed in Table 6.1-9 pertain to lifetime or other long-term exposures (i.e., 7 years
to lifetime). However, for noncarcinogenic chemicals, chronic exposure is not a prerequisite for toxicity to be
manifested; even a single exposure or shorter-duration exposure may be sufficient to produce adverse effects.
More recently, EPA has begun developing acute and subchronic reference doses, which are useful for
characterizing potential noncarcinogenic effects associated with shorter-term exposures (i.e., acute and
subchronic). Acute and subchronic reference doses are used to evaluate the potential noncarcinogenic effects
of exposure periods lasting 1 day or more than 1 day but less than 7 years.
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Development of acute and subchronic reference doses parallels the development of chronic reference doses; the
distinction is one of exposure duration. If acute or subchronic data are not available and a chronic RfD derived
from chronic data exists, the chronic RfD is adopted as the acute or subchronic RfD. There is no application of
an uncertainty factor to account for differences in exposure duration in this instance. The critical toxicity
factors (Dr values) used for the acute and subchronic PPLVs are listed in Table 6.1-10.
Toxicity profiles for each of the COCs were published in the HHEA. Toxicity profiles for each RMA target
contaminant were generated from current toxicological literature and include considerations of dose, routes of
exposure, types of adverse effects manifested, transport, and fate and a quantitative evaluation of a DT value.
Each profile is composed of seven sections that address the following elements:
• Summary
• Chemical and physical properties
• Transport and fate
• Health effects
• Toxicity to wildlife and domestic animals
• Regulations and standards
• DT value
The toxicity factors contained in the toxicity profiles were revised if current values contained in the Integrated
Risk Information System or the Health Effects Summary Table differed from those contained in the HHEA
toxicity profile. Tables 6.1-8 and 6.1-9 list the toxicity factors used in the IEA/RC.
6.1.4 Risk Characterization
PPLVs, which are risk-based concentrations of chemicals in soil that are considered protective of human health
given a defined set of exposure and toxicity assumptions, were used to estimate risks to human health. For
noncarcinogens, PPLVs are defined as soil concentrations unlikely to pose adverse health effects. For
carcinogens, PPLVs are defined as soil concentrations protective of human health at a specified cancer risk
level. PPLVs are a function of media intake rates, exposure frequencies and durations, partition coefficients,
physiological parameters (e.g., breathing rates, body rates, skin surface areas), pharmacokinetic parameters
(e.g., contaminant absorption fractions), and toxicity data.
6.1.4.1 Calculation of PPLVs
Probabilistic PPLVs were computed for each of the five potentially exposed populations via the direct and
indirect exposure pathways. In addition, because exposure to contaminants may occur from a number of
exposure routes, cumulative direct and indirect PPLVs were also calculated over all the single pathways.
Acute/subchronic deterministic and chronic probabilistic approaches differ in their use of exposure
assumptions. The exposure parameters used in the estimation of probabilistic PPLVs are characterized by a
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distribution of values or ranges of exposures potentially occurring within the population. It is assumed that
some individuals have a high level of exposure and others have a lower level. The exposure parameters used in
the estimation of deterministic PPLVs (i.e., nonprobabilistic) are the fixed numerical estimates that correspond
to a reasonable maximally exposed individual (RME). EPA defines the RME as the highest exposure mat is
reasonably expected to occur at a site and in practice is estimated by combining upper bound fixed values for
some but not all exposure parameters.
During the HHRC, both 5th and 50th percentile cumulative direct PPLVs (Tables 6.1-11 and 6.1-12, respectively)
were calculated for each of the five receptor populations. The 5th percentile defines the RME PPLV (i.e., there is
95 percent confidence that the PPLV will be protective at the specified risk level), and the 50th percentile
represents the median PPLV estimate (i.e., there is 50 percent confidence that the PPLV will not exceed the
specified risk level). The remediation decisions are based on the 5th percentile PPLV, which corresponds to a
reasonable maximum exposure (and risk) evaluation. The lowest (more protective) cumulative direct PPLVs were
generally derived for the biological worker. The only exceptions are related to the PPLVs calculated for certain
volatile organic compounds (i.e., benzene, carbon tetrachloride, chloroacetic acid, chlorobenzene, and toluene); for
these compounds, the lowest PPLVs were derived for the industrial worker.
The single-pathway PPLVs used to derive the cumulative PPLVs are summarized in Tables 6.1-13 through 6.1-17.
As shown in these tables, the majority of the cumulative direct PPLVs were derived based on a carcinogenic
endpoint. The dermal absorption pathway accounts for the majority of the cumulative risk for most of the organic
COCs. The only exceptions are aldrin, dieldrin, DDE, endrin, isodrin, chlordane, DDT, and DCPD, for which soil
ingestion is the driver exposure pathway, and DCPD and HCCPD, for which soil particulate inhalation is the driver
exposure pathway for some populations/subpopulations.
For aldrin, soil ingestion is the driver exposure pathway for the biological worker, recreational visitor,
regulated/casual visitor, and commercial worker subpopulations. For dieldrin, soil ingestion is the driver
exposure pathway for the biological worker, regulated/casual visitor, and commercial worker subpopulations.
For DDE, endrin, and isodrin, soil ingestion is the driver exposure pathway for the biological worker and
commercial worker subpopulations. For chlordane, DDT, and DCPD, soil ingestion is the driver exposure
pathway for the commercial worker subpopulation.
For DCPD, inhalation is the driver exposure pathway for all populations/subpopulations except the commercial
worker, for which ingestion is the driver exposure pathway. For HCCPD, inhalation is the driver exposure
pathway for all populations except the recreational visitor, for which dermal exposure is the driver exposure
pathway.
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Soil ingestion and paniculate inhalation are the driver pathways for metals. (As explained in Section 6.1.2.2,
dermal absorption was not quantified for metals.) Soil ingestion represents the driver pathway for arsenic, lead,
and mercury, and paniculate inhalation represents the driver pathway for cadmium and chromium.
6.1.4.2 Determination of Carcinogenic and Noncarcinogenic Risks
Once PPLVs were calculated, they were combined with exposure point concentrations to calculate excess lifetime
carcinogenic risks and noncarcinogenic His. As noted in Section 6.1, these excess lifetime cancer risks are
probabilities that are generally expressed in scientific notation (e.g., 1 x 10*). An excess lifetime cancer risk of
1 x 1CT* indicates that, as a plausible upper bound, an individual has a 1 in 1 million chance of developing cancer as
a result of site-related exposure to a carcinogen over 30 years of exposure over a 70-year life span under the
specific exposure conditions at a she.
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is expressed as the HQ
(or the ratio of the estimated intake derived from the contaminant concentration in a given medium to the
contaminant's RfD). By adding the HQs for all contaminants within a medium or across all media to which a
given population may reasonably be exposed, the HI can be generated. The HI provides a useful reference point
for gauging the potential significance of multiple contaminant exposures within a single medium or across media.
For carcinogens, cumulative risks (representing all exposure pathways and COCs) were compared to an acceptable
risk range that is no greater than 1 x 10"* to 1 x Iff4. For carcinogens causing health effects in addition to cancer
and for noncarcinogens, potential adverse health effects were identified where HI values exceeded 1.0, below
which is considered the safe, or benchmark, level. As stated by EPA (OSWER-EPA 1991b), where the cumulative
site risk to an individual based on the RME for both current and future land-use scenarios is less than 1 x 10"4, and
the HQ is less than 1.0, action generally is not warranted; however, when risk reduction is warranted, the
remediation goals should be towards 1 x 10"* risk-based concentrations.
Location-Specific Risks and His
RME risks were calculated for each of the 178 sites using Cnpiafpa concentrations and PPLVs. During the
HHRC, site risks were calculated for Horizon 0 (0-ft to 1-ft depth interval), Horizon 1 (0-ft to 10-ft depth
interval), and Horizon 2 (> 10 ft to groundwater). Because Horizon 0 results were not graphically displayed in
the IEA/RC report, this section mainly focuses on the results for that horizon. More information on site risks
for Horizons 1 and 2, as well as results for surficial soil (0 inches to 2 inches), can be found in the IEA/RC
report.
PPLVs were derived for each of the five potentially exposed populations/subpopulations evaluated in the risk
characterization. Table 6.1-18 lists the number of site C^,tVpfa values exceeding the corresponding PPLV for
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Horizon 0. As shown in this table, only five carcinogenic contaminants have C^^^., estimates exceeding a 1 x
10"* cancer risk PPLV: aldrin, chlordane, dieldrin, arsenic, and DBCP. For noncarcinogens, only chloroacetic
acid, endrin, isodrin, and chromium have 0^,,^ values exceeding the corresponding PPLV (assuming an HI of
1.0 as the target criterion).
The results of the HHRC indicate that site-specific cancer risks and His were highest in Horizons 0 and 1 for the
biological worker (open space option) and industrial worker (economic development land-use option). Given these
findings, and the fact mat the biological worker exposure setting is most reflective of anticipated future land uses at
RMA, the following summary is based on results obtained for the biological worker. These results indicate mat
potential cancer risks are highest in the following areas, which are generally located in the central portions of
RMA:
• Chemical Sewers (site SP10)
• Lime Basins, including sites SP1E (Buried M-l Pits) and NC1B (Section 36 Lime Basins)
• South Plants, with sites SP3A (ditch), SP1A (Central Processing Area), and SP3B (concrete salt storage
pad) exhibiting the highest risks
• Former Basin F (site NC3)
• Sanitary/Process Water Sewers (site NCSA)
• Basin A (site NCI A)
• Shell Trenches (site CIA)
The generalized locations of these sites are depicted on Figure 6.1-3. Exceedances of 1 x 10"4 cancer risk levels are
limited to the sites listed above (the Basin F Wastepile was not evaluated separately, but would fall into this
category) (Figure 6.1-4). The results for noncarcinogenic endpoints (His) exhibit similar trends; however, more
sites exceed an HI of 1.0 than those identified above (e.g., one sanitary landfill and additional sites in South Plants
[Figure 6.1-5]).
Summary of Principal Chemical Risk Drivers
Figures 6.1-6 and 6.1 -7 summarize cancer risks and His associated with the C^ ^^ concentrations for Horizon 0.
As shown in these figures, the number of exceedances shown for the biological worker at Horizon 0 is larger than
for any of the other populations; however, the cumulative direct PPLVs (summarized in Table 6.1-11) are
generally lower (and are thus drivers) for the biological worker. As indicated in Section 3 of the JEAJRC report,
Horizon 1 Qq, concentrations show slightly higher cancer risks and His than for Horizon 0, probably because the
indirect soil vapor inhalation pathways were not evaluated for shallow depth intervals. As is also indicated in the
IEA/RC report, Horizon 2 C^ concentrations revealed far lower cancer risks and His (relative to results for
Horizons 0 and 1). No site exceedances of a 10"4 cancer risk level were identified for either the biological or
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industrial workers. Only 2.2 percent (four sites) of Horizon 2 site cancer risks calculated for the industrial worker
exceed 10"*; similar trends are exhibited for HI endpoints.
For cancer risk endpoints, DBCP, aldrin, arsenic, and dieldrin are the primary contributors to the total estimated
risks for the biological worker at Horizon 1. It should be noted, however, that the apparent major contribution
of DBCP stems in large part from the elevated observation at the Chemical Sewers (site SP10), where the
DBCP cancer risk was 7.6 x 10"3 and the HI was 0.016. The influence of arsenic on total cancer risks for
Buried M-l Pits (site SP1E) and some North Plants agent storage sites (sites NP5 and NP6) is expected as
arsenic is a component of the agent compounds that were stored or disposed in these areas. For
noncarcinogenic risk endpoints, DBCP, aldrin, and arsenic account for the majority of the total estimated His.
No cancer risk estimates exceed 10*4 at Horizon 2. However, for those sites with Horizon 2 cancer risks exceeding
\0*, chloroform and benzene are the major contributors to the total estimated risks. For those sites with His
exceeding 1.0, DBCP, DCPD and HCCPD account for the majority of the total estimated His.
Detailed data regarding the contribution of individual chemicals to total site risks and His are provided in the
additivity reports; which can be accessed using the HHRC software provided in Appendix D of the IEA/RC report.
Summary of Pathway Risk Drivers
Carcinogenic and noncarcinogenic risks estimated for the biological worker and other open space land-use option
receptors were attributed primarily to the direct soil exposure pathways (soil ingestion and dermal absorption; see
Tables 6.1-13 through 6.1-17). In contrast to trends identified for the biological worker, the soil vapor inhalation
pathway was the dominant exposure pathway for the driver COCs identified for industrial (and commercial)
workers.
A sensitivity analysis was conducted for the HHRC to rank the influence of several distributed input parameters on
the variability of the cumulative direct PPLVs for aldrin, dieldrin, DBCP, arsenic, and chlordane. These chemicals
were chosen because of their strong contributions to overall risk at RMA. The sensitivity analysis considered both
biological and industrial worker receptors (representing open space and economic development land-use options,
respectively) for both cancer risk and HI endpoints. Standardized regression coefficients and full-model partial
correlation coefficients were computed for each input parameter to provide two separate measures of a parameter's
influence on the variability of the direct exposure pathway PPLVs.
The eight distributed input parameters used for the direct PPLV calculations included the following:
TE Exposure duration (years) (for carcinogens only)
DW Annual frequency of exposure (days/year)
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TM Daily exposure rate (hours/day)
RAFdenni) Relative absorption factor for dermal absorption (unitless)
RAFtagestion Relative absorption factor for ingestion (unitless)
CSS Dust loading factor (ug/m3)
SC Skin soil covering (mg/cm3)
SI Soil ingestion (ing/day)
The results of this analysis indicate that variability in exposure duration is consistently the dominant contributor to
variability in the direct carcinogenic PPLV, followed by soil ingestion. Soil ingestion is also a dominant
contributor to variability in the direct noncarcinogenic PPLV. Other influential parameters include
n. ***& soil covering.
Risks for the boring-by-boring analysis were characterized using the following sampling data:
• Surficial soil results (samples collected from a 0- to 2-inch soil-depth interval in areas outside of
designated sites)
• Boring-by-boring results (maximum contaminant concentrations detected in each soil-depth interval
for individual borings located within designated sites)
Surficial Soil Results
Figure 6.1-8 shows the incremental cancer risks estimated for the biological worker using surficial soil (0-inch to
2-inch depth interval) results. This map indicates only three surficial soil locations with incremental cancer risks
exceeding Iff4: one occurs east of Basin C, one occurs in Basin A, and one occurs in the southern area of Section
36. Similar trends are apparent for His; of the 493 non-zero observations, only three surficial soil locations have
incremental His exceeding 1.0. The surficial soil results supplement the subsurface boring evaluation discussed
below, and may be more relevant to the evaluation of direct contact exposure risks for open space land-use option
receptors than corresponding results for deeper soil intervals (in particular, the recreational and regulated/casual
visitor subpopulations).
Boring-Specific Risks and His
The findings of the boring-specific evaluation for Horizons 0 and 1 basically parallel those described for the site
analysis summarized above in that exceedances of a 1 x Iff4 cancer risk level (Figures 6.1-9 and 6.1-10) or an HI
of 1.0 (Figures 6.1-1 1 and 6.1-12) at individual borings are generally limited to the following areas located in the
central portions of RMA: South Plants, Sewer Systems, Lime Basins, Former Basin F, Basin A, and the Complex
Trenches located in Section 36. Isolated exceedances of a 1 x 10"* cancer risk were also identified at borings
located in Basin C, Sand Creek Lateral, the North Plants Agent Storage Areas, and the sanitary landfill near the
Rail Yard (located in the western portion of RMA). The boring-specific HI results exhibit similar trends.
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Figures 6.1-13 and 6.1-14 show the composite of carcinogenic and noncarcinogenic chronic risk exceedances, as
well as acute risk exceedances.
For all receptors evaluated in the HHRC, the major contaminants contributing to potential cancer risks were aldrin,
DBCP, arsenic, and dieldrin. For noncancer risk endpoints, DBCP, aldrin, and arsenic account for the majority of
the total estimated His.
Acute and Subchronic Risk Evaluation
In the probabilistic evaluation, PPLVs were calculated to be protective of chronic (long-term) exposures.
However, it is possible that exposures to COCs at RMA could be short term, such as exposures occurring only on a
single day (acute), or exposures lasting more than 1 day but less than 7 years (subchronic). These PPLVs,
originally calculated for the HHEA Addendum, are summarized in Tables 6.1-19 and 6.1-20. The cumulative
direct acute and subchronic PPLVs are protective of exposure via three pathways, soil ingestion, paniculate
inhalation, and dermal contact with soil. The PPLVs presented in these tables are the same as those originally
calculated, with two exceptions: PPLVs for aldrin and dieldrin were recalculated during the HHRC to reflect
updated toxicity criteria and the dermal relative absorption factor (all receptor scenarios) and soil covering factor
(visitor populations only) were revised.
In general, and particularly for the biological and industrial worker populations, the acute and subchronic
PPLVs shown in Tables 6.1-19 and 6.1-20 are higher than the corresponding chronic noncarcinogenic 5th
percentile PPLVs (Tables 6.1-13 through 6.1-17). This finding is expected because the body can generally
tolerate a higher contaminant dose over a short (e.g., acute) duration than over a long (chronic) duration for a
given dose rate. However, for the recreational and regulated/casual visitor exposure settings, acute/subchronic
PPLVs for some chemicals are lower than corresponding chronic noncarcinogenic 5th percentile PPLVs.
Figure 6.1-15 shows sample locations exceeding an HI of 1.0 for all COCs having acute PPLV values.
6.2 Ecological Risk Characterization
Ecological risk .characterization focuses on chemicals that, because of their toxicity, may adversely affect biota
populations, individuals of threatened or endangered species, or the species diversity in a community. For these
effects to occur, toxic chemicals must be present in the environment, potential biota receptors must be present
and they must be engaged in activities that would expose them to chemicals that are not only present, but
bioavailable (Figure 6.2-1). The sections below summarize the steps of the ERC at RMA, which are similar to
the HHRC steps.
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6.2.1 Identification of Contaminants of Concern
Fourteen chemicals detected on RMA were selected as of concern to biota: aldrin, dieldrin, chlordane, endrin,
DDT, dichlorodiphenyldichloroethene (DDE), mercury, arsenic, cadmium, chlorophenylmethylsulfide (CPMS),
chlorophenylmethylsulfone (CPMS02), copper, DBCP, and DCPD. The biota COCs were selected on the basis
of criteria (toxicity, persistence, amount used or produced at RMA, and areal extent of contamination)
developed collectively by the Army, EPA, USFWS, and Shell to focus on the potential main risk drivers.
Of the 14 biota COCs considered in the ERC, six (aldrin, dieldrin, endrin, DDT, DDE, and mercury) are known
to biomagnify substantially, and seven do not biomagnify substantially or at all (arsenic, cadmium, CPMS,
CPMS02, copper, DBCP, and DCPD). Chlordane can biomagnify (usually in the form of its metabolites), but
was not treated quantitatively as such because no tissue sample data were available for this chemical.
Biomagnification means that each successive organism in the food chain (e.g., from plant to insect, mouse, and
hawk) will have a higher concentration of the chemical in its body tissue.
6.2.2 Exposure Assessment
Numerous ecological studies have been performed at RMA, particularly by USFWS in the 1960s, the Army in
the 1970s to mid-1980s, and by Shell, USFWS, and the Army in the late 1980s and 1990s to identify the
ecological receptors that may be exposed to the biota COCs and to determine the effects of this exposure.
Using the data from these studies, several food webs were constructed to represent the biota food chains present
at RMA. For the purposes of the IEA/RC, a food web is a collection of food chains that all culminate in a
single top predator. Five such food webs were evaluated for RMA, each headed by different predators:
• Bald eagle
• American kestrel
• Great homed owl
• Great blue heron
• Shorebird
The following types of biota were selected to represent the various feeding levels (trophic boxes) in these RMA
food webs and were evaluated from past varied studies where tissues were collected for analysis of COC
concentrations:
• Earthworms
• Insects (represented by grasshoppers and ground beetles)
• Small birds (represented by vesper sparrows, western meadowlarks, and mourning doves)
• Small mammals (represented by deer mice and 13-lined ground squirrels)
• Medium mammals (represented by desert cottontails and black-tailed prairie dogs)
• Water birds (represented by mallards, blue-winged teal, and American coots)
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• Shorebirds (represented by killdeer)
• Large fish (represented by northern pike and largemouth bass)
• Small fish (represented by channel catfish, black/brown bullheads, and bluegills)
• Aquatic invertebrates
• Plankton
• Terrestrial and aquatic plants
The data on tissue concentrations of contaminants were used to bom document the nature and extent of
contamination in biota and to provide tissue data that could be used in the ERC process described in Section
6.2.4. The exposure assessment included the estimation of exposure area soil concentrations; the estimation of
species- and chemical-specific biomagnification factors (BMFs) based on bioaccumulation factors (BAFs) that
describe the amount of COC transfer from food to consumers; and the identification of dietary items, fraction of
items consumed, and feed rates. Exposure area soil concentrations were calculated based on an area-wide
average (i.e., an arithmetic mean) concentration, an "area" being defined as an organism's estimated foraging or
exposure area. The area-averaged concentration was computed from spatially interpolated soil concentrations
in the 0-ft to 1-ft depth interval (except for the prairie dog's exposure area, which incorporated a vertical
average for the 0-ft to 20-ft depth interval). The interpolated soil concentrations were calculated on a square
grid with 100-ft spacing using surrounding actual soil sample concentration data and the inverse distance-
squared algorithm. Before the soil data were interpolated, values that were below certified reporting limits
(BCRL) were replaced with estimated values based on nearby detections when the surrounding data were
sufficient using the inverse distance-squared algorithm. Because the spatial interpolation of BCRL data
proceeded iteratively, a previously estimated BCRL value may have been included with nearby detections to
estimate a replacement value for a BCRL at a different location (see Appendix C of the IEA/RC report for a
detailed description of the spatial interpolation of BCRL data). Specifically, exposure area soil concentrations
were estimated in three steps: spatial interpolation of BCRL data, interpolation of soil concentrations onto an
RMA-wide grid, and averaging of interpolated data within an exposure area to compute exposure area soil
concentrations. A best estimate of the exposure range of each receptor was obtained from the literature and
represented by a circle (to facilitate the modeling of average risk) within which an individual receptor was
assumed to be exposed. By centering the exposure range circle for a given receptor on a grid block and
averaging the soil values within grid blocks that fell half or more within the circle, an average exposure
concentration was estimated. This process was repeated for each grid block over the entire RMA area.
The BMP used at RMA represents a ratio between the concentration of a chemical in biota tissue (generally
represented as the "whole-body concentration," which includes the whole animal for small mammals, such as
deer mice, and the skinned/eviscerated carcass for medium mammals, such as prairie dogs) and that in soil.
Three different methods of calculating the BMP were used in evaluating potential risk at RMA, which yielded
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differing BMP values for four COC categories (Table 6.2-1). The differences reflect the uncertainties
associated with the data as well as the alternate methods used to derive the BMFs. Because the BMFs resulted
in varying risk estimations, the SFS (see Section 6.2.4.3) will attempt to resolve uncertainties about the spatial
extent of potential excess exposure and resulting subpopulation risk to biota compared to the three ranges of
risk derived from the three BMFs.
Once a BMP was developed for a particular chemical/receptor combination, it was multiplied by the estimated
exposure soil concentration in each block to obtain an estimated tissue concentration for the ecological receptor
centered on that grid block. Data on dietary fractions and feed rates were obtained from the literature and from
studies conducted at RMA. Where appropriate, the RMA-specific dietary data were used instead of literature
values; however, if RMA data were not available, preference was given to literature dietary information from
geographic and habitat types most similar to those at RMA. The exposure assessment parameters (Table 6.2-2)
were based on best estimates of averages and were used to calculate potential tissue concentrations and dosages
based on ingestion of contaminated soil and prey.
6.2.3 Toxicity Assessment
Literature data on chemical toxicity that include biota COC concentrations associated with some type of
adverse health effect were used as numerical thresholds against which risk was evaluated. Reported effects on
reproduction were preferred because these have the most obvious connection with detrimental population
impacts; however, nonreproductive effects, such as behavioral toxicity, may also be important, but these effects
are more difficult to evaluate and quantify. Other such toxicological endpoints were considered from a
qualitative perspective. For all of the receptors evaluated, both tissue-based (i.e., maximum allowable tissue
concentrations, or MATCs) and dose-based (i.e., toxicity-reference values, or TRVs) threshold values were
sought in the literature. Each of the values found in the literature was evaluated as to its appropriateness for use
as a threshold value (NOAELs and no observed effects levels, or NOELs, were the preferred endpoints). UFs
were applied to the final literature-based pre-UF MATCs and pre-UF TRVs to help ensure adequate protection
of biota populations. UFs were developed for the MATC and the TRY (Table 6.2-3) approaches in parallel
(i.e., it was decided to apply the same rationale and values for each derivation process).
UFs were developed for four categories as follows:
• Intertaxon variability in toxicological responses to contaminants when extrapolating from the species
used in an experimental study to a target species at RMA
• Extrapolation from the duration of an experimental study to the chronic exposure being assessed at
RMA
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• Extrapolation from a toxicity endpoint in an experimental study to the desired no adverse effects
endpoint for the ecological risk assessment at RMA
• Modifying factors to account for additional sources of uncertainty
The final UF, the product of the results of these four categories, is divided into the pre-UF MATC or pre-UF
TRY critical value to determine a final MATC or TRY (Table 6.2-4). The total uncertainty (final UF) applied
for tiie derivation of TRVs ranged from 4 to 7,500 and the total uncertainty for MATCs ranged from 1.5 to 375.
However, if the final UF exceeded 400, a final UF of 400 was used. The total uncertainty ranges for the main
risk driver, aldrin/dieldrin, was much tighter: 4 to 30 for the aldrin/dieldrin TRVs (Table 6.2-5) and 1.5 to 30
for the aldrin/dieldrin MATCs (Table 6.2-6).
The MATCs represent maximum whole-body concentrations of bioaccumulative chemicals that are unlikely to
cause harmful effects to specific receptors. The MATCs, expressed as the weight of contaminant per unit of
body weight (mg/kg-bw), were derived from literature data on tissue concentrations associated with the
presence or absence of observed lexicological effects in biological test species (to produce pre-UF MATCs),
and then adjusted with the COC/receptor-specific UF to produce final MATCs.
The final TRVs represent estimates of a daily dose (mg/kg-bw-day) that are likely to be without an appreciable
risk of harmful effects to target receptors. The TRVs computed for the IEA/RC follow an approach that is
different from that described in the Off-Post Operable Unit Endangerment Assessment/FS for RMA (Harding
Lawson Associates 1992); however, both RMA approaches are similar to the methodology used by EPA to
compute RfDs for assessing risks to human health.
The final toxicological threshold values, MATCs and TRVs, are compared to the site-specific exposure
measurements (i.e., population mean contaminant tissue concentrations and doses) to estimate potential risk to
biota populations (Section 6.2.4.1). The toxicological threshold values are intended to be protective of biota
populations and individual bald eagles at RMA.
The final tissue- and dose-based threshold values selected for the characterization of risk are shown in Table
6.2-4. When both tissue-based and dose-based threshold values were available, the value with the lower UF was
selected. When the uncertainty was equal, the TRV was selected because it avoided the use of a BMF, which
introduced uncertainty of its own. Where two values were calculated, the value that is shown in bold face was
used to estimate risk.
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6.2.4 Risk Characterization
6.2.4.1 Methods
The characterization of potential risk from the biota COCs to terrestrial receptors was performed by integrating
the exposure assessment and the toxicity assessment with a Geographic Information System (CIS) to produce a
series of maps that display areas of potential risk (i.e., HQs or His greater than 1.0).
For the tissue-based approach, estimated tissue concentrations were compared directly with a tissue-based
toxicity threshold value to calculate an HQ, which represented an estimate of potential risk in a grid block for
the chemical/receptor combination being investigated. This approach is represented by the following equation:
HQ = Tiyftit Concentration
MATC
Alternatively, if the dose-based approach was used, the dose to the receptor being investigated was estimated
and compared to a dose-based toxicity threshold value to calculate an HQ. The dose-based approach is
represented by the following equation:
HQ - Dose
TRV
The HQ equations presented above are a generalized representation of those actually used in the ERC.
Appendix C of the IEA/RC report contains a detailed description of the equations used. The risk
characterization processes were repeated for all grid blocks and for all chemical/receptor combinations for
which biomagnification factors were calculated. There were variations from these approaches for chemicals
having no tissue data, for predators that were not sampled for nonbioaccumulative COCs, and for aquatic food
chains. These variations are also described in Appendix C of the IEA/RC report.
An HQ greater than 1.0 indicated a potential risk from a particular chemical. The sum of all HQs for a single
receptor resulted in an HI, which indicates the potential risk from all biota COCs to that receptor. HQs and His
were mapped using CIS to show the geographic extent of areas having potential risk (Figures 6.2-2 through
6.2-5).
The degree to which the results of the risk characterization were consistent with the ecological measurement
endpoints on observable field effects identified within the ecological database available for RMA was also
evaluated. Ecological measurement endpoints were selected at the community, population, and individual
levels of ecosystem organization. The community-level measurement endpoints considered were species
richness and trophic diversity; these provide information on the assessment endpoint of biological structural
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diversity of the RMA and regional ecosystem. Population-level measurement endpoints were relative
abundance, reproductive success, and morbidity; these provide information on the assessment endpoint of
population robustness. Selected biomarkers (i.e., acetylcholinesterase inhibition and eggshell thinning) were
examined at the individual level, but evaluated as measurement endpoints for extrapolation to population
effects. Endpoints at the individual level are appropriate for evaluating adverse effects on individuals of
threatened or endangered species (e.g., bald eagle), which by definition have populations reduced to the level
where individuals are important.
6.2.4.2 Results
Quantitative results were calculated for all five of the predators (bald eagle, American kestrel, great homed owl,
great blue heron, and shorebird) heading the food webs developed for RMA and for four of the trophic boxes in
their food webs (small bird, small mammal, medium mammal, and water bird). Other trophic boxes, including
all strictly aquatic organisms in the RMA lakes, were not evaluated quantitatively because toxicity threshold
values for these biota COCs/trophic box combinations were not available in the literature. The results of the
terrestrial risk characterization are presented primarily in maps, which best show the spatial variability of the
estimated potential risk. Figures 6.2-2 and 6.2-3, which illustrate the number of receptors having potential risk,
are based on the Shell BMP because Shell BMP results were intermediate between the Army and EPA BMP
results. Many other such maps are available in the IEA/RC report (Section 4 and Appendix C.3). In viewing
these maps, h should be remembered that a small hot spot (identified by only a few borings) or a large
relatively clean area can affect the soil concentrations interpolated for several surrounding grid blocks. These
grid blocks in turn can affect the estimated exposure soil concentrations for many grid blocks, particularly for
receptors with large exposure ranges such as raptors. Such species are likely to have sizable areas of potential
risk because very high contaminant concentrations in hot spots around the manufacturing plants and basins
were averaged over large exposure ranges. If the high contaminant concentrations in just these hot spots were
reduced, then the area! extent of potential risk, as well as the magnitude of HQs and His, would be reduced.
Conversely, if large relatively clean areas are included in the estimation of exposure soil concentrations, the
effect could be a dilution of concentration attributed to hot spots.
Potential risk varied depending on the BMP used, the chemical or chemical group being considered, and
receptor (trophic box) being evaluated. Differences in risk among receptors for a given chemical were partly
due to differences in the toxicity threshold values, and especially due to differences in the exposure range size.
Figure 6.2-2 shows the number of representative trophic boxes that have His greater than 1.0 in various parts of
RMA. This figure shows that the areas of potential risk to the greatest number of species tend to be smaller and
located toward the center of RMA, even though the specific receptors subject to potential risk in one area may
be different from those subject to potential risk elsewhere. Terrestrial areas where all trophic boxes are
expected to be at potential risk (based on cumulative risk from all of the COCs combined) are most of the
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central sections of RMA, including South Plants; Basins A, B, C, D, and F; and the northernmost upland areas
adjacent to the South Lakes area. Pesticides (especially aldrin/dieldrin) are the primary biota COCs
contributing to biota risk at RMA, as shown in Figure 6.2-3. This figure shows the number of trophic boxes
having an HI greater than 1.0 for aldrin/dieldrin, DDT/DDE, and endrin based on soil exposure and the Shell
BMP approach. Metals are also significant contributors to biota risk.
The degree to which potential risk predicted by the EPA, Shell, and Army BMFs differed for a single
COC/receptor combination based on the TRY (dose-based) approach is shown for aldrin/dieldrin in Figure
6.2-4 for the great homed owl and in Figure 6.2-5 for the small mammal. The effect of the small mammal's
much smaller exposure range can be seen by comparing Figure 6.2-4 with Figure 6.2-5. Receptors with larger
exposure ranges generally show greater areas of potential risk, and receptors with smaller exposure areas tend
to show smaller areas of potential risk that more directly reflect specific areas of higher soil contamination. The
areas depicted in the maps do not necessarily denote the extent of magnitude or severity of potential risks to
biota, nor do they depict the ecological relevance of the potential risks to local populations. The ecological
relevance of the potential risks will be addressed as part of remedial design and incorporate the ongoing
USFWS biomonitoring program, as well as the SFS and other evaluations being performed by the BAS (see
Section 6.2.4.3). EPA defines ecological relevance generally in terms of "population sustainability and
community integrity" for both current and future exposure and risk.
The potential risk to predators at the top of food webs having aquatic food chains is shown in Table 6.2-7.
These risks are tabulated because a single risk value was calculated for all the lakes combined. In combining
measured tissue concentrations from the various lakes, feeding was assumed to be proportional to the size of the
lake. Table 6.2-7 shows that potential risk from aquatic food chains is greatest to the great blue heron.
The results of the quantitative ERC were also compared with the results of evaluating potential ecological
effects such as impacts on reproduction, species abundance, and species diversity. No strong trends in any of
these data indicated populationa! effects. However, because sampling was concentrated in contamination areas,
average tissue concentrations exceeded the MATC (which represents the tissue-based toxicity threshold value)
for dieldrin, mercury (for this COC, the detection limit also exceeded the MATC), and DDE. Likely adverse
effects of RMA contamination have been observed in individual animals collected at RMA, but these effects
were not apparent in the available data collected for wildlife populations as a whole at RMA. The available
data were obtained from studies that had varying purposes and degrees of ability to discern contaminant effects
on local populations. It should be noted that the state and EPA disagreed with the ability to draw conclusions
on wildlife populations or on the effects of RMA contaminants to individual animals from the available data.
In accordance with the Conceptual Remedy, all Parties, through their representatives on the BAS, will continue
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to evaluate the SFS and USFWS biomonitoring studies and provide information to risk managers on the status
and health of biota at RMA in terms of the need to refine design boundaries to include additional locations
where biota risks were deemed to be excessive. This process will continue during the remedial design after the
ROD is siped (see Section 6.2.4.3).
The potential risk from all COCs combined covered most of RMA for at least one species. However, a number
of considerations should be taken into account when evaluating this risk. For example, the risk from mercury is
overestimated for RMA because all mercury was assumed to be in its most toxic and bioavailable form, methyl
mercury, although this is not the most prevalent form at RMA. Conversely, because chlordane was not
quantitatively modeled as a bioaccumulative COC, its risks to biota may be underestimated. For terrestrial and
aquatic receptors, there are uncertainties inherent in the toxicity threshold values used and in the estimated
tissue concentrations that were compared to these threshold values. The uncertainties in threshold values are
mostly reflected in the magnitude of UFs used to derive each TRY or MATC. For terrestrial receptors,
uncertainties in estimated tissue concentrations result primarily from uncertainties in the estimates of the
exposure soil concentration and the BMP.
The available ecological data used to evaluate ecological effects were also subject to uncertainty resulting from
the short-term nature of many of the studies, lack of sufficient precision of the results, and study designs that
were not always oriented toward correlating ecological parameters with contaminant concentrations. As noted
previously, not all the Parties agreed with the appropriateness of the ecological data used in this comparison.
6.2.4.3 Continuing Biological Studies
Generally, the results of the ERC showed that the areas of highest potential risk are located in the central portions
of RMA and are associated with major chemical manufacturing processes or a disposal area that contains the
greatest concentration of contaminants. Although the Army, Shell, and EPA approaches all agree regarding
excessive risk (i.e., HQ or HI greater man 1.0) to wildlife in the central areas of RMA, they differ in their estimates
of areas and magnitudes of potential ecological risk in other parts of RMA. The major variation is due to the use of
different BMFs (as calculated by the Army, EPA, and Shell) to estimate exposure. Because of the scientific
differences of opinion concerning the best approach to determine field BMFs at RMA, the SFS was established.
Phase I of the SFS is designed to determine whether unacceptable levels of exposure (i.e., risk) exist within the
Area of Dispute (Figure 6.2-6). The Area of Dispute is defined as the difference in the areas of potential
aldrin/dieldrin risk (HQ greater man 1.0, based on MATC) to small mammals based on the Army and EPA
approaches and was delineated for the primary purpose of sample collection in Phase I of the SFS. It may or may
not reflect the area of uncertainty in terms of excessive risk to biota, although this is also coincidentally the ROD
Area of Contamination (AOC) boundary. If Phase I of the SFS indicates that unacceptable risks to biota are likely,
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the 'SFS may proceed with Phase II under RMA Council direction to collect additional tissue and soil data to
estimate field BMFs for selected species.
The goal of biota remediation is to achieve appropriate remediation such that it is protective of biota health (i.e.,
sustainability of local subpopulations and individuals of threatened or endangered species). His were used in
the EEA/RC to provide a semiquantitative characterization of predicted risks to biota at RMA. In general, His
less than 1.0 denote the absence of excessive risk to biota populations. His greater than 1.0 may indicate
potential adverse risks to biota populations; the greater the HI, the greater the potential risk.
To demonstrate spatial representation of biota risk, a series of additional risk maps (pre- and post-remediation)
are presented for the American kestrel and great homed owl using the Army and EPA BMP approaches
(Figures 6.2-7 through 6.2-14). These residual risk maps show locations and relative magnitudes of estimated
biota risks due to exposure to the bioaccumulative COCs (excluding mercury) following proposed remediation.
Residual risk areas will be evaluated by the BAS as potential locations for additional ecotoxicological studies.
Mean His for the American kestrel and great homed owl were estimated within the pre-remediation areas
identified as having an HI greater than 1.0 using the Army and EPA BMP approaches based on a
semiquantitative analysis of the pre- and post-remediation risk maps (Figure 6.2-7 through 6.2-14). Several
general conclusions about the pre- and post-remediation risks to biota and associated uncertainty can be made
from this semiquantitative analysis as follows:
• EPA mean HI estimates were an average of about 3 times higher than the Army mean HI estimates
based on differences in the BMFs (ranging from about 2 to 4 times higher; American kestrel had the
highest difference).
• Pre-remediation mean His ranged from about 2 to 120 using Army BMFs and about 7 to 270 using
EPA BMFs (bald eagle was the highest in both cases).
• Post-remediation mean His ranged from 1 to 7 using Army BMFs and about 4 to 16 using EPA BMFs
(bald eagle was the highest in both cases). The residual risk maps show that in general residual risks
remain adjacent to the ROD's biota remediation areas (shown as the shaded areas in Figure 6.2-6) and
that the highest ranges of residual risk are located adjacent to the southwest section of the green-
shaded areas.
• In general, both the Army and EPA methods show at least a 10-fold reduction in risk for all species of
concern following remediation of the shaded areas shown in Figure 6.2-6.
While the SFS is being conducted, certain areas of more highly contaminated surficial soil, which represent the
areas in which all three BMF approaches yielded HQs greater than 1.0 (using the MATC approach) for
aldrin/dieldrin for small mammals, as well as some additional areas north of Former Basin F and areas identified by
USFWS as priority areas (i.e., known areas of high contamination and posing a threat to wildlife based on field
observations), have been identified as candidates for initial focused remediation and are identified as the green-
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shaded areas in Figure 6.2-6. The process outlined in the Conceptual Remedy and summarized below permits the
further investigation of other identified areas of potential residual risk outside the green-shaded areas in order to
more accurately characterize actual biota risk and impacts and to refine design boundaries if warranted. This
process includes the following:
• The BAS of technical experts (e.g., ecotoxicologists, biologists, range/reclamation specialists) from the
Parties will focus on the planning and conduct of both the USFWS biomonitoring programs and the
SFS/risk assessment process. The BAS will provide interpretation of results and recommendations to
the Parties' decision makers.
• The ongoing USFWS biomonitoring programs and the SFS/risk assessment process will be used to
refine design boundaries for surficial soil and aquatic contamination to be remediated.
- Phase I and the potential Phase II of the SFS will be used to refine the general areas of surficial
soil contamination concern. The field BMFs from Phase tt will be used to quantify ecological
risks in the Area of Dispute, identify risk-based soil concentrations considered safe for biota, and
thus refine the area of excess risks (Figure 6.2-6).
- Pursuant to the FFA process, USFWS will conduct detailed site-specific exposure studies of
contaminant effects and exposure (tissue levels and Army-provided abiotic sampling) on
sentinel or indicator species of biota (including the six key species identified in the EEA/RC
report as appropriate). These studies will address both the aquatic resources and at least the
surficial soil in and around the Area of Dispute. These site-specific studies will be used in
refining contamination impact areas in need of further remediation.
- Results from both the SFS/risk assessment process and the site-specific studies will be
considered in risk-management decisions, which may further refine the areas of surficial soil and
aquatic contamination to be remediated. (In the event of a conflict between management of
RMA as a wildlife refuge and performance of remedial response actions, the Rocky Mountain
Arsenal National Wildlife Refuge Act indicates that response actions will take priority.)
• The BAS will serve as a technical resource to the Parties' decision makers by using technical expertise
in analyzing, and potentially collecting, data sufficient to support design refinement for surficial soil
areas and aquatic resources that will break unacceptable exposure pathways in consideration of
minimizing habitat disturbance. Further, it will assess through monitoring the efficacy of remedies in
breaking unacceptable pathways to biota. If any additional sites are identified, the remedy will be
implemented as follows:
- It will be staged to allow habitat recovery.
- It will be performed first on locations selected through a balance of factors such as:
- The Parties agree an area has a negative impact on or excessive risk to fish or wildlife.
- The effort will not be negated by recontamination from other remediation activities.
- The existing fish and wildlife resource value.
- It will include revegetation of a type specified by USFWS; if the initial revegetation is not
successful, the appropriate adjustments will be made and revegetation again implemented.
- It will provide mat the locations and timing of remediation are to be determined with
consideration of and in coordination with USFWS refuge management plans and activities.
6.3 Uncertainty Analysis
Several sources of uncertainty must be considered in the evaluation of the HHRC and ERC results. Model
parameter distributions were developed based on empirical data, and in instances where empirical data were
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6.0 Summary of Site Risks
lacking, best professional judgment was incorporated. In addition, when uncertainty in the empirical data for a
given parameter warranted conservative assumptions, these assumptions were incorporated into the exposure
and risk estimations.
6.3.1 Human Health Risk Characterization
6.3.1.1 Chemical Database
Contributing to the chemical database uncertainty are the different analytical techniques used by the RI Phase I
and Phase II programs for some of the organic chemicals. Phase I employed gas chromatography/mass
spectrometry (GC/MS), and Phase II employed more precise GC methods. The Phase I techniques made use
of higher detection limits; thus, chemicals present at lower levels may not have been detected. In a few cases,
Phase I samples required dilution to facilitate analysis, and the dilution may have masked the presence of some
compounds by raising the effective detection level. When necessary, an expanded suite of Phase II analyses
and/or additional GC/MS analyses were used to ensure that all target analytes were evaluated. Some other
limitations associated with the chemical database are soil sample collection, tentatively identified compounds,
unidentified compounds, and Army agent contamination. Uncertainties associated with soil sample collection
can under- or overestimate risk. Tentatively identified and unidentified compounds were not considered in the
risk characterization and the detections of Army chemical agent reported in the chemical database were not
quantitatively evaluated. Potential risk may have been underestimated based on the exclusion of agent and
tentatively identified compounds from the evaluations.
6.3.1.2 Exposure Point Concentration
Uncertainties associated with the exposure point concentrations include the estimation method used to
approximate site concentration values used to calculate risk. In accordance with EPA guidance, representative
soil concentrations were estimated using the arithmetic mean (C^,,,^. The uncertainty in these estimates was
characterized by reporting the 95 percent upper and lower confidence limits (95% UCL and 95% LCL,
respectively) on the mean. The 95% UCL (C^,,^) was used to estimate the RME risks. Conservative
assumptions were also employed to address potential dilution effects when soil boring samples were
composited and to calculate the boring-by-boring risk estimates; the highest detected concentration of the COC
was used regardless of the depth of the sample.
6.3.1.3 Land-Use and Exposure Scenarios
Uncertainty exists regarding the likelihood that the land uses evaluated will in fact occur under a future
development scenario at RMA. Land use at RMA is currently limited to commercial, industrial, recreational,
and open space (i.e., nature preserve/wildlife refuge) uses. The land-use designations were based on
information obtained from several governmental agencies overseeing and directing land use within their
respective jurisdictions surrounding RMA. The FFA restricts the ownership, use, and transfer of property at
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RMA now and into the future. Consistent with the FFA, certain future land uses at RMA are not considered
foreseeable, such as residential and agricultural development. It is for this reason that certain pathways of
exposure (e.g., potable and agricultural use of groundwater, surface water and sediment exposures, and
consumption pathways) were not evaluated at RMA. The uncertainties associated with the human health
exposure scenarios evaluated in the EEA/RC as related to land use, target receptors, spatial exposure patterns,
and exposure pathways could result in an over- or underestimation of risk.
6.3.1.4 Human Health Toxictty Estimates
The toxicity factors (DT; the dose-response parameter based on the slope factor or RfD) used in the HHRC were
designated as a fixed parameter to maintain consistency with established EPA toxicity factors used in CERCLA
risk assessments. However, a large degree of uncertainty is known to be associated with the toxicity factors.
This uncertainty could lead to an over- or underestimation of risk. The major sources of uncertainty include the
following:
• Extrapolation of toxicity factors from effects observed at high doses administered in a laboratory
setting to effects observed at relatively low doses expected from human contact with the chemical in
environmental media
• Use of short-term toxicity studies to predict the effects of long-term (chronic) exposures and vice versa
• Use of animals to predict the effects of contaminant exposure on humans where adequate human data
are lacking
• Use of toxicity data from laboratory animals (homogeneous populations) and healthy humans to
predict the effects observed in a general population, which included individuals having a wide range of
sensitivities
As indicated in "Guidelines for Carcinogenic Risk Assessment," the cancer slope factors generated from the
linearized multistage extrapolation procedure lead to what is considered a "plausible upper limit to the risk that
is consistent with some proposed mechanisms of carcinogenesis. Such an estimate, does not necessarily give a
realistic prediction of the cancer risk. The true value of the risk is unknown, and may be as low as zero" (EPA
1986). Descriptions of the uncertainties associated with the toxicity factors are contained in Appendix B and
Appendix E of the IEA/RC report.
6.3.1.5 Exposure Parameters and PPLVs
The variability and uncertainty in the PPLVs were estimated by developing probabilistic distributions for each
of the HHRC model's parameters. The variability in the parameter distribution refers to the real variation in
possible parameter values, which may be spatial (e.g., soil density), temporal (e.g., dust loading), physiological
(e.g., body weight, skin surface areas) or due to the effects of other factors such as behavior. Uncertainty is that
part of the parameter distribution resulting from random sampling variation and other sources of potential error.
Uncertainty increases the overall spread of the distribution and may also result in bias, both intentional (e.g.,
conservative assumptions) and unintentional (unknown). There was substantial uncertainty about the
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6.0 Summary of Site Risks
representativeness of data for parameters describing human exposures (e.g., soil intake parameters, time-
dependent exposure parameters). In general, however, conservative assumptions were made. Ages and
activities associated with the open space visitor land-use options were characterized using available empirical
data and professional judgment. Although survey data were used to characterize time and activity patterns for
the refuge worker population and biological worker subpopulation in order to improve the confidence in the
analysis, the representativeness of the resulting distributions for current and future exposed populations at RMA
remains uncertain. The datasets compiled for these populations or subpopulations may under-represent
exposures for some portion of the future RMA population and over-represent for some other portion. It is not
possible to determine with certainty whether data representativeness in the risk evaluations imparted a
conservative or underconservative bias to the results. Summaries of the major uncertainties associated with the
PPLV equation parameters are presented in Tables 6.3-1 through 6.3-3.
The variation in the HHRC model parameters is reflected in the spread of the PPLV distribution. Because the
uncertainty and/or variability in many key probabilistic parameters is higher for particular chemicals or for
exposed populations, the resulting PPLV distributions corresponding to these chemicals and land uses have a
wider spread. A detailed description of the PPLV distribution variability is described in Appendix E of the
IEA/RC report.
6.3.1.6 Risk Estimates
The PPLV-based risk estimations were based on a target cancer risk of 1 x 10"* or an HQ of 1.0 and exposure
point concentrations representing the Cmix, C^,,^, and CrepiUppCT (the different risk calculation methods are
available via the HHRC model). When the cancer risk estimates are based on the 5th percentile PPLV and the
Crep upp(.p the results can be considered as upper bound estimates of potential risk.
In the IEA/RC, both carcinogenic risks and noncarcinogenic HQs are assumed to be additive, consistent with
current risk assessment guidance. There are several limitations associated with this assumption. Due to these
limitations, the potential to over- or underestimate risk cannot be firmly established. In summing cancer risks,
the underlying assumption is that there is an independence of action (i.e., effect to organ, tissue, etc.) by the
chemicals involved and that there are no synergistic or antagonistic chemical interactions. Uncertainty is also
associated with summing cancer risks for multiple chemicals that have differing weights of evidence for human
carcinogenicity (i.e., Group A versus Group C carcinogens; see Section 6.1.3). Because little or no information
on antagonistic or synergistic effects was available for the RMA COCs, noncarcinogenic effects from multiple
chemicals were also assumed to be additive. A limitation with the additive approach used for the IEA/RC is
that the COC-specific HQs were not segregated by major toxic effect prior to summing to derive the HI;
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however, this simplifying step may not have introduced large degrees of uncertainty because most of the
noncancer effects were attributed to a single COC (dieldrin).
6.3.2 Ecological Risk Characterization
6.3.2.1 Chemical Database
The same uncertainties associated with the chemical database that were identified for the HHRC apply to the
ERC. However, the database used for the ERC also included results associated with biota sample collection
and analysis. Despite the relative abundance of site-specific field data to characterize ecological risk at RMA,
the need to work with data from sampling programs designed for other purposes (e.g., to establish nature and
extent of contamination) may have been less man ideal for the estimation of exposure soil concentrations and
BMFs. It is difficult to know if the use of these data resulted in an over- or underestimation of potential risks to
biota. The biota species sampled on RMA were chosen from species that best represented the uptake of
contaminants from environmental media and the subsequent transfer, via food consumption, through food
chains to top predators. Uncertainty is associated with the use of these biota samples to derive RMA-specific
BMFs. Some uncertainty is also associated with the more scattered peripheral abiotic sampling where
heterogeneous soil contamination occurs, and where detection limits, in some cases, exceeded the risk-based
concentrations. These factors, along with lesser sampling density and little collocation of tissue and soil
samples, added to the uncertainties associated with the chemical database.
6.3.2.2 Exposure Pathways
Exposure pathways were selected to include the predominant pathways of exposure believed to exist at RMA.
Those selected for the food-web model included food consumption, dermal exposure to surface water by
organisms, ingestion of water by some terrestrial organisms, and sediment and soil ingestion by some aquatic
and terrestrial organisms. Exposure pathways excluded from the food-web model included inhalation of
contaminant vapors and particulates and dermal exposure to contaminants from soil contact. These exposure
pathways are implicitly contained in the BMP because measured tissue concentrations (from sampled biota
species) are the result of cumulative exposure by all pathways. Additional uncertainties related to the exposure
pathways are presented in Section 6.3.2.4.
6.3.2.3 Exposure Concentrations
Most of the uncertainty regarding exposure concentrations centers on the estimated exposure area
concentrations used to calculate terrestrial risk. Aquatic risk was estimated directly from measured tissue
concentrations and therefore was not based on quantitative exposure concentrations in aquatic media.
Terrestrial tissue concentrations, dose, and risk are theoretically dependent on exposure soil concentrations
(ESCs), i.e., the concentration in soil that is bioavailable and accessed by an individual during exposure
activity. The ESC is, for all practical purposes, unverifiable in the field; therefore, it is represented by
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6.0 Summary of Site Risks
estimated exposure area soil concentration, i.e., the average soil concentration in a specified depth profile
within a circular species-specific exposure area. Two types of uncertainty occur when applying ESC to
estimate risk. "Representation uncertainty" refers to the uncertainty in adequately representing spatial and
temporal scales of the ESC by exposure area soil concentration, and "estimation uncertainty" refers to the
uncertainty in analytically estimating the exposure area soil concentration based on available data.
Representation uncertainty explains the difference between true exposure concentration for an individual and
the exposure area concentration for a typical (mean) individual. Unfortunately, representation uncertainty is for
all practical purposes unquantifiable and irreducible, because the detailed information on individual organisms
(and their prey) required for its calculation cannot be practically obtained. Estimation uncertainty explains the
differences between the true exposure area soil concentration in a given area or for a given individual, and the
estimated exposure area soil concentration based on available sampling and analytical data.
The empirical mathematical constant used to relate exposure area soil concentration to tissue concentration is
the BMP. BMF is therefore defined as a correlation based on the variable exposure area soil concentration and
not on actual exposure soil concentration. The BMF values determined purely from literature data, rather than
site-specific data from RMA, will describe the relationship between tissue concentration and a different dose-
based quantity than ESC, and therefore may create more or less bias if used with ESC to predict risk at RMA.
Uncertainty is also associated with the BMF based on the use of site-specific information (e.g., RMA-soil and
biota data collected at different times and locations and for various purposes). The uncertainty associated with
the exposure concentration, including the estimation of BMFs, will be further ascertained by review of the
findings gathered from the SFS and the ongoing USFWS biomonitoring studies.
6.3.2.4 Ecological Toxicity Estimates
MATC and TRY uncertainty was incorporated quantitatively by use of UFs as discussed in Section 6.2.3. The
UFs were applied to add a margin of safety to the extrapolated toxicity measures. The UF protocol included
factors to account for four categories of uncertainty: intertaxon variability, study duration, toxicity effect levels
(study endpoints), and other modifying factors (including nine subcategories) that were multiplied to arrive at
the total estimated uncertainty.
In addition to the uncertainty incorporated in the UFs are potentially unrecognized or unquantifiable sources of
uncertainty. These include the following:
• Representativeness of toxicity endpoint tissue concentration data from one species relative to other
species in the trophic box
• Differences in metabolic rate, body size, and physiology between test and target species
• Differences in feeding habits and behavioral patterns in test v. target species
• Differences in the life stage of the organisms tested v. those exposed
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• Seasonal differences in response to toxicants (e.g., "fat" versus "lean" times)
• Difficulty in adequately estimating exposure concentrations (including environmental variability in
time and space)
• The possibility that exposed organisms may avoid, or be attracted to, contaminated media (e.g.,
pesticide-debilitated prey) and so may not show effects seen in laboratory tests (Suter 1993)
• Inability to quantify the other stresses that biota may face (e.g., climate, food supplies, background
levels of toxicants, habitat disturbance, and other manmade causes)
• The possibility that exposure pathways, in addition to ingestion, are significant
• The fact that there are no standard measures of effect, patterns of dosing, durations of exposure, etc.,
so comparison across studies/ecosystems is obscured or confounded
6.3.2.5 Risk Estimates
Toxicological effects from multiple chemicals were assumed to be additive, consistent with the risk assessment
procedures used for human health. This assumes independence of action, i.e., no net synergistic or antagonistic
effects, since these effects are poorly understood with the limited toxicological data available. This practice of
additivity without a toxicological basis (i.e., common mechanism of action or target organ effect) is protective
but scientifically questionable; however, some means of evaluating the potential cumulative effects of exposure
was required and EPA guidance requires such an approach in the absence of site-specific data on additivity.
Hence, the individual HQs for each COC were summed to estimate the total risk (HI) for each trophic box. It is
difficult to determine whether this procedure over- or underestimated risks to biota. As noted in the IEA/RC
report, a range of potential risk was presented for the bioaccumulative COC because three different BMFs were
employed. Because of the overall uncertainty associated with each of the parameters incorporated in the food-
web model and the toxicity threshold values, it is difficult to state with certainty at this time which of the three
BMF approaches best estimated risk to biota at RMA. Additionally, it is possible that actual residual risk to
biota of an excessive nature may occur in some cases following remediation based on the uncertainty associated
with the food-web risk modeling process and its application to delineated areas proposed for remediation.
Again, the uncertainty associated with the risk estimates will be further ascertained by review of the findings
gathered from the SFS and the ongoing USFWS biomonitoring studies.
6.3.2.6 Ecological Measurement Endpoints
The presence of potential ecological risk was given further perspective by considering it together with available
field data on ecological endpoints. The available data on ecological status and health used to evaluate
ecological endpoints are also subject to uncertainty. In this context, uncertainty results from the following:
• The short-term nature of many of the studies relative to the cycles of natural variability
• Estimation of quantitative ecological parameters at levels of precision that may not be biologically
and/or statistically significant and/or use of endpoints that may not have been sensitive enough to
discern the various potential human health risks to biota
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• Study designs that did not precisely and quantitatively correlate ecological parameters with parameters
related to contaminant concentrations
• Study designs that did not precisely quantify all parameters that might have positively or negatively
affected the ecological data
Appendix E of the IEA/RC report presents a detailed discussion on the assumptions, limitations, and
uncertainties associated with each of the uncertainty categories listed above.
6.4 Conclusions
Both the human health and the ecological risk assessment results are based on probabilistic methodologies. The
probabilistic methods account for the variability in literature and field data for the various parameters used to
quantify exposure and risk and at least partially reflect the uncertainty associated with these parameters. The
use of this methodology and the discussions of uncertainty increases the understanding the risk characterization
by clarifying the uncertainties associated with the input values and their implications on estimated risks.
The results of the risk assessment, as presented in the IEA/RC report, indicate that potential risks exist for both
human and ecological receptors. The contaminants that are the major contributors to overall potential risks are
similar for both receptor groups, i.e., the OCPs. Likewise, the areas that pose the greatest potential risks to both
receptor groups are in the central core region of RMA. It is very important to remember that the potential risks
presented in this report are based on current and historical contamination evaluated under present or future
land-use scenarios. However, data from some of the areas at RMA that have undergone interim remediation
(e.g., capping to eliminate possible exposure pathways for receptors) were not revised to reflect the
remediation; the actual risks are, therefore, likely to be lower than the risks presented in the IEA/RC report.
Areal extents of biota remediation that are needed to reduce or prevent excessive risks to ecological health are
not completely known at present, but will be further refined as part of remedial design and incorporate ongoing
ecotoxicological evaluations by the BAS. Recommendations regarding the nature and extent of excessive risks
to biota will be presented by the BAS to RMA risk managers for inclusion in soil remedial actions to reduce
risks to acceptably healthy levels in accordance with EPA Superfund guidance, the Rocky Mountain Arsenal
National Wildlife Refuge Act, and the selected remedy.
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this ROD, may present an imminent and substantial endangerment to public health,
welfare, or the environment.
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FOSTER WHEELER ENVIRONMENTAL CORPORATION
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Land-Use
Options
Land-Use
Scenarios
Predominant
Receptor
Populations
(Associated
activities)
Maximally
Exposed
Subpopulations
Workers
(Office work,
retailing)
Refuge
Workers
, Biological
Workers <
(Subpopulation
due to high
potential for
extensive soil
exposure)
Regulated Visitors
(Bus tours, research)
Casual Visitors
(Picnicking, bird
watching, photography)
; Regulated/Casual
Visitors from Local
Neighborhoods ,
(Subpopulation due to
potential for frequent
visits to flMA
compared to general
visitor populations)
Recreational
Visitors
(Jogging, athletics,
child play)
,
Recreational Visitors
,,' from Local
Neighborhoods
(Subpopulation due to
potential for frequent
visits to RMA
,, compared to, general
Visitor populations)
1 - Receptor populatlons/subpopulatlons shown In
shaded boxes were evaluated In this risk assessment
Figure 6.1-1
Projected Land-Use Scenarios for RMA1
RMA ROD 6.96 jb
Rocky Mountain Arsenal
Prepared by: Foster Wheeler Environmental Corporation
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Primary Secondary
Primary Release Secondary Release Direct
Sources Mechanisms Sources Mechanisms Pathways
Human Receptors
Biological Commercial
Worker Worker
RegulateoV
Industrial Recreational Casusl
Worker Visitor Visitor
Inhalation3
Boundary
Containment
Systems and
Intercept
Pump and
Treatment
Systems
No Receptors
Ingestlon4
Inhalation
DermaH
Contact
Ingestlon
Dermal
Contact
1 - Building, Equipment, and Storage Sites Include only the soils present
at these sites, not the structures themselves.
2 - Isolated Contamination Sites are not generally considered sources
In the sense that they could provide releases to the environment.
3 - Enclosed space vapor inhalation evaluated for commercial and
Industrial populations only. Open space vapor Inhalation evaluated
for all populations except commercial workers.
4 - Only ephemeral lake sediments evaluated.
RMA ROD 6.96 jb
Figure 6.1-2
RMA Site Conceptual Model
for Human Receptors
Rocky Mountain Arsenal
Prepared by: Foster Wheeler Environmental Corporation
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Legend
RMA Boundary
SAR Site Boundary1
Munitions Testing
Agent Storage
Lake Sediments
Dachas/Drainage- Areas
Basins (A-F)
Sewer Systems
Disposal Trenches
Sanitary Landfills
time Basins
South Plants
Burled Sediments/Ditches
Section 36 Balance of Areas
Burlat Trenches
RMA Balance of Areas2
Section Number
'Study Area Report
(«• Remedial Investigation Summary
Report, Ebosco 1992o).
2RMA Balance of Areas sH» designation
Includna all RMA areas not shaded.
-N-
Prepared for; U.S. Army Program Manager for
Rocky Mountain Arsenal
June 1996
Figure 6.1-3
RMA Site Designations used In the HHRC
Rocky Mountain Arsenal
Prepared by: Foster Wheeler Environmental Corporation
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RMA Boundary
SAR Site Boundary1
CR > 10
1Cf
CR < 1
-------
Leqend
RMA Boundary
SAR Site Boundary'
EH Hl > 10
I"""] 1 < HI £ 10
I I COCs Reported Below CRLs
'-• Section Number
'Study Area Report (see Remedial
Investigation Summary Report,
Ebasco 1992a).
2Based on RME exposure parameters
and Cr«p,upper for 0-ft to 1—ft
depth interval.
-N-
A
1 SCO 0 1 SCO 3000 F»«t
Prepared for: U.S. Army Program Manager for
Rocky Mountain Arsenal
Figure 6.1-5
Total Site Hazard Indices for Biologica
Worker,2 Horizon 0
Totter Wh**l«r Environmental Corporation
June 1996
-------
Biological Worker*
Recreational Visitor*
Regulated/Casual Visitor*
Industrial Worker**
Commercial Worker**
90%
* Open Space Receptor
"Economic Development Receptor
% Sites with B % Sites with D % Sites with
Cancer Risk > 10"4 1
-------
1
Percent of Sites
isi at
2 I
Total
Incremental
u
3
I"
Total
v £P
a
A *
a^
*!
(O
3
0)
Incremental
&
I
Total
Incremental
I
I.
Total
o »
Incremental
I
I
Total
n
a
Incremental
-------
-------
Legend
RMA Boundary
SAR Slt» Boundary1
Human Health Exceedanoa Ar«a
Conc«r Risk ^ 10E-4
"; Section Number
'Study Area Report (see Remedial
Investigation Summary Report,
Eboseo 1992a).
2Based on RME exposure parameters
and Cmax on boring by boring basis
for 0-ft to 1-ft depth Interval.
*
-N-
n
1500 3O05 Fe«I
Prepared fon U.S. Army Program Monag«r for
Rocky Mountain Ars«nal
Figure 6.1-9
Human Health Carcinogenic
Exceedance Areas,2 Horizon 0
Foster WhMler Environmental Corporation
Juni 1996
-------
Legend
•—•"" RMA Boundary
SAR Site Boundary1
Human Health Exceedance Area
Cancer Risk S 1 OE-4
5 Section Number
'Study Area Report (see Remedial
Investigation Summary Report,
Ebasco 1992a).
2Based on RME exposure parameters
and Cmaxon boring by boring basis
for 0-ft to 10-ft depth Interval.
-N-
ft
Pc«par«d for: U.S. Army Program Manager for
Rocky Mountain Arsenal
Figure 6.1-10
Human Health Carcinogenic
Exceedance Areas,2 Horizon 1
Foster Wh««l«r Envlronmvntal Corporation
Jun> 1996
-------
Legend
RMA Boundary
SAR Site Boundary'
Human Health Exceedance Area
Chronic HI 2: 1.0
Section Number
'Study Area Report (see Remedial
Investigation Summary Report.
Ebasco 1992a).
2Based on RME exposure parameters
and Cmax on boring by boring basis
for 0-ft to 1-ft depth Interval.
-N-
n
1500 JOOO Fact
Prepared for: U.S. Army Program Manager for
Rocky Mountain Arsanal
Figure 6.1 -1 1
Human Health Noncarcinogenic
Exceedance Areas,2 Horizon 0
Foilar Whaeler Environmental Corporation
Jun. 1996
-------
gend
RMA Boundary
SAR Site Boundary'
Human Health Exceedance Area
Chronic HI a. 1.0
Section Number
'Study Area Report (se» Remedial
Investigation Summary Report,
Ebasco 1992a).
2Based on RME exposure parameters
and C max on boring by boring basis
for 0-ft to 10-ft depth Interval.
*
1500 3OCD F«*t
Prspared for: U.S. Army Program Manogor for
Rocky Mountain Arttnal
Figure 6.1-12
Human Health Noncarclnogenic
Exceedance Areas,2 Horizon 1
Foliar Wh««tar Environmental Corporation
Junt 1996
-------
Legend
RMA Boundary
SAR Site Boundary1
Human Health Exceedance Area
Cancer Risk 5 10E-4,
Chronic HI k 1.0, or Acute HI i 1.0
Section Number
'Study Area Report (see Remedial
Investigation Summary Report,
Eboseo 1992a).
2Based on RME exposure parameters
and Cmaxon boring by boring basis
for 0-tt to 1 -ft depth Interval.
-N-
1500 3OOO F
Prepared for U.S. Army Program Manager for
Rocky Mountain Arsenal
Figure 6.1-13
Human Health Exceedance Areas?
Horizon 0
Foster Whaeler Environmental Corporation
Jun« 1996
-------
Legend
RMA Boundary
SAP Site Boundary
Human Health Exceedance Area
Cancer Risk 2 10E-4,
Chronic HI i 1.0, or Acute HI £ 1.0
Section Number
'Study Area Report (sea Remedial
Investigation Summary Report,
Ebosco 1992a).
2Based on RME exposure parameters
and C max on boring by boring basis
for 0-ft to 10-ft depth interval.
-N-
Prepared for: U.S. Army Program Manager for
Rocky Mountain Arsenal
Figure 6.1-14
Human Health Exceedance Areas?
Horizon 1
Foiter Wheetor Environmental Corporallon
June 1996
-------
*
J
i
Legend
SAR Site
Section Number
Section Line
Drainage
Rood
Railroad
. Sample Exceeds Acute Criteria
Hl*£ 1.0,
0—1 foot depth interval
Cumulative HI developed using
deterministic exposure parameters
presented in Table 6.1-6
on environmental soil data, for all
COCs with acute PPLV values
(Table 6.1-19)
Scale In
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Araenal
Jun* 1996
Rgure 6.1-15
Acute Exceedance Sample Locations
Rocky Mountain ArMnal
Prepared by: Fott«r Wlntlti' Envtronmtntaf Coro.
-------
Primary
Sources
Primary
Release
Mechanisms
Secondary
Sources
Secondary
Release
Mechanisms
Direct
Pathways
Biota Receptors
Dust and/or
Volatile
Emissions,
and/or
Aerosol
Dispersion
Inhalation
Terrestrial
Plants Animals Aquatic
NA
NA
Direct Contact
tngostlon
HA
NA
NA
NA
NA
NA
Direct Contact
IngMUon
NA
NA
NA
Direct Contact
Ingeatlon
NA
NA
NA
Direct Contact
IngeaUon
NA
NA
NA
1 Building, Equipment, and Storage Sites Include only the soils
present at these sites, not the structures themselves.
2 Isolated Contamination Sites are not generally considered sources
In the sense that they could provide releases to the environment.
3 Only cottonwoods are expected to reach groundwater.
NA-Not applicable.
Inhalation
NA
Figure 6.2-1
RMA Site Conceptual Model
for Ecological Receptors
RMA ROD 6.96 jb
Rocky Mountain Arsenal
Prepared by: Foster Wheeler Environmental Corporation
-------
Legend
1 trophic box with HI > 1
3-4 trophic boxes with HI > 1
\".t>" 5-7 trophic boxes with HI > 1
C/ loke
31 Section Number
Section Une
I
i
Seal* In F««t
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arwnal
June 1996
Figure 6.2-2
Number of Trophic Boxes wKh Soil Hazard
Indices Greater than 1.0 for All COCs
Combined Based on the Shell Approach
Rocky Mountain ArMnol
Prepared by? Foeter Wheeler Envlronmeiilul Covt
-------
Legend
31
1 trophic box with Ht > 1
a-4 -trophic boxes with HI > 1
5-7 trophic boxes with HI > 1
Lake
Section Number
Section Une
»
i
Seal* In Fwt
Prepored for:
U.S. Army Program Managtr
for Rocky Mountain Arsenal
June 1996
Rgure 6.2-3
Number of Trophic Boxes with Soil Hazard
Indices Greater than 1.0 for Aldrin/0i»ldrin,
DDT/OOE. and Endrin Combined Bated on
the Shell Approach
Rocky Mountain VMnot
Praparad by: Fnttr WhMfw Environmwlnt Cam.
-------
I
I
Legend
EPA Approach
Arny and EPA Approaches
Arny and Shell and EPA Approaches
Colors thow which approaches result in HO > 1
in the oraas indicated
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arsenal
June 1996
Figure 6.2-4
Mdrin/Dieldrin Hazard Quotient Map (HQ>1)
for the Great Homed Owl Trophic Box Based
on Exceedance of TRV and using the Army,
EPA, and Shell Approaches
Rocky Mountain Arsenal
Prtporad by: Foster Whttlsr EmiroiwnenUil Corp.
-------
Legend
EPA Approach
|f Shell and EPA Approaches
Arny and Shell and EPA Approaches
Colon show which approaches resuR In HQ > 1
in th« areas Indicated
31 Section Number
Section Une
s
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arsenal
June 1996
Figure 6.2-5
AMrfn/DieWrin Hazard Quotient Map (HQ>1)
for the SmaH Mammal Trophic Box Bated
on Exceedonce of TIN and using the Army.
EPA. and Shell Approaches
-------
Legend
Areo of Dispute and Prey
Study Area based on MATC
Biota Risk Area1
Human Health Exceedance Area
(Cancer Risk i 1.0E-4; Chronic
or Acute HI i 1.0)
SAR Site Boundary2
<:;/ Lake
31 Section Number
Section Une
1The area in which EPA, Shell, and Army
models all show small mammal HI > 1.0
for aldrin/dieldrin.
2 Study Area Report
(see Remedial Investigation
Summary Report, Ebasco 1992a).
I
I
Seal* ki F««t
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arsenal
June 1996
Figure 6.2-6
Human Health and Biota
Risk Areas
Rocky Mountain Arsenal
Prepared by-. Foster Whlilir Environmental Corp
-------
Legend
i < HI < ra
10 < HI < 100
HI 2 too
';,/" Lake
31 Section Number
Section Line
I
i
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arsenal
June 1996
Figure 6.2-7
Pre-Remediation Risk Distribution using
Army BMF for American Kestrel
Rocky Mountain Arwnal
Prepared by: Fottw Whettor Cnvfronmtfltol Coip
-------
i
Legend
a i < HI < 10
10 < HI < 100
HI > 100
'.,.r Lok«
3] Section Number
Section Une
»
i
Seal* In F««t
Prepared for
U.S. Army Program Manager
for Rocky Mountain Arsenal
June 1996
Figure 6.2-8
Pre-Remediotion Risk Distribution using
EPA BMP for American Kestrel
Rocky Mountain Ararat
Prepared by: Porter Ohetler Envfronmentol Corp
-------
Legend
i < HI < 10
to < HI < 100
HI 1 100
C." Loke
3] Section Number
Section Line
I
Seal* In r
-------
fl
I
Legend
i < HI < 10
10 < HI < 100
HI 2 wo
31
Lake
Section Number
Section Une
I
i
Seal* In Fxt
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arsenal
June 1996
Figure 6.2—10
Pre—Remediation Risk Distribution using
EPA BMP for Great Homed Owl
Rocky Mountain ATMIM!
Prepared by: Fatter Whedw Environmental Cotp
-------
Legend
i < HI < to
10 < HI < too
HI 2 100
',,./' Lake
31 Section Number
Section Une
I
i
Prepared for
U.S. Army Program Manager
tor Rocky Mountain Arsenal
June 1996
Figure 6.2-11
Residual Risk Distribution using
Army BMF for American Kestrel
Rocky Mountain Anew)
Prepared by: Foiter Wheeler Ei
-------
!
|
!
|
a
3
Legend
i < HI < 10
10 < HI < 100
HI > 100
'.,.,-" Lake
31 Section Number
Section Une
I
i
Prepared for
U.S. Army Program Manager
for Rocky Mountain Arsenal
June 1996
Figure 6.2-12
Residual Risk Distribution using
EPA BMF for American Kestrel
Rocky Mountain Arsenal
Prepared by; Foster Wheeler Environmental Com
-------
Legend
i < HI < 10
10 < HI < 100
HI 2 100
'."..,." Lake
31 Section Number
Section Line
»
$
Seal* In FMt
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arsenal
June 1996
Figure 6.2-13
Residual Risk Distribution using
Army BMP for Great Homed CM
Prepared by: Forter Wh««t«r Environmental Com
-------
28 \
/
33
j ;x:-i :! tm
4 i~:, :. WW
!:*:l f. «*i':
9
n
•'
Legend
JO
i < HI < io
10 < HI < 100
HI > 100
O" Laks
3] Soctlon Number
Sectfon Une
I
I
PreponwJ fort
U.S. Army Program Manager
for Rocky Mountain Arsenal
June 1906
Figure 6.2—14
Residual Risk Distribution using
EPA BMF for Great Homed Owl
Rocky Mountain Antnal
Prapartd by: Foster Wittier Environmental Cofp.
-------
Table 6,1-1 Chemicals of Concern for the IEA/RC Page 1 of 1
Aldrin
Arsenic
Benzene
Cadmium
Carbon Tetrachloride
Chlordane
Chloroacetic Acid
Chlorobenzene
Chloroform
Chromium
DBCP
DCPD
DDE
DDT
1,2-Dichlororethane
1,1 -Dichloroethylene
Dieldrin
Endrin
HCCPD
Isodrin
Lead
Mercury
Methylene Chloride
1,1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
TCE
TO8/1506G.DOC
-------
Table 6.1-2 Soil Horizons and Exposure Pathways Evaluated for the HHRC
Page 1 of 1
Open Space Option Receptor
Soil Horizon
Surficial Soil
Horizon 0
Horizon 1
Horizon 2
Depth Interval
0-2 inches'
0-1 ft2
0-10 ft2
>10 ft-Groundwater2
Biological Worker
Dir
Dir
Dir, Ind
(Open Space)
Ind
(Open Space)
Local Neighborhood
Regulated/Casual and
Recreational Visitor
Dir
Dir
Dir
(Open Space)
Not Evaluated
Economic Development Option Receptor
Industrial Worker
Dir
Dir
Dir, Ind
(Open and Enc. Space)
Ind
(Open and Enc. Space)
Commercial Worker
Dir
Dir
Dir, Ind
(Enc. Space)
Ind
(Enc. Space)
1 Risks for this depth horizon were calculated on a boring-by-boring basis using results of surficial soil samples collected in areas peripheral to designated sites. The
surficial soil interval (0-2 inches) is not a subset of Horizon 0 (0-1 ft).
2 Cumulative risks for these soil horizons were calculated on both a site-specific basis (representing both direct and indirect pathway exposures) and a boring-by-boring
evaluation (representing direct exposure pathways only).
Dir Denotes direct soil exposure pathway evaluation (soil ingestion, dermal contact, and particulate inhalation). Dermal contact with metals in soil was not evaluated for any
receptors due to negligible contaminant absorption from this exposure route.
Ind Denotes indirect vapor inhalation pathway evaluation for open space and/or enclosed space (e.g., enclosed basement structures). Both open and enclosed space soil vapor
inhalation e
Horizon 0.
rma\1577G.DOC
-------
Table 6.1-3 Time-Dependent and
Parameter
Exposure Time (TM) (hours/day)
Reg/casual visitor
Recreational visitor
Biological worker
Commercial worker
Industrial worker
Exposure Frequency (DW) (days/year)
Reg/casual visitor
Recreational visitor
Biological worker
Commercial worker
Industrial worker
Exposure Duration (TE) (years)
Reg/casual visitor
Recreational visitor
Biological worker
Commercial worker
Industrial worker
Basement
Length (m)
Width (m)
Ventilation Flow Rate (cm3/sec)
Other Parameter Values
Distribution
Family
Lognormal
Lognormal
Fixed Value
Normal
Normal
Lognormal
Lognormal
Normal
Normal
Normal
Lognormal
Lognormal
Truncated Normal
Lognormal
Lognormal
Uniform
Uniform
Mean
2.47
1.8
8
7.42
7.42
34.9
63.14
225
236
236
10.1
10.1
7.18
4.38
4.38
10
8.5
Triangular 617500
Value
50%
1.87
1.38
7.42
7.42
29.6
43.3
225
236
236
5.45
5.45
7.18
2.32
2.32
10
8.5
617500
Page 1 of 1
95%
6.34
4.96
12.8
12.8
76.1
181
242
241
241
33.8
33.7
18.7
14.8
14.8
16.3
13.45
1008960
Percent Organic Carbon (fraction)
(Aquatic) in Sediments
Percent Organic Carbon (fraction)
(Terrestrial) in Sediments
Lognormal 0.1197716 0.1039339 0.2496338
Lognormal 0.0038779 0.003735 0.0058623
Soil Density
Soil Porosity (fraction)
Soil Temperature (celsius)
Soil Moisture (unitless)
Respiratory Deposition
Vapor (fraction)
Paniculate (fraction)
Normal
Normal
Fixed Value
Exponential
Fixed Value
Fixed Value
1.45315
0.45164
9.9
0.07099
1
0.85
1.45315 1.752022
0.45164 0.5644193
0.04921 0.2126
rma\1565G.DOC
-------
Table 6.1 -4 Chemical-Specific Parameter Values
Page 1 of 4
Chemical
Molecular Molecular Soil/Water Partition
Weight Diffusivity Coefficient (L/kg)
(g/mole) (cmVsec) Mean 50% 95%
Vapor Pressure (ATM)
Mean 50% 95%
Henry's Law Constant
(unitless)
Mean 50% 95%
Aldrin
Arsenic
Benzene
Cadmium
Carbon
Tetrachloride
Chlordane
Chloroacetic
Acid
Chlorobenzene
Chloroform
Chromium (VI)
DDE
DDT
DBCP
1,2-Dichloro-
ethane
1,1-Dichloro-
ethylene
DCPD
Dieldrin
Endrin
HCCPD
F 364.3 F 0.0407 A 298100 151800 1027000
F 74.92 F NA A 179.9 55.76 691
F 78.11 F 0.0819 A 19034 158.1 461.3
F 112.4 F NA A 169.9 59.2 645.2
F 153.8 F 0.0750 A 513 457.1 .1007
F 409.8 F 0.0404 A 280900 156900 925600
F 94.5 F NA A 1.787 1.66 3.125
F 112.5 F 0.0676 A 611.3 508.9 1378
F 119.4 F 0.0834 A 86.01 81.29 141.3
F 52 F NA A 20.91 11.16 70.52
F 318 F 0.00440 A 667800 579500 1392000
F 354.5 F 0.0423 A 1425000653400 5099000
F 236.4 F 0.0600 A 310.2 245.4 756.5
F 98.96 F 0.0856 A 38.45 36.17 64.31
F 96.95 F 0.0744 A 63.13 59.57 104.4
F 132.2 F 0.0562 A 274300 153300 904200
F 380.9 F 0.0416 A 64170 42190 190300
F 380.9 F 0.0416 A 201600 140100 569900
F 273 F 0.0522 A 274300 153300 904200
A 5.84E-08 2.78E-08 2.07E-07
NA
0.104
NA
NA
NA
0.107 0.1514207
NA NA
E 0.124 0.124 0.159
A 1.76E-07 4.14E-08 6.79E-07
B 0.0004323 0.0004323 0.0008136
C 0.0151 0.01518330.0166427
E 0.241 0.241 0.3084536
NA NA NA
E 8.69E-09 8.69E-09 1.07E-08
A 4.82E-10 3.41E-10 1.34E-09
B 0.0053025 0.0053025 0.0099803
E 0.0825 0.0825 0.122
A 0.763 0.763 0.8791
B 0.009292 0.009292 0.0174892
A 3.44E-09 1.38E-09 1.27E-08
D 2.50E-09 2.48E-09 4.62E-09
E 0.000107 0.000107 0.0001481
D 0.000306 0.0003033 0.0005831
NA NA NA
E 0.00533
NA
0.00533
NA
0.007074
NA
E 0.0237 0.0237 0.0356600
A 0.0002760 0.0001186 0.0010061
A 1.28E-08
E 0.00363
E 0.0031
NA
D 7.35E-04
D 3.49E-05
A 6.61E-04
8.36E-09
0.00363
0.0031
NA
7.28E-04
3.47E-05
6.55E-04
3.81E-08
0.0044410
0.0042152
NA
1.41E-03
6.03E-05
1.27E-03
A 0.0033426 0.0031828 0.0053260
A 0.01598 0.01485 0.02792
A 0.0539400 0.0330400 0.168400
D 3.51E-05 3.48E-05 6.85E-05
D 4.71E-06 4.67E-06 8.81E-06
A 0.0225900 0.021068 0.0389100
ma\!566G.DOC
-------
Table 6.1-4 Chemical-Specific Parameter Values
Page 2 of4
Chemical
Isodrin
Lead
Mercury
Methylene
Chloride
1,1,2,2-Tetra-
chloroethane
Tetrachloro-
ethylene
Toluene
TCE
Molecular
Weight
(g/mole)
F
F
F
F
F
F
F
F
364.9
207.2
200.6
84.94
167.9
165.9
92.13
131.4
Molecular
DifTusivity
(cm2/sec)
F 0.407
F NA
F NA
F 0.0958
F 0.0958
F 0.00798
F 0.0736
0.0749
Soil/Water Partition
Coefficient (L/kg)
Mean 50% 95%
A 298100
A 6386000
A 149.1
A 14.97
A 14.97
A 577.8
A 494.5
A 455.9
151800
3371
115.3
14.13
14.13
457.1
417.4
317.4
1027000
2012000
375.8
24.75
24.75
1409
1088
1287
A
C
C
E
C
E
Vapor Pressure (ATM)
Mean 50% 95%
5.84E-08
NA
NA
0.3347
0.00725
0.0207
2.78E-08
NA
NA
0.327
0.00725
0.0207
2.07E-07
NA
NA
0.5479
0.0100956
0.0282022
0.0323333 0.0328564 0.0399016
0.0826
0.0826
0.1.27
D
E
E
D
C
C
Henry's Law Constant
(unitless)
Mean 50% 95%
0.000306
NA
NA
0.00236
0.000415
0.0185
0.00625
0.0092333
0.000304
NA
NA
0.00236
0.000415
0.0184
0.0063042
0.0093961
0.000583
NA
NA
0.0035476
0.0005565
0.0334
0.0068655
0.0125647
rma\l566G.DOC
-------
Table 6.1-4 Chemical-Specific Parameter Values
Page 3 of 4
Chemical
Aldrin
Arsenic
Benzene
Cadmium
Carbon
Tetrachloride
Chlordane
Chloroacetic
Acid
Chlorobenzene
Chloroform
Chromium
(VI)
DDE
DDT
DBCP
1,2-Dichloro-
ethane
1,1-Dichloro-
ethylene
DCPD
Dieldrin
Endrin
HCCPD
Isodrin
Lead
Mercury
RAF Dermal (RfD)
Mean 50% 95%
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
B
0.00291
NA
0.775
NA
0.845
0.023
0.845
0.845
0.75
NA
0.022
0.022
0.845
0.845
0.845
0.022
0.0056
0.022
0.058
0.022
NA
NA
0.00291
NA
0.775
NA
0.845
0.023
0.845
0.845
0.75
NA
0.022
0.022
0.845
0.845
0.845
0.022
0.0056
0.022
0.058
0.022
NA
NA
0.00497
NA
0.9775
NA
0.9845
0.041
0.9845
0.9845
0.93
NA
0.04
0.04
0.9845
0.9845
0.9845
0.04
0.00956
0.04
0.076
0.04
NA
NA
RAF Dermal (CPF)
Mean 50% 95%
B 0.00291
NA
B 0.775
NA
B 0.845
B 0.023
NA
B 0.845
B 0.845
NA
B 0.022
B 0.022
B 0.845
B 0.845
B 0.845
NA
B 0.0056
NA
NA
NA
NA
NA
0.00291
NA
0.775
NA
0.845
0.023
NA
0.845
0.845
NA
0.022
0.022
0.845
0.845
0.845
NA
0.0056
NA
NA
NA
NA
NA
0.00497
NA
0.9775
NA
0.9845
0.041
NA
0.9845
0.9845
NA
0.04
0.04
0.9845
0.9845
0.9845
NA
0.00956
NA
NA
NA
NA
NA
B
B
B
F
B
B
B
B
B
F
B
B
B
B
B
B
B
B
B
B
B
B
RAF
Mean
0.45
0.71
0.805
1
0.84
0.805
0.84
0.84
0.84
1
0.805
0.805
NA
NA
0.84
0.805
0.8
0.805
0.805
0.805
0.65
0.545
Oral (RfD)
50% 95%
0.45
0.71
0.805
1
0.84
0.805
0.84
0.84
0.84
1
0.805
0.805
NA
NA
0.84
0.805
0.8
0.805
0.805
0.805
0.65
0.545
0.63
0.971
0.9805
1
0.984
0.9805
0.984
0.984
0.984
1
0.9805
0.9805
NA
NA
0.984
0.9805
0.98
0.9805
0.9805
0.9805
0.964
0.9545
B
B
B
B
B
B
F
B
B
B
B
B
B
RAF Oral (CPF)
Mean 50% 95%
0.45
0.71
0.805
NA
0.84
0.805
NA
NA
0.74
1
0.805
0.805
0.84
0.84
0.84
NA
0.8
NA
NA
NA
NA
NA
0.45
0.71
0.805
NA
0.84
0.805
NA
NA
0.74
1
0.805
0.805
0.84
0.84
0.84
NA
0.8
NA
NA
NA
NA
NA
0.63
0.971
0.9805
NA
0.984
0.9805
NA
NA
0.92
1
0.9805
0.9805
0.984
0.984
0.984
NA
0.98
NA
NA
NA
NA
NA
rma\1566G.DOC
-------
Table 6.1-4 Chemical-Specific Parameter Values
Page 4 of4
RAF Dermal (RfD)
Chemical Mean 50% 95%
Methylene
Chloride B 0.845
1,1,2,2-Tetra-
chloroethane B 0.845
Tetrachloro-
ethylene B 0.845
Toluene B 0.91
TCE B 0.845
0.845
0.845
0.845
0.91
0.845
0.9845
0.9845
0.9845
0.991
0.9845
RAF Dermal (CPF) RAF Oral (RfD)
Mean 50% 95% Mean 50% 95%
B 0.845
B 0.845
B 0.845
NA
B 0.74
0.845
0.845
0.845
NA
0.74
0.9845 B 0.84 0.84 0.984
0.9845 B 0.84 0.84 0.984
0.9845 B 0.84 0.84 0.984
NA B 0.88 0.88 0.988
0.92 B 0.84 0.84 0.984
RAF Oral (CPF)
Mean 50% 95%
B 0.84 0.84 0.984
B 0.84 0.84 0.984
B 0.84 0.84 0.984
NA NA NA
B 0.73 0.73 0.91
(A) Lognormal Distribution
(B) Uniform Distribution
(C) Triangular Distribution
(D) Uniform-Triangular Distribution
(E) Normal Distribution
(F) Fixed
(G) The cancer potency factor relative absorption factor differs from the reference dose relative absorption factor.
NA Not Applicable
nta\l566G.DOC
-------
Table 6.1-5 Summary of Data Sources for PPLV Direct and Indirect Equation Parameters
Page 1 of 3
Parameter
Data Source (s)
Basement Parameters
Area
Volume
Volume/Area Ratio
Depth
Ventilation Rate
Time for Air Exchange
Body Weight
Breathing Rate (BR, DINH, RB)
Density of Arsenal Soils
Dust Loading Factor (CSS)
Henry's Law Constant
Molecular Weight
Percent Organic in Aquatic Sediments
Fraction Organic Carbon in Soils
Professional Judgment
Professional Judgment
Professional Judgment
Professional Judgment
Commerce City and Denver 1988 Uniform Building Codes Handbook
Computed as function of ventilation and basement volume
OHEA-EPA 1989
—Exposure Factors Handbook
Professional Judgment (EPA 1985)
RMA-Specific
—Walsh 1988
—SCS 1987
General Literature
RMA-Specific
—Comprehensive Monitoring Program
General Literature
General Literature
RMA-Specific
—Walsh 1988
RMA-Specific
—Walsh 1988
ma\I564G.DOC
-------
Table 6.1-5 Summary of Data Sources for PPLV Direct and Indirect Equation Parameters
Page 2 of 3
Parameter
Data Source (s)
Refuge Worker Time-Dependent Variables
Relative Absorption Factor (RAF)
Dermal
Oral
Respiratory Disposition
Soil Covering
Soil Ingestion
Soil Moisture Content
Soil Temperature
Soil to Water Partition Coefficient (K^)
Normalized to Organic Carbon
RMA-Specific (Shell 1991)
—Shell/Army Refuge Worker Survey
General Literature
OHEA-EPA 1991
—Interim Guidance for Dermal Exposure Assessment
General Literature
General Literature
EPA 1982
—Air Quality Criteria for Paniculate Matter and Sulfur Oxides
(Denver specific data)
General Literature
Professional Judgment
OHEA-EPA 1991
—Interim Guidance for Dermal Exposure Assessment
General Literature
Professional Judgment
OSWER-EPA 1991a
—Risk Assessment Guidance (OSWER Directive)
RMA-Specific
—Comprehensive Monitoring Program
—Remedial Investigation for RMA
Regional Annual Average Temperature
General Literature
ma\l564G.DOC
-------
Table 6.1-5 Summary of Data Sources for PPLV Direct and Indirect Equation Parameters
Page 3 of 3
Parameter
Data Source (s)
Skin Surface Area (SX)
Total Soil Porosity
Vapor Pressure
Professional Judgment
EPA 1985
Calculated from soil and particle density
General Literature
ma\I5MG.DOC
-------
Table 6.1-6 RME Estimates For Acute Exposure
Parameter Name
Soil Ingestion
Breathing Rate
Dust Load Factor
Pulmonary Retention
Pulmonary Absorption
Daily Exposure Period
Annual Exposure Frequency
Lifetime Exposure Duration
Skin Surface Area
Soil Covering
Soil Matrix Factor
Dermal Absorption
Body Weight
Regulated/Casual Visitors
2-l/2yr 250mg/day
2-l/2yr 4.2l/min
0.042 mg/m3
0.75
1(1 00 percent)
8 hours
NA
NA
2-1/2 yr 2,100cm2
0.51 mg/cm2
1.0
0.0 1 (metals)
O.lO(organics)
Child: 10thpercentile(M&F)'
Recreational Visitors
2-1/2 yr 250mg/day
2-1/2 yr 8.3 I/min
0.042 mg/m3
0.75
1 (100 percent)
8 hours
NA NA
NA NA
2-1/2 yr 2,100cm2
0.51 mg/cm2
1.0
0.01 (metals)
0.10(organics)
Child: 10th percentileOVI&F)1
Commercial
Workers
100 mg/day
4.8 mVday
0.021 mg/m3
0.75
1(100 percent)
8 hours
NA
NA
1,120 cm2
0.11 mg/cm2
1.0
0.01 (metals)
O.lO(organics)
Adult: 70 kg
Page 1 of 1
Industrial
Workers
100 mg/day
20 mVday
0.042 mg/m3
0.75
1 (100 percent)
8 hours
NA
NA
3,200 cm2
1.5 mg/cm2
1.0
0.01 (metals)
0.10(organics)
Adult: 70 kg
NA Not Applicable.
' Determined from the average of the male and female 10th percentile bodyweights as summarized in OHEA-EPA (1989).
ima\l605G.DOC
-------
Table 6.1-7 RME Estimates For Subchronic Exposure
Page lof 1
Parameter Name
Soil Ingestion
Breathing Rate
Dust Load Factor
Pulmonary Retention
Pulmonary Absorption
Daily Exposure Period
Annual Exposure Frequency
Lifetime Exposure Duration
Q-Factor
Skin Surface Area
Soil Covering
Soil Matrix Factor
Dermal Absorption
Body Weight
Regulated/Casual Visitors
2-l/2yr
6yr
2-l/2yr
6yr
2-1/2 yr
6yr
250 mg/day
250 mg/day
4.2 1/min
13.3 1/min
0.042 mg/m3
0.75
1(1 00 percent)
8 hours
108 day/year
7 years
7 years
2,100cm2
2,500cm2
0.51 mg/cm2
1.0
0.01 (metals)
0.10 (organ ics)
Child: 10th percentileCM&F)'
Recreational Visitors
2-1/2 yr
6yr
2-1/2 yr
6yr
2-l/2yr
6yr
250 mg/day
250 mg/day
8.3 1/min
20.3 1/min
0.042 mg/m3
0.75
1 (100 percent)
8 hours
108 days/year
7 years
7 years
2,100cm2
2,500cm2
0.51 mg/cm2
1.0
0.01 (metals)
0.10(organics)
Child: 10th percentileCM&F)1
Commercial
Workers
100 mg/day
4.8 mVday
0.021 mg/m3
0.75
1(100 percent)
8 hours
253 days/year
7 years
7 years
1,120cm2
0.11 mg/cm2
1.0
0.01 (metals)
0.10(organics)
Adult 70 kg
Industrial
Workers
100 mg/day
20 m3/day
0.042 mg/m3
0.75
1 (100 percent)
8 hours
253 days/year
7 years
7 years
3,200 cm2
1.5 mg/cm2
1.0
0.01 (metals)
O.lO(organics)
Adult: 70 kg
NA Not Applicable.
1 Determined from the average of the male and female 10th percentile bodyweights as summarized in OHEA-EPA (1989).
rnia\l604G.DOC
-------
Table 6.1-8 Carcinogenic Dose-Response Data
Chemical
Aldrin
Arsenic
Benzene
Cadmium
Carbon Tetrachloride
Chlordanc
Chloroacetic Acid
Chlorobenzene
Chloroform
Chromium (VI)
DBCP
DCPD
.
DDE
DDT
1,2-Dichloroethane
1 , 1 -Dichloroethylene
Dieldrin
Endrin
HCCPD
Isodrin
Lead
Mercury
Methylene Chloride
1 , 1,2,2-Tetrachloroethane
Tetrachloroethylene
Weight of Evidence
Classification1
B2
A
A
Bl
B2
B2
ME3
D
B2
A
B2
NE
B2
B2
B2
C
B2
D
D
NE
B2
D
B2
C
B2
Exposure
Route
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Cancer Slope
Factor
(mg/kg/day)
1.7E+01
1.7E+01
1.75E+00
1.5E+01
2.90E-02
2.90E-02
NA2
6.30E+00
1.30E-01
5.25E-02
1.30E+00
1.30E+00
NA
NA
6.10E-03
8.00E-02
NA
4.20E+01
1.40E+00
2.40E-03
NA
NA
3.40E-01
3.40E-014
3.40E-01
3.40E-01
9.10E-02
9.10E-02
6.00E-01
1.80E-01
1.60E+01
1.60E+01
NA
NA
NA
NA
7.50E-03
1.60E-03
2.00E-01
2.00E-01
5.10E-02
1.80E-03
Page 1 of 2
Carcinogenic
Dose for 10"* risk
(mg/kg-day)
5.90E-08
5.90E-08
5.70E-07
6.70E-08
3.40E-05
3.40E-05
NA
1.60E-07
7.70E-06
1.90E-05
7.70E-07
7.70E-07
NA
NA
1.60E-04
1.20E-05
NA
2.40E-08
7.IOE-07
4.20E-04
NA
NA
2.90E-06
2.90E-06
2.90E-06
2.90E-06
1.10E-05
1.10E-05
1.70E-06
5.70E-06
6.20E-08
6.20E-08
NA
NA
NA
NA
1.30E-04
6.10E-04
5.00E-06
5.00E-06
2.00E-05
5.50E-04
rma/15070X>OC
-------
Table 6.1-8 Carcinogenic Dose-Response Data
Page 2 of 2
Chemical
Toluene
TCE
Weight of Evidence
Classification1
D
B2
Exposure
Route
Oral
Inhalation
Cancer Slope
Factor
(mg/kg/day)
1.10E-02
5.90E-03
Carcinogenic
Dose for 10"* risk
(mg/kg-day)
9.10E-05
1.70E-04
A = Human carcinogen.
B1/B2 = Probable human carcinogen.
BI = Indicates limited human data are available.
B2 = Indicates sufficient evidence in animals and inadequate or no evidence in humans.
C = Possible human carcinogen.
D = Not classifiable as a carcinogen.
NA denotes Not Applicable.
NE denotes no Weight of Evidence Classification Assigned.
Inhalation cancer slope factor for DDE not available. Value shown is direct extrapolation from oral pathway.
nna/1507G.DOC
-------
Table 6.1-9 Chronic Noncarcinogenic Dose-Response Data
Chemical
Aldrin •
Arsenic
Benzene
Cadmium
Carbon Tetrachloride
Chlordane
Chloroacetic Acid
Chlorobenzene
Chloroform
Chromium (VI)
DBCP
DCPD
DDE
DDT
1,2-Dichloroethane
1 , 1 -Dichloroethy lene
Dieldrin
Endrin
HCCPD
Isodrin
Route of Exposure
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral, water
Oral, food
Oral
NA
Oral
Inhalation
Oral
Inhalation /
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Page 1 of 2
Chronic RfD
(mg/kg-day)
3.00E-05
3.00E-051
3.00E-04
3.00E-041
NA2
NA
5.00E-04
I.OOE-03
7.00E-04
7.00E-041
6.00E-05
6.00E-051
2.00E-03
2.00E-031
2.00E-02
5.00E-03
l.OOE-02
l.OOE-021
5.00E-03
6.00E-07
2.00E-04
6.00E-053
3.00E-02
6.00E-05
NA
NA
5.00E-04
5.00E-041
NA
NA
9.00E-03
9.00E-031
5.00E-05
5.00E-05 '
3.00E-04
3.00E-041
7.00E-03
2.00E-05
7.00E-05
7.00E-05
im a/1508G.DOC
-------
Table 6.1-9 Chronic Noncarcinogenic Dose-Response Data
Page 2 of 2
Chemical
Lead
Mercury
Methylene Chloride
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
TCE
Route of Exposure
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation v
Chronic RfD
(mg/kg-day)
1.40E-03
4.30E-04
3.00E-04
9.00E-05 3
6.00E-02
8.60E-01
NA
NA
l.OOE-02
l.OOE-02 '
2.00E-01
I.10E-01 3
NA
NA
Inhalation RfD for chemical not available. Value shown is direct extrapolation from oral pathway.
NA denotes Not Available.
Inhalation RfD extrapolated from RfC, assuming inhalation of 20 cubic meters/day and body weight of 70 kg.
nna/1508G.DOC
-------
Table 6.1-10 DT Values For Acute and Subchronic Exposure
Page 1 of3
Contaminant
Aldrin
Arsenic
Atrazine
Benzene
Benzothiazole
BCHPD
Cadmium
Carbon tetrachloride
Chlordane
Chloroacetic acid
Chlorobenzene
Chloroform
CPMS
Chlorophenylmethyl sulfoxide
CPMS02
Chromium VI
Copper
DBCP
DDE
DDT
1,1-Dichloroethane
1,2-Dichlorethane
1 , 1 -Dichlorethylene
1 ,2-Dichloroethylene
DCPD
Dieldrin
DIMP
Dimethyl disulfide
Dimethylmethyl phosphonate
Acute
DtlNG DrENH
(mg/kg-day) (mg/kg-day)
l.OE-04
8.0E-03
l.OE-02
NA
NA
NA
4.0E-03
4.0E-01
6.0E-03
NA
2.0E-01
1.8E-01
NA
NA
NA
l.OE-01
NA
5.0E-03
NA
5.0E-04
NA
NA
2.0E+00
NA
NA
l.OE-04
8.0E-01
NA
NA
l.OE-04
2.9E-04
l.OE-02
NA
NA
NA
1.4E-01
1.8E-01
6.0E-03
NA
2.0E-01
4.3E-01
NA
NA
NA
l.OE-01
NA
5.0E-03
NA
5.0E-04
NA
NA
l.OE+00
NA
NA
l.OE-04
8.0E-01
NA
NA
Subchronic
DjING DrlNH
(mg/kg-day) (mg/kg-day)
l.OE-04
l.OE-03
5.0E-03
NA
NA
NA
5.0E-04
7.0E-03
6.0E-05
2.0E-02
2.0E-01
l.OE-02
NA
NA
NA
2.0E-02
NA
NA
NA
5.0E-04
l.OE-KJO
NA
9.0E-03
l.OE-01
3.0E-01
l.OE-04
8.0E-01
NA
NA .
l.OE-04
2.9E-04
5.0E-03
NA
NA
NA
5.0E-04
2.7E-02
1.4E-04
2.0E-02
5.0E-02
6.8E-03
NA
NA
NA
5.7E-06
NA
NA
NA
5.0E-04
l.OE+00
NA
2.3E-02
l.OE-01
6.0E-04
l.OE-04
8.0E-01
NA
NA
ima\I588GDOC
-------
Table 6.1-10 DT Values For Acute and Subchronic Exposure
Page 2 of 3
Contaminant
Dithiane
Endrin
Ethylbenzene
Fluoroacetic acid
HCCPD
Isodrin
Isopropylmethyl phosphonic acid
Isopropylmethyl phosphonate
Lead
Lewisite
Lewisite oxide
Malathion
Mercury(inorganic)
Methylene chloride
Methyl isobutyl ketone
NDMA
1,4-Oxathiane
Parathion
Sarin
Sulfur mustard
Supona
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
Thiodiglycol
Toluene
1,1,1 -Trichloroethane
1,1,2-Trichloroethane
TCE
Vapona
Acute
DrlNG
(mg/kg-day)
NA
2.0E-03
3.0E+00
NA
NA
NA
NA
NA
NA
NA
NA
2.0E-02
2.0E-01'
l.OE+00
NA
NA
NA
NA
NA
NA
NA
NA
2.0E-01
NA
2.0E-HH)
l.OE+01
6.0E-02
2.4E+00
NA
DT-INH
(mg/kg-day)
NA
2.0E-03
3.0E+00
NA
NA
NA
NA
NA
NA
NA
NA
2.0E-02
2.0E-01
4.9E+00
NA
NA
NA
NA
NA
NA
NA
NA
1.9E+00
NA
4.3E+00
4.0E-01
4.0E-02
4.3E-01
NA
Subchronic
DflNG DTINH
(mg/kg-day) (mg/kg-day)
NA
5.0E-04
l.OE+00
NA
7.0E-02
NA
NA
NA
NA
NA
NA
2.0E-02
3.0E-04
6.0E-02
5.0E-01
NA
NA
6.0E-03
NA
NA
NA
NA
l.OE-01
NA
2.0E+00
9.0E-01
4.0E-02
2.5E+00
NA
NA
5.0E-04
2.8E-01
NA
2.0E-04
NA
NA
NA
NA
NA
NA
2.0E-02
8.5E-05
8.5E-01
2.0E-01
NA
NA
6.0E-03
5.7E-07
NA
NA
NA
1.7E-01
NA
5.7E-01
2.8E+00
4.0E-02
2.5E+00
NA
nna\1588G.DOC
-------
Table 6.1-10 DT Values For Acute and Subchronlc Exposure Page 3 of 3
Acute Subchronic
DpING DrlNH I^ING DtlNH
Contaminant (mg/kg-day) (mg/kg-day) (mg/kg-day) (mg/kg-day)
M-xylene 4.0E+00 4.0E-KX) 4.0E-KX) l.OE+00
O,p-Xylene 4.0E+00 4.0E+00 4.0E-H)0 8.5E-02
Zinc . NA NA 2.0E-01 2.0E-01
NA Dose-response data not available from EPA.
DjING Allowable dose for ingestion
DTING Allowable dose for inhalation
nna\1588G.DOC
-------
Table 6.1-11 Summary of Chronic Cumulative Direct Soil PPLVs for the 5th Percentile1'2 Page 1 of 1
Receptor-Specific Soil PPLVs (Units: mg/kg)
Open Space Populations
Chemical
Aldrin
Benzene
Carbon Tetrachloride
Chlordane
Chloroacetic Acid*
Chlorobenzene*
Chloroform
DDE
DDT
DBCP
1,2-Dichloroethane
1 , 1 -Dichloroethylene
DCPD*
Dieldrin
Endrin*
HCCPD*
Isodrin*
Methylene Chloride
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene*
TCE
Metals (Indicator Level3)
Arsenic (IL = 10 ppm, >driving PPLV)
Cadmium (IL = 2.0 ppm)
Chromium (IL •= 40 ppm, >driving PPLV)
Lead* (IL = 40 ppm)
Mercury* (IL = 0. 1 ppm)
Biological
Worker
7.16E-01
1.18E+01
2.51E+00
3.72E+00
1.01E-HJ2
9.66E+02
4.82E+01
1.25E+01
1.35E+01
2.01E-01
3.23E+00
S.16E-01
3.69E+03
4.14E-01
2J2E+02
1.06E+03
S.24E+01
3.53E+01
1.45E+00
5.43E+00
9.46E+03
2.84E+01
4.17E+00
5.01E+01
7.52E+00
2.17E+03
5.74E+02
Regulated/
Casual Visitor
1.16E+01
5.76E+01
1.32E+01
5.39E+01
8.13E+02
6.95E+03
3.23E+02
1.77E+02
1.51E+02
I.17E+00
1.74E+01
2.82E+00
6.11E+04
6.45E+00
2.99E+03
1.47E+04
6.43E+02
2.06E+02
1.94E+00
3.57E+01
6.48E+04
1.78E+02
7.91E+01
8.S5E+02
1.29E+02
4.77E+04
9.85E+03
Recreational
Visitor
3.29E+00
1.30E+01
2.69E+00
1.09E+01
2.34E+02
2.55E+03
8.91E+01
3.05E+01
3.60E+01
2.52E-01
3.75E+00
7.33E-01
2.91E+04
1.96E+00
8.65E+02
6.16E+03
2.15E+02
4.58E+01
9.61E+00
6.26E+00
2.11E+04
3.98E+01
3.68E+01
2.17E+02
3.28E+01
2.65E-KW
5.49E+03
Economic Development
Populations
Industrial
Worker
3.02E+00
1.04E+01
233E+00
7.58E+00
7.71E+01
8.45E+02
4.84E+01
1.87E+01
3.61E+01
2.36E-01
3.39E+00
5.21E-01
6.65E+03
1.40E+00
3.18E+02
1.78E+03
7.39E+01
4.43E+01
1.49E+00
5.87E+00
7.22E+03
2.90E+01
2.60E+01
2.12E+02
3.23E+01
4.46E+03
1.24E+03
Commercial
Worker
4.71E+00
2.26E+02
5.14E+01
2.66E+01
1.88E+03
1.68E+04
1.11E+03
1.26E+02
9.58E+01
4.51E+00
7.07E+01
1.02E+01
5.83E+04
2.54E+00
U2E+03
1.67E+04
2.51E+02
7.78E+02
3.31E+01
1.30E+02
1.38E+05
6.27E+02
2.60E+01
1.87E+03
2.36E+02
7.06E+03
1.35E+03
Denotes a noncarcinogen. No asterisk denotes PPLV based on carcinogenic slope factors for both oral and inhalation pathways.
Cumulative direct PPLVs represent a cancer risk level of 10"6 for carcinogens; the PPLV at a 10"4 cancer risk is 100 times higher than the
values shown in this table. Values in bold face represent the driver PPLVs for the corresponding receptor population.
Summaries of dominant exposure pathways comprising the cumulative (5th percentile) direct PPLV are provided in Appendix Section B.4.1
of the IEA/RC report for each receptor population evaluated (Appendix Tables B.4.1-1 through B.4.1-5). As shown in these tables, the
majority of PPLVs listed above reflect the carcinogenic endpoint. Also, for most chemicals, dermal absorption was the driver exposure
pathway. The only exceptions were certain OCPs (aldrin, DDE, endrin, and isodrin), for which soil ingestion was the driver pathway, and
metals, for which ingestion or inhalation pathways were drivers.
Indicator level is the assumed background concentration for the inorganic COCs.
ma\1567G.DOC
-------
Table 6.1-12 Summary of Chronic Cumulative Direct Soil PPLVs for the 50th Percentile1 Page 1 of 1
Receptor-Specific Soil PPLVs (Units: mg/kg)
Open Space Populations
Chemical
Aldrin
Benzene
Carbon Tetrachloride
Chlordane
Chloroacetic Acid*
Chlorobenzene*
Chloroform
DDE
DDT
DBCP
1,2-Dichloroethane
1 , 1 -Dichloroethylene
DCPD*
Dieldrin
Endrin*
HCCPD*
Isodrin*
Methylene Chloride
1 , 1 ,2,2-TetrachIoroethane
Tetrachloroethylene
Toluene*
TCE
Metals (Indicator Level2)
Arsenic (IL = 10 ppm, >driving PPLV)
Cadmium (IL = 2.0 ppm)
Chromium (IL - 40 ppm, >driving PPLV)
Lead* (IL = 40 ppm)
Mercury* (IL = 0. 1 ppm)
Biological
Worker
4.27E+00
3.43E+01
7.69E+00
1.97E+01
2.19E+02
2.19E+03
1.91E+02
7.I3E+01
6.49E+01
7.24E-01
1.07E+01
1.57E+00
8.12E+03
2.4SE+00
6.42E+02
2.22E+03
1.48E+02
1.27E+02
S.16E+00
1.92E+01
2.04E+04
1.03E+02
2.64E+01
3.10E+02
4.72E+01
7 XI E+03
1.80E+03
Regulated/
Casual Visitor
1.10E+02
6.21E+02
I.28E+02
3.30E+02
2.84E+03
2.88E-HM
3.08E+03
1.28E+03
1.29E+03
1.24E+01
1.88E+02
2.94E+01
2.17E+05
5.73E+01
1.28E+04
6.12E+04
2.67E+03
2.04E+03
9.04E+01
3.64E+02
1.74E+05
1.84E+03
9.38E+02
1.24E+04
1.89E+03
2.37E+05
6.82E+04
Recreational
Visitor
9.43E+01
3.26E+02
6.75E+01
2.35E+02
1.31E+03
1.28E+04
1.66E+03
8.10E+02
1.01E+03
6.21E+00
9.14E+01
1.52E+01
2.09E+05
4.81E+01
6.72E+03
4.05E+04
1.56E+03
1.19E+03
4.55E+01
1.86E+02
9.02E+04
8.83E+02
9.02E-H)2
1.36E+04
2.16E+03
2.18E+05
6.81E+04
Economic Development
Populations
Industrial
Worker
1.52E+01
1.04E+02
1.94E-H)!
5.03E-K)!
I.67E+02
1.61E+03
4.58E+02
1.95E+02
2.20E+02
1.89E+00
2.99E+01
4.53E+00
1.66E+04
8.42E+00
6.81E+02
6.80E+03
1.55E+02
3.51E+02
1.32E+01
5.33E+01
1.46E+04
2.79E+02
1.38E+02
2.34E403
3.56E+02
1.68E+04
4.35E+03
Commercial
Worker
3.89E401
1.53E+03
3.05E+02
2.53E+02
2.60E+03
2.50E+04
7.48E+03
8.22E+02
9.01E+02
2.89E+01
3.99E+02
6.83E+01
1.33E+05
2.27E+01
3.41E+03
3.32E+04
7.76E+02
5.32E+03
1.97E+02
7.51E+02
1.76E+05
4.62E+03
2.44E+02
2.19E+04
4.21E+03
2.40E+04
5.96E+03
* Denotes a noncarcinogen. No asterisk denotes PPLV based on carcinogenic slope factors for both oral and inhalation pathways.
1 Cumulative direct PPLVs represent a cancer risk level of 10"6 for carcinogens; the PPLV at a 1O*4 cancer risk is 100 times higher than the
values shown in this table. Values in bold face represent the driver PPLVs for corresponding receptor population.
2 Indicator level is the assumed background concentration for the inorganic COCs.
ima\)610G.DOC
-------
Table 6.1-13 Summary of 5th Percentile Direct Single-Pathway PPLVS for the Biological Worker
Chemical Name
Aldrin
Benzene
Carbon Tetrachloride
Chlordane
Chloroacetic Acid
Chlorobenzene
Chloroform
DDE
DDT
DBCP
1 ,2-Dichloroethane
1,1-Dichloroethylene
Dicyclopentadiene
Dieldrin
Endrin
Hexachlorocyclopentadiene
Isodrin
Methylene Chloride
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
Trichloroethylene
Arsenic
Cadmium
Chromium
Lead
Mercury
Soil Ingestion SPPLV
7.64E-01
1.29E+02
8.14E+01
2.71E+01
3.98E+03
4.12E+04
4.58E+03
1.96E+01
3.02E+01
2.96E+00
1.13E+02
1.84E+01
3.72E+04
5.90E-01
2.43E+02
9.74E+03
1.02E+02
9.51 E+02
2.30E+01
6.05E+02
4.69E+05
1.41E+03
4.36E+00
3.47E+04
3.47E+05
2.22E+03
6.24E+02
Soil Inhalation SPPLV
9.56E+01
1.02E+04
1.20E+04
7.18E+02
3.74E+05
9.36E+05
I.12E+04
1.88E+03
1.84E+03
1.27E+05
6.97E+03
3.61E+03
4.24E+03
4.02E+01
3.76E+04
1.41E+03
4.42E+03
3.95E+05
1.51E+03
5.13E+05
l.OOE+06
1.08E+05
9.56E+01
5.01 E+01
7.52E+00
9.28E+04
7.17E+03
Dermal Absorption
SPPLV
1.30E+01
1.30E+01
2.59E+00
4.34E+00
1.04E+02
9.91 E+02
4.90E+01
3.53E+01
2.47E+01
2.16E-01
3.32E+00
5.31 E-01
1.20E+05
1.43E+00
6.47E+03
7.48E+03
1.10E+02
3.66E+01
1.55E+00
5.48E+00
9.75E+03
2.90E+01
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
Cumulative Direct
PPLV-CARC2
7.16E-01
1.18E+01
2.51E+00
3.72E+00
NA
NA
4.82E+01
1.25E+01
1.35E+01
2.01E-01
3.23E+00
5.16E-01
NA
4.14E-01
NA
NA
NA
3.53E+01
1.45E+00
5.43E+00
NA
2.84E+01
4.17E+00
5.01E+01
7.52E+00
NA
NA
Page 1 of 1
Cumulative Direct
PPLV-NONCARC2
7.12E+01
NA
3.63E+01
5.51 E+01
1.01 E+02
9.66E+02
4.41 E+02
NA
4.09E+02
9.75E+00
NA
4.52E+02
3.69E+03
5.77E+01
2.32E+02
1.06E+03
5.24E+01
3.11E+03
NA
5.47E+02
9.46E+03
NA
4.76E+02
5.29E+02
3.87E+01
2.17E+03
5.74E+02
Values reported as mg/kg. Values are 5th percentite PPLVs, based on a 10 risk level for carcinogens, and an HI of 1.0 for noncarcinogens. Values in bold face represent
the driver exposure pathway.
Where a chemical is both a carcinogen (CARC) and noncarcinogcn (NONCARC), the single-pathway PPLVs summarized represent the carcinogenic endpoint
RMA\I61IG.DOC
-------
Table 6.1-14 Summary of 5th
Chemical Name Sc
Aldrin
Benzene
Carbon Tetrachloride
Chlordane
Chloroacetic Acid
Chlorobenzene
Chloroform
DDE
DDT
DBCP
1 ,2-Dichloroethane
1 , 1 -Dichloroethylene
Dicyclopentadiene
Dieldrin
Endrin
Hexachtorocyclopentadiene
Isodrin
Methylene Chloride
1 , 1 ,2,2-Tetrathloroethane
Tetrachloroethylene
Toluene
Trichloroethylene
Arsenic
Cadmium
Chromium
Lead
Mercury
Percentile Direct
)il Ingestion SPPLV
6.36E+00
5.74E+03
3.29E+03
5.14E+01
5.30E+04
6.36E+05
8.26E+04
4.48E+02
7.98E+02
I.50E+02
5.57E-H)3
5.05E+01
3.85E+05
3.48E+01
9.83E+03
7.88E+04
2.02E+03
2.17E+04
2.70E+03
9.93E+03
1. OOE+06
2.06E+04
6.16E+01
3.96E+04
3.96E+05
2.75E+04
5.91E+03
Single-Pathway PPLVS
Soil Inhalation SPPLV
4.79E+02
8.62E+04
1.91E+05
5.67E+02
.OOE+06
.OOE+06
.21E+05
7.35E+03
.93E+04
.OOE+06
1.11E+05
5.65E+03
4.49E+04
6.24E+02
.43E+05
.50E+04
.07E+05
.OOE+06
5.03E+04
.OOE+06
.OOE+06
4.31E+05
9.15E+01
2.19E+02
3.28E+01
7.08E+05
7.70E+04
for the Recreational
Dermal Absorption
SPPLV
6.93E+00
1.30E+01
2.69E+00
1.41 E+01
2.35E+02
2.56E+03
8.39E+01
3.29E+01
3.78E+01
2.52E-01
3.75E+00
7.44E-01
1.05E+05
2.08E+00
9.55E+02
1.21E+04
' 2.41E+02
4.59E+01
1.94E+00
6.27E+00
2.21E+04
3.99E+01
OO.OE+00
OO.OE+00
OO.OE+00
OO.OE+00
OO.OE+00
Visitor1
Cumulative Direct
PPLV-CARC2
3.29E+00
I.30E+01
2.69E+00
1.09E+01
NA
NA
8.91E+01
3.05E+01
3.60E+01
2.52E-01
3.75E+00
7.33E-01
NA
1.96E+00
NA
NA
NA
4.58E+01
9.61E+00
6.26E+00
NA
3.98E+01
3.68E+01
2.17E+02
3.28E+01
NA
NA
Page 1 of 1
Cumulative Direct
PPLV-NONCARC2
4.63E+02
NA
8.65E+01
1.59E+02
2.34E+02
2.55E+03
1.17E+03
NA
1.62E+03
2.32E+01
NA
1.06E+03
2.91E+04
4.70E+02
8.65E+02
6.16E+03
2.15E+02
7.30E+03
NA
1.28E+03
2.11E+04
NA
5.84E+03
6.53E+03
3.55E+02
2.65E+04
5.49E+03
Values reported as mg/kg. Values are 5th perccntile PPLVs, based on a 10~* risk level for carcinogens, and an HI of 1.0 for noncarcinogens. Values in bold face represent
the driver exposure pathway.
Where a chemical is both a carcinogen (CARC) and noncarcinogen (NONCARC), the single-pathway PPLVs summarized represent the carcinogenic endpoint
ma\16l2O.DOC
-------
Table 6.1-15 Summary of
Chemical Name
Aldrin
Benzene
Carbon Tetrachloride
Chlordane
Chloroacetic Acid
Chlorobenzene
Chloroform
DDE
DDT
DBCP
1 ,2-Dichloroethane
1 , 1 -Dichloroethylene
Dicyclopentadiene
Dieldrin
Endrin
Hexachlorocyclopentadiene
Isodrin
Methylene Chloride
1 , 1 ,2,2-TetrachIoroethane
Tetrachloroethylene
Toluene
Trichloroethylene
Arsenic
Cadmium
Chromium
Lead
Mercury
5th Percentile Direct Single-Pathway PPLVS for the Regulated/Casual Visitor1
Soil Ingestion SPPLV
2.32E+01
4.05E+03
1.17E+03
2.91E+02
5.62E+04
7.37E+05
2.34E+04
3.66E+02
U1E+03
7.20E+01
1.24E+03
2.05E+02
l.OOE+06
9.24E+00
1.15E+04
2.48E+05
3.04E+03
1.33E+04
5.74E+02
2.52E+03
l.OOE+06
1.25E+04
1.03E+02
2.90E+04
l.OOE+06
5.01E+04
1.05E+04
Soil Inhalation SPPLV
3.68E+02
1.36E+05
9.73E+04
5.99E+03
l.OOE+06
l.OOE+06
7.49E+04
1.16E+04
1.56E+04
l.OOE+06
4.40E+04
2.28E+04
7.81E+04
3.17E+02
3.43E+05
2.24E+04
3.27E+05
l.OOE+06
2.00E+04
l.OOE+06
l.OOE+06
6.80E+05
3.43E+02
8.80E+02
1.29E+02
l.OOE+06
1.58E+05
Dermal Absorption
SPPLV
2.48E+01
5.85E+01
1.34E+01
6.69E+01
8.25E+02
7.07E+03
3.29E+02
3.52E+02
1.77E+02
1.19E+00
1.77E+01
2.86E+00
3.91E+05
2.28E+01
4.09E+03
5.18E+04
8.17E+02
2.09E+02
9.78E+00
3.62E+01
7.44E+04
1.80E+02
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
Cumulative Direct
PPLV-CARC2
1.16E+01
5.76E+01
1.32E+01
5.39E+01
NA
NA
3.23E+02
1.77E+02
1.51E+02
1.17E+00
1.74E+01
2.82E+00 .
NA
6.45E+00
NA
NA
NA
2.06E+02
1.94E+00
3.57E+01
NA
1.78E+02
7.91E+01
8.55E+02
1.29E+02
NA
NA
Page 1 of 1
Cumulative Direct
PPLV-NONCARC2
1.09E+03
NA
2.86E+02
5.82E+02
8.13E+02
6.95E+03
4.41E+03
NA
5.89E+03
7.76E+01
NA
3.49E+03
6.11E+04
9.39E+02
2.99E+03
1.47E+04
6.43E+02
2.37E+04
NA
3.82E+03
6.48E+04
NA
9.97E+03
1.30E+04
7.38E+02
4.77E+04
9.85E+03
1 Values reported as mg/kg. Values are 5th percentile PPLVs, based on a 10"6 risk level for carcinogens, and an HI of 1.0 for noncarcinogens. Values in bold face represent
the driver exposure pathway.
2 Where a chemical is both a carcinogen (CARC) and noncarcinogen (NONCARC), the single-pathway PPLVs summarized represent the carcinogenic endpoint.
raia\16t3G.DOC
-------
Table 6.1-16 Summary of 5th Percentile Direct Single-Pathway PPLVS for the Industrial Worker
Chemical Name
Aldrin
Benzene
Carbon Tetrachloride
Chlordane
Chloroacetic Acid
Chlorobenzene
Chloroform
DDE
DDT
DBCP
1 ,2-Dichloroethane
1 , 1 -Dichloroethylene
Dicyclopentadiene
Dieldrin
Endrin
Hexachlorocyclopentadiene
Isodrin
Methylene Chloride
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
Trichloroethylene
Arsenic
Cadmium
Chromium
Lead
Mercury
Soil Ingestion SPPLV
9.96E+00
3.25E+03
8.19E+02
1.04E+02
5.99E+04
5.77E+04
1.52E+04
6.58E+01
3.49E+02
6.98E+01
1.12E+03
1.10E+02
3.60E+05
8.94E+00
4.78E+03
1.71E+05
1.62E+03
1.53E+04
5.42E+02
2.39E+03
I.OOE+06
2.19E+03
3.03E+01
1.28E+04
1.28E+05
4.60E+03
1.43E+03
Soil Inhalation SPPLV
1.29E+02
7.59E+04
2.18E+04
3.06E+03
6.82E+005
l.OOE+06
2.68E+04
3.57E+03
6.48E+03
4.81E+05
1.26E+04
1.25E+04
7.84E+03
9.10E+01
2.22E+05
2.38E+03
8.32E+03
6.99E+05
1.12E+04
6.30E+05
l.OOE+06
2.09E+05
1.83E+02
2.15E+02
3.23E+01
1.52E+05
8.95E+03
Dermal Absorption
SPPLV
4.50E+00
1.04E+01
2.33E+00
8.20E+00
7.72E+01
8.58E+02
4.87E+01
2.64E+01
4.06E+01
2.37E-01
3.40E+00
5.23E+01
4.95E+04
1.69E+00
3.41 E+02
7.44E+03
7.82E+01
4.44E+01
1.49E+00
5.88E+00
7.32E+03
2.94E+01
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
Cumulative Direct
PPLV-CARC2
3.02E+00
1.04E+01
2.33E+00
7.58E+00
NA
NA
4.84E+01
1.87E+01
3.61E+01
2.36E-01
. 3.39E+00
5.21E-01
NA
1.40E+00
NA
NA
NA
4.43E+01
1.49E+00
5.87E+00
NA
2.90E+01
2.60E+01
2.12E+02
3.23E+01
NA
NA
Page 1 of 1
Cumulative Direct
PPLV-NONCARC2
1.19E+02
NA
2.96E+01
6.23E+01
7.71E+01
8.45E+02
3.73E+02
NA
4.70E+02
7.99E+00
NA
3.28E+02
6.65E+03
1.06E+02
3.18E+02
1.78E+03
7.39E+01
2.25E+03
NA
4.05E+02
7.22E+03
NA
8.67E+02
1.05E+03
7.30E+01
4.46E+03
1.24E+03
Values reported as tag/kg. Values are Sth percentile PPLVs, based on a 10"6 risk level for carcinogens, and an HI of 1.0 for noncarcinogens. Values in bold face represent
the driver exposure pathway.
Where a chemical is both a carcinogen (CARC) and noncarcinogen (NONCARC), the single-pathway PPLVs summarized represent the carcinogenic endpoint.
iroa\16UG.DOC
-------
Table 6.1-17 Summary of 5th Percentile Direct Single-Pathway PPLVS for the Commercial Worker1
Chemical Name
Aldrin
Benzene
Carbon Tetrachloride
Chlordane
Chloroacetic Acid
Chlorobenzene
Chloroform
DDE
DDT
DBCP
1 ,2-Dichloroethane
I , I -Dichloroethylene
Dicyclopentadiene
Dieldrin
Endrin
Hexachlorocyclopentadiene
Isodrin
Methylene Chloride
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
Trichloroethylene
Arsenic
Cadmium
Chromium
Lead
Mercury
Soil Ingestion SPPLV
4.81E+00
9.47E+02
1.11E+03
4.96E+01
1.38E+04
8.24E+04
1.33E+04
1.43E+02
1.06E+02
4.72E+01
5.78E+02
8.66E+01
9.55E+04
2.58E+00
1.16E+03
2.02E+05
2.57E+02
6.51E+03
3.20E+02
1.32E+03
l.OOE+06
U8E+04
2.61 E+01
5.56E+04
6.15E+04
7.11E+03
1.36E+03
Soil Inhalation SPPLV
5.76E+03
2.36E+05
2.30E+05
1.77E+04
l.OOE+06
l.OOE+06
9.56E+04
2.83E+05
2.83E+05
l.OOE+06
8.76E+04
4.36E+04
1.79E+05
7.75E+03
l.OOE+06
2.08E+04
4.75E+05
l.OOE+06
3.83E+04
l.OOE+06
l.OOE+06
l.OOE+06
8.38E+03
1.93E+03
3.28E+02
l.OOE+06
2.39E+05
Dermal Absorption
SPPLV
2.43E+02
2.97E+02
5.40E+01
5.75E+01
2.19E+03
2.15E+04
I.23E+03
1.07E+03
9.87E+02
4.98E+00
8.06E+01
1.16E+01
9.20E+05
1.75E+02
2.96E+04
I.47E+05
1.09E+04
8.84E+02
3.69E+01
1.44E+02
1.91 E+05
6.63E+02
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
Cumulative Direct
PPLV-CARC2
4.71E+00
2.26E+02
5.14E+01
2.66E+01
NA
NA
1.11E+03
1.26E+02
9.58E+01
4.51E+00
7.07E+01
1.02E+01
NA
2.54E+00
NA
NA
NA
7.78E+02
3.31E+01
1.30E+02
NA
6.27E+02
2.60E+01
1.87E+03
3.26E+02
NA
NA
Page 1 of 1
Cumulative Direct
PPLV-NONCARC2
2.04E+02
NA
6.24E+02
2.I6E+02
1.88E+03
1.68E+04
8.93E+03
NA
1.92E+03
1.84E+02
NA
7.74E+03
5.83E+04
2.26E+02
1.12E+03
I.67E+04
2.51E+02
5.06E+04
NA
8.75E+03
1.38E+05
NA
1.30E+03
1.70E+03
7.82E+02
7.06E+03
1.35E+03E
Values reported as mg/kg. Values are 5th percentile PPLVs, based on a 10"* risk level for carcinogens, and an HI of 1.0 for noncarcinogens. Values in bold face represent
the driver exposure pathway.
Where a chemical is both a carcinogen (CARC) and noncarcinogen (NONCARC), the single-pathway PPLVs summarized represent the carcinogenic cndpoint
rma\1615G.DOC
-------
Table 6.1-18 Summary of Sites with Crap Values Exceeding 5th Percentlle PPLVs
in Horizon 0 Page 1 of 1
Number of Sites with Chemical-Specific C^,,,^, Concentrations Exceeding 5th
Percentile PPLVs
Chemical1'2
Aldrin
Benzene
Carbon Tetrachloride '
Chlordane
Chloroacetic Acid
Chlorobenzene
Chloroform
DBCP
DCPD
DDE
DDT
1,2-Dichloroethane
1 , 1 -Dichloroethy lene
Dieldrin
Endrin
HCCPD
Isodrin
Methylene Chloride
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
Trichloroethylene
Arsenic
Cadmium
Chromium
Lead
Mercury
Biological
Worker
10
0
0
4
1
0
0
1
0
0
0
0
0
9
2
0
3
0
0
0
0
0
5
0
5
0
0
Regulated/
Casual
Visitor
1
0
0
2
0
0
0
1
0
0
0
0
0
2
0
0
0
0
0
0
0
0
1
0
0
0
0
Recreational
Visitor
3
0
0
2
1
0
0
1
0
0
0
0
0
4
0
0
0
0
0
0
0
0
1
0
1
0
0
Industrial
Visitor
7
0
0
4
1
0
0
1
0
0
0
0
0
5
2
0
2
0
0
0
0
0
4
0
2
0
0
Commercial Worker
5
0
0
2
0
0
0
1
0
0
0
0
0
4
0
0
0
0
0
0
0
0
3
0
0
0
0
Boldface type indicates exceedances of 10"4 cancer risk or His of LO.
For carcinogens, exceedances of 1 x 10"* risk levels are noted. For noncarcinogens, exceedances of a target HI of 1.0
are given.
rma\1509G.DOC
-------
Table 6.1-19 Summary of Acute RME PPLVs for Cumulative Direct Soil Exposure
Pathway Page 1 of 1
Receptor-Specific Soil
Chemical
Aldrin2
Benzene
Carbon Tetrachloride
Chlordane
Chloroacetic Acid
Chlorobenzene
Chloroform
DDE
DDT
DBCP
1,2-Dichloroethane
1 , 1 -Dichloroethylene
Dicyclopentadiene
Dieldrin2
Endrin
Hexachlorocyclopentadiene
Isodrin
Methylene Chloride
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
TCE
Metals
Arsenic
Cadmium
Chromium
Lead
Mercury
Biological/
Industrial
Worker
5.6E+01
ND
4.8E+04
7.2E+02
ND
2.4E+04
2.2E+04
ND
6.0E+01
6.0E+02
ND
2.4E+04
ND
4.7E+01
2.4E+02
ND
ND
1.2E+05
ND
2.4E+04
2.4E+05
2.9E+05
3.4E+03
1.9E+03
4.7E+04
ND
9.4E+04
Regulated/
Casual
Visitor
3.8E+00
ND
1.1E+04
1.7E+02
ND
5.6E+03
5.0E+03
ND
1.4E+01
1.4E+02
ND
5.6E+03
ND
3.7E+00
5.6E+01
ND
ND
2.8E+04
ND
5.6E+03
5.6E+04
6.7E+04
3.0E+02
1.5E+02
3.8E+03
ND
7.7E+03
PPLVs (Units: rag/kg)
Recreational
Visitor
3.8E+00
ND
1.1E+04
1.7E+02
ND
5.6E+03
5.0E+03
ND
1.4E+01
1.4E+02
ND
5.6E+03
ND
3.7E+00
5.6E+01
ND
ND
2.8E+04
ND
5.6E+03
5.6E+04
6.7E+04
3.0E+02
1.5E+02
3.8E+03
ND
7.7E+03
Commercial
Visitor
6.9E+01
ND
2.5E+05
3.7E+03
ND
1.2E+05
1.1E+05
ND
3.1E+02
3.1E+03
ND
1.2E+05
ND
6.9E+01
1.2E+03
ND
ND
6.2E+05
ND
1.2E+05
3
3
5.4E+03
2.8E+03
6.9E+04
ND
1.4E+05
1 Based on an HI of 1.0, and using the exposure assumptions listed in Appendix Table B.6-1 of the IEA/RC report Values in bold face
represent the driver PPLVs for the corresponding receptor population.
2 RME PPLVs for aldrin and dieldrin were recalculated using an RID recently updated by EPA (OHEA-EPA 1992) (1.0 x 10"* mg/kg-day; see
Appendix Table B.6-3 in the IEA/RC); this criterion supersedes the value used in the HHEA Addendum. These recalculated PPLVs also
reflect the following: (1) dermal RAFs for aldrin and dieldrin were revised to equal 0.0052 and O.I, respectively, consistent with the
assumptions used in the IEA/RC; and (2) concomitant with this revision of the aldrin/dieldrin dermal RAFs, the soil covering assumed for
recreational and regulated/casual visitor populations was revised to equal 1.0 mg/cm2, consistent with recent EPA dermal exposure assessment
guidance.
3 PPLV is greater than I x 10' mg/kg, indicating that the allowable soil concentrations are equivalent to exposure to pure compound over all
direct soil pathways at the soil intake rates assumed for this analysis.
ND Not Developed; EPA dose-response information not available.
rma\1562G
-------
Table 6.1-20 Summary of Subchronic RME PPLVs for Cumulative Direct Soil
Exposure Pathway1 Page 1 of 1
Receptor-Specific Soil
Chemical
Aldrin2
Benzene
Carbon Tetrachloride
Chlordane
Chloroacetic Acid
Chlorobenzene
Chloroform
DDE
DDT
DBCP
1 ,2-Dichloroethane
1 , 1 -Dichloroethylene
Dicyclopentadiene
Dieldrin2
Endrin
Hexachlorocyclopentadiene
Isodrin
Methylene Chloride
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
TCE
Metals
Arsenic
Cadmium
Chromium
Lead
Mercury
1 Based on an HI of 1.0. Values
* RMF PPI Vs fnr ulrfrin anrf rfiel,
Biological/
Industrial
Worker
8.0E+01
ND
1.2E+03
l.OE+01
3.5E+03
3.5E+04
1.7E+03
ND
8.7E+01
ND
ND
1.6E+03
3.4E+04
6.8E+01
8.7E+01
8.8E+03
ND
l.OE+04
ND
1.7E+04
3.5E+05
4.3E+05
6.7E+02
3.4E+02
7.2E+02
ND
2.0E+02
Regulated/
Casual
Visitor
2.7E+01
ND
1.4E+03
1.2E+01
3.9E+03
3.9E+04
2.0E+03
ND
9.8E+01
ND
ND
1.8E+03
5.4E+04
2.6E+01
9.8E+01
1.3E+04
ND
1.2E+04
ND
2.0E+04
3.9E+05
4.9E+05
2.7E+02
1.4E+02
2.4E+03
ND
8.2E+01
PPLVs (Units: mg/kg)
Recreational
Visitor
2.7E+01
ND
1.4E+03
1.2E+01
3.9E+03
3.9E+04
2.0E+03
ND
9.8E+01
ND
ND
1.8E+03
5.4E+04
2.6E+01
9.8E+01
1.3E+04
ND
1.2E+04
ND
2.0E+04
3.9E+05
4.9E+05
2.7E+02
1.4E+02
2.4E4-03
ND
8.2E+01
Commercial
Visitor
l.OE+02
ND
6.3E+03
5.4E+01
1.8E+04
1.8E+05
9.0E+03
ND
4.5E+02
ND
ND
8.1E+03
2.0E+05
l.OE+02
4.5E+02
5.1E+04
ND
5.4E+04
ND
9.0E+04
3
3
9.9E+02
5.0E+02
5.3E+03
ND
3.0E-1-02
in bold face represent the driver PPLVs for the corresponding receptor population.
thin were recalculated usine an RfD recently undated hv F.PA fOHFA.FPA 1
-------
Table 6.2-1 Mean BMP Calculated by Alternate Methods1
Page 1 of2
Trophic Box
Aldrin/Dieldrin
Soil
Terrestrial Plant
Worm
Insect
Small Bird
Small Mammal
Medium Mammal
Herptile
Kestrel
Owl
Shorebird
Heron
Eagle
DDE/DDT
Soil
Terrestrial Plant
Worm
Insect
Small Bird
Small Mammal
Medium Mammal
Herptile
Kestrel
Owl
Shorebird
Heron
Eagle
BMP by the Army
Calibration Procedure
Mean BMP
1
1.6E-02
2.3E-01
7.4E-02
2.1E-01
2.7E-01
3.8E-01
2.4E-KJO
2.6E+00
8.0E+00
3.6E+00
2.9E+00
6.1E+00
1
6.6E-01
1.4E+00
7.5E-01
5.4E-01
4.6E-01
4.9E-01
1.3E+00
9.9E+00
3.2E+01
4.8E+01
1.1E+01
1.9E+01
BMFob, by the Shell
Collocated Distributions
Approach
Mean BMP
1
6.0E-02
l.OE+00
9.7E-02
2.7E-01
5.9E-01
2.7E-01
2.4E+00
4.9E+00
6.9E+00
2.3E+00
3.0E+00
4.4E+00
1
9.2E-01
1.1E+00
9.9E-01
8.1E-01
6.5E-01
3.1E+00
2.5E+00
1.4E-H)!
1.7E+02
6.0E+01
1.8E+01
1.2E+02
BMFob, by the (EPA) Modified
Paired Data Approach
Mean BMP
1
1.8E-01
2.5E+00
4.2E-01
6.8E-01
3.0E-KX)
1.9E+00
7.7E+00
2.3E+01
4.1E+01
6.2E+00
8.6E+00
2.8E+01
I
52E+00
7.8E+00
3.9E-H)!
3.3E+00
2.8E+00
6.0E+00
6.3E+00
5.5E+01
3.4E+02
1.5E+02
4.2E+01
2^E+02
ma\1568G.DOC
-------
Table 6.2-1 Mean
BMP Calculated by Alternate
Methods1
BMFoh, by the Shell
BMP by the Army Collocated Distributions
Calibration Procedure Approach
Trophic Box
Endrin
Soil
Terrestrial Plant
Worm
Insect
Small Bird
Small Mammal
Medium Mammal
Herptile
Kestrel
Owl
Shorebird
Heron
Eagle
Mercury
Soil
Terrestrial Plant
Worm
Insect
Small Bird
Small Mammal
Medium Mammal
Herptile
Kestrel
Owl
Shorebird
Heron
Eagle
Mean BMP
1
1.4E-01
4.0E-01
l.OE-01
1.1E-01
1.7E-01
3.3E-02
l.OE-KK)
1.9E-01
8.8E-02
9.9E-01
1.1E-01
6.7E-02
1
3.5E-02
6.2E-01
1.1E-02
1.1E-01
5.5E-01
2.8E-01
6.0E-01
3.2E-01
2.6E-01
1.2E+0
6.8E-01
2.3E-01
Mean BMP
I
2.1E-01
2.4E-01
5.3E-02
1.3E-01
2.7E-01
3.6E-01
9.0E-01
2.6E-01
4.0E-01
6.0E-01
l.OE-Ol
4.0E-01
I
I.6E-01
4.0E-01
1.3E-01
1.9E-01
1.5E-02
3.3E-01
7.8E-01
6.8E-02
2.4E-01
1.6E-01
7.2E-01
2.6E-01
Page 2 of 2
BMFofc by the (EPA) Modified
Paired Data Approach
Mean BMP .
I
1.3E+00
UE+00
3.6E-01
9.IE-01
1.5E+00
1.2E-KX)
1.5E+00
1.3E+00
1.4E+00
I.IE+OO
1.6E-01
1.3E+00
I
3.1E-01
8.1E-00
2.7E-01
3.4E-01
1.7E-01
7.3E+00
8.2E-01
1.8E-01
4.8E+00
1.8E-02
7.6E-01
5.4E-KX)
For the three BMF^ methods, kestrel, owl, heron, and eagle BMFs were calculated with the food-web model because
there are no available field data. For these four trophic boxes:
*
BAFlit(k)
where:
BMF,^) is the BMP for predator trophic box k
BAF|it(V:) is the literature-derived BAF distribution for trophic box k
SUMj) is the summation function over the argument j
FR^) is the mass fraction of predator k's food from prey trophic box j
is the BMP for prey trophic box j
rm.\l568G.DOC
-------
Table 6.2-2 ERC Model Input Parameter Values
Biota
Chemical
Distribution
Mean*
LOG
Std. Dev. Mean
Page 1 of 9
LOG
Std Dev.
End
Point
Parameter = Bioaccumulation Factor (BAF)
Small Bird
Small
Mammal
Medium
Mamma!
Water Bird
Kestrel
Owl
Shorebird
Heron
Aldrin/Dieldrin
Endrin
DDE/DDT
Arsenic
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Arsenic
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Arsenic
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Arsenic
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Arsenic
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Arsenic
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Arsenic
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Arsenic
Mercury
Normal
Lognormal
Uniform
Uniform
Triangular
Uniform
Lognormal
Uniform
Lognormal
Triangular
Uniform
Lognormal
Uniform
Lognormal
Triangular
Normal
Lognormal
Normal
Uniform
Lognormal
Normal
Lognormal
Uniform
Uniform
Triangular
Normal
Lognormal
Lognormal
Uniform
Triangular
Normal
Lognormal
Uniform
Uniform
Triangular
Normal
Lognormal
Normal
Uniform
Lognormal
6.6
1.0
NA
NA
0.33
NA
0.08
NA
0.19
22.5
NA
0.16
NA
0.19
22.5
16
1.0
96
NA
4.1
10.5
1.0
NA
NA
0.33
21.1
1.0
43.7
NA
0.33
13.3
1.0
NA
NA
0.33
16
1.0
93.5
NA
4.1
1.8
1.6 0.000
NA
NA
NA
NA
1.0 -2.526
NA
4.7 -1.684
NA
NA
1.1 -1.833
NA
4.7 -1.684
NA
5.1
1.6 0.000
26.2
NA
3.4 1.411
1.2
1.6 0.000
NA
NA
NA
3.4
1.6 0.000
2.4 3.777
NA
NA
4.2
1.6 0.000
NA
NA
NA
5.1
1.6 0.000
20
NA
3.4 1.411
0.470
0.001
1.543
0.095
1.543
0.470
1.224
0.470
0.470
0.875
0.470
0.470
1.224
7.7, 29
0.3,3
0.001, 2
0.64, 1.6
0.44, 0.98
0.001, 50
0.64, 3.2
0.44, 0.98
0.001, 50
0.3,3
7.7, 29
0.3,3
0.001,2
0.3,3
0.001, 2
7.7, 29
0.3,3
0.001,2
0.3,3
nna\1569G.DOC
-------
Table 6.2-2 ERC Model Input Parameter Values
Biota
Chemical
Distribution
Mean*
LOG
Std. Dev. Mean
Page 2 of 9
LOG End
Std Dev. Point
Parameter = Bioaccumulation Factor (BAF)
Bald Eagle
Aldrin/Dieldrin
Endrin
DDE/DDT
Arsenic
Mercury
Normal
Lognormal
Lognormal
Uniform
Triangular
15.9
1.0
27.1
NA
0.33
3.9
1.6 0.000
2.4 3.300
NA
NA
0.470
0.875
0.3,3
0.001,2
Mean = arithmetic mean for normal distribution, geometric mean for lognormal distribution, and apex for triangular
distribribution
nna\1569G.DOC
-------
Table 6.2-2 ERC Model Input Parameter Values
Page 3 of 9
Predator
Parameter = Dietary Fractions (FR)
Terrestrial Food Chain
Small Birds
Small Mammals
Medium Mammal
Kestrel
Owl
Heron
Bald Eagle
Aquatic Food Chain
Water bird
Prey Item
Soil
Terrestrial Plants
Earthworm
Insect
Soil
Terrestrial Plants
Earthworm
Insect
Soil
Terrestrial Plants
Insect
Soil
Insect
Small Mammal
Small Bird
Soil
Small Mammal
Medium Mammal
Small Bird
Soil
Reptile
Small Mammal
Water
Aquatic Plant
Aquatic Invertebrates
Small Fish
Large Fish
Amphibian
Soil
Small Mammal
Medium Mammal
Small Bird
Waterbird
Large Fish
Water
Sediment
Aquatic Plant
Aquatic Invertebrates
Biomass Fraction*
0.057
0.113
0.116
0.714
0.020
0.866
0.008
0.106
0.074
0.926
0.000
0.029
0.184
0.665
0.122
0.029 .
0.121
0.830
0.020
0.036
0.060
0.013
0.071
0.000
0.024
0.186
0.604
0.006
0.029
0.000
0.936
0.003
0.030
0.002
0.019
0.038
0.942
0.001
rma\1569G.DOC
-------
Table 6.2-2 ERG Model Input Parameter Values Page 4 of 9
Predator Prey Item Biomass Fraction*
Shorebird Terrestrial Plants 0.007
Insect 0.728
Sediment 0.160
Aquatic Invertebrates 0.105
* Fractions reported as zero are pathways considered to be relatively inconsequential to model output due to their small
values.
nna\1569GI>OC
-------
Table 6.2-2 ERG Model Input Parameter Values
Page 5 of 9
Biota
Distribution Mean* Std. Dev.
LOG
Mean
LOG
Std Dev.
Parameter = Feed Rate (R)
Water Bird
Small Bird
Small Mammal
Medium
Mammal
Shorebird
Kestrel
Owl
Heron
Bald Eagle
kg/kg body weight/day
Normal 0.07602 0.0245
Fixed
Fixed
Fixed
0.0879
0.12
0.096
Lognormal 0.0879 1.652 -2.4315 0.50189
Normal 0.08913 0.02689
Normal 0.08913 0.02689
Normal 0.08913 0.02689
Normal 0.08913 0.02689
* Mean'= Arithmetic mean for normal distribution, geometric mean for lognormal distribution, and apex for triangular
distribribution.
ima\1569G.DOC
-------
Table 6.2-2 ERC Model Input Parameter Values
Page 6 of 9
Biota
Chemical
Distribution Value
Parameter = Maximum Allowable Tissue Concentration (MATC)
Small Bird Aldrin/Dieldrin Fixed 0.15
Endrin Fixed 0.052
DDE/DDT Fixed 0.14
Mercury Fixed 0.017
Small
Mammal
Medium
Mammal
Reptile
Kestrel
Owl
Water bird
Shorebird
Heron
Bald Eagle
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
0.19
NA
0.22
NA
0.19
NA
0.22
NA
NA
NA
NA
NA
0.73
0.052
4.3
0.017
0.76
0.087
0.53
0.017
0.24
0.09
0.18
0.01
0.15
0.052
1.4
0.011
0.87
0.043
15
0.011
0.41
0.031
2.2
0.0083
ima\1569G.DOC
-------
Table 6.2-2 ERC Model input Parameter Values
Page 7 of 9
Biota
Chemical Distribution
Value
Parameter = Toxicity Reference Values (TRV)
Terrestrial Plant
Small Bird
Small
Mammal
Medium
Mammal
Arsenic Fixed
Aldrin/Dieldrin Fixed
Endrin Fixed
DDE/DDT Fixed
Mercury Fixed
Arsenic Fixed
Copper Fixed
Cadmium Fixed
DCPD Fixed
Chlordane Fixed
CPMS Fixed
CPMS02 Fixed
DBCP Fixed
Aldrin/Dieldrin Fixed
Endrin Fixed
DDE/DDT Fixed
Mercury Fixed
Arsenic Fixed
Copper Fixed
Cadmium Fixed
DCPD Fixed
Chlordane Fixed
CPMS Fixed
CPMS02 Fixed
DBCP Fixed
Aldrin/Dieldrin Fixed
Endrin Fixed
DDE/DDT Fixed
Mercury Fixed
Arsenic Fixed
Copper Fixed
Cadmium Fixed
DCPD Fixed
Chlordane Fixed
CPMS Fixed
CPMS02 Fixed
DBCP Fixed
1.9
0.028
0.002
0.003
0.0019
0.38
0.96
0.24
8.9
0.035
NA
NA
0.17
0.004
0.010
0.029
0.0014
0.038
0.75
0.045
2.8
0.10
0.24
0.27
0.05
0.004
0.010
0.029
0.0014
0.038
0.75
0.045
2.8
0.10
0.24
0.27
0.05
NA Data not available to calculate a TRV.
nna\1569G.DOC
-------
Table 6.2-2 ERC Model Input Parameter Values
Page 8 of 9
Biota
Kestrel
Owl
.
Water brid
Shorebird
Chemical
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Arsenic
Copper
Cadmium
PCPD
Chlordane
CPMS
CPMS02
DBCP
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Arsenic
Copper
Cadmium
DCPD
Chlordane
CPMS
CPMS02
DBCP
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Arsenic
Copper
Cadmium
DCPD
Chlordane
CPMS
CPMS02
DBCP
Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Arsenic
Copper
Cadmium
DCPD
Chlordane
CPMS
Distribution
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Value
0.01
0.002
0.04
0.0019
0.38
0.96
0.24
8.9
0.035
NA
NA
0.17
0.004
0.003
0.008
0.0019
0.38
0.96
0.24
8.9
0.035
NA
NA
0.17
0.027
0.003
0.004
0.00094
0.38
0.96
0.24
3.2
3.1
NA
NA
0.17
0.022
0.002
0.008
0.00094
0.38
0.96
0.24
8.9
0.035
NA
nna\1569G.DOC
-------
Table 6.2-2 ERC Model Input Parameter Values
Page 9 of 9
Biota Chemical
CPMS02
DBCP
Heron Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Arsenic
Copper
Cadmium
DCPD
Chlordane
CPMS
CPMS02
DBCP
Bald Eagle Aldrin/Dieldrin
Endrin
DDE/DDT
Mercury
Arsenic
Copper
Cadmium
DCPD
Chlordane
CPMS
CPMSO2
DBCP
Distribution
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Fixed
Value
NA
0.17
0.03
0.003
0.004
0.00094
0.38
0.96
0.24
8.9
0.035
NA
NA
0.17
0.002
0.001
0.005
0.00063
0.19
• 0.48
0.10
5.3
0.035
NA
NA
0.17
NA
Data not available to calculate a TRY.
ima\1569G.DOC
-------
Table 6.2-3 Uncertainty Factor Protocol
Page 1 of 1
Basis for Uncertainty
Uncertainty Value Assigned
Intertaxon Variability Extrapolation Category—
Same species
Same genus, different species
Same family, different genus
Same order, different family
Same class, different order
1
2
3
4
5
Study Duration Extrapolation Category—
Chronic studies where contaminants attained equilibrium
Chronic studies where equilibrium not attained or possibly not attained,
including subchronic studies
Acute studies
1
5
20
Study Endpoint Extrapolation Category—
No observed effects level
No observed adverse effects level
Lowest observed effects level
Lowest observed adverse effects level
Frank effects level
Nonlethal
NOEL: 1
NOAEL: 1
LOEL: 3
LOAEL: 5
PEL: 10
Lethal
NOEL: 3
NOAEL: 3
LOEL: 10
LOAEL: 10
PEL: 15
Modifying Factor Category—
Threatened and endangered species
Relevance of endpoint to ecological health
Extrapolating lab to field
Study had co-contaminants
Endpoint was unclear
Study species was obviously highly sensitive
Ratios used to get from organ or egg to whole body
Intraspecific variability
Oor2
-1 toO
Oto2
-1 to+1
-2 to +2
•2 to+2
Oto2'
Oto2
1 Used only for MATC (not TRY) uncertainty factor development.
ima/1578G
-------
Table 6.2-4 Toxicity Threshold Values Selected for Representative Receptors (Trophic Boxes)1'2p 3
Page 1 of 1
Chemical
Aldrin/
Dieldrin
DDT/DDE
Endrin
Mercury
Arsenic
Copper
Cadmium
DCPD
Chlordane
CPMS
CPMSO2
DBCP
American Bald Great Great Blue Shorebird Water Small Small Medium Reptile Terrestrial
Kestrel Eagle Homed Owl Heron Bird Bird Mammal Mammal Plant
MATC TRV MATC TRV MATC TRY MATC TRY MATC TRY MATC TRY MATC TRY MATC TRY MATC TRY MATC TRY MATC TRY
0.73 0.01 0.41
4.27 0.04 2.17
0.05 0.002 0.03
0.02 0.002 0.01
0.378
0.96
0.24
8.889
0.035
ND
ND
0.167
0.002 0.76
0.005 0.53
0.001 0.09
0.001 0.02
0.189
0.48
0.103
5.333
0.035
ND
ND
0.167
0.004 0.87
0.008 15
0.003 0.09
0.002 0.01
0.378
0.96
0.24
8.889
0.035
ND
ND
0.167
0.027 0.15
0.004 1.38
0.003 0.05
0.001 0.01
0.378
0.96
0.24
8.889
0.035
ND
ND
0.167
0.022 0.24
0.008 0.18
0.002 0.09
0.001 0.01
0.378
0.96
0.24
8.889
0.035
ND
ND
0.167
0.027 0.15
0.004 0.14
0.003 0.05
0.001 0.02
0.378
0.96
0.24
3.2
3.125
ND
ND
0.167
0.028 0.19
0.003 0.22
0.002 NA
0.002 NA
0.378
0.96
0.24
8.889
0.035
ND
ND
0.167
0.004 0.19
0.029 0.22
0.01 NA
0.001
0.038
0.75
0.045
2.833
0.1
0.235
0.272
0.05
0.004
0.029
0.01
0.001
0.038
0.75
0.045
2.833
0.1
0.235
0.272
0.05
NA
NA
NA
NA
NA 1.9
NA
NA
NA
NA
NA
NA
NA
' Values shown in bold face were selected for use in the estimation of potential risk based on their total uncertainty and whether or not use of a BAF was necessary.
2 Tissue-based approach was used for calculation of risk from mercury to shorebird from aquatic food chains; other trophic boxes with mixed food chains (bald eagle
and great blue heron) used the same approach for aquatic and terrestrial food chains.
1 MATC values are presented in mg/kg, and TRVs are presented in mg/kg-bw-day.
mta/1481G.XLS
-------
Table 6.2-5 Toxicity Reference Value (Post-UF)1
Page 1 of 1
Critical Intertaxon
Aldrin/Dieldrin Value (1)
American Kestrel 0.04
Bald Eagle 0.05
Great Horned Owl 0.06
Great Blue Heron 0.4
Shorebird 0.22
Waterbird 0.4
Small Bird 0.28
Sm. Mammal 0.06
Med. Mammal 0.06
Reptile NA
Trophic Box Total
UF
American Kestrel 4
Bald Eagle 30
Great Horned Owl 16
Great Blue Heron 1 5
Shorebird 10
Waterbird 15
Small Bird 10
Sm. Mammal 16
Med. Mammal 16
Reptile NA
1
5
4
5
5
5
5
4
4
NA
Final
TRV
0.010
0.002
0.004
0.027
0.022
0.027
0.028
0.004
0.004
NA
Study Study
Duration Endpoints
(Q2) (Q3)
1
1
1
3
1
3
1
1
1
NA NA
Modifying Lab
Factor Endpoint to
(U) T&E Relevance Field
4
6 2
4
1 -1
2
1 -1
2
4 2
4 2
NA NA NA NA
ID.
Co- Unclear Sensitive Intraspecific
Contain. Endpoint Species Variability
2
0 2
0 2
1
1
NA NA NA NA
' Values reported as mg/kg bw.
2 If 0 < U < 1 , it was replaced with 1 ; if U < 0, it was replaced with 0.5.
Final TRV Critical value/total UF
NA Not Available
Total UF 1*Q2*Q3*U
TRV Toxicity Reference Value
U Sum of factors to right
UF Uncertainty Factor
irna/l 616G.DOC
-------
Table 6.2-6 Post-Uncertainty MATC1
Page 1 of 1
Aldrin/Dieldrin
American Kestrel
Bald Eagle
Great Horned Owl
Great Blue Heron
Shorebird
Waterbird
Small Bird
Mammal
Trophic Box
American Kestrel
Bald Eagle
Great Horned Owl
Great Blue Heron
Shorebird
Waterbird
Small Bird
Mammal
Study Study Modifying Lab ID.
Critical Intertaxon Duration Endpoints Factor2 Endpoint to Co- Unclear Sensitive
Value (1) (Q2) (Q3) (U) T&E Relevance Field Contain. Endpoint Species
2.9
12.2
12.2
1.3
2.9
7.1
2.9
4.5
Total
UF
4
30
16
1.5
20
30
20
24
1
5
4
1
5
5
5
4
1
1
1
3
1
3
1
1
4 2
62 2
4 2
0.5 0 -1
4 2
2 -1
4 2
6 22
Tissue
to Whole- Intraspeciflc
Body Ratio Variability
1
1
1
0
1
1 1
1
1 1
Final
MATC
0.73
0.41
0.76
0.87
0.
15
0.24
0.
0.
15
19
1 Values reported as mg/kg bw.
2 If 0 < U < 1, it was replaced with I; if U < 0, it was replaced with 0.5.
Total UF 1*Q2*Q3*U
U Sum of factors to right
Final TRV Critical value/total UF
rma/16l7G.DOC
-------
Table 6.2-7 HQs and His for Exposure through Aquatic Food Chains Page 1 of 1
Trophic Box
Water bird
Shorebird
Great Blue Heron
Bald Eagle
Hazard
Quotients
for
Aldrin/Dieldrin
2.87
0.19
2.28
0.93
Hazard
Quotients
for
DDT/DDE
1.66
2.60
1.06
0.17
Hazard
Quotients
for
Endrin
0.63
1.17
0.63
0.03
Hazard
Quotients
for
Mercury
6.75
8.30
15.63
0.21
Hazard Index
11.91
12.26
19.60
1.34
rma\1483G
-------
Table 6.3-1 Uncertainties Potentially Influencing Assigned Distributions for Soil Intake Parameters
Page 1 of 4
Soil Covering
Soil Ingestion
Dust Loading
Population and Age
Class
1 to<7
7 to < 18
Uncertainties
Population and Age
Class
Uncertainties
Population and Age
Class
Uncertainties
Regulated/Casual • Judgment
Visitor distribution
Oto< 1
Regulated/Casual • Assumed minimal Regulated/Casual and
Visitor (1 mg/day) Recreational Visitor
0 to < 1 All Ages
• Assumed outdoor
ambient exposure
• Representation of
activities by ambient
outdoor dust loading
conditions
• Data measurement
error
Data measurement
error
Extrapolation of
sample patch to
entire surface area
Data representation
of age distribution
and activities
Data measurement
error
Extrapolation of
sample patch to
entire surface area
Data representation
of age and activities
1 to<7
7 to < 75
Judgment 95th
percentile (EPA
default)
Data median
(literature)
Data measurement
error
Data representation
of age and activities
Judgment 95th
percentile (EPA
default)
Shape extrapolated
from literature
distribution for child
rma\1583G
-------
Table 6.3-1 Uncertainties Potentially Influencing Assigned Distributions for Soil Intake Parameters
Page 2 of 4
Soil Covering
Soil Ingestion
Dust Loading
Population and Age
Class
Uncertainties
Population and Age
Class
Uncertainties
Population and Age
Class
Uncertainties
18 to < 75
Recreational Visitor
Oto< 1
1 to<7
Data measurement
error
Extrapolation of
sample patch to
entire surface area
Data representation
of age and activities
Judgment
distribution
Data measurement
error
Extrapolation of
sample patch to
entire surface area
Data representation
of age and activities
0 to < 1 • Assumed minimal
(1 mg/day)
1 to < 7 • Judgment 95th
percentile (EPA
default)
• Data median
(literature)
• Data measurement
error
• Data representation
of age and activities
ima\1583G
-------
Table 6.3-1 Uncertainties Potentially Influencing Assigned Distributions for Soil Intake Parameters
Page 3 of 4
Soil Covering
Soil Ingestion
Dust Loading
Population and Age
Class
Uncertainties
Population and Age
Class
Uncertainties
Population and Age
Class
Uncertainties
7 to < 18
18 to < 75
Data measurement
error
Extrapolation of
sample patch to
entire surface area
(data
representativeness)
Representation of
age and activities
(study
representativeness)
Data measurement
error
Extrapolation of
sample patch to
entire surface area
(data
representativeness)
Representation of
age and activities
(study
representativeness)
7 to < 75
Judgment 95th
percentile (EPA
default)
Shape extrapolated
from literature
distribution (child)
rma\l583G
-------
Table 6.3-1 Uncertainties Potentially Influencing Assigned Distributions for Soil Intake Parameters
Page 4 of 4
Soil Covering
Soil Ingestion
Dust Loading
Population and Age
Class
Uncertainties
Population and Age
Class
Uncertainties
Population and Age
Class
Uncertainties
Commercial Worker
Industrial Worker
Biological/
Maintenance
Worker
Theoretical estimate
of mean, judgment
range
Commercial Worker
Judgment 95th
percentile (EPA
default)
Distribution shape
extrapolated from
biological/
maintenance worker
Data representation
of time spent in
activities
Data representation
of soil covering to
projected activities
Judgment estimate of
indoor soil covering
distribution
Industrial Worker
Biological Worker
Judgment 50th and
95th percentile
Judgment 95th
percentile
Shape extrapolated
from literature
distribution (child)
Data representation
of time spent in
activities
Judgment based
activity specific
distributions
Commercial Worker
Industrial Worker
Biological Worker
Assumed indoor
exposure
Dust loading data
measurement error
Outdoor/indoor
attenuation data
measurement error
Assumed ambient
outdoor exposure
Representation of
activities by ambient
conditions
Data measurement
error
Data representation
of time spent in
activities
rma\l583G
-------
Table 6.3-2 Uncertainties Potentially Influencing Assigned Distributions for Time-Dependent Exposure Parameters
Page 1 of 2
Population
TM (Hours/Day)
DW (Days/Year)
TE (Years/Lifetime)
Regulated/Casual
Visitor
Recreational Visitor
Commercial/Industrial Worker
Representativeness of chosen activities
for neighborhood population
Representativeness of data-based mean
for activity-specific distributions
Judgment-based distribution shape
Representativeness of participation
rate in multiple daily activities
Representativeness of national means
for percent participation in each
activity and duration of each activity
Representativeness of chosen activities
for neighborhood population
Representativeness of data-based mean
for activity-specific distributions
Judgment-based distribution shape
Representativeness of participation
rate in multiple daily activities
Representativeness of national means
for percent participation in each
activity and duration of each activity
Representativeness of national data on
hours spent at work
No data specific to visitation of RMA
neighborhood subpopulation
Intentional conservative estimation
bias
Judgment-based distribution for
number of activity days/year
Judgment-based distribution for
fraction of activity days occurring at
RMA
Intentional conservative estimation
bias
Representativeness of chosen activities
for neighborhood subpopulation
Representativeness of western region
and national means for percent
participation in activity
Representativeness of national
distribution of number of jogging days
per week and assumption of 52 weeks
per year for neighborhood
subpopulation
1 Judgment-based distribution for
number of activity days/year for some
activity-specific distributions
• Judgment-based distribution for
fraction of activity days occurring at
RMA
• Incorporation of judgment estimates
for vacation time and holidays
• Representativeness of western region
data on job. absence rates (BNA
1974-90)
Representativeness of PSCo data for
neighborhood subpopulation (PSCo
1989)
Positive bias (overestimation) due to
analysis method, which under-
represents low TE values in
population
Negative bias (underestimation) due to
moves within same county
Representativeness of PSCo data for
neighborhood subpopulation (PSCo
1989)
Positive bias (overestimation) due to
analysis method, which under-
represents low TE values in
subpopulation
Negative bias (underestimation) due to
moves within same county
Representativeness of Mountain States
Employer's Council mean job
turnover data used to obtain
distribution mean (MSEC 1981-90)
Representativeness of national data on
occupational turnover used to obtain
distribution shape
rtna\1584G
-------
Table 6.3-2 Uncertainties Potentially influencing Assigned Distributions for Time-Dependent Exposure Parameters Page 2 of 2
Population TM (Hours/Day) DW (Days/Year) TE (Years/Lifetime)
Biological Worker • Representativeness of on-site work • Representativeness of on-site work • Representativeness of job tenure
schedule of interviewed personnel at schedule of interviewed personnel at history of interviewed personnel at
three refuges three refuges three refuges (Bureau of the Census
1987)
• Censored data (current tenure was
longer than reported at time of
survey)
rma\IS84G
-------
Table 6.3-3 Uncertainties Potentially Influencing Assigned Distributions for Chemical-Specific Parameters1
Page 1 of 2
Henry's Law Constant (KH)2
Soil to Water Partition
Coefficient Normalized to
Organic Carbon
KK (Kd)3
Vapor Pressure (Vp)2
Chemical Group
Uncertainties
Chemical Group
Uncertainties
Chemical Group
Uncertainties
Aldrin
Endrin
1,1,2,2-Tetrachloroethane
DDT
DDE
Chlordane
HCCPD
Representation of
RMA temperature
regime
Experimental
measurement error
< 6 data points
Aldrin
Endrin
1,2-Dichloroethane
Methylene Chloride
Experimental measurement Endrin
error Chlorobenzene
< 6 data points Chlordane
Experimental
measurement error
Representation of
RMA temperature
regime
< 6 data points
Isodrin
Representation of
RMA temperature
regime
Experimental
measurement error
No data, extrapolation
across chemicals
Isodrin
1,1-Dichloroethylene
HCCPD
DCPD
DBCP
Experimental measurement
error
< 2 data points
Extrapolation across
chemicals
1,1-Dichloroethylene
1,1,2^2-Tetrachloroethane
DDE
HCCPD
Experimental
measurement error
Representation of
RMA temperature
regime
< 6 data points
Intentional
conservative bias
in estimation of
SD
DCPD
DBCP
Chloroacetic Acid
• Representation of Chloroacetic Acid
RMA temperature
regime
• Experimental
measurement error
• No data, extrapolation
based on vapor
pressure and solubility
• < 2 data points
• Extrapolation from other
partitioning information
Isodrin
Chloroacetic
DCPD
DBCP
• Experimental
measurement error
• Representation of
RMA temperature
regime
• 2 data points
• Judgment range
mia\1585G
-------
Table 6.3-3 Uncertainties Potentially Influencing Assigned Distributions for Chemical-Specific Parameters1
Page 2 of 2
Henry's Law Constant
Soil to Water Partition
Coefficient Normalized to
Organic Carbon
KOC (Kd)>
Vapor Pressure (VP)2
Chemical Group
Uncertainties
Chemical Group
Uncertainties
Chemical Group
Uncertainties
Dieldrin
Toluene
Benzene
Chloroform
1 ,2-Dichloroethane
1,1-Dichloroethylene
Methylene Chloride
Carbon Tetrachloride
Tetrachloroethylene
Chlorobenzene
TCE
• Representation of
RMA temperature
regime
• Experimental
measurement error
Dieldrin • Experimental measurement
Toluene error
Benzene
Chloroform
Carbon Tetrachloride
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
Chlorobenzene
TCE
DDT
DDE
Chlordane
Arsenic*
Cadmium*
Chromium*
Lead*
Mercury*
Aldrin
Dieldrin
Toluene
Benzene
Chloroform
1 ,2-Dichloroethane
Methylene Chloride
Carbon Tetrachloride
Tetrachloroethylene
TCE
DDT
• Experimental
measurement error
• Representation of
RMA temperature
regime
1 See IEA/RC report (Appendix E) for discussion of types of uncertainties.
1 KH2 and Vf2 not defined for metals.
3 Kd (distribution coefficient) used for organic COCs lacking K^ data.
imaMSSSG
-------
7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed
7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed
7.1 Summary of the Feasibility Study Process
The FS process involved two major phases: the Development and Screening of Alternatives and the Detailed
Analysis of Alternatives. Each contaminated environment at RMA (water, structures, and soil) was subdivided into
several medium groups of similarly contaminated groundwater plumes, structures, or soil sites to organize and
streamline the FS process.
At the outset of the Development and Screening of Alternatives, Remedial Action Objectives (RAOs) were
identified. These goals provide general guidance for the FS by identifying the contaminants and media of interest,
potential exposure pathways, and preliminary remediation goals. For the On-Post Operable Unit, RAOs were
developed for water, structures, and soil based on the results of the IEA/RC, an evaluation of ARARs specified in
federal and state environmental laws and regulations, and the provisions of the FFA. (ARARs are listed in
Appendix A.) The human health and biota remediation goals are to achieve appropriate remediation such that the
selected remedy is protective of both humans and biota.
During the Development and Screening of Alternatives, a wide range of alternatives was evaluated for each medium
group with respect to effectiveness, implementability, and cost. Those alternatives retained for further consideration
were evaluated during the Detailed Analysis of Alternatives against a set of threshold and primary balancing criteria
defined in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (see Section 8). Also
taken into account were RMA-specific considerations such as Army safety procedures and USFWS guidance
regarding the future use of the site as a national wildlife refuge.
A range of alternatives including no action, institutional controls, containment, and treatment options was developed
for each of the water, structures, and soil medium groups. The No Action alternative (as required by EPA) and the
No Additional Action alternative were also developed and used as a baseline against which other alternatives were
evaluated. The No Action alternative represents current site conditions with no remedial actions undertaken,
ongoing, or planned and IRAs discontinued. The No Additional Action alternative involves no action beyond the
IRAs currently being implemented on post.
Once the alternatives for each group were evaluated with respect to the seven threshold and primary balancing
criteria, the comparative performance of each alternative was evaluated and a range of alternatives was retained for
each medium group/subgroup to use in the development of sitewide alternatives. Tables 7.1-1, 7.1-2, and 7.1-3
present descriptions of all individual technologies used to develop the respective sitewide alternatives for the water,
structures, and soil medium groups. It should be noted that the No Action and No Additional Action alternatives
FOSTER 0 WHEELER
rma\M91G.DOC FOSTER WHEELER ENVIRONMENTAL CORPORATION 7-1
-------
Record of Decision for the On-Post Operable Unit
were developed for each contaminated medium, but were eliminated from consideration during the comparative
analysis conducted for sitewide alternatives because they were not sufficiently protective.
All of the alternatives that were identified have several features in common as follows:
• Land-Use Restrictions - The Rocky Mountain Arsenal National Wildlife Refuge Act of 1992 restricts
current and future land use, specifies that the U.S. government shall retain ownership of RMA, and
prohibits certain activities such as agriculture, use of on-post groundwater as a drinking source, and
consumption of fish and game taken at RMA. Continued restriction on land use or access are included as
an integral component of all on-post alternatives. Long-term management includes access restrictions to
capped and covered areas to ensure the integrity of the containment systems.
• Five-Year Review - In accordance with CERCLA, a review will be performed a minimum of every 5 years
after initiation of remedial action to ensure that the various remedial actions where contamination continues
to exist, such as the capped areas or the hazardous waste landfill, remain protective of human health and
the environment and comply with ARARs.
• Site Monitoring - The Army will continue to conduct air, groundwater, and surface water monitoring
programs at RMA, and will continue to fund USFWS to conduct on-post wildlife monitoring programs.
Samples will be collected periodically to assess the effectiveness of the remedy for protection of human
health and the environment. The actual compliance monitoring program for each of the environmental
media will be finalized during the remedial design.
• Revegetation - Any time vegetation is disturbed during remedial construction, the disturbed areas will be
revegetated consistent with a USFWS refuge management plan.
• Long-Term Operation and Maintenance - Areas that are remediated will be operated and maintained as
required. Management activities may include maintaining capped and covered areas or operating the
on-post hazardous waste landfill or groundwater treatment systems.
• On-Post Water Supply - A sufficient on-post water supply will be maintained to support remedial actions
(revegetation, habitat enhancement, maintenance of lake levels).
7.1.1 Area of Contamination
An AOC is defined by EPA (OSWER-EPA 1989b) as the areal extent (or boundary) of contiguous contamination.
Such contamination must be continuous, but may contain varying types and concentrations of hazardous substances.
For on-site disposal, placement occurs when wastes are moved from one AOC into another AOC. Placement does
not occur when wastes are left in place or moved within a single AOC.
Placement does not occur when wastes are:
• Treated in situ
• Capped in place
• Consolidated within the AOC
• Processed within the AOC (but not in a separate unit, such as a tank) to improve its structural stability (e.g.,
for capping or to support heavy machinery
Placement does occur when wastes are:
• Consolidated from different AOCs into a single AOC
FOSTER J3 WHEELER
7-2 POSTER WHEEtai ENVIRONMENTAL CORPORATION mja\1491G.DOC
-------
7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed
• Moved outside of an AOC (e.g., for treatment or storage) and returned to the same or a different AOC
• Excavated from an AOC, placed in a separate unit, such as an incinerator or tank that is within the AOC,
and redeposited into the same AOC
If placement does not occur, land disposal restrictions (LDRs) are not applicable to the Superfund action.
Correspondingly, if placement on site does occur, LDRs would be applicable to the Superfund action.
At RMA, an AOC was defined that encompasses all principal threat exceedance areas, the majority of human health
exceedance areas, and wildlife risk areas defined by the study area that is the subject of the SFS. The boundaries of
the AOC are shown on Figure 7.1-1.
7.1.2 Corrective Action Management Unit
Several of the proposed alternatives for the On-Post Operable Unit include the construction and operation of a new
on-post hazardous waste landfill for disposal of principal threat and human health exceedance soil and debris as
defined in the Detailed Analysis of Alternatives report. Some of this material is RCRA-Iisted or potentially RCRA-
characteristic hazardous waste (based on TCLP). Therefore, during the development of the Detailed Analysis of
Alternatives, it was determined that a Corrective Action Management Unit (CAMU) would be required (EPA 1993).
The CAMU will incorporate a future hazardous waste landfill, a Basin F Wastepile drying unit, and an appropriate
waste staging and/or management area(s). The CAMU was designated by CDPHE under authority of and in
accordance with CHWMA. The CAMU designation provides for landfilling of hazardous wastes and movement of
waste into the CAMU from anywhere on post, within or outside the AOC, including treatment units. This ROD also
provides for use of the CAMU rule as an ARAR for several remedial alternatives (see Appendix A).
The basis for designation of a CAMU and the requirements for the CAMU that are to be specified as part of the
designation are provided in 6 CCR 1007-3, Section 264.552. In addition, Section 264.552(a)(3) specifies that where
remediation waste placed into a CAMU is hazardous waste, the CAMU shall comply with Part 265, Subparts B, C,
D, and E of 6 CCR 1007-3 (Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and
Disposal Facilities [TSDFs]). When such remediation wastes are to remain in place after closure, Section
264.552(a)(3) also requires compliance with the siring requirements for hazardous waste disposal sites (6 CCR
1007-2, Part 2). The new hazardous waste landfill is the only facility within the CAMU to which these siting
requirements apply; however, the CAMU may include additional areas as necessary to implement other actions.
A draft CAMU Designation Document (CDD) was submitted to CDPHE on January 12,1996. It was resubmitted
with additional information on March 15, 1996 and was followed by a public comment period. A public hearing
was held April 17, 1996, and the comment period closed May 20, 1996. The CDD contains a discussion of the
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guidelines to be used for the designation of the RMA CAMU as well as a discussion of the operational, monitoring,
closure, and post-closure guidelines that will be implemented following designation of the CAMU.
The following decision-making criteria were addressed in designating the CAMU:
• Facilitation of the remedy
• Risks to human health and the environment
• Justification of inclusion of uncontaminated area
• Containment of remediation waste remaining after closure
• Expeditious timing of remedial activity implementation
• Application of treatment technologies
• Minimization of land area where wastes remain in place
CDPHE desipated the CAMU by way of the final CDD (Harding Lawson Associates 1996) and a Corrective
Action Order. The CAMU boundaries are shown in Figure 7.1-1.
7.1.3 Development of Criteria for Evaluating Soil Contamination
The NCP (EPA 1990a) indicates that acceptable exposure levels for suspected carcinogens are "generally concentration
levels mat represent an excess upper bound lifetime cancer risk to an individual of between Iff4 and Iff6" and that the
10"* level shall be used as the point of departure for determining remediation goals. EPA (OSWER-EPA 1991b)
indicates mat action generally is not warranted for sites with additive excess cancer risks less than Iff4 and an HI less
than 1.0 for noncarcinogenic contaminants. Therefore, the human health SEC for contaminated soil were defined as the
additive excess cancer risks of COCs equal to Iff4 and/or additive noncarcinogenic His equal to 1.0. The boring-by-
boring analysis was used to identify the areas of each site, if any, that exceeded the human health SEC and were
therefore candidates for remediation. Sites with contaminant concentrations that result in exceedances of these criteria
are termed exceedance sites, and their contaminants and resultant volumes are referred to as exceedance COCs and
exceedance volumes. Table 7.1-4 presents the human health SEC, which are based on a 10~* cumulative excess cancer
risk and noncarcinogenic HI of 1.0 (the criteria ultimately selected in the Detailed Analysis of Alternatives). The human
health SEC are based on the lower of the industrial or biological worker PPLVs for each COC. Acute risk criteria were
used as human health SEC where they were lower than the corresponding chronic risk human health SEC.
The NCP (EPA 1990a) and EPA guidance documents also develop the concept of a principal threat. Although EPA
guidance allows for considerable interpretation in identifying specific sites or areas as principal threats, the EPA fact
sheet "Guide to Principal Threat and Low-Level Threat Wastes" (OERR-EPA 1991) provides the following general
definition of principal threats:
...those source materials considered to be highly toxic or highly mobile that generally cannot be reliably contained
or would present a significant risk to human health or the environment should exposure occur. They include
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liquids or other highly mobile materials (e.g., solvents) or materials having high concentrations of toxic
compounds. No "threshold level" of toxicity/risk has been established to equate to "principal threat." However,
where toxicity and mobility of source material combine to pose a potential [excess] cancer risk of 10'3 or greater,
generally treatment alternatives should be evaluated.
In addition, the guidance includes a determination as to whether a source material is a principal threat waste:
...should be based on the inherent toxicity as well as a consideration of the physical state of the material (e.g.,
liquid), the potential mobility of the wastes in the particular environmental setting, and the liability and degradation
products of the material. However, this concept of principal threat waste should not necessarily be equated with
risks posed by site contaminants via various exposure pathways.
Principal threats, as defined in EPA's "Guide to Selecting Superfund Remedial Actions" (1990b), include the following:
• Areas contaminated with relatively high concentrations of toxic compounds
• Liquids and other highly mobile materials
• Contaminated media (e.g., sediment or soil) that pose a significant risk of excessive exposure
• Media containing contaminants several orders of magnitude above health-based levels
The objective of identifying the principal threat wastes is to focus the remediation on the areas of highest risk to human
health and the environment. This focused approach is especially appropriate to RMA because many sites combine
large areas of minimal or low-level contamination with small areas of high-level contamination that fall within the
definition of principal threats being several orders of magnitude above health-based levels. Because 10"4 was set as the
human health SEC, the principal threat criteria for RMA soil were established at a 10"3 excess cancer risk and a
noncarcinogenic HI of 1,000. These criteria are listed by COC in Table 7.1-4. It should be noted and emphasized that
the principal threat criteria are risk-management endpoints for use in directing and prioritizing remedial activities; only
the SEC denote protective boundaries based on risks (with varying uncertainties) to health. The areas of RMA that
exceed the human health SEC and principal threat criteria are shown in Figure 7.1-1.
7.1.4 Soil Volume Modeling and Estimation
Most of the soil alternatives that were evaluated make use of a volume or area estimate to accurately analyze the
proposed remedial actions and to develop costs. These volume or area estimates were developed based on the
above-described exceedance criteria.
Human health exceedance volume estimates were generated by one of two methods. The distribution of
contaminants in some sites was modeled using a commercial software package (TECHBASE). A three-dimensional
model, represented by an array of blocks, was created for each site and was bounded vertically by the ground-
surface elevation at the time of sampling and depth of the water table (or to a maximum 10-ft depth based on the
exposure assessment performed as part of the IEA/RC) and laterally by the site boundary as defined in the Remedial
Investigation Summary Report. The modeling routine then searched within a defined volume (based on sample
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distribution within the site) around each block and used a three-dimensional inverse distance squared algorithm to
estimate contaminant concentrations in each block.
Modeled soil concentrations were compared to the human health SEC to identify blocks to be included in the human
health exceedance volume for each site. Similarly, soil concentrations were compared to the principal threat criteria
to identify blocks to be included in principal threat exceedance volume. Concentrations were evaluated to account
for potential cumulative effects of multiple contaminants, and all soil located between ground surface and the
deepest exceedance block was counted in the exceedance volume. Areas were estimated by projecting all
exceedance blocks to the surface and contouring around the surface projection. Perimeters were also estimated
from these projections.
Additional volumes and areas were calculated for sites not considered amenable to modeling. In general, if
modeling was subject to great uncertainty due to the physical characteristics of a site, highly heterogeneous or
uneven spatial contamination, or limited data availability, information from the Study Area Reports (as summarized
in the Remedial Investigation Summary Report) was used for volume and area calculations. A boring-by-boring
analysis was performed to identify individual sample exceedances, and depth and lateral extents were projected
halfway to the next nonexceedance sample. Volumes and areas were calculated using physical dimensions as listed
in the Study Area Reports and measured distances between exceedance and nonexceedance samples.
Biota exceedance volumes were developed based on the potential biota risk areas as identified through the risk
assessment process described in Section 6.2. The volume was calculated by multiplying the potential risk area by
1 ft (depth). The potential risk area for a site is defined as the entire biota exceedance area within the boundaries of
a site, less any human health exceedance area, to avoid double-counting of the volume.
Potential agent and UXO areas were determined from boundaries presented in the Remedial Investigation Summary
Report. Potential volume was calculated using these areas and the depths presented in the Detailed Analysis of
Alternatives report. The expected agent or UXO volume of soil reflects a 0.1 percent factor to estimate actual agent
or UXO occurrence within the potential volume. In addition, UXO surface debris volume was calculated by
multiplying the potential UXO area by 1 ft (depth); the result is considered the maximum potential debris volume.
For each site, overlap between agent, UXO, or UXO debris volume and human health or biota volume was
calculated. Exceedance volumes were adjusted to prevent double-counting of soil volumes. UXO debris volume
may include human health and/or biota exceedance volume. Actual human health exceedance volume or biota
exceedance volume would increase to the previously unadjusted volume if less than the maximum potential debris
volume is encountered.
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The volume and area estimates that resulted from these calculations represent the soil quantities used for all soil
alternative detailing. Volume increases due to commonly used excavation practices (such as sidesloping, bottom
leveling, and perimeter rounding), although expected to be small, were not included in these calculations.
Table 7.1-5 lists human health, principal threat, excess biota, agent, UXO, and UXO debris volumes for each soil
medium group, and Table 7.1-6 lists the corresponding areas for each soil medium group.
7.2 Remedial Alternatives for Groundwater
7.2.1 Description of Medium
As described in Section 5, contaminated groundwater plumes were detected primarily in the vicinity of the basins,
North and South Plants, and the northern and western sections of RMA (Figure 5.4-3). Plumes are generally
moving to the north and northwest. Groundwater contaminant plumes predominantly consist of organic compounds
(solvents, chloroform, dieldrin, DIMP, DCPD, DBCP, and organosulfur compounds) and fluoride and chloride salts
(Tables 5.4-1 through 5.4-5). The overall concentrations and configurations of the plumes suggest that the greatest
contaminant releases to the UFS have occurred from Basin A and the Lime Settling Basins, the South Plants
chemical sewer, South Plants Tank Farm and production area, the Army and Shell Trenches in Section 36, and the
Former Basin F. Plumes emanating from the Motor Pool/Rail Yard and North Plants areas are other sources of
contaminant releases to the UFS.
Four groundwater alternatives were developed based on the contaminant concentrations in the individual plumes
and evaluated against the remedial alternative screening criteria (see Section 8). A range of alternatives was
developed and analyzed for each plume group. These alternatives included no action, continued operation of
existing systems, and groundwater extraction and treatment approaches. Alternatives selected for each plume group
were combined into four sitewide alternatives that were evaluated and compared against the screening criteria.
Groundwater flow modeling utilizing commercially available software (MODFLOW), as summarized in the South
Plants/Basin A groundwater flow model report (Foster Wheeler Environmental 1995c), was conducted to assess
flow patterns and estimate flow and extraction rates in the South Plants and Basin A areas.
7.2.2 Remedial Action Objectives
The following RAOs were established for on-post groundwater at RMA:
Human Health
• Ensure that the boundary containment and treatment systems protect groundwater quality off post by
treating groundwater flowing off RMA to the specific remediation goals identified for each of the
boundary systems.
• Develop on-post groundwater extraction/treatment alternatives that establish hydrologic conditions
consistent with the preferred soil alternatives and also provide long-term improvement in the performance
of the boundary control systems.
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Ecological Protection
• Ensure that biota are not exposed to biota COCs in surface water in concentrations capable of causing acute
or chronic toxicity.
7.2.3 Description of Sltewide Remedial Alternatives for Groundwater
Flow of surface water at RMA occurs through a network of streams, lakes, and canals, and flow of groundwater
occurs within the alluvium and the uppermost weathered portion of the Denver Formation (UFS). Deeper water-
bearing units within the Denver Formation (CFS) are separated from the UFS by low-permeability confining units.
Depending on site-specific hydrological characteristics, varying degrees of hydraulic interchange are possible
between surface water and groundwater and between the UFS and CFS. In general, analytical and hydraulic data
indicate little hydraulic interchange between the UFS and CFS.
The following are considerations for all water alternatives:
• Chloride is expected to attenuate naturally at the NBCS, where it currently exceeds the remediation goal of
250 mg/1. It has been estimated that chloride concentrations will attenuate to concentrations less than the
remediation goal at the north boundary within 30 years (MK 1996). Assessment of chloride concentrations
will occur during the 5-year site reviews.
• The remediation goal of 540 mg/1 for sulfate at the NBCS represents the natural background concentration.
It is estimated that sulfate will attenuate to the remediation goal within approximately 25 years (MK 1996).
Assessment of sulfate concentrations will occur during the 5-year site reviews.
• NDMA has been detected in the North Boundary Plume Group and at the NBCS. Monitoring for NDMA
using a method detection limit of 20 parts per trillion (ppt) is ongoing. If the current monitoring program
identifies an NDMA problem, potential design modifications (both on post and at the boundary or adjacent
to the boundary) required to achieve the remediation goal at the RMA boundary will be prepared during
the remedial design. Any upgrades required for existing treatment systems to address the remediation goal
will be incorporated into the remedial actions.
7.2.3.1 Alternative 1 - Boundary Systems
Under Alternative 1, the three boundary systems all continue to operate and the systems installed as IRAs are
discontinued. The boundary systems are the following:
• Northwest Boundary Containment System (NWBCS)
• North Boundary Containment System (NBCS)
• Irondale Containment System (ICS)
Each of the boundary systems includes groundwater extraction and reinjection systems and a treatment system that
removes organic contaminants through carbon adsorption; the NWBCS and NBCS include slurry walls for
containment and control of groundwater flow. The total amount of water currently treated at the boundary systems
is about 1 billion gallons per year. Boundary systems will continue to operate as necessary to achieve remedial
action objectives until remediation is complete, and the CERCLA Wastewater Treatment Plant continues to operate
as needed to support remedial activities.
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Under Alternative 1, the following IRAs are discontinued: the Basin F extraction system, the Basin A Neck
extraction and treatment system (including breaching of the slurry wall to allow groundwater flow), the Rail Yard
extraction system, 'and the Motor Pool extraction system. Monitoring of boundary system influent and effluent
concentrations and groundwater monitoring continue. In addition, caps or covers installed in South Plants and
Basin A as part of the soil remedy minimize infiltration of precipitation, thereby reducing contaminant migration
through lowering of the water table (passive dewatering).
The components of this alternative are summarized in Table 7.2-1. The total estimated cost for this alternative (in
1995 dollars) is $111 million (present worth cost of $80 million). A breakdown of capital and operations and
maintenance (O&M) costs is presented in Table 7.2-2. Operations are assumed to continue for at least 30 years.
The operation of each of the boundary systems is detailed below.
Northwest Boundary Containment System
Under Alternative 1, operation of the NWBCS for the Northwest Boundary Plume Group continues. The NWBCS is
designed to capture and treat organic contaminants, primarily dieldrin, in groundwater approaching the northwest
boundary. The NWBCS includes extraction wells, a slurry wall, reinjection wells, and a GAC adsorption system.
When the system was constructed, a slurry wall was installed along the northwest boundary to minimize migration of
the contaminated groundwater flowing across that boundary. This wall, constructed of soil/bentonite and originally
measuring 1,425 ft long by 3 ft wide by approximately 30 ft deep, was subsequently extended by an additional 665 ft in
the northeast direction to intercept groundwater flowing through the alluvial channel to the northeast. The slurry wall
extension was keyed a minimum of 10 ft into the existing slurry wall and the extension ranged from 28 to 35 ft deep.
Five extraction wells were also added to the original system, two along the slurry wall, and mree southwest of the
system. Four reinjection wells were installed to the southeast of the newly installed extraction wells to maintain a
separation between contaminants migrating to the north versus contaminants migrating to the northwest and to push
groundwater toward the NWBCS along a small, localized groundwater divide. One additional extraction well was
added to the southwest extension in early 1996 in response to hydrological changes associated with increased pumping
rates in off-post SACWSD water supply wells and decreased infiltration rates at the Havana Ponds (south of Lake Mary
and Lake Ladora in Section 11). The southwest extension currently extracts 425 gpm and reinjects approximately 230
gpm; the balance (195 gpm) is reinjected at the original NWBCS system. The rest of the NWBCS extracts and reinjects
approximately 600 gpm and 795 gpm, respectively, for a total system flow of approximately 1,025 gpm.
Groundwater is pumped from the extraction wells to the influent sump adjacent to the treatment building. The
treatment system consists of three identical GAC vessels, two of which are operated in parallel; the third is used as a
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backup unit. Each'vessel contains 40,000 Ibs (1,400 cubic ft) of GAC, is operated in an upflow mode, and has a design
capacity of 500 gpm and a residence time of 22 minutes. Treated water is currently discharged into an effluent sump
from which the water is pumped (using two 500-gpm pumps) through a recharge header pipe to the reinjection
(recharge) wells. The system includes two 500-gpm backup pumps. There are 25 recharge wells mat range in depth
from approximately 40 ft to 60 ft below the ground surface.
The NWBCS generates two sidestreams requiring treatment or disposal, spent carbon and filter solids. The spent
carbon in the adsorbers is removed and regenerated at an off-post facility. The filter solids are drummed and disposed
in a landfill regulated by RCRA and CHWMA.
North Boundary Containment System
Under Alternative 1, operation of the NBCS for the North Boundary Plume Group continues, but the operation of the
extraction well that is currently part of the Basin F Groundwater IRA is discontinued. The NBCS is a pump-and-treat
system that consists of 35 extraction wells approximately 35 ft deep, 12 of which are currently operating, and a
soiM>entonite slurry wall 6,740 ft long, 3 ft wide, and 30 ft deep. The extracted water is treated at the treatment plant
with GAC and recharged through 15 reinjection trenches. The NBCS was upgraded as part of the IRA for this system.
The upgraded system has an improved treatment system, 5 new recharge trenches installed in 1990, and 10 recharge
trenches installed in 1988. The trenches parallel the line of extraction wells and are located about 45 ft north of the
existing soil/bentonhe slurry wall. The existing 38 recharge wells are not in operation, but can be used as backups if
needed. The trenches were installed close to the slurry wall to better maintain a reverse gradient.
The NBCS treatment system originally included prefiltration units, three 30,000-lb GAC adsorbers operated in parallel,
and a combination of cartridge and bag postfilters. Treated effluent is discharged to a sump for groundwater recharge.
The treatment plant has undergone minor operational changes (associated mostly with carbon handling) and now has
two 20,000-lb GAC adsorbers operated in series; a third unit is available as a backup. The GAC units operate in
downflow mode, and the carbon usage is approximately 100,000 Ibs per year. The total capacity of the modified
extraction/treatment system is estimated to be 450 gpm. Flow through the treatment plant currently averages 270 gpm.
The NBCS generates two sidestreams requiring treatment or disposal, spent carbon and filter solids. The spent carbon
in the adsorbers is removed and regenerated at an off-post facility. The filter solids are drummed and disposed in a
landfill regulated by RCRA and CHWMA.
Water levels in the Former Basin F area have been declining for years. The new cap and soil covers in this area will
cause the water level to drop further.
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Irondale Containment System
Originally, the ICS consisted of two rows of extraction wells and one row of recharge wells. A number of
modifications to the ICS system configuration were completed by 1991. The extraction systems have changed as some
wells have reached cleanup goals and more contaminated wells have been added to the system. Six of the original
extraction wells are currently operating as extraction wells and three of the original extraction wells have been
converted to injection wells. Nine new recharge wells, which reduce the water table depression caused by heavy
SACWSD pumping rates and which enlarge the zone of captured groundwater on the south edge of the ICS, were
installed south of the original system. Additionally, four new extraction wells, three of which are currently operating,
were installed 2,000 ft upgradient of the original ICS in an area of greater saturated thickness than the original ICS
extraction wells.
Under Alternative 1, all groundwater extracted from the Western Plume Group is treated at the ICS. The water is
collected in an influent sump and is treated with GAC adsorption before being reinjected into the aquifer. The
treatment plant has three existing treatment trains, each capable of treating a maximum of 700 gprri, although
historically only two of the trains have been run simultaneously. The treatment system consists of three identical GAC
vessels, two of which are operated in parallel; the third is used as a backup unit. Each vessel contains 40,000 Ibs of
GAC, is operated in an upflow mode, and has a design capacity of 700 gpm and a corresponding residence time of 15
minutes. Alternative 1 does not include the operation of the two IRA systems (Motor Pool and Rail Yard) mat feed into
the ICS.
The ICS generates two sidestreams requiring treatment or disposal, spent carbon and filter solids. The spent carbon in
the adsorbers is removed and regenerated at an off-post facility. The filter solids are drummed and disposed in a
landfill regulated by RCRA and CHWMA.
7.2.3.2 Alternative 2 - Boundary Systems/IRAs
Under Alternative 2, all boundary systems continue to operate as for Alternative 1. Passive dewatering is
accomplished through installation of the soil caps and covers. In addition, all the IRAs continue to operate as
follows:
• The systems in the Motor Pool and Rail Yard areas continue to extract groundwater and pipe it to the ICS
for treatment.
• The Basin F Groundwater IRA continues to extract water north of Basin F for treatment at the Basin A
Neck IRA System.
• Under the Basin A Neck IRA, water migrating from Basin A continues to be extracted at Basin A Neck and
treated by carbon adsorption. A slurry wall helps control contaminant migration. Water from north of
Basin F (Basin F Groundwater IRA) is treated by air stripping and carbon adsorption at Basin A Neck.
• The CERCLA Wastewater Treatment Plant continues to operate as needed to support remedial activities.
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Operation of the internal groundwater extraction IRA systems continue as necessary until remedial action objectives
are met. The other systems operate as necessary to achieve remedial action objectives until remediation is complete.
Groundwater and system influent and effluent monitoring continue under this alternative.
The Rail Yard and Motor Pool IRA systems include seven extraction wells to intercept DBCP contamination and two
extraction wells to intercept a TCE plume, respectively. These wells became operational in September 1991. Five of
the seven wells in the Rail Yard IRA are currently pumping at a total rate of approximately 230 gpm; the two other
wells are backup extraction wells and have not been used. The two wells in the Motor Pool area are currently pumping
approximately 100 gpm. The groundwater that is extracted from the Motor Pool Area and Rail Yard extraction wells is
pumped from the wells through a metering station to a manifold and then flows via an 8-inch-pipeline to the ICS.
To allow for the additional flow at the ICS, the capacity of this system was increased by bringing the third GAC bed on
line, although this option has not been required with present flow rates (the ICS is treating approximately 1,030 gpm as
of August 1995). With all three trains operating in parallel, the ICS has a maximum design capacity of 2,100 gpm.
The Basin F Groundwater IRA was implemented to capture contamination moving north out of the Basin F Area.
Water is extracted using one well at a rate of 1 to 4 gpm and is then piped to the Basin A Neck IRA system where it
is treated prior to reinjection into the Basin A Neck recharge trenches.
The Basin A Neck IRA is a pump-and-treat system that intercepts and treats contamination in groundwater as it moves
northwest from Basin A. The extraction system consists of seven alluvial wells that currently pump a total flow of
approximately 20 gpm. Three gravel-filled recharge trenches (160 ft, 170 ft, and 180 ft in length) are located across the
more permeable, deeper portions of the Basin A Neck. A soil/bentonite slurry wall extends 830 ft across the Basin A
Neck between the extraction wells and the recharge trenches to limit recirculation of water between the two systems
and inhibit any flow of contaminants not captured by the extraction wells. Treated water from the CERCLA
Wastewater Treatment Plant is conveyed to the Basin A Neck treatment plant by an underground pipeline, combined
with effluent from the plant at a maximum rate of 5 gpm, and reinjected in the Basin A Neck reinjection trenches. The
CERCLA Wastewater Treatment Plant treats water in a semibatch mode on an as-needed basis.
Groundwater extracted from both the Basin A Neck and the Basin F Groundwater IRAs is treated at the Basin A Neck
IRA treatment facility. Approximately 1 to 4 gpm of groundwater from the Basin F Groundwater IRA is filtered and
then treated in an air stripper. The vapor emissions from the air stripper are treated by two vapor-phase GAC vessels
operated in series and an additional backup unit. The effluent from the air stripper is combined with the Basin A Neck
IRA influent and treated by pre-filtration through a multimedia filter followed by adsorption in two 2,000-lb carbon
vessels in series (one backup vessel is on standby). The GAC effluent is filtered through multimedia filters and
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discharged to a 3,000-gallon effluent tank. Water from the tank is then filtered through 5-micron bag filters and
pumped to the recharge trenches.
The Basin A Neck IRA treatment system generates two sidestreams requiring treatment or disposal, spent carbon and
filter solids. The spent carbon in the adsorbers is removed and regenerated at an off-post facility. The filter solids are
disposed in a landfill regulated by RCRA and CHWMA.
The components of this alternative are summarized in Table 7.2-1. The total estimated cost for this alternative (in
1995 dollars) is $139 million (present worth cost of $98 million). A breakdown of capital and O&M costs is
presented in Table 7.2-2. Operations under this alternative are assumed to continue for at least 30 years.
7.2.3.3 Alternative 3 - Boundary Systems/IRAs/On-Post Dewatering
Alternative 3 includes all components described for Alternative 2. In addition, the water table in the Basin A and
South Plants areas is lowered by installing a network of dewatering wells (active dewatering) in die central areas of
South Plants and Basin A and by installing caps or soil covers in the same area as part of the soil remedy (passive
dewatering). Extracted water is treated in a new treatment system by air stripping and GAC adsorption and is then
reinjected. Concurrently, groundwater in the South Tank Farm Plume is treated by active in situ biological treatment.
The South Tank Farm Plume is monitored for the presence of LANPL and, if freely drainable product accumulates to a
sufficient thickness, this product is separated and treated. Treatment system and groundwater monitoring is
conducted.
Alternative 3 involves removing the most contaminated portions of the Basin A Plume Group, lowering and
maintaining future groundwater levels beneath Basin A, and dewatering the South Plants groundwater mound,
including the South Plants North Source and South Plants Southeast Plumes. Based on modeling results (see Foster
Wheeler Environmental 1995c) for the proposed well layout in Basin A and South Plants, an initial pumping rate of
approximately 80 gpm will be used for the first 10 years to reduce the groundwater mound. After 10 years, a
pumping rate of 35 gpm will be used to maintain groundwater elevations. Dewatering is accomplished using a
system of horizontal wells that are installed prior to the initiation of structures medium remedial activities. The caps
are installed as part of the soil remedy. The successful operation of the alternative relies on the active
extraction/dewatering of the aquifer to reverse horizontal gradients and induce inward flow to the dewatering well
system.
The operational goal under Alternative 3 for Basin A is to actively dewater contaminated portions of the soil and the
alluvial aquifer. During the first decade (Phase I), the extraction system removes an estimated 60 gpm and the water
table is artificially lowered 20 ft or more in the center of Section 36, and to a lesser degree in other areas beneath
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Basin A. It is estimated that the long-term pumping rate sufficient to maintain this depressed water level is
approximately 20 gpm in Basin A once the soil cap or cover is in place (Phase II). The Basin A Neck IRA intercept
system continues to operate and extracts contaminants that are downgradient and beyond the influence of the
dewatering system. The dewatering systems are expected to be installed prior to installation of the Basin A and South
Plants soil covers, which are to be completed as part of the soil remedy.
Under Alternative 3, dewatering and in situ biotreatment occur concurrently in the South Plants area. Because
horizontal wells are used, dewatering under the South Plants Central Processing Area can be initiated before or during
demolition or capping activities. The water table is lowered approximately 20 ft through extraction of 20 gpm during
the first 10 years (Phase I). The water level is then maintained through extraction of 15 gpm in Phase II. The use of
horizontal wells provides flexibility in the overall cleanup of South Plants because the wells can be installed from
outside the other construction and demolition areas. The concurrent treatment for the South Tank Farm Plume involves
in situ biodegradation of benzene. Water is extracted from the South Tank Farm Plume source area at a rate of 10 gpm.
The extracted groundwater is transferred to a collection tank and men reinjected after the appropriate amounts of
hydrogen peroxide and nutrients have been added; reinjecting the water flushes the plume as it enhances biological
growth and degradation of contaminants in the subsurface. When the northernmost cell (Cell I) of the in situ
biotreatment system becomes inefficient after several years due to dewatering of the South Plants area, three of the
injection wells in Cell I are converted to extraction wells and become part of the overall dewatering system. The
remainder of the in situ system continues to operate for an estimated 10 years.
Each of the proposed extraction systems under Alternative 3 requires installation of performance monitoring wells.
Groundwater-quality and water-level data from the newly installed performance monitoring wells are used to evaluate
the effectiveness and operation of the extraction/dewatering system. The final location of the wells is based upon
review of existing well locations and screened intervals. Where appropriate, existing wells are utilized in place of
construction of new monitoring wells.
The components of this alternative are summarized in Table 7.2-1. The total estimated cost for mis alternative (in 1995
dollars) is $179 million (present worth cost of $130 million). A breakdown of capital and O&M costs is presented in
Table 72-2. Operations under this alternative are assumed to continue for at least 30 years.
7.2.3.4 Alternative 4 - Boundary Systems/IRAs/lntercept Systems
Alternative 4 includes all components of Alternative 2 as well as groundwater extraction from the Section 36 Bedrock
Ridge Plume in an interceptor configuration followed by treatment at the existing Basin A Neck IRA (which includes
air stripping and GAC adsorption). Treated water is reinjected to the aquifer through the existing recharge trenches.
The interceptor configuration is designed to prevent further migration of the Section 36 Bedrock Ridge Plume northeast
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7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed
out of the Basin A area towards the First Creek drainage. Alternative 4 is accomplished in conjunction with the soil
remedy, which includes caps or soil covers over the Basin A and South Plants areas, and caps and slurry walls
associated with the Shell Trenches and the Army Complex Trenches.
Groundwater-quality and water-level data are collected and used to evaluate the effectiveness and operation of the
Bedrock Ridge and Basin A Neck systems. It is assumed that mere are sufficient existing wells in both areas to be used
for performance monitoring, so no new wells are installed. Wells closed during the implementation of the soil remedy
will be replaced if required to maintain adequate performance monitoring. Further evaluation of the hydraulic control
provided by the entire system (wells, caps, and slurry walls) will be performed during the remedial design.
Alternative 4 also includes groundwater monitoring of the CFS. Monitoring of the CFS is to be conducted in the
South Plants area, the Basin A area, and close to Basin F. Data from these wells are assessed to determine whether
contaminant levels within the CFS are increasing or migrating significantly with time. Due to poor construction or
documentation of well-installation techniques, screened intervals, and bentonite-seal locations, approximately 30 to 40
CFS wells are closed and abandoned. Both groundwater and system monitoring continues.
Water levels in Lake Ladora, Lake Mary, and Lower Derby Lake will be maintained to support aquatic ecosystems.
The biological health of the ecosystems will continue to be monitored. Lake-level maintenance or other means of
hydraulic containment or plume control will be used to prevent South Plants plumes from migrating into the lakes at
concentrations exceeding CBSGs in groundwater at the point of discharge. Groundwater monitoring will be used to
demonstrate compliance.
The components of this alternative are summarized in Table 7.2-1. The total estimated cost for this alternative is
$146 million (present worth cost of $104 million). A breakdown of capital and O&M costs is presented in Table
7.2-2. Operations under this alternative are assumed to continue for at least 30 years.
7.3 Description of Sitewide Remedial Alternatives for Structures
7.3.1 Description of Medium
As described in Section 5 and detailed in the structures inventory tables (Tables 5.4-6 through 5.4-9), approximately
94 percent of the remaining 798 structures at RMA were identified as potentially contaminated based on previous
use or location in manufacturing areas. To date, 525 structures at RMA have been demolished. The debris has been
disposed off post or is awaiting disposal.
FOSTER ® WHEELER
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Record of Decision for the On-Post Operable Unit
7.3.2 Remedial Action Objectives
The RAOs for structures were developed based on potential risks, both physical and chemical, to human and
ecological receptors through the potential exposure pathways of inhalation, dermal contact, or ingestion of
contaminants potentially present in, or emanating from, structures at RMA. They were also based on the potential
for the movement of contaminants through soil, air, or water from structures. The RAOs for the structures medium
are as follows:
Human Health
• Prevent contact with the physical hazards and contaminant exposure associated with structures.
• Limit inhalation of asbestos fibers to applicable regulatory standards.
• Limit releases or migration of COCs from structures to soil or water in excess of remediation goals for
those media or to air in excess of risk-based criteria for inhalation as developed in the HHRC.
Ecological Protection
• Prevent contact with the physical hazards associated with structures.
• Prevent biota from entering structures that are potentially contaminated.
7.3.3 Description of Sitewide Remedial Alternatives for Structures
Before any structures remedial alternatives can be implemented, each structure must be visually examined to
determine the structural integrity of the building. The decontamination status of each structure is also determined
with respect to ACM and PCBs.
The scope of the ongoing Asbestos IRA is to remove and dispose all ACM from RMA structures, piping, and tanks.
The Asbestos IRA continues as part of the structures remediation, so any asbestos remaining in the structures will be
removed as an integral part of the remediation process and disposed in the on-post hazardous waste landfill.
Agent-related and nonagent-related process equipment and piping located in the North Plants and South Plants is being
sampled, decontaminated, and dismantled under the Chemical Process-Related Activities IRA. Although much of the
equipment in these areas has already been removed, process-related equipment not remediated as part of this IRA will
be disposed in the new on-post TSCA-compliant hazardous waste landfill as part of the final remedy.
Army structures have been subject to a comprehensive sampling program under the PCB IRA to identify all PCB-
contaminated equipment and structural materials. The results of this program are to be presented in the PCB IRA
completion report. PCB-contaminated materials will be disposed in the on-post hazardous waste landfill, which will
meet Toxic Substances Control Act (TSCA) requirements. The results of the PCB IRA completion report for Army
structures will be incorporated into remediation activities as discussed below.
FOSTER E| WHEELER
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7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed
Equipment and structures for which the Army has responsibility will be handled as follows:
• Equipment - PCB fluids will be drained and sent off post for disposal in compliance with applicable TSCA
regulations. PCB-contaminated equipment will be disposed in the new on-post hazardous waste landfill
that meets TSCA requirements. The equipment will be disposed under one of three possible scenarios:
- Identified and disposed as part of the ongoing PCB IRA.
- Identified under the PCB IRA but disposed under the final structures cleanup.
- Agent-decontaminated materials to be disposed under the final structures cleanup.
• Structures - The PCB contamination in No Future Use structural materials will be identified in the PCB
IRA completion report. Based on a 50 parts per million (ppm) action level, structural materials will be
addressed in one of two ways:
- Structural materials with PCB concentrations of 50 ppm or above that exist above the ground elevation, as
well as contaminated parts of ground floor slabs and foundations that will be removed, will be identified
prior to demolition, segregated during demolition, and disposed in the on-post TSCA-compliant
hazardous waste landfill. Similar materials with PCB concentrations less than 50 ppm will be disposed
according to use history as described in the alternative detailing.
- PCB-contaminated sections of ground floor slabs or foundations at or below grade that are not required to
be demolished as part of the remediation and with PCB concentrations of less than 50 ppm will be left in
place. However, slabs or foundation materials with PCB concentrations of 50 ppm or greater will be
removed during demolition and disposed in the new TSCA-compliant hazardous waste landfill.
Army Future Use structures have been managed for occupancy under current environmental and worker protection
regulations. There is no evidence of PCB contamination in this medium group.
Potential PCB contamination in Shell structures are to be identified through visual evidence, and will be disposed in
accordance with TSCA requirements and guidance. Structures and equipment for which Shell has responsibility are so
indicated in Tables 5.4-6 through 5.4-9 and will be handled as follows:
• All Shell buildings to be demolished during the final remedy will be inspected for equipment containing
fluids potentially contaminated with PCBs prior to demolition. Potentially contaminated fluids will be
drained and sent off post for disposal in compliance with applicable TSCA regulations. Equipment that
contained these fluids, as well as all other equipment, will be disposed in the on-post TSCA-compliant
hazardous waste landfill. Significant Contamination History structures will be demolished and the
resulting debris will be placed in the new on-post TSCA-compliant hazardous waste landfill. Other
Contamination History structures will be evaluated by Shell and EPA for any visual evidence of leaks or
spills. If observed in areas where potential PCB releases may be reasonably expected to occur, the affected
debris will be disposed in the on-post TSCA-compliant hazardous waste landfill. Examples of this type of
visual evidence would include stains near equipment potentially containing PCB fluids or stains in
buildings where there are numerous instances of equipment potentially containing PCB-contaminated
fluids. Further details of this work will be addressed at the remedial design stage.
• All fluorescent-light ballasts will be disposed at an off post-disposal facility in accordance with applicable
TSCA regulations.
Shell does not have responsibility for any structures within the Future Use or Agent History Groups.
FOSTER © WHEELER
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Most of the demolition at RMA will consist of dismantling (i.e., reducing a standing building to a pile of debris),
using a combination of demolition techniques and equipment such as a backhoe with a thumb attachment, a
wrecking ball and crane, or a crane and clamshell, or by performing piece-by-piece disassembly, sawing, or
crushing. Additional techniques, such as structural undermining or explosives demolition, may be appropriate in
some cases. Standard dust-suppression measures consistent with the remediation goals are used throughout the
demolition process to meet state and federal requirements.
As the structural debris is removed, materials are segregated for purposes of recycling and waste classification.
Economically recyclable materials, such as scrap metals, are collected for salvage. Structural materials not salvaged
are placed in a bermed dirt or concrete staging area. Hie debris is segregated into potentially hazardous and
nonhazardous waste as the structure is dismantled and placed in separate containment areas. The debris is sized for
disposal concurrent with stockpiling to limit the amount of settling in the landfill or consolidation area. Due to the
potential hazards, these handling activities are limited for Agent History structures.
The debris is then transported by truck to the disposal site. Debris from Agent History structures is monitored for
the presence of agent and treated, as necessary, before disposal in the hazardous waste landfill. Agent-contaminated
structures will be handled in compliance with AR 385-61, AR 50-6, and Department of Defense regulations in effect
at the time of remediation. Action must be taken to treat the agent contamination within the structure or debris to a
level consistent with Army regulations (3X or 5X) so it may be properly disposed. Debris from the Significant
Contamination and Other Contamination History structures are taken directly to the hazardous waste landfill,
depending on the remedial alternative. Floor slabs and foundations at or below grade for the Other Contamination
History and Significant Contamination History Groups are left in place unless they must be removed to provide
access to underlying contaminated soil (i.e., the slabs and foundations of structures located in the South Plants
Central Processing Area within principal threat or human health soil exceedance areas, which are removed to a
depth of 5 ft along with the contaminated soil). Floor slabs not removed are broken in place to prevent water
ponding and are contained beneath the soil covers specified for the specific areas in which they occur (see Section
7.4).
7.3.3.1 Alternative 1- Landfill/Cap in Place
Alternative 1 addresses each of the three No Future Use medium groups as follows:
• No Future Use, Significant Contamination History - The structures are dismantled using dust controls,
metals salvaged (if appropriate), and the remaining debris disposed in the on-post hazardous waste landfill.
• No Future Use, Other Contamination History - The structures are dismantled using dust controls, metals
salvaged (if appropriate), and the remaining debris consolidated and capped in one of three places: the
Rail Yard, North Plants, or the South Plants Central Processing Area. Multilayer caps are used for
containment of the debris.
FOSTER ® WHEELER
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7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed
• No Future Use, Agent History - The structures are dismantled using dust controls and air monitoring, the
debris monitored for the presence of Army chemical agent and caustic washed as necessary, and the
resulting debris disposed in the on-post hazardous waste landfill. Spent caustic wash is treated in an
evaporator/crystallizer; the resulting waste salts are drummed and disposed in the on-post hazardous waste
landfill.
The components of this alternative are summarized in Table 7.3-1. The total estimated cost of this alternative (in
1995 dollars) is $114 million (present worth cost of $106 million). A breakdown of capital and O&M costs for each
component of this alternative is presented in Table 7.3-2. This alternative requires approximately 2 years for
implementation.
7.3.3.2 Alternative 2 - Landfill/Consolidate
Alternative 2 addresses each of the three No Future Use medium groups as follows:
• No Future Use, Significant Contamination History - The structures are dismantled using dust controls,
metals salvaged (if appropriate), and the remaining debris disposed in the on-post hazardous waste landfill.
• No Future Use, Other Contamination History - The structures are dismantled using dust controls, metals
salvaged (if appropriate), and the remaining debris transported to the Basin A consolidation area for use as
gradefill.
• No Future Use, Agent History - The structures are dismantled using dust controls and air monitoring, the
debris monitored for the presence of Army chemical agent and caustic washed as necessary, and the
resulting debris disposed in the on-post hazardous waste landfill. Spent caustic wash is treated in an
evaporator/crystallizer; the resulting waste salts are drummed and disposed in the on-post hazardous waste
landfill.
The components of this alternative are summarized in Table 7.3-1. The total estimated cost of this alternative (in
1995 dollars) is $112 million (present worth cost of $104 million). A breakdown of capital and O&M costs for each
component of this alternative is presented in Table 7.3-2. This alternative requires approximately 2 years for
implementation.
7.3.3.3 Alternative 3 - Landfill
Alternative 3 addresses each of the three No Future Use medium groups as follows:
• No Future Use, Significant Contamination History - The structures are dismantled using dust controls,
metals salvaged (if appropriate), and the remaining debris disposed in the on-post hazardous waste landfill.
• No Future Use, Other Contamination History - The structures are dismantled using dust controls, metals
salvaged (if appropriate), and the remaining debris disposed in the on-post hazardous waste landfill.
• No Future Use, Agent History - The structures are dismantled using dust controls and air monitoring, the
debris monitored for the presence of Army chemical agent and caustic washed as necessary, and the
resulting debris disposed in the on-post hazardous waste landfill. Spent caustic wash is treated in.an
evaporator/crystallizer; the resulting waste salts are drummed and disposed in the on-post hazardous waste
landfill.
FOSTER GJ WHEELER
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Record of Decision for the On-Post Operable Unft
The components of this alternative are summarized in Table 7.3-1. The total estimated cost of this alternative (in
1995 dollars) is $118 million (present worth cost of $109 million). A breakdown of capital and operating and
maintenance costs for each component of this alternative is presented in Table 7.3-2. This alternative requires
approximately 2 years for implementation.
7.4 Description of Sltewlde Remedial Alternatives for Soil
7.4.1 Description of Medium
As described in Section 5, the majority of contamination is present in the trenches, disposal basins, and the South
Plants manufacturing area, covering approximately half of the central six sections of RMA (Figure 5.4-1 and
Tables 5.4-11 and 5.4-12). The highest contaminant concentrations tend to occur in soil within 5 ft of the ground
surface, although exceptions are noted, particularly at sites where burial trenches, disposal basins, or manufacturing
complexes are located. In general, contaminant distribution is significantly influenced most by the physical and
chemical properties of the contaminants, the environmental media through which they are transported, and the
characteristics of the sources (i.e., former manufacturing and disposal practices).
7.4.2 Remedial Action Objectives
The RAOs identified for the soil medium are the following:
Human Health
• Prevent ingestion of, inhalation of, or dermal contact with soil or sediments containing COCs at
concentrations that generate risks in excess of 1 x 10"4 (carcinogenic) or an HI greater than 1.0
(noncarcinogenic) based on the lowest calculated reasonable maximum exposure (5th percentile) PPLV
values (which generally represent the on-site biological worker population).
• Prevent inhalation of COC vapors emanating from soil or sediments in excess of acceptable levels, as
established in the HHRC.
• Prevent migration of COCs from soil or sediment that may result in off-post groundwater, surface water, or
windblown particulate contamination in excess of off-post remediation goals.
• Prevent contact with physical hazards such as UXO.
• Prevent ingestion of, inhalation of, or dermal contact with acute chemical agent hazards.
Ecological Protection
• Ensure that biota are not exposed to COCs in surface water, due to migration from soil or sediment, at
concentrations capable of causing acute or chronic toxicity via direct exposure or bioaccumulation.
• Ensure that biota are not exposed to COCs in soil and sediments at toxic concentrations via direct exposure
or bioaccumulation.
7.4.3 Description of Sitewide Remedial Alternatives for Soil
The implementation of any soil alternative is tied to structures remediation because most of the structures at RMA
are located in areas of soil contamination. In such areas, structures must be demolished before components of the
soil remedy, such as excavation or the construction of containment systems, can be implemented.
FOSTER ® WHEELER
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7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed
PCB-contaminated soil at RMA was identified under the PCB IRA program. The remedial activities for PCB-
contaminated soil are dependent on the concentration and location as follows:
• The three PCB-contaminated soil areas identified by the PCB IRA with concentrations of 250 ppm or
greater will be removed. The limits of contamination will be determined based on visual evidence with
immunoassay field confirmation sampling (SW-846).
• There are five PCB-contaminated soil areas identified by the PCB IRA with concentrations from SO ppm to
below 250 ppm. These areas will receive a minimum of 3 ft of soil cover, and the PCB-contaminated soil
there will be left in place. The soil cover will be maintained as part of the wildlife refuge and is subject to
the institutional controls of the FFA.
• No remaining areas of PCB-contaminated soil with concentrations above 50 ppm have been identified by
the PCB IRA. If necessary, any suspected PCB soil contamination areas will be characterized further
during the remedial design. If additional PCB-contaminated soil is found in concentrations of 50 ppm or
above, the Army will determine any necessary remedial action in consultation with EPA.
• PCB-contaminated soil that is excavated under any soil alternative is disposed in the on-post TSCA-
compliant landfill.
7.4.3.1 Alternative 1 - Caps/Covers
Alternative 1 involves the containment of 1,200 acres through the installation of a cap and the landfilling of
290,000 bank cubic yards (BCY) of contaminated soil. Under this alternative, multilayer caps are installed to
contain contaminated soil. The capped areas are located in the central portions of RMA (Figure 7.4-1). The
existing cover for the Former Basin F Subgroup is augmented to improve performance and meet EPA guidance
governing caps and covers. A composite cap is constructed over the existing cover for the Basin F Wastepile.
Approximately 17.8 million BCY of borrow materials are required as backfill and gradefill to achieve the design
grades for capping, and an additional 11.3 million BCY of borrow (clay and common fill) are required for
construction of the caps.
In addition to capping, all sewer manholes are plugged with cement. Slurry walls are used in conjunction with caps
for the Complex Trenches, Shell Trenches, Hex Pit, and Buried M-1 Pits Subgroups to augment the containment of
these sites. The groundwater inside the contained area is pumped and treated if necessary.
Areas outside the central portions of RMA that are suspected to have potential chemical agent or UXO presence are
screened and cleared. Any excavated agent-contaminated soil identified during agent monitoring is treated by
caustic washing and then landfilled. In addition, any identified HE-filled (high explosive) or agent-filled UXO is
excavated, packaged, and transported off post to an existing Army facility for detonation and disposal (unless the
UXO is unstable and must be detonated on post) or other demilitarization process. The 200,000 BCY of
contaminated soil and debris from several sites in the eastern and western portions of RMA are excavated and
placed in the on-post hazardous waste landfill along with debris from munitions screening operations. The
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Record of Decision for the On-Post Operable Unit
110,000 BCY of human health exceedances from the Surflcial Soil, Lake Sediments, and Agent Storage Medium
Groups are also landfilled.
Soil posing risk to biota is generally capped as discussed above. No action is undertaken for soil that potentially
poses risks to biota that is located outside of the capped area including Upper Derby Lake and the Surflcial Soil,
Ditches/Drainage Areas, and Agent Storage Medium Groups. The soil in these areas is sampled periodically. No
action (other than monitoring) is conducted for the aquatic lake sediments. Ongoing monitoring of biota in these
areas will be conducted in support of design refinement/design characterization.
The components of this alternative are summarized in Table 7.4-1. The total estimated cost for this alternative (in
1995 dollars) is $542 million (present worth cost of $386 million). A breakdown of capital and O&M costs for each
component of this alternative is presented in Table 7.4-2. This alternative requires approximately 17 years for
implementation.
7.4.3.2 Alternative2-Landfill/Caps
Alternative 2 involves containment of approximately 490 acres through the installation of multilayer caps and the
landfilling of 2 million BCY of contaminated soil. The areas outside the central portion of RMA are excavated and
landfilled. The 110,000 BCY of human health exceedances from the Lake Sediments, Surficial Soil, and Agent
Storage Medium Groups are landfilled. Any excavated agent-contaminated soil identified during monitoring is
treated by caustic washing and then landfilled. In addition, any HE-filled or agent-filled UXO identified through
geophysical surveys or other screening methods are excavated, packaged, and transported off-post to an existing
Army facility for detonation and disposal (unless the UXO is unstable and must be detonated on post) or other
demilitarization process. Chemical sewer lines in the central portion of the South Plants complex and within the
Complex Trenches are plugged with cement and the sanitary sewer manholes are plugged. The remaining chemical
sewers and associated contaminated soil are excavated and placed in the on-post hazardous waste landfill.
A 390-acre area in the central portion of RMA is covered with multilayer caps. The capped areas consist of human
health exceedance areas and areas with residual contamination in Section 36, the South Plants Central Processing
Area, and the Former Basin F (Figure 7.4-2). The existing cover for the Former Basin F Subgroup is augmented to
improve performance and meet EPA guidance governing caps and covers. A composite cap is constructed over the
existing cover for the Basin F Wastepile. Approximately 8.8 million BCY of borrow materials are required as
backfill and gradefill to achieve the design grades for capping, and an additional 3.9 million BCY of borrow (clay
and common fill) are required for construction of the caps.
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7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed
Slurry walls are used in conjunction with caps for the Complex Trenches, Shell Trenches, Hex Pit, and Buried M-l
Pits Subgroups to augment the containment of these sites. The groundwater inside the contained area is pumped
and treated if necessary to maintain lowered water table elevations.
Soil posing risk to biota within the central six sections of RMA is generally excavated and landfilled as discussed
above. No action is undertaken for soil that potentially poses risks to biota that is located outside of the capped area
including Upper Derby Lake and the Surficial Soil, Ditches/Drainage Areas, and Agent Storage Medium Groups.
Although a residual risk to biota exists outside the capped area, the magnitude of die residual risk is comparatively
low (see Section 6.2.4.3) and the short-term destruction of habitat is minimized. The soil in these areas is sampled
periodically. No additional action other than monitoring is conducted for the aquatic lake sediments. Ongoing
monitoring of biota in these areas will be conducted in support of design refinement/design characterization.
The components of this alternative are summarized in Table 7.4-1. The total estimated cost for this alternative (in
1995 dollars) is $383 million (present worth cost of $276 million). A breakdown of capital and O&M costs for each
component of this alternative is presented in Table 7.4-2. This alternative requires approximately 16 years for
implementation.
7.4.3.3 Alternative 3 - Landfill
Alternative 3 involves the containment of 3.4 million BCY of contaminated soil in an on-post hazardous waste
landfill. Approximately 100 acres of principal threat or human health exceedance soil areas are contained with a
multilayer cap instead of being landfilled, and 300 acres are capped (multilayer cap), after removing the human
health exceedance volume and landfilling, to address residual contamination (Figure 7.4-3).
Contaminated soil from nearly all of the sites (3.4 million BCY total) is excavated and landfilled. Chemical sewers
and associated contaminated soil are excavated and placed in the on-post hazardous waste landfill. The 87,000
BCY of human health exceedance volume from the Surficial Soil Medium Group, soil with human health
exceedances in the Agent Storage Medium Group (2,900 BCY), and human health exceedances and soil that may
pose a risk to biota from the Lake Sediments (including portions of Upper Derby Lake) and Ditches/Drainage Areas
Medium Groups (90,000 BCY) are also excavated and landfilled. Any excavated agent-contaminated soil identified
during monitoring is treated by caustic washing and then landfilled. The excavation of the Former Basin F, Buried
M-l Pits, Shell Trenches, and Hex Pit Subgroups requires the use of vapor- and odor-suppression measures such
as foam, liners, or a transportable structure.
The sanitary sewer manholes are plugged. Any HE-filled (high explosive) and agent-filled UXO identified through
geophysical surveys or other screening methods are excavated, packaged, and transported off post to an existing
FOSTER © WHEELER
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Anny facility for detonation and disposal (unless the UXO is unstable and must be detonated on post) or other
demilitarization process.
The Basin F Wastepile and the Complex Trenches Subgroups are left in place and capped. A composite cap is
constructed over the existing cover for the Basin F Wastepile. Following the excavation and landfilling of human
health exceedances, 390 acres in Section 36, South Plants Central Processing Area, and the Former Basin F are
capped (multilayer caps). Approximately 10.1 million BCY of borrow materials are required as backfill and
gradefill to achieve the design grades for capping, and an additional 3.86 million BCY of borrow are required for
construction of the cap.
Slurry walls are used in conjunction with the caps for the Complex Trenches Subgroup to augment the containment
of this site. The groundwater inside the contained area is pumped and treated.
Soil posing risk to biota within the central six sections of RMA is generally excavated and landfilled as discussed
above. No action is undertaken for soil that potentially poses risks to biota in the Surficial Soil Medium Group, but
the soil in this area is sampled periodically. Although a residual risk to biota exists in this medium group, the
magnitude of the residual risk is comparatively low (see Section 6.2.4.3) and the short-term destruction of habitat is
minimized. No action other than monitoring is conducted for the aquatic lake sediments. Ongoing monitoring of the
biota in these areas will be conducted in support of design refinement/design characterization.
The components of this alternative are summarized in Table 7.4-1. The total estimated cost for this alternative (in
1995 dollars) is $576 million (present worth cost of $384 million). A breakdown of capital and O&M costs for each
component of this alternative is presented in Table 7.4-2. This alternative requires approximately 22 years for
implementation.
7.4.3.4 Alternative 4 - Consolidation/Caps/Treatment/Landfill
Alternative 4 involves consolidation of 1.5 million BCY of soil with low levels of contamination into Basin A,
Former Basin F, and the South Plants Central Processing Area; capping or covering of 1,100 acres of contaminated
soil; landfilling of 1.7 million BCY of soil and debris; and treatment of 207,000 BCY of soil by solidification/
stabilization (Figure 7.4-4). This alternative also includes a contingent soil volume of 150,000 BCY that may be
landfilled. The locations of the contingent volume will be based on visual field observations such as soil stains,
presence of barrels, or newly discovered evidence of contamination. In addition, 14 samples from North Plants,
Toxic Storage Yards, Lake Sediments, Sand Creek Lateral, and Burial Trenches Medium Groups and up to 1,000
additional confirmatory samples may be used to identify the contingent soil volume requiring landfilling.
FOSTER 0 WHEELER
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7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed
Approximately 180,000 BCY of principal threat soil in the Former Basin F are treated by in situ
solidification/stabilization, and 26,000 BCY of principal threat and human health exceedance soil from the Buried
M-l Pits are excavated, solidified, and placed in the on-post landfill. Excavation of the Buried M-l Pits will be
conducted using vapor-, and odor-suppression measures.
Approximately 1,000 BCY of principal threat material from the Hex Pit are treated using an innovative thermal
technology. The remaining 2,300 BCY are excavated and disposed in the on-post hazardous waste landfill.
Remediation activities will be conducted using vapor- and odor-suppression measures as required. Treatability
testing will be performed during remedial design to verify the effectiveness of the innovative thermal process and
establish operating parameters for the design of the full-scale operation. The innovative thermal technology must
meet the treatability study technology evaluation criteria as described in the dispute resolution agreement (PMRMA
1996). Treatment will be revised to a solidification/stabilization technology if all evaluation criteria for the
innovative thermal technology are.not met. Treatability testing for solidification will be performed to verify the
effectiveness of the solidification process and determine appropriate solidification/stabilization agents. Treatability
testing and technology evaluation will be conducted in accordance with EPA guidance (OSWER-EPA 1989a) and
EPA's "Guide for Conducting Treatability Studies Under CERCLA" (1992).
The approximately 650,000 BCY of highly contaminated soil from the Basin F Wastepile and the Section 36 Lime
Basins Subgroups is excavated (using vapor- and odor-suppression measures) and disposed in triple-lined cells
within the on-post hazardous waste landfill. Soil from the Basin F Wastepile not passing the EPA paint filter test
(SW-846, Method 9095) will be reduced to acceptable moisture-content levels by using a dryer in an enclosed
structure. Any contaminants released from the soil during drying will be captured and treated.
Approximately 1 million BCY of human health exceedance soil from other sites throughout RMA, as well as debris
from UXO clearance operations, are landfilled under this alternative. Any excavated agent-contaminated soil
identified during monitoring is treated by caustic washing and then landfilled. In addition, any identified HE-filled
and agent-filled UXO are excavated, packaged, and transported off post to an existing Army facility for detonation
and disposal (unless the UXO is unstable and must be detonated on post) or other demilitarization process.
Slurry walls are used in conjunction with the caps for the Shell Trenches and Complex Trenches Subgroups to
augment the containment of these sites. For the purposes of conceptual design and costing during the FS, it was
assumed that the groundwater inside the contained area is pumped and treated at the Basin A Neck treatment system
(this assumption will be reevaluated during the remedial design). The Shell Trenches and Complex Trenches caps
are designed to be RCRA-equivalent caps. The complex trenches cap includes a 6-inch-thick formed concrete
layer. The sanitary sewer manholes and the chemical sewers located in the South Plants Central Processing Area
FOSTER © WHEELER
nna\1491G.DOC FOSTER WHEELER ENVIRONMENTAL CORPORATION 7-25
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Record of Decision for the On-Post Operable Unit
and Complex Trenches are plugged. The remaining human health exceedance soil and chemical sewer debris are
excavated and placed in the landfill.
Soil posing a potential risk to biota within the Secondary Basins as well as the North Plants Manufacturing Area is
contained in place using 2-ft-thick soil covers. Soil posing a potential risk to biota within the Ditches/Drainage
Areas, Sanitary Landfills, Section 36 Balance of Areas, Sand Creek Lateral, South Plants, and some of the Lake
Sediments and Surficial Soil Medium Groups/Subgroups are consolidated as gradefill soil within Basin A, South
Plants Central Processing Area, or Former Basin F and are contained beneath the cap or soil covers for those sites.
The construction of the cap and covers of these three areas requires approximately 5.7 million BCY of gradefill to
provide sufficient slope for proper drainage. Other sites require an additional 3.1 million BCY of backfill and
gradefill to achieve design grades for caps/covers. An additional 5.1 million BCY of borrow material are required
for construction of all caps/covers. The Former Basin F cap is designed to be RCRA-equivalent. Basin A and the
South Plants Central Processing Area are contained with a 4-ft-thick soil cover and, respectively, a 6-inch-thick
formed concrete layer and 1-ft-thick crushed concrete layer for prevention of biota intrusion.
The South Plants Balance of Areas is covered with a variable-thickness soil cover. The former human health
exceedance area is covered with a 3-ft-thick soil cover and the former potential risk to biota area is covered with a
1-ft-thick soil cover. Prior to placing this cover, two composite samples per acre will be collected to ensure that the
soil under the 1-ft-thick soil cover does not exceed human health or principal threat criteria. If the residual soil is
found to exceed these levels, the 3-ft-thick cover will be extended over these areas or the exceedance soil will be
excavated and landfilled. The top 1 ft of the entire soil cover area will be constructed using uncontaminated soil
from the on-post borrow areas.
The Section 36 Balance of Areas will also be covered with a variable-thickness soil cover. The former human
health exceedance area is covered with a 2-ft-thick soil cover and the former potential risk to biota area is covered
with a 1-ft-thick soil cover.
Soil posing risk to biota is generally excavated and consolidated within the Basin A and South Plants Central Area
covers or placed beneath the Basin F cap. No action is undertaken for soil that potentially poses risks to biota that is
located outside of this area, i.e., soil within the Lake Sediments or Surficial Soil Medium Groups. Although a
residual risk to biota exists in these areas, the magnitude of the residual risk is comparatively low (see Section
6.2.4.3) and the short-term destruction of habitat is minimized. These areas are sampled periodically. No action
(other than monitoring) is conducted for the aquatic lake sediments. Ongoing monitoring of the biota in these areas
will be conducted in support of design refinement/design characterization.
FOSTER 0 WHEELER
7-26 FOSTER WHEElfR ENVIRONMENTAL COHFOMT10N ma\149IG.DOC
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7.0 Description of the Feasibility Study Process and the Remedial Alternatives Developed
The components of this alternative are summarized in Table 7.4-1. The total estimated cost for this alternative (in
1995 dollars) is $566 million (present worth cost of $401 million). A breakdown of capital and O&M costs for each
component of this alternative is presented in Table 7.4-2. This alternative requires approximately 17 years for
implementation.
7.4.3.5 Alternative 5 - Caps/Treatment/Landfill
Alternative 5 is composed of the following features: capping of 530 acres of contaminated soil, landfilling of
4 million BCY of soil and debris, and treatment of 1.1 million BCY of contaminated soil (Figure 7.4-5).
Approximately 1.1 million BCY of principal threat soil are treated by thermal desorption, incineration, or
solidification/stabilization. The majority of the soil treated by thermal desorption is from the Basin F Wastepile,
Former Basin F and South Plants Central Processing Area Subgroups. The excavation of soil from both the Basin F
Wastepile and Former Basin F for treatment may require use of vapor- and odor- suppression measures. Soil in the
Shell Trenches and Hex Pit Subgroups (103,000 BCY) is excavated and treated by incineration. The excavation of
both the Shell Trenches and Hex Pit also requires use of vapor- and odor-suppression measures. All soil treated by
thermal desorption or incineration is placed in the on-post hazardous waste landfill.
A total of 27,000 BCY of soil contaminated with inorganic contaminants are treated by solidification. The majority
of the soil to be solidified is excavated from the Buried M-l Pits Subgroup, which requires vapor- and odor-
suppression measures during excavation.
The Complex Trenches Subgroup is left in place and contained with a multilayer cap and slurry walls. The
groundwater inside the contained area is pumped and treated as necessary.
Following the excavation of human health exceedance volumes for treatment or disposal, 530 acres in Section 36,
the South Plants Central Processing Area, and the Former Basin F are capped (multilayer caps). Approximately
10.5 million BCY of borrow materials are required as gradefill to achieve the design grade for the caps, and an
additional 3.9 million BCY of borrow are required for construction of the caps.
Approximately 4 million BCY of contaminated soil, primarily from sites outside of the central portions of RMA, as
well as debris from UXO clearance operations, are landfilled under this alternative. The incinerated soil and debris
and the thermally desorbed soil are also placed in the on-post hazardous waste landfill. Any agent-contaminated
soil identified during screening is treated by caustic washing and then landfilled. In addition, any identified HE-
filled and agent-filled UXO is excavated, packaged, and transported off post to an existing Army facility for
detonation and disposal (unless the UXO is unstable and must be detonated on post) or other demilitarization
FOSTER ©WHEELER
ima\I491G.DOC FOSTER WHEELER ENVIRONMENTAL CORPORATION 7-27
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Record of Decision for the On-Post Operable Unit
process. The sanitary sewer manholes are plugged. The chemical sewers and any associated contaminated soil are
excavated and placed in the on-post hazardous waste landfill. The 87,000 BCY of human health exceedance
volume from the Surficial Soil Medium Group are also landfilled.
Soil posing risk to biota within the central six sections of RMA is generally excavated and landfilled. An additional
1,600 acres, of soil representing a potential risk to the great horned owl are addressed through agricultural
practices, which reduces the level of contamination in near-surface soil. No action other than monitoring is
conducted for the aquatic lake sediments. Ongoing monitoring of biota in these areas will be conducted in support
of design refinement/design characterization.
The components of this alternative are summarized in Table 7.4-1. The total estimated cost for this alternative (in
1995 dollars) is $1.01 billion (present worth cost of $542 million). A breakdown of capital and O&M costs for each
component of this alternative is presented in Table 7.4-2. This alternative requires approximately 28 years for
implementation.
FOSTER ©WHEELER
7-28 FOrrEft WHEELER ENVIRONMENTAL COflPOMATXMI nna\1491GJDOC
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Legend
RMA Boundary
SAR Site Boundary1
Principal Threat Exceedance Area
Cancer Risk ^ 10E-3
or HI ^ 1000
Human Health Exceedance Area
Cancer Risk s 10E-4,
Chronic HI £ 1.0. or Acute HI i 1.0
Biota Risk Area
Section Number
Area of Contamination Boundary
CAMU Boundary
'Study Area Report (see Remedial
Investigation Summary Report,
Ebasco 1992o).
2Based on RME exposure parameters
and Cm
-------
5
Legend
—~ RMA Boundary
SAR Site Boundary'
j j Capped Areas
P'""II
[J Landfill Site
|?y| Areas to be Landfilled
Agent Screening Area
Agent Screening Area
(Caustic wash/landfill)
UXO Screening Area
(Detonation/landfill)
Basin F Wasteplle Cap
Access Restrictions
Section Number
'Study Area Report
(see Remedial Investigation
Summary Rsporf, Ebasco 1992a).
I
-N-
n
I MO 3000 Feet
Prepared for: U.S. Army Program Manager for
Rocky Mountain Arsenal
Figure 7.4-1
Caps/Covers Alternative
Fo'ster Wheeler Environmental Corporation
June 1996
-------
Legend
—— RMA Boundary
SAR Site Boundary'
} ) Capped Areas
F~n Landfill Site
Areas to be Landfilled
Agent Screening Area
(Caustic wash/landfill)
UXO Screening Area
(Detonation/landfill)
Basin F Wostepile Cap
Access Restrictions
Section Number
'Study Area Report
(see Remedial Investigation
Summary Report. Ebasco I992a).
-N-
d
1500 3000 Feet
Prepared for: U.S. Army Program Manager for
Rocky Mountain Arsenal
Figure 7.4-2
Landfill/Caps Alternative
Foster Wheeler Environmental Corporation
June 1996
-------
Legend
"" RMA Boundary
SAR Sits Boundary'
D Capped Areas
following Landfill
["T] Landfill Site
ETj Areas to be Landfllled
mi Agent Screening Area
HsH (Caustic wash/landfill)
UXO Screening Area
(Detonation/landfill)
Basin F Wasteptle Cap
Section Number
1 Study Area Report
(300 Remedial Investigation
Summary Report. Ebasco 1992a).
-N-
1500 3000 F«et
Prepared for: U.S. Army Program Manager for
Rocky Mountain Arsenal
Figure 7.4-3
Landfill Alternative
Foster Wheeler Environmental Corporation
June 1996
-------
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5
Legend
RMA Boundary
SAR Site Boundary1
Landfill and Cap following2
.,.,„,„,.. Thermal Desorption of
mm Principal Threat Volumes In
lisil Basin A, Former Basin F,
South Plants Central Processing
p:ii,;a Thermal Desorpfion of
ff-^f] Wastepile or Principal
Threat Volume; Landfill
Incineration
Landfill Site
Areas to be Landfilled
Cap
Direct Solidification/Stabilization
Agent Screening Area
(Caustic wash/landfill)
UXO Screening Area
(Detonation/landfill)
In Situ Agricultural Practices
Access Restrictions
Section Number
'Study Area Report
(see Remedial Investigation
Summary Report, Fbasco 1992a).
2Solldlflcatlon/Stabillzatton of Principal
Threat Volume with inorganic exceedance
tor South Plants Central Processing Area.
1300 0 1300 3000 Feet
Pr»por»d for: U.S. Army Program Manager for
Rocky Mountain Arsenal
Figure 7.4-5
Cops/Treatment/Landftll Alternative
Foster Wheeler Environmental Corporation
June 1996
-------
Table 7.1-1 Description of Water Technologies1
Page 1 of 2
Technology
Granular-Activated
Carbon Adsorption
Description
Dewatering . Dewatering involves the withdrawal of groundwater from an underground water-
bearing zone, effectively lowering the water table in an area. A lower water
table separates contamination in soil near the surface from groundwater.
Prior to dewatering, groundwater levels are close to the ground surface. In
areas of shallow groundwater, it is relatively easy for chemical spills or
contaminants in soil near the surface to migrate down to the groundwater.
Following dewatering, contaminated soil and groundwater are separated from
each other and further contamination of groundwater is reduced.
Dewatering is also used in construction and demolition activities in areas of
shallow groundwater to stabilize subsurface soil. For example, before an old
building and its basement can be demolished, the ground around it is dewatered.
Once an area is dewatered, heavy equipment can be used and water is prevented
from filling up the excavation. Dewatering also reduces the chances that the
underground walls will cave in on workers.
GAC adsorption refers to the removal of dissolved contaminants from an
aqueous stream, although it may also be applied to gaseous streams. In the
GAC process, water containing dissolved organic compounds is brought into
contact with GAC, onto which the organic compounds preferentially adsorb.
The attraction of organic molecules in solution to the surface of the carbon is
dependent on the strength of the molecular attraction between the carbon and the
organic contaminant, the molecular weight of the contaminant, the type and
characteristics of the carbon, the surface area of the carbon, and the pH and
temperature of the solution. The GAC process option can be used as a single
treatment technology or as one of a series of treatments designed to optimally
address a contaminant mixture in a treatment process train.
Air Stripping Air stripping is an effective and proven method for removal of volatile organic
compounds from water. The process involves the removal of the volatiles from
an aqueous stream by mass transfer through countercurrent contact of the stream
with air. Air stripping is a means for transferring the contamination from the
liquid phase to gas (vapor). The gases are collected and require additional
treatment.
ma\1580G
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Table 7.1-1 Description of Water Technologies1
Page 2 of 2
Technology
Description
In Situ Biological
Treatment
Groundwater
Extraction/Reinjection
In situ biodegradation, or biological treatment, takes advantage of naturally
occurring microorganisms in the aquifer that are capable of breaking down and
destroying contaminants. In situ means "in place;" the term is appended to the
name of this technology because the degradation occurs underground in the
aquifer.
The microorganisms that make this treatment technology work are already
present in the aquifer, but they are not plentiful enough to significantly decrease
the concentration of contaminants in the aquifer. To encourage their growth,
oxygen and nutrients containing nitrogen are added to the aquifer. This is done
by extracting some of the groundwater, adding chemicals to the water, and then
reinjecting it into the aquifer. The microorganism population increases after the
nutrients are added. The contaminants serve as a source of food for the
microorganisms, with the result that the contaminants are destroyed.
Groundwater extraction methods may be used to collect contaminated
groundwater from aquifers for surface treatment and reinjection, to dewater
excavations in areas with a shallow water table, and/or to contain a plume of
contaminated groundwater. The design of the extraction system is determined
by site-specific conditions and the intended purpose of the system. For
example, an intercept system may be designed to capture either the leading edge
of a plume or the most contaminated portion of the plume. Under a mass-
reduction approach, an extraction system is designed to capture the central mass
or most contaminated portion of the plume. In addition to removing the mass
of contamination, a mass reduction or dewatering approach eliminates contact
between overlying contaminated soil and groundwater by lowering the water
table. The layout, pumping rates, well spacing, etc., all differ for each of these
examples depending on the desired effect. The groundwater extraction
technology under consideration is extraction wells, with provisions for
trenches/drains if needed. The reinjection method under consideration is a
recharge trench. Extracted water is pumped to a treatment facility and the
effluent from treatment is reinjected. Recharge trenches are excavated to a
depth sufficient to convey water to the water table and may use any type of
buried conduit used to convey liquids by gravity flow.
1 Detailed discussion of all water remediation technologies considered is presented in the Detailed Analysis of Alternatives
report
rmaMSSOG
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Table 7.1-2 Description of Structures Technologies1
Page 1 of 2
Technology
Description
Structures Demolition
Salvage
On-Post Landfill
Caustic Washing of
Agent-Contaminated
Structure Debris
Structures demolition involves the physical dismantling of structures, sizing of
debris, and separation of salvageable materials. Dismantling requires the use of
medium to heavy equipment to demolish a structure, i.e., to take it apart piece
by piece. The structure is broken up using bulldozers, backhoes, wrecking balls,
clamshells, universal processors with cutting shears or other similar types of
equipment. Contaminants are not treated through this process, but the volume is
decreased and converted to a more workable form for subsequent treatment or
disposal. Dust-control measures are commonly taken during the operation,
generally consisting of spraying or misting water over the work area.
Dismantling is applicable to all types and sizes of structures as well as pipes and
tanks.
Salvage consists of recycling scrap metal, process equipment, and piping. It
represents an opportunity to reduce disposal costs and minimize waste streams.
Materials that are salvaged include metal structure materials (rebar, support
beams, etc.) and process equipment and piping. In addition, salvage includes
the recycling of any metal materials that are stockpiled in "boneyards" on post.
All metal materials from Army-owned structures are salvaged through the
Defense Reutilization and Marketing Office. Metal materials may either be
resold to salvage companies, recycled on or off post, or redistributed to Army
facilities.
A landfill securely contains contaminated structure debris by providing a
physical barrier both above and below the contaminated material. The low-
permeability cover protects human and biota receptors from direct contact with
the contaminants, and the low-permeability liner restricts contaminant mobility,
protecting the underlying soil and groundwater. The landfill technology is
applicable primarily for the disposal of untreated soil and debris, but may also
be used for the disposal of treated debris and soil/debris mixtures. In addition,
oversize materials removed during materials-handling activities for both soil and
structures treatment alternatives will also require placement in a landfill.
Caustic washing is a physical/chemical treatment process in which agent-
contaminated structural debris is excavated, mixed with caustic wash fluids in an
aboveground unit to degrade agent, and then separated from the fluids. The
process is carried out at ambient temperature and atmospheric pressure. The
makeup of the treatment solution is based upon suspected contaminants and
suspected contaminant concentrations. At RMA this process is based upon the
suspected presence of GB, VX, lewisite, and mustard. Although there are
chemical treatment alternatives that more effectively treat each individual
contaminant, this process has been designed to treat all aforementioned
compounds and generate by-products of greatly reduced toxicity.
nna\1579G
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Table 7.1-2 Description of Structures Technologies1 Page 2 of 2
Technology Description
Multilayer Cap A multilayer cap reduces both the migration of hazardous substances into the
surrounding environment by minimizing deep percolation through the
contaminated media and the potential for direct exposures by humans or biota to
contaminated media through containment (i.e., the isolation of the contaminated
media). From top to bottom, a multilayer cap generally consists of three layers:
a 4-ft-thick soil/vegetation layer designed to minimize erosion and promote
drainage; a 1-ft-thick layer of crushed concrete or cobbles as a biota barrier
serving to protect the underlying low-permeability soil layer; and a 2-ft-thick
layer of compacted, low-permeability soil. The cap is constructed with
sufficient slope to prevent ponding of rainwater. The vegetation used for the
top layer consists of locally adapted perennial grasses and low-growing plants
selected to minimize erosion and discourage burrowing animals from using the
cover as habitat.
1 Detailed discussion of all structures remediation technologies considered is presented in the Detailed Analysis of Alternatives
report
nna\1579G
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Table 7.1-3 Description of Soil Technologies1
Page 1 of 4
Technology
Description
Excavation Excavation is the removal of soil, debris, drums, pipes, tanks, or any other solid
material from the ground. Examples of conventional excavation equipment are
bulldozers, backhoes, clamshells, drag lines, front-end loaders, and scrapers.
Excavated soil is loaded and transported to a disposal area or treatment facility.
Backfilling (using on-post borrow material) and reclamation is required
following excavation. Additional process requirements for excavation may
include dust suppression, control of air emissions, dewatering, or removal of
debris or UXO.
Soil Cover A soil cover isolates the contaminated media from potential receptors, such as
humans or biota, thereby preventing direct exposures through direct contact. A
soil cover consists of a variable-thickness layer of soil and may include crushed
or formed concrete layers as biota/excavation barriers. Soil covers may be
sloped for erosion control and are vegetated with locally adapted perennial
grasses and low-growing plants. A soil cover is not intended to provide a
low-permeability barrier to infiltration.
Multilayer Cap A multilayer cap reduces both the migration of hazardous substances into the
surrounding environment by minimizing deep percolation through the
contaminated media and the potential for direct exposures by humans or biota to
contaminated media through containment (i.e., the isolation of the contaminated
media). From top to bottom, a multilayer cap generally consists of three layers:
a 4-ft-thick soil/vegetation layer designed to minimize erosion and promote
drainage; a 1-ft-thick layer of crushed concrete or cobbles as a biota barrier to
protect the underlying low-permeability soil layer; and a 2-ft-thick layer of
compacted, low-permeability soil. The cap is constructed with sufficient slope
to prevent ponding of rainwater. The vegetation used for the top layer consists
of locally adapted perennial grasses and low-growing plants selected to
minimize erosion and discourage burrowing animals from using the cover as
habitat.
Slurry Wall Slurry walls are vertical barriers that serve to impede the lateral flow of
contaminated groundwater. The installation of a slurry wall entails the
excavation of a trench, placement of the slurry mixture in the trench, and
addition of fill material in the slurry-filled trench. The slurry wall mixture
(commonly backfill soil, bentonite, and water) is selected based on compatibility
and optimization concerns. The completed slurry wall acts as a low-
permeability barrier to lateral groundwater flow. Slurry walls may be installed
around sites in conjunction with a multilayer cap to form an isolation cell
around the contaminated soil.
nna\1576G
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Table 7.1-3 Description of Soil Technologies1
Page 2 of 4
Technology
Description
Composite Cap
On-Post Landfill
Thermal Desorption
Off-Post
Demilitarization of
UXO
A composite cap reduces both the migration of hazardous substances into the
surrounding environment by minimizing infiltration through the contaminated
soil and the potential for direct exposures by both humans and biota to
contaminated media through containment (i.e., the isolation of the contaminated
media). A composite cap consists of multiple layers including a soil/vegetative
layer and a flexible-membrane liner overlying a layer of compacted clay. The
composite cap design used in the soil alternatives includes a biota-intrusion
barrier, drainage layers (sand and geotextile), and a geogrid for stability. The
cap is constructed with sufficient slope to prevent ponding of rainwater, and the
vegetation used for the top layer consists of locally adapted perennial grasses
and low-growing plants selected to minimize erosion and discourage burrowing
animals from using the cover as habitat.
A landfill securely contains contaminated soil by providing a physical barrier
both above and below the contaminated material. The low-permeability cover
protects human and ecological receptors from direct contact with the
contaminants, and the low-permeability liner restricts contaminant mobility,
protecting the underlying soil and groundwater. The landfill technology is
applicable primarily for the disposal of untreated soil and debris, but may also
be used for the disposal of treated debris and soil/debris mixtures. In addition,
oversize materials removed during materials handling activities for both soil and
structures treatment alternatives will also require placement in a landfill.
Thermal desorption uses heat to physically separate volatile (and some
semivolatile) organic compounds from soil or sludge. In general, the operating
temperature of the desorber (95°C to 540°C) is not high enough to oxidize or
destroy the organic compounds to any significant extent, i.e., the desorber
separates the organic contaminants so that the secondary combustion chamber
may destroy them. Offgas from the secondary combustion chamber is treated
for particulates and acid-gas emissions. Thermal desorption also volatilizes
some metals; the extent of volatilization is a function of the selected operating
temperature. For example, at the higher range of thermal desorption
temperatures, mercury is almost entirely volatilized and arsenic is partially
removed. Thermal desorption, however, cannot be used as a treatment
technology for inorganic contaminant remediation.
Off-post demilitarization of UXO involves excavation, packaging, and
transportation of the UXO to an appropriate Army facility for demilitarization.
This process, applicable to any UXO identified involves shipping HE or
agent-filled UXO that is safe or rendered safe to an Army facility specially
designed for UXO demilitarization.
nna\1576G
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Table 7.1-3 Description of Soil Technologies1
Page 3 of 4
Technology
Description
Caustic Washing of
Agent-Contaminated
Soil
Incineration
Stabilization/
Solidification
Agricultural Practices
(Landfarming)
Caustic washing is a physical/chemical treatment process in which agent-
contaminated soil is excavated, mixed with caustic wash fluids in an
aboveground unit to degrade agent, and then separated from the fluids. The
process is carried out at ambient temperature and atmospheric pressure. The
makeup of the treatment solution is based upon suspected contaminants and
suspected contaminant concentrations. At RMA, this process is based upon the
suspected presence of GB, VX, lewisite, and mustard. Although there are
chemical treatment alternatives that more effectively treat each individual
contaminant, this process has been designed to treat all aforementioned
compounds and generate byproducts of greatly reduced toxicity.
Incineration is a high-temperature process that uses either direct or indirect heat
exchange to alter or destroy organic contaminants in soil, sludge, sediment, or
debris. In general, the operating temperature of the incinerator (640°C to
1,000°C) is high enough to destroy the contaminants by oxidation or pyrolysis.
Natural organic material is also burned out of the soil matrix. Incineration will
remove, but not destroy, volatile metals such as mercury and arsenic. Off gas
from the incinerator passes through a cyclone separator to remove particulates.
Residual organic contaminants are destroyed in a secondary combustion
chamber. Off gas from the secondary combustion chamber is treated for
particulates and acid-gas emissions.
Solidification/stabilization processes use additives, or binding agents, to limit the
mobility of contaminants and improve the physical characteristics of the waste
by eliminating free liquids and producing a solid with high structural integrity.
Although solidification/stabilization has historically addressed inorganic
contamination through the use of cement-based agents, the advent of specialized
additives has broadened the applicability to media containing both inorganic and
organic contamination. Solidification/stabilization can be accomplished using ex
situ or in situ processes. Ex situ processes rely on mechanical mixing
equipment, such as a pug mill, to properly mix the contaminated soil with the
binding agents. Mixing for in situ processes is accomplished using auger or
rotor mixers. The binding agents are either placed on the soil surface and are
drawn in by the mixing equipment or are injected through nozzles in the augers.
An overlapping drilling pattern is used to obtain complete contact with the
contaminated soil volume.
This technology consists of using landfanning techniques either with farm
machinery (V-ripper, plow, and disk) or a soil stabilizer along with seeding to
facilitate stabilization and attenuation of contaminants in surface soils (0-ft to
1-ft depth interval). Mixing surface contamination with the soil below is
expected to promote contaminant loss and to reduce both contaminant exposure
to surface receptors and migration of contaminants by surface dust dispersion.
nna\1576G
-------
Table 7.1-3 Description of Soil Technologies1 Page 4 of 4
Technology Description
Pipe Plugging This process option consists of filling the interior of pipes with grout. The
purpose is to eliminate this contaminant migration pathway and immobilize
contamination within the pipe, reducing its mobility. The technique involves
using a mobile grout plant to mix and inject the plugging material into the pipe.
The pipes to be plugged are first drained of any residual liquids, and any fittings
that block the grout are cut from the pipe run. Aboveground pipe sections are
cut into manageable lengths of 100 ft for diameters up to 12 inches and SO ft
for diameters up to 36 inches. The grout is pumped into the pipe run from the
low end until it exits the high end, which is closed once grout starts coming out.
The lower end is then closed off, and the grout is allowed to harden. Pumping
grout from the low end to the high end helps to prevent the formation of voids.
1 Detailed discussion of all soil remediation technologies considered is presented in the Detailed Analysis of Alternatives
report.
nna\1576G
-------
Table 7.1-4 Site Evaluation Criteria and Principal Threat Criteria for Soil
Page 1 of 1
Acute and Subchronic Risk-Based
Chronic Risk-Based Criteria Criteria 0- to 1-ft Interval (where lower
0- to 10-ft Interval than chronic)
Contaminants of Concern
Aldrin
Benzene
Carbon Tetrachloride1
Chlordane1
Chloroacetic Acid1
Chlorobenzene1
Chloroform1
DDE
DDT1
DBCD
1,2-Dichloroe thane
1 , 1 -Dichloroethene
DCPD1
Dieldrin
Endrin1
HCCPD1
Isodrin1
Methylene Chloride1
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethylene1
Toluene1
TCE
Arsenic
Cadmium1
Chromium1
Lead1
Mercury1
Principal Threat Criteria2
720
10,400
2,300
3,700
77,000
850,000
48,000
13,000
14,000
200
3,200
; 520
NA
410
230,000
NA
52,000
35,000
1,500
5,400
NA
28,000
4,200
24,000
7,500
NA
570,000
Site Evaluation
71
1,040
30
55
77
850
370
1,300
410
8
320
52
3,700
41
230
1,100
52
2,300
150
410
7,200
2,800
420
530
39
2,200
570
Preliminary Remediation
Criteria2 Goals2 Site Evaluation Criteria*
0.72 3.8
10
2.3
3.7 12
77
850
48
13
14 14
0.2
3.2
0.52
3,700
0.41 3.7
230 56
1,100
52
35
1.5
5.4
7,200
28
4.2 270
50 140
7.5
2,200
570 82
SEC based on noncarcinogenic PPLV.
Units presented in parts per million.
rma\1510G
-------
Table 7.1-5 Soil Exceedance Volumes by Medium Group1'2
Page 1 of 1
Human Health Principal Threat Excess Biota Expected Expected UXO
Exceedance Exceedance Volume; Agent UXO Debris
Volume3 Volume 0-1 ft Volume Volume Volume4
Medium Group/Subgroup (BCY) (BCY) (BCY) (BCY) (BCY) (BCY)
Munitions Testing
North Plants
Toxic Storage Yards
Lake Sediments
Ditches/Drainage
Surficia! Soil
Basin A
Basin F Wastepile
Secondary Basins
Former Basin F
Sanitary/Process Water Sewers
Chemical Sewers
Complex Trenches
Shell Trenches
Hex Pit
Sanitary Landfills5
Section 36 Lime Basins
Buried M-l Pits
S.P. Central Processing6
S.P. Ditches
S.P. Balance of Areas
Buried Sediments
Sand Creek Lateral
Section 36 Balance of Areas
Burial Trenches
0
220
2,700
19,000
0
87,000
160,000
600,000
32,000
740,000
0
86,000
400,000
100,000
3,300
14,000
54,000
26,000
110,000
33,000
130,000
16,000
15,000
64,000
28,000
0
0
0
0
0
1,500
32,000
600,000
0
180,000
0
46,000
400,000
100,000
3,300
0
9,000
22,000
38,000
3,400
11,000
0
0
0
0
0
17,000
0
19,000
23,000
460,000
88,000
0
140,000
0
0
0
0
0
0
23,000
0
0
27,000
22,000
510,000
0
90,000
140,000
0
61
220
710
69
1,300
91
29
160
160
300
12
450 89,000
94 47,000
1,300 130,000
50 5,000
160 78,000
550 57,000
Total
2,700,000
1,400,000 1,600,000
3,100 2,600 410,000
AH volumes presented to two significant figures. Detailed volume calculations are available in the administrative record
(Foster Wheeler 1996).
Individual volumes presented here may differ from those presented in the Detailed Analysis of Alternatives report (Volume IV,
Appendix A) due to adjustments for overlap between exceedance categories. The total volume listed for each medium group
remains consistent with those presented in the Detailed Analysis of Alternatives report.
The human health exceedance volume includes the principal threat exceedance volume.
The UXO debris volume includes human health exceedance volume as follows: Basin A, 16,500 BCY; Complex Trenches,
43,000 BCY; Section 36 Balance of Areas, 15,000 BCY; and Burial Trenches, 4,000 BCY.
This medium group also contains 380,000 BCY of nonhazardous soil and debris.
Exceedance volumes are based on a 5-ft depth cutoff due to difficulties in deeper excavation at this site.
Additional exceedance volumes for the 5-ft to 10-ft depth interval are 32,000 BCY human health volume, including 17,000 BCY
principal threat volume.
nna\1586G.XLS,Sheetl
-------
Table 7.1-6 Soil Exceedance Areas by Medium Group1
Page 1 of 1
Medium Group/Subgroup
Munitions Testing
North Plants
Toxic Storage Yards
Lake Sediments
Ditches/Drainage
Surflcial Soil
Basin A
Basin F Wastepile
Secondary Basins
Former Basin F
Sanitary/Process Water Sewers
Chemical Sewers
Complex Trenches
Shell Trenches
Hex Pit
Sanitary Landfills
Section 36 Lime Basins
Buried M-l Pits
S.P. Central Processing
S.P. Ditches
S.P. Balance of Areas
Buried Sediments
Sand Creek Lateral
Section 36 Balance of Areas
Burial Trenches
Total
Human Health Principal Threat
Exceedance Exceedance
Area (sy) Area (sy)
0
330
1,700
45,000
0
260,000
320,000
75,000
92,000
350,000
0
100,000
130,000
32,000
860
12,000
34,000
8,700
140,000
50,000
170,000
7,900
34,000
150,000
12,000
2,000,000
0
0
0
0
0
4,500
35,000
75,000
0
110,000
.0
49,000
120,000
32,000
860
0
6,700
8,700
42,000
5,500
8,100
0
0
0
0
500,000
Excess
Biota
Area (sy)2
0
50,000
0
57,000
70,000
1,400,000
260,000
0
410,000
0
0
0
0
0
0
69,000
0
0
80,000
65,000
1,500,000
0
270,000
430,000
0
4,700,000
Potential
Agent
Area (sy)
28,000
130,000
430,000
76,000
390,000
34,000
8,700
98,000
48,000
90,000
7,100
1,300,000
Potential
UXO
Area (sy)
270,000
140,000
390,000
15,000
230,000
170,000
1,200,000
1 All areas presented to two significant figures. Detailed area calculations are available in the administrative record.
2 Biota areas have been calculated to account for overlap with human health exceedance area and potential UXO area.
ima\]586G.XLS,Sheel2
-------
Table 7.2-1 Description of Water Alternatives
Page 1 of 1
Alternative 1
Boundary Systems
Alternative 2
Boundary Systems / IRAs
Alternative 3
Boundary Systems / IRAs /
De watering
Alternative 4
Boundary Systems / IRAs /
Intercept Systems
Boundary systems continue to
operate, but all on-post
groundwater IRAs are dismantled.
The ICS captures water from the
Western Plume Group, the
NWBCS captures water from the
Northwest Boundary Plume
Group, and the NBCS captures
water from the North Boundary
Plume Group.
Boundary systems continue to
operate as in Alternative I and the
on-post groundwater IRAs remain
in operation. The IRAs include the
two capture systems at the Motor
Pool and Rail Yard area in the
Western Plume Group that extract
water and pump it for treatment at
the ICS, the capture system north
of Basin F in the North Boundary
Plume Group that extracts water
for treatment at the Basin A Neck
System, and the Basin A Neck
IRA that captures and treats water
migrating from Basin A.
Boundary systems and IRAs
continue to operate as in
Alternative 2. Dewatering and
treatment systems are installed to
remove the contaminated central
portions of the South Plants Plume
Group and Basin A Plume Group
groundwater. Dewatering
accelerates lowering of the water
table in South Plants and Basin A;
the extracted water is treated in a
new system. The South Tank Farm
Plume in South Plants is treated
separately by in situ biological
treatment.
Boundary systems and IRAs
continue to operate as in
Alternative 2. Additionally, an
extraction system is installed in the
Section 36 Bedrock Ridge area to
minimize contaminant migration
from this part of the Basin A Plume
Group. The extracted water is piped
to the Basin A Neck system.
Groundwater plumes in the South
Plants area are monitored and lake-
level maintenance or other means
of hydaulic containment will be
used to prevent South Plant plumes
from migrating into the lakes at
concentrations exceeding CBSGs.
RMAROD6.96jb
-------
Table 7.2-2 Capital and O&M Costs for Water Alternatives1-2
Page 1 of 1
Plume Group
Capital Operating
Total Cost PWCost3 Total Cost PWCost3
Total
Total Cost PWCost3
Alternative 1
Northwest Boundary
Western
North Boundary
Basin A
South Plants
On-Post Water Supply4
Total
0
0
0
28,500
0
15,000,000
15,000,000
0
0
0
28,500
0
14,600,000
14,600,000
32,500,000
5,940,000
51,200,000
3,280,000
3,270,000
0
96,200,000
21,500,000
4,890,000
33,900,000
2,340,000
2,340,000
0
65,000,000
32,500,000
5,940,000
51,200,000
3,308,500
3,270,000
15,000,000
111,000,000
21,500,000
4,890,000
33,900,000
2,368,500
2,340,000
14,600,000
80,000,000
Alternative 2 *
Northwest Boundary
Western
North Boundary
Basin A
South Plants
On-Post Water Supply4
Total
Alternative 3
Northwest Boundary
Western
North Boundary
Basin A
South Plants
On-Post Water Supply4
Total
Alternative 4
Northwest Boundary
Western
North Boundary
Basin A
South Plants
On-Post Water Supply4
Total
0
0
80,000
0
0
15,000,000
15,100,000
0
0
80,000
0
0
14,600,000
14,700,000
32,500,000
5,940,000
51,400,000
30,700,000
3,270,000
0
124,000
21,500,000
4,910,000
34,100,000
20,500,000
2,340,000
0
83,400,000
32,500,000
5,940,000
51,480,000
30,700,000
3,270,000
15,000,000
139,000,000
21,500,000
4,910,000
34,180,000
20,500,000
2,340,000
14,600,000
98,000,000
0
0
80,000
7,050,000
5,740,000
15,000,000
27,900,000
0
0
80,000
6,940,000
5,740,000
14,600,000
27,400,000
32,500,000
5,940,000
51,400,000
41,300,000
20,000,000
0
151,000,000
21,500,000
4,910,000
34,100,000
27,600,000
14,100,000
0
102,000,000
32,500,000
5,940,000
51,480,000
48,350,000
25,740,000
15,000,000
179,000,000
21,500,000
4,910,000
34,180,000
34,540,000
19,840,000
14,600,000
130,000,000
0
0
80,000
3,540,000
80,000
0
0
80,000
3,540,000
80,000
15,000,000 14,600,000
32,500,000
5,940,000
51,400,000
29,800,000
7,400,000
0
18,700,000 18,300,000 127,000,000
21,500,000
4,910,000
34,100,000
19,800,000
5,100,000
0
85,400,000
32,500,000
5,940,000
51,480,000
33,340,000
7,480,000
15,000,000
146,000,000
21,500,000
4,910,000
34,180,000
23,340,000
5,180,000
14,600,000
104,000,000
Detailed discussion of cost estimates is presented in the Detailed Analysis of Alternatives report
All costs presented in 1995 dollars.
Present-worth calculations are based on a 3 percent discount rate.
Based on acquisition of a water supply of 1,500 acre-feet. Final on-post water requirements will be determined in the water
management plan during remedial design.
ima/1581G.DOC
-------
Table 7.3-1 Description of Structures Alternatives
Page 1 of 1
Alternative I
Landfill/Cap in Place
Alternative 2
Landfill/Consolidate
Alternative 3
Landfill
No Future Use, Significant Contamination
History: The structures are dismantled using
dust controls, metals salvaged (if appropriate),
and the remaining debris disposed in the on-
post hazardous waste landfill.
No Future Use, Other Contamination History:
The structures are dismantled using dust
controls, metals salvaged (if appropriate), and
the remaining debris consolidated and capped
(multilayer caps) in one of three places: the
Rail Yard, North Plants, or the South Plants
Central Processing Area.
No Future Use, Agent History: The structures
are dismantled using dust controls and air
monitoring, the debris monitored for the
presence of Army chemical agent and caustic
washed as necessary, and the resulting debris
disposed in the on-post hazardous waste
landfill.
No Future Use, Significant Contamination
History: The structures are dismantled using
dust controls, metals salvaged (if appropriate),
and the remaining debris disposed in the on-
post hazardous waste landfill.
No Future Use, Other Contamination History:
The structures are dismantled using dust
controls, metals salvaged (if appropriate), and
the remaining debris disposed in the Basin A
consolidation area.
No Future Use, Agent History: The structures
are dismantled using dust controls and air
monitoring, the debris monitored for the
presence of Army chemical agent and caustic
washed as necessary, and the resulting debris
disposed in the on-post hazardous waste
landfill.
No Future Use, Significant Contamination
History: The structures are dismantled
using dust controls, metals salvaged (if
appropriate), and the remaining debris
disposed in the on-post hazardous waste
landfill.
No Future Use, Other Contamination
History: The structures are dismantled
using dust controls, metals salvaged (if
appropriate), and the remaining debris
disposed in the on-post hazardous waste
landfill.
No Future Use, Agent History: The
structures are dismantled using dust
controls and air monitoring, the debris
monitored for the presence of Army
chemical agent and caustic washed as
necessary, and the resulting debris
disposed in the on-post hazardous waste
landfill.
RMA ROD 6.96 jb
-------
Table 7.3-2 Capital and O&M Costs for Structures Alternatives1'2
Page 1 of 1
Medium Group
Capital
Total Cost
PWCost3
Operating
Total Cost
PWCost*
Total
Total Cost PW Cost3
Alternative 1
No Future Use, Significant
Contamination History
No Future Use, Other
Contamination History
No Future Use, Agent History
Total
Alternative 2
No Future Use, Significant
Contamination History
No Future Use, Other
Contamination History
No Future Use, Agent History
Total
Alternative 3
No Future Use, Significant
Contamination History
No Future Use, Other
Contamination History
No Future Use, Agent History
Total
1,088,000 1,014,000 13,206,000 12,252,000 14,294,000 13,266,000
72,000 68,000 38,728,000 35,685,000
5,888,000 5,517,000 55,323,000 51,345,000
7,048,000 6,599,000 107,257,000 99,282,000
38,800,000 35,753,000
61,211,000 56,862,000
114,000,000 106,000,000
1,088,000 1,014,000 13,206,000 12,252,000 14,294,000 13,266,000
0
5,888,000
6,976,000
0 36,636,000 34,030,000 36,636,000 34,030,000
5,517,000 55,323,000 51,345,000 61,211,000 56,862,000
6,531,000 105,165,000 97,627,000 112,000,000 104,000,000
1,088,000 1,014,000 13,206,000 12,252,000 14,294,000 13,266,000
4,112,000 3,834,000 37,847,000 35,098,000 41,959,000 38,932,000
5,888,000 5,517,000 55,323,000 51,345,000 61,211,000 56,862,000
11,088,000 10,365,000 106,376,000 98.695.000 118,000,000 109,000,000
1 Detailed discussion of cost estimates is presented in the Detailed Analysis of Alternatives report.
2 AH costs presented in 1995 dollars.
3 Present-worth calculations are based on a'3 percent discount rate.
ma/1582G.DOC
-------
Table 7.4-1 Description of Soil Alternatives
Page 1 of 6
Medium Groups/
Subgroups
Alternative 1
Caps/Covers1
Alternative 2
Landfill/Caps1
Alternative 3
Landfill1
Alternative 4
Consolidation/Caps/
Treatment/Landfill
Alternative 5
Caps/Treatment/
Landfill1
Munitions Testing
Munitions screening; off-
post detonation of UXO;
landfill debris and soil
above TCLP.
Munitions screening;
off-post detonation of
UXO; landfill debris
and soil above TCLP.
Munitions screening;
off-post detonation of
UXO; landfill debris and
soil above TCLP.
Munitions screening;
off-post detonation of
UXO; landfill debris
and soil above TCLP.
Munitions screening;
off-post detonation of
UXO; landfill debris
and soil above TCLP.
North Plants
Landfill human health
exceedance; agent
monitoring during
excavation; caustic
washing; install soil
cover over soil posing
risk to biota and
processing area.
Landfill human health
exceedance; agent
monitoring during
excavation; caustic
washing; install soil
cover over soil posing
risk to biota and
processing area.
Landfill human health
exceedance; agent
monitoring during
excavation; caustic
washing; install soil
cover over soil posing
risk to biota and
processing area.
Landfill human health
exceedance; agent
monitoring during
excavation; caustic
washing; install soil
cover over soil posing
risk to biota and
processing area.
Landfill human health
exceedance; agent
monitoring during
excavation; caustic
washing; install soil
cover over soil posing
risk to biota and
processing area.
Toxic Storage
Yards
Landfill human health
exceedance; utilize New
Toxic Storage Yard for
borrow area; agent
monitoring during
excavation and site
preparation; caustic
washing.
Landfill human health
exceedance; utilize New
Toxic Storage Yard for
borrow area; agent
monitoring during
excavation and site
preparation; caustic
washing.
Landfill human health
exceedance; utilize New
Toxic Storage Yard for
borrow area; agent
monitoring during
excavation and site
preparation; caustic
washing.
Landfill human health
exceedance; utilize New
Toxic Storage Yard for
borrow area; agent
monitoring during
excavation and site
preparation; caustic
washing.
Landfill human health
exceedance; utilize New
Toxic Storage Yard for
borrow area; agent
monitoring during
excavation and site
preparation; caustic
washing.
Lake Sediments
Landfill human health
exceedances; additional
action determined by
Parties based on
continuing monitoring of
biota in these areas.
Landfill human health
exceedances; additional
action determined by
Parties based on
continuing monitoring
of biota in these areas.
Landfill human health
exceedances and soil
posing risk to biota
(Upper Derby Lake);
deferral to USFWS for
aquatic sediments.
Landfill human health
exceedances and
consolidate soil posing
risk to biota (Upper
Derby Lake); deferral to
USFWS for aquatic
sediments.
Landfill human health
exceedances and soil
posing risk to biota
(Upper Derby Lake);
deferral to USFWS for
aquatic sediments.
RMAROD696jb
-------
Table 7.4-1 Description of Soil Alternatives
Page 2 of 6
Medium Groups/
Subgroups
Alternative 1
Caps/Covers'
Alternative 2
Landfill/Caps1
Alternative 3
Landfill1
Alternative 4
Consolidation/Caps/
Treatment/Landfill
Alternative 5
Caps/Treatment/
Landfill1
Surficial Soil
Landfill human health
exceedances; additional
action determined by
Parties based on
continuing monitoring of
biota in these areas.
Landfill human health
exceedances; additional
action determined by
Parties based on
continuing monitoring
of biota in these areas.
Landfill human health
exceedances; additional
action determined by
Parties based on
continuing monitoring
of biota in these areas.
Landfill human health
exceedances;
consolidate soil posing
risk to biota in Basin A,
Former Basin F, and
South Plants; additional
action determined by
Parties based on
continuing monitoring
of biota in these areas.
Agricultural practices
for soil posing risks to
biota and landfill human
health exceedances.
Ditches/Drainage
Areas
Additional action
determined by Parties
based on continuing
monitoring of biota in
these areas.
Additional action
determined by Parties
based on continuing
monitoring of biota in
these areas.
Landfill soil posing risk
to biota.
Consolidate soil posing
risk to biota in Basin A.
Landfill soil posing risk
to biota.
Basin A
Cap principal threat
and human health
exceedances and soil
posing risk to biota.
Cap principal threat
and human health
exceedances and soil
posing risk to biota.
Landfill principal threat
and human health
exceedances; cap entire
site including soil posing
risk to biota.2
Construct soil cover
with concrete barrier
over principal threat
and human health
exceedances and soil
posing risk to biota;
consolidate soil posing
risk to biota/structural
debris from other sites.
Thermal desorption of
principal threat soil;
landfill human health
including treated soil;
cap entire site including
soil posing risk to
biota.2
Basin F Wastepile
Modify existing cap
according to RCRA
requirements (composite
cap).
Modify existing cap
according to RCRA
requirements
(composite cap).
Modify existing cap
according to RCRA
requirements (composite
cap).
Landfill entire wastepile
(principal threat
exceedance) in triple-
lined cell (excavate with
vapor control) after
drying saturated
materials.
Thermal desorption of
entire wastepile
(principal threat
exceedance)(excavate
with vapor control);
landfill treated soil.
RMAROD6.96jb
-------
Table 7.4-1 Description of Soil Alternatives
Page 3 of 6
Medium Groups/
Subgroups
Alternative 1
Caps/Covers'
Alternative 2
Landfill/Caps1
Alternative 3
Landfill1
Alternative 4
Consolidation/Caps/
Treatment/Landfill
Alternative 5
Caps/Treatment/
Landfill1
Former Basin F
Modify existing cap to
RCRA-equivalent cap.
Modify existing cap to
RCRA-equivalent cap.
Landfill principal threat
and human health
exceedances(excavate
under vapor enclosure);
cap entire site.
In situ solidification/
stabilization of principal
threat exceedance
volume; cap entire site
with RCRA-equivalent
cap.
Thermal desorption of
principal threat soil
(excavate under vapor
enclosure); landfill
human health
exceedances including
treated soil; cap entire
site.
Secondary Basins Cap human health
exceedances and soil
posing risk to biota.
Landfill human health
exceedances and soil
posing risk to biota.
Landfill human health
exceedances and soil
posing risk to biota.
Landfill human health
exceedances; install soil
cover over soil posing
risk to biota.
Landfill human health
exceedances and soil
posing risk to biota.
Sanitary/Process Plug remaining
Water Sewers manholes.
Plug remaining
manholes.
Landfill sewer lines.
Plug remaining
manholes.
Plug remaining
manholes.
Chemical Sewers Plug sewer lines.
Plug sewer lines in
South Plants Central
Processing Area and
Complex Trenches;
landfill remaining
principal threat and
human health
exceedances.2
Landfill principal threat
and human health
exceedances.2
Plug sewer lines in
South Plants Central
Processing Area and
Complex Trenches;
landfill remaining
principal threat and
human health
exceedances.2
Thermal desorption of
principal threat soil;
landfill human health
exceedances including
treated principal threat
soil.2
Complex Trenches
Cap principal threat and
human health
exceedances and soil
posing risk to biota and
install a slurry wall
around disposal trenches.
Cap principal threat and
human health
exceedances and soil
posing risk to biota and
install a slurry wall
around disposal
trenches.
Cap principal threat and
human health
exceedances and soil
posing risk to biota and
install a slurry wall
around disposal
trenches.
Cap (RCRA-equivalent
cap with concrete
barrier) principal threat
and human health
exceedances and soil
posing risk to biota and
install a slurry wall
around disposal
trenches.
Cap principal threat and
human health
exceedances and soil
posing risk to biota and
install a slurry wall
around disposal
trenches.
RMAROD6.96jb
-------
Table 7.4-1 Description of Soil Alternatives
Page 4 of 6
Medium Groups/
Subgroups
Alternative 1
Caps/Covers1
Alternative 2
Landfill/Caps1
Alternative 3
Landfill1
Alternative 4
Consol idation/Caps/
Treatment/Landfill
Alternative 5
Caps/Treatment/
Landfill1
Shell Trenches
Modify existing cover
and install slurry wall
around trenches.
Modify existing cover
and install slurry wall
around trenches.
Landfill trenches after
materials handling
(excavate with vapor
control).
Modify existing cover to
be RCRA-equivalent
cap and modify existing
slurry wall around
trenches.
Incinerate trenches;
landfill treated soil
(excavate with vapor
control).
Hex Pit
Install cap and slurry
wall around trenches.
Install cap and slurry
wall around trenches.
Landfill disposal pit
after materials handling
(excavate with vapor
control).
Treatment of
approximately 1,000 bey
of principal threat
material using an
innovative thermal
technology and landfill
remaining soil (excavate
with vapor control).
Treatment will be revised
to a solidification/
stabilization technology
if all evaluation criteria
for the innovative thermal
technology are not met.
Incinerate disposal pit;
landfill treated soil
(excavate with vapor
control).
Sanitary Landfills Cap entire site.
Landfill human health
exceedances, debris,
and soil posing risk to
biota.
Landfill human health
exceedances, debris,
and soil posing risk to
biota.
Landfill human health
exceedances;
consolidate debris and
soil posing risk to biota
in Basin A.
Landfill human health
exceedances, debris,
and soil posing risk to
biota.
Section 36 Modify existing cover.
Lime Basins
Modify existing cover.
Landfill principal threat
and human health
exceedances; cap entire
site.2
Landfill principal threat
and human health
exceedances in triple-
lined cell; repair
existing soil cover.2
Landfill principal threat
and human health
exceedances; cap entire
site.2
RMAROD6.96jb
-------
Table 7.4-1 Description of Soil Alternatives
Buried M-1 Pits
Install cap and slurry
wall around entire site.
Install cap and slurry
wall around entire site.
Landfill principal threat
and human health
exceedances (excavate
with vapor control).2
Page 5 of 6
Medium Groups/
Subgroups
Alternative 1
Caps/Covers1
Alternative 2
Landfill/Caps'
Alternative 3
Landfill1
Alternative 4
Consolidation/Caps/
Treatment/Landfill
Alternative 5
Caps/Treatment/
Landfill 1
Solidification/
stabilization and
landfill of principal
threat and human health
exceedances (excavate
with vapor control).2
Solidification/
stabilization and
landfill of principal
threat and human health
exceedances (excavate
with vapor control).2
South Plants
Central Processing
Area
Cap principal threat
and human health
exceedances and soil
posing risk to biota.
Cap principal threat
and human health
exceedances and soil
posing risk to biota.
Landfill principal
threat and human health
exceedances; cap entire
site including soil posing
risk to biota.z
Landfill principal
threat and human health
exceedances (excavate
to depth of 5 feet);
construct soil cover with
biota barrier over entire
site including soil posing
risk to biota; consolidate
soil posing risk to biota
from other South Plants
sites.2
Thermal desorption and
solidification of
principal threat
exceedances; landfill
human health
exceedances including
treated soil; cap entire
site including soil
posing risk to biota.2
South Plants
Ditches
Cap principal
threat and hu
human health
exceedances and soil
posing risk to biota.
Landfill principal
threat and human health
exceedances and soil
posing risk to biota.
Landfill principal
threat and human health
exceedances and soil
posing risk to biota.
Landfill principal
threat and human health
exceedances; consolidate
soil posing risk to biota
into excavated areas;
install soil cover
(variable thickness) over
entire site.
Thermal desorption of
principal threat soil;
landfill human health
exceedances, including
treated soil and soil
posing risk to biota.
South Plants
Balance of Areas
Cap principal
threat and human health
exceedances and soil
posing risk to biota.
Landfill principal
threat and human health
exceedances and soil
posing risk to biota.2-3
Landfill principal
threat and human health
exceedances and soil
posing risk to biota.2'3
Landfill principal
threat and human health
exceedances; consolidate
soil posing risk to biota
into excavated areas;
install soil cover
(variable thickness) over
entire site.2-3
Thermal desorption of
principal threat soil;
landfill human health
exceedances, including
treated soil and soil
posing risk to biota.2.3
RMA ROD 6.96 jb
-------
Table 7.4-1 Description of Soil Alternatives
Page 6 of 6
Medium Groups/
Subgroups
Alternative 1
Caps/Covers'
Alternative 2
Landfill/Caps1
Alternative 3
Landfill1
Alternative 4
Consolidation/Caps/
Treatment/Landfill
Alternative 5
Caps/Treatment/
Landfill1
Buried Sediments Cap human health
exceedances.
Landfill human health
exceedances.
Landfill human health
exceedances.
Landfill human health
exceedances.
Landfill human health
exceedances.
Sand Creek Lateral
Cap human health
exceedances and soil
posing risk to biota.
Landfill human health
exceedances and soil
posing risk to biota.
Landfill human health
exceedances and soil
posing risk to biota.
Landfill human health
exceedances; consolidate
soil posing risk to biota
into Basin A.
Landfill human health
exceedances and soil
posing risk to biota.
Section 36
Balance of Areas
Cap human health
exceedances and soil
posing risk to biota.
Landfill human health
exceedances and soil
posing risk to biota.2-3
Landfill human health
exceedances and soil
posing risk to biota.2-3
Landfill human health
exceedances; consolidate
soil posing risk to biota
into Basin A; install soil
cover (variable thickness)
over entire site.2-3
Landfill human health
exceedances and soil
posing risk to biota.2-3
Burial Trenches
Landfill human health
exceedances.2'3
Landfill human health
exceedances.2'3
Landfill human health
exceedances.2'3
Landfill human health
exceedances.2'3
Landfill human health
exceedances.2'3
' Cap consists of a clay/soil cap unless otherwise noted.
2 Agent monitoring during excavation and treatment of any soil containing agent by caustic washing.
3 Munitions screening prior to excavation, off-post detonation of any munitions encountered, and landfilling of munitions debris and associated soil above TCLP.
RMAROD6.96jb
-------
Table 7.4-2 Capital and O&M Costs for Soil Alternatives1
Page 1 of 5
Medium Group/Subgroup
Sitewide Alternative 1 - Caps/Covers
Munitions Testing
North Plants
Toxic Storage Yards
Lake Sediments
Surficial Soil
Ditches/Drainage Areas
Basin A
Basin F Wastepile
Secondary Basins
Former Basin F
Sanitary/Process Water Sewers
Chemical Sewers
Complex Trenches
Shell Trenches
Hex Pit
Sanitary Landfills
Section 36 Lime Basins
Buried M-l Pits
South Plants Central Processing Area
South Plants Ditches
South Plants Balance Of Areas
Buried Sediments
Sand Creek Lateral
Section 36 Balance Of Areas
Burial Trenches
Total
Capital Cost
Total Cost Present Worth2
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
7,110,000
2,370,000
4,310,000
3,350,000
12,420,000
-
58,400,000
8,160,000
53,900,000
36,300,000
344,000
853,000
38,400,000
2,930,000
676,000
14,300,000
4,520,000
1,660,000
26,400,000
8,590,000
126,000,000
3,380,000
16,500,000
46,800,000
8,190,000
486,000,000
$
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
$
$
$
$
6,150,000
1,770,000
3,720,000
2,160,000
8,470,000
-
52,000,000
5,920,000
34,100,000
24,400,000
280,000
719,000
26,600,000
2,400,000
588,000
10,300,000
3,280,000
1,450,000
21,500,000
6,600,000
96,800,000
2,840,000
10,900,000
33,300,000
6,680,000
363,000,000
$
$
$
$
$
$
$
S
$
S
$
$
$
S
S
$
$
$
S
$
$
$
$
$
$
S
O&M Cost
Total Cost Present Worth2
713,000
1,610,000
1,330,000
154,000
680,000
-
3,580,000
6,360,000
2,930,000
2,730,000
-
2,720,000
6,970,000
2,650,000
984,000
,000,000
,200,000
,020,000
,820,000
,410,000
7,730,000
994,000
2,160,000
3,900,000
772,000
55,400,000
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
296,000
670,000
554,000
63,800
282,000
-
1,490,000
2,640,000
1,220,000
1,130,000
-
1,130,000
2,900,000
1,100,000
409,000
416,000
498,000
422,000
757,000
586,000
3,210,000
413,000
897,000
1,620,000
321,000
23,000,000
$
$
S
$
$
$
S
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
S
Total Cost
Total Cost Present Worth2
7,820,000
3,980,000
5,640,000
3,500,000
13,100,000
-
61,980,000
14,500,000
56,800,000
39,000,000
344,000
3,570,000
45,400,000
5,580,000
1,660,000
15,300,000
5,720,000
2,680,000
28,200,000
10,000,000
134,000,000
4,370,000
18,700,000
50,700,000
8,960,000
542,000,000
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
6,450,000
2,440,000
4,270,000
2,220,000
8,750,000
-
53,500,000
8,560,000
35,300,000
25,500,000
280,000
1,850,000
29,500,000
3,500,000
1,000,000
10,700,000
3,780,000
1,870,000
22,300,000
7,190,000
100,000,000
3,250,000
11,800,000
34,900,000
7,000,000
386,000,000
ma\l595O.XLS
-------
Table 7.4-2 Capital and O&M Costs for Soil Alternatives1
Page 2 of 5
Medium Group/Subgroup
Sitewide Alternative 2 - Landfill/Caps
Munitions Testing
North Plants
Toxic Storage Yards
Lake Sediments
Surficial Soil
Ditches/Drainage Areas
Basin A
Basin F Wastepile
Secondary Basins
Former Basin F
Sanitary/Process Water Sewers
Chemical Sewers
Complex Trenches
Shell Trenches
Hex Pit
Sanitary Landfills
Section 36 Lime Basins
Buried M-l Pits
South Plants Central Processing Area
South Plants Ditches
South Plants Balance Of Areas
Buried Sediments
Sand Creek Lateral
Section 36 Balance Of Areas
Burial Trenches
Total
Capital Cost
Total Cost Present Worth2
$5,930,000
$2,160,000
$3,230,000
$3,100,000
$11,400,000
$0
$55,900,000
$8,280,000
$12,900,000
$38,200,000
$344,000
$12,000,000
$40,100,000
$2,980,000
$677,000
$29,700,000
$4,680,000
$1,680,000
$17,400,000
$4,780,000
$47,600,000
$1,890,000
$9,370,000
$26,100,000
$6,900,000
$347,000,000
$5,130,000
$1,610,000
$2,790,000
$2,000,000
$7,510,000
$0
$49,000,000
$6,190,000
$8,290,000
$25,600,000
$280,000
$10,000,000
$27,700,000
$2,440,000
$590,000
$21,500,000
$3,490,000
$1,420,000
$13,800,000
$3,670,000
$36,000,000
$1,590,000
$6,200,000
$18,600,000
$5,460,000
$261,000,000
O&M Cost
Total Cost Present Worth2
$258,000
$1,360,000
$391,000
$55,600
$246,000
$0
$3,580,000
$6,360,000
$487,000
$2,730,000
$0
$608,000
$6,970,000
$2,650,000
$984,000
$1,210,000
$1,200,000
$1,020,000
$1,820,000
$162,000
$2,130,000
$45,400
$303,000
$1,350,000
$266,000
$36,200,000
$110,000
$581,000
$167,000
$23,800
$105,000
$0
$1,530,000
$2,720,000
$208,000
$1,170,000
$0
$260,000
$2,980,000
$1,140,000
$421,000
$520,000
$513,000
$435,000
$780,000
$69,400
$912,000
$19,400
$130,000
$576,000
$114,000
$15,500,000
Total Cost
Total Cost Present Worth2
$6,190,000
$3,520,000
$3,620,000
$3,160,000
$11,600,000
$0
$59,500,000
$14,600,000
$13,400,000
$40,900,000
$344,000
$12,600,000
$47,100,000
$5,630,000
$1,660,000
$30,900,000
$5,880,000
$2,700,000
$19,200,000
$4,940,000
$49,700,000
$1,940,000
$9,670,000
$27,500,000
$7,170,000
$383,000,000
$5,240,000
$2,190,000
$2,960,000
$2,020,000
$7,620,000
$0
$50,500,000
$8,910,000
$8,500,000
$26,800,000
$280,000
$10,260,000
$30,700,000
$3,580,000
$1,010,000
$22,000,000
$4,000,000
$1,860,000
$14,600,000
$3,740,000
$36,900,000
$1,610,000
$6,330,000
$19,200,000
$5,570,000
$276,000,000
ma\l595G.XLS
-------
Table 7.4-2 Capital and O&M Costs for Soil Alternatives1
Page 3 of 5
Medium Group/Subgroup
Sitewide Alternative 3 - Landfill
Munitions Testing
North Plants
Toxic Storage Yards
Lake Sediments
Surficial Soil
Ditches/Drainage Areas
Basin A
Basin F Wastepile
Secondary Basins
Former Basin F
Sanitary/Process Water Sewers
Chemical Sewers
Complex Trenches
Shell Trenches
Hex Pit
Sanitary Landfills
Section 36 Lime Basins
Buried M-l Pits
South Plants Central Processing Area
South Plants Ditches
South Plants Balance Of Areas
Buried Sediments
Sand Creek Lateral
Section 36 Balance Of Areas
Burial Trenches
Total
Capital
Total Cost
$5,790,000
$2,120,000
$3,030,000
$4,320,000
$11,200,000
$4,270,000
$74,300,000
$8,310,000
$12,700,000
$138,000,000
$10,300,000
$17,800,000
$40,600,000
$35,300,000
$4,770,000
$30,000,000
$10,100,000
$6,890,000
$28,600,000
$4,710,000
$46,600,000
$1,870,000
$9,230,000
$25,500,000
$6,770,000
$543,000,000
Cost
Present Worth2
$4,860,000
$1,590,000
$2,620,000
$2,550,000
$7,440,000
$2,830,535
$61,600,000
$5,850,000
$7,450,000
$85,900,000
$8,390,000
$14,900,000
$22,800,000
$24,100,000
$4,020,000
$16,100,000
$7,130,000
$5,800,000
$21,900,000
$3,510,000
$34,000,000
$1,530,000
$6,110,000
$14,800,000
$4,490,000
$372,000,000
O&M Cost
Total Cost Present Worth2
$197,000
$1,310,000
$215,000
$84,500
$188,000
$114,000
$4,810,000
$6,360,000
$373,000
$4,450,000
$26,600
$415,000
$6,970,000
$221,000
$7,300
$929,000
$1,430,000
$83,900
$2,270,000
$124,000
$1,570,000
$34,800
$232,000
$914,000
$199,000
$33,500,000
$70,700
$470,000
$77,000
$30,300
$67,500
$40,854
$1,720,000
$2,280,000
$134,000
$1,600,000
$9,516
$149,000
$2,500,000
$79,300
$2,620
$333,000
$511,000
$30,100
$815,000
$44,500
$562,000
$12,500
$83,200
$328,000
$71,200
$12,000,000
Total Cost
Total Cost Present Worth2
$5,990,000
$3,430,000
$3,250,000
$4,400,000
$11,400,000
$4,380,000
$79,100,000
$14,700,000
$13,100,000
$142,000,000
$10,300,000
$18,200,000
$47,600,000
$35,500,000
$4,780,000
$30,900,000
$11,500,000
$6,970,000
$30,900,000
$4,830,000
$48,200,000
$1,900,000
$9,460,000
$26,400,000
$6,970,000
$576,000,000
$4,930,000
$2,060,000
$2,700,000
$2,580,000
$7,510,000
$2,870,000
$63,300,000
$8,130,000
$7,600,000
$87,500,000
$8,400,000
$15,000,000
$25,300,000
$24,200,000
$4,020,000
$16,400,000
$7,640,000
$5,830,000
$22,700,000
$3,550,000
$34,600,000
$1,540,000
$6,190,000
$15,100,000
$4,560,000
$384,000,000
mia\l595G.XLS
-------
Table 7.4-2 Capital and O&M Costs for Soil Alternatives1
Page 4 of 5
Medium Group/Subgroup
Capital Cost
Total Cost Present Worth2
O&M Cost
Total Cost Present Worth2
Total Cost
Total Cost Present Worth2
Sitewide Alternative 4 - Consolidation/Caps/Treatment/Landfill
Munitions Testing
North Plants
Toxic Storage Yards
Lake Sediments
Surficial Soil
Ditches/Drainage Areas
Basin A
Basin F Wastepile
Secondary Basins
Former Basin F
Sanitary/Process Water Sewers
Chemical Sewers
Complex Trenches
Shell Trenches
Hex Pit
Sanitary Landfills
Section 36 Lime Basins
Buried M-l Pits
South Plants Central Processing Area
South Plants Ditches
South Plants Balance Of Areas
Buried Sediments
Sand Creek Lateral
Section 36 Balance Of Areas
Burial Trenches
Contingent Soil Volume
Total
$6,150,000
$2,120,000
$3,160,000
$3,790,000
$20,000,000
$2,410,000
$52,900,000
$130,000,000
$7,840,000
$83,200,000
$344,000
$12,000,000
$47,000,000
$2,850,000
$5,180,000
$14,600,000
$8,170,000
$24,000,000
$18,900,000
$3,020,000
$34,900,000
$1,830,000
$4,720,000
$19,100,000
$7,100,000
$9,860,000
$525,000,000
$5,320,000
$1,580,000
$2,730,000
$2,440,000
$13,500,000
$1,600,000
$42,500,000
$92,300,000
$5,350,000
$52,800,000
$289,000
$10,400,000
$31,100,000
$2,330,000
$4,480,000
$11,200,000
$6,090,000
$20,100,000
$15,400,000
$2,390,000
$27,600,000
$1,540,000
$3,130,000
$13,600,000
$6,140,000
$8,020,000
$384,000,000
$379,000
$1,340,000
$334,000
$81,700
$361,000
$0
$4,330,000
$2,180,000
$2,010,000
$4,210,000
$0
$619,000
$8,370,000
$3,400,000
$9,800
$58,600
$326,000
$192,000
$2,950,000
$142,000
$4,960,000
$66,800
$62,400
$3,500,000
$377,000
$637,000
$40,900,000
$157,000
$557,000
$139,000
$33,900
$150,000
$0
$1,800,000
$904,000
$835,000
$1,750,000
$0
$257,000
$3,480,000
$1,410,000
$4,100
$24,300
$135,000
$79,800
$1,220,000
$58,900
$2,060,000
$27,700
$25,900
$1,450,000
$157,000
$265,000
$17,000,000
$6,530,000
$3,460,000
$3,490,000
$3,870,000
$20,400,000
$2,410,000
$57,200,000
$132,000,000
$9,850,000
$87,400,000
$344,000
$12,600,000
$55,400,000
$6,250,000
$5,190,000
$14,700,000
$8,500,000
$24,200,000
$21,900,000
$3,160,000
$39,900,000
$1,900,000
$4,780,000
$22,600,000
$7,480,000
$10,500,000
$566,000,000
$5,480,000
$2,140,000
$2,870,000
$2,470,000
$13,700,000
$1,600,000
$44,300,000
$93,200,000
$6,190,000
$54,600,000
$289,000
$10,700,000
$34,600,000
$3,740,000
$4,480,000
$11,200,000
$6,230,000
$20,200,000
$16,600,000
$2,450,000
$29,700,000
$1,570,000
$3,160,000
$15,100,000
$6,300,000
$8,300,000
$401,000,000
mu\1595G.XLS
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Table 7.4-2 Capital and O&M Costs for Soil Alternatives1
Medium Group/Subgroup
Sitewide Alternative 5 - Caps/Treatment/Landfill
Munitions Testing
North Plants
Toxic Storage Yards
Lake Sediments
Surficial Soil
Ditches/Drainage Areas
Basin A
Basin F Wastepile
Secondary Basins
Former Basin F
Sanitary/Process Water Sewers
Chemical Sewers
Complex Trenches
Shell Trenches
Hex Pit
Sanitary Landfills
Section 36 Lime Basins
Buried M-l Pits
South Plants Central Processing Area
South Plants Ditches
South Plants Balance Of Areas
Buried Sediments
Sand Creek Lateral
Section 36 Balance Of Areas
Burial Trenches
Total
Capital
Total Cost
$5,710,000
$2,130,000
$3,020,000
$4,300,000
$11,700,000
$4,230,000
$73,300,000
$87,200,000
$12,500,000
$151,000,000
$344,000
$19,200,000
$40,800,000
$52,000,000
$5,490,000
$29,700,000
$10,100,000
$13,600,000
$29,800,000
$4,740,000
$46,300,000
$1,860,000
$9,150,000
$25,200,000
$6,700,000
$650,000,000
Cost
Present Worth2
$4,800,000
$1,590,000
$2,610,000
$2,000,000
$6,680,000
$2,570,000
$50,200,000
$63,000,000
$6,550,000
$98,600,000
$297,000
$16,100,000
$22,900,000
$31,100,000
$4,490,000
$14,000,000
$5,450,000
$10,800,000
$24,300,000
$3,640,000
$36,100,000
$1,130,000
$5,380,000
$13,400,000
$5,150,000
$433,000,000
O&M Cost
Total Cost Present Worth2
$174,000
$1,310,000
$214,000
$74,600
$166,000
$101,000
$13,300,000
$206,000,000
$329,000
$53,400,000
$0
$12,800,000
$6,970,000
$37,100,000
$1,220,000
$820,000
$1,410,000
$9,090,000
$13,000,000
$781,000
$3,480,000
$30,700
$205,000
$840,000
$177,000
$363,000,000
$52,300
$393,000
$64,100
$22,400
$49,900
$30,200
$4,000,000
$61,900,000
$98,800
$16,000,000
$0
$3,850,000
$2,090,000
$11,100,000
$367,000
$246,000
$424,000
$2,730,000
$3,890,000
$234,000
$1,040,000
$9,210
$61,500
$252,000
$53,000
$109,000,000
Page 5 of 5
Total Cost
Total Cost Present Worth2
$5,880,000
$3,440,000
$3,230,000
$4,370,000
$11,900,000
$4,330,000
$86,600,000
$293,000,000
$12,800,000
$204,000,000
$344,000
$32,000,000
$47,800,000
$89,100,000
$6,710,000
$30,500,000
$11,510,000
$22,700,000
$42,800,000
$5,520,000
$49,800,000
$1,890,000
$9,360,000
$26,000,000
$6,880,000
$1,012,000,000
$4,850,000
$1,980,000
$2,670,000
$2,020,000
$6,730,000
$2,600,000
$54,200,000
$125,000,000
$6,650,000
$115,000,000
$297,000
$20,000,000
$25,000,000
$42,200,000
$4,860,000
$14,200,000
$5,870,000
$13,500,000
$28,200,000
$3,870,000
$37,100,000
$1,140,000
$5,440,000
$13,700,000
$5,200,000
$542,000,000
All costs presented in 1995 dollars.
Present-worth calculations based on a 3 percent discount rate.
rma\l595G.XLS
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8.0 Comparative Analysis of Alternatives
8.0 Comparative Analysis of Alternatives
The purpose of the comparative analysis is to identify the advantages and disadvantages of each alternative
relative to the others and to identify the tradeoffs to be made in selecting the preferred alternatives. A preferred
alternative was developed for each contaminated medium (groundwater, structures and soil) because the
interactions among potential soil alternatives and water or structures alternatives were most effectively
addressed in this manner. v
The NCP identifies nine criteria to be used in the evaluation of remedial alternatives during the Detailed
Analysis of Alternatives (Figure 8.0-1). Criteria 1 and 2 (Overall Protection of Human Health and the
Environment, and Compliance with ARARs) are considered "threshold criteria" that must be met by the
preferred alternative. Criteria 3 through 7 (Short-Term Effectiveness; Long-Term Effectiveness; Reduction of
Toxicity, Mobility, or Volume through Treatment; Implementability; and Cost) are considered "balancing
criteria" because they are used to achieve the best overall solution, taking into account technical, cost,
institutional, and risk concerns. As required by EPA guidance, costs are compared on a present worth basis.
The present worth cost is the amount of principal (in current dollars) needed to yield the total cost over the
desired time frame; it accounts for interest gained on principal invested at the start of the project and the cost of
inflation over the life of the project. Criteria 8 and 9 (State Acceptance and Community Acceptance) are used
to evaluate the feasibility of implementing an alternative in terms of its acceptance by regulatory agencies and
the community.
8.1 Comparative Analysis of Alternatives for Groundwater
The four groundwater alternatives compared in this section all include continued operation of the boundary
containment and treatment systems that are currently operational at RMA. Three of the four alternatives
(Alternatives 2, 3, and 4) involve continued operation of the existing IRAs, and two alternatives (Alternatives 3
and 4) include construction of additional on-post extraction and treatment systems. The No Action alternative
(which involves discontinuing the existing boundary systems) was evaluated in the FS, but because it does not
achieve the threshold criteria (overall protection of human health and the environment and compliance with
ARARs), it was not retained as a potential remedy. A summary of the comparative analysis of the groundwater
alternatives is provided in Table 8.1-1.
8.1.1 Overall Protection of Human Health and the Environment
All four groundwater alternatives are protective of human health and the environment because groundwater is
treated at the RMA boundary and because restrictions for potable on-post water use imposed by the FFA are
observed. Nonpotable uses of on-post groundwater were not anticipated and risk was therefore not considered
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Record of Decision for the On-Post Operable Unit
in the HHRC for such uses. A risk evaluation would be performed prior to any future nonpotable use to ensure
that such use is protective of human health and the environment.
A greater degree of protection is provided by Alternative 3 (Boundary Systems/IRAs/Dewatering), which
reduces on-post migration through additional on-post extraction and treatment systems. The operation of the
dewatering and extraction systems will reduce flow through Basin A Neck, reduce the South Plants
groundwater mound, limit migration into the lakes, and prevent flow through the Section 36 bedrock ridge.
Migration is also reduced by the on-post systems included in Alternatives 2 (Boundary Systems/IRAs) and 4
(Boundary Systems/IRAs/Intercept Systems). Because Alternative 4 includes an additional on-post system (the
Section 36 Bedrock Ridge Extraction System), it is slightly more protective than Alternative 2. Alternatives 2
and 4 also result in a natural lowering of the water table in South Plants when combined with the soil covers or
caps in this area. Lowering of the water table will reduce further spreading of contamination, thereby
protecting human health and the environment. Alternative 1 (Boundary Systems) is adequately protective of
human health and the environment, but is slightly less protective than the other three alternatives because it
only addresses groundwater contamination at the boundaries. Site reviews will be conducted every 5 years to
evaluate the effectiveness of the remedies and ensure protection of human health and the environment.
8.1.2 Compliance with ARARs
All four alternatives, if selected, are expected to meet chemical-specific ARARs identified for each treatment
system and comply with action- and location-specific ARARs. The remediation goals for chloride and sulfate
at the NBCS will be achieved through natural attenuation. The goal for sulfate will be the natural background
concentration. Assessment of the chloride and sulfate concentrations will occur at the 5-year site review.
Monitoring and assessment of NDMA contamination will occur in support of potential design
refinement/design characterization to achieve the remediation goals specified for boundary groundwater
treatment systems.
8.1.3 Long-Term Effectiveness and Permanence
All four alternatives provide a high degree of long-term effectiveness and permanence because operation of the
boundary systems eliminates the potential for off-post exposure and because restrictions for potable on-post
water use imposed by the FFA are observed. Nonpotable uses of on-post groundwater were not anticipated and
risk was therefore not considered in the HHRC for such uses. A risk evaluation would be performed prior to
any future nonpotable use to ensure that such use is protective of human health and the environment.
Boundary system operations are proven, effective, and reliable, and treatment residuals are safely disposed off
post. All alternatives also reduce contaminant migration through passive dewatering, a result of a reduction of
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8.0 Comparative Analysis of Alternatives
infiltration and removal of water from process and fire protection pipes in the areas of South Plants and Basin A
that will be covered as a part of the selected soil remedy. Additionally, Alternative 2 reduces contaminant
migration through operation of the IRAs. Alternative 3 achieves contaminant reduction through active
dewatenng as well as operation of the on-post IRAs. Alternative 4 reduces contaminant migration through
continued operation of the IRAs and the Section 36 Bedrock Ridge Extraction System.
\
8.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment
Operation of the boundary systems, which is a component of all four alternatives, provides substantial reduction
in toxicity, mobility, or volume through treatment of contaminated groundwater; approximately 1 billion
gallons per year of water are currently being treated at the systems. Alternatives 2,3, and 4 provide additional
reduction in toxicity, mobility, or volume because they involve operation of the IRAs and additional on-post
extraction/treatment systems. Compared to Alternative 1, Alternatives 2 and 4 treat approximately 170 million
additional gallons per year, while Alternative 3 treats an additional 215 million gallons per year for the first 10
years and 190 million gallons per year for the next 20 years. On-post treatment under Alternatives 2, 3, or 4
will be continued until remediation is complete.
All alternatives achieve reductions in contaminant mobility and volume through passive dewatenng, which is a
result of installation of the soil covers or caps in the Basin A and South Plants areas. Mobility and volume are
not reduced through treatment but through passive methods. Alternative 3 achieves the most rapid reduction in
toxicity, mobility, or volume through active dewatering, which lowers the water table, thereby reducing
migration and leaching of residual contamination from soil. Alternative 4 is slightly more effective in reducing
toxicity than Alternative 2 because the additional volume of contaminated water that is extracted and treated is
small. Alternative 4 also reduces or prevents the mobility of contaminants in groundwater, thus
reducing/preventing their migration into the First Creek alluvial channel.
8.1.5 Short-Term Effectiveness
All four alternatives are protective of workers, the community, and the environment during the construction and
implementation phases. Alternative 2 has the least impact as it is already in place and involves no additional
actions. Alternatives 1 and 4 have minimal potential impacts. For Alternative 1, these impacts are associated
with demolition of the existing IRAs; for Alternative 4, they are associated with drilling and construction of the
Section 36 Bedrock Ridge Extraction System. Alternative 3 involves more intrusive activities than the other
three alternatives, but it can still be implemented within a fairly short time period and with minimal negative
impact to workers, the community, and the environment.
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Record of Decision for the On-Post Operable Unit
8.1.6 Implementability
Alternative 2 is most easily implemented because it involves continued operation of all existing systems
without any additional construction or demolition. Alternatives I and 4 are slightly more difficult to implement
than Alternative 2 because they involve installation of a small extraction and piping system (Alternative 4) or
demolition of the existing IRAs (Alternative 1). Alternative 3 is the most difficult to implement since it
requires installation of horizontal well networks and a new treatment system. All of the alternatives use
available technologies that are both technically and administratively implementable, although horizontal wells
are an innovative technology. The monitoring systems included in each alternative will allow evaluation of the
effectiveness of the remedy, and additional actions could be implemented readily if monitoring indicated that
ARARs were not being met.
8.1.7 Cost
The total present worth costs for the groundwater alternatives range from $80 million to $130 million (1995
dollars). Alternative 1 has the lowest cost at $80 million, Alternatives 2 and 4 have comparable present worth
costs at $98 million and $104 million, respectively, and Alternative 3 is the most expensive alternative at $130
million. A breakdown of O&M costs for the components of each alternative is presented in Table 7.2-2.
8.1.8 State Acceptance
The state of Colorado has been actively involved throughout the RI/FS and remedy selection process for the
On-Post Operable Unit. The state was provided the opportunity to comment on the RI/FS documents and on
the Proposed Plan, and has taken part in numerous public meetings, including the public meeting on November
18, 1995, to inform the public of the content of the Proposed Plan. Written comments received from the state
during the public comment period indicate their concern about the water-supply issue, the Medical Monitoring
Program, the Trust Fund, and hydraulic control of the lakes in the South Lakes area.
Responses to the state's comments are provided in the Responsiveness Summary (Section 12).
8.1.9 Community Acceptance
Interested members of the public, including individual citizens, representatives of the local communities, and
representatives of national groups, have been actively involved in reviewing the FS and evaluating potential
remedial alternatives for the past 2 years as a result of the outreach program described in Section 3. The
preferred groundwater alternative for the On-Post Operable Unit was presented to the public in the Proposed
Plan, which provides a brief summary of all of the alternatives evaluated during the Detailed Analysis of
Alternatives phase of the FS. The original comment period of 60 days was extended to 90 days at the request
of some commenters.
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8.0 Comparative Analysis of Alternatives
The concerns expressed by the public included the water-supply issue, the adequacy of the selected remedy and
the monitoring program, the implementation of the Medical Monitoring Program, the establishment of the Trust
Fund, and presence of NDMA in groundwater.
Responses to the communities comments are provided in the Responsiveness Summary. (Section 12).
\
8.1.10 Conclusions
All four groundwater alternatives provide adequate protection of human health and the environment through
continued operation of the boundary systems. Alternative 3 is more protective than the other alternatives
because it removes the largest amount of contaminants and most rapidly reduces the potential for additional on-
post migration. Alternative 4 is more protective than Alternative 2 because it involves additional treatment
beyond the existing IRAs, and Alternative 2 is more protective than Alternative 1.
All alternatives will comply with ARARs and all provide equivalent long-term effectiveness and permanence.
Alternative 3 provides the greatest reduction in toxicity, mobility, or volume through treatment, but it is less
effective in the short term and less implementable than the other three alternatives because it involves
construction of new extraction and treatment systems. Alternative 4 provides a greater reduction in toxicity,
mobility, or volume through treatment than Alternatives 1 or 2, but it is slightly less effective in the short term
and is slightly less implementable than Alternative 2. The short-term effectiveness and implementability of
Alternative 1 is similar to that of Alternative 4, but Alternative 1 provides the least reduction in toxicity,
mobility, or volume through treatment of contaminated groundwater.
Alternative 1 has the lowest present worth cost because all existing IRAs are discontinued, while Alternative 3
has the highest cost because it involves the most new construction and treatment. The costs of Alternatives 2
and 4 lie between Alternatives 1 and 3. Alternative 4 provides a small amount of additional treatment
compared to Alternative 2 at a slightly higher cost.
Alternative 4 is superior to the other groundwater remedial alternatives for the On-Post Operable Unit for the
following principal reasons:
• Alternative 4 is preferable to Alternatives 1 and 2 because it provides additional reduction of toxicity,
mobility, or volume of contaminated groundwater at a reasonable cost and with minimal short-term
effects. It is also readily implementable.
• Although Alternative 3 provides greater reduction of toxicity, mobility, and volume than Alternative 4,
it is less readily implementable than Alternative 4. Furthermore, when considered in conjunction with
the preferred soil alternative and the continued operation of the boundary groundwater containment
and treatment systems, Alternative 3 provides limited added benefit compared to Alternative 4 at a
higher cost.
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Record of Decision for the On-Post Operable Unit
8.2 Comparative Analysis of Alternatives For Structures
The three structures alternatives compared in this section involve removing all No Future Use structures and
disposing the debris in the on-post hazardous waste landfill. All structures alternatives include the completion
or continuation of structures IRAs as described in Section 7.3.3. The ultimate disposal method for the
structures medium groups is chosen based on the following approach:
• The Agent History Group must be disposed in the hazardous waste landfill to comply with Army
regulations. v
• The Significant Contamination History Group contains structures with use histories that indicate a
possibility of significant contamination. This group is disposed in the hazardous waste landfill.
• For the Other Contamination History Group, the disposal options include capping in place,
consolidation in Basin A, or disposal in the on-post hazardous waste landfill.
The No Action Alternative (which involves leaving all structures in place) was evaluated in the FS, but it was
not retained as a potential remedy because it did not achieve a threshold criterion (overall protection of human
health and the environment). A summary of the comparative analysis of the structures alternatives is provided
in Table 8.2-1.
8.2.1 Overall Protection of Human Health and the Environment
All three structures alternatives are protective of human, health and the environment because all potentially
contaminated structures are demolished and disposed to prevent exposure to humans or wildlife. Alternative 3
(Landfill) is slightly more protective than Alternative 2 (Landfill/Consolidate) because all structural debris is
placed in the on-post hazardous waste landfill. Alternative 2 is in turn slightly more protective than
Alternative 1 (Landfill/Cap in Place) because the debris that is not landfilled is consolidated at one location
under a thick soil cover that includes a layer of concrete. Agent-contaminated debris is treated as necessary
under all three alternatives, but other treatment is not undertaken because there is a potential for increased
worker exposures at no added benefit.
8.2.2 Compliance with ARARs
All three structures alternatives comply with the chemical-, action- and location-specific ARARs listed in
Appendix A.
8.2.3 Long-Term Effectiveness and Permanence
All three structures alternatives provide adequate long-term effectiveness and permanence. Removal and
disposal of the structures involves significantly less long-term risk than leaving the structures in place and
restricting access to them. Additionally, the majority of the structures must be removed to accommodate the
soil remedial alternatives. Because structure debris is contained by capping or landfilling, there is low residual
risk.
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8.0 Comparative Analysis of Alternatives
Because high levels of contamination are not expected to be associated with the majority of the structures, the
long-term risks associated with waste management are expected to be low. Adequate controls are provided, and
the permanence of the solution is verified by long-term monitoring. Alternatives 2 and 3 are slightly more
effective in the long term than Alternative 1 because the structural debris is consolidated into central locations
(the landfill and, for Alternative 2, Basin A) rather than remaining dispersed under several caps that require
additional long-term maintenance. v
8.2.4 Reduction of Toxicity, Mobility, or Volume Through Treatment
All three structures alternatives reduce contaminant toxicity, mobility, or volume through treatment.
Demolition of structures reduces the standing volume. Capping or landfilling the structural debris reduces the
mobility of contaminants through engineering controls, although this reduction may-be compromised should the
cap or landfill leak. Caustic washing irreversibly reduces the toxicity, mobility, and volume of Army chemical
agent through treatment, but produces a hazardous liquid sidestream that will be treated on post. Alternative 3 is
slightly more effective in reducing mobility than Alternative 2 because the structural debris is contained in a
landfill, and Alternative 2 is slightly more effective in reducing mobility than Alternative 1 because the debris
is consolidated into two central locations rather than dispersed under several caps that require additional long-
term maintenance.
8.2.5 Short-Term Effectiveness
All three structures alternatives provide equal short-term effectiveness. Air monitoring and dust controls are
required during demolition, transportation, and disposal. Worker protection will be required for physical
hazards associated with dismantling and for chemical hazards associated with caustic washing and handling of
agent-contaminated debris. Remediation is completed within 3 to 4 years under all three alternatives. Because
high levels of contamination are not expected to be associated with the majority of the structures, the risks
associated with short-term worker and community exposure are expected to be low for all alternatives.
There are unique concerns for structures with potential Army chemical agent presence. After demolishing the
structures, caustic washing is administered to debris, as necessary, and the debris is disposed in the on-post
hazardous waste landfill to comply with Army agent regulations. Because the highest probability of
encountering agent residues is in process piping and tanks, which are currently being treated and removed as
part of the chemical process-related IRA activities, the potential for encountering agent associated with building
materials is low. Thus, short-term risks during such remediation activities are considered low for all
alternatives.
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8.2.6 Implementability
All three structures alternatives are generally technically and administratively feasible, although Alternatives 2
and 3 are more implementable because there are regulatory concerns with capping structural debris in place
(Alternative 1). Implementation of structures remediation will require coordination with the remediation
scheduled for other environmental media. However, because the time frame during which structures are to be
demolished is relatively short, structures remediation should not hinder the remainder of the remediation
efforts. The structures demolition must begin in the areas in which soil remediation is planned so that the soil
remediation schedule is not delayed. Structures covered under any chemical weapons agreements may need to
be removed to comply with the requirements of these agreements.
Significant Contamination History Group and Agent History Group structural debris will be placed into the cm-
post hazardous waste landfill as demolition proceeds. Accordingly, the landfill must be constructed and in
operation prior to the commencement of demolition activities. Other Contamination History Group debris may
be placed in the Basin A consolidation area, which requires minimal preparation; in the on-post hazardous
waste landfill, which must be ready before demolition begins; or in the areas to be capped, which require
minimal preparation. In general, structures must be removed before the soil remedy can be implemented.
8.2.7 Cost
The present worth costs (1995 dollars) are similar for all three alternatives ($106 million for Alternative 1, $104
million for Alternative 2, and $109 million for Alternative 3) because the alternatives only differ with regard to
the disposal method for the Other Contamination History Group debris. There are several ongoing structures
IRAs whose costs also contribute significantly to the total cost of structures remediation. The total estimated
structures IRA costs are $76,000,000, of which $41,000,000 will be spent by the completion of the ROD (and is
not included in the above costs), and an additional $35,000,000 will be spent in post-ROD removal actions (not
included in the above costs). A breakdown of capital and O&M costs for the components of each alternative is
*
presented in Table 7.3-2.
8.2.8 State Acceptance
The state has been actively involved throughout the RI/FS and remedy selection process for the On-Post
Operable Unit. The state was provided the opportunity to comment on the RI/FS documents and on the
Proposed Plan, and has taken part in numerous public meetings, including the public meeting on November 18,
1995, to inform the public of the content of the Proposed Plan. Written comments received from the state
during the public comment period indicate that there were no major concerns regarding the structures remedy.
Responses to the state's comments are provided in the Responsiveness Summary (Section 12).
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8.0 Comparative Analysis of Alternatives
8.2.9 Community Acceptance
Interested members of the public, including individual citizens, representatives of the local communities, and
representatives of national groups, have been actively involved in reviewing the FS and evaluating potential
remedial alternatives for the past 2 years as a result of the outreach program described in Section 3. The
preferred structures alternative for the On-Post Operable Unit was presented to the public in the Proposed Plan,
which provides a brief summary of all of the alternatives evaluated during the Detailed Analysis of Alternatives
V
phase of the FS. This original comment period of 60 days was extended to 90 days at the request of some
commenters.
The concerns expressed by the public included questions with regards to the adequacy of the structures
sampling and analytical program. Responses to the community's comments are provided in the Responsiveness
Summary (Section 12).
8.2.10 Conclusions
All three structures alternatives provide adequate protection of human health and the environment. Treatment
technologies are generally not included because of the exposure risks to workers and the limited benefits for all
but the Agent History Group. On-post hazardous waste landfilling for the Significant Contamination History
Group is a protective remedy that is included in all three alternatives. The long-term effectiveness of
Alternatives 2 and 3 is higher than Alternative 1, which relies on caps in several disposal locations. All three
alternatives are equivalent with respect to reduction of toxicity, mobility, or volume through treatment or
engineering controls and short-term effectiveness. For Alternative 1, regulatory concerns remain about capping
Other Contamination History Group debris in place, which makes its implementibility less certain.
Consolidation or landfilling of Other Contamination History Group debris (under Alternatives 2 and 3,
respectively) is implementable and cost effective.
Alternative 2 is superior to the other structures alternatives for the On-Post Operable Unit for the following
principal reasons:
• Alternatives 2 and 3 are preferable to Alternative 1 because they are more implementable and
structural debris is consolidated into one or two disposal locations.
• Alternative 2 is more desirable than Alternative 3 because the Other Contamination History Group
structural debris is used as fill in Basin A, reducing the amount of clean borrow needed and reducing
the total volume to be landfilled. This alternative is also slightly less costly than Alternative 3.
8.3 Comparative Analysis of Alternatives for Soil
The five soil alternatives that are compared in this section involve a combination of containment (as a principal
element) and treatment technologies to reduce contamination. A summary of the comparative analysis of the
soil alternatives is provided in Table 8.3-1.
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As described in Section 7.1.3, the criteria for evaluating soil contamination helped focus the evaluation of
potential remedial activities on areas of highest risk to human health and the environment. Alternatives were
developed to include treatment of principal threat volumes, where practicable, with containment or institutional
controls being enacted for the balance of the exceedance areas. The sheer volume of contaminated soil present
on the site precludes a remedy in which all contaminants could be excavated and cost effectively treated.
\
8.3.1 Overall Protection of Human Health and the Environment
The five alternatives for soil provide overall protection of human health through a combination of containment
and treatment. Alternatives 1 (Caps/Covers), 2 (Landfill/Caps), and 3 (Landfill) provide for protection of
human health primarily through containment of human health exceedances, which interrupts exposure pathways
and reduces the migration of contaminants to groundwater and the atmosphere. Alternatives 4
(Consolidation/Caps/Treatment/Landfill) and 5 (Caps/Treatment/Landfill) address portions of the most
contaminated soil through treatment, but still rely on capping and landfilling to protect human health in the
majority of the contaminated areas.
Under each of the five alternatives, the protection of wildlife is generally accomplished through containment of
portions of the core areas of RMA that may pose a risk to biota by capping, covering, or landfilling. These
actions interrupt the potential for biota exposure, and also prevent burrowing animals from coming into contact
with contaminated soil. Outside the core area, these alternatives address surficial soil with low levels of
contamination using two different approaches. Alternative 5 includes the treatment of approximately 1,600
acres through agricultural practices, which reduces the level of OCPs in near-surface soil but results in the
disturbance of habitat over widespread areas of RMA. The other four alternatives address low-level surficial
soil contamination by continued monitoring only, thereby avoiding the disruption of wildlife in these areas
during remedial activities and habitat restoration.
Alternatives 3, 4, and 5 are more protective than Alternatives 1 or 2 because larger volumes of contaminated
soil are contained in a secure landfill and/or treated. Alternatives 3 and 4 offer equivalent overall
protectiveness because there is a tradeoff between landfilling a greater total volume under Alternative 3 versus
landfilling the Basin F Wastepile and treating more material under Alternative 4. Alternative 5 is more
protective than the other alternatives because more material is treated.
8.3.2 Compliance with ARARs
Each of the five alternatives complies with chemical-, action-, and location-specific ARARs. The number of
ARARs, and the difficulties associated with demonstrating compliance with these ARARs, are substantially
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8.0 Comparative Analysis of Alternatives
higher for Alternative 5 based on the complexity of the alternative and the use of thermal treatment
technologies.
8.3.3 Long-Term Effectiveness and Permanence
Each of the five alternatives results in minimal residual risk based on the adequacy and reliability of controls
offered by each alternative. All five alternatives rely on fcontainment of a significant portion of the
contaminated soil to protect human health and the environment, requiring long-term maintenance and
monitoring activities. Long-term management also includes access restrictions to capped and covered areas to
ensure the integrity of the containment systems. Alternatives 4 and 5 leave smaller volumes of contaminated
soil (approximately 8 percent and 40 percent of the human health exceedance volume, respectively, are treated)
with lower levels of contamination requiring long-term controls; however, these alternatives still rely on
containment of large volumes of contaminated soil (92 and 60 percent, respectively). Alternative 5 also
includes the treatment of approximately 1,600 acres through agricultural practices, which reduces the level of
OCPs in near-surface soil but results in the disturbance of habitat over widespread areas of RMA. The
containment systems for the five alternatives are adequate and reliable for long-term protection of human health
and the environment.
Alternative 1 addresses both highly contaminated soil and large volumes of contaminated soil through
containment in place. The installation of caps/covers provides adequate protection for human health and
wildlife by eliminating exposure to contaminated soil. The caps provide long-term reduction in the migration
of contaminants to groundwater. Based on the operation of the existing groundwater systems and the
groundwater removal systems to be installed as part of the selected water alternative, this alternative provides
long-term effectiveness and a low residual risk. A residual risk may exist for biota because surficial soil that
may pose a risk to biota is left in place and monitored. However, widespread areas of wildlife habitat are not
disturbed to address this residual risk.
Alternatives 2 and 3 both rely on containment systems that effectively protect humans and biota from exposure
to contaminated soil. The bottom liner of a landfill controls the migration of leachate. Landfill covers and caps
both provide long-term protection by preventing infiltration into the contaminated materials and releases to the
atmosphere. These two alternatives provide similar levels of long-term protection and minimal long-term risks,
although landfilling does provide, by virtue of the liner, an increased level of containment than a cap does.
Both of these alternatives involve potential risk for biota because surficial soil that may pose a risk to biota is
left in place and monitored; however, widespread areas of habitat are not disturbed to address this residual risk.
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Alternatives 4 and 5 treat portions of the most contaminated soil, thereby reducing the level of contamination in
the soil requiring long-term controls. However, both alternatives use similar containment systems as the other
three alternatives to address large volumes of lower-level contamination (92 percent and 60 percent of the
human health exceedance volume, respectively). Alternative 5 does treat a larger volume of soil, primarily
through treatment of the Basin F Wastepile, but still relies on containment of a large volume of soil to provide
long-term protection. Alternatives 4 and 5 provide similar levels of Jong-term protection, but do not eliminate
the need for long-term monitoring and maintenance of capped and landfilled areas.
8.3.4 Reduction of Toxlcity, Mobility, or Volume Through Treatment
Alternatives 4 and 5 provide the greatest reduction in toxicity, mobility, or volume through treatment. These
alternatives permanently reduce the toxicity, mobility, or volume of contaminated soil through treatment of
207,000 and 1.1 million BCY of soil, respectively, and they reduce the mobility of contaminants in the
remaining soil through containment with caps, soil covers, and landfills. The other three alternatives provide
reduction in mobility through containment; however, Alternative 1 provides somewhat lower reduction in
mobility because Alternatives 2 and 3 include landfilling of some of the contaminated soil, which provides
some measure of additional containment of contaminants and reduction in mobility compared to capping.
Ultimately, however, all containment alternatives rely on the effectiveness of the caps and soil covers to reduce
infiltration.
8.3.5 Short-Term Effectiveness
The short-term effectiveness of the five alternatives is primarily governed by the risks posed during remedial
actions and the time required until remediation goals are achieved. Short-term effectiveness decreases as a
result of the increase in risks during remedial actions and the longer time frames for implementation of the
more complex remedial alternatives.
Alternatives 1 and 2 have minimal to low short-term risks as the central portions of RMA (with high levels of
contamination) are capped in place. Thus, the risks to workers and the surrounding community from the
excavation, transportation, and treatment/disposal of soil with high-level contamination are avoided. The
implementation time of these alternatives is approximately 17 and 16 years, respectively. Alternative 2
includes the landfilling of 2 million BCY of contaminated soil (instead of containment in place), but the risks
associated with excavation, transportation, and disposal of this soil are not significantly increased compared to
capping based on the low levels of contamination in the soil to be landfilled. These two alternatives address
soil in the core area of RMA that may pose a risk to biota through containment, but do not entail additional
remedial actions for surficial soil that may pose a risk to biota, which is left in place and monitored. In this
manner, widespread areas of habitat are not disturbed to address soil with a low residual risk.
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8.0 Comparative Analysis of Alternatives
The other three alternatives involve excavation and treatment/disposal of portions of the most contaminated
soil, which increases the short-term risks to workers and the community. Alternative 4 removes a smaller
volume of highly contaminated soil, and therefore exhibits lower risks due to excavation, transportation, and
disposal activities than Alternatives 3 or 5, which present the highest short-term risk to workers and the
community. Under these alternatives, the largest volume of highly contaminated areas is excavated for
treatment and/or disposal, requiring specialized vapor- and odor-suppression measures to minimize the release
of contaminants. The implementation time frame for Alternative 5 is the longest at approximately 28 years.
Although steps can be taken to control short-term risks during remedial actions under these three alternatives,
the short-term effectiveness for these alternatives is lower than for Alternatives 1 or 2. Negative-pressure vapor
enclosures are one approach to controlling vapors and odors that may be emitted from several areas to be
excavated under Alternatives 3, 4, and 5. Work within enclosures would require extensive worker protection
and could present significant hazards to workers. Although the air within the enclosure is collected and treated,
or, where an enclosure was not used, other measures could be taken to mitigate short-term risks, the short-term
risks of contaminant release associated with excavating these areas cannot be completely eliminated.
8.3.6 Implementability
The implementability of the five alternatives varies from easy for Alternatives 1 and 2, which are readily
constructed using common construction equipment, to difficult for Alternative 5. This alternative presents
difficulties in the construction and operation of the treatment technologies, which have not been implemented at
any other site in the country at the scale required at RMA. The implementability of Alternatives 3 and 4 is
moderate.
Alternatives 1 and 2 are both considered easy to implement because they consist of the proven and available
technologies of capping and landfilling and because they do not require the use of vapor controls. Alternatives
3 and 4 involve a similar level of difficulty in the excavation, transportation, and disposal of large volumes of
highly contaminated soil. Alternative 4, which makes use of readily available mobile equipment for treatment
of soil by solidification/stabilization, is implementable. Implementability of the innovative thermal technology
for the Hex Pit will be determined during remedial design treatability testing. Consolidation of some soil
potentially posing risk to biota (as a source of gradefill) decreases the cost and disruption of habitat for borrow
areas. Alternative 5 is the most difficult to implement and requires the longest time frame based on the
difficulties with implementation of vapor controls, if necessary, and treatment technologies. There is a high
level of uncertainty in the performance of thermal technologies on the complex contaminant mixtures and high
salt levels in some principal threat soil, leading to a potential for failure to meet the treatment specifications and
a potential for extensive shut-down time to modify and maintain the system.
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Record of Decision for the On-Post Operable Unit
8.3.7 Cost
The estimated present worth cost (in 1995 dollars) for Alternative 2 is the lowest at $276 million. The present
worth cost for Alternative 1 is estimated to be $386 million, followed by Alternatives 3 and 4 at $384 and $401
million, respectively. The estimated present worth cost for Alternative 5 is the highest at $542 million for soil
remediation. A breakdown of capital and O&M costs for the components of each alternative is presented in
Table 7.4-2.
The greatest overall cost uncertainty is associated with the remediation of soil, and the uncertainty is higher for
alternatives that include excavation and treatment than for alternatives that minimize the handling of highly
contaminated soil through containment in place. The level of cost uncertainty is relatively low for Alternatives
1, 2, and 4 because demonstrated construction and excavation technologies are used. The cost uncertainty
associated with Alternative 3 is moderate as demonstrated technologies are used for containment, although
large volumes of highly contaminated soil are excavated. Alternative 5 entails the highest degree of cost
uncertainty due to the use of complex treatment technologies and the excavation, transportation, treatment, and
disposal of large volumes of highly contaminated soil.
8.3.8 State Acceptance
The state has been actively involved throughout the RI/FS and remedy selection process for the On-Post
Operable Unit The state was provided the opportunity to comment on the RI/FS documents and on the
Proposed Plan, and has taken part in numerous public meetings, including the public meeting on November 18,
1995, to inform the public of the content of the Proposed Plan. Written comments received from the state
during the public comment period indicate their concerns about the Medical Monitoring Program, the Trust
Fund, and treatment of the Hex Pit.
Responses to the state's comments are provided in the Responsiveness Summary (Section 12).
8.3.9 Community Acceptance
Interested members of the public, including individual citizens, representatives of the local communities, and
representatives of national groups, have been actively involved in reviewing the FS and evaluating potential
remedial alternatives for the past 2 years as a result of the outreach program described in Section 3. The
preferred soil alternative for the On-Post Operable Unit was presented to the public in the Proposed Plan, which
provides a brief summary of all of the alternatives evaluated during the Detailed Analysis of Alternatives phase
of the FS. The original comment period of 60 days was extended to 90 days at the request of some commenters.
FOSTER 0 WHEELER
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8.0 Comparative Analysis of Alternatives
The concerns expressed by the public included questions related to the Medical Monitoring Program, the Trust
Fund, the adequacy of the selection remedy and the monitoring program, and concerns regarding the potential
presence of dioxin. Responses to the community's comments are provided in the Responsiveness Summary
(Section 12).
8.3.10 Conclusions *
Alternative 1 provides the level of protection of human health and wildlife required under CERCLA by
preventing exposures to contaminated soil. In addition, this alternative has minimal short-term risks since the
central portions of RMA (with high levels of contamination) are capped in place, thereby avoiding the risks
from excavation, transportation, and treatment/disposal of soil with high-level contamination. The mobility of
the contaminants is reduced by minimizing the amount of infiltration that may mobilize the contaminants from
the soil to the groundwater and eliminating the airborne migration pathway. However, no action is taken to
reduce the toxicity or volume of the contaminated soil. The implementation time frame for Alternative 1 is less
than the other alternatives, although its cost is higher than Alternative 2. The overall effectiveness of
Alternative 1 is somewhat lower than the other alternatives based on the lower reduction in mobility resulting
from capping as compared to landfilling or the destruction of contaminants through treatment. However, all
alternatives rely on capping/landfllling of the majority of the contaminated soil to provide long-term risk
reduction.
Alternative 2 protects humans and biota by providing a physical barrier, through capping and landfilling, to
prevent exposures and reduce the amount of infiltration that may mobilize contaminants to groundwater.
Caps/covers and landfills provide effective containment of the contaminated soil. The contaminated soil from
the outlying sections of RMA that is landfilled poses a minor risk to workers and the community during
excavation and transportation due to the low level of contamination in the soil. Soil in the core area of RMA
with high levels of contamination (such as the Basin A, Disposal Trenches, and Basin F Medium Groups and
South Plants Central Processing Area Subgroup) is left in place and capped. The mobility of the contaminants
in these areas is further reduced by minimizing the infiltration through the contaminated soil and eliminating
the airborne migration pathway. The overall effectiveness of Alternative 2 is high because it provides effective
containment of the contaminants by balancing the short-term risks of excavation with long-term effectiveness.
Alternative 3 protects humans and biota by providing a physical barrier that prevents exposure through
landfilling and capping. However, significant risks are posed to workers and the community during excavation
and transportation of large volumes of highly contaminated soil. Although vapor- and odor-suppression
measures are used during the excavation of several sites, the short-term risks associated with excavation of
contaminated soil cannot be completely eliminated. The mobility of the contaminants is eliminated by placing
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Record of Decision for the On-Post Operable Unit
the contaminated soil in the landfill, but no action is taken to reduce the toxicity or volume of the contaminated
soil. The overall effectiveness of Alternative 3 is moderate because it provides low long-term risk but entails
high short-term risks during excavation and transportation of highly contaminated soil.
Alternative 4 protects humans and biota by treating some principal threat materials and providing a physical
barrier (i.e., caps, soil covers, and landfill) to prevent exposure. Mobility of the contaminants is reduced by
minimizing the amount of infiltration into the contaminated soil below the caps or in the landfill. The toxicity
and mobility of contaminated soil is reduced through treatment of some principal threats by
solidification/stabilization. Increased short-term risks are posed to workers and the community during
excavation, transportation, and landfill of highly contaminated soil. The risks associated with excavation are
reduced, but are not eliminated, through the use of vapor- and odor-suppression measures at several excavation
areas. In addition, placement of soil excavated from the Basin F Wastepile and Section 36 Lime Basins in a
triple-lined landfill cell provides added assurance of containment. The consolidation of 1.5 million BCY of
contaminated soil in Basin A, Basin F, and the South Plants Central Processing Area prior to capping these sites
lowers the cost of obtaining borrow materials and reduces the area disturbed for borrow. The implementability
of this alternative is moderate because highly contaminated soil is excavated. However, the overall
effectiveness of Alternative 4 is high because it provides low long-term risk, compensating for the increased
short-term risk during excavation.
Alternative 5 treats areas of highly contaminated soil, thereby reducing the contaminant toxicity, mobility, or
volume. However, workers and the community are exposed to the highest short-term risks under Alternative 5
(compared to other alternatives) during excavation, transportation, and treatment. Although vapor- and odor-
suppression measures are used during the excavation of several sites, the short-term risks associated with
excavation of highly contaminated soil cannot be completely eliminated. The mobility of the contaminants is
minimized by placing the contaminated soil in a landfill. However, this alternative has a low overall
effectiveness based on the high short-term risks during remedial actions and the longer time frame (a minimum
of 14 years) until actions are completed. In addition, the implementability of this alternative is very difficult
because of the large volume of highly contaminated soil (including the Basin F Wastepile) to be treated by
thermal treatment.
Alternative 4 is superior to the other soil remedial alternatives for the On-Post Operable Unit for the following
principal reasons:
• Alternative 4 is preferable to Alternatives 1, 2, and 3 because it provides additional reduction of
toxicity, mobility, or volume of contaminated soil through some treatment with minimal short-term
effects and more secure containment of the Basin F Wastepile materials in a new triple-lined landfill
cells. Alternative 4 is also readily implementable.
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8.0 Comparative Analysis of Alternatives
Although Alternative 5 provides greater reduction of toxicity, mobility, or volume through more
treatment than Alternative 4, it is much less readily implementable than Alternative 4 because the
treatment technologies identified have never been used at the scale required at RMA. Furthermore,
Alternative 5 is significantly more costly than Alternative 4, and the uncertainty of execution related to
schedule and budget is much higher for Alternative 5 than for Alternative 4.
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FOSTER SI WHEELER
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•I Overall Protection of 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.
13 Implementability refers to the
technical and administrative feasibility
of a remedy. This includes the
availability of materials and services
needed to cany out a remedy. It
also includes coordination of federal,
state, and local governments to work
together to clean up the site.
B Compliance with Applicable
or Relevant and Appropriate
Requirements (ARARs) addresses
whether or not a remedy will meet
all federal and state environmental
laws and standards and/or
provides grounds for a waiver.
Q Cost evaluates the estimated
capital, operating, and
maintenance costs of each
alternative in comparison to other
equally protective alternatives.
El Short-Term Effectiveness
addresses the period of time
needed to complete the remedy
and any adverse effects to human
health and the environment that
may be caused during the
construction and implementation
of the remedy.
D State Acceptance indicates
whether the state agrees with,
opposes, or has no comment on
the preferred alternative.
D Long-Term Effectiveness
and Permanence refers to the
ability of a remedy to provide
reliable protection of human
health and the environment over
time.
El Community Acceptance includes
determining which components of the
alternatives interested persons in the
community support, have reservations
about, or oppose. This assessment
may not be completed until public
comments on the Proposed Plan are
reviewed.
El Reduction of Toxfcity, Mobility,
or Volume through Treatment
refers to the preference for a
remedy that through treatment
reduces health hazards, the
movement of contaminants, or
the quantity of contaminants at
the site.
IMA ROD 6.96 jb
Figure 8.0-1
Cleanup Evaluation Criteria
Rocky Mountain Arsenal
Prepared by Foster Wheeler Environmental Corporation
-------
Table 8.1-1 Comparative Analysis of Water Alternatives
Page 1 of2
Criteria
Alternative 1
Boundary Systems
Alternative 2
Boundary Systems/
IRAs (No Additional Action)
Alternative 3
Boundary Systems/
IRAs/Dewatering
Alternative 4
Boundary Systems/
IRAs/Intercept Systems
Overall Protection
of Human Health
and the
Environment
Protective. Provides
protection through operation
of boundary systems.
Protective. Provides
protection through operation
of boundary systems and
minimizes cm-post migration
through operation of IRAs.
Protective. Provides
protection through boundary
systems and minimizes on-
post migration through
operation of IRAs and
additional on-post systems.
Protective.Provides - - ~.
protection: through boundary
systems and minimizes on- ,
post migration through
operation of IRAs and >
additional on-post systems.
Compliance with
ARARs
Complies with action-,
chemical-, and location-
specific ARARs through
active treatment and natural
attenuation of inorganics.
Complies with action-,
chemical-, and location-
specific ARARs through'
active treatment and natural
attenuation of inorganics.
Complies with action-,
chemical-, and location-
specific ARARs through
active treatment and
natural attenuation of
inorganics.
Complies with action-, :
chemical-, and location-
specific ARARs through
active treatment and natural
attenuation of inorganics.
Long-Term
Effectiveness
and Permanence
Low residual risk. Potential
for off-post exposure is
lowered. No on-post
exposure due to FFA
restrictions. Long-term
monitoring required;
contaminant migration
reduced through passive
dewatering.
Low residual risk. Potential
for off-post exposure is
lowered. No on-post
exposure due to FFA
restrictions. Long-term
monitoring required;
contaminant migration
reduced through IRAs,
source capture, and passive
dewatering.
Low residual risk. Potential
for off-post exposure is
lowered. No on-post
exposure due to FFA
restrictions. Long-term
monitoring required;
contaminant migration
reduced through IRAs,
source capture, and active
dewatering.
Low residual nik. Potential
for off-post exposure is <
lowered. No on-post exposure '
due to FFA restrictions. Long-
term monitoring required',
contaminant migration
reduced through IRAs, source }
capture, and passive
dewatering. „ ;
Reduction of
Toxicity, Mobility,
or Volume (TMV)
TMV reduced at boundary.
Contaminants removed by
GAC adsorption, reducing
toxicity and volume.
Selected alternative
TMV reduced at boundary
and on post. Contaminants
removed by GAC adsorption
and air stripping, reducing
toxicity and volume; source
capture at Basin A Neck and
passive dewatering limit
migration.
TMV reduced at boundary
and on post. Contaminants
removed by GAC adsorption
and air stripping, reducing
toxicity and volume;
dewatering and source
capture significantly limit
migration and mobility.
TMV reduced at boundary /
and on post. Contaminants,, ' •
removed by GAC adsorption '
and air stripping, reducing
toxicity and volume; source ;
capture and passive 1
dewatering limit mobility.
RMAROD6.96jb
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Table 8.1-1 Comparative Analysis of Water Alternatives
Page 2 of 2
Criteria
Alternative 1
Boundary Systems
Alternative 2
Boundary Systems/
IRAs (No Additional Action)
Alternative 3
Boundary Systems/
IRAs/Dewateri ng
Alternative 4 <
Boundary Systems/
IRAs/Intercept Systems
Short-Term
Effectiveness
Effective. Minimal
negative impact;
achieves RAOs.
Effective. No additional
impact associated with
continued operation;
achieves RAOs.
Effective. Minimal
negative impact
associated with
installation of dewatering
system; achieves RAOs.
Effective. Minimal negative
, impact associated with
installation of extraction
system; achieves RAOs.
Implementability
Technically and
administratively feasible.
Technically and
administratively feasible.
No additional construction
involved.
Technically and
administratively feasible.
Treatment by proven
technologies except for in
situ biological treatment in
South Plants.
Technically and
administratively feasible.
Treatment by proven,
technologies.
Present Worth Cost $80 million
$98 million
$130 million
$104 million
Conclusion
Not selected. Meets
evaluation criteria, but
provides less protection than
other alternatives.
Not selected. Meets
evaluation criteria, but does
not provide additional
control and protection
beyond what is currently in
place.
Not selected. Meets
evaluation criteria and
provides additional on-post
controls, but at higher cost
than the other alternatives.
Selected. Meets evaluation
criteria and is consistent with
me proposed soil alternative.
Provides adequate on-post
controls at minimal added
cost , , '
Selected alternative
RMA ROD 6.96 jb
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Table 8.2-1 Comparative Analysis of Structures Alternatives
Page 1 of 2
Criteria
Alternative 1
Landfill/Cap in Place
Alternative 2
Landfill/Consolidate
Alternative 3
Landfill
Overall Protection of
Human Health and
the Environment
Protective. Debris is contained by
capping or landfilling. Agent debris is
treated as necessary.
Protective. Debris is contained by
consolidation or landfilling. Agent
debris is treated as necessary.
Protective. Debris is contained by
landfilling. Agent debris is treated as
necessary.
Compliance with
ARARs
Complies with action-, chemical-, and
location-specific ARARs.
Complies with action-, chemicals
and location-specific ARARs.
Complies with action-, chemical-, and
location-specific ARARs.
Long-Term
Effectiveness and
Permanence
Low residual risk. Structural debris is
contained by capping or landfilling.
Adequate controls; long-term
monitoring is required. Habitat is
improved at site but limited at
landfill.
Low residual risk, Structural debris
is contained by consolidation or
landfilling. Adequate controls;
long-term monitoring is required.
Habitat is improved at site but
limited at landfill.
Low residual risk. Structural debris is
contained by landfilling. Adequate
controls; long-term monitoring is
required. Habitat is improved at site
but limited at landfill.
Reduction of
Toxicity, Mobility, or
Volume (TMV)
TMV Reduced. Capping or landfilling
reduces mobility. Reduction in
mobility may be reversed if cap or
landfill leaks. Caustic wash
irreversibly reduces TMV of agent,
but produces a hazardous liquid
sidestream that must be treated.
TMV Reduced, Consolidation or
landfilling reduces mobility.
Reduction in mobility reversed if
consolidation area or landfill leaks.
Caustic wash irreversibly reduces
TMV of agent, but produces a
hazardous liquid sidestream that
must be treated.
TMV Reduced. Landfilling reduces
mobility. Reduction in mobility may
be reversed if landfill leaks. Caustic
wash irreversibly reduces TMV of
agent, but produces a hazardous liquid
side-stream that must be treated.
Selected alternative
RMA ROD 6.96 jb
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Table 8.2-1 Comparative Analysis of Structures Alternatives
Page 2 of 2
Criteria
Alternative 1
Landfill/Cap in Place
Alternative 2
Landfill/Consolidate
Alternative 3
Landfill
Short-Term
Effectiveness
Effective. Dust controls needed for
demolition. Worker protection
necessary for physical hazards
associated with dismantling and for
chemical hazards associated with
caustic washing and handling agent-
contaminated debris. Habitat
improved at site, limited at disposal
areas. RAOs achieved in 3 to 4 years.
Effective. Dust controls needed for
demolition. Worker protection
necessary for physical hazards
associated Witt) dismantling and for
chemical hazards associated with
caustic washing and handling -.
agent-contaminated debris. Habitat
improved at site, limited at disposal
areas. RAOs achieved in 3 to 4
years. ,
Effective. Dust controls needed for
demolition. Worker protection
necessary for physical hazards
associated with dismantling and for
chemical hazards associated with
caustic washing and handling agent-
contaminated debris. Habitat improved
at site, limited at disposal areas. RAOs
achieved in 3 to 4 years.
Implementability
Technically and administratively
feasible. Regulatory concerns with
capping.
Technically and administratively ,
feasible.
Technically and administratively
feasible.
Present Worth
Costl
$106 million
$104 million
$109 million
Conclusion
Not selected. Meets evaluation
criteria and is consistent with soil
remedial alternatives. Not identified
as the preferred alternative due to
regulatory concerns over capping
debris from Other Contamination
History structures.
Selected. Meets evaluation criteria
and is consistent with soil remedial
alternatives.
Not selected. Meets evaluation criteria
and is consistent with soil remedial
alternatives. Not identified as the
preferred alternative because it is
less cost effective than Alternative 2.
Selected alternative
'These costs do not include $35 million in post ROD removal actions.
RMA ROD 6.96 jb
-------
Table 8.3-1
Criteria
Comparative Analysis
Alternative 1
Caps/Covers
of Soil Alternatives
Alternative 2
Landfill/Caps
Alternative 3
Landfill
Alternative 4
Consolidation/Caps/
Treatment/Landfill
Page 1 of 2
Alternative 5
I Caps/Treatment/
; Landfill
Overall Protection
of Human Health
and the Environment
Protective. Exposures to
humans and animals
prevented by containing
contaminated soil in
place.
Protective. Exposures to
humans and animals
prevented by con-
taining contaminated
soil in place.
Protective. Exposures to
humans and animals
prevented by containing .
contaminated soil in
place.
Protective. Exposures to
humans and animals '
prevented by containing
contaminated soil In
place and by treating •'
some of the principal
threat volume. - - •
Protective. Exposures to
humans and animals
prevented by containing
contaminated soil in
place and by treating
principal threat volume.
Compliance with
ARARs
Complies with action-,
chemical-, and location-
specific ARARs.
Complies with action-,
chemical-, and location-
specific ARARs.
Complies with action-,
chemical-, and location-
specific ARARs.
CowpWiM with action-, :
chemical-, and location-
specific ARARs.
Complies with action-,
chemical-, and location-
specific ARARs. More
difficult due to action-
specific ARARs
regarding treatment.
Long-Term
Effectiveness
and Permanence
Minimal residual risk.
Relies on caps and
groundwater controls to
prevent migration and
exposure.
Minimal residual risk.
Relies primarily on caps
and groundwater
controls, with some
landfilling, to prevent
migration and exposure.
Minimal residual risk.
Relies on landfilling,
with some caps and
groundwater controls
to prevent migration
and exposure.
Minimal residual risk.
Relies on treatment of
some highly , , ,
contaminated soil,.
groundwater .controls, '•'
and capping/landfilling
to prevent migration and
exposure. ';-<..
Minimal residual risk.
Relies on treatment of
- most of the highly
contaminated soil and
landfilling/capping to
prevent migration and
exposure.
Reduction of
Toxicity, Mobility,
or Volume (TMV)
TMV Reduced. Mobility
reduced through
containment; no toxicity
or volume reduction.
TMV Reduced. Mobility
reduced through
containment; no toxicity
or volume reduction.
TMV Reduced. Mobility
reduced through
containment; no toxicity
or volume reduction
some highly
contaminated soil -
reduced through
treatment; relies on
containment for most
mobility reduction.
; TMV Reduced. TMV
{ of the most highly
contaminated soil
i reduced through
, treatment; relies on
• containment for
; additional mobility
5 reduction.
Selected alternative
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Table 8.3-1 Comparative Analysis of Soil Alternatives
Page 2 of 2
Criteria
Short-Term
Effectiveness
Alternative 1
Caps/Covers
Effective. Minimal short-
term risk. No excavation
or potential releases.
Alternative 2
Landfill/Caps
Effective. Low short-
term risk. High-risk sites
not excavated; minimal
potential for releases.
Alternative 3
Landfill
Effective. Moderate
short-term risk. All
sites excavated and
transported with
high potential for
releases.
Alternative 4
Consolidation/Caps/
Treatment/Landfill -
Effective. Moderate
short-term risk. Some
high-risk sites
excavated and
transported; moderate
potential for releases.
X s >' '
<' i < ^
Alternative 5
. Caps/Treatment/
Landfill
Effective. Higher short-
t term risk. Most high-
risk sites excavated,
transported, and treated;
= large volumes of less
' contaminated soil
moved; high potential
for releases.
Implementability
Implementable. Easy to
construct caps on
schedule; short time to
complete.
Implementable. Easy to
construct caps and
landfill for soil with low
levels of contamination;
short time to complete.
Moderate
implementability.
Construction and
permitting of large
landfill for highly
contaminated material
may delay schedule.
Moderate . < -
implementabitity.
Construction and
permitting of large
landfill for highly
contaminated material
may delay schedule.
Difficult
implementability.
Construction and
permitting of large
landfill and thermal
treatment facility may
delay schedule.
Problems in excavation,
treatment, and emissions
control; longest time to
complete.
Present Worth Cost Total: $386 million
Total: $276 million
Total: $384 million
Total: $401 million
Total: $542 million
Conclusion
Not selected. Higher
long-term risks and no
substantial cost savings
compared to other
alternatives.
Not selected. Higher
long-term risk, although
low cost.
Not selected. High
short-term risks without
improving long-term
protection, which
ultimately relies on
containment.
Selected. Cost effective;
balances short-term
risks with higher long-
term protection.
Not selected. High cost,
short-term risks, and
difficult to implement.
Selected alternative
RMAROD6.96jb
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9.0 Identification of the Selected Remedy
9.0 Identification of the Selected Remedy
The selection of the preferred remedy for remediation of groundwater, structures, and soil for the On-Post
Operable Unit was based on the NCP evaluation criteria, which are described in Figure 8.0-1 and discussed
with respect to each of the alternatives evaluated in Sections 8.1 through 8.3. As a result of these evaluations,
the selected remedy for the On-Post Operable Unit consists of implementing Groundwater Alternative 4,
Structures Alternative 2, and Soil Alternative 4. These selected alternatives are described in detail in Section 7.
Remediation goals for the selected remedy satisfies the evaluation of statutory requirements under CERCLA as
described in Section 10.
9.1 Groundwater Alternative 4 - Boundary Systems/IRAs/lntercept Systems
The selected groundwater alternative is Alternative 4. This alternative includes operation of all existing
boundary systems and on-post groundwater IRA systems, installation of a new extraction and piping system,
and development of an extended monitoring program. The specific components of the alternative are as
follows:
• Operation of the three boundary systems, the NBCS, NWBCS, and ICS, continues. These systems
include extraction and recharge systems, slurry walls (NBCS and NWBCS) for hydraulic controls, and
carbon adsorption for removal of organics. The systems will be operated until shut-off criteria, as
described below, are met.
• Operation of existing on-post groundwater IRA systems continues. The Motor Pool and Rail Yard
IRA systems, which pipe water to ICS for treatment, will be shut down when shut-off criteria, as
described below, are met. The Basin F extraction system continues to extract water that is treated at the
Basin A Neck system and the Basin A Neck system continues to extract and treat water from Basin A
until shut-off criteria are met.
• A new extraction system will be installed in the Section 36 Bedrock Ridge area. Extracted water will
be piped to the Basin A Neck system for treatment (e.g., by air stripping or carbon adsorption).
• Water levels in Lake Ladora, Lake Mary, and Lower Derby Lake will be maintained to support aquatic
ecosystems. The biological health of the ecosystems will continue to be monitored.
Lake-level maintenance or other means of hydraulic containment or plume control will be used to
prevent South Plants plumes from migrating into the lakes at concentrations exceeding CBSGs in
groundwater at the point of discharge. Groundwater monitoring will be used to demonstrate
compliance.
• Confined aquifer wells are monitored in the South Plants, Basin A, and Basin F areas. Specific
monitoring wells will be selected during remedial design.
• Those monitoring wells installed in the confined aquifer that may represent pathways for migration
from the unconfined aquifer (approximately 30-40 wells) are closed and sealed; replacement wells
will be installed if the Parties jointly determine that specific wells to be closed are necessary for future
monitoring.
• Chloride and sulfate are expected to attenuate naturally to the CSRGs.
• Monitoring and assessment of NDMA contamination will be performed in support of design
refinement/design characterization to achieve remediation goals specified for the boundary
groundwater treatment systems.
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Record of Decision for the On-Post Operable Unit
CSRGs were established for each containment/treatment system on the basis of ARARs and health-based
criteria. The ARAR-based values were either Colorado Basic Standards for Groundwater (CBSGs), federal
maximum contaminant levels (MCLs), or non-zero maximum contaminant level goals (MCLGs). The health-
based values are to-be-considered criteria (TBCs) and were based on EPA health advisories and/or EPA
Integrated Risk Information System database criteria. All of the boundary CSRGs are consistent with those
derived for the ROD for the Off-Post Operable Unit (Harding Lawson Associates 1995). CSRGs were
developed for each of the existing boundary and IRA systems, depending on the specific contaminants found
upgradient of each system and whether the systems were on post or at the boundary. Tables 9.1-1,9.1-2,9.1-3,
and 9.1-4 present the CSRGs for the three boundary systems, and the Basin A Neck system. Where the CSRG
is below the detection limit, the detection limit is listed next to the CSRG. Except where technically
impractical, the detection limit is less than the CSRG.
Criteria for shutting down boundary systems and internal systems have also been developed and are provided as
follows:
• Existing wells within the boundary and off-post containment systems can be removed from production
when concentrations of constituents detected in the well are less than the ARARs listed in Appendix A
and/or it can be demonstrated that discontinuing operation of a well would not jeopardize the
containment objective of the systems as identified by the remediation goals described above and the
CSRGs listed in Tables 9.1-1, 9.1-2, and 9.1-3. Wells removed from production and monitoring wells
upgradient and downgradient of the boundary and off-post containment systems will be monitored
quarterly for a period of 5 years to determine whether contaminants have reappeared; however, those
wells turned off for hydraulic purposes will not be subject to the quarterly monitoring requirements.
Boundary and off-post containment system extraction wells removed from production for water-
quality reasons will be placed back into production if contaminant concentrations exceed ARARs.
Wells with concentrations less than ARARs can remain in production if additional hydraulic control is
required.
• Existing wells within the internal containment systems can be removed from production when
concentrations of constituents detected in the wells are less than ARARs listed in Appendix A and/or it
can be demonstrated that discontinuing operation of a well would not jeopardize the containment
objective of the systems as identified by the CSRGs listed in Table 9.1-4. Wells removed from
production and monitoring wells upgradient and downgradient of the internal containment systems
will be monitored quarterly for a period of 5 years to determine whether contaminants have
reappeared; however, those wells turned off for hydraulic purposes will not be subject to the quarterly
monitoring requirements. Internal containment system extraction wells removed from production for
water-quality reasons will be placed back into production if contaminant concentrations exceed
ARARs. Wells with concentrations less than ARARs can remain in production if additional hydraulic
control is required.
• Shell and the Army will operate the ICS for 2 years or until the Rail Yard/Motor Pool plumes no
longer require containment at the ICS.
Figure 9.1-1 illustrates the selected alternative. Additional detail on this alternative is provided in the Detailed
Analysis of Alternatives report.
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9.0 Identification of the Selected Remedy
9.2 Structures Alternative 2 - Landfill/Consolidate
Structures Alternative 2 is the selected alternative for the structures medium. This alternative applies to all No
Future Use structures, i.e., structures in the Other Contamination History, Significant Contamination History,
and Agent History Groups. Under this alternative, the following activities will occur:
• All No Future Use structures will be demolished.
• Agent History structures will be monitored for the presence of Army chemical agent, and treated by
caustic washing as necessary prior to disposal.
• Both Agent History and Significant Contamination History Group structural debris will be disposed in
the on-site hazardous waste landfill.
• Other Contamination History Group structural debris will be used as grade fill in Basin A, which will
subsequently be covered as part of the soil remediation.
• Structural assessments and review of ACM and PCB contamination status and disposition of ACM or
PCB-contaminated materials will be performed as described in Section 7.3.3.
• Process-related equipment not remediated as part of the Chemical Process-Related Activities IRA will
be disposed in the on-post hazardous waste landfill.
An inventory of structures in each medium group is presented in Tables 5.4-6, 5.4-7, 5.4-8, and 5.4-9.
Refinement of the Future Use structures inventory will be completed during remedial design. Most of the
demolition at RMA will consist of dismantling with standard dust-suppression measures Remediation goals
and standards have been identified for each medium group (see Table 9.5-1). The Other Contamination History
Group structural debris is disposed by consolidation in Basin A. This procedure includes transporting the
debris to the consolidation area and using it as a portion of the gradefill required by the soil remediation. When
the consolidation area has been regraded, it will be covered as part of the soil remediation. Significant
Contamination History Group and Agent Contamination History Group structural debris is disposed in the on-
post hazardous waste landfill. The slabs and foundations of structures located in the South Plants Central
Processing Area within principal threat or human health soil exceedance excavation areas are removed to a
depth of 5 ft. In most cases, floor slabs and foundations for the Other Contamination History and Significant
Contamination History Groups are left behind after demolition (unless contaminated soil is to be excavated
from beneath the slabs or foundations). Floor slabs are broken to prevent water ponding. Additional detail on
this alternative is provided in the Detailed Analysis of Alternatives Report.
9.3 Soil Alternative 4 - Consolidation/Caps/Treatment/Landfill
The selected soil alternative is Alternative 4. This alternative includes consolidation of 1.5 million BCY of soil
with low levels of contamination into Basins A and F and the South Plants Central Processing Area; capping or
soil cover of contaminated soil in the Basins, South Plants, North Plants, and Section 36 sites (including Shell
and Complex Trenches); treatment (primarily by in situ solidification/stabilization) of 207,000 BCY of
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principal threat soil; and on-post landfilling of 1.7 million cubic yards of soil and debris, including the Basin F
Wastepile. The specific components of this alternative are listed below and are summarized in Table 9.3-1:
• On-Post Hazardous Waste Landfill - Construction of a RCRA- and TSCA-compliant hazardous waste
landfill on post.
• Former Basin F - Treatment of approximately 180,000 BCY of principal threat soil in the Former
Basin F to a depth of 10 ft (measured from below the base of the overburden) using in situ solidifica-
tion/stabilization to reduce the mobility of the contaminants and minimize further contamination of
groundwater. The mixture of solidification agents will be determined during remedial design by treat-
ability testing. This treatability testing will be used to verify the effectiveness of the treatment process
and establish operating parameters for the design of the full-scale operation. The entire site is capped
(including the Basin F Wastepile footprint) with a RCRA-equivalent cap that includes a biota barrier.
• Basin F Wastepile - Excavation of approximately 600,000 BCY of principal threat soil and liner
materials from the wastepile and containment in dedicated triple-lined landfill cells at the on-post
hazardous waste landfill facility. Excavation is conducted using vapor- and odor-suppression
measures as necessary. If the wastepile soil fails EPA's paint filter test, the moisture content of the
soil will be reduced to acceptable levels by using a dryer in an enclosed structure. Any volatile
organics (and possibly some semivolatile organics) released from the soil during the drying process are
captured and treated; however, the main objective of this process is drying. Prior to excavation of the
wastepile, overburden from the existing cover is removed and set aside. The excavation area is
backfilled with on-post borrow material and stockpiled overburden.
• Basin A - Construction of a soil cover consisting of a 6-inch-thick layer of concrete and a 4-ft-thick
soil/vegetation layer over the principal threat and human health exceedance soil and soil posing a
potential risk to biota, and consolidation of debris and soil posing a potential risk to biota and
structural debris from other sites. No RCRA-listed or RCRA-characteristic waste from outside the
AOC will be placed in Basin A. Any UXO encountered will be removed and transported off post for
detonation (unless the UXO is unstable and must be detonated on post) or other demilitarization
process.
• South Plants Central Processing Area - Excavation and landfill of principal threat and human health
exceedance soil to a depth of 5 ft and caustic washing and landfill of any agent-contaminated soil
found during monitoring. Backfill excavation and placement of a soil cover consisting of a 1-ft-thick
biota barrier and a 4-ft-thick soil/vegetation layer over the entire site to contain the remaining human
health exceedance soil and soil posing a potential risk to biota. Soil posing a potential risk to biota
from other portions of South Plants may be used as backfill and/or gradefill prior to placement of the
soil cover.
• South Plants Ditches - Excavation and landfill of principal threat and human health exceedance soil.
Excavation of soil posing a potential risk to biota and consolidation under the South Plants Central
Processing Area soil cover. Backfill excavated area with on-post borrow material. These sites are
contained under the South Plants Balance of Areas soil cover.
• South Plants Balance of Areas - Excavation (maximum depth of 10 ft) and landfill of principal threat
and human health exceedance soil and caustic washing and landfill of any agent-contaminated soil
found during monitoring. Any UXO encountered will be excavated and transported off post for
detonation (unless the UXO is unstable and must be detonated on post) or other demilitarization
process. Excavation of soil posing a potential risk to biota and consolidation as backfill and/or
gradefill under the South Plants Central Processing Area soil cover and/or for use as backfill for
excavated areas within this medium group. The former human health exceedance area is covered with
a 3-ft-thick soil cover and the former potential risk to biota area is covered with a 1-ft-thick soil cover.
Prior to placing this cover, two composite samples per acre will be collected to verify that the soil
under the 1-ft-thick soil cover does not exceed human health or principal threat criteria. If the residual
soil is found to exceed these levels, the 3-ft-thick cover will be extended over these areas or the
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9.0 Identification of the Selected Remedy
exceedance soil will be excavated and landfilled. The top 1 ft of the entire soil cover area will be
constructed using soil from the on-post borrow areas.
• Section 36 Balance of Areas - Excavation and landfill of human health exceedance soil and UXO
debris and excavation and consolidation to Basin A of soil posing a potential risk to biota. The
consolidated material is contained under the Basin A cover and the human health excavation area is
backfilled with on-post borrow material. Prior to excavation, a geophysical survey is conducted to
locate potential UXO. Any UXO encountered will be excavated and transported off post for
detonation (unless the UXO is unstable and must be detonated on post) or other demilitarization
process. Caustic washing and landfill of any agent-contaminated soil found during monitoring. The
former human health exceedance area is covered with a 2-ft-thick soil cover and the former potential
risk to biota area is covered with a 1-ft-thick soil cover.
• Secondary Basins - Excavation and landfill of human health exceedance soil. The excavated area is
backfilled with on-post borrow material. A 2-ft-thick soil cover is placed over the entire area of
Basins B, C, and D, including the potential biota risk area.
• Complex Trenches - Construction of a RCRA-equivalent cap, including a 6-inch-thick layer of
concrete, over the entire site. Installation of a slurry wall into competent bedrock around the disposal
trenches. Dewatering within the slurry wall is assumed for purposes of conceptual design and will be
reevaluated during remedial design. Soil excavated for the slurry wall trench is graded over the
surface of the site and is contained under the cap. Prior to installing the slurry wall and cap, a
geophysical survey is conducted to locate potential UXO within construction areas. Any UXO
encountered will be removed and transported off post for detonation (unless the UXO is unstable and
must be detonated on post) or other demilitarization process.
• Shell Trenches - Modification of the existing soil cover to be a RCRA-equivalent cap with a biota
barrier. Expansion of the existing slurry wall around the trenches. Dewatering within the slurry wall
is assumed for purposes of conceptual design and will be re-evaluated during remedial design. Soil
excavated for the slurry wall trench is graded over the surface of the site and is contained under the
cap.
• Hex Pit - Treatment of approximately 1,000 BCY of principal threat material using an innovative
thermal technology. The remaining 2,300 BCY are excavated and disposed in the on-post hazardous
waste landfill. Remediation activities are conducted using vapor- and odor-suppression measures as
required. Treatability testing will be performed during remedial design to verify the effectiveness of
the innovative thermal process and establish operating parameters for the design of the full-scale
operation. The innovative thermal technology must meet the treatability study technology evaluation
criteria described in the dispute resolution agreement (PMRMA 1996). Solidification/stabilization will
become the selected remedy if all evaluation criteria for the innovative thermal technology are not met.
Treatability testing for solidification will be performed to verify the effectiveness of the solidification
process and determine appropriate solidification/stabilization agents. Treatability testing and
technology evaluation will be conducted in accordance with EPA guidance (OSWER-EPA 1989a) and
EPA's "Guide for Conducting Treatability Studies under CERCLA" (1992).
• Section 36 Lime Basins - Excavation and containment of principal threat and human health
exceedance soil in a triple-lined landfill cell at the on-post hazardous waste landfill facility. Prior to
excavation of exceedance soil, overburden from the existing cover is removed and set aside. The
excavated area is backfilled with clean borrow and the soil cover is repaired. Caustic washing and
landfill of any agent-contaminated soil found during monitoring.
• Buried M-l Pits - Approximately 26,000 BCY of principal threat and human health exceedance soil is
treated by solidification/stabilization and then landfilled. The mixture of solidification/stabilization
agents will be determined during remedial design by treatability testing. This treatability testing will
be used to verify the effectiveness of the treatment process and establish operating parameters for the
design of the full-scale operation. Excavation is conducted using vapor- and odor-suppression
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Record of Decision for the On-Post Operable Unit
measures. Caustic washing and landfill of any agent-contaminated soil found during monitoring. The
excavated area is backfilled with clean borrow.
• Burial Trenches - UXO in these sites is located using a geophysical survey, excavated, and transported
off post for detonation (unless the UXO is unstable and must be detonated on post) or other
demilitarization process. Excavation and landfill of human health exceedance soil and backfill with
on-post borrow material. Caustic washing and landfill of any agent-contaminated soil found during
monitoring. Removal and landfill of munitions debris and nearby soil in excess of TCLP.
• Chemical Sewers - For sewers located within the South Plants Central Processing Area and Complex
Trenches area, the sewer void space is plugged with a concrete mixture to prohibit access to these lines
and eliminate them as a potential migration pathway for contaminated groundwater. The plugged
sewers are contained beneath the soil cover or cap in their respective sites. For sewers located outside
the South Plants Central Processing Area and Complex Trenches areas, sewer lines and principal threat
and human health exceedance soil are excavated and landfilled. Any agent-contaminated soil found
during monitoring is caustic washed and landfilled. Prior to excavation of exceedance soil,
overburden is removed and set aside. The excavated area is backfilled with on-post borrow material
and the overburden replaced.
• Sanitary/Process Water Sewers - Void space inside sewer manholes is plugged with a concrete
mixture to prohibit access and eliminate the manholes as a potential migration pathway for
contaminated groundwater. Aboveground warning signs are posted every 1,000 ft along the sewer
lines to indicate their location underground.
• North Plants - Excavation and landfill of human health exceedance soil. Any agent-contaminated soil
found during monitoring is caustic washed and landfilled. The excavated area is backfilled with on-
post borrow material. A 2-ft-thick soil cover is placed over the soil posing a potential risk to biota and
the footprint of the North Plants processing area.
• Toxic Storage Yards - Excavation and landfill of human health exceedance soil. Any agent-
contaminated soil found during monitoring is caustic washed and landfilled. The excavated area is
backfilled with on-post borrow material. The New Toxic Storage Yards are used as a borrow area for
both low-permeability soil and structural fill.
• Munitions Testing - UXO in these sites is located using a geophysical survey, excavated, and
transported off post for detonation (unless the UXO is unstable and must be detonated on post) or
other demilitarization process. Removal and landfill of munitions debris and nearby soil in excess of
TCLP.
• Lake Sediments - Excavation and landfill of human health exceedance soil and excavation and
consolidation of soil posing risk to biota from Upper Derby Lake to Basin A. The excavated human
health exceedance area is backfilled with on-post borrow material and the consolidated material is
contained under the Basin A cover. Aquatic sediments are left in place and the area is monitored to
ensure that the sediments continue to pose no unacceptable risk to aquatic biota.
• Ditches/Drainage Areas - Excavation and consolidation to Basin A of soil posing a potential risk to
biota. The consolidated material is contained under the Basin A cover. The excavated area is
backfilled with on-post borrow material.
• Sanitary Landfills - Excavation and landfill of human health exceedance soil and excavation and
consolidation to Basin A of landfill debris and soil posing a potential risk to biota. The consolidated
material is contained under the Basin A cover. The excavated area is backfilled with on-post borrow
material.
• Buried Sediments - Excavation and landfill of human health exceedance soil. The excavated area is
backfilled with on-post borrow material.
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9.0 Identification of the Selected Remedy
• Sand Creek Lateral - Excavation and landfill of human health exceedance soil and excavation and
consolidation to Basin A of soil posing a potential risk to biota. The consolidated material is contained
under the Basin A cover. The excavated area is backfilled with on-post borrow material.
• Surficial Soil - Excavation and landfill of human health exceedance soil and excavation and
consolidation to Basin A or Former Basin F of soil posing a potential risk to biota from this medium
group and excavation and landfill of soil from the pistol and rifle ranges. The consolidated material is
contained under the Basin A cover or Basin F cap, and the human health exceedance area is backfilled.
• Excavation and disposal in the on-post TSCA-compliant landfill of PCB-contaminated soil (three areas
identified by the PCB IRA with concentrations of 250 ppm or greater). Soil identified with
concentrations ranging from SO to 250 ppm will be covered with at least 3 ft of soil (five areas
identified by the PCB IRA).
• Contingent Volume - Excavation and landfill of up to 150,000 BCY of additional volume to be
identified based on visual field observations. An additional 14 samples from North Plants, Toxic
Storage Yards, Lake Sediments, Sand Creek Lateral, and Burial Trenches and up to 1,000 additional
confirmatory samples may be used to identify the contingent soil volume requiring excavation.
• Remedy components for all sites include reconditioning the surface soil and revegetating areas
disturbed during remediation with locally adapted perennial vegetation.
Exceedance volumes for all medium groups are listed in Table 7.1-5. For sites with excavation as part of the
selected remedy, the exceedance volume is considered the volume to be excavated and no confirmatory
sampling will occur during implementation, other than to identify contingent volume.
Additional detail on this alternative is provided in the Detailed Analysis of Alternatives report. Figure 9.3-1
shows the selected sitewide soil remedy; Figures 9.3-2, 9.3-3, and 9.3-4 show the major excavation areas and
cap or cover components of the selected soil remedy; and Figure 9.3-5 shows the areas where exceedance
volumes are left in place and the type of containment systems used in those areas following implementation of
the selected remedy. Tables 9.3-2 and 9.3-3 show the disposition of exceedance volumes and Table 9.3-4
details the capped/covered areas for the selected soil remedy. A process will be presented in future
implementation documents that will allow for independent confirmation that volumes (defined spatially) are
removed. The process will allow for verification by the state or EPA during remedial action.
9.4 Additional Components of the Selected Remedy
The Army, Shell, EPA, USFWS, and state of Colorado have agreed to several additional components that will
be included in the overall on-post remedy. These components have been considered in the selection of the
preferred alternatives and are as follows:
• Provision of $48.8 million held in trust to provide for the acquisition and delivery of 4,000 acre-feet of
potable water to SACWSD and the extension of the water-distribution lines from an appropriate water
supply distribution system to all existing well owners within the DIMP plume footprint north of RMA
as defined by the detection limit for DIMP of 0.392 parts per billion (ppb). In the future, owners of
any domestic wells, new or existing, found to have DIMP concentrations of 8 ppb (or other relevant
CBSG at the time) or greater will be connected to a water-distribution system or provided a deep well
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or other permanent solution. The Army and Shell have reached an Agreement in Principle with
SACWSD, enclosed as Appendix B of this ROD, regarding this matter.
• In compliance with NEPA, PMRMA will separately evaluate the potential impacts to the environment
of both the acquisition of a water supply for SACWSD and for extension of water-distribution lines.
• The Army and Shell will fund ATSDR to conduct an RMA Medical Monitoring Program in
coordination with CDPHE. The program's nature and scope will include baseline health assessments
and be determined by the on-post monitoring of remedial activities to identify exposure pathways, if
any, to any off-post community.
A Medical Monitoring Advisory Group (MMAG) has been formed to evaluate information concerning
exposure pathways and identify and recommend appropriate public health actions to CDPHE and
ATSDR and to communicate this information to the community. CDPHE and ATSDR will use the
recommendations of the MMAG to jointly develop an appropriate medical monitoring plan and jointly
define the trigger for when such a plan will take effect. Any human health assessment completed by
CDPHE and ATSDR will be formally reviewed by the Parties and the MMAG prior to issuance to the
public. The MMAG includes representatives from the affected communities, regulatory agencies, local
governments, Army, Shell, USFWS, and independent technical advisors. Any necessary technical
advisors will be identified in coordination with CDPHE and funded through ATSDR.
The primary goals of the Medical Monitoring Program are to monitor any off-post impact on human
health due to the remediation and provide mechanisms for evaluation of human health on an individual
and community basis, until such time as the soil remedy is completed. On behalf of the communities
surrounding RMA, the MMAG will develop and submit to CDPHE and ATSDR specific
recommendations defining goals, objectives, and the methodology of a program designed to respond
effectively to RMA-related health concerns of the community.
Elements of the program could include medical monitoring, environmental monitoring,
health/community education or other tools. The program design will be determined through an
analysis of community needs, feasibility, and effectiveness.
• Trust Fund - During the formulation and selection of the remedy, members of the public and some
local governmental organizations expressed keen interest in the creation of a Trust Fund to help ensure
the long-term operation and maintenance of the remedy once the remedial structures and systems are
installed. In response to this interest, the Parties have committed to good-faith best efforts to establish
a Trust Fund for the operation and maintenance of the remedy, including habitat and surficial soil.
Such operation and maintenance activities will include those related to the new hazardous waste
landfill; the slurry walls, caps, and soil and concrete covers; all existing groundwater pump-and-treat
systems; the groundwater pump-and-treat system to intercept the Section 36 Bedrock Ridge Plume; the
maintenance of lake levels or other means of hydraulic containment; all monitoring activities required
for the remedy; design refinement for on-post surficial soil as described in Section 9.4; and any
revegetation and habitat restoration required as a result of remediation.
These activities are estimated to cost approximately $5 million per year (in 1995 dollars). The
principal and interest from the Trust Fund would be used to cover these costs throughout the lifetime
of remedial program.
The Parties recognize that establishment of such a Trust Fund may require special legislation and that
there are restrictions on the actions federal agencies can take with respect to proposing legislation and
supporting proposed legislation. In addition to the legislative approach, the Parties are also examining
possible options that may be adapted from trust funds involving federal funds that exist at other
remediation sites. Because of the uncertainty of possible legislative requirements and other options, the
precise terms of the Trust Fund cannot now be stated.
A trust fund group will be formed to develop a strategy to establish the Trust Fund. The strategy
group may include representatives of the Parties (subject to restrictions on federal agency
FOSTER 0 WHEELER
9-8 FOOTDIWHEEIEN ENVIRONMENTAL CORPORATION nna\1493G.DOC
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9.0 Identification of the Selected Remedy
participation), local governments, affected communities, and other interested stakeholders, and will be
convened within 90 days of the signing of the ROD.
Notwithstanding these uncertainties, it is the intent of the Parties that if the Trust Fund is created it will
include the following:
- A clear statement that will contain the reasons for the creation of the Trust Fund and the purposes
to be served by it.
- A definite time for establishing and funding the Trust Fund, which the Parties believe could occur
as early as 2008, when the remedial structures and systems may have been installed.
- An appropriate means for competent and reliable management of the Trust Fund, including
appropriate criteria for disbursements from the Trust Fund to ensure that the money will be
properly used for the required purposes.
• Continued operation of the CERCLA Wastewater Treatment Plant to support the remediation
activities.
• Stored, drummed waste identified in the waste management element of the CERCLA Hazardous
Waste IRA may be disposed in the on-post hazardous waste landfill in accordance with the CDD
(Harding Lawson Associates 1996).
• Continued monitoring, as part of design refinement, for areas that may pose a potential risk to biota as
outlined in the following process:
- The BAS of technical experts (such as ecotoxicologists, biologists, and range/reclamation
specialists) from the Parties will focus on the planning and conduct of both the USFWS
biomonitoring programs and the SFS/risk assessment process. The BAS will provide
interpretation of results and recommendations for design refinements to the Parties' decision
makers.
- The ongoing USFWS biomonitoring programs and the SFS/risk assessment process will be used
to refine design boundaries for surficial soil and aquatic contamination to be remediated.
- Phase I and the potential Phase II of the SFS will be used to refine the general areas of surficial
soil contamination concern. The field BMFs will be used to quantify ecological risks in the Area
of Dispute, identify risk-based soil concentrations considered safe for biota, and thus refine the
area of excess risks (Figure 6.2-6).
- Pursuant to the FFA process, USFWS will conduct detailed site-specific exposure studies of
contaminant effects and exposure (tissue levels and Army-provided abiotic sampling) on
sentinel or indicator species of biota (including the six key species identified in the IEA/RC
report as appropriate). These studies will address both the aquatic resources and at least the
surficial soil in and around the Area of Dispute. These site-specific studies will be used in
refining contamination impact areas in need of further remediation.
- Results from both the SFS/risk assessment process and the site-specific studies will be
considered in risk-management decisions, which may further refine the areas of surficial soil and
aquatic contamination to be remediated. (In the event of a conflict between management of
RMA as a wildlife refuge and performance of remedial response actions, the Rocky Mountain
Arsenal National Wildlife Refuge Act indicates that response actions will take priority.)
- The BAS will serve as a technical resource to the Parties' decision makers by using technical
expertise in analyzing, and potentially collecting, data sufficient to support design refinement for
surficial soil areas and aquatic resources that will break unacceptable exposure pathways in
consideration of minimizing habitat disturbance. Further, it will assess through monitoring the
efficacy of remedies in breaking unacceptable pathways to biota. If any additional sites are
identified, the remedy will be implemented as follows:
FOSTER © WHEELER
imaM 493G.DOC FOtTER WHEELER ENVIRONMENTAL CORPORATION 9-9
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Record of Decision for the On-Post Operable Unit
- It will be staged to allow habitat recovery.
- It will be performed first on locations selected through a balance of factors such as:
- The Parties agree an area has a negative impact on or excessive risk to fish or wildlife.
- The effort will not be negated by recontamination from other remediation activities.
- The existing fish and wildlife resource value.
- It will include revegetation of a type specified by USFWS; if the initial revegetation is not
successful, the appropriate adjustments will be made and revegetation again implemented.
- It will provide that the locations and timing of remediation are to be determined with
consideration of and in coordination with USFWS refuge management plans and activities.
- The SFS, biomonitoring programs, and recommendations of the BAS will be used to refine the
areas of remediation during remedial design.
• Any UXO encountered during remediation will be excavated and transported off post for detonation
(unless the UXO is unstable and must be detonated on post) or other demilitarization process.
• Within 180 days after issuance of the Notice of Availability for the ROD, the Army will append to the
ROD a complete, detailed schedule for completion of activities associated with the selected remedy.
The schedule will identify the enforceable project milestone dates for design activities. Future design
documents will detail milestone dates for implementation activities. Revisions to this schedule will be
initiated prior to the start of each fiscal year to allow adequate time for review and concurrence by the
Parties.
9.5 Remediation Goals and Standards
The treatment components of the selected groundwater remedy will meet the CSRGs presented in Tables 9.1-1
through 9.1-4, and the components of the selected soil and structures remedy will meet the remediation goals
and standards presented in Table 9.5-1. The selected remedies will comply with the performance standards as
provided in Appendix A (ARARs).
9.6 Cost of the Selected Remedy
The total estimated cost (in 1995 dollars) for the selected remedy is $2.2 billion (present worth $1.8 billion).
Table 9.6-1 presents the capital and O&M costs for the selected alternatives. The time required for
implementation is approximately 17 years, with groundwater system operations continuing for at least 30 years.
The implementation of the remedy could be accelerated if funding is available that exceeds $100 million/year.
9.7 Long-Term Operations
Long-term operations are those ongoing activities that will be performed after the initial remediation work is
completed and that will continue after EPA releases the site to USFWS as a wildlife refuge. These include
monitoring and maintaining containment systems, such as the caps and the landfill, and continuing the
operation of groundwater treatment systems.
FOSTER 0 WHEELER
9-10 IQSTER WHEELEM ENVIRONMENTAL CORPORATION nna\1493G.DOC
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9.0 Identification of the Selected Remedy
Soil sites where covers or caps are constructed will be inspected on a regular basis, and damage to the
vegetative cover or any eroded soil will be repaired. Long-term management also includes access restrictions
to capped and covered areas to ensure the integrity of the containment systems. Where human health
exceedances are left in place at soil sites, groundwater will be monitored, as necessary, to evaluate the
effectiveness of the remedy. The on-site hazardous waste landfill will be closed and monitored according to
RCRA and TSCA requirements. Long-term activities at this facility will include leachate collection and
disposal, regular cover inspections with repair of vegetative cover damage or erosion, and sampling of
upgradient and downgradient wells to monitor for migration of landfill contaminants into the groundwater.
Monitoring activities for biota will continue by USFWS in support of evaluating the effectiveness of the
selected remedy.
Long-term activities for the water medium include continued operation of the NWBCS, NBCS, ICS, the Basin
A Neck and North of Basin F Groundwater IRA systems, and the new Section 36 Bedrock Ridge groundwater
Extraction System. Operation of wells within these systems may be discontinued according to the shutdown
criteria listed in Section 9.1. Maintenance of lake levels and groundwater monitoring will be continued as
described in Section 9.1.
A network of monitoring wells will be sampled to evaluate the effectiveness of the remedy. A select number of
deep wells will also be sampled to monitor any contamination in the confined aquifer. Surface water will be
monitored and managed in a manner consistent with the selected remedy.
There are no long-term activities directly associated with the structures medium groups as all potentially
contaminated structures will be demolished and the structural debris placed into the on-post hazardous waste
landfill or used as fill under the Basin A cover. These sites will be monitored and maintained as described
above.
Technical working groups or subcommittees will combine their efforts to evaluate the effectiveness of the
remedy and make recommendations to the Parties' decision makers. In addition, site reviews will be conducted
at least every 5 years (following the signing of the ROD) for all sites where contaminants that exceed
remediation goals are left in place. The effectiveness of containment remedies will be evaluated to determine
what additional remedial actions may be required if containment is found to be inadequate. In the event other
contaminants not included as COCs are identified as a concern (e.g., dioxin) during or after design or
implementation, an evaluation will be conducted as required by EPA guidance (OSWER-EPA 1989a) to ensure
that the remedial action is protective of human health and the environment. At a minimum, evaluations will be
part of the 5-year site review.
FOSTER ® WHEELER
nna\1493G.DOC FOSTER WHEELER ENVIRONMENTAL CORPORATION 9-11
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Record of Decision for the On-Post Operable Unit
FOSTER ® WHEELER
FOSTER WHEELER ENVIRONMENTAL CORPORATION
-------
f
£
.. .. „ .
North Boundary
illiiilllllllWlff Containment System
Northwest Boundary i
Containment System !
Irondale
Containment
System
• Section 36 Bedrock
Ridge Extraction System
Army Complex Trench
Slurry Walls and
Dewatering Wells
CERCLA Wastewater
Treatment Facility
Motor Pool and
Roil Yard Plume
I
i
LEGEND
Boundary System
Treatment System
Existing IRA
Slurry Wall
Groundwater extraction well
Capped/Covered Area
North Boundary Plume Group
Basins C and F Plume
North Plants Plum*
Northwest Boundary Plume Group
(Outlined In blue: )
Basin A Neck Plume
Sand Creek Lateral Plume*
Western Plume Group
Western Plume
(Outlined in yellow: )
Motor Pool Plume
Rail Yard Plume
Basin A Plume Group
South Plants North Plume
Basin A Plume
Section 36 Bedrock Ridge Plume
South Plants Plume Group
South Plants North Source Plume
South Plants Southeast Plume
South Plants Southwest Plume
South Tank Farm Plume
Colored portions of plumes Indicate summed
total organic concentrations above 100 ug/l.
omcji of m« frof
FIGURE ».1-I
MtomaUM 4: Con*
•d DM
A wK
itfan of I
BouvMry Syitera and »VU ond Extrorttoo'tam
Section M Bxkmfc Map
by:
Fort*- WhMMr Ehvtanraftol Cofporatfen
-------
-N-
RMA Boundary
SAR Site Boundary1
In-sltu Solidification of Principal
Threat Volume; RCRA-Equivalent Cap
RCRA—Equivalent Caps
Direct Solidification/Stabilization
Innovative Thermal Treatment
(Hex Pit)
Basin A Consolidation Area
Landfill Human Health Soil?
Consolidation of Biota Soil
Landfill Human Health Soil3
Landfill Site
Soli Covers
Agent Screening Area
(Caustic wash/landfill)
UXO Screening Area
(Detonation/landfill)
Surflclal Soil Consolidation
Access Restrictions
Section Number
1 Study Area Report (see Remedial
Investigation Summary Report, Ebosco 1992a
JPebrls from the Sanitary Landfills
Medium Group will be consolidated.
3Wasteplle material will be dried prior to
landflmng, If necessary, to pass EPA
point filter test.
1500 0 1500 MOOFeol
Prepared for: U.S. Army Program Manager for
Rocky Mountain Arsenal
Figure 9.3-1
Selected Soil Remedy
Consolidation/Caps/Treafment/Landfill
Foster Wheeler Environmental Corporation
June 1996
-------
Legend
!v.v] Former Basin F Solidification Area
RCRA-Equivotent Cap
n Human Health and Principal
Threat Excavation Area
|j Biota Excavation Area
.'. ,| Basin F Wastepile Excavation
X] 2-Foot Soil Cover Area
SAP, Site Boundary
(Study Area Report: Bee
Remedial Investigation Summary
Report. Ebasco 1992o.)
Section Number I
Section Une H
Drainage
Road
Railroad
t=2
Scale In Feet
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arsenal
Prepared June 1996
Figure 9.3-2
Section 26 Excavation Areas and
Cap/Cover Components
Rocky Mountain Arsenal
Prepared by: Foster Wheeler Environmental Corp,
-------
Legend
Basin A Consolidation Area with
fr"M 4-Foot Soil Cover/6-lnch Concrete Layer
RCRA—Equivalent Caps
D Human Health and Principal
Threat Excavation Area
|£/1 Biota Excavation Area
2-Foot Soil Cover Area
1-Foot Soil Cover Area
31
SAR Site Boundary
(Study Area Report; see
Remedial Investigation Summary
Report. Ebasco 1992a.)
Section Number
Section Line
Drainage
Rood
Railroad
Seal* In Feet
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arsenal
Prepared June 1996
Figure 9.3-3
Section 36 Excavation Areas and
Cap/Cover Components
Rocky Mountain Arsenal
Prepared by: Foster Wheeler Environmental Corp.
-------
£
£
Leoend
Human Health am) Principal
Threat Excavation Area
Biota Excavation Area
South Plant* Central Processing Area Cover
(4—foot soil cover with biota barrier)
3-Foot Soil Cover Area
1—Foot Soil Cover Area
SAR Site Boundary
(Study Area Report; see
Remedial Investigation Summary
Report, Ebaseo 1992o.)
Section Number
Section Line
Drainage
Road
Railroad
»
$
Seal* In FMt
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arsenal
Prepared June 1996
Rgure 9.3—4
South Plants Excavation Areas and
Cover Components
Rocky Mountain Arsenal
Prepared by. Foster Wheeler Environmental Corp
-------
_TL
22
'88
33
27
34
10
35
^B-,^
'.';> L LAKE I.
P4
NORTH PLANTS
25,
J_
12
19
30
31
32
Principal Inniat EncMdonc* Ana
Human HMRh BuaxtanM M*a1
Bfote 6xe»«»anc« ATM
RCMA.-Egulval«lt Cap2
Soi Cow2' 3
S*eaon Numbw
SteUan Un*
31
eapi and Bo»lr) A and South
Pkxrtt Cantral PrecMdng ATM M) conn
Inelud* a bMn-Mnnfen knw.
Sol oom* vary In thlrliiim fram I to 4 n.
K! in South Plant. Ombal
d«pth of «xeovoUon.
I
i
Scato in F««t
Prepared for
U.S. Army Program Manager
for Rocky Mountain Arsenal
Prepared June 1996
Figure 9.3-5
Containment Systems for Exceedances
Remaining in Place following Remediation
Rocky Mountain ArMnal
Prepared by: Foster Wheeler Environmental Corp
-------
Table 9.1-1 CSRGs for the Northwest Boundary Containment System Page 1 of 1
Containment System
Remediation Goals
Chemical Group/Compound (Hg/0
VHOs (Volatile Halogenated Organics)
Trichloroethylene 3'
Chloroform 62
OPHBGs (Organophosphorous Compounds; Isopropylmethyl Phosphonofluoridate (GB) Agent Related)
DIMP (Diisopropylmethyl phosphonate) 82
Other Organics
NDMA (n-Nitrosodimethylamine) 0.0074 (0.033)1
OCPs (Organochlorine Pesticides)
Dieldrin 0.002* (0.05)3
Endrin 0.22
Isodrin 0.06'
Arsenic 2.35'
1 Health-based value from the ROD for the Off-Post Operable Unit (Harding Lawson Associates 1995).
1 Colorado Basic Standards for Groundwater. The Basic Standards for Groundwater, 5 CCR 1002.8, Section 3.11.
3 Current certified reporting limit or practical quantitation limit readily available from a certified commercial laboratory.
4 Risk-based value from Integrated Risk Information System (OHEA-EPA 1995).
rma\!515G
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Table 9.1-2 CSRGs for the Irondale Containment System Page 1 of 1
Chemical Group/Compound Containment System Remediation Goals (ng/I) .
VHOs (Volatile Halogenated Organics)
Trichloroethylene 5U
Other Organics
DBCP (Dibromochloropropane) 0.21-2
' Colorado Basic Standards for Groundwater. The Basic Standards for Groundwater, 5 CCR 1002.8, Section 3.11.
z Federal maximum contaminant levels, 40 CFR 141.
tma\15I6G
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Table 9.1-3 CSRGs for the North Boundary Containment System
Page 1 of 2
Chemical Group/Compound
Containment System Remediation Goals
(ug/l)
VHOs (Volatile Halogenated Organics)
1,2-Dichloroethane
1,2-Dichloroethylene
Carbon tetrachloride
Chloroform
Methylene chloride
Tetrachloroethylene
Trichloroethylene
VHCs (Volatile Hydrocarbon Compounds)
DCPD (Dicyclopentadiene)
VAOs (Volatile Aromatic Organics)
Benzene
Xylenes
Toluene
OSCMs (Organosulfur Compounds; Mustard Agent Related)
1,4-Oxathiane
Dithiane
OSCHs (Organosulfur Compounds; Herbicide Related)
Chlorophenylmethyl sulfide
Chlorophenylmethyl sulfone
Chlorophenylmethyl sulfoxide
OPHGBs (Organophosphorous Compounds; Isopropylmethyl Phosphonofluoridate (GB)
Agent Related)
DIMP (Diisopropylmethyl phosphonate)
OPHPs (Organophosphorous Compounds; Pesticide Related)
Atrazine
Malathion
'
0.41
7Qt,2
0.3
61
51'
5
46
33
1,000s
1,000
1.2
160;
18:
30 4
36 4
36 4
8'
1,2
100;
(1.0)*
(0.99)5
rma\I517G.DOC
-------
Table 9.1-3 CSRGs for the North Boundary Containment System
Page 2 of 2
Chemical Group/Compound
Containment System Remediation Goals
(Hg/l)
OCPs (Organochlorine Pesticides)
Aldrin
Dieldrin
Endrin
Isodrin
Other Organics
DBCP (Dibromochloropropane)
NDMA (N-Nitrosodimethylamine)
0.0021
0.002 '
0.2 '
0.063
0.21'2
0.0076
(0.05)3
(0.05)5
(0.033)s
Arsenic
2.353
Anions
Fluoride
Chloride
Sulfate
2,000 uo
250,000'•'
540,000 '•*•'
1 Colorado Basic Standards for Groundwater. The Basic Standards for Groundwater, 5 CCR 1002.8, Section 3.11.
2 Federal maximum contaminant levels, 40 CFR 141.
3 Health-based value from the ROD for the Off-Post Operable Unit (Harding Lawson Associates 1995).
4 EPA Region VIII Health Advisory value.
5 Current certified reporting limit or practical quantitation limit readily available from a certified commercial laboratory.
6 Risk-based level from the Integrated Risk Information System (OHEA-EPA 1995).
7 Methylene chloride is a common laboratory contaminant and analytical anomalies may be observed during compliance monitoring.
' As described in Section 7.2.2, chloride and sulfate are expected to attenuate naturally, achieving remediation goals with time.
9 Inorganic CSRG for sulfate may be the natural background concentration.
10 The federal MCL for fluoride is 4,000 ug/1.
ma\1517O.DOC
-------
Table 9.1-4 CSRGs for the Basin A Neck IRA Treatment System Page 1 of 2
Containment System
Remediation
Chemical Group/Compound Goals (ng/1)
VHOs (Volatile Halogenated Organics)
1,2-Dichloroethane 0.4' (l.l)4 -
1,1,1-Trichloroethane 2001-2
1,1-Dichloroethylene 71-2
Carbon tetrachloride 0.31 (l.O)4
Chlorobenzene 100'-z
Chloroform 61
Tetrachloroethylene 5I>Z
Trichloroethylene 51-2
VHCs (Volatile Hydrocarbon Compounds)
Dicyclopentadiene 46J
VAOs (Volatile Aromatic Organics)
Benzene 5U
OPHPs (Organophosphorus Compounds; Pesticide Related)
Atrazine 3I>2
SHOs (Semivolatile Halogenated Organics)
Hexachlorocyclopentadiene 50'
OCPs (Organochlorine Pesticides)
DDT (Dichlorodiphenyltrichloroethane O.I1
Dieldrin 0.0021 (O.I)4
Endrin 0.21
OSCHs (Organosulfur Compounds; Herbicide Related)
Chlorophenylmethylsulfide 303
Chlorophenylmethylsulfone 363
Chlorophenylmethylsulfoxide 36'
Dicyclopentadiene 463
OSCMs (Organosulfur Compounds; Mustard Agent Related)
1,4-Oxathiane 160'
Dithiane 183
rma\1518G
-------
Table 9.1-4 CSRGs for the Basin A Neck IRA Treatment System Page 2 of 2
Containment System
Remediation
Chemical Group/Compound Goals (ng/I)
Arsenic 501-2
Mercury 21-2
1 Colorado Basic Standards for Oroundwater. The Basic Standards for Groundwater, 5 CCR 1002.8, Section 3.11.
2 Federal maximum contaminant levels, 40 CFR 141.
J Health-based value from the ROD for the Off-Post Operable Unit (Harding Lawson Associates 1995).
4 Current practical quantitation limit or certified reporting limit
rma\1518G
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Table 9.3-1 Summary of the Selected Soil Remedy
Page 1 of 2
Medium Groups/Subgroups
Remedial Action
Munitions Testing
North Plants
Toxic Storage Yards
Lake Sediments
Surficial Soil
Ditches/Drainage Areas
Basin A
Basin F Wastepile
Former Basin F
Secondary Basins
Sanitary/Process
Water Sewers
Chemical Sewers
Complex Trenches
Shell Trenches
Munitions screening; off-post detonation of UXO (450 BCY);
landfill debris and soil above TCLP (89,000 BCY).
Landfill human health exceedance (220 BCY); agent
monitoring during excavation; caustic washing; construct soil
cover over biota risk area and processing area footprint
(160,000 SY).
Landfill human health exceedance (2,700 BCY); utilize New
Toxic Storage Yard for borrow area; agent monitoring during
site excavation and preparation; caustic washing.
Landfill human health exceedances (19,000 BCY);
consolidate soil posing risk to biota from Upper Derby Lake
(19,000 BCY) into Basin A or South Plants; deferral to
USFWS for aquatic sediment.
Landfill human health exceedances (87,000 BCY);
consolidate soil posing risk to biota in Basin A/Former Basin
F/South Plants (460,000 BCY).
Consolidate soil posing risk to biota in Basin A (23,000
BCY).
Construct soil cover with formed concrete layer over principal
threat and human health exceedances and soil posing risk to
biota (670,000 SY); consolidate debris and soil posing risk to
biota (790,000 BCY) and structural debris (160,000 BCY)
from other sites.
Landfill entire wastepile (principal threat exceedance)
(600,000 BCY) in triple-lined cell (with vapor controls) after
drying saturated materials.
In situ solidification/stabilization of principal threat volume
(180,000 BCY); construct RCRA-equivalent cap over entire
site (including Basin F Wastepile footprint) (525,000 SY).
Landfill human health exceedances (32,000 BCY); construct
soil cover over soil posing risk to biota (520,000 SY).
Plug remaining manholes.
Plug sewer lines in South Plants Central Processing Area and
Complex Trenches; landfill remaining principal threat and
human health exceedances (64,000 BCY).
Construct RCRA-equivalent cap with formed concrete layer
over principal threat and human health exceedances and soil
posing risk to biota (390,000 SY) and install a slurry wall
around disposal trenches.
Modify existing cover to be a RCRA-equivalent cap (32,000
SY) and modify existing slurry wall around trenches.
ima/1514G
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Table 9.3-1 Summary of the Selected Soil Remedy
Page 2 of 2
Medium Groups/Subgroups
Remedial Action
Hex Pit
Sanitary Landfills
Section 36 Lime Basins
Buried M-l Pits
South Plants Central Processing Area
South Plants Ditches
South Plants Balance of Areas
Buried Sediments
Sand Creek Lateral
Section 36 Balance of Areas
Burial Trenches
Contingent Volume '
Treatment of buried material (1,000 BCY) using an
innovative thermal technology (with vapor controls); landfill
remaining volume (2,300 BCY). Solidification/stabilization
will become the selected remedy if all evaluation criteria for
the innovative thermal technology are not met.
i
Landfill human health exceedances (14,000 BCY);
consolidate debris and soil posing risk to biota in Basin A
(410,000 BCY).
Landfill principal threat and human health exceedances in
triple-lined cell (54,000 BCY); repair existing soil cover.1
Solidification of principal threat and human health
exceedances (26,000 BCY) and landfill (with vapor controls).1
Landfill principal threat and human health exceedances
(110,000 BCY); construct soil cover over entire site including
soil posing risk to biota (220,000 SY); consolidate soil posing
risk to biota from other sites (370,000 BCY).1
Landfill principal threat and human health exceedances
(33,000 BCY); consolidate soil posing risk to biota into
excavated areas or South Plants Central Processing Area
(22,000 BCY); construct soil cover over entire site (120,000
SY).
Landfill principal threat and human health exceedances
(130,000 BCY); consolidate soil posing risk to biota into
excavated areas or South Plants Central Processing Area
(510,000 BCY); construct soil cover over entire site
(1,700,000 SY).U
Landfill human health exceedances (16,000 BCY).
Landfill human health exceedances (15,000 BCY);
consolidate soil posing risk to biota into Basin A (90,000
BCY).
Landfill human health exceedances and debris (140,000
BCY); consolidate soil posing risk to biota into Basin A
(140,000 BCY); construct soil cover over entire site (850,000
SY).1-2
Landfill human health exceedances and debris (85,000
BCY).1-2
Landfill identified volume (up to 150,000 BCY).
1 Agent monitoring during excavation and treatment of any soil containing agent by caustic solution washing.
: Munitions screening prior to excavation, off-post detonation of any munitions encountered, and landfill munitions debris/soil
above TCLP.
rmi/1514G
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Table 9.3-2 Final Disposition of Soil Exceedance Volumes1
Page 1 of 1
Medium Group/Subgroup
Munitions Testing
North Plants
Toxic Storage Yards
Lake Sediments
Ditches/Drainage Areas
Surficial Soil
Basin A
Basin F Wastepile
Secondary Basins
Former Basin F3
Sanitary/Process Water Sewers
Chemical Sewers
Complex Trenches
Shell Trenches
Hex Pit3
Sanitary Landfills
Section 36 Lime Basins
Buried M-l Pits3
South Plants Central Processing Area
South Plants Ditches
South Plants Balance of Areas
Buried Sediments
Sand Creek Lateral
Section 36 Balance of Areas
Burial Trenches
Totals
Enhanced Consolidation
RCRA RCRA Consolidation Consolidation within South
Landfill2 Landfill2 in Basin A in Basin F Plants
89,000
220
2,700
19,000 19,000
23,000
87,000 109,000 351,000
600,000
32,000
64,000
•
2,300
14,000 406,000
54,000
1 10,000
33,000 22,000
135,000 510,000
16,000
. 15,000 90,000
142,000 140,000
85,000
847,000 654,000 787,000 351,000 532,000
Caustic
Washing
and
Treatment3 Landfill
61
220
180,000
20
1,000
91
26,000 29
160
160
300
207,000 1,040
UXO
Demilitarization
Off Post
450
5
130
"
50
160
550
1,340
All volumes given in bank cubic yards. The soil volumes referenced in this table are summarized in Table 7.1-5, and are based on the TECHBASE software and other
calculations. All soil volumes referenced in this table are subject to the addition of "contingent volumes" based on findings during implementation of remedial activities.
2 Landfill volume does not include contingent soil volume (up to 150,000 BCY), structures demolition debris, treated material volume, or landfill daily cover.
3 Treatment detailed as follows: Former Basin F, in situ solidifcation; Hex Pit, innovative thermal; Buried M-l Pits, solidification and landfill.
tma\IS91G.XLS
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Table 9.3-3 Untreated Soil Exceedance Volumes Remaining In Place1'2
Page 1 of 1
Medium Group/Subgroup
Munitions Testing
North Plants
Toxic Storage Yards
Lake Sediments
Ditches/Drainage Areas
Surficial Soil
Basin A
Basin F Wastepile
Secondary Basins
Former Basin F
Sanitary/Process Water Sewers
Chemical Sewers
Complex Trenches
Shell Trenches
Hex Pit
Sanitary Landfills
Section 36 Lime Basins
Buried M-l Pits
South Plants Central Processing Area
South Plants Ditches
South Plants Balance of Areas
Buried Sediments
Sand Creek Lateral
Section 36 Balance of Areas
Burial Trenches
Totals
' AH volumes given in bank cubic yards.
Human Principal
Health Threat Biota Agent UXO UXO Debris
17,000
160,000 32,000 88,000 710 89 470003
140,000
560,000
21,500 11,500 49
400,000 400,000 1,300 1,170 130,0004
100,000 100,000
32,000* 17,0005 27,000
12
1,270,000 561,000 272,000 2,070 1,260 177,000
Consolidated Soil Total Volume
from Other Sites Remaining in Place
17,000
787,000 1,080,000
140,000
351,000 911,000
21,500
532,000
100,000
•"
370,000 429,000
162,000 162,000
1,670,000 3,390,000
2 All volumes remaining in place are contained beneath soil covers or caps.
3 Debris volume remaining includes 1 7,000 BCY human health exceedance volume and 30,000 BCY of biota risk volume.
4 Debris volume remaining includes 43,000 BCY human health exceedance volume and 87,000 BCY of biota risk volume.
maM592G.XLS
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Table 9.3-4 Cap and Soil Cover Components1 Page 1 of 1
Soil Covers
RCRA-Equivalent 4 ft minimum 3 ft minimum 2 ft minimum 1 ft minimum
Medium Group/Subgroup Caps thickness thickness thickness thickness
Munitions Testing
North Plants 157,000
Toxic Storage Yards
Lake Sediments
Ditches/Drainage Areas
Surficial Soil
Basin A2 667,000
Basin F Wastepile
Secondary Basins 523,000
Former Basin F 525,000
Sanitary/Process Water Sewers
Chemical Sewers
Complex Trenches2 390,000
Shell Trenches 32,000
Hex Pit
Sanitary Landfills
Section 36 Lime Basins
Buried M-l Pits
South Plants Central Processing Area 230,000
South Plants Ditches3
South Plants Balance of Areas 826,000 1,010,000
Buried Sediments
Sand Creek Lateral
Section 36 Balance of Areas 345,000 506,000
Burial Trenches
Totals 947,000 897,000 826,000 1,030,000 1,520,000
1 All areas given in square yards.
2 Cap or cover includes a 6-inch formed concrete layer.
3 South Plants Ditches sites are included under the South Plants Balance of Areas cover area.
ma\1593G.XLS
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Table 9.5-1 Remediation Goals and Standards for the On-Post Operable Unit
Page 1 of 9
Technology
Medium Group/Subgroup
Remediation Goals' and Standards2
Primary
Components of
Rationale1
RCRA/TSCA Munitions Testing; Landfill
Hazardous Waste Secondary Basins; •
Landfill Chemical Sewers;
Sanitary Landfills;
South Plants Central Processing Area; •
South Plants Ditches;
South Plants Balance of Areas;
Buried Sediments;
Sand Creek Lateral; Cap
Section 36 Balance of Areas; •
Burial Trenches;
Buried M-l Pits;
Hex Pit;
North Plants;
Toxic Storage Yards;
Lake Sediments; Liner
Surficial Soil; •
No Future Use Structures, Significant
Contamination History;
No Future Use Structures, Agent •
History
Standard: Landfill principal threat and human health soil
exceedance volumes, UXO debris, agent-contaminated material,
and structural debris.
Standard: Design landfill to meet state 1,000-year siting criteria.
Standard: Ensure all material disposed in landfill passes EPA paint
filter test.
Standard: Minimize infiltration by limiting the hydraulic
conductivity of the clay/synthetic composite barrier layer
(1 x 10"7 cm/sec or less for clay layer).
Standard: Meet or exceed all RCRA, TSCA, and state
requirements.
RCRA/TSCA
regulations;
State RCRA
regulations;
CAMU
Designation
Document
Standard: Minimize percolation by limiting the hydraulic
conductivity of the compacted clay layer to 1 x 10"T cm/sec or -
less.
Standard: Install two composite liners, each consisting of 3 ft of
compacted clay and a synthetic liner.
Standard: Meet or exceed all RCRA, TSCA, and state
requirements.
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Table 9.5-1 Remediation Goals and Standards for the On-Post Operable Unit
Page 2 of 9
Technology
Medium Group/Subgroup
Remediation Goals' and Standards2
Primary
Components of
Rationale1
Enhanced RCRA Basin F Wastepile;
Hazardous Waste Section 36 Lime Basins
Landfill
Landfill
RCRA regulations;
Standard: Landfill principal threat and human health soil State RCRA
exceedance volumes and agent-contaminated material. regulations;
Standard: Design landfill to meet state 1,000-year siting criteria. CAMU
Standard: Ensure all material disposed in landfill passes EPA paint Designation
filter test. Document
Cap
Standard: Minimize infiltration by limiting the hydraulic
conductivity of the clay/synthetic composite barrier layer
(1 x 10"7 cm/sec or less for clay layer).
• Standard: Meet or exceed all RCRA, TSCA, and state
requirements.
Enhanced liner
• Standard: Minimize percolation by limiting the hydraulic
conductivity of the compacted clay layer to 1 x 10"7 cm/sec or
less.
• Standard: Install two composite liners, each consisting of 3 ft of
compacted clay and a synthetic liner, and one additional composite
liner.
• Standard: Meet or exceed all RCRA and state requirements.
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Table 9.5-1 Remediation Goals and Standards for the On-Post Operable Unit
Page 3 of 9
Technology
Medium Group/Subgroup
Remediation Goals' and Standards2
Primary
Components of
Rationale3
RCRA-
Equivalent Cap
UXO Clearance
Former Basin F;
Complex (Army) Trenches
w/concrete layer;
Shell Trenches
Munitions Testing;
Basin A;
Section 36 Balance of Areas;
Complex (Army) Trenches;
Burial Trenches;
South Plants Balance of Areas
Ensure cap performance is equivalent to RCRA landfill cap with
these objectives:
- Standard: Allow no greater range of infiltration through the
cap than the range of infiltration that would pass through an
EPA-approved RCRA cap.
- Standard: Prevent contact between hazardous materials and
humans/biota by using biota barriers and maintaining
institutional controls.
- Goal: Serve as effective long-term barriers.
— Standard: Demonstrate cap performance equivalent to a
RCRA landfill cap according to an EPA- and state-approved
demonstration that will include comparative analysis and field
demonstration.
Goal: Maximize runoff and minimize ponding.
Standard: Maintain cover percolation less than or equal to the
percolation of the underlying native soil.
Goal: Minimize erosion by wind and water.
Goal: Prevent damage to integrity of cap by biota and humans. -
Goal: Maintain cover of locally adapted perennial vegetation.
Standard: Identify, transport off post, neutralize, and destroy
explosives/explosive residue.
Standard: Ensure excavation of all identified munitions-
contaminated soil exceeding TCLP (Munitions Testing and Burial
Trenches) and munitions debris and disposal in the on-post RCRA
landfill.
State and federal
RCRA regulations
Army surety
safety and UXO
regulations
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Table 9.5-1 Remediation Goals and Standards for the On-Post Operable Unit
Page 4 of 9
Technology
Medium Group/Subgroup
Remediation Goals' and Standards2
Primary
Components of
Rationale3
Agent
Decontamination
Soil Cover
(South Plants
Consolidation
Area)
North Plants;
Toxic Storage Yard;
Section 36 Balance of Areas;
Buried M-l Pits;
Burial Trenches;
South Plants Central Processing Area;
South Plants Balance of Areas;
Section 36 Lime Basins;
Chemical Sewers;
No Future Use Structures, Agent
History
South Plants Central Processing Area;
South Plants Ditches;
South Plants Balance of Areas
Standard: Certify 3X decontamination or caustic wash of soil and
structural debris to achieve 3X decontamination.
Standard: Ensure disposal of 3X-decontaminated soil and
structural debris in the on-post RCRA landfill.
Army surety
safety regulations
Standard: Consolidate biota soil exceedance volume in South
Plants Central Processing Area.
Standard: Maintain minimum cover thickness of 4 ft.
Goal: Minimize infiltration through cover.
Goal: Maximize runoff and minimize ponding.
Standard: Maintain cover percolation less than or equal to the
percolation of the underlying native soil.
Goal: Minimize erosion by wind and water.
Goal: Prevent damage to integrity of cover by biota and humans.
Standard: Prevent biota and humans from accessing underlying
contaminated soil by using biota barriers and maintaining
institutional controls.
Goal: Maintain cover of locally adapted perennial vegetation.
Detailed Analysis
of Alternatives;
EPA guidance
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Table 9.5-1 Remediation Goals and Standards for the On-Post Operable Unit
Page 5 of 9
Technology
Medium Group/Subgroup
Remediation Goals' and Standards2
Primary
Components of
Rationale3
Soil Cover with
Concrete Layer
(Basin A
Consolidation
Area)
Soil Cover
Solidification/
Stabilization
Basin A;
Lake Sediments;
Surficial Soil;
Section 36 Balance of Areas;
Sand Creek Lateral;
Sanitary Landfills;
Ditches/Drainage Areas;
No Future Use Structures,
Other Contamination History
Secondary Basins;
North Plants;
South Plants Ditches;
South Plants Balance of Areas;
Section 36 Balance of Areas
Former Basin F
Standard: Consolidate biota soil exceedence volume and structural
debris in Basin A.
Standard: Maintain minimum cover thickness of 4 ft.
Goal: Maximize runoff and minimize ponding.
Standard: Maintain cover percolation less than or equal to the
percolation of the underlying native soil.
Goal: Minimize erosion by wind and water.
Goal: Prevent damage to integrity of cover by biota and humans.
Standard: Prevent biota and humans from accessing underlying
contaminated soil by using biota barriers and maintaining
institutional controls.
Goal: Maintain cover of locally adapted perennial vegetation.
Standard: Maintain minimum cover thicknesses specified in
Section 9.3 of ROD.
Goal: Maximize runoff and minimize ponding.
Standard: Maintain cover percolation less than or equal to the
percolation of the underlying native soil.
Goal: Minimize erosion by wind and water.
Goal: Prevent damage to integrity of cover by biota.
Standard: Prevent humans from accessing underlying contaminated
soil by maintaining institutional controls.
Goal: Maintain cover of locally adapted perennial vegetation.
Standard: Comply with requirements of Basin F closure plan and
design documents.
Detailed Analysis
of Alternatives;
EPA guidance
Detailed Analysis
of Alternatives;
EPA guidance
State RCRA
regulations;
EPA guidance
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Table 9.5-1 Remediation Goals and Standards for the On-Post Operable Unit
Page 6 of 9
Technology Medium Group/Subgroup
Innovative Hex Pit
Thermal
Technology
Remediation Goals' and Standards2
• Standard: Design to achieve 90% or greater destruction of
contaminants.
• Standard: Landfill all treatment residuals and untreated material in
the cm-post hazardous waste landfill.
Primary
Components of
Rationale3
EPA guidance
Solidification/ Buried M-l Pits
Stabilization
Plugging Sanitary/Process Water Sewers;
Chemical Sewers
Standard: Design to reduce contaminant concentrations in leachate; EPA guidance
a 90 to 99% reduction in contaminant concentrations in leachate is
a general guidance and may be varied within a reasonable range
considering the effectiveness of the technology and the cleanup
goals for the site.
Goal: Design treatability testing to achieve a 90% reduction in
contaminant concentrations in leachate.
Standard: Landfill all solidified material in the on-post RCRA
landfill.
Standard: Provide adequate unconflned compressive strength after
solidification/stabilization to meet disposal requirements.
Standard: Interrupt exposure pathway by permanently plugging all
Sanitary Sewer manholes.
Standard: Interrupt exposure pathway by permanently plugging all
chemical sewer lines and manholes not excavated.
Detailed Analysis
of Alternatives
ima\1587G
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Table 9.5-1 Remediation Goals and Standards for the On-Post Operable Unit
Page 7 of 9
Technology
Medium Group/Subgroup
Remediation Goals' and Standards2
Primary
Components of
Rationale3
Slurry Wall
Drying
Excavation
Complex (Army) Trenches;
Shell Trenches
Basin F Wastepile
Munitions Testing; Secondary Basins;
Chemical Sewers; Sanitary Landfills;
South Plants Central Processing Area;
South Plants Ditches;
South Plants Balance of Areas;
Buried Sediments;
Sand Creek Lateral;
Section 36 Balance of Areas;
Burial Trenches; Hex Pit
Buried M-l Pits;
North Plants;
Toxic Storage Yards;
Lake Sediments;
Section 36 Lime Basins;
Surficial Soil;
Ditches/Drainage Areas;
Basin F Wastepile
Goal: Minimize groundwater flow across the slurry wall with a
design goal Ix 10"7 cm/sec hydraulic conductivity.
Goal: Construct slurry wall with sufficient thickness to withstand
maximum hydraulic gradient.
Goal: Construct slurry wall with materials that are compatible
with the surrounding groundwater chemistry.
Goal: Minimize migration by keying the slurry wall in an
underlying low permeability strata
Goal: Dewater as necessary to ensure containment.
Standard: Ensure dried material passes EPA paint filter test.
Standard: Comply with requirements of Basin F closure plan and
design documents.
Detailed Analysis
of Alternatives
State regulations
Standard: Excavate all contaminated soil identified in the ROD for State regulations;
treatment, landfilling, or consolidation that corresponds to the EPA guidance
areal and vertical extent detailed by the soil volume calculations in
the administrative record.
rma\1587G
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Table 9.5-1 Remediation Goals and Standards for the On-Post Operable Unit Page 8 of 9
Primary
Components of
Technology Medium Group/Subgroup Remediation Goals' and Standards2 Rationale3
PCB Removal Equipment TSCA PCB
• Standard: Remediate in accordance with PCB IRA requirements. regulations
Structures
. • Standard: Remove structural materials with PCB concentrations of
50 ppm or greater that exist above ground level, as well as
contaminated parts of floor slabs and foundations identified for
removal, and dispose in the on-post TSCA-compliant landfill.
• Standard: PCB-contaminated sections of floor slabs or foundations
that are not identified for removal, and that have PCB
concentrations of less than 50 ppm, will be left in place.
Soil
* Standard: Interrupt exposure pathway with a minimum of 3 ft of
soil in the five areas identified as having PCB contamination
<250 ppm.
• Standard: Removal of contamination >250 ppm in the three areas
identified by the PCB IRA and disposal in on-post TSCA-
compliant landfill.
• Standard: If necessary, any suspected PCB soil contamination
areas will be characterized further during remedial design. If
additional PCB-contaminated soil is found with concentrations of
50 ppm or greater, the Army will determine any necessary
remedial action in consultation with EPA.
Asbestos • Standard: Removal of asbestos and ACM to attain TSCA TSCA asbestos
Removal requirements. regulations;
State regulations
tma\1587G
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Table 9.5-1 Remediation Goals and Standards for the On-Post Operable Unit
Page 9 of 9
Technology
Groundwater
Treatment
System
Structure
Demolition
Medium Group/Subgroup
Groundwater
No Future Use Structures, Agent
History
Remediation Goals' and Standards2
• Standard: Capture and treat contaminated groundwater to meet or
exceed CSRGs as specified in the ROD.
• Standard: Certify 3X decontamination or caustic wash to achieve
3X decontamination.
Primary
Components of
Rationale3
CBSG, MCL,
MCLG, Risk-
based criteria
State regulations;
Army surety
safety regulations
Structure
Demolition
Air Emissions
Control
No Future Use Structures, Significant
Contamination History; No Future Use
Structures, Other Contamination
History
All medium groups
Standard: Demolish all structural material identified in the ROD
for landfilling or consolidation.
State regulations
Goal: Control emissions, as necessary, during remediation.
Standard: Control emissions and odors for Basin F Wastepile
excavation and Former Basin F remediation, in accordance with
Basin F closure plan and design documents.
Standard: Meet air quality and odor standards that are ARARs. _
Goal: Control air emissions as necessary to attain criteria that will
be developed via an air pathway analysis program that will ensure
that the remedial action will be protective of human health and the
environment and minimize nuisance odors.
1 A broadly defined remediation objective supported by regulatory requirement, regulatory guidance, on agreement by the Parties. Typically, goals are less quantitative or
measurable than standards.
1 A quantitative or physical objective for remediation design that is based on a regulatory requirement, regulatory guidance, standard practice, or agreement by the Parties.
1 This column indicates only a reference to ARARs in Appendix A as a portion of the rationale used to support the remediation goal. It does not include ARARs, nor is it
intended to replace any ARARs. A complete listing of ARARs is presented in Appendix A.
mia\1587G
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Table 9.6-1 Total Estimated Cost for the Selected Remedy1-2
Page 1 of 1
Cost Element
Soil
Water
Structures4
Pre-ROD Costs5
PMRMA Mission Support
Total Cost
1 Detailed cost information is
2 All costs presented in 1995
3 Total cost does not account
Capital
Total Cost1
$530 million
$19 million
$7 million
$750 million
$550 million
$1.9 billion
Present Worth
Cost
$380 million
$18 million
$6.5 million
$750 million
$430 million
$1.6 billion
provided in the Detailed Analysis of Alternative
dollars.
for inflation over the time frame for remediation,
Operating and
Total Cost3
$41 million
$130 million
$140 million
—
.. —
$310 million
report
Maintenance
Present Worth
Cost
$17 million
$85 million
$130 million
—
—
$230 million
Total
Total Cost3
$570 million
$150 million
$150 million
$750 million
$550 million
$2.2 billion
Cost
Present Worth
Cost
$400 million
$100 million
$140 million
$750 million
$430 million
$1.8 billion
rma/l52!G
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10.0 Statutory Determinations
10.0 Statutory Determinations
This section describes how the selected remedy meets statutory requirements and complies with CERCLA and
NCP requirements.
10.1 Consistency with the Statutory Requirements of CERCLA in Section 121
The selected remedy complies with Section 121 of CERCLA as described below.
10.1.1 Protection of Human Health and the Environment
The selected remedy will result in the remediation of the On-Post Operable Unit contaminated groundwater,
structures, and soil consistent with the RAOs established for these media. It will eliminate, reduce, or control
risks posed through each exposure pathway by engineering controls, treatment, or institutional controls so that
cumulative site risks are reduced to acceptable levels. All human health, principal threat, and biota risk is being
addressed by the selected remedy, thus resolving the risks at the On-Post Operable Unit. Additional biota
studies are being performed in support of design refinement in areas (termed the Area of Dispute) where the
potential risks to biota have not been agreed upon. There will be no unacceptable short-term risks or cross-
media impacts caused by implementation of the remedy.
10.1.1.1 Groundwater
The groundwater remedial actions proposed under Alternative 4 will address the potential risks to human health
and the environment by continuing treatment of groundwater at the boundary systems (NWBCS, NBCS, and
ICS) as well as the on-post groundwater IRA systems (Basin A Neck, Motor Pool/Rail Yard, and North of
Basin F IRAs), and through construction of a new groundwater extraction system northeast of the Army
Complex Trenches (in the Section 36 Bedrock Ridge area). The toxicity, mobility, and volume of contaminated
groundwater will be reduced through activated carbon (primarily) and air stripping treatment technologies. The
extent of MDMA groundwater contamination and potential design refinements to achieve the remediation goals
are currently being evaluated (see Section 7.2.2).
Contaminant concentrations at the RMA boundary will be reduced to meet or surpass the CSRGs, which
represent applicable federal or state standards and are consistent with the ROD for the Off-Post Operable Unit.
Consumption of groundwater or surface water on post will be restricted by institutional controls in accordance
with the FFA. Nonpotable uses of on-post groundwater were not anticipated and risk was therefore not
considered in the HHRC for such uses. A risk evaluation would be performed prior to any future nonpotable
use to ensure that such use would be protective of human health and the environment. Continued monitoring of
shallow (unconfined aquifer) and deeper (confined aquifer) groundwater and 5-year reviews of the site will be
used to evaluate the effectiveness of the remedy. Water levels in Lake Ladora, Lake Mary, and Lower Derby
FOSTER E/ WHEELER
Fma\1494G.DOC FOSTER WHEELER ENVIRONMENTAL COHPOMTION 10-1
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Record of Decision for the On-Post Operable Unit
Lake will be maintained to support aquatic ecosystems. The biological health of the ecosystems will continue
to be monitored. Lake-level maintenance or other means of hydraulic containment or plume control will be
used to prevent South Plants plumes from migrating into the lakes at concentrations exceeding CBSGs in
groundwater at the point of discharge. Groundwater monitoring will be used to demonstrate compliance.
10.1.1.2 Structures
The structures remedial actions proposed under Alternative 2 will address the potential risks to human health
and the environment by demolishing and disposing of all No Future Use structures (approximately 94 percent
of all remaining structures at RMA, which include all contaminated and potentially contaminated structures).
As the structural debris is removed, materials are segregated for purposes of recycling and waste classification.
Economically recyclable materials such as scrap metals are collected for salvage. Demolition debris from
structures in the Significant Contamination History Group will be placed hi the on-post hazardous waste
landfill. Structures in the Agent History Group will be monitored following demolition, and any debris
showing agent contamination will be treated; all debris from this group will then be placed in the on-post
hazardous waste landfill. Debris from structures in the Other Contamination History Group will be used as fill
under the cover in Basin A. Chemical process-related equipment, ACM, and PCB contamination not addressed
during IRAs will be segregated during demolition and disposed in the on-post hazardous waste landfill (see
Section 7.3.3).
These remedial actions achieve the structures remedial action objectives and reduce the mobility of
contaminants through containment in the on-post hazardous waste landfill or under the Basin A cover. The
potential for exposure to humans or biota is thereby controlled. Toxicity is reduced through treatment of agent-
contaminated structural debris by caustic washing.
10.1.1.3 Soil
The soil remedial actions proposed under Alternative 4 will address the potential risks to human health and the
environment using a combination of containment (as a principal element) and treatment technologies. A
discussion of the human health and ecological risks is presented in Section 6.1 and Section 6.2, respectively.
Approximately 180,000 BCY of principal threat soil at the Former Basin F site will be treated to a depth of
10 ft below the base of the overburden by in situ solidification/stabilization and the site will be contained with a
RCRA-equivalent cap. All soil/sludge from the Buried M-l Pits will be treated by ex situ solidification/
stabilization, followed by placement in the on-post hazardous waste landfill. Approximately 1,000 BCY of
principal threat soil from the Hex Pit will be treated using an innovative thermal technology.
Solidification/stabilization will become the selected remedy for the Hex Pit if all evaluation criteria for the
innovative thermal technology are not met These treatment actions, in addition to the more than 11 million
FOSTER® WHEELER
10-2 fO*TER WHEELER ENVIRONMENTAL CORPORATION nna\1494G.DOC
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10.0 Statutory Determinations
gallons of contaminated liquids from the Former Basin F already treated by incineration as part of the Basin F
IRA, will achieve permanent reductions in the toxicity, mobility, or volume of some highly contaminated soil.
Although the selected remedy in large part is a containment remedy, these treatment components satisfy
CERCLA statutory preference for treatment. The large volume of contaminated soil present on the site
precludes a remedy in which all contaminants could be excavated and cost-effectively treated.
i
Approximately 1.7 million BCY of contaminated soil from a number of soil medium groups at RMA (Basin F
Wastepile, Section 36 Lime Basins, South Plants Central Processing Area, South Plants Ditches, South Plants
Balance of Areas, Secondary Basins, Munitions Testing, Chemical Sewers, Sanitary Landfills, Lake Sediments,
Surficial Soil, Buried Sediments, Sand Creek Lateral, Section 36 Balance of Areas, and Burial Trenches) will
be contained in the on-post hazardous waste landfill. Another 1.5 million BCY of soil that may pose a risk to
biota will be excavated and used as fill under the Basin A and South Plants soil covers and Basin F RCRA-
equivalent cap. The Army and Shell Trenches will be contained in place with slurry walls and RCRA-
equivalent caps. Soil covers will be constructed over all of the South Plants area; the processing areas of the
North Plants; all of Basins A, B, C and D; and the Section 36 Balance of Areas. PCB-contaminated soil will be
remediated as described in Section 9.3. These containment actions, in conjunction with institutional controls,
will prevent exposure of humans to contaminants, reduce exposure of biota to contaminants, and reduce
contaminant mobility.
10.1.1.4 Additional Components of the Remedy
Additional actions described in Section 9.4 that contribute to protection of human health and the environment
and are an integral part of the on-post remedy are the following:
• Provision of $48.8 million held in trust to provide for the acquisition and delivery of 4,000 acre-feet of
potable water to SACWSD and the extension of water-distribution lines from an appropriate municipal
water supply distribution system to all existing well owners within the DIMP plume footprint north of
RMA as defined by the detection limit for DIMP of 0.392 parts per billion. The Army and Shell have
reached an Agreement in Principle with SACWSD, enclosed as Appendix B of this ROD, regarding
this matter.
• In compliance with NEPA, PMRMA will separately evaluate the potential impacts to the environment
of both the acquisition of a replacement water supply for SACWSD and for the extension of water-
distribution lines.
• The Army and Shell will fund ATSDR to conduct an RMA Medical Monitoring Program in
coordination with CDPHE. The primary goals of the Medical Monitoring Program are to monitor any
off-post impact on human health due to the remediation and provide mechanisms for evaluation of
human health on an individual and community basis until such time as the soil remedy is completed.
Elements of the program could include medical monitoring, environmental monitoring,
health/community education, or other tools. The program design will be determined through an
analysis of community needs, feasibility, and effectiveness.
• Trust Fund - During the formulation and selection of the remedy, members of the public and some
local governmental organizations expressed keen interest in the creation of a Trust Fund to help ensure
FOSTER ©WHEELER
rma\l494G.DOC FOSTER WHEELER ENVIRONMENTAL COWORMTON 10-3
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Record of Decision for the On-Post Operable Unit
the long-term operation and maintenance of the remedy once the remedial structures and systems have
been installed. In response to this interest, the Parties have committed to good-faith best efforts to
establish a Trust Fund for the operation and maintenance of the remedy, including habitat and surficial
soil. Such operation and maintenance activities will include those related to the new hazardous waste
landfill; the slurry walls, caps, and soil and concrete covers; all existing groundwater pump-and-treat
systems; the groundwater pump-and-treat system to intercept the Section 36 Bedrock Ridge Plume; the
maintenance of lake levels or other means of hydraulic containment; all monitoring activities required
for the remedy; design refinement for areas that may pose a potential risk to biota as described in
Section 9.4; and any revegetation and habitat restoration required as a result of remediation.
These activities are estimated to cost approximately $5 million per year (in 1995 dollars). The
principal and interest from the Trust Fund would be used to cover these costs throughout the lifetime
of the remedial program.
The Parties recognize that establishment of such a Trust Fund may require special legislation and that
there are restrictions on the actions federal agencies can take with respect to proposing legislation and
supporting proposed legislation. In addition to the legislative approach, the Parties are also examining
possible options that may be adapted from trust funds involving federal funds that exist at other
remediation sites. Because of the uncertainty of possible legislative requirements and other options, the
precise terms of the Trust Fund cannot now be stated.
A trust fund group will be formed to develop a strategy to establish the Trust Fund. The strategy
group may include representatives of the Parties (subject to restrictions on federal agency
participation), local governments, affected communities, and other interested stakeholders, and will be
convened within 90 days of the signing of the ROD.
Notwithstanding these uncertainties, it is the intent of the Parties that if the Trust Fund is created it will
include the following:
- A clear statement that will contain the reasons for the creation of the Trust Fund and the purposes
to be served by it.
- A definite time for establishing and funding the Trust Fund, which the Parties believe could occur
as early as 2008, when the remedial structures and systems may have been installed.
- An appropriate means for competent and reliable management of the Trust Fund, including
appropriate criteria for disbursements from the Trust Fund to ensure that the money will be
properly used for the required purposes.
• Restrictions on land use or access are incorporated as part of this ROD. The Rocky Mountain Arsenal
National Wildlife Refuge Act of 1992 and the FFA restrict future land use, and prohibit certain
activities such as agriculture, use of on-post groundwater as a drinking source, and consumption of
fish and game taken at RMA. Continued restrictions on land use or access are included as an integral
component of all on-post alternatives. Long-term management includes access restrictions to capped
and covered areas to ensure the integrity of the containment systems.
• Continued operation of the CERCLA Wastewater Treatment Plant to support the remediation
activities.
• Stored, drummed waste identified in the waste management element of the CERCLA Hazardous
Wastes IRA may be disposed in the on-post hazardous waste landfill in accordance with the CDD
(Harding Lawson Associates 1996).
• Continued monitoring as part of remedial design to refine the remediation of surficial soil and lake
sediments that may pose a potential risk to wildlife (see Section 6.2.4.3).
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10.0 Statutory Determinations
10.1.2 Compliance with ARARs
A comprehensive listing of chemical-, location-, and action-specific ARARs and TBCs that are pertinent to the
selected remedy were developed and are presented in Appendix A. The identified ARARs and TBCs address
the water, soil, and structures at RMA. A summary of location- and chemical-specific ARARs for the selected
remedy is presented in Tables 10.1-1 and 10.1-2, respectively. A summary of action-specific ARARs related to
the selected remedy is presented in Table 10.1-3. Not every action specified in the summary of action-specific
ARARs (Table 10.1-3) will apply to every activity in the selected remedy. For example, ARARs regarding air
emissions during demolition do not apply to GAG adsorption of contaminants from groundwater.
The identified ARARs and TBCs comply with Section 121(d) of CERCLA. ARARs were identified according
to the procedures outlined in the most recent EPA guidance (OERR-EPA 1988a, b; OSWER-EPA 1989b, c)
andtheNCP.
10.1.2.1 Chemical-Specific ARARs
RMA chemical-specific ARARs set concentration limits or ranges in various environmental media for specific
hazardous substances, pollutants, or contaminants. Such ARARs either set protective cleanup levels for the
COCs in the designated media or indicate an appropriate level of discharge based on health- and risk-based
analyses and technological considerations. Chemical-specific ARARs were established for individual
groundwater treatment systems, surface water, soil, and structures and are presented in Appendix A and are
summarized in Table 10.1-2. The selected remedy will comply with all chemical-specific ARARs, which are
described below by medium.
Water
RMA groundwater and surface water ARARs include federal standards based on the following regulatory
programs:
• Safe Drinking Water Act (SDWA) MCLs: 40 CFR 141 Subparts B and G, 40 CFR 143.3
• SDWA Maximum Contaminant Level Goals: 40 CFR 141 Subpart F
• Clean Water Act (CWA) Water Quality Criteria: 33 USC Section 1313
• RCRA MCLs: 40 CFR Section 264.94
With respect to state standards, ARARs cited include any state provisions that are equivalent to or more
stringent than federal requirements:
• Colorado Rules and Regulations Pertaining to Hazardous Waste
• Colorado Basic Standards for Groundwater
• Colorado Primary Drinking Water Regulations
• Colorado Basic Standards and Methodologies for Surface Water
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ARARs and TBCs for groundwater and surface water were identified by evaluating the current lists of target
contaminants addressed by the groundwater and surface water monitoring programs and identifying
corresponding standards, regulations, or requirements.
Structures
TSCA establishes cleanup levels for PCB spills occurring after May 4, 1987 and EPA (OERR-EPA 1990)
presents cleanup standards that may serve as TBCs for PCB-contaminated structural surfaces and debris. The
LDR Best Demonstrated Available Technology (BDAT) levels are ARARs for structural debris if placement
occurs. Placement considerations are detailed in Section 7.1.1.
Soil
The proposed RCRA Corrective Action Rule example action levels (55 FR 30798, July 27, 1990), LDR
Universal Treatment Standard (UTS) and TSCA PCB Spill Cleanup Policy (40 CFR Part 761 Subpart G), are
TBC values for soil and sediments at RMA. LDR BDAT levels (40 CFR Part 268) are cited ARARs if
placement occurs. Several other Colorado and federal laws and regulations set specific values for certain
contaminants in specific media, but no laws other than TSCA, Clean Air Act, and RCRA set specific values that
are likely ARARs or TBCs for RMA soil and sediments. EPA proposed soil treatment standards in the UTS
rule on September 14,1993, but deferred action on soil LDRs when that rule was finalized; consequently, UTSs
are TBCs with respect to soil at RMA. In addition, there are no chemical-specific standards set by SDWA or
CWA or the state equivalents for soil and sediments. TSCA establishes guidance on action levels for PCBs in
soil.
Air
RMA chemical-specific ARARs for air include the following: National Ambient Air Quality Standards
(40 CFR 50) and National Emission Standards for Hazardous Air Pollutants (40 CFR 61). State standards that
are equivalent or more stringent than federal requirements are also considered ARARs, specifically the
Colorado Ambient Air Standards (5 CCR 1001-5 Regulation 3 and 5 CCR 1001-14) and Control of Hazardous
Air Pollutants (5 CCR 1001-8).
10.1.2.2 Location-Specific ARARs
RMA location-specific ARARs are those requirements that restrict, depending upon the location or
characteristics of the site and the requirements that apply to it, remedial activities or limit allowable
contaminant levels. Examples of such regulations include siting laws for hazardous waste facilities, laws
regarding activities in wetlands or floodplains, and laws regarding preservation of historic or cultural sites. The
selected remedy will comply with all location-specific ARARs, which are listed in Appendix A and
summarized in Table 10.1-1.
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10.0 Statutory Determinations
10.1.2.3 Action-Specific ARARs
RMA action-specific ARARs and TBCs are standards that restrict or control specific remedial activities related
to the management of hazardous substances or pollutants. These requirements are triggered by a particular
remedial activity, not by specific chemicals or the location of the activity. There may be several ARARs for
any specific action. These action-specific ARARs do not in themselves determine the appropriate remedial
alternative, but indicate performance levels to be achieved by an alternative. The selected remedy will comply
with all action-specific ARARs, which are listed in Appendix A and summarized in Table 10.1-3.
10.1.2.4 Other Requirements
In addition to the chemical-, location-, and action-specific ARARs and TBCs cited above, there are a number of
other requirements and potential requirements mat constrain or direct remedial actions at RMA. These
additional items are detailed in Appendix A and include the following:
• Federal Facility Agreement
• Endangered Species Act
• Migratory Bird Treaty Act
• Bald and Golden Eagle Protection Act
• Army UXO and agent management and disposal requirements
• Chemical Weapons Convention
10.1.3 Cost Effectiveness
Cost effectiveness is determined by evaluating three of the five balancing criteria to determine overall
effectiveness: long-term effectiveness and permanence; reduction of toxicity, mobility, or volume through
treatment; and short-term effectiveness. Overall effectiveness is then compared to cost to ensure that the
remedy is cost effective.
Proportional to cost, the selected remedy for groundwater, structures, and soil provides the best overall
effectiveness of all the alternatives considered. The selected remedy will achieve the remedial action objectives
for the contaminated media and greatly reduce the toxicity, mobility, or volume of contamination. The remedy
makes use of proven technologies that will be protective over the long term and minimize or mitigate short-
term impacts during remediation. The selected remedy is therefore cost effective in mitigating risks posed at
the site by contaminated groundwater, structures and soil.
10.1.4 Utilization of Permanent Solutions to the Maximum Extent Practicable
The selected remedy for the On-Post Operable Unit makes use of proven treatment and containment
technologies for the most highly contaminated soil and structures at RMA, and makes use of reliable
groundwater treatment technologies. Approximately 207,000 BCY of contaminated soil will be treated, and
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Record of Decision for the On-Post Operable Unit
more than 1.8 million BCY of soil and structural debris will be contained in a new RCRA- and TSCA-
compliant hazardous waste landfill to be constructed on post. Groundwater treatment will continue at a rate of
several hundred million gallons per year until shut-off criteria are met, at which time pumping rates may be
reduced.
Although the selected remedy in large part is a containment remedy, this remedy provides the best balance of
tradeoffs in terms of long-term effectiveness and permanence; reduction of toxicity, mobility, or volume
through treatment; short-term effectiveness; implementability; and cost. The remedy uses permanent solutions
and alternative treatment technologies to the maximum extent practicable. Components of the selected remedy
satisfy the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or volume as
a principal element. The large volume of contaminated soil present on the site precludes a remedy in which all
contaminants could be excavated and cost effectively treated. The selected remedy has received state and
community acceptance.
10.2 State and Community Acceptance
10.2.1 State Acceptance
The state of Colorado concurs with the selected remedy for RMA as providing the best balance of the nine
criteria. The state also concurs with the selected ARARs.
10.2.2 Community Acceptance
Based on comments to the Proposed Plan, community members view the remedy as an acceptable approach to
reduce risks at a reasonable cost, with the proviso that an additional water supply, Medical Monitoring
Program, and Trust Fund be established as described in Section 9.4. Some community members feel that
additional treatment of soil should be performed.
10.3 Consistency with NCP
The process used to select the remedy for RMA is consistent with the NCP. Specifically, alternatives were first
identified and screened from a broad range of alternatives that achieved the RAOs and then evaluated against
the nine evaluation criteria presented in the NCP (see Section 8). Also in accordance with the NCP, the
selected remedy fulfills the following requirements:
• It will be protective of human health and the environment.
• It will attain ARARs or provide grounds for invoking a waiver.
• It will be cost effective (provided that it first satisfies the threshold criteria).
• It will use permanent solutions to the maximum extent practicable.
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10.0 Statutory Determinations
10.4 Consistency with NEPA
Implementation of the selected remedy is in compliance with NEPA. Numerous studies conducted in support
of the FS process have indicated that there are no likely significant environmental impacts. Therefore, in
accordance with the procedures contained in Army Regulation 200-2, PMRMA is advising the public that the
remediation program is in compliance with NEPA and that no further documentation is necessary. However,
PMRMA will separately evaluate the potential impacts to the environment of both the acquisition of a
replacement water supply by SACWSD and for the extension of water-distribution lines.
10.5 Summary
The preferred remedy for the On-Post Operable Unit includes Groundwater Alternative 4, Structures
Alternative 2, and Soil Alternative 4. The remedy was selected in accordance with the requirements of
CERCLA and the NCP. The remedial actions that comprise the selected remedy will reduce the toxicity,
mobility, or volume of contamination and address the risks to human health and the environment through
treatment and institutional controls for contaminated groundwater; demolition, treatment (as necessary for
Army agent), and containment for all No Future Use structures; and a combination of containment (as a
principal element) and treatment technologies for contaminated soil.
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Record of Decision for the On-Post Operable Unit
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Table 10.1-1 Summary of Location-Specific ARARs for the Selected Alternatives
Page 1 of 4
ARAR/TBC
Requirement
Citation
Description
Location-
Specific
Protection of Wetlands
Protection of Floodplains
Endangered Species Act
RCRA Subtitle C - Location
Standards
Fish and Wildlife Coordination
Act and Wild and Scenic Rivers
Act
Executive Order 11990
42 USC Section 1344
40 CFR Part 230, Subpart H
33 CFR Parts 320-330
40 CFR 6.302(a)
40 CFR 6, Appendix A,
Sections 3(a) and 3(a)
Executive Order 11988
40 CFR 257.3-1 (a)
40CFR264.18(b)
6 CCR 1007-3,264.18(b)
40 CFR 6. Appendix A
40CFR6.302(b)
Section 3(a), 3(b), and
3(b)(4)
44 FR 43239 (July 24,1979)
16 USC 1531
40CFR264.18(a)
6 CCR 1007-3,264.18(a)
6 CCR 1007-2, Part 2
16 USC Part 661-663
40 CFR 6.302 (e) and (g)
16USC1274elssq,
Requires consideration of impacts to wetlands in order to minimize their
destruction, loss, or degradation, and to preserve/enhance wetland values.
Potentially applicable to activities which would impact wetlands
Potentially applicable to activities occurring within the 100-year
floodplain.
Establishes requirements for the protection of federally listed threatened
and endangered species and their habitat. Potentially applicable to
activities which could affect threatened or endangered species or their
habitat. Note: the Endangered Species Act, along with the Migratory Bird
Treaty Act and Bald and Golden Eagle Protection Act, are not ARARs,
but independently apply to remedial activities.
New treatment facilities, storage facilities, or hazardous waste disposal
facilities should not be within 200 ft of a fault. Facilities should not be
located in areas prone to earthquakes, floods, fire, or other disasters that
could cause a breakdown of the public water system.
Fish or wildlife resources that may be affected by actions resulting in
control or structural modification of any natural stream or body of water
should be protected. Federal agencies taking such actions must consult
with USFWS. The Wild and Scenic Rivers Act established requirements
for water resource projects affecting wild, scenic or recreational rivers in
the National Wild and Scenic Rivers system. Applicable to area(s)
affecting stream or river.
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Table 10.1-1 Summary of Location-Specific ARARs for the Selected Alternatives
Page 2 of4
ARAR/TBC
Requirement
Citation
Description
National Historic Preservation Act
Prehistoric, historic, or
archeologica! sites owned or
controlled by a federal agency
Historical, prehistoric, and
archeological resources and State
register of Historic Places Act
Cultural resource owned or
controlled by a federal agency
l6USC470aae±s£gt
36 CFR 800
44 FR 6068
36 CFR 60
36 CFR 63
Proposed 36 CFR 66
CRS § 24-80-401 et seq.
CRS §24-80.1-101
35 FR 8921
Archeological or historic site
owned or controlled by a federal
agency
16USC469ei5SJU
The National Historic Preservation Act identifies procedures for protection
of Historically and Culturally Significant Properties, including Colorado's
delegated responsibilities under the act. Applicable to historically or
culturally significant properties.
Department of Interior regulations for determining site eligibility for the
National Register of Historic Places and standards for data recovery
should be complied with.
Consultation with the Colorado Historic Society, the State Archaeologist,
and State Register of Historic Places is required before an action is taken.
Executive Order 11593: Any federal agency controlling culturally
significant resources is the designated leader in the preservation of those
resources. This order ensures that all culturally significant resources
located on an agency's property are protected.
The federal agencies are responsible for identifying, evaluating, and
nominating (where appropriate) to the National Register of Historic Places
all culturally significant resources found on their land.
The Archeological and Historic Preservation Act of 4974 requires that a
federal agency notify the Secretary of Interior regarding any agency
project that will destroy a significant archeological site. The Secretary of
the notifying agency may support data recovery programs to preserve the
resource.
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Table 10.1-1 Summary of Location-Specific ARARs for the Selected Alternatives
Page 3 of 4
ARAR/TBC
Requirement
Citation
Description
Historically significant property
owned and managed by the U.S.
Army
Army Regulation 420
32 CFR 650.181 to 193
Technical Manual 5-801-1
Technical Note 78-17
32 CFR 229
Archaeological resources on U.S. 16 USC 470 aa et seq.
Department of the Army
installations
Prehistoric, historic, or
archeological sites owned or
controlled by the U.S. Army
16USC470a
36 CFR 800
43 CFR 3
43 CFR 7
36 CFR 296
U.S. Department of the Army has procedures and standards for preserving
historically significant properties and procedures for implementing the
Archeological Resources Protection Act. Department of the Army
Regulations 420 prescribe Army policy procedures and responsibilities for
compliance with the National Historic Preservation Act of 1966, as
amended, for maintaining the preservation of historically significant sites,
the hiring of qualified personnel to manage the sites, and the conduct of
state-of-the-art preservation standards regarding personnel and projects for
accomplishment of the historic preservation program.
This regulation also requires that each installation prepare a historic
preservation plan or have documentation on file indicating that no
resources appropriate for such management planning exist.
The Archeological Resources Protection Act of 1979 establishes criminal
and civil penalties for anyone damaging archeological resources. This act
also allows the Secretary of the Army to issue excavation permits for
archeological resources.
The National Historic Preservation Act of 1966 requires the Secretary of
the Interior to inventory, evaluate, and nominate (where appropriate)
significant properties to the National Register of Historic Places.
Preservation of American antiquities: Provides for the protection of
historic or prehistoric remains of any object of any antiquity on federal
lands.
Protection of archeological resources: Provides for the protection of
archeological resources located on public lands.
Executive Order No. 11593, According to Executive Order No. 11593, each federal agency shall
May 13, 1971,36 FR 8921, exercise caution to ensure that any such property that might qualify for
Section 2(b) inclusion is not inadvertently transferred, sold, demolished, substantially
altered, or allowed to deteriorate significantly.
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Table 10.1-1 Summary of Location-Specific ARARs for the Selected Alternatives
Page 4 of 4
ARAR/TBC
Requirement
Citation
Description
16USC470aafiLss$U
36CFR60.6
National Historic Landmark
Program
Colorado Requirements for Siting
of Hazardous Waste Disposal
Sites
36CFR65
6 CCR 1007-2, Part 2
Based on the historical and field inventory information, the significance
of all identified sites should be evaluated following criteria set forth in 36
CFR 60.6 and in accordance with guidelines from the Colorado State
Historic Preservation Office before conducting any ground-altering
activity. The act also requires the Army agency to consult with the
Advisory Council on historic issues that may affect those significant
properties. A federal agency should take into account the effect of the
project on any National Register-listed or eligible property and is directed
to complete an appropriate data recovery program before such a site is
damaged or destroyed.
The National Historic Landmark Program was established to identify and
designate National Historic Landmarks and encourage the long range
preservation of nationally significant properties that illustrate or
commemorate the history and prehistory of the United States.
State siting requirements control the location, design, and design
performance of hazardous waste disposal sites. Such disposal sites must
be located and designed in a manner that ensures long-term protection of
human health and the environment Disposal sites must be designed to
prevent adverse effects on:
• Groundwater
• Surface water
• Air quality
• Public health and the environment
National Wildlife Refuge System
Administration Act
The National Wildlife Refuge Administration Act prohibits the taking or
possessing any fish, bird, mammal, or other wild vertebrate or invertebrate
animals or part or nest or egg thereof within any such area; or enter, use,
or otherwise occupy any such area for any purpose; unless such activities
are performed by persons authorized to manage such area or unless such
activities are permitted.
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Table 10.1-2 Summary of Chemical-Specific ARARs for the Selected Alternatives
Page 1 of 2
ARAR/TBC
Requirement
Citation
Description
Chemical
Specific
Safe Drinking Water Act
Colorado Primary Drinking Water
Regulations
Clean Water Act Ambient Water
Quality Criteria
RCRA MCLs
40 CFR 141
5 CCR 1003-1
Guidance Criteria
33 USC Sections 1313-1314
40 CFR Section 264.94
Colorado Rules and Regulations 6 CCR 1007-3
Pertaining to Hazardous Waste
Colorado Basic Standards for
Groundwater
5 CCR 1002-8
Colorado Basic Standards and 5 CCR 1002-8
Methodologies for Surface Water
RCRA Corrective Action Rule 40 CFR Part 264 Subpart S
6 CCR 1007-3, Part 264,
Subpart(s)
55 FR 30798, July 27,1990
(TBC)
PCB Remedial Action Guidance Guidance on Remedial
Actions for Superfund Sites
with PCB Contamination
40 CFR 761 Subpart G
(TBC)
National Ambient Air Quality
Standards
40 CFR 50
Drinking water standards that apply to specific contaminants and have
been determined to have an adverse effect on human health. These
standards, expressed as MCLs and MCLGs, are potential ARARs for
groundwater and/or surface water cleanup and replacement standards
Federal Water Quality Criteria established for the protection of human
health and or aquatic organisms are not enforceable; however, Section
121(dX2KA) of CERCLA states that remedial actions must attain FWQC
where they are relevant and appropriate under the circumstances of a
release or threatened release.
Concentration limits for hazardous constituents in groundwater used for
the protection of groundwater.
Provides definitions and the general and specific standards necessary for
the storage, treatment, and disposal of hazardous waste.
Statewide standards and a system of classifying groundwater and adopting
water quality standards for such classifications to protect existing and
potential uses of groundwater.
Basic standards and an antidegradation rule for maintaining and improving
the quality of surface waters in Colorado.
Corrective action standards proposed to establish a comprehensive
regulatory framework for implementing the EPA's corrective action
program under RCRA. The proposed standards include constituent-
specific concentration levels for the protection of groundwater and soil.
Provides recommended approach for evaluating and remediating
Superfund sites with PCB contamination. Provide spill cleanup
requirements for PCB spills that occurred after May 4,1987.
Sources cannot cause or contribute to an exceedance of a national ambient
air quality standard.
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Table 10.1-2 Summary of Chemical-Specific ARARs for the Selected Alternatives ^__ Page 2 of 2
ARAR/TBC Requirement Citation Description
National Emissions Standards for 40 CFR 61, Subpart M No visible emissions allowed unless alternative waste management
Hazardous Air Pollutants procedures followed.
Colorado Ambient Air Quality 5 CCR 1001-5, Regulation 3 Sources cannot cause or contribute to an exceedance of a national or
Standard 5 CCR 1001-14 Colorado ambient air quality standard.
Colorado Standards for Control of 5 CCR 1001-8 Standard for hazardous air pollutants not to be exceeded.
Hazardous Air Pollutants
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Table 10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
Pagel of 11
ARAR/TBC
Requirement
Citation
Description
Action-
Specific
Worker Protection
Health and safety protection
Worker exposure
Air Emissions
Particulate emissions
29 CFR Part 1910
29 CFR 1910.120 (b) to (j)
29CFR1926SubpartP
ACGIH 1991-1992 (TBC)
NIOSH1990(TBC)
29 CFR 1910.1000
5 CCR 1001-3, Regulation 1,
Section III (D)
5 CCR 1001-5, Regulation 3
5 CCR 1001-2, Section II
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to the
handling of hazardous waste/materials at uncontrolled hazardous waste
sites. Note: OSHA regulations are independently applicable regulatory
requirements, not ARARs.
29 CFR 1910.120 (b) through 0) provides guidelines for workers
involved in hazardous waste operations and emergency response actions
on sites regulated under RCRA and CERCLA.
29 CFR 1926 Subpart P provides guidelines for workers engaged in
activities related to construction and utilization of trenches and ditches.
Chemical-specific worker exposure guidelines established by OSHA,
ACGIH, and NIOSH.
Colorado air pollution regulations require owners or operators of sources
that emit fugitive particulates to minimize emissions through use of all
available practical methods to reduce, prevent, and control emissions. In
addition, no off-site transport of particulate matter is allowed. Fugitive
dust-control measures will be written into workplans in consultation with
the state.
Estimated emissions from the proposed remedial activity per Colorado
APEN requirements.
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Table 10.1-3 Summary off Action-Specific ARARs for the Selected Alternatives
Page 2 of 11
ARAR/TBC
Requirement
Citation
Description
Emission of hazardous air
pollutants
Volatile organic chemical
emissions
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USC Section 7412
5 CCR 1001-9, Regulation 7
Emission of certain hazardous air pollutants is controlled by NESHAPs.
Remediation activities could potentially cause emission of hazardous air
pollutants.
National standards for site remediation sources that emit hazardous air
pollutants are scheduled for promulgation by the year 2000. Standards
will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air quality
control area for RMA is currently nonattainment for ozone. Storage and
transfer of VOCs and petroleum liquids are controlled by these
requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control technologies
are utilized.
Odor emissions
Air emissions from diesel-
powered vehicles associated with
excavation and backfill
operations
Standards for asbestos waste
disposal
PM/CO Emissions
5 CCR 1001-4, Regulation 2
.Colorado odor emission regulations require that no person shall allow
emission of odorous air contaminants that result in detectable odors that
are measured in excess of the specified limits.
5 CCR 1001 -15, Regulation 12 Colorado Diesel-Powered Vehicle Emission Standards for Visible
Pollutants apply to motor vehicles intended, designed, and manufactured
primarily for use in carrying passengers or cargo on roads, streets, and
highways, and state.
40 CFR 61 Subpart M Prevents discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing waste; requires
disposal of asbestos-containing waste as soon as possible at disposal site;
requires transport vehicles be marked appropriately during loading and
unloading operations.
42 USC Section 7502-7503 New or modified major stationary sources in a nonattainment area are
required to comply with the lowest achievable emission rate.
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Table 10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
Page 3 of 11
ARAR/TBC
Requirement
Citation
Description
Visibility protection
Design/installation of caps/covers
Smoke and opacity
Waste Characterization
Solid waste determination
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
Final Covers on Hazardous
Waste Landfills and Surface
Impoundments
(EPA/530/SW-89/047) (TBC)
5 CCR 1001-3, Regulation 1,
Section H.A
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Section 260.30-
31
40 CFR 261.2
6 CCR 1007-3 Section 261.2
40 CFR 261.4
6 CCR 1007-3 Section 261.4
Remediation activities must be conducted in a manner that does not
cause adverse impacts on visibility. Visibility impairment interferes with
the management, protection, preservation, or enjoyment of federal Class
I areas.
The Colorado Ambient Air Quality Standard for the AIR Program area is
a standard visual range of 32 miles. The averaging time is 4 hours. The
standard applies during an 8-hour period from 8:00 a.m. to 4:00 p.m.
each day (Mountain Standard Time or Mountain Daylight Time, as
applicable). The visibility standard applies only during hours when the
hourly average humidity is less than 70 percent.
Caps and covers must be designed and installed to prevent wind dispersal
of hazardous wastes. They should be designed, constructed, and
installed as specified in this EPA report
Remedial activities must be conducted in a manner that will not allow or
cause the emission into the atmosphere of any air pollutant that is in
excess of 20% opacity.
A solid waste is any discarded material that is not excluded by a variance
granted under 40 CFR 260.30 and 260.31. Discarded material includes
abandoned, recycled, and waste-like materials. These materials may
have any of the following qualities:
• Abandoned material may be
- Disposed
- Burned or incinerated
ima\ISS2G.DOC
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Table 10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
Page 4 of 11
ARAR/TBC
Requirement
Citation
Description
Solid waste classification
6 CCR 1007-2, Section 1
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Section 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
Waste Management
Discharge of liquid wastes
40 CFR Part 122
40 CFR Part 125
40 CFR Part 129
40 CFR 262
40 CFR 264
- Accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material that is
- Used in a manner constituting disposal
- Burned for energy recovery
- Reclaimed
- Speculatively accumulated
• Waste-like material is material that is considered inherently waste-
like.
If a generator of wastes has determined that the wastes do not meet the
criteria for hazardous wastes, they are classified as solid wastes. The
Colorado solid waste rules contain five solid waste categories: industrial
wastes, community wastes, commercial wastes, special wastes, and inert
material.
Wastes generated during remedial activities must be characterized and
evaluated according to the following method to determine whether the
waste is hazardous:
• Determine whether the waste is excluded from regulation under 40
CFR 261.4
• Determine whether the waste is listed under 40 CFR 261
• Determine whether the waste is identified in 40 CFR 261 by testing
the waste according to specified test methods or by applying
knowledge of the hazardous characteristics of the waste in light of
the materials or the process used.
Any wastewater generated during remedial activities will be routed to the
on-post CERCLA Wastewater Treatment Plant if it is not hazardous
waste and will not interrupt the existing treatment system. If wastewater
is routed to the on-post treatment plant, it must be treated in accordance
with NPDES requirements.
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Table 10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
Page 5 of 11
ARAR/TBC
Requirement
Citation
Description
Asbestos waste handling
management
Asbestos waste storage
management
40CFR61,SubpartM
5 CCR 1001-10, Regulation
Part B, Section S.B.III.c.8
6 CCR 1007-2, Part B,
Section 5.4
Prevents discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing wastes; requires
disposal of asbestos-containing waste as possible at disposal site;
requires transport vehicles be marked appropriately during loading and
unloading operations.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos handling, transportation, and storage.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos storage.
PCB storage
40CFR761.65
PCB decontamination standards 40 CFR 761.79
Storage facilities must be constructed with adequate roofs and walls;
have impervious floors with curbs (no floor drains expansion joints or
other openings); and be located above 100-year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing nonliquid
PCBs, such as contaminated soil, rags, debris, need not comply with
above requirements. Containers must be dated when they are placed in
storage.
AH storage areas must be properly marked and stored articles must be
checked for leaks every 30 days.
PCB, containers to be decontaminated by triple rinsing of internal
surfaces with solvent containing <50 ppm PCB.
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Table 10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
Page 6 of 11
ARAR/TBC
Requirement
Citation
Description
PCB chemical waste landfilling
standards
PCB incineration standards
TSCA-PCB design standards
Treatment, storage, or disposal of
RCRA hazardous waste.
40CFR761.75
40CFR76I.70
40 CFR 761 Subpart D
Part 264.100 (e)(2)
6 CCR 1007-3 Section
264.100(eX2)
Part 264 Subpart I
6 CCR 1007-3 Part 264
Subpart I
Part 264 Subpart F
6 CCR 1007-3 Part 264
Subpart F
Part 264 Subpart J
6 CCR 1007-3 Part 264
Subpart J
Landfill must be located in thick, relatively impermeable soil formation
or on soil with high clay and silt content; synthetic membranes must be
used when these conditions cannot be met. In addition, other structural.
requirements include avoidance of location in a floodplain; required
runon/runoff structures if below the 100-year floodplain; and
ground/surface water monitoring for specified parameters. PCB wastes
must be segregated from wastes not chemically compatible with PCBs.
The landfill must include a leachate monitoring system.
Incineration requirements for nonliquid PCB apply to PCB
concentrations >50 ppm and include specified dwell times; combustion
efficiency of 99.9999 percent; process record/monitoring requirements;
automatic shut-off standards; a maximum mass air emission of 0.001 g
PCB per kg of PCB entering the incinerator.
On-post hazardous waste landfills shall be designed and operated in
compliance with applicable substantive requirements of 40 CFR 761
Subpart D.
Corrective action program.
Applicability of the requirements of containers.
Corrective action for solid waste management units.
Applicability of the requirements for tanks or tank systems.
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Table 10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
Page 7 of 11
ARAR/TBC
Requirement
Citation
Description
Part 264 Subpart L
6 CCR 1007-3 Part 264
Subpart L
Part 264 Subpart M
6 CCR 1007-3 Part 264
Subpart M
Part 264 Subpart N
6 CCR 1007-3 Part 264
Subpart N
Part 264 Subpart O
6 CCR 1007-3 Part 264
Subpart O
Part 264.16 (a)(l)
6 CCR 1007-3
Section 264.16(aXl)
Part 264.31 (a)
6 CCR 1007-3
Section 264.3 l(a)
Part 264.51 (a)
6 CCR 1007-3
Section 264.5 l(a)
Part 264.52 (a)
6 CCR 1007-3
Section 264.52(a)
Part 264 Subpart cc
6 CCR 1007-3 Part 264
Subpart cc
Design and operating requirements for waste piles.
Design and operating requirements for land treatment.
Design and operating requirements for landfills.
Applicability of incinerator requirements.
Personnel training.
Facility design and operation requirements.
Purpose and implementation of contingency plans.
Content of contingency plans.
Air emission standards for tanks.
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Table 10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
Page 8 of 11
ARAR/TBC
Requirement
Citation
Description
Management of Remediation
Wastes
Corrective action management
units
Temporary Units
Detonation of UXQ Containing
High Explosives
40CFR264,SubpartS
6 CCR 1007-3, Part 264
Subpart S
6 CCR 1007-2, Part 2
6 CCR 1007-3 Section 264.553
40 CFR 264.553
AR 75-15
AR-385-10
AR 385-64
AMC-R 385-100
The CAMU regulations allow for exceptions from otherwise generally
applicable LDRs-UTS and minimum technology requirements for
remediation wastes managed at CAMUs. These regulations provide
flexibility and allow for expedition of remedial decisions in the
management of remediation wastes. One or more CAMUs may be
designated at a facility. Placement of hazardous remediation wastes into
or within the CAMU does not constitute land disposal of hazardous
wastes so the LDRs-UTS are not triggered.
Design, operating, or closure standards for temporary tanks and container
storage areas may be replaced by alternative requirements. The TU must
be located within the facility boundary, used only for the
treatment/storage of remediation waste, and will be limited to one year of
operation with a one year extension upon approval by the regulatory
. authority.
If UXO is encountered during excavation, workers must comply with the
substantive requirements of AMC-R 385-100, AR 75-15, AR 385-10,
and AR 385-64.
UXO detonation
On-post detonation of UXO
AR 75-15
40 CFR 264 Subpart X
6 CCR 1007-3 Section 264
Subpart X
HE UXO will be detonated in compliance with the substantive
requirements of AR 75-15 regarding demilitarization of class V
materials.
On-post detonation of UXO must comply with the substantive
requirements of the environmental performance standards described in
40 CFR 264 Part 264, including 264.601 (6 CCR 1007-3 Section
264.601) and substantive portions of the monitoring, analysis, reporting,
and corrective action requirements of 40 CFR 264.602 (6 CCR 1007-3,
Section 264.602).
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Table 10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
Page 9 of 11
ARAR/TBC
Requirement
Citation
Description
Chemical Agent Decontamination
Agent decontamination
Decontamination and Disposal
Standards for Chemical Agents
Treatment and disposal of
hazardous debris
AR 385-61
AR 50-6
AR 385-61
AR50-6
40 CFR 268.45
6 CCR 1007-3, Part 268.45
On-post land disposal of
hazardous wastes
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
EPA/540/G-89/006 (TBC)
Treatment, storage, or disposal of 40 CFR Part 264
hazardous waste 6 CCR 1007-3 Part 264
40 CFR Part, Subpart L
6 CCR 1007-3 Section 264,
Subpart L
40 CFR Part 268
6 CCR 1007-3 Part 268
40 CFR Part 264, Subpart I
6 CCR 1007-3, Section 264,
Subpart I
Section 264.171-173
Decontamination of chemical agent-contaminated material must comply
with the requirements of AR 385-61 and AR 50-6.
Army regulations provide standards for decontamination of items
exposed to chemical agents. Material, equipment, and clothing that has
been decontaminated to the 3X level may be landfilled in a RCRA-
approved hazardous waste landfill.
Hazardous debris generated during remedial activities must be treated
using specific technologies to extract, destroy, or immobilize hazardous
constituents on or in the debris if placement occurs. In certain cases, the
debris may no longer be subject to RCRA Subtitle C regulation after
treatment
Based upon a determination of whether the disposal technique constitutes
placement, LDRs-UTS may be applicable. If placement occurs, the on-
site disposal facility must comply with the substantive requirements of
40 CFR Part 264 (6 CCR 1007-3 Part 264) and 40 CFR Part 268 (6 CCR
1007-3 Part 268).
If remedial activities at RMA generates hazardous wastes, the wastes
must be treated and stored in accordance with RCRA regulations.
Wastes stored in stockpiles that are determined to be RCRA hazardous
wastes must be stored, treated, and disposed in compliance with RCRA
regulations, including LDRs-UTS if placement occurs.
Applicability of the requirements for containers.
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Table 10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
Page 10 of 11
ARAR/TBC
Requirement
Citation
Description
Stormwater Management
Discharge of stormwater to on-
post surface waters
Dredged Material Management
Discharge of Dredged Materials
Certification of Federal Licenses
and Permits (401 Certification)
Wastewater Treatment/Disposal
Discharge of waste water to the
treatment plant
40 CFR Parts 122-125
40CFR230SubpartB
33 USC Section 1341
Section 401 of Clean Water Act
40 CFR Part 122
40 CFR Part 125
40 CFR Part 129
40 CFR Part 262
6 CCR 1007-3 Part 262
40 CFR Part 264
6 CCR 1007-3 Part 264
40CFRPartl44.13(c)
40 CFR Part 146
Stormwater runoff, snow melt runoff, and surface runoff and drainage
associated with industrial activity (as defined in 40 CFR 122) from RMA
remedial actions that disturb 5 acres or more and that discharge to
surface waters must be conducted in compliance with the stormwater
management regulations.
Dredging operations in wetland areas must be managed in accordance
with the applicable requirements based on the impacts resulting from
specific dredged material discharges associated with sediment removal
activities.
Provides for state review of facility operations for the purposes of
ensuring that applicable effluent limitations or other limitations or other
applicable water quality requirements will not be violated.
Any wastewater generated during cleanup or remedial actions will be
directed to the on-post RMA wastewater treatment plant and treated in
accordance with NPDES requirements.
Wastewater that is determined to be a hazardous waste must be treated in
accordance with the provisions of RCRA.
Some of the Colorado standards for owners and operators of hazardous
waste management, storage, and disposal facilities are more stringent
than the equivalent federal regulations. These standards are detailed on
Appendix A, Table A-12.
Injection trenches and wells must be constructed per the requirements of
EPA's Underground Injection Control Program.
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Table 10.1-3 Summary of Action-Specific ARARs for the Selected Alternatives
Page 11 of 11
ARAR/TBC
Requirement
Citation
Description
Monitoring
Groundwater monitoring
Noise abatement
40 CFR 264 Subpart F
6 CCR 1007-3 Part 264
Subpart F
2 CCR <*02-2, Rule 10
RCRA Groundwater
Monitoring TEGD (TBC)
6 CCR 1007-3
Colorado Revised Statute,
Section 25-12-103
Groundwater monitoring will be conducted for the presence of hazardous
constituents in the groundwater downgradient from solid waste
management units. Monitoring wells should be constructed and installed
according to the requirements of 2 CCR 402-2, Rule 10 and the guidance
in the RCRA Groundwater Monitoring TEGD.
Colorado groundwater regulations specify requirements for determining
background groundwater quality.
The Colorado Noise Abatement Statute provides that "Applicable
activities shall be conducted in a manner so any noise produced is not
objectionable due to intermittence, beat frequency, or shrillness. Noise is
defined to be a public nuisance if sound levels radiating from a property
line at a distance of twenty-five feet or more exceed the sound levels
established for the specified time periods and zones."
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11.0 Documentation of Significant Changes
11.0 Documentation of Significant Changes
The Proposed Plan indicated that the preferred remedy for the Hex Pit would be identified prior to the ROD and
that remedies being considered involved solidification and thermal treatment technologies. As mis ROD details,
the selected remedy for the Hex Pit is treatment using an innovative thermal technology. Treatment will be
applied to approximately 1,000 BCY of principal threat material; the remaining 2,300 BCY of soil will be
excavated and disposed in the on-post hazardous waste landfill. Process performance will be evaluated through
treatability testing during remedial design. Solidification/stabilization will become the selected remedy if all
evaluation criteria for the innovative thermal technology are not met.
There are no other significant changes to the ROD. However, overall remedy implementation time frames and
present worth costs presented in the ROD differ slightly from those presented in the Proposed Plan due to
modifications in scheduling and funding limitation assumptions.
FOSTER 0 WHEELER
rma\1495G.DOC FOSTER WHEELER ENVIRONMENTAL CORPORATION 11-1
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Glossary
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Glossary
Glossary
Active Dewatering - Lowering the water table by pumping and extraction or other water-removal methods.
Acute Exposure - Based on the exposure model developed for RMA, an exposure duration of 1 to 14 days.
Agent - A solid, liquid, or gas that through its chemical properties produces lethal or damaging effects on man,
animals, material, or plants or that produces a screening or signaling smoke. Examples of chemical agents at RMA
include Sarin (GB), a nerve agent, and mustard (HD), a blistering agent.
Agent Monitoring - Analytical technique used during excavation to survey soil for the presence of Army
chemical agent.
Agricultural Practices - A process that involves tilling the soil with farm machinery and seeding h with locally
adapted vegetation in a manner consistent with RMA refuge management plan. Agricultural practices have been
shown to reduce the level of surficial soil contamination.
Air Monitoring - Collection of air samples that are analyzed for key contaminants to ensure that allowable
concentrations are not exceeded.
Air Stripping - As it applies to groundwater treatment, extracting contaminated groundwater and pumping to an
air stripper, which is a tall, hollow vessel. The water is pumped to the top of the vessel and allowed to splash down
to the bottom. As the water passes through the air, contaminants are transferred from the water to the air, which is in
turn treated before it is discharged to the atmosphere.
Alternative - An option for cleaning up a site.
Applicable or Relevant and Appropriate Requirements (ARARs) - Federal and state legal requirements
that a selected remedy for a site will meet, such as allowable levels of chemicals in water.
Bioaccumulation - The amplification of the concentration of a chemical between the initial source (e.g., water,
soil, or sediment) and a specified target species or trophic box. A bioaccumulative chemical can increase in
concentration in a living organism as the organism breathes contaminated air, drinks contaminated water, or
consumes contaminated food.
Biomagnification - The process by which tissue concentrations of bioaccumulative chemicals increase as a
chemical passes up the food chain (e.g., from plant to insect, mouse, and hawk). It is measured as the ratio of the
concentration of a chemical in an organism to the concentration in the diet of the organism.
Boundary System - Groundwater extraction, containment, and treatment system at RMA boundaries. There are
three such systems, the Irondale, Northwest, and North boundary systems.
Cap - An in-place containment technology. The standard cap design consists of a layer of soil/vegetation, a
crushed layer of concrete or cobbles, and a layer of low-permeability soil. Caps are sloped for erosion control and
are vegetated with locally adapted perennial grasses and low-growing plants.
Caustic Washing - A treatment process in which agent-contaminated soil or structural debris is treated with
caustic (high pH) fluids to degrade the agent compounds.
FOSTER © WHEELER
ima\1497G.DOC porrER WHKUH ENVIRONMENTAL CORPORATION G-l
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Record of Decision for the On-Post Operable Unit
CERCLA - Comprehensive Environmental Response, Compensation and Liability Act. Also known as Superfund,
a law passed in 1980 that establishes a program to identify inactive hazardous waste sites, ensure they are cleaned
up, evaluate damages to natural resources, and create claims procedures for parties remediating the sites.
Chronic Exposure - Based on the exposure model developed for RMA, an exposure duration of 7 to 30 years.
Composite Sample -A representative sample that has been combined from several samples of the same medium.
In this sampling method, samples are systematically collected either vertically and/or horizontally from a medium
and thoroughly mixed together to form a representative sample. Examples of composite samples are depth
composites often used in subsurface soil sampling and area composites used in surficial soil sampling.
Conceptual Remedy - Agreement for a Conceptual Remedy for the Cleanup of the Rocky Mountain Arsenal.
Signed by the Parties on June 13, 1995, it outlines the general approach for the remediation of RMA. The
Conceptual Remedy was the result of dispute resolution (as provided in the FFA) and formed the basis for the
Detailed Analysis of Alternatives report and Proposed Plan.
Consolidation - Movement of soil with low levels of contamination to areas proposed for capping or covering.
The consolidated soil is placed underneath the cap or cover to develop slopes so that surface-water runoff can be
controlled and collected.
Containment - A remedial action that interrupts exposure pathways through the use of physical barriers and
reduces the spread of contamination.
Contaminant of Concern (COC) - A chemical selected for evaluating potential human or animal health effects.
Selection is based on concentration, toxicity, and site-specific information.
Cover - A layer of clean soil that isolates contamination in place, thereby preventing exposure to humans and
animals. A soil cover consists of a variable thickness layer of soil and may include crushed or formed concrete
layers as biota/excavation barriers. Soil covers may be sloped for erosion control and are vegetated with locally
adapted perennial grasses and low-growing plants.
Detection Limit - The lowest concentration of a chemical that can be distinguished from the background response
of an analytical instrument.
Dismantling - Controlled demolition of a structure using heavy equipment. Contaminants are not treated in this
process, but the volume of structural material is decreased and converted into a more workable form for disposal.
Dust Controls - An action, such as spraying water or foam, used to control the emission of dust (e.g., during
excavation activities).
EPA Paint Filter Test - A test that demonstrates the presence or absence of free liquid in waste material to be
landfilled (based on a test method in SW 846, Method 9095).
Ex Situ - Not in the original place (Latin). With reference to hazardous waste treatment, this refers to excavation
or extraction from the ground prior to treatment.
Excavation - The removal of soil, debris, drums, pipes, tanks, or any other solid material from the ground.
Exposure Duration - The amount of time a receptor is exposed to a chemical.
FOSTER 0 WHEELER
G-2 FOOTER VWEElfR ENVIRONMENTAL CORPORATION ma\1497G.DOC
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^ ^ Glossary
Exposure Pathway - The pathway a chemical travels from the source to the individual. At RMA, two pathways
were evaluated, direct (consuming, contacting, or breathing contamination) and indirect (breathing contaminated
vapors).
Extraction System - A system of wells used to remove groundwater from an aquifer.
Feasibility Study (FS) - An investigation that recommends the selection of a protective, cost-effective alternative
for remediation. It usually is begun during the Remedial Investigation (RI); together these investigations are
commonly referred to as the RI/FS.
Federal Facility Agreement (FFA) - A legal document that sets the framework for cleanup at RMA.
Gas Chromatography/Mass Spectrometry (GC/MS) - A laboratory analytical method used to detect
organics in soil or water.
Geophysical Survey - A technique used to locate buried metal, such as unexploded ordnance, using nonintrusive
instruments that measure various properties of subsurface materials.
Granular Activated Carbon (GAC) - A treatment method used to remove organic chemicals from contaminated
groundwater.
Habitat Modifications - The exclusion of biota from contaminated areas by installing physical barriers (e.g., a
chain-link fence) or changing the quality of the habitat (e.g., sowing grasses that are less attractive to biota as an
environment in which to live).
Hazard Index (HI) - A value that represents the summation of hazard quotients for a particular chemical for all
exposure pathways evaluated.
Hazard Quotient (HQ) - The ratio of the estimated actual daily chemical intake (dose) to the estimated allowable
daily intake that is not likely to cause adverse health effects.
Hazardous Waste Landfill - A secure disposal facility that is specially designed, operated, closed, and
monitored to contol the potential release of hazardous substances into the environment.
Horizontal Well - A well that is drilled with a major portion of its length parallel to the ground surface and that
could be used to capture contamination in plumes.
Human Health Exceedance - At RMA, soil posing risk to human health as determined by concentrations of
chemicals present above action levels developed in the Integrated Endangerment Assessment/Risk Characterization
for carcinogens (an excess lifetime cancer risk of 10"4) and noncarcinogens (a hazard index of 1.0).
Hydrology - The science dealing with the properties, distribution, and circulation of water.
ICP Metals - Metals detected by Inductively Coupled Plasma, a laboratory analytical method.
Implementability - The ability to execute and complete the remedial actions required under an alternative.
Evaluation of implementability includes, for example, considering the availability of materials and skilled workers.
In Situ - In the original place (Latin). With reference to hazardous waste treatment, this refers to treatment in the
ground (i.e., without excavation or extraction).
FOSTER ® WHEELER
ima\1497G.DOC FOSTER WHEEIER ENVIRONMENTAL CORPORATION G-3
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Record of Decision for the On-Post Operable Unit
In Situ Biological Treatment - An in-place biodegradation process that takes advantage of the naturally
occurring micro-organisms in the aquifer. Oxygen and nutrients containing nitrogen are added to the aquifer so that
organisms grow more numerous. As the population increases, the organisms turn to the contamination present in the
aquifer as a source of food, thereby breaking down and destroying the contamination.
In Situ Vitrification - A thermal treatment process using electrical current to melt soil or sludges in place,
resulting in a chemically inert and stable glass product.
Incineration - A treatment technology involving destruction of waste or contamination by controlled burning at
high temperatures.
Inorganic - Pertaining to or composed of chemical compounds that do not contain carbon as the principal element,
i.e., matter other than plant or animal.
Interim Response Action (IRA) - A remedial measure that is implemented in an expedited time frame before
the final remedy and that has been determined to be necessary and appropriate for the site.
Maximum Contaminant Level (MCL) - The maximum permissible level of a contaminant in water delivered to
users of a public water system as specified in the Safe Drinking Water Act. MCLs are enforceable water-quality
standards and are applicable or relevant and appropriate requirements for groundwater remediation.
Medium (pi. media) - A specific environment such as groundwater, surface water, soil, sediment, or air.
Medium Groups - Similarly contaminated soil sites, groundwater plumes, or structures.
Migration Pathway - The way in which a chemical moves through the environment. For example, a constituent
in soil may be susceptible to transport by wind suspension as fugitive dust, by alluvial erosion during periods of
seasonal and/or episodic surface-water runoff, or by dissolving in infiltrating rainwater.
Multilayer Cap - A cap that prevents exposure to humans and animals by isolating the contamination. From top
to bottom, it generally consists of three layers: a 4-ft-thick soil/vegetation layer, a 1-ft-thick layer of crushed
concrete or cobbles, and a 2-ft-thick layer of compacted low-permeability soil to provide long-term minimization of
infiltration.
Munitions Screening - Technique used prior to excavation to survey soil for the presence of munitions (weapons
and ammunition) and/or munitions debris.
National Oil and Hazardous Substances Pollution Contingency Plan (NCP) - The federal regulations
that govern the implementation of CERCLA.
National Priorities List - A list published by the U.S. Environmental Protection Agency that ranks all of the
CERCLA sites in order of priority for remediation.
Operable Unit - Term for a geographic area or a separate activity undertaken as part of a cleanup conducted under
CERCLA.
Organic - Pertaining to or composed of compounds that contain carbon as a principal element
Organizations - The U.S. Army, U.S. Environmental Protection Agency, U.S. Agency for Toxic Substances and
Disease Registry, U.S. Fish and Wildlife Service, U.S. Department of Justice, and Shell Oil Company. They signed
the Federal Facility Agreement.
FOSTER GJ WHEELER
G-4 FOSTEflWHEEIXft ENVIRONMENTAL CORPORATION ma\1497G.DOC
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Glossary
Parties - U.S. Department of the Army, Shell Oil Company, State of Colorado, U.S. Environmental Protection
Agency, and U.S. Fish and Wildlife Service. They oversee the remedial process at RMA.
Passive Dewatering - Lowering the water table without actively removing the water by pumping and extraction
or other methods. It is accomplished by limiting the infiltration of water across an area using controls such as a cap
or cover or elimination of water utilities.
Plume - An area of contaminated groundwater containing one or more chemicals at concentrations that exceed
remediation goals.
Preliminary Pollutant Limit Value (PPLV) - Risk-based concentrations of chemicals in soil that are considered
protective of human health given a defined set of exposure and toxicity assumptions.
Principal Threat Exceedance - At RMA, soil that is considered to be highly toxic or highly mobile that would
pose a significant risk to human health should an exposure occur (i.e., more than 10'3 excess lifetime cancer risk or a
hazard index of 1,000).
Probabilistic PPLVs - Risk-based concentrations of chemicals in soil developed to represent the likelihood of a
potential effect on an organism as a result of exposure to a chemical constituent. In a probabilistic evaluation, a
range of input values can be assigned to reflect variability, the shape of the range defined, and a prescribed certainty
assigned to a range of results, thereby providing an informed context within which risks can be managed. At RMA,
for example, the use of a 5th percentile preliminary pollutant limit value (PPLV) would protect 95 percent of an
exposed human population.
RCRA-Equivalent Cap - A cap with physical barriers that achieve the performance standards of a cap as
described in the Resource Conservation and Recovery Act, a law that regulates the management of hazardous waste
from point of generation to disposal. A multilayer cap was assumed to be RCRA equivalent in this ROD for
purposes of costing alternatives.
Receptor - The animal or person for which potential exposure and risk to a chemical is evaluated.
Record of Decision (ROD) - A public document that records and explains the cleanup alternative(s) to be used
at a CERCLA site. It is based on information from the Remedial Investigation/Feasibility Study, public comments,
and community concerns.
Remedial Investigation (Rl) - A study that reports the types, amounts, and locations of contamination at a site.
RF Heating - A thermal treatment process using radio frequency (RF) energy to heat soil in place, volatilizing •
contaminants, which are collected at the ground surface.
Slurry Wall - A buried vertical barrier commonly made of a soil and bentonite clay mixture.
Soil Cover - See Cover.
Soil Posing Risk to Biota - Area containing a potential risk to biota as defined by a hazard quotient greater than
1.0. The hazard quotient is calculated using a biota risk model based on an animal's foraging range (the average
area over which they obtain their food). "Biota" refers to wildlife.
Soil Vapor Extraction - Removes volatile compounds from contaminated soil in the unsaturated zone by
applying a vacuum using vapor extraction wells and blowers. Vacuum blowers induce air flow through the soil
matrix, stripping volatile compounds from the soil. Contaminated vapor is withdrawn through extraction wells,
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Record of Decision for the On-Post Operable Unit
collected, and treated. Enhanced soil vapor extraction may use heating elements to include removal of some
semivolatile compounds.
Soil Venting - A technique used to extract contaminated vapors from soil above the water table, usually by
applying a vacuum to a system of wells.
Solidification/Stabilization - A process in which a hardening agent (such as cement) is combined with
contaminated soil. The mixture is allowed to harden, fixing the contaminants in a less teachable form.
Subchronic Exposure - Based on the exposure model developed for RMA, an exposure duration of 2 weeks to 7
years.
Supplemental Field Study (SFS) - An assessment designed to determine whether potential risk to wildlife is
present in the area peripheral to the center of RMA.
Surface Heating - General technology name for soil treatment technologies that involve heating soil to volatilize
contaminants. During treatment, volatile and semivolatile organic compounds are vaporized from the solid phase
and either recovered or destroyed by an off-gas treatment system.
TCLP - Toxicity Characteristic Leaching Procedure. A test used to evaluate whether a waste exhibits
characteristics of toxicity as specified in the Resource Conservation and Recovery Act.
Thermal Desorption - A process that uses heat to vaporize (desorb) contamination from solid materials. The air
stream generated during the process is treated to remove the contaminants.
Transportation - The movement of structural, soil, or liquid material from a site to disposal or treatment facilities.
Unexploded Ordnance (UXO) - Generic term for military munitions that are potentially active. Munitions are
filled with high explosives (HE-filled) or chemical agent.
Unsaturated Zone - The subsurface zone above the water table. Also known as the vadose zone.
Use History - Narratives (e.g., plant operational records, official Army and Shell histories, depositions from
operating personnel) that describe how a particular structure was used during its operational history. To focus
investigations at RMA, structures were grouped into similarly contaminated (or uncontaminated) medium groups
based on use histories.
Vapor- and Odor-Suppression Measures - Vapor-suppressing materials, such as foam or liners, or a
transportable structure, used during excavation to control emissions of odors and gases.
Volatile - A chemical constituent that readily evaporates (volatilizes) from a solid or liquid state to a gaseous or
vapor state. This process may be enhanced by applying heat or reducing pressure or by a combination of these
processes.
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Bibliography
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Bibliography
Bibliography
BNA (Bureau of National Affairs)
1974-90 Personnel Policies Forum. Job Absentee and Turnover Survey. Quarterly and Annual Surveys from
1974 to Current. Western Region Absence and Turnover Data from 1978 to Current.
Bureau of the Census
1987 Current Population Study, Tenure with Current Employer by Age and Sex. Prepared for the Bureau of Labor
Statistics. January 1981,1983,1987.
Ebasco (Ebasco Services Incorporated)
1994 (July) Integrated Endangerment Assessment/Risk Characterization. Final. Prepared for the Program
Manager for Rocky Mountain Arsenal. Version 4.2,4 v. RTIC 94266R01.
1992a (January) Remedial Investigation Summary Report. Final. Prepared for the Program Manager for Rocky
Mountain Arsenal. Version 3.2,5v. RTIC92017R01.
1992b (December) Development and Screening of Alternatives Report. Final. Prepared for the Program Manager
for Rocky Mountain Arsenal. Version 4.1,7 v. RTIC92363R01.
1992c (December) Human Health Exposure Assessment, Addendum for Rocky Mountain Arsenal, Task B-2.
Final. Prepared for the Program Manager for Rocky Mountain Arsenal. Version 3.2,3 v. RTIC 93011R01.
1990 (September) Human Health Exposure Assessment for Rocky Mountain Arsenal. Final. Prepared for the
Program Manager for Rocky Mountain Arsenal. Version 4. l,8v. RTIC90277R01.
1988 (October) Summary of Results, Structures Survey Report, Task 24. Final. 3v. RTIC 883061202.
EPA (U.S. Environmental Protection Agency)
1993 Corrective Action Management Units and Temporary Units; Corrective Action Provisions; Final Rule.
Federal Register 58 (29): 8658,40 CFR Part 260 et al.
1992 (October) Guide for Conducting Treatability Studies Under CERCLA. Final. EPA/540/R-92/071a.
1990a (March 8) National Oil and Hazardous Substances Pollution Contingency Plan; Final Rule, 40 CFR Part 300
(Federal Register 55 (46): 8666-8865).
1990b (April) Guide to Selecting Superfund Remedial Actions. EPA/9355.0-27/FS.
1986 Guidelines for Carcinogenic Risk Assessment. 51 Federal Register. September 24. Page 33992.
1985 Development of Statistical Distributions or Ranges of Standard Factors Used in Exposure Assessment.
Prepared by CGA Corp. Chapel Hill, NC. EPA/600/8-85/010.
1982 (December) Air Quality Criteria for Particulate Matter and Sulfur Oxides. V. 3. Environmental Criteria and
Assessment Office. EPA/600/8-82/0290.
EPA (U.S. Environmental Protection Agency) et al.
1989 (February) Federal Facility Agreement for the Rocky Mountain Arsenal. Pursuant to CERCLA Section 120,
Docket No. CERCLA Vffl-89-13. RTIC 89068R01.
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Record of Decision for the On-Post Operable Unit
ESE (Environmental Science and Engineering)
1989 (May) Biota Remedial Investigation. Task 9. Final. Prepared for the Program Manager for Rocky Mountain
Arsenal. Version 3.2,4v. RTIC89173R02.
Foster Wheeler Environmental (Foster Wheeler Environmental Corporation)
1996 (May) Feasibility Study Soil Quantity Calculations Summary Report. Prepared for the Program Manager for
Rocky Mountain Arsenal.
1995a (October) Detailed Analysis of Alternatives Report. Final. Prepared for the Program Manager for Rocky
Mountain Arsenal. Version 4.l,7v. RTIC95290R01.
1995b (October) Proposed Plan for the Rocky Mountain Arsenal On-Post Operable Unit. Prepared for the
Program Manager for Rocky Mountain Arsenal.
1995c (October) South Flams/Basin A Groundwater Flow Model. Final. Prepared for the Program Manager for
Rocky Mountain Arsenal. Version 4.0, Iv. RTIC 96025R01.
Harding Lawson Associates
1996 (May) Corrective Action Management Unit Designation Document, Rocky Mountain Arsenal, Commerce
City, Colorado.
1995 (December) Rocky Mountain Arsenal Ofrpost Operable Unit Final Record of Decision, Rocky Mountain
Arsenal, Commerce City, Colorado. Prepared for the Program Manager for Rocky Mountain Arsenal.
1992 Ofrpost Operable Unit, Endangerment AssessmemYFeasibility Study. Final.
MK (MK-Environmental Services)
1996 Development of Chloride and Sulfate Remediation Goals for the North Boundary Containment System at the
Rocky Mountain Arsenal. Prepared by MK-Environmental Services and Foster Wheeler Environmental
Corporation.
MSEC (Mountain States Employer's Council, Inc.)
1981-90 Metro Denver Turnover Surveys, Annual Surveys from 1981 to Current. Incorporated into Colorado
Turnover Survey Data after 1989.
OERR-EPA (Office of Emergency and Remedial Response, U.S. Environmental Protection Agency)
1991 (November) Guide to Principal Threat and Low-Level Threat Wastes. Fact Sheet. OSWER Directive
9380.4-06FS.
1990 (August) Guidance on Remedial Actions for Superfund Sites with PCB Contamination. EPA/540/G-90/007.
1989 Risk Assessment Guidance for Superfund. Volume 1, Human Health Evaluation Manual (Part A). Interim
Final, EPA/540/1-89/002. Volume n, Environmental Evaluation Manual. Interim Final, EPA/540/1-89/001.
1988a (August) CERCLA Compliance with Other Laws Manual: Interim Final. OSWER/9234.1-01.
EPA/540/G-89/006.
1988b (October) Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA.
Interim Final. OSWER/9355.3-01. EPA/540/G-89/004.
OHEA-EPA (Office of Health and Environmental Assessment, U.S. Environmental Protection Agency)
1995 Integrated Risk Information System. Online. Environmental Criteria and Assessment Office, Cincinnati,
OH.
FOSTER © WHEELER
B-2 KMTtHWHEEUHENVIRONMEMTALCOMMIMnON nna\149£GDOC
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Bibliography
1992, Integrated Risk Information System. Online. Environmental Criteria and Assessment Office, Cincinnati,
OH.
1991 Interim Guidance for Dermal Exposure Assessments. OHEA-E-B67.
1989 Exposure Factors Handbook. EPA/600/8-89/043.
OSWER-EPA (Office of Solid Waste and Emergency Response, U.S. Environmental Protection Agency)
1992 Supplemental Guidance to RAGS: Calculating the Concentration Term. EPA 9285.7-081.
1991a Risk Assessment Guidance for Superfund. Volume I, Human Health Evaluation Manual, Supplemental
Guidance: Standard Default Exposure Factors. OSWER Directive 9285.6-03.
1991b Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions. EPA 9355.0-30.
1989a (July) Guidance on Preparing Superfund Decision Documents. Interim Final. OSWER/9355.3-02.
1989b (July) Superfund LDR Guide No. 5: Determining When Land Disposal Restrictions (LDRs) Are Applicable
to CERCLA Response Actions. (Fact Sheet [Final]). EPA/9347.3-05/FS.
1989c (August) CERCLA Compliance With Other Laws Manual: Part EL Clean Air Act and Other Environmental
Statutes and State Requirements. OSWER/9234.1-02. EPA/540/G-89/009.
PMRMA (Program Manager for Rocky Mountain Arsenal)
1996 On-Post Operable Unit Record of Decision Dispute Resolution Agreement.
1988 (March) Technical Program Plan FY88-FY92 (Remedial Investigations/Feasibility Study/Interim Response
Actions). Final. RTIC 88131R01.
PSCo (Public Service Company of Colorado)
1989 Residential Energy Use Survey.
Public Law 102-402,9 October 1992. Rocky Mountain Arsenal National Wildlife Refuge Act of 1992.
SCS (Soil Conservation Service)
1987 Soil Interpretation Record for Lincoln County, Colorado. Form Number 5. United States Department of
Agriculture.
Shell (Shell Oil Company)
1991 Draft Refuge Worker Activities Assessment. Prepared with Program Management Office, Rocky Mountain
Arsenal, and Ebasco Services Incorporated.
Suter, G.W., III (ed.)
1993 Ecological Risk Assessment. Lewis Publishers, Chelsea, MI.
Walsh (J.P. Walsh and Associates)
1988 Soil Investigation and Inventory of the Rocky Mountain Arsenal, Adams County, Colorado. Prepared for
Morrison-Knudsen Engineers, Inc. Boulder, CO.
FOSTER ® WHEELER
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TECHNICAL SUPPORT FOR
ROCKY MOUNTAIN ARSENAL
Record of Decision
for the On-Post Operable Unit
Volume 2
Section 12
Version 3.1
June 1996
Contract No. DAAA 05-92-D-0002
Prepared by:
Foster Wheeler Environmental Corporation
Prepared for:
U.S. Army Program Manager's Office for the
Rocky Mountain Arsenal
This document is intended to comply with the National Environmental Policy Act of 1969.
The information and conclusions presented in this report represent the official position of the Department of the Army unless
expressly modified by a subsequent document. This report constitutes the relevant portion of the administrative record for this
CERCLA operable unit.
The use of trade names in this report does not constitute an official endorsement or approval of the use of such commercial
products. This report may not be cited for purposes of advertisement.
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Record of Decision for the On-Post Operable Unit
group meetings, solicited input using surveys and questionnaires, and pursued phone contacts to identify interested
citizens and organizations, assess public perceptions of the issues, and determine appropriate mechanisms for
engaging in two-way communication.
Educational outreach efforts have included developing several publications that describe current investigations and
available remedial technologies, making literature regarding the on-post cleanup effort available to the public, and
conducting open houses and public meetings. An example of a current publication includes "Update," which has
been distributed to all (approximately 125,000) households within a 10-mile radius of the installation on a quarterly
basis since 1990. Various topics are discussed in mis quarterly pamphlet including RMA technical information
and history, wildlife viewing tour schedules, educational programs, and recycling programs. The Army has also
made the comprehensive documentation generated during the cleanup process available to the public in the
JARDF, in the information repository maintained at the EPA Region Vm library, and at the Adams County,
Aurora, Commerce City, Denver, Lakewood, Montbello, and Park Hill2 libraries.
The Army held one of its largest public open houses in January 1994, following the release and distribution of the
draft Detailed Analysis of Alternatives report for the On-Post Operable Unit Regulatory agencies represented at
the event were EPA, CDPHE, and Tri-County Health Department The two primary responsible parties, Shell and
the U.S. Army, were also represented, as were members of USFWS. The purpose of the event was to allow the
public one-on-one experience with federal, state, and local professionals who could explain in simple terms the
positions of their organizations in the various aspects of the cleanup. Videos were shown mat detailed, in easy-to-
understand terms, the various technologies outlined in the draft Detailed Analysis of Alternatives report As part of
the open house, the Army also offered site tours of RMA to the 1,000 citizens who attended.
Prior to April 1994, various public meetings and workshops were coordinated with interested citizens through the
TRC, which was established under CERCLA guidelines. The committee, initiated at RMA in 1989, was
comprised of representatives from local health and regulatory agencies, community residents, and local
government In November 1993, the TRC opened its meetings to the public. In April 1994, the Department of
Defense directed military installations involved in environmental cleanup to form RABs. The RAB at RMA serves
as a forum to exchange information and establish dialog among the communities, regulatory agencies, and the
Army.
2 Only the Proposed Plan and the Final Detailed Analysis of Alternatives report were available for review at Park Hill Library.
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12.0 Responsiveness Summary
Other tools used by the Army to keep the public informed have included Hie issuance of press releases and hotline
phone numbers that provide callers with up-to-date information about cleanup operations. In addition, Army
representatives visit area libraries, schools and grocery stores on a regular basis to distribute flyers and brochures
dealing with public meetings and cleanup and recreational activities available at RMA.
Hie Proposed Plan was presented to the public on October 16,1995. Press releases were sent to a variety of local
and state news media, including the Rocky Mountain News and The Denver Post The October 1995 edition of
"Update," summarized the information provided in the Proposed Plan and was sent to all households within a 10-
mile radius of RMA. Legal notice of the comment period, which at mat time ran from October 16 through
December 15, 1995, was published in The Denver Post on October 18, 1995 and in the Rocky Mountain News
October 20, 1995. It was republished in mid-December in both newspapers when the comment period was
extended.
At the December 7, 1995 RAB meeting it was decided to extend the public comment period for 1 month, i.e., to
January 15,1996, at the request of some commenters. Verbal and/or written comments were accepted by PMRMA
both before and after the public meeting up to the deadline of January 15,1996.
12.3 Responses to Comments
The remainder of this section consists of the Army's responses to written questions and comments received during
the public comment period.
Since 1989, all remedial investigation activities at RMA have been performed in accordance with the FFA signed
by the Army, EPA, USFWS, ATSDR, Shell, U.S. Department of the Interior, and U.S. Department of Justice. By
signing the FFA, these entities were made part of all decision processes at RMA. The state of Colorado elected not
to sip the FFA, but has played an active role in the decision-making processes for the On-Post Operable Unit.
Throughout the RI/FS process, CDPHE (previously known as Colorado Department of Health) has been involved
and has provided the Army with comments on the various aspects of the remediation at RMA.
Responses to comments are presented in the following order, based on the originator of comment:
Section Topic
12-1 Responses to CDPHE Comments Dated January 19,1996
12-2 Responses to EPA Comments Dated January 4,1996
12-3 Responses to USFWS Comments Dated January 19,1996
12-4 Responses to Shell Comments Dated January 19,1996
12-5 Responses to City and County Government Comments
—Adams County
—City and County of Denver
—Northern Community Coalition
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Record of Decision for the On-Post Operable Unit
12-6 Responses to Environmental Action Group Comments
—League of Women Voters
—Sierra Club
12-7 Public Meeting Transcript
12-8 Responses to Citizen Comments
A glossary of acronyms used in Section 12 is provided as part of the general table of contents.
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12-1
Responses to CDPHE Comments
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STATE OF COLORADO
Roy Romer, Governor
Pati Shwayder, Acting Executive Director
D«cfate4 to proiect/rga/KffoprovfrytteneaMaflcf environ
HAZARDOUS MATERIALS AND WASTE MANAGEMENT DIVISION
4300 Cherry Creek Dr. S. 222 S. 6th Street, Room 232
Denver, Colorado 80222-1530 Grand Junction, Colorado 81501-2768
Phone 003) 692-3300 Phone O03) 248-7164
Fax 003) 759-5355 Fax 003) 248-7198
January 19, 1996
Mr. Charlie Scharmann
Office of the Program Manager
Rocky Mountain Arsenal
AMCPM-RM
Commerce City, CO 80022-1748
Dear Mr. Scharmann:
Please find enclosed the state's comments on the On-Post Proposed
Plan. If you have any questions, please don't hesitate to call.
Sincerely,
Barbara Nabors
RMA Project Manager
Hazardous Materials and
Waste Management Division
cc: Laura Williams Ronel Finley
Lorraine Ross Jonathan Potter
Ken Conright Edward McGrath
Martin Kosec Robert Foster
Bill Adcock Vicky Peters
9602504-1/1
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Colorado Department of Public Health and Environment
Comments on the RMA On-Post Proposed Plan
1. The Agreement for a Conceptual Remedy for the Cleanup of the
pocky Mountain Arsenal (Conceptual Agreement) which was signed by
the parties on June 13, 1995, paragraph 17, provides that all
well owners living within the DIMP plume footprint, defined by
the detection limit of .392 ppb, based on the most recent
quarterly monitoring results at the time the Record of Decision
is signed, will be hooked up to an appropriate water distribu-
tion system. This hook up will be paid for by the Army and
Shell. It is the State's understanding that all persons within
the DIMP plume footprint, including those in the Henderson area
and those with deep wells, will be offered a hook up to an
appropriate distribution system.
It is also the State's understanding, confirmed by the Army
and EPA at the public meeting held in Henderson on December 12,
1995 that Shell and the Army have made a separate and distinct
commitment to provide an additional 4,000 acre feet of water to
SACWSD, or, if such water is not available, to make a payment in
an agreed-upon sum in lieu of water. This commitment is
contained in paragraph 16 of the Conceptual Agreement.
2. The Conceptual Agreement, paragraph 18, provides that the Army
and Shell will fund ATSDR to conduct an RMA Medical Monitoring
Program in coordination with CDPHE. The state wishes to clarify
that the Army and Shell are responsible for fully funding the
participation of the state and ATSDR in the Medical Monitoring
Program.
3. Paragraph 19 of the Conceptual Agreement provides that the
Parties commit to good faith best efforts to establish a trust
fund for the operations and maintenance of the remedy, including
habitat and surficial soils. The Final Detailed Analysis of
Alternatives and the Proposed Plan provide that these activities
are estimated to cost approximately $5 million per year (in 1995
dollars) and that the principal and interest from the trust fund
will be used to cover these costs.
To date, the Army and Shell have failed to identify legal
mechanisms that would be necessary to establish the trust fund or
otherwise develop basic trust fund details. Given the Conceptual
Agreement and widespread stakeholder interest, the state requests
that a series of working meetings on the trust fund be set up
within the next month.
4. As previously noted to the Army, page 3 of the Proposed Plan
contains an error. The Conceptual Agreement provides for RCRA-
equivalent caps on Former Basin F, Army Complex and Shell
Trenches. A RCRA-equivalent cap is not planned for Basin A.
9602504-l/l-A
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5. The Proposed Plan states that*[g]roundwater plumes in the
South Plants area are monitored and high lake levels are
maintained to reduce migration of groundwater into the southern
lakes (Page 13, Table 4)." In the Final DAA, the Army states
that *[h]ydraulic controls are maintained to prevent contaminants
from entering the lakes at levels that could have an adverse
effect on biota.* These descriptions differ from the Conceptual
Agreement language which states that "lake levels...or other
means of hydraulic containment will be used to prevent South
Plants plumes from migrating into the lakes.* It is our
understanding that the method of hydraulic containment (either
lake levels or other) will continue to be discussed and will be
addressed prior to the final ROD. The state is encouraged that
technical working group meetings are being held to discuss this
issue.
6. Contrary to the Proposed Plan and the Detailed Analysis of
Alternatives, the Army has not given adequate consideration to
innovative treatment technologies for Hex Pit remediation.
During negotiations on the Conceptual Agreement, stakeholders
expressed a strong desire that a site on the Arsenal be used as a
demonstration site to evaluate the use of innovative treatment
technologies for other Army/Department of Defense facilities.
The Parties contemplated that a variety of technologies would be
considered based on a range of factors including effectiveness
and cost. In the spirit of the Conceptual Agreement, all
relevant factors for innovative technologies at the Hex Pit need
to be considered as part of reaching a final decision in the ROD.
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOl 'NTAIN ARSENAL
COMMERCE CITY. COLORADO 30022.174S
June 11, 1996
REPLY TO
ATTENTION OF:
Office of the Program Manager
Ms. Barbara Nabors
Colorado Department of Public
Health and Environment
4300 Cherry Creek Drive South
Denver, Colorado 80222-1530
Dear Ms. Nabors:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Responses to your comments are provided below, numbered to correspond to your
comments.
1. The U.S. Army and Shell Oil Company (Shell) remain committed to a resolution
providing eligible residents with hook-ups as stated in the On-Post Record of Decision (ROD)
and the Agreement in Principle with South Adams County Water and Sanitation District
(SACWSD). The State is correct in noting that, based on the Agreement in Principle (enclosed)
residents with wells within the diisopropyl methylphosphonate (DIMP) footprint will be offered
connection to an alternative water supply.
2. To clarify the second part of your comment, the Army and Shell have made a separate
and distinct commitment to provide a supplemental water supply to SACWSD. The Agreement
in Principle with SACWSD requires that SACWSD water be supplied to consenting drinking
water well owners within the DIMP plume footprint by January 1999. In addition, the Agreement
in Principle requires SACWSD to provide 4,000 acre-feet of water to Commerce City and the
Henderson area by 2004. The Parties involved in the water negotiations believe that the
settlement is fair and will permit SACWSD to secure an adequate water supply to satisfy
Commerce City's and Henderson's water needs. If you have any further questions regarding the
water supply, please contact Mr. Tim Kilgannon of this office at 303-289-0259 or Mr. Larry
Ford of SACWSD at 303-288-2646.
3. To clarify the State's concern of funding for the Medical Monitoring Program as
outlined in Paragraph 18 of the Agreement for a Conceptual Remedy for the Cleanup of the
Rocky Mountain Arsenal, the Army and Shell will fund the Agency for Toxic Substances and
Disease Registry (ATSDR) to conduct this effort in coordination with the Colorado
Department of Public Health and Environment (CDPHE). The Program's nature and scope
will include baseline health assessments and will be determined by the on-post monitoring of
remedial activities to identify exposure pathways, if any, to any off-post community. This
Readiness is our Profession
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-2-
Program will continue until the soil remediation is completed. A Medical Monitoring
Advisory Group (MMAG) has been established to evaluate specific issues covered by the
Medical Monitoring Program. The MMAG is composed of representatives of the Army,
Shell, the U.S. Environmental Protection Agency, CDPHE, Tri-County Health Department,
ATSDR, the U.S. Fish and Wildlife Service, Denver Health and Hospitals, and the Site-
Specific Advisory Board. The MMAG also includes representatives from the communities of
Commerce City, Henderson, Denver, Montbello, and Green Valley Ranch.
4. A Trust Fund group will be formed to develop a strategy to establish the Trust
Fund. The strategy group may include representatives of the Parties (subject to restrictions on
federal agency participation), local governments, affected communities, and other interested
stakeholders and will be convened within 90 days of the signing of the ROD.
5. The State is correct in noting the error made on page 3 of the Proposed Plan. A
Resource Conservation and Recovery Act-equivalent cap is not planned for Basin A. Basin A
will be covered with a 6-inch formed concrete layer and a 4-ft soil cover as detailed in
Section 9.3 of the ROD.
6. Water levels in Lake Ladora, Lake Mary, and Lower Derby Lake will be
maintained to support aquatic ecosystems. The biological health of the ecosystems will
continue to be monitored.
Lake-level maintenance or other means of hydraulic containment or plume control will
be used to prevent South Plants plumes from migrating into the lakes at concentrations
exceeding Colorado Basic Standards for Groundwater (CBSG) in groundwater at the point of
discharge. Groundwater monitoring will be used to demonstrate compliance.
7. The Army understands the State's concern of considering innovative treatment
technologies for the Hex Pit remediation. Subject to the results of treatability testing and
technology evaluation, it has been decided that approximately 1,000 bank cubic yards (BCY)
of principal threat material from the Hex Pit will be treated by an innovative thermal
technology. Solidification will become the selected remedy if all evaluation criteria for the
innovative thermal technology are not met. The remaining 2,3'. 0 BCY of material will be
excavated and disposed in the on-post hazardous waste landfill.
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-3-
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you
again for your comments.
Sincerely,
>-^
Bishop
Colonel,'U.S. Army
Program Manager
Enclosure
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Mr. Howard Roitman, Director, Hazardous Material and Waste Management Division,
Colorado Department of Public of Health and Environment, 4300 Cherry Creek Drive,
Denver, Colorado 80222-1530
Ms. Victoria Peters, Attorney General's Office, CERCLA Litigation Unit,
1525 Sherman Street, 5th Floor, Denver, Colorado 80203
Mr. Ira Star, Geotrans Inc., 4888 Pearl East Circle, Suite 300-E,
Boulder, Colorado 80301
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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12-2
Responses to EPA Comments
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
§89 18th STREET • SUITE 600
DENVER, COLORADO 80202-2469
JAN -A 1996
Ref: 8EPR-FF
Mr. Charles Schannann
Office of the Program Manager
for the Rocky Mountain Arsenal
AMXRM-PM, Building 111
Commerce City, Colorado 80022-2180
Re: EPA Comments of the Final On-Post Detailed Analysis of Alternatives (DAA) and
Proposed Plan dated October 16,1995
Dear Mr. Schannann:
The U.S. Environmental Protection Agency (EPA) has reviewed the Final On-Post
Detailed Analysis of Alternatives (DAA) and Proposed Plan which were issued for public
comment on October 16,1995. EPA previously raised fifteen disputes on the draft DAA in
a letter dated September 22,1995, and ten disputes on the draft Proposed Plan in a letter
dated October 5,1995. These disputes have been resolved through the inclusion of changes
in the October 16th version of the DAA and proposed plan. EPA appreciates the effort
expended by the Army to incorporate EPA's comments into the final documents.
Attached are comments regarding errors and omissions identified in the final DAA
and Proposed Plan. These comments should be addressed via an errata sheet to the final
DAA or an addendum to the DAA. Some of the comments are pertinent to the draft ROD
which is scheduled to be issued this month. In addition, EPA may be submitting additional
comments on the ARARs section of the final DAA.
If you have any questions regarding these comments, please contact me at 003) 312-
6540.
Sincerely,
DeniseJJnk
Superrund Project Manager
Enclosure 9W04lo-i/i
O
Printed on Ktcycltd ftptr
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cc: Laura Williams, EPA Rooel Finley, USFWS
Barbara Nabors, CDPHE Vicky Peters, Co. AGO
Lorraine Ross, EPA Jonathon Potter, Army
Mike Anderson, Shell Ken Conright, TCHD
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Comments on
Final Detailed Analysis of Alternatives Report, Version 4.0
October 1995
GENERAL COMMENTS
ft is difficult to correlate the data presented in the spreadsheets in Volume IV with the
volumes, areas, and costs presented throughout the text and tables in Volumes n and
in due to rounding and volume approximations.
Executive Summary
Page 3-15. first paragraph. Reference is made to figure ES 3-3.1 which shows the
AOC. This critical figure is not included in this document ft should be included in
tbeDAA.
Page 11-1. Section 11. Throughout this section, the DAA refers to the volume of
contaminated soils in the Basin F WastepHe medium group as 600,000 BCY (580,000
BCY plus 20,000 BCY of contaminated material from the finer and subgrade). Table
B4.2-3 shows that only 180,000 BCY of material from the Basin F Wastepile medium
group would be disposed in the on-post landfill. Obviously an incorrect volume was
used in this table. Consequently, the remediation cost shown in Table B4.2-3 has
been underestimated by approximately $100 million. Please correct this discrepancy
and confirm that the correct costs were used to determine the total remediation costs.
Soils DAA
Page 11-4. second paragraph. As stated in EPA's letter, dated September 22,1995,
the EPA believes that mis paragraph contains conclusions about the operation and
performance of the Basin F Waste Pile Systems that are not agreed upon by the EPA
and the State. Language pertaining to the operation and performance of the Basin F
Waste Pile Systems should be removed from the DAA.
Page 14-24 last paragraph, second sentence. The EPA is concerned by the Army's
statement mat, 'ft is assumed mat this cap is RCRA-equivalent* The EPA has
reviewed existing guidance documents which address the design requirements of a -
RCRAcap. AU of these documents fist a minimum three layer configuration
consisting of cover, drainage and barrier layers. The Army's proposed cap does not
include a drainage layer. A RCRA cap is designed to operate as a complete structure
with each layer preforming a specific required function. The drainage layer provides
9600410-1/1-*
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protection to the barrier layer and the waste below. It does this by conveying water
off of the top surface of the barrier layer. This action reduces the hydraulic gradient
across the barrier layer to the most minimum level possible. Without a drainage layer
being present, as is the case in the Anny's proposed cap, water that has infiltrated the
cover will collect in the biota barrier. This water win attract root growth from
above, increase the hydraulic gradient across the compacted clay barrier layer below
and reduce the shear strength or structural stability of the cap.
The EPA would prefer that the Army include a drainage layer in their proposed cap
configuration. This action would only minimally impact the capital cost of the cap
and it would provide additional protection to the barrier layer.
Water DAA
Page 6-2T first paragraph. This page starts in mid-sentence. Obviously some text is
missing. Please correct this error.
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Commeots on the .
Proposed Plan for the Rocky Mountain Arsenal
On-Poa Operable Unit
October 1995
Page 8. Ecological Risk Characterization. The Proposed Plan does not adequately
describe the results of the Ecological Risk Characterization. The Army did not
incorporate the suggested text revision made by EPA with our October 5th comments.
The On-Post ROD should describe in more detail where contaminant exposure
pathways to wildlife exist and how these pathways will be eliminated or the risk
reduced to an acceptable level. In addition, the ROD should contain more detail on
the results and conclusions drawn from the ERC. The area of dispute should be
explained as well as the process outlined Paragraph 27 a. of the Conceptual
Agreement.
9600410-l/l-B
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOUNTAIN ARSENAL
COMMERCE CITY. COLORADO 8iY:M 748
June 11, 1996
REPLY TO
ATTENTION OF:
Office of the Program Manager
Ms. Laura Williams
U.S. Environmental Protection Agency
Region VIH
Mail Code 8EPR-F
999-18th Street, Suite 500
Denver, Colorado 80202-2466
«
Dear Ms. Williams:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan.
In response to your comment on the Proposed Plan description of the results of the
Ecological Risk Characterization, the U.S. Army followed U.S. Environmental Protection Agency
(EPA) Guidance on Preparing Superfund Decision Documents, which states the Proposed Plan
should be written in a clear and concise manner and should direct the public to the Remedial
Investigation/Feasibility Study (RI/FS) report as the primary source of detailed information.
In preparing the Proposed Plan, the Army worked closely with all the Parties to address
their dispute items from the draft version of the document. All comments, from each Party, were
addressed.
The Army agrees with EPA that the Record of Decision (ROD) should include more
detail. The ROD (1) describes in more detail where contaminant exposure pathways to wildlife
exist and how either these pathways will be eliminated or the risk will be reduced to an acceptable
level, (2) details the conclusions drawn from the Ecological Risk Characterization, (3) defines the
Area of Dispute, and (4) outlines the process as first set forth in the Agreement for a Conceptual
Remedy for the Cleanup of Rocky Mountain Arsenal (dated June 13, 1995), Paragraph 27a, to be
used to monitor and evaluate areas that may pose risk to biota and to refine areas to be
remediated.
Readiness is our Profession
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-2-
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Colonel/U.S. Army
Program Manager
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Mr. Eduardo Quintana, Assistant Regional Counsel, U.S. Environmental
Protection Agency, One Denver Place, Suite 500, 999-18th Street,
Denver, Colorado 80202-2405
Mr. Gene Czyzewski, COM Federal Program Corporation, 1626 Cole Boulevard,
Suite 100, Golden, Colorado 80401
Program Manager Rocky Mountain Arsenal, Attn. AMCPM-RMI-D, Document Tracking Center
Commerce City, Colorado 80022-1748
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12-3
Responses to USFWS Comments
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Otf, Gdtnk M022-I74I
TdqAooc 003) 21942)2
wimrumm f»00))2f»457»
January 19, 1996
Mr. Charles Scharnann
Program Manager for Rocky Mountain Arsenal
Building 111
Commerce City, Colorado 80022-1748
Dear Mr. Scharmann:
The U.S. Fish and Wildlife Service has reviewed the Final On-Post Detailed
Analysis of Alternatives and the Proposed Plan, which were released for public
review In October 1995, and provides the following comments.
Overall, the Service believes that the subject documents adequately portray
the Analysis of Alternatives considered, the resolution of disputes raised and
the agreements made 1n reaching the Agreement for a Conceptual Remedy which
was signed on June 13, 1995.
Although we believe the documents effectively describe the alternatives and
the proposal, there are several areas where further planning and commitments
are essential before a Record of Decision (ROD) can be developed for release
and concurrence.
Two Items Included In the Conceptual Remedy which are of major concern to the
Service are the development and delivery of on-Post water supplies and the
establishment of a trust fund.
Although much attention and discussion has deservedly centered upon the
development of off-Post water supplies, equal consideration needs to be given
to future on-Post water needs. A dependable source of quality water 1s vital
to maintaining future lake levels and to establish the revegetatlon essential
for restoration and litigation of contamination and remediation efforts.
Likewise the establishment of a trust fund, as envisioned 1n the Conceptual
Agreement, would provide a continuing contingency to ensure the efficacy of
the cleanup as a long ten success.
The Service believes that resolution on the design and Implementation of these
Items Is an achievable and essential element of the forthcoming ROD. He look
forward to working with all Parties towards that goal.
lay
Project Leader
9601915-1/1
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Copies Furnished:
Ms. Laura VI11lams, U.S. Environmental Protection Agency, 999 18th Street,
Suite 500, Denver, Colorado 80202
Mr. William MdCinney, Shell Oil Company, 1700 Lincoln Street, Suite 4100,
Denver, Colorado 80202
Mr. Howard Roitman, Colorado Department of Health and the Environment, 4300
Cherry Creek Drive South, Denver, Colorado 80222-1530
Ms. Barbara Nabors, Colorado Department of Health and Environment, 4300 Cherry
Creek Drive South, Denver, Colorado 80222-1530
Mr. Dan McAuliffe, Department of Natural Resources, 1313 Sherman Street, Room
718, Denver, Colorado 80203
Document Tracking Center, Office of the Program Manager for Rocky Mountain
Arsenal, Building 111, Commerce City, Colorado 80022-1748
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOUNTAIN ARSENAL
COMMERCE CITY. COLORADO 800:2-1748
June 11, 1996
REPLY TO
ATTENTION OF:
Office of the Program Manager
Mr. Ray Rauch
U.S. Fish and Wildlife Service
Rocky Mountain Arsenal National Wildlife Refuge
Building 613
Commerce City, Colorado 80022-1748
Dear Mr. Rauch:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan.
The Army agrees that the on-post water supply is an important issue, and measures similar
to those delineated for off-post alternative water supplies are ongoing to ensure that water of
appropriate quality is provided on-post.
During the formulation and selection of the remedy, members of the public and some local
governmental organizations expressed keen interest in the creation of a Trust Fund, as you do in
your comment, to help ensure the long-term operations and maintenance of the remedy. The
Panics have committed to good-faith best efforts to establish such a Trust Fund, as described in
the On-Post Record of Decision (ROD). Principal and interest from the Trust Fund would be
used to cover the costs of long-term operations and maintenance throughout the lifetime of the
remedial program. These costs are estimated to be approximately $5 million per year (in 1995
dollars).
It is the intent of the Parties that if the Trust Fund is created it will include a statement
containing the reasons for the creation of the Trust Fund, a time frame for establishing and
funding the Trust Fund, and an appropriate means to manage and disburse money from the Trust
Fund. The Parties are also examining possible options that may be adapted from trust funds
involving federal funds that exist at other remedial sites. The Parties recognize that establishing a
Trust Fund may require special congressional legislation and that there are restrictions on the
actions federal agencies can take with respect to such legislation. Because of the uncertainty of
possible legislative requirements and other options, the precise terms of the Trust Fund cannot
now be stated.
Readiness is our Profession
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-2-
A trust fund group will be formed to develop a strategy to establish the Trust Fund. The
strategy group may include representatives of the Parties (subject to restrictions on federal agency
participation), local governments, affected communities, and other interested stakeholders and
will be convened within 90 days of the signing of the ROD.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
EugeneH. Bishof
Colonel, U.S. Army
Program Manager
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Mr. L. Ronel Finley, Coordinator, U.S. Fish and Wildlife Service, Rocky
Mountain Arsenal, Building 111, Commerce City, Colorado 80022-2180
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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12-4
Responses to Shell Comments
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Shell Oil Company
tto Hofen* ROOMS A Owtn LLC
Su*»4100
ITOOUneoh
January 19, 1996
Mr. Charles T. Scharmann
RMA Committee Coordinator
Office of the Program Manager
Rocky Mountain Arsenal
ATTN: AMCPM-RM
Commerce City CO 80022-1748
Re: Comments on the Final RMA On-Post Proposed Plan
Dear Charlie:
Shell generally agrees with the site-wide remedy
selection for the Rocky Mountain Arsenal (RMA), as described in
the Final Proposed Plan for the RMA On-Post Operable Unit i
(October, 1995), and believes that it complies with the
requirements of the Federal Facility Agreement and the Agreement
for a Conceptual Remedy for the Cleanup of the RMA.
Consequently, we have no comments on this document.
If you have any questions or need additional
information, please contact me at your convenience.
Yours very truly,
W.J. McKii
Project Manage]^
Denver Site Project
WJM:crc
9601910-1/1
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cc:
Mr. Kevin T. Blose
Technical Director
Office of the Program Manager
Rocky Mountain Arsenal
ATTN: AMCPM-RM
Commerce City, CO 80022-1748
Mr. Brian Anderson
Office of the Program Manager
Rocky Mountain Arsenal
ATTN: AMCPM-RME-P
Commerce City, CO 80022-1748
Major Jonathan Potter
Rocky Mountain Arsenal
ATTN: AMCPM-RM
Building 111
Commerce City, CO 80022-1748
Ms. Laura Williams
RMA Coordinator
Environmental Protection Agency
Region VIII, One Denver Place
Mail Code 8EPR-FF
999 18th Street, Suite 801
Denver, CO 80202-2466
Ms. Barbara Nabors
Colorado Department of Public Health
And Environment
Hazardous Materials and Haste Management Div.
4300 Cherry Creek Drive South
Denver, CO 60222-1530
Mr. Ray Rauch
U.S. Fish and Wildlife Service
Rocky Mountain Arsenal
National Wildlife Refuge
Building 613
Commerce City, CO 80022-1748
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REPLY TO
ATTENTION OF:
DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOUNTAIN ARSENAL
COMMERCE CITY. COLORADO 30V2M74S
June 11, 1996
Office of the Program Manager
Mr. William J. McKinney
Shell Oil Company
c/o Holme Roberts & Owen, LLC
Suite 4100
1700 Lincoln
Denver, Colorado 80203
Dear Mr. McKinney:
Thank you for your letter regarding the Rocky Mountain Arsenal (RMA) On-Post
Proposed Plan and your general agreement with the selected site-wide remedy. The
U.S. Army understands that Shell Oil Company has no comment on the Proposed Plan.
If you have any questions or concerns regarding the RMA On-Post Proposed Plan, please
direct them to Mr. Brian Anderson of this office at 303-289-0248.
Sincerely,
Eugene H. Bishop
Colonel, U.S. Army
Program Manager
Readiness is our Profession
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-2-
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80011-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Mr. William Adcock, Shell Oil Company, c/o Holme Roberts & Owen, Suite 4100,
1700 Lincoln Street, Denver, Colorado 80203
Mr. M.T. Anderson, Shell Oil Company, c/o Holme Roberts and Owen, Suite 4100,
1700 Lincoln Street, Denver, Colorado 80203
Mr. Edward McGrath, Holme Roberts and Owen, Suite 4100, 1700 Lincoln Street,
Denver, Colorado 80203
Mr. Thomas Cope, Holme Robert and Owen, Suite 4100, 1700 Lincoln Street,
Denver, Colorado 80203
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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12-5
Responses to
City and County Government
Comments
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Adams County
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ADAMS COUNTY, COLORADO
DEPARTMENT OF PLANNING AND DEVELOPMENT 4M$ £A8T Jfm AVEMUE COMMERCE CTrY, COLORADO M02MS3
ROBERT D. CONEY, DIRECTOR
Januaiy 19,1996
On-Post Proposed Plan Conuneott
Program Manager
Rocky Mountain Arsenal
Attn: AMCPM-PM/
Col. Eugene H. Bishop
Building 111-RMA
Commerce City, CO 80022-1748
Dear Col. Bishop:
Under the Proposed Plan and Conceptual Agreement, non-hazardous waste from the Rocky Mountain
Arsenal is proposed to be placed in die Basin A area for disposal. Hie placement of this waste would
occur without a liner system normally required for such disposal.
It is not clear that this would be a cost effective method of disposal for the Arsenal's non-hazardous
wastes. Adams County believes that the Record of Decision should allow the alternative option of off-site
disposal of non-hazardous material. This would allow for a study of all the comparative cost and benefits
of both on-site and off-site of non-hazardous materials.
This alternative is supported by the Director of Hazardous Materials and Waste Management Division,
Colorado Department of Public Health and Environment'*, letter to you, dated September 6,1995. It is
also supported by Tri-Counry Health Department
Contamination at the Rocky Mountain Arsenal has negatively impacted economic development in the
areas surrounding the Arsenal. Using local contractors to transport and dispose of the non-hazardous
material would partially oflset this negative impact Off-site disposal would also allow the waste to be
disposed of in a RCRA designed facility in segregated cells.
Past interim remedial actions at the Arsenal allowed removal of non-hazardous waste from the Arsenal
and disposal of those wastes in facilities within Adams County. Adams County considers these wastes
Special Waste and requires that they be placed into segregated cells in a RCRA designed facility.
Should you have any questions concerning these comments, please call. My number is 853-7003.
Sincerely,
Craig Tesstier^nvironmental Analyst
cc: County Administrator
Director, Planning and Development
BOARD OF COUNTY ELAINE T. VALEKTE OUILLERMO A. DEHERRERA MARTIN J. FLAUM
COMMISSIONERS DISTRICT 1 DISTRICT 2 DISTRICTS
PEOPLE, PRIDE AND PROGRESS
CX3UUOAHSENALVMIOKJWOOMMEWTIDOC 9601912-1/1
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOl \TAIX AK-T\AI.
OOMMHROE CITY. ooLOKAiv vo::.; :•»•>
June 11,1996
REPLY TO
ATTENTION OF:
Office of the Program Manager
Mr. Craig Tessmer
Adams County Department of Planning and Development
4955 E. 74th Avenue
Commerce City, Colorado 80022-1535
Dear Mr. Tessmer:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
Your letter proposes offsite disposal of nonhazardous materials in a Resource
Conservation and Recovery Act-designed facility rather than placing it in the Basin A
Consolidation Area. The Army understands your concern that this material be disposed properly
and believes that the approach of placing the material under the Basin A cover will adequately
immobilize any contaminants and provide a cost-effective method for disposal of nonhazardous
materials In addition, a large volume of fill material will be required to construct the Basin A
Consolidation Area, and the RMA nonhazardous material will satisfy that need. Furthermore, by
using this nonhazardous material onsite, there will be no negative impact from a very large
number of trucks moving through the surrounding community. Cost for fill material is also
minimized. Therefore, the Army chose to keep the nonhazardous material onsite to be used as fill
material for the Basin A Consolidation Area.
In response to your other query about providing business opportunities to local
contractors, to the extent that such efforts are consistent with federal contracting guidelines, the
Army will continue to make a concerted effort to use local labor and contractors to support
remediation activities.
Readiness is our Profession
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If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Eugene H. Bishop
Colonel, U.S. Army
Program Manager
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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City and County of Denver
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CITY AND COUNTY OF DENVER
DEPARTMENT OF HEALTH AND HOSPITALS
WELLINGTON E. WEBB
PUBLIC HEALTH
605 BANNOCK STREET
DENVER, COLORADO 80204-4607
PHONE: (303) 436-7300
Iteyor
FAX: (303) 436-5074
Program Manager January 19,1996
Rocky Mountain Arsenal
Ann: AMCPM.PM/ Col. Eugene H. Bishop
Building 111-RMA
Commerce City, Colorado 80022-1748
re: On-Post Proposed Plan
Dear Colonel Bishop:
Provided below are the Denver Public Health Department, Environmental Protection Division
comments on the Army's Proposed Plan for the Rocky Mountain Arsenal.
General Comments
1. Potential Air Emissions
Any remedial activity that may result in the emission of air pollutants b of concern to Denver.
Air emission modeling associated with the SQI has shown that die populated area of maximal
total off-post deposition (even though negligible for the SQI) is the Montbello neighborhood.
Understandably, die community is extremely concerned about combined emissions from future
remedial measures because of the potential for detrimental health effects. In order ID ensure the
healdi and safety of onsite workers, visitors to the Arsenal, and die general population, we have
previously advised diat die characteristics and risks associated widi die combined sources of air
emissions be considered when evaluating die alternative remedial actions. More specifically, we
expect diat all dispersion associated widi die various sources of emissions would be evaluated by
air modeling and diat die cumulative effect of all components of die separate sources be
included in a Human Healdi Risk Assessment This analysis has not yet been performed.
Furthermore, we advised diat in addition to monitoring emissions at dieir source and at die
boundary of the Arsenal, diat air monitoring stations be established within die surrounding
communities for baseline and subsequent routine monitoring of indicator pollutants.
2. On-post Detonation of UXO
Component 14 of die Parties' agreement states diat if explosives-containing munitions are found,
diey are to be taken to die closest on-post site for detonation. The DAA report (Vol. Vn, page 9-
4) indicates diat site ESA-4b could be used again for on-site detonations, b that site suitable
today and will it remain so throughout die duration of die remedy, considering die continual
development of die Denver International Airport and die vehicular corridor adjacent to the
9602413-1/1
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Comments re: On-Post Proposed Phn
January 19,
(page 2 of 5)
eastern side of the Arsenal? How and where will agent-containing, unexptoded munitions be
destroyed?
3. Institutional Controls and Restrictions
As stated in our comments of 9/16/94, we would like to see a comparison of die effects of
proposed restrictions associated with the various remedial alternatives on humans and wildlife,
both during and after implementation.
4. Trust Fund
The Proposed Plan and the DAA report lack any proposed legal mechanism for the development
of a Trust Fund. That mechanism and at least an estimated date when the Fund could be
established should have been provided.
5. Human Health Risk Characterization .
Since performing the human health risk characterization, DIMP, PCBs, and NDMA have been
identified as contaminants of concern beyond die 27 others previously evaluated. More recent
analyses of animals and soils have proven die presence of dioxins on die RMA. How will die
risks posed by diese new COCs be evaluated? After completion of die proposed remediation,
how would any future additional contaminated media found to pose a significant risk be
addressed?
7. Environmental Justice
Our 9A694 response to die Parties' descriptions of five conceptual cleanup approaches,
reported several concerns heard from die residents living adjacent to die Arsenal. The Parties'
agreement could partially address some concerns, such as medical healdi monitoring for
Montbello residents (Component 18 of die Agreement). However, odier concerns also exist:
How will surrounding property values be effected by die proposed cleanup
approach?
Will education and vocational training opportunities be offered to die community
during die remediation of die RMA?
What emergency response measures will be established to protect die surrounding
communities?
Will die local communities' contractors and work force benefit from die
opportunities afforded by die selected remedial actions?
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Comments re: On-Post Proposed PUn
January 19,1996
(page 3 of 5)
8. Five-Year Reviews
It is not clear when die clock will be started on the five-year review of remedial actions. It is
recommended that the reviews be site-specific and the trigger for starting die time clock be the
completion of a separate site activity within die total site remedy. For example, review of die
protectiveness of die remedy applied to die Army (Complex) Trenches should be performed
within five years subsequent to completion of die slurry wall and RCRA-equivalent cap/cover.
9. Prioritizatioh of Remedial Actions
Please see die attached letter, dated January 17, 1996.
Structures Medium
10. Structures Containing Agent
What measures will be taken to prevent accidental releases during die demolition, crushing,
sorting, and sizing of debris from potentially agent-contaminated structures? If a release to air
occurs at South Plants or elsewhere on RMA, how will die chemical agent's risk to die healdi and
safety of any off-site human population be mitigated?
11. Caustic Washing of Structures and Soil Containing Chemical Agent
The DAA report, Vol. vn, page 9-8 states diat "detailed laboratory and pilot scale testing would
be necessary before implementing this alternative as this technology has not been well
demonstrated and is largely theoretical." The narrative goes on to describe previous testing of
diis procedure at RMA. Re-formation of GB during die spray drying of die brine [spent caustic)
solution, difficulties confirming that die brine was free from agent, and reported exceedance of
air emission action levels were reported. At RMA diere is potential for several types of chemical
agents and other COCs in any batch of material to be treated, which further complicates die
process and may require re-treatment Yet, diese implementation difficulties are not discussed
elsewhere in die DAA report or die Proposed Plan. Please clarify why diis process is die
preferred alternative. Where would die treatment facilities be constructed?
Soils
12. Inconsistencies in Soils Volume Estimates
What is die estimated total volume of soils in die South Plants Central Processing Area exceeding
Human Health and Principle Threat? Human Health and Principle Threat volumes for soils were
estimated in die DAA report for each contaminant of concern between land surface and a depth
of 10 feet (or to die water table If It is shallower). (DAA, Vol. IV, pages A-4). Why wasn't die
volume for die Proposed Plan's 5-foot depdi of excavation detailed in diis appendix? Volumes of
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Comments re-. On-Post Proposed Plan
January 19,1996
(ptge4of5)
the soils media are inconsistently stated among numerous sections of the DAA report, Its
appendices, and the Mass Balance Logic Flow Diagram. Which are die correct estimates?
13. Firing Ranges
The October 1995 edition of "RMA Update," which was distributed at the same time as die
Proposed Plan, includes a map on die front page showing areas of RMA where cleanup activities
would be conducted under die Proposed Plan. Two soil remediation areas are depicted in
Sections 12 and 19 on that map, which are believed to be firing ranges; these areas are not
included in die Proposed Plan's Figure 4 • Preferred Soil Alternative. Please clarify whether these
areas will be included in die remedial action.
14. Slurry Wall Construction
The DAA report (Vol. VII, page 6-9) states "for a slurry wall to control groundwater migration, a
groundwater removal system is generally installed in conjunction with die slurry wall." We
concur. It is recommended diat dewatering and treatment of liquids within die Army (Complex)
Trenches and die Shell Trenches be retained as an initial, necessary component of die remedy.
15. South Plants Cap/Cover
How was it determined that a biota barrier and 4 or more feet of soil cover would not be needed
over die Human Health and Principle Threat exceedance soils that are proposed to be covered in
die Soudi Plants Balance of Areas?
16. Biota Barrier
b it truly protective to use rubble from a demolished RMA structure as a biota barrier without
first performing verification sampling and confirming die presumed lack of contamination?
17. Hex Pits
We would like to see an innovative treatment technology be applied to die 3300 cu. yd. of waste
in die Hex Pits, if practicable. Of die available treatment alternatives, die alternative posing the
least amount of risk to human healdi and safety is preferable.
18. Soudiem Lakes
Degradation of die quality of die surface waters in die soudiern lakes is threatened by die
contaminants widiin die South Plant's plumes. The Proposed plan involves maintaining
hydraulic control of die lakes and continued monitoring of groundwater quality and water-level
data near die lakes in conjunction widi die proposed capping of Soudi Plants. The frequency of
monitoring events and die method of controlling lake levels is not discussed. It appears
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Comment* re: On-Post Proposed Plan
January 19,1996
(page'of 5)
however, that the proposed alternative would only delay the need to extract/treat ever increasing
concentrations of contaminants further from their source area. Should the ability to maintain
the lake water levels be compromised (for example, due to the loss of a dam or die result of a
severe draught) what response actions would be implemented?
19. Confined Flow System Monitoring
The DM report offers several hypotheses regarding mechanisms to explain the numerous
detections of contaminants in the confined flow system. Additional investigation and
characterization of mis deeper zone of groundwater contamination appears to be warranted.
The proposed establishment of a monitoring well network consisting of 20 existing welb and
annual sampling, seems premature and potentially insufficient Additional wells are needed to
assess die lateral extent of contaminant migration. More frequent sampling (such as quarterly
sampling over some limited duration) would provide the data needed to better identify and
designate a more appropriate monitoring network.
Thank you for extending the public comment period and for considering all comments. If you
have any questions, feel free to call (tel. 436-7305).
Sincerely,
John D. Student
Remedial Program Manager
Environmental Protection Division
Denver Public Health Department
attachment
cc: Tom Stauch, Environmental Supervisor, Environmental Protection Division
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CITY AND COUNTY OF DENVER
DEPARTMENT OF HEALTH AND HOSPITALS
WEUJNGTONE.WEB8
PUBLIC HEALTH
605 BANNOCK STREET
DENVER, COLORADO 80204-4507
PHONE: (303) 436-7300
Mayor
FAX: (303) 436-5074
January 17,1996
SENT BY FAX (289-0485 & 289-0582)
Program Manager
Rocky Mountain Arsenal
Attn: Mr. Brian Anderson
Environmental Engineering Division
Commerce City, Colorado 80022
re: Sequencing of Remedial Activities
Dear Mr. Anderson:
The Denver Public Health Department, Environmental Protection Division, has reviewed the
documentation for the Army's proposed sequence of remedial actions at the Rocky Mountain Arsenal.
In general we found the sequence logical. Our exceptions to your priorities are noted on the attached
Remedial Activities Rating Sheet.
In addition to addressing the "fixed facilities" subproject group that you have identified, we would like a
commitment for early action on the following additional critical path issues:
medical monitoring program,
Trust Fund for O&M of remedial actions,
contingency, health and safety, and emergency response plans, and
air pathway monitoring program and baseline concentrations.
Please note that this letter supersedes my previous letter to you concerning this subject, dated January
16,1996. Please discard that letter. Should you have any questions, please feel free to contact me (tel.
(303)436-7305).
Sincerely,
John D. Student
Remedial Program Manager
Environmental Protection Division
Denver Public Health Department
cc: Tom Stauch, Environmental Supervisor, Environmental Protection Division
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Remedial Activities Rating Sheet
Indicate impression of risk (high/medium/low) and community interest (high/medium/low) for each subproject group.
Rate each subproject group between 0 (low priority) and 6 (high priority-) with total not to exceed 6 poinu for all
subproject groups combined.
Subproject Group
Risk
(H'Mt)
Community Interest
(H/M/L)
Comments
Points
Fixed Facilities
Off-Post Water
Section 36
Section 26
North Plants
South Plants
Other
NA
NA
If there is exposure this must
be addressed ASAP.
Shell Trenches and complex
Trenches need early remediation
Basin F Wastepile is control lee
and final remedy can be delayed
Structures £ Soil can be
delayed.
Hex pits need early remediation.
Structures remediation should
concentrate early in South
Plants in order to accelerate
schedule.
Other structures could be
delayed if they don't block
soils clean-up and access can
t»e controlled. Munitions should
be addressed ASAP.
NA
Total
vt Environmental Protection Division
jsarne .___ —
Organization Denver Public Health
priority doc 12/7/95
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR RiVKY MOI NTA1N ARSCXAI.
. E CITY. i VLOKAPO sV: v T-H
June II, 1996
REPLY TO
ATTENTION OH.
Office of the Program Manager
Mr. John D. Student
Environmental Protection Division
Denver Public Health Department
605 Bannock Street
Denver, Colorado 80204-4507
Dear Mr. Student:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
Responses to your comments on the Proposed Plan are provided in the enclosure to this
letter.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
tugene
Colonel, U.S. Army
Program Manager
Enclosure
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
Readiness is our Profession
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U.S. ARMY RESPONSES TO COMMENTS BY THE CITY AND COUNTY OF
DENVER DEPARTMENT OF HEALTH AND HOSPITALS ON THE
ROCKY MOUNTAIN ARSENAL ON-POST PROPOSED PLAN
General Comments
1. Potential Air Emissions
Your comment cites air emissions modeling associated with the Rocky Mountain Arsenal (RMA)
Submerged Quench Incinerator (SQI) as a way to locate the "maximal" off-post deposition in the
Montbello neighborhood. The SQI modeling reflected emissions from a 100-foot stack. Under
these circumstances and stable atmospheric boundary layer conditions, maximum concentrations
from a high emission source are frequently projected a considerable distance downwind.
However, in the future remediation activity projected at RMA, all remediation will be associated
with ground-level sources, and the maximum deposition, or ambient concentrations, will occur in
the immediate proximity of the work area and will decrease rapidly with distance from the source.
This phenomenon was demonstrated in the 1988 Basin F Interim Response Action (IRA) when
moderate concentrations of various volatile organic compounds (VOC) and pesticides were
detected in the immediate work area and decreased rapidly with distance from the work site.
The prevailing nighttime drainage wind is generally from south to north away from Montbello,
and although the worst-case modeling scenario might reflect some higher concentrations in any
random direction because of topography, this likely will not occur to the south. The prevailing
dispersion pattern and windrose calculated during active remediation of Basin F illustrates this
fact. It is also true that during daytime hours, heating of the ground can cause the wind flows to
reverse, blowing up valley (from north to south). Thus Montbello will be downstream of the
Arsenal during these times. However, as noted, the remedial actions will occur at ground level, in
the center of the Arsenal, several miles away from the southern RMA boundary. Also,
atmospheric conditions will be neutral to unstable, confining impacts to the close proximity to the
remediation area. For these reasons, it is anticipated that impacts upon Montbello will be small.
A risk assessment conducted immediately after the Basin F IRA (Ebasco Constructors et al., }989
Basin F Interim Action Close-out Safety Report. Draft Final. August 1989), indicated no risks at
the RMA perimeter to public health and safety. As Montbello is at a farther distance and in the
opposite direction of prevailing worst-case conditions, and as the past remediation of Basin F
most likely reflects worst-case emissions, the Army does not anticipate high concentrations in the
direction of Montbello. Recent smaller remediation activities during Pond A and Pond B closures
and the South Plants pilot building demolition project provided similar results.
The Army intends to take proper precautions for Montbello and all other RMA perimeter areas
when future active remediation commences. Dispersion associated with various sources of
emissions will be evaluated by air modeling (as was done in the past), and intensive air monitoring
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will be conducted both within the interior and at the perimeter of RMA during active remediation.
Real-time monitoring will also be conducted close to all remediation sources for the health and
protection of workers at RMA.
With respect to monitoring at nearby communities, both for baseline and routinely during
remediation activity, a Medical Monitoring Program has been initiated. The primary goals of the
Medical Monitoring Program are to monitor any off-post impact on human health due to the
RMA remediation and to provide mechanisms for evaluation of health status on an individual and
community basis. This Program will continue until the soil remediation is completed. A Medical
Monitoring Advisory Group has been established to evaluate specific issues covered by the
Medical Monitoring Program. As you are aware, the Group is composed of representatives of the
Army, Shell Oil Company, the U.S. Environmental Protection Agency (EPA), the Colorado
Department of Public Health and Environment (CDPHE), Tri-County Health Department, the
Agency for Toxic Substances and Disease Registry (ATSDR), the U.S. Fish and Wildlife Service
(USFWS), Denver Health and Hospitals, and the Site-Specific Advisory Board. The Group also
includes representatives from the communities of Montbello, Commerce City, Henderson, Green
Valley Ranch, and Denver.
2. On-Post Detonation of Unexploded Ordnance (UXO)
Identified UXO will be transported to an off-post Army facility for detonation or other
demilitarization process unless the UXO is unstable and must be detonated on-post. On-post
detonation will only be performed if UXO is unstable and cannot be safely transported to Army
facilities that specialize in explosives or agent-filled UXO demilitarization. The suitability of
on-post UXO detonation sites (including ESA-4b) will be evaluated during remedial design and. it
needed, will be in accordance with Army Materiel Command (AMC) Safety Procedures (AMC-R
385-100 and AR 75-15). Site ESA-4b is located more than one mile from the eastern boundary
of RMA, much farther than the 2,400 feet suggested in the AMC Safety Procedures. Agent-filled
UXO will be transported off-post for demilitarization at an Army facility. Procedures for agent-
filled UXO are described in the Final Detailed Analysis of Alternatives (DAA) in Volume VII,
pages 9-3 and 9-4. Agent will be removed from the UXO, if possible, following Army regulation
(AR 385-61 and AR 50-6).
3. Institutional Controls and Restrictions
The effects of restrictions would be similar for all remedial alternatives both during and after
implementation.
4. Trust Fund
During the formation and selection of the remedy, members of the public and some local
governmental organizations expressed keen interest in the creation of a Trust Fund, as you do in
your comment, to help ensure the long-term operation and maintenance of the remedy. The
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Parties have committed to good-faith best efforts to establish such a Trust Fund, as described in
the On-Post Record of Decision (ROD). Principal and interest from the Trust Fund would be
used to cover the costs of long-term operation and maintenance throughout the lifetime of the
remedial program. The costs are estimated to be approximately $5 million per year (in 1995
dollars).
It is the intent of the Parties that if the Trust Fund is created it will include a statement containing
the reasons for the creation of the Trust Fund, a time frame for establishing and funding the Trust
Fund, and an appropriate means to manage and disburse money from the Trust Fund. The Parties
are also examining possible options that may be adapted from trust funds involving federal funds
that exist at other remedial sites. The Parties recognize that establishing a Trust Fund may require
special congressional legislation and that there are restrictions on the actions federal agencies can
take with respect to such legislation. Because of the uncertainty of possible legislative
requirements and other options, the precise terms of the Trust Fund cannot now be stated.
A Trust Fund group will be formed to develop a strategy to establish the Trust Fund. The
strategy group may include representatives of the Parties (subject to restrictions on federal agency
participation), local governments, affected communities, and other interested stakeholders, and
will be convened within 90 days of the signing of the ROD.
5. Human Health Risk Characterization
Polychlorinated biphenyl (PCB)-contaminated soil (identified by the PCS IRA with
concentrations of 250 parts per million (ppm) or greater) will be excavated and disposed in the
on-post Toxic Substance Control Act-compliant landfill. Soil identified with concentrations
ranging from 50 to 250 ppm will be covered.
Aldrin and dieldrin are the principal risk drivers for soil. Contaminated soil will either be placed in
a hazardous waste landfill, covered with Resource Conservation and Recovery Act or equivalent
caps, covered with concrete caps, or covered with one or more foot of soil (in the case of the
least hazardous soil). In addition, institutional controls and biota barriers will be in place to
prevent intrusion by humans or animals. These actions will address risk concerns regarding other
soil contaminants beyond the 27 compounds identified in the ROD. Groundwater contaminants
are addressed by removing sources on-post, pump and treat systems on-post and off-post,
attenuation, and alternate water supplies off-post. The combination of these two approaches will
address risk concerns both on-post and off-post for any contamination not yet identified as well as
PCBs, N-nitrosodimethlylamine (NDMA), and diisopropyl methylphosphonate (DIMP).
However, monitoring will continue, and necessary modifications to the remedy will be evaluated,
with public input.
In addition to the air monitoring and medical monitoring described in the response to your
Comment Number 1, the Army will conduct monitoring of the remedy as it is implemented.
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The selected remedy will also undergo a periodic, five-year review, as required by the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
If the monitoring or the five-year review reveals additional contamination or that the cleanup
approach is inadequate for the protection of human health and the environment, necessary
modifications to the remedy will be evaluated, with public input, and will be made at that time.
6. Letter had omitted #6.
7. Environmental Justice
The-Army believes that the selected remedy is consistent with the policies and guidelines
pertaining to environmental justice. The Army will continue to inform and seek input from
elected officials, local chamber groups, schools, stakeholder groups, realtors, and local businesses
regarding activities presently underway and those planned for the future. Regarding medical
health monitoring for Montbello residents, please see the response to your Comment Number 3,
above. The following items are addressed individually:
• The Army understands that RMA has had both perceived and actual impacts on
surrounding communities. The Army also believes that RMA has benefitted and
contributed to the surrounding communities. The goal of the Army at RMA is to provide
for an environmentally safe National Wildlife Refuge that will continue to contribute to a
positive image for surrounding communities. RMA has had a very active public outreach
program and will continue to work with the public on matters regarding the environmental
cleanup program until RMA is fully transitioned to a Refuge. Additionally, the Army and
Shell have agreed to provide $48.8 million to purchase a supplemental water supply for
South Adams County Water and Sanitation District.
• Education and vocational training opportunities: The Army and the USFWS provide
educational opportunities through remediation and wildlife tours, and the Army has
recently received accreditation for its environmental education program through the
Colorado School of Mines and the Denver Public Schools. These opportunities are
expected to continue during the remedial activities. The Army also provides used
computer equipment to the public schools in the local communities.
• Emergency response measures: The Army developed a contingency plan for
emergencies many years ago and continually reviews the plan to keep it current with
activities underway. Emergency plans will be part of the post-ROD remedial design
activities. The Parties and the public will be kept informed of these contingency plans as
they are written.
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• Local contractors and workers: The Army has made and will continue to make a
concerted effort, within federal contracting guidelines, to use local contractors and labor
to support remediation activities.
8. Five-Year Reviews
A five-year review may be conducted any time within the five-year period after the finalization of
the ROD and within each five-year period following. The site will be reviewed as a whole during
that review. See also the response to Comment Number 7, above. Five-year reviews are intended
to evaluate whether the response action remains protective of humans and the environment.
Statutory five-year reviews are required no less often than each five years after the initiation of the
remedial action.
9. Prioritization of Remedial Actions
Comment noted. Discussions with the Parties about sequencing remedial activities are ongoing.
Structures Medium
10. Structures Containing Agent
There is not sufficient contamination of the structures to generate an off-site air release. On-site
workers will be wearing protective equipment during remediation to protect them from any on-
site air releases. Therefore, the Army does not anticipate that either the surrounding communities
or on-site workers will be exposed to air releases. Monitoring of the workers and air monitoring
at work site boundaries and RMA boundaries will be performed to ensure safety. In addition,
various dust control measures will be used to ensure no exposures to the surrounding
communities.
11. Caustic Washing of Structures and Soil Containing Chemical Agent
Caustic washing was selected as the preferred alternative for agent-contaminated soil and
structure debris because it effectively treats all agent compounds suspected to be present at RMA
Although caustic washing has not been demonstrated at full scale, the associated equipment is
well-demonstrated and widely available. Implementation problems (e.g., materials handling,
emission control) identified during testing can be overcome through proper engineering controls.
and pilot-scale testing will be necessary prior to implementation to determine the proper treatment
solution. Other treatment alternatives evaluated (e.g., solvent extraction with caustic,
incineration) were not cost-effective due to batch operation and high residual disposal cost or high
capital cost, and had similar or more difficult implementation concerns. Location of the treatment
facilities will be determined during the remedial design.
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Soils Medium
12. Soil Volume Estimates
The human health and principal threat exceedance volumes presented in the Detailed Analysis of
Alternatives (DAA) (Vol. IV, Tables A-2 and A-3) for the South Plants Central Processing Area
are estimated using the agreed-upon 5-ft depth criteria for excavation, and are an exception to the
statement "...between the soil surface and a depth of 10 ft...". Exceedance volumes remaining in
place between 5 and 10 feet include 32,000 bank cubic yards (BCY) of human health exceedance
soil with a 17,000-BCY principal threat exceedance volume. The apparent discrepancies between
the DAA text, Appendix A volume tables, and the Mass Balance Logic-Flow Diagram are due to
overlapping volumes between human health exceedance volume, estimated agent volume, and
UXO debris volume. Volumes presented in the Appendix A tables are total estimated volumes
and are not adjusted for volume overlaps. Material quantities and costs were developed from
adjusted volumes obtained by subtracting the overlapping volumes from the human health
exceedance volume. The Mass Balance Logic-Flow Diagram is correct and in agreement with
these adjusted volumes, with the exception of the surficial soil human health exceedance volume,
which has been corrected to 87,367 BCY (corrected to include firing ranges volume).
Overlapping volumes are discussed in the individual medium group sections (Sections 5-19) in the
DAA (Volumes II and III).
13. Firing Ranges
The two soil remediation areas shown in the October 1995 edition of RMA Update and not
shown in Figure 4 of the Proposed Plan are the Pistol Range in Section 19 and the Rifle Range in
Section 12. These two areas were inadvertently left off Figure 4 but are included in the remedy
The selected alternative includes disposal in the on-post landfill of approximately 2,300 BCY of
lead-contaminated soil from these sites.
14. Slurry Wall Construction
The necessity of dewatering upgradient of the slurry walls for the Complex Trenches and Shell
Trenches will be evaluated during the remedial design If dewatering is included as part of the
final design, the extracted water will be treated at an on-post facility (e.g., Basin A Neck
treatment facility).
15. South Plants Cap/Cover
The selected alternative states that all modeled human health and principal threat volume in the
South Plants Balance of Areas is excavated to a depth of up to 10 feet and disposed in the on-post
landfill. No human health or principal threat exceedances are left in place; therefore, a wildlife
barrier and 4 or more feet of soil cover are not necessarv
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16. Biota Barrier
The broken concrete or cobble from demolished structures will either be landfilled in the on-post
hazardous waste landfill or consolidated under the Basin A cover. The biota barrier for the Basin
A cover consists of a formed concrete layer and does not use any broken concrete or cobble from
the on-post structures demolition, Rubble used for other wildlife barriers will be obtained from
off-post sources.
17. Hex Pit
Subject to the results of treatability testing and technology evaluation, innovative thermal
treatment will be used to treat 1,000 BCY of principal threat material front the Hex Pit.
Solidification will become the selected remedy if all evaluation criteria for the innovative thermal
technology are not met. The remaining 2,300 BCY of material will be excavated and disposed in
the on-post hazardous waste landfill.
18. Southern Lakes
Since the issuance of the On-Post Proposed Plan, a technical working group composed of
representatives from the Army, Shell, State, and EPA has been studying existing data from the
southern lakes and assessing the need for additional action. No additional action has been
determined necessary at this time. Water levels in Lake Ladora, Lake Mary, and Lower Derby
Lake will be maintained to support aquatic ecosystems. The biological health of the ecosystems
will continue to be monitored.
Lake-level maintenance or other means of hydraulic containment or plume control will be used to
prevent South Plants plumes from migrating into the lakes at concentrations exceeding Colorado
Basic Standards for Groundwater at the point of discharge. Groundwater monitoring will be used
to demonstrate compliancy.
19. Confined Flow System Monitoring
The proposed monitoring network was established after having reviewed years of confined flow.
system (CFS) data. Two different reports issued separately by the Army and Shell in 1994
provided extensive information about the wells in the CFS. The Army believes the proposed CF*»
monitoring network is adequate based on existing information. Increasing the frequency of
sampling in the confined aqusfer would not provide information to change that opinion, given the
extremely low flow rate, typically about 13 feet per year.
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Northern Community Coalition
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. *•<•*-
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SENT BY:TRI-OOlNnr H.TH DEPT : 1-19-96 ; 3:35PM ;TRI-COLMY HLTH DEFT- 903 289 0485* 2/ I
Tri-County Health Department
Saving Adam. Arcpcroe and Dou0cx Countle*
M«hfto(var.lyLD.MJ«.
Obector
January 17, 1996
On-Poat Proposed Plan Comments
Program Manager
Bocky Mountain Arsenal
Xttn.t AMCPM-PM/ColOMl B if hop
Building 111-RMX
irc« City, Colorado 00022-1748
Dear colonel Bichopi
Attached are the comentB of the' Northern Community Coalition on the
Proposed Plan* The coalition include* representative of AdaiM County, the
City of Commerce City, south Adane County water and Sanitation District,
School District 14, Tri-County Health Department and RepreaentatiTe Jeannie
Reeaer'i office.
Me are available to diseuae our coamente or anawer gueetiona you nay have.
Feel free to contact mm if you deaire additional diecueaion. WO hope our
comments will be ueeful in bringing to final revolution the matter of the
on-poet remedy. The community continues to support a protective, timely
end effective remedy. The Coalition appreciates the opportunity to comment
on the Proposed Plan.
at, M.P.B., Ph.D.
Deputy Director
9601914-1/1
Administrative Office u 7000 East BeBevtew Avenue a Suite 301 u Pnotewood Cotororln
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SENT BY:TRI-COUNTY HLTO DEPT ; i-is-ae; 3=35P« -.TRI-COUNTY HUH DEPT- aoa 289 MSS* a/ 8
cowans or xm MOKTHIBII caacnrxrr COALZTZOM
OH IBB PROPOSED FLAM fOR CUAMOP OF TBB BOCXT
January 1996
The Northern coonuaity Coalition (HOC) appreciates the opportunity to
comment on the Proposed Plan. For the most part, the Proposed Plan is
consistent with the conceptual Agreement that was developed by the 0.8.
Army* Shell Oil Company, the ftate of Colorado, the Environmental
Protection Agency, and the B.S. fish and Wildlife Service on May 9-11,
1995. As the ffCC has stated in the pact, the renedy outlined in the
Conceptual Agreement satisfies the conmunity's goal for a timely remedy
that will proride long-term protection of public health, wildlife, and the
environment even though it does not actually represent the community's
concept of the ideal cleanup. It is, therefore, in the community's best
interest to accept the proposed remedies so cleanup can be completed as
soon as possible.
nevertheless, the HOC conditioned its support of the Conceptual Agreement
upon the appropriate resolution of certain issues. Satisfactory closure of
these issues has not occurred and/or ie not incorporated into the Proposed
Plan. As a result, the HOC can only support the Proposed Plan if it is
stodified to Include the followingi
1. A SATISFACTORY AtTKRNACT WXTKR SUPPLY.
The HCC's top priority ie to obtain replacement of the water supply
impacted by the Arsenal. The Coalition cannot support a final on-post
ROD unless the renedy selected includes an acceptable replacement
supply of water or alternative cash resolution for future
replacement. The water supply to be provided must Beet the following
eriteriat
a. Reliable, long-tera, fin annual yield of a satisfactory amount
that Includes a quantity sufficient to serv« the Henderson area}
b. Potable water quality;
c. Delivered at an acceptable location for service to the couth
Adams District;
d. Fully authorised and permitted;
e. Completed and delivered in a reasonable period of tiao;
f. Assured by a suitable security mechanism; and
g. long term quality of the eupply is assured by a watershed
protection program.
9601914-1/1-A
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SENT BY:TCI-COWTT HLTH DEFT ; 1-19-96 : 3:36PM ;TRI-COWTY H.1H DEPT" 303 289 0485:* 4/
January If, 1996
Page 2
With regard to the alternate water supply, paragraph 16 of the
Conceptual Agreement providess
The U.S. Army and Shell Oil Company agree to provide or arrange
for the provision of 4,000 acre feet of water, the details of
which will be worked ovt between the U.S. Army, Shell Oil
Company, and SACWSD. If such water is not available, the U.S.
Army and Shell Oil Company will provide payment of an agreed upon
amount of money in lieu of water. This obligation will be part
of the final remedy and will be incorporated into the on-post HOD.
The HOC ha* never agreed that 4,000 acre feet is sufficient to replace
the supply affected by the Arsenal, particularly if that quantity is
also supposed to serve the DZHP plume area Including Benderson.
nevertheless, the nee could support an alternate water supply or an
•in lieu of cash settlement so long ae it is mutually acceptable to
the Amy, Shell, and the South Adams County Water and Sanitation
District (as required by the highlighted language above) and the
selected water supply or cash settlement is incorporated into the
final on-post ROD.
The Army'* Proposed Plan departs from the Conceptual Agreement by
omitting the very crucial highlighted language, requiring SACwaD's
concurrence in the water eupply selection. This omission appears to
allow the Army and Shell to unilaterally decide what constitutes ma
acceptable water supply for the community. This is clearly contrary
to the Conceptual Agreement and unacceptable to the Coalition.
2. A SATISFACTORY SCHtPOLt OF 1NPHMCTTATIOH THAT PMOMTH18
ACTIVITIES OB TfflC BASIS 'pF PUBLIC HEALTH"AND ACTUAL MSK.
Another key concern of the HOC was timely implementation of the
remedy. To be acceptable, the cleanup must be expedited to ensure
that it is completed within 10 to IS years, further, the cleanup must
proceed in a fashion that addresses public health protection first.
With this in mind, the Proposed Plan should ensure that the remedy
proceeds in the following sequencei
a. Alternate water eupply — The firat priority should be to
finalise the agreement to provide drinking water to South Adams
County Water and Sanitation District. Protection of the drinking
water through an alternate supply provides the necessary safety
factor in assuring that the exposure pathway from contaminated
groundwater to drinking water cannot be completed. The
groundwater ie currently the most significant direct threat to
public health offpoet of the AHA.
b. Basardou* Waste Disposal Sit* — The design and construction of
the hazardous waste disposal site should also be commenced as
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SENT BY'TRI-COUNTY HLTH DEPT : 1-18-86 ; 3:36PM JTRI-COUNTY HLTH DEFT- 303 288 0485;f 5/ I
January 19, 1996
Page 3
eoon a* feasible aa it ie key to Buch of the other planned
remediation.
e. Small ligh Risk Project! — The smaller high riak project* with
loss complexity and uncertainty ebould then be implemented to
gain the most benefit for the cent and to gain experience with
oversight, Boaitoring and other issues before ttodertaklng the
major projects.
d. Larger ligh Risk Projects — Once experience ia gained on the
•nail high risk projects, clean up of areas of higher risk with
few uncertainties (e.g., the South Plants area) should be
implemented. This will help ensure that funds are available to
reduce the real risks presented by the
e. other Projects — The low risk, high cost projects should be
deferred to the end. The Basin t wastepile is a good example of
this type of project. Zt clearly involves the most complex and
costly remediation strategy — and likely poses the greatest
potential cleanup riak to workers and adjacent residents, but is
currently stable with a fully effective liner and cap. The
Coalition has stated previously that, with enhanced containment,
the Basin F wastepile could be left in place. The HOC does not
believe that the benefits of excavating the waetopile and
redlsposing the material in a new RCRA compliant landfill are
commensurate with the health and safety risks and the costs of
such excavation and redieposal. Furthermore, the Coalition ie
concerned about the cost growth of such en operation,
particularly in the context of materials handling and
emissions/odor control, consequently, if the wastepile ie not
designated aa a low cleanup priority then uncertainties of cost
growth and the lack of actual experience to define effective
oversight and monitoring of other onpost remediation projects
could result in a significant investment of limited funds for
little value added in terms of risk reduction.
The VCC is currently engaging in a priority ranking exercise for
IMft. The results of that exercise will enable us to present a
more specific proposal to the Parties concerning a balance
between funding anticipated to be available and individual
cleanup project priorities.
3. A SATISraCTORY 'MtMIDIATIOK OVERSIGHT AND MOHITORIHC PBOCMM.
The long term permanence of the remedy will depend, in large part,
upoa the quality of engineering and construction of structures such as
the landfill and the caps that are proposed. To ensure the necessary
high quality of these activities, the Northern Community Coalition
insists upon adequate and effective project oversight by qualified
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SENT BY'TRI-COWIY HLTH DEPT : 1-19-96 : S'STFM ;TRI-COlWnf HLTH DEFT* 303 289 0485:1 6/
January 19, 1996
Page 4
individuals who are responsive to community eonearna about tha
cleanup. It is tha Coalition's poaition that Tri-Oountj Health
Department mat be oloaely involved in oversight activities as tha
community's rapreaentttive for technical and health and aafety issues.
Further, tha MCC will insist on offaite aabient monitoring where
Material* Bight be excavated that eoold releaae noxious and/or
hazardous not contaminants into the air. Tha specifies of offaite
aonitor ing should be addressed with the community'a input.
Additionally* the Medical monitoring committee that has been
•atabliahad must be involved in the continuing evaluation of
Monitoring needs during the cleanup process. The basis and
effectiveness of all planned medical monitoring in providing a clear
cause-effect relationship between IDA contamination and health effects
or changes in bionarkars should be clearly described prior to
performing the monitoring.
4. « SATISFACTORY COMMUKIT* IMPACT ASSISTMfCt PROGRAM.
The Coalition believea that the past activities at the RMa have
stigmatised the local community. As a result real estate property
values have declined, economic and eonmunity growth and development
opportunities have been lost and the financial burden for
infrastructure, services and education has increased as a result of
the presence of M0U To complete the remedy, the Proposed Plan must
address these issues with a satisfactory community assistance program.
Such a program is particularly compelling in this instance given the
racial, ethnic, and income makeup of the local community and the
President's Executive Order on environmental justice (1.0. 12698,
February 11, 1994).
Furthermore, it must be remembered that the ICC played a key role in
getting the parties to even consider a mutually acceptable conceptual
Agreement. Zn the process, the HOC backed away from firmly held
beliefs in order to encourage compromise among the parties and the
stakeholders. Put another way, the MCC elevated tha "common good"
above its particular special interests. Vow that the conceptual
agreement has been achieved, the parties should not turn a blind eye
to these efforts. Rather, like the MCC, the parties should ensure
that the final remedy actually achieves ths "common good." it is not
enough to simply clean up the contamination and ignore the stigma
damages which have clearly been caused by the Km. Damages to the
community have not been addressed. The remedy simply is not complete
without including a program for community impact assistsaee. That
program must includet
a. A public outreach program that educates the public on the cleanup
aetivltiee and the potential risks during cleanup;
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SENT BY'TRl-COWTY HLTH DEFT : 1-18-86 I 3:371* ;1KI-COUNTY H.TH DEFT- 303 288 0485;f 7/
January 19, 1996
Page 5
b. The joint preparation (by the Army and the HOC) of a written
contingency plan including appropriate evacuation procedure*)
e. A ceoBittMnt for the partiea to work with School District
14 to address the long-term impact to the District of lost
property tax revenue fro* the RMA land.
d. A commitment to hire local labor where qualified individual! are
available to fulfill contract labor need*.
5. A SATlsrACTOltf TRUST TOP.
The tract fund vat specifically discussed in the Conceptual Agreement.
This fund ia necessary to address potential future failures and/or
deficiencies in the Proposed Plan and to allow for further cleanup, as
appropriate, with the development of new technologies. Xn short, this
fund is critical to the long-term permanence of the remedy.
«. A BA3IH a QROPHPWATER DlWrCTIHO COMTIHCTHCT PLAH.
The "containment" of contaminants in the Basin A area will be
partially achieved by dewatering the aquifer underlying Basin A. It
is not clear to the HOC that total dewatering will ever occur. As a
result, the Proposed Plan should include a contingency plan. Xf the
aquifer underlying Basin A is not dewatered within 10 years, then the
remedy must be modified to include a slurry wall to bedrock around the
entire Basin A area.
7. TOT BTCKVATIOM OF ALL O> TO1 WASTE IH TM1 W8T1RN TIBK IAKPFIU.3.
The KCC believes that the waste in the western tier landfills is
acting as a continual source of pollution which is contaminating the
South Adams County Water ami Sanitation District's existing water
•upply. In order to be effective, the proposed reaedy at these
landfills must include the complete excavation of all of the waste ia
the landfills. At various times/ the parties have Indicated verbally
that they intend to implement such a complete excavation. However,
given that importance of this issue, the »CC requires that the
complete excavation of waste in the western tier landfills be
specifically described in the Proposed Plan.
•. BOUHDMIY gYSTlMS
for the marginal extra cost relative to the overall strategy, the Army
should give additional consideration to Alternative 3 instead of
Alternative 4. The length of operation of the boundary systems is one
of the more uncertain features of the remediation. Due to the
extremely slow dispersal of contaminants, it may make sense to simply
eliminate the source of the contamination (i.e.. Basin A and South
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SENT BY'TRI-COWTY HLTH DEPT ; 1-19-96 ; 3:38111 JTRI-COLNTY HLTH DEPT- 303 289 0485:* 8/
January 19, 1996
Page •
riant*). Comparison of tba coat of adding the treatment at these two
sites with tha eoat of extending tho operation of th* boundary ayataaa
•ay demonstrate that It !• more offactive to do tha localised
traataant. Zn othar word*, allaination of tba contaminant maaa at tho
Baain A and tooth Planta shorten tha tine that tlw boundary aystems
will have to oporata?
Moat of tho contaminants of concern at the boundary systems have
extremely low solubilities. The regulatory lerala for these materials
are, however, alao very lev. A relatively email amount of this
material in contact with the groundwater could leaoh at a level
requiring treatment action for a very long period of time. While the
data indicate that there ia a down trend of the contaelnanta reaching
the systems, it may be that the contamination levels reach a ateady
etafce above that of the regulatory linit and continue for eone time.
Zf some atajor sources of contamination have been eliminated by XftAs,
etc., there Bay indeed be a reason for the ateady drop in
contamination reaching the boundary. Bowever, if there remain MCI
eourcet of low solubility contaminants in contact with the
groundwater, the water reaching the treatment eyeteai could remain
contaminated for long period* of tine. The failure of dieldrin levele
in the groundwater to chow a decrease over time could be an indication
of thie mechanism.
9. aTROCTDBBS
The alternative ia worded such that structures with a hlatory of agent
use will be demolished, monitored, caustic washed if necessary and
disposal in the haserdoua waste landfill. It appears to Indicate that
if monitoring doea not identify agent, the material will not be washed
but will etill be placed in the landfill. If material from these
straeturee does not indicate the presence of agent it should be used
ae consolidation material for Basin A or diapoeed of off site. If
feasible, in exchange for clean fill that oould be brought en site for
Basin & fill* That remedy may also reduce resources necessary for the
cap/cover to be constructed at Basin A.
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SENT BY:iai-coum HLTH DEPT ; 1-19-95; a:35PK ;TRI-COWIY HTH DEFT-
FAX COVER MEMO
303 289 0485:* It
Deliver to:
Conaentc:
Tri-County Health Department
Swvlng Mom Aiapahoe and Oougkn Courtlw
. (includ. »emo)
r
Af~>*- Dept.
Dept.
llve O(Ae* O 7000 Bast Be«l»vtewAv»rvje D Suite 301 D Er&ewood. Coloraao 80111-1628
303/2204200 D FAX 303/2204208
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCk'V MOUNTAIN' ARSENAL
COMMERCE CITY. COLORADO W:M74S
REPLY TO T ,, ,.._..
ATTENTION OF JuttB 11, 1996
Office of the Program Manager
Mr. Chris J. Wiant
Tri-County Health Department
7000 East Belleview Avenue, Suite 301
Englewood, Colorado 80111-1628
Dear Mr. Wiant:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
Your letter was emphatic in that the period for comments on the On-Post Proposed Plan
should not be extended without good reason and that, if it were extended, no more than 30 days
should be granted. In order to allow additional time for comment without excessively delaying
the Record of Decision, the comment period was extended by 30 days.
Responses to the Northern Community Coalition's comments are enclosed.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Bishop
Colonel, U.S. Army
Program Manager
Enclosures
Readiness is our Profession
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-2-
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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U.S. ARMY RESPONSES TO COMMENTS OF THE NORTHERN COMMUNITY
COALITION ON THE ROCKY MOUNTAIN ARSENAL ON-POST PROPOSED PLAN
1. Alternate Water Supply
The Army believes that the Agreement in Principle regarding a water supply satisfies the
criteria identified by your comment. The Army and Shell have reached an Agreement in Principle,
enclosed with this letter, with South Adams County Water and Sanitation District (SACWSD)
that includes payment of $48.8 million to SACWSD and requires that SACWSD water be
supplied to consenting drinking water well owners within the diisopropyl methylphosphonate
(DEMP, an RMA byproduct) plume by January 1999. In addition, the Agreement in Principle
requires SACWSD to provide 4,000 acre-feet of water to Commerce City and the Henderson
area by 2004. An independent qualified water resource expert will be selected by SACWSD to
direct the selection, acquisition, and implementation of a water supply that'can be operational by
October 1, 2004. The parties involved in the water negotiations believe that the settlement is fair
and will permit SACWSD to secure an adequate water supply to satisfy Commerce City's and
Henderson's water needs. If you have any further questions regarding the water supply, please
contact Mr. Tim Kilgannon of this office at 303-289-0259 or Mr. Larry Ford of SACWSD at
303-288-2646.
2. Schedule of Implementation that Prioritizes Activities on the Basis of Public Health
and Actual Risk
The Army agrees with the basic outline of the Northern Community Coalition's (NCC)
schedule, which is to clean up the higher risk areas first and proceed to the lower risk areas. The
actual time required to complete the cleanup will depend in part on available funding from
Congress as well as on developing and maintaining a cooperative working relationship with the
regulatory agencies during design, construction, and operation of the remedy.
The water supply issue is a high priority, and the Army agrees that timely implementation
is most important. Please refer to the response to Comment number 1 regarding the schedule for
providing the water supply. Landfill design and construction is a prerequisite for accomplishing
other remediation tasks and must be started as soon as possible. Moving the Basin F wastepile i>
a lower priority item because the waste is presently contained.
3. Remediation Oversight and Monitoring Program
It is the Army's policy to use the most qualified personnel to oversee both the construction
and quality assurance/quality control of each project for the remediation, as well as to be
responsive to community concerns. The U.S. Environmental Protection Agency (EPA) and the
Colorado Department of Public Health and Environment (CDPHE) will provide regulatory
oversight. The Tri-County Health Department will be provided opportunities to review
remediation activity.
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4. Community Impact Assessment Program
The Army is currently reviewing state proposals on air pathway analysis and will ensure
that adequate onsite and offsite monitoring occurs during remedial actions that may release vapors
or odors.
In addition, a Medical Monitoring Program has been established. The primary goals of the
Medical Monitoring Program are to monitor any offpost impact on human health due to the RMA
remediation and provide mechanisms for evaluation of health status on an individual and
community basis. This Program will continue until the soil remediation is completed. A Medical
Monitoring Advisory Group (MMAG) has been established to evaluate specific issues covered by
the Medical Monitoring Program. The MMAG is composed of representatives of the Army,
Shell, EPA, CDPHE, Tri-County Health Department, the Agency for Toxic Substances and
Disease Registry (ATSDR), the U.S. Fish and Wildlife Service (USFWS), Denver Health and
Hospitals, and the Site-Specific Advisory Board. The MMAG also includes community
representatives from the communities of Commerce City, Henderson, Denver, Green Valley
Ranch, and Montbello. If you would like more information on the Medical Monitoring Program
or wish to participate as part of the Medical Monitoring Advisory Group, please call Ms. Mary
Seawell of CDPHE at 303-692-3327.
The Army understands RMA has had both perceived and actual negative impacts on surrounding
communities. The Army also believes RMA has made positive contributions to the surrounding
communities. The goal of the Army at RMA is to provide for an environmentally safe National
Wildlife Refuge that will continue to contribute to a positive image for surrounding communities
The Army has a very active public outreach program and will continue to work with the public on
matters regarding the environmental cleanup program until RMA is fully transitioned to a Refuge
The USFWS also has a very aggressive public education program complementing the wildlife
resources and future plans for RMA. The Army will continue to inform and seek input from
elected officials, local chamber groups, schools, stakeholder groups, realtors, and local businesses
regarding activities presently underway and those planned for the future.
As part of the Medical Monitoring Program, public outreach will be the MMAG's
foremost objective. The Army believes that public education will provide a real understanding of
the ongoing cleanup and its associated risks. Also, the Medical Monitoring Plan will include a
contingency plan, which will be based on the RMA wide contingency plan already in effect.
Emergency Response Measures: The Army has maintained a contingency plan for
emergencies for many years and continues to update it as needed. Emergency plans will be part
of the post-ROD remedial design activities. The Parties and the public will be kept informed of
these contingency plans as they are written.
Education and Vocational Training Opportunities: The Army and the USFWS provide
educational opportunities through remediation and wildlife tours, and the Army has recently
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received accreditation for its environmental education program through the Colorado School of
Mines and the Denver Public Schools. These opportunities are expected to continue during the
remedial activities. The Army also provides used computer equipment to the public schools in the
local communities.
Local Labor: The Army has made and will continue to make a concerted effort, within
federal contracting guidelines, to use local contractors and labor to support remediation activities.
5. Trust Fund
During the formulation and selection of the remedy, members of the public and some local
governmental organizations expressed keen interest in the creation of a Trust Fund, as you do in
your comment, to help ensure the long-term operation and maintenance of the remedy. The
Parties have committed to good-faith best efforts to establish such a Trust-Fund, as described in
the ROD. Principal and interest from the Trust Fund would be used to cover the costs of long-
term operations and maintenance throughout the lifetime of the remedial program. These costs
are estimated to be approximately $5 million per year (in 1995 dollars).
It is the intent of the Parties that if the Trust Fund is created it will include a statement
containing the reasons for the creation of the Trust Fund, a time frame for establishing and
funding the Trust Fund, and an appropriate means to manage and disburse money from the Trust
Fund. The Parties are also examining possible options that may be adapted from trust funds
involving federal funds that exist at other remedial sites. The Panics recognize that establishing a
Trust Fund may require special congressional legislation and that there are restrictions on the
actions federal agencies can take with respect to such legislation. Because of the uncertainty of
possible legislative requirements and other options, the precise terms of the Trust Fund cannot
now be stated.
A Trust Fund group will be formed to develop a strategy to establish the Trust Fund. The
strategy group may include representatives of the Parties (subject to restrictions on federal agency
participation), local governments, affected communities, and other interested stakeholders and
will be convened within 90 days of the signing of the ROD.
6. Basin A Groundwater Dewatering Contingency Plan
It appears that this comment refers to "total dewatering" as the dewatering of the
saturated alluvium in Basin A. The partial dewatering resulting from construction of the soil
cover will be a 10- to 13-foot lowering of the water table. As a result of dewatering, the water
table will no longer be in contact with the most contaminated soils, and the groundwater flux out
of the Basin A area will be substantially reduced. Groundwater migrating out of Basin A will be
captured by the Basin A Neck Treatment System and the Section 36 Bedrock Ridge extraction
system.
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7. Excavation of All Waste in the Western Tier Landfills
The Western Tier landfills have never been demonstrated to be sources of groundwater
contamination: however, complete excavation of these landfills is planned and is described in the
ROD. Approximately 6630 bank cubic yards of human health exceedance materials in the
landfills will be excavated and placed in the on-post hazardous waste landfill. The remainder of
the Western Tier landfill materials have been characterized as nonhazardous debris and will be
used as consolidation material in Basin A.
8. Boundary Systems
The Army believes that the Interim Response Actions (IRAs) implemented on-post to
control sources and plumes of contamination, as well as the continued operation of the boundary
containment systems, have been extremely effective in containing and treating contamination from
sources and in treating the contamination that escaped before the IRAs were installed. Evaluation
of Alternative 3 shows that active dewatering does not have a substantial impact on boundary
system operation and that there is limited cost benefit associated with this alternative. The
effectiveness of the selected passive dewatering approach for Basin A and South Plants, combined
with boundary system treatment, will be evaluated during the five-year post-ROD remedy review.
At that time, changes to the remedy will be made as necessary.
The containment and passive dewatering approach will limit the leaching of all soil
chemicals, particularly those relatively low-solubility compounds that preferentially sorb to the
soil. A primary factor in the decision to use soil containment as part of the on-post remedy was
the presence of insoluble compounds in soil.
9. Structures
The NCC's interpretation of how structures materials will be handled is correct. This
waste, even without confirmation of agent presence, falls into the "3X" category based on its
history and must be landfilled in a Resource Conservation and Recovery Act-equivalent landfill,
according to Army regulation.
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME: AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12M DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
zoo® laswoo vira ~- Aia MVI HIANH AJIHV sn otelm m YVJ »S:CT m 95/92/10
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
COOQj
ISSNflOO VRH
Aid «V1 HIAN3 AJWV Sfl
0*62969 COZ XVd SS'CT IHd 96/9Z/TO
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O. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD. AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
lasNnoo
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AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMTTnNG, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. -"
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10-26/01/96
SOOgj 13SNI10D VHH «•*•«• Aid MV1 HIAN3 AIHV Sil 0»6Z969 COZ, XVJ 9S = CT IHJ 96/9Z/TO
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01/26/96 FRI 13:57 FAX 703 6962940
US ARMY ENVIR LAW DIV
RHA COUNSEL
Si 006
20-d
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12-6
Responses to
Environmental Action Group
Comments
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EXHIBIT B
07-O*>0S
FULM
Fuller East Estates %JBV
CUENT
FIRST TAX 10 OTHER TAX 10
TYPE AMOUNT
GMtgoM,B«*T»
6086 &Choatir Way
co 80111
Work*: (303)201.6450
K 4.0
aOmUBrawn
•443Jara*vaRd
Montaon CO 80406
Work*: (303)897-1330
R 4,0
rT.«E.JaonBryaon
1490MifegeR
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EXHIBIT B
OMteJS
RJL23 Fuller East Estates %JBV
CUENT
FIRST TAX ID OTHER TAX 10 T**6 AMOUNT
10644 County RoKlff46
Ctay«vwVkMt CO 80010
14217 Downing 8t
Brtf*>n CO 80601
673Btt»Ct
CvoJStrMm 1180188
Woricfc
Wortcfc (303)450-2222
Woricff: (312)701-4486
44
9.8
R 2.45
Rtdlnk«Mn£.C«tMn
. 104 w. am si
CO 80737
Woritft (303)474-3331
R 44
MohiVrf K. RJnivi
VM tl^««bMrfAM 0^4
I^OV HBITWlpWO nQ.
Rodcvflt MO 20852-1029
Wortcf: 001)8384008
Richard K. Rlran
12361 N.FlMVWiTr.
P»tar CO 801344219
Wertcff: (303)7334X28
ThomMC.«MvttMA.Rodctan Work* (410)358^000
FMcriug MO 21048
LMMon CO 80122
07»1Ckel>Ortw
WMn*«(» CO 80030
Worttf: 003)446-7273
Wort* 003)887-1212
OpUon%
John J. VtodmMr HI, TrMtM
bravooM«Tiwl 2186 Egbert St
f123
CO 80218
Work* 003)427-7941
44
2701E. 112ft Aw.
Thornton CO 80233
Wort* 003)2804068
Option %
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EXHIBIT B
FUL23 Fuller E*«t Ertates %JBV
C"ENT _ FIRST TAX O OTHER TAX ID TVPE AMOUNT
R**iVhnoJr. Work* (303)963-5252 R Z46
13215W.C.R«d8
Fort U^ton CO 80821 :
RotaltLMVbno Workf: (303)88W2S2 R 2.«
1675 W. 113th Aw.
CO 80234
RotortP.Vtono Workf: (303)89«2S2 R 2.45
1675 W. 113th Aw.
W^tminrtr CO 80234
100
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EXHIBIT B
FUL22 Fulter46 Estates %JJV
07-OwHS
CUBIT
FIRST TAX 10 OTHER TAX 10 TVPE AMOUNT
7975 W. 44th Av«.
WhMt Rkfc« CO 80033
Wortcf: (303)423.7142
R 44
PX>.B« 36602
Cotando Springs CO 80037
Work* (501)85W)eie
ll&DaOolilrneUTratfer/CNdm Wortcf: 003)780-2221
780Waahkvtonf14CH
Otntr CO 80203
R 44
PMp « Sunn Evim ft M. Erb
3443 S. Barton Ct
OMWV CO 80231
Wortci:
R 44
EoVwd L & Cwlyne K. G**n*
12206 BrivSt
' KS 66211
Work*:
R 44
•CadU.HiBnin
P.O. Bac 2800
Corana CA 91720
I/toy Ann Hoh«
8243E.PMkvtewAM.
CO 80111
UiraltiG.
221S.G«flald«211
CO 60209
Wortci: (808)277.1010
Wortc* (303)962-7068
Wortc* (303)322-4180
R 44
R 2.45
R 44
EBMHJ.BO
2B7DNMitadSt
OWKV CO 80214
BeottNuM
Aim CO 80013
Wortcfc
Wortc f: (303)8B«107
R 245
R 44
ThmnC.UulhouMr
7206 S. Sundown Ore*
ICMonCO 80120
Wortc f: (303)6806467
R 44
9534503-1/1-B
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EXHIBIT B
FUL22
FulleMS Estates %JJV
CUENT
FIRST TAX 10 OTHER TAX 10 TYPE AMOUNT
State RUM!
1317 StttoJwnpw Court
UiVigMNV 80118
Work* (702)2SM600
CttmE. Morgana Jr.
1147PMfcvfewOnVt
I Rode CO 80104
Work* 003)781-3620
JahnWSfcmPMcal
1244M«1pOMSt
OMMT CO 80204
Work ft (303}G2»«300
1C « Shlrtay F. PeRon
1S544 County Ro«d f40
Ctwy«raW«l* CO 80610
Work*
R 4.9
Perry
16622 W.
Gotten CO 80403
Work* (303)420-4132
R 1225
PMteRomroSchrnlt
4868 Rocky Rd.
BSobranteCA 84803
Work* (510)8344856
R 2.45
Dorothy LRorr*ro
1460 TfMtBML 91436
WMMtCiMk CA 94598
Work*: (303)455-2208
R 2,45
•TMCkoteDrtM
WMbnkwter CO 80030
Work*: (303)887.1212
Cotton % 1
Jam B. Vim
27D1E.112hA«&
Thornton CO 80233
Workf: (303)2604056
Option % 1
82BWMhfe«lonSt
Dvww CO 80203
Workf:
R 4*
100
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EXHIBIT B
BUF22
Buffalo Estates %JJV
CLIENT
FIRST TAX 10 OTHER TAX ID TYPE AMOUNT
•Md Eagb RMOUTCM, T.
154 BlM Sprue* MM
EwrgrMn CO 80430
Work* 003*894191
R 3.7$
MdE*0»ReM>uro«.S.Sri*ri
OtoSccflSntfh 2025 S. Owm Ct
Utowood CO 80227
003)8300100
R 0
Rudolph A. Bwtxv*
8918 Whom Ct
CO 80030
003)373.7244
R 8
1846E.EueHdAMnu>
UBMon CO 80121
Wo** 003)787.3014
R 6
OenJ.Binttu
3»8.
Aurora CO 80013
Wort*
R 5
•UunBtatonv)
29VliBwMtoni
CA 94566
Work* (510)6314829
Brfan BoyinovBty % Chuck MMOO
707N«MlStrM(
WA 993S2
Work* (509)525-1700
R o
•rkn Boymoviky
22014 490th SbMt
Atari Cty 10 50510
Work*
23M980
R S
NnyA-Branton
e040W.39lh.A«.
CO 80033
Work* O03)45M418
R OS
NJ 07871
Work*
R as
TSUMrelStrMt
OWMT CO 80206
Work* 003)321^277
R 8
9534503-1/1-c
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EXHIBIT B
BUF22 Buffalo Estates %JJV
07-Dec46
CUENT
FIRST TAX 10 OTHER TAX ID TYPE AMOUNT
EMM J. to
2S70NMtandSt
OMMT CO 80214
Work*
R 10
RtaColMnKMVMdy
4365EMntt
CO 80033
Work*:
R 23
Rictwtf Rtwnunon
436SEVMMSL
CO 80033
Work*: (303)38^5603
2.S
Scad Mum
37BBS.CiylonWay
Aurora CO 80013
740EwraBSL
CO 80215
Work* (303)6B3-»107
Workf: (303)B38>72»1
ZS
2.5
CtataW.AGriM.Mnen
707N»MlSt
WriiWril WA 08382
Work*: 000)5254661
UmfeJ.McAnincti
CTSBMoiCL
Cwal3bMmlL8018B
11847 LrtapB*
Nortfltom CO 80233
CMmE.Mar0vti.tr.
tRock CO 80104
Workf: (321)701-4406
Work*: (303)538-2836
Work*: (303)781-3520
ZS
25
20600 BarMiDraMi
BrooMaU Wt 53045
873BW«Ct
CvolSlrMm R. 80188
Work*:
Work*: (312)701^405
28
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EXHIBIT B
07-OM46
BUF22
Buffalo Estates %JJV
CUEKT
FIRST TAX 10 OTHER TAX 10 **** AMOUNT
nOHvringlonRd.
RoeMto MD 20852-1029
Work ft (301)8384898
R 8
•lAlMMri If *"
iQafmrnQ Fv FwsWI
12361 N.PhtVtahTr.
Pvtar CO 801344219
Wortcf: 003)7334428
R 0
1908FkumeyRd.
CA 90288
Wortcf: (310)548-2995
MvyPB*»T*Mni
742S.Youtfto«Ct
UkMnodCO 80228
Wertf: (303)571 -3857
R 0
Gettm CO 80401
Wortcf: (303)2364751
R 0.5
. Ctaberah K TadaM
3354S.Fk»MrStrMt UnlfSS
Uamiood CO 80227
Wortcf:
R OS
AnbMt»M.T*taaniftJ.Nartand Wortcf:
Acton CA 93610
R OS
7858S.HKTlMnCircta
UBMon CO 80122
Wortcf: (303)9774080
R 5
DonridH.tMvtoTivmn
11 W«fcom» Rd.
NJ 07982
Wortcf:
R 0
DonTbran
1371KihHJlMilOrtM
HA 98734
Wortcf: (808)2824142
R 5
8791 Cfeobi OrtM
Wartrtrmer CO 80030
Wortcf: (303)887-1212
R 0.825
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EXHIBIT B
BUF22 Buffalo Estates %JJV
FIRST TAX ID OTHER TAX ID
TYPE
Johnl. Vfeno Work* (303)2804066 R«guto% 0.825
2701 E. 112th AM.
Thornton CO 80233
CMiT«dY««aE¥ilMUuYanB Worts f: R 5
SnSuNfMOritt
Oddw CO 80401
100
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER IOR ROCKY MO' STAIN ARSENAL
CITY. COLORAPO SY:: ::-(•;
REPLY TO
ATTENTION OF.
June 11, 1996
Office of the Program Manager
Fuller East Partnership
Fuller 45 Partnership
Buffalo Estates Partnership
General Partnerships
Mr. John J. Vandemoer
Mr. JohnB. Villano
Managing and General Partners
8791 Circle Drive
Westminster, Colorado 80030
Dear Mr. Vandemoer and Mr. Villano:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
In response to your comment about an alternative water supply, the Army and Shell Oil
Company have reached an Agreement in Principle, enclosed with this letter, with South Adams
County Water and Sanitation District (SACWSD) that includes the payment of $48.8 million to
SACWSD and requires that SACWSD water be supplied to consenting drinking water well
owners within the diisopropyl methylphosphonate (DIMP, an RMA byproduct) plume footprint
by January 1999. In addition, the Agreement in Principle requires SACWSD to provide 4,000
acre-feet of water to Commerce City and the Henderson area by 2004. The parties involved in
the water negotiations believe that the settlement is fair and will permit SACWSD to secure an
adequate water supply to satisfy Commerce City's and Henderson's water needs. If you have any
further questions regarding the water supply, please contact Mr. Tim Kilgannon of this office at
303-289-0259 or Mr. Larry Ford of SACWSD at 303-288-2646.
Readiness is our Profession
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-2-
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Eugene H. Bishop
Coldnel, U.S. Army
Program Manager
Enclosure
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
ZOO® IHSNnOO VKH -~ Aid MV1 HIAN3 AJWV Sil 0>6l969 tOL Tfd »S:CT IHJ 96/9Z/TO
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
coo®
via «•«•«- Aid Min HLVNH AHHV sn
062969 COZ IVJ SS-'CT IHJ 96/92/10
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
laSNnoD
0*62969 C
-------
AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. -"
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10 - 26/01/96
laswoo via «•«-«• AIQ in HIANH AMHV sn omseg coz xvj 9s:ci iaj 96/92/10
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League of Women Voters
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I
THE LEAGUE
OF WOMEN VOTERS
OF COLORADO
1410 Cram. B-204
Denver. Colorado 80203
.W86XW37
On-Post Propo*ed Plan Comment*
Program Manager
Rocky Mountain Arcana1
Attn: AMCPM-PM/Col. Eugene H. Bishop
Building 111 RMA
Commerce City, CO 80022-1748
Colonel Bishop,
The League of Women Voters of Colorado must congratulate you
on your efforts to engage the public in the decision-making process
which has led to the On-Post Proposed Plan. Rocky Mountain Arsenal
has moved from a facility which refused public admission even to
Technical Review Meetings to one which now pays for newspaper
advertising in order to encourage participation. Issues under
discussion have been brought out into the public whereas in the
past they were kept under wraps until resolved by the Parties.
Hopefully, the final decisions will be more acceptable to the *
public because their concerns have been answered.in the process.
Our comments have taken the form of questions which we feel
•ust be answered in the Record ; of Decision (ROD). Specific
contingency and review plans must be built into the ROD in order to
demonstrate that these important steps have been carefully planned.
1. If "Placement of hazardous wastes into the Corrective
Action Management Unit will not constitute 'land disposal' as
defined by RCRA" (page 9) what criteria will be used?
2. Will 4,000 acre feet of water completely replace lost
sources of well water? How much money will be paid if water is not
available? Will it include costs of water systems or only the
water? Who will be parties to the agreement? Will there be
payment for economic loss is adequate safe water is not available?
3. One of the more reassuring aspects of the Proposed Plan is
the establishment of a trust fund for future expenses. However we
feel that the tentative nature of the trust fund wording offers
little promise of future commitment. What if proceeds are
inadequate to cover costs of future operation, maintenance and/or
contamination in spite of remediation? If a trust fund cannot be
established, how will this be paid for? • . :
4. If in-situ solidification or any other technology doesn't
work and contamination plumes continue to move or to increase in
contamination levels, what are the back-up plans?
9535303-1/1
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5. Bow can medical and biological monitoring be designed to
catch early signs of system failure? What steps are to be taken in
case of future impact?
6. If innovative technologies are used what is the back-up
procedure? How will the public be involved in selection of
technology and back-up plans?
We again congratulate you for your impressive public
involvement effort during the past year or so. We cannot over-
state the importance of continuing that involvement throughout the
selection/ implementation/ monitoring and evaluation processes.
rhank
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOl ;\TAIN ARSENAL
COMMERCE CITY. COLOR APO .W:;.174S
June II, 1996
REPLY TO
ATTENTION OF:
Office of the Program Manager
Ms. Marilyn Shuey
The League of Women Voters
of Colorado
1410 Grant, B-204
Denver, Colorado 80203
Dear Ms. Shuey:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
Responses to your specific comments are provided below.
1. U.S. Environmental Protection Agency (EPA's) goal in establishing the Corrective
Action Management Unit (CAMU) Rule, which has been adopted by the State of Colorado in the
Colorado Hazardous Waste Management Act (CHWMA), was to "provide remedial decision
makers with an added measure of flexibility in order to expedite and improve remedial decisions"
while "existing closure regulations and requirements for [Resource Conservation and Recovery
Act] RCRA-regulated units, which require closure to occur in a manner that is protective of
human health and the environment, remain in effect." Purpose and context of the CAMU Rule 58
Fed. Reg. 8659 (1993) (to be codified at 40 C.F.R. Parts 260, 263, 264, 265, 268, 270 and 271).
The on-site landfill that is central to the CAMU will meet all CHWMA landfill siting,
construction, monitoring, and closure requirements.
2. The Parties to the On-Post Record of Decision (ROD) have determined that the 4,000
acre-feet water supply is adequate to serve as an additional layer of protection to people north of
RMA in the unlikely event that all the caps/covers, liners, and multiple groundwater treatment
systems were to fail. The Army and Shell Oil Company (Shell) have reached an Agreement in
Principle, enclosed with this letter, with South Adams County Water and Sanitation District
(SACWSD) that includes payment by the Army and Shell to SACWSD in the amount of $48.8
million and requires that SACWSD provide the water to consenting drinking water well owners
within the diisopropyl methylphosphonate (DIMP, an RMA byproduct) plume footprint by
January 1999. In addition, the Agreement in Principle requires SACWSD to provide 4,000
acre-feet of water to Commerce City and the Henderson area by 2004. The payment will cover
the water distribution system as well as acquisition of the water supply. The Army, Shell, and
SACWSD believe that the settlement is fair and will permit SACWSD to secure an adequate
Readiness is our Profession
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-2-
water supply to satisfy Commerce City's and Henderson's water needs. If you have any further
questions regarding the water supply, please contact Mr. Tim Kilgannon of this office at
303-289-0259 or Mr. Larry Ford of SACWSD at 303-288-2646.
3. During the formulation and selection of the remedy, members of the public and some
local governmental organizations expressed keen interest in the creation of a Trust Fund, as you
do in your comment, to help ensure the long-term operation and maintenance of the remedy. The
Parties have committed to good-faith best efforts to establish such a Trust Fund, as described in
the On-Post ROD. Principal and interest from the Trust Fund would be used to cover the costs of
long-term operation and maintenance throughout the lifetime of the remedial program. These
costs are estimated to be approximately $5 million per year (in 1995 dollars).
It is the intent of the Parties that if the Trust Fund is created it will include a statement containing
the reasons for the creation of the Trust Fund, a time frame for establishing and funding the Trust
Fund, and an appropriate means to manage and disburse money from the Trust Fund. The Parties
are also examining possible options that may be adapted from trust funds involving federal funds
that exist at other remedial sites. The Parties recognize that establishing a Trust Fund may require
special congressional legislation and that there are restrictions on the actions federal agencies can
take with respect to such legislation. Because of the uncertainty of possible legislative
requirements and other options, the precise terms of the Trust Fund cannot now be stated.
A Trust Fund group will be formed to develop a strategy to establish the Trust Fund. The
Strategy group may include representatives of the Parties (subject to restrictions on federal
agency participation), local governments, affected communities, and other interested stakeholders
and will be convened within 90 days of the signing of the ROD.
4. The extensive site-wide monitoring program that is planned will provide early
detection of any problems with either soil or groundwater remediation. Additionally, the required
periodic five-year review of the remedy will evaluate whether the remediation is effective and
remains protective of human health and the environment. Alternate remediation technologies will
be substituted or systems will be added if soil or water problems are discovered.
5. Environmental rather than medical and biological monitoring will be used to detect
early signs of system failure. The environmental monitoring program includes soil, groundwater,
and air monitoring.
A Medical Monitoring Program for the surrounding communities has also been identified as pan
of the Proposed Plan to measure health effects, if any, during the remediation. The primary goals
of the Medical Monitoring Program are to monitor any off-post impact on human health due to
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the RMA remediation and provide mechanisms for evaluation of human health status on an
individual and community basis. This Program will continue until the soil remediation is
completed. A Medical Monitoring Advisory Group (MMAG) has been established to evaluate
specific issues covered by the Medical Monitoring Program. The MMAG is composed of
representatives from the Army, Shell, U.S. Environmental Protection Agency, Colorado
Department of Public Health and Environment, Tri-County Health Department, U.S. Agency for
Toxic Substance and Disease Registry, U.S. Fish and Wildlife Service, Denver Health and
Hospitals, and the Site Specific Advisory Board. The MMAG includes representatives from the
communities of Commerce City, Henderson, Denver, Montbello, and Green Valley Ranch. The
League of Women Voters is also represented on the MMAG.
6. Innovative technologies will go through necessary tests prior to implementation. The
public (stakeholders) has been included in discussions of the selected remedy. If it became
necessary to modify the selected remedy, an Explanation of Significant Difference or Amendment
to the ROD would be issued and would be available for public review and comment.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Colonel, U.S. Army
Program Manager
Enclosure
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FTNALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
zooia lasunoo via -«•*• AIQ *n HIANS Airav sn oisISSs SOL rvj >S:CT i&i 96/92/10
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT .
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
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Om969 tOL
SS=CT IHd 96/9Z/IO
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O. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
j. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT is
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
AW I sn
0*62969 C0£ IVJ »S:CI ItU 96/9Z/TO
-------
AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENtS OF STATE AND FEDERAL LAW. ^
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10 -26/01/96
lasmoo via «•«•«• Aid «n aim AJWV sn o»ez969 SOL ivj 9s:ci IHJ 95/92/10
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01/26/96 FRI 13:57 FAX 703 6962940
US ARMY ENVIR LAW DIV -.-.-» RMA COUNSEL
Q 006
20'd
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League of Women Voters
Adams County
Colorado
On-Post Proposed Plan Comments
Program Manager
Rocky Mountain Arsenal
Attn:AMCPM-PH/Col. Eugene H. Bishop
Building 111 - RMA
Commerce City, CO 80022-1748
Gentlemen,
Thank you for the opportunity to provide comment regarding
the proposed remediation of the Rocky Mountain Arsenal.
As you reviev the options before you, ve urge you to
consider affected community appeals for adequate water
supplies and delivery systems so those stakeholders can plan
for their futures vith confidence.
We support a medical monitoring program that not only seeks
to anticipate and identify problems but also makes such
information readily available to the public in a timely
manner.
We ask that all parties be vigilant in their duties, meeting
or exceeding those requirements regarding the disposal of
haxardous waste. And that the remediation of all
contaminants be accomplished with the welfare of our
citizens as your uppermost consideration.
Finally, we encourage ongoing dialogue between the..
parties and stakeholders as a way to build a mutual respect
and consideration that ultimately translates into a shared
vision for the peoples/ land and natural resources impacted
by the activities at the Rocky Mountain Arsenal.
Respectfully,
9535302-1/1
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REPLY TO
ATTENTION OF;
DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOUNTAIN ARSENAL
COMMERCE CITY. COLORADO S002M 748
June 11, 1996
Office of the Program Manager
Ms. Gerry Sarconi
League of Women Voters
Adams County Chapter
2681 E. 98th Avenue
Thornton, Colorado 80229
Dear Ms. Sarconi:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
The Army and Shell Oil Company (Shell) have reached an Agreement in Principle,
enclosed with this letter, with South Adams County Water and Sanitation District (SACWSD)
that includes payment of $48.8 million to SACWSD and requires that SACWSD water be
supplied to consenting drinking water well owners within the diisopropyl methylphosphonate
(DIMP, an RMA byproduct) plume by January 1999. In addition, the Agreement in Principle
requires SACWSD to provide 4,000 acre-feet of water to Commerce City and the Henderson area
by 2004. The Parties involved in the water negotiations believe that the settlement is fair and will
permit SACWSD to secure an adequate water supply to satisfy Commerce City's and Henderson's
water needs. If you have any further questions regarding the water supply, please contact
Mr. Tim Kilgannon of this office at 303-289-0259 or Mr. Larry Ford of SACWSD at
303-288-2646.
A Medical Monitoring Program for the surrounding communities has also been identified
as part of the Proposed Plan to measure health affects, if any, during the remediation. Elements
of the Medical Monitoring Program may include medical monitoring, environmental monitoring,
or health/community education. Environmental monitoring will be used to evaluate the
effectiveness of the remedy. The primary goals of the Medical Monitoring Program are to
monitor any off-post impact on human health due to the RMA remediation and provide
mechanisms for evaluation of human health status on an individual and community basis. This
Program will continue until the soil remediation is completed. A Medical Monitoring Advisory
Group (MMAG) has been established to evaluate specific issues covered by the Medical
Monitoring Program. The MMAG is composed of representatives from the Army, Shell,
U.S. Environmental Protection Agency (EPA), Colorado Department of Public Health and
Environment, Tri-County Health Department, Agency for Toxic Substances and Disease Registry.
Readiness is our Profession
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-2-
U.S. Fish and Wildlife Service (USFWS), Denver Health and Hospital, and the Site-Specific
Advisory Board. The MMAG also includes representatives from the communities to
Commerce City, Henderson, Denver, Montbello, and Green Valley Ranch. The League of
Women Voters is also represented on the MMAG.
The Biological Advisory Subcommittee is currently deciding which chemicals to use to
evaluate wildlife health at RMA.
The Army is proud of its success in cooperating with the State of Colorado, Shell, EPA,
USFWS, and local stakeholders to arrive at a Record of Decision to remediate RMA, and we look
forward to working with the stakeholders during the remediation as well. As you know, the
ultimate goal of this process is to establish a National Wildlife Refuge at RMA, and the Army
intends to maintain the land and natural resources so that the Refuge may flourish.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
u^-
Eugerie H. Bishop
Colonel, U.S. Army
Program Manager
Enclosure
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
zoo 8 laswnoo via ~«- Aia «vi HIANH AIHV sn otezm m m »S:CT IEJ 86/92/10
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOKUPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WELL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT -
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
coo®
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0*62969 COi IVd SS:CT IHd 96/9Z/TO
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
13SMOD VKH ~~ A|fl MV1 8IAM3
sn om969 toz rvj BS:CT iaj 95/92/10
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AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. "•"
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENTS ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10-26/01/96
BOOB lasNiioo via «•••«- AIO MVI HIANH AMHV sn omses m ivj 95:CT IHJ BS/SZ/U
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01/26/96 FRI 13:57 FAX 703 6962940
US ARMY ENVIR LAW DIV
RMA COUNSEL
3 006
20'd TbJ.01
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Sierra Club
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December 7,1995
Rocky Mountain Arsenal Subcommittee
Rocky Mountain Chapter Sierra Club
14S2NorthcrestDr.
Highlands Ranch, CO 80126
Colonel Eugene H.Bishop
Building 111- Rocky Mountain Arsenal
Commerce Chy, CO 80022
Sir
The Rocky Mountain Subcommittee of the Rocky Mountain Chapter of the Sierra Club
requests that an extension be granted for the submission of comments regarding the
Proposed Plan for the Rocky Mountain Arsenal On-Post Operable Unit We ask that this
extension be for no less that 60 days. This will greatly aid us in our research on this
important document
Thank you for your consideration in this matter.
Sincerely,
Sandra A. Horrocks
RMA Subcommittee Chairperson
9534502-1/1
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SIERRA
DEC 18 '95 e4:£3PM CDC 301 P.I
Rocky Mououfn Chapter
777Gr»ntStrtt< Suiu606 Deaver, Colorado I020J 30j.|6|.|||9
December It. 199S
Colonel Eugene KBiahop
Building 111 -Rocky Mountain Anenal
Commerce Gty. CO 10022
Sin
It has become apparent to the Rocky Mountain Chapter of the Sierra dub that
replacement water for the Off-Pott area of the anenal should be dealt with in the Off-Port
RODandnottheOn-PoatROD. Tbti was not bow the Off-Post area wai approached
initially. However, problems have arisen which are causing u« to eaO Into question the
direction given to ui to consider Off-Post replacement water part of the On-Post ROD.
To begin, we are not quite sure why replacement water in contaminated areas Off-Post has
taken this long to resorv*. It was proven many years ago that wefls were contaminated,
and h should have been a matter of integrity for the U.S.Anny and Shell Oil Company to
insure that these areu had a perinanem1 alternate water source at that time. The amount
of water replaced should have been equal to the amount of water "^Trf'
Secondly, in Mndtffit we do not understand why replacement water, left to be taken care
of during the ROD process, should not have been handled in the Off-Post ROD. After all,
the areas where this water is needed is in the Off-Post area. Also, the Off-Post Plan was
considering what to do about contaminated underground water, fi only makes sense that
these problems should have been considered as one, which they are.
Additionally, given the net that the replacement water is being handled as a part of the
On-Post ROD, specific details regarding this water should at feast be given. Merely
stating that 4000 A. ft, qf water wffl be supplied for thli purpose is not enough. This is
not equal to the amc^ of water available to u* surrounding co^^
damaged. It also does not include any detail of how this water would be divided thus
opening up aO kinds of potatbflhi* for back-room deals to be made periiapf resulting in an
unfair percentage of water being given to one community over another.
Finally, making replacement water a part of the On-Post ROD has resulted lame
appearance mat It Is being used as a trading piece for the amount of clean-up that should
be taking place on the Rocky Mountain Arsenal (RMA). in otherwords, h seems that tf
rnty leaders want enough wat» to supply their constituents theo they must be
wllUng to hwer their voices fa asking for RMA to be properly cleaned.
The Rocky Mountain Chapter of the Sierra dub is only asking for what is fair following
the uif jtwf sotwgnfrrt c^v^mffl •*»«" of one of the most basic rights of all f&aakmd...Bn
9535301-1/1
.,'
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ICC 18 '95 B4.-23R1 CDC 201
P. 2
that thU iwisiofl
ific information Rich u the communities which win receive
replacement water and a detail description of bow much each community will receive. We
tee this as the only fair and rational way in which to handle this matter.
We trust that you wffl give your utmost attention to these concerns, and thaiwewiD
receive a response to this letter.
Youn truly,
Heidi Arbury
Chairperson - Rocky Mountain Chapter Sierra Club
(\ ' A 0
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^^^^^••^^•i^^^^T^**^^ B> ^ ^^^r^^^k^^M^^^^^n^^^^'
BriaaAndreja "
Chairperson • Social Justice Committee
Chairperson • Water Quality Committee
SueMtret
Chairperson • Hazard Waste Committee
-^-Hr
Sandra Gbrrocks
Chairperson -RMA Subcommittee
oc: Bin Yenowtafl, Regional Administrator, Raf. Vffl, Environmental Protection Agency
Hoy Romer, Governor, State of Colorado
Gail Scboettler, Lieutenant Governor, State of Colorado
Judge Dana, Judiciary Arbitration Group
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JPM 19 '96 Bi:4aPH CDC 2BL._ ' P.2
Rocky Mountain Chipwr
777GrantStraet Suit*606 D.nver.Colorado80203 X>}.|6| .f||f
SIERRA
January IS, 1996 .
On-Port Proposed Plan Comments
Program Manager
Rocky Mountain Anenal
Altn.: AMCPM-PM/ Col, Eugene H. BUhop
Building 111—RMA
Commerce City, CO 80022-1748
Sir:
The Rocky Mountain Anenal Subcommittee of the Rocky Mountain Chapter of
the Sierra Club hat reviewed the Proposed Plan for the Rocky Mountain Arsenal On-Post
Operable Unit. The following points represent our comment! regarding thii document Bach
area of concern it proceeded with t descriptive subtitle of that area.
Water, Structure! and Soil
a. Water
Our viewpoint regarding the alternatives preaeoted for water if moit inline whh that presented by
Alternative 3, We would add that additional treatment, beside* carbon filtering at the boundaries
and other processing plants, needs to be added due to those chemicals which are not currently
being treated such as NDMA and inorganic compounds. Also, there is no mention of the
hazardous plume which has recently been identified moving southward off the Anenal.
Remediation of this plume should be a part of the ROD.
Also, we feel that the resolution of community water replacement ihould have been rectified many
yews ago. The current amount of water offered for replacement is neither adequate nor
«erj»pf iiMe, T>e water replaced ahauld be equal to the amount \uhieh WM e^fffaitnin^H Ky fte
Arsenal over the last 54 years. The amcftmt for each affected commffihy should be stated up
front to there is no possibility of one community making aide deals for additional water at another
cooununhy'i expense. The amount of water should also be taken out of any negotiations for
remediation at RMA since h is not a negotiable commodity.
9601913-1/1
rtcveltd pp*
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JPM 19 '96 01:48PM CDC 201 P.3
Rocky Mountain Chiptor
777 Grant Street Suite 606 D«nver. Colorado 1020) 30J.tt|.|||9
SIERRA
b. Structures
Alternative 3 best roceti our expectations for removal of structures. We ire concerned that
remediation of Basin A win not be satisfied by adding additional contaminated soils and structures
to help provide t cap for that area. Acceptance of Alternative 2 would mean supporting the
capping of Basin A which we are unable to do. We do support the recycling of as much buBding
material aa possible after appropriate detoxification. Those building materials remaining should
then be placed in the on-she landfill.
We do have a question regarding the number of structures that will be left standing following
remediation. What will 47 structures be used for on a wildlife refuge and which structures are
they?
c. Soil
We cannot fully support any alternative proposed for soil remediation. Most of the remediation
types proposed do not include treatment If soils are not detoxified, we presume that remediation
of this she will be revisited in the future thus causing further problems for residents in the vicinity
ofRMA. We see this as an unnecessary expense to taxpayers.
During the winter of 1995, we participated in the instruction on alternative cleanup technologies.
We saw several methods that could be applied at tibe Arsenal, in particular the Eco-Logic
process. It would seem more cost effective to do a slower cleanup (due to the additional initial
cost) that would be permanent and not have to be funded again in the future.
Trust Fund
The only guarantee we have that there may be any money for any lingering future problems at
RMA is a trust fund. We have been asking that this be guaranteed for several years. Although
the Proposed Plan does mention this tiust fund, H does not guarantee that it could be
implemented. We want to see a guarantee that it win be a reality.
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JAM 19 '96 81:49PM CDC 201 P.4
Rocky Mountain Chapter
777 Grant Street Suite 606 Denver, Colorado S0203 J03-I6I.III9
SIERRA
Health Monitoring
We are concerned that monitoring of the populace surrounding RMA has not been ewried out in
the most scientific manner. We have been unhappy with the studies which have been conducted
byATSDR. We fed that studies of this type could be carried out better by the state health
department of Colorado in collaboration with a volunteer advisory board. We do believe that the
populace in mat area deserves some type of assurance that Off-Post medical monitoring wiD be
long-term and so be maintained bom during and after remediation.
Additionally, medical monitoring should be designed to satisfy apprehensions about the
remediation itself and confirm that the health of the surrounding populace is not being
compromised by residence adjacent to RMA. Community trust in this program is essential tor
medical monitoring to be successful. In otherwards, we wish to see a more thorough and
scientifically accurate monitoring program than what we have seen ATSDR provide so far.
Wildlife
Wildlife health and welfare if of particular interest to us, especially when coniidering that RMA
has been designated as a wildlife refuge. We are pleased to see that wildlife monitoring is
progressing at RMA after a very slow initial start. We would have thought that some progress on
those studies would have been included in this plan to inform the public of the type of research
being conducted regarding the effects of the toxic wastes on the wildlife. An explanation of what
win be done to protect the wDdlife during the remediation should also have been included. We
wiQ be interested in reviewing reports of animal health during and after the remedial period to
evaluate any differences in heahh.
Additionally, the Proposed Plan does not mention which chemicals of concern will be used to
determine animal heahh. We anticipate that this means all possible contaminants will be reviewed
for wfldlife health effects. For example, recent studies indicate elevated levels of the 2,3,7,8-
TCDD dioxin were detected In wildlife residing in the South Plants area. This dioxin testing along
with testing for other chemicals of concern should be continued b order to provide am ongoing
evaluation of overall wildlife heahh. How can this be guaranteed?
*cretort pip*
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JflN 19 '96 81:49PMiCDC 201 —- P.5
SIERRA
Rocky Mountain Chapter
777 Grant Street Suite «* Denver, Colorado 1020) 503-161. Ill 9
Overall Plan
There is one very great diuppointment with fhil document. It seems that once again the public is
being spoken to out of two sides of the government's mouth. From one side we are being told
that the purpose of the Proposed Plan is 'so that the public can participate in the alternative
selection process.' However, ai we read further, the other side of the mouth mentions a
'Conceptual Remedy* that has already been agreed upon. It seems somewhat odd that we, the
public, are being footed to join in a selection process mat has already been completed. ThU
Conceptual Agreement should have been explained in greater detail. We are including our
comments dated May 30.1995 regarding that agreement as an attachment. We want them to be
included In the ROD along with this document.
Also, the alternatives presented did not include the many types of technologies reviewed for
possible use. These techniques were not presented as the viable considerations that they became
in the alternatives summarized in this document.
We think you for your attention to our comments.
Sincerely,
Sandra A. Hbrrocks
RMA Subcommittee Chairperson
cc EPA
CDPHB
Shell Oil Company
USFWS
O
••cycled pcpw
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JflN 19 '96 8i:49PM CDC 201 . p-6
SIERRA
t*T T TT>
I I I IK
May .30, 1995
To Tie United States Army. Shell Oil Company, The Environmental Protection
Agency, and the State of Colorado, '
The Sierra
document generated
would like n address
CTahat ttauet
1) Lack of PfTOKifJFHf?n! After spending numerous months reviewing
documents and technology alternatives, we are discouraged to see a plan which
primarily yi^**** fftnTi!nTr**f as the lead remediation t***hniflw. rather *h*p
treatment of the chemicals of concern. We are of the opinion that innovative
technologies show potential utility for clean-up at several of die areas currently
slated for proposed landfilling and/or capping. We are concerned mat chemicals
manufactured on RMA have the potential to contaminate soil and water for many
generations.
2) ^QdjQ]l_Uji]iz&tifi&L During the clean-up alternatives public f^Fnirifn*
period, several of our committee members recommended a landfill be shed on the
kMA in lit* of effective treatment remedies, However, an important component
of our recommendation appears to have been overlooked. .It was proposed that
the landfill serve u an interim measure until u effective technology became
available in the future. The current proposal indicates thai the landfill woold serve
as a permanent remedy. This is not acceptable to the Sierra Qub. While we see
dw need to build a landfill* we would like to see it utilized only until adequate
technology becomes available for detoxification of the chemicals of concern.
In addition, we believe the current sanitary landfill should be;
and all waste placed into die new stata-of-the-art landfill. In order' to guarantee
the safety of our future generations, we believe these requests moat be addressed.
3) Tm« pppft To guarantee adequate financial IMOUMM will h« «v«,l»>,T> fer
the completion of etc clean-up, a crust fund most be established, lie Sietn dub
aees the creation of this fund as a commitment from the responsible parties that
they are seriously ftftmmif*^1 to the surrounding community and to the
of fjftip Supctfund aitc.
4) RfiT.irch nnrt flavilrrPfftf' Th* concept of research being'
conducted on the RMA ia very important to me Sierra dub. We envision the
9601913-l/l-A
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19 '9G 0i! 50PM-ere aai p-7
SIERRA
TTTGnMfcmc Sufetti DMVfr.C^Md.10201 J03.tft.itl9
Arsejul serving as a natioiisltite for JDMvatiw Ir
Is obvious'from-the.lack of defoxirying technologies in the Agreement
~ ,^1*^: . ' a needed for effective sad
*
* •^^T^^M^^HI^^PIV «^^VW ••V^^^B* ^HIVBI^^-^^H^HB WV^r^B* ^""^ ™» T^'^^^^r^*l »^« *^^™^VV»* ^ VW^
safe rffriif^JiTf**** of chemicals irch as Dieldrin> We are blessed to lean that the'
•Hex Pits aty -serve as A site for teehnoloiy evalnation and we fully aupport thii
idea, ' .
5) ArMMl Tann- We believe it would be prudent of die principle parties to
request » halt to public toon on RMA during toe clean-up process. As this site
clean-up Involves movement of hazardous chemicals, the only safeguard against
visitor exposure is stoppage of tours during the remediation period.
6) WiM'fftffghfofc We would like to advocate protection of wildlife
habitats during die remediation efforti. As the Arsenal will become a Wildlife
Refuge upon clean-up completion, an assurance of adequate and un-
evvntiZntnmTrA habitat tones duiug the pfoceu must be provided.
7) PitmnTegriap The issue of dioxin contaminatioo on (he Arsenal has
lo date not been effectively addressed. The generation of dioxins is possible from
incomplete combustion processes or as by-products of chemical manufacturing.
Both of these scenarios occurred on RMA. To improve public credibility, it u
essential that die PRPs initiate soil sampling for dioxins.
Site Sneciflc Issues
1) fljudiLA: Foremost, we an concerned mat no treatment of soils will
take place in this basin prior to capping the area. The potential for ground water
contamination might be possible for an indefinite period of rime. la ail previous
proposals, a de-watering and/or starry waH baaierwurecommeadfld. We would
advocate dewaierlng of Basin-A prior to capping. Also, many yards of soU win be
~ ~ 'toaaiment, we would like to see solidification of
all soils before adding to dusoasin to ensure lack of chemical migration
.Although a treattneM technology isproposed for thi* site,
ition the effectiveneii of soil solidification, lu's method was not
\\y discussed during the innovative technology Tmhur Also, because.
only the first tea feet wBIfaa treated, the potential for ground water
is possible ftorn chemical movement in the lower soil depths.
O^
^^^^"
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JflN 19 '96 Bi:SBPM CDC 201 .. ... P.8
SIERRA
SulfctMf Dewer.Coleitdeia»J
3) Paring W««tBoi1e: We ixe pleased due the wastepOe will be stored in t
*« _ ^•^^^^•^^•••^•^•'•••ei^se". . , _ ^ * _ _ _ _ 4» '•_.*'. *«Y • «^ _j» _•_,* *^' *•_ *
celled landfill, however, we have iwo areas of concern: (1) Jack of detoxtfiratioru
and (i) odor abatement, "lie detoxification issue was previously addressed in
^^^ %. *i T *T 'TIT ^. ^ . '.•• • • •_..__* _ ^_»_ _ • i.T *• t ^ - •
flobil istncf'^1* Odor |dfenitiQ& during 'exctvtdon of i&t wutipile ii a topic
which must be tddreued. We would like to tee lir caUfion moniEorinf devices
In place for the dunoon of the wtstepile excavtdoh. For the protection of the
surrounding communities, an enclosure nurouodiof the excavation sites is
advocated.
4) South Plants: The proposed excavation to 5 feet should be increased to
ten feet to be fully protective of human health.
S) North Plants: .la the Conceptual Ageeemeat Document there is no
indication of the depth of soil which will be excavated for placement in the
landfill We would encourage the parties to adhere to a depth no less than 10 feet
6) Pte/Trgneher The Army and Shell trenches may contain extremely
hazardous materials. We would agree with the proposal of expanding the slurry
walls prior to capping the sites.
The proposal of utilizing an innovative technology tor the remediation of
the Hex Pits is supported by the Siena Club. We would like to see more
information as to the options for technologies considered.
H-l pit? ; What solidifbation technology wjll be used to stabilize me
chexnicalas?
7) Qigmieij Seweri; la the South Plants region, no treatment of chemicals or
movement of soil is proposed. We are concerned about continued groundwattr
contamination if me suggested actions are followed,
I) Oroundwann There are several issues we would like to see
tf-d in the groundwater proposal.
(a.) Why isn't de-watering still a viable option for the basins?
(o.) Appropriation of water from alternative sources-what is the current
status of this proposal ?
(c.) Boundary aystem-We would like some written ••fiyTff"^ as to the
(d.) Tbe proposed 4\000 acre feet is inadequate to meet the growing
' needs of the surrounding communities. We would like to see mis
allocation increased. Also, we would like some clarification as to
who would be responsible for hook-up fees once the main system is
installed.
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JflN 19 '96 0i:50PM CDC 201 P'9
SIERRA
Rocky MoMvutfft Chuur
WOrawtew SutuW6
(9) &BfifllL2ttll> We would like to see a proposal for soil
not equivalent » biota cixfrnfanfle levels. This is a relevant issue in regard to
wildlife health on the Arsenal. A provision should be included to account for
future data generated from animal studies if lower chemical exposure is shown to
ctuie adverse effects.
(10) QfLSfiRK This is an issue not yet addressed: We would advocate (reatment
of contaminatod soil! or Ifiy^fi^nfl thffli as an inwim action,
(11) Mnntiieiift' This is an issue not yet addressed: We would strongly
recommend soil and health screening be conducted in this community. It it
critical to ihe PRPs for i*«fat«fafaf community relations.
As we have worked diligently as volunteers on numerous issues relating to ths
RMA, we hope you will keep us informed as to any modifications of the
Conceptual Agreement We look forward to receiving your written responses
addrc«ting these issues. Thank-yon.
Sincerely.
Sandy Horroeks
Sierra Club Rocky Mountain Arsenal Subcommittee Chairperson
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JflN 19 '96 01!48R1 CDC
•P.I
GALILEO
INTERNATIONAL
1 To:
Company:
Phone:
Fax:
From:
Company:
Phone:
Fax:
Date:
Ptg« IncL this cover page:
(UV'.e
u .*> . -
Sd^wuJLv- V\or^T5tV-S
GALILEO International
,
(303)397-5299 or 5296
^l^l\ \IL.
*(
Comments:
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REPLY TO
ATTENTION OF:
DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOl STAIN ARSENAL
COMMERCE CITY. COLORADO &v:M 7-tS
June 11, 1996
Office of the Program Manager
Ms. Sandra Horrocks
Chairperson, RMA Subcommittee
Sierra Club
Rocky Mountain Chapter
777 Grant Street, Suite 606
Denver, Colorado 80203
Dear Ms. Horrocks and Sierra Club Members:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component in the remediation process, and your participation
helps maintain the dialogue between the Army and the public.
Your letter dated December 7, 1995, requested that the comment period for the On-Post
Proposed Plan be extended by no less than 60 days; other parties requested that there be no
extension whatsoever so that the Record of Decision (ROD) would not be delayed. In order to
allow additional time for comment without excessively delaying the ROD, the comment period
was extended by 30 days.
Your letter dated December 18, 1995, stated your belief that the replacement water for the
off-post area of RMA should be dealt within the Off-Post ROD. The alternative water supply is
addressed in the On-Post ROD because it is part of the overall on-post remedy, not the off-post
remedy. The containment portion of the on-post remedy requires leaving some waste in place
under a cap or in a hazardous waste landfill. For that reason, the Army decided to provide a
separate water supply to alleviate any concerns the public may have about leaving the waste in
place The Off-Post ROD was signed by the Army and the U.S. Environmental Protection
Agency (EPA), and the State of Colorado concurred on December 19, 1995.
In response to your comment requesting details about an alternative water supply, the
Army and Shell have reached an Agreement in Principle, enclosed with this letter, with the South
Adams County Water and Sanitation District (SACWSD) that includes payment of $48.8 million
by the Army and Shell to SACWSD and requires that SACWSD water be supplied to consenting
drinking water well owners within the diisopropyl methylphosphonate (DIMP, an RMA
byproduct) plume by January 1999. In addition, the Agreement in Principle requires SACWSD to
provide 4,000 acre-feet of water to Commerce City and the Henderson area by 2004. The parties
involved in the water negotiations believe that the settlement is fair and will permit SACWSD to
secure an adequate water supply to satisfy Commerce City's and Henderson's water needs.
Readiness is our Profession
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-2-
If you have any further questions regarding the water supply, please contact Mr. Tim Kilgannon
of this office at (303) 289-0259 or Mr. Larry Ford of SACWSD at 303-288-2646.
Your letter of January 18, 1996, contained several additional comments on the On-Post
Proposed Plan, and the Army's responses are contained in the enclosure to this letter. Also
enclosed are responses to your letter dated May 30, 1995.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Eugene H. Bishop
Colonel, U.S. Army
Program Manager
Enclosures
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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U.S. ARMY RESPONSES TO COMMENTS ON THE ON-POST PROPOSED PLAN
FROM THE SIERRA CLUB, ROCKY MOUNTAIN CHAPTER,
DATED JANUARY 18,1996
1. Water. Structures, and Soil
a. Water
The Army believes Alternative 4 is superior to the other groundwater remedial alternatives
for the On-Post Operable Unit for the following principal reasons:
• Alternative 4 is preferable to Alternatives 1 and 2 because it provides additional
reduction of toxicity, mobility, or volume of contaminated groundwater at a
reasonable cost and with minimal short-term effects. It is also readily
implementable.
• Although Alternative 3 provides greater reduction of toxicity, mobility, and
volume than Alternative 4, it is less readily implementable than Alternative 4.
Furthermore, when considered in conjunction with the preferred soil alternative
and the continued operation of the boundary groundwater containment and
treatment systems. Alternative 3 provides limited added benefit compared to
Alternative 4 at a significantly higher cost.
The Army is currently conducting N-nitrosodimethylamine (MDMA) treatment studies in water
and taking steps to lower the analytical detection limit as required by the Agreement for a
Conceptual Remedy for the Cleanup of the Rocky Mountain Arsenal (RMA Conceptual Remedy),
which was signed by the Parties on June 13, 1995. The Army is continuing to work with its
laboratory on this issue. If additional treatment is warranted at the boundary systems, the Army is
committed to implementing the appropriate treatment system to meet the Remediation Goals set
forth in the Record of Decision (ROD).
Regarding your comment about the "hazardous plume moving southward off the Arsenal", no
such groundwater plume has been identified by the extensive groundwater monitoring programs
the Army conducts annually. The water table elevation in the southeast corner of RMA is
approximately 5,300 feet above mean sea level (ft M S L ), and the elevation of the water table at
the South Platte River is approximately 5,000 ft M S L Therefore, groundwater flows downhill
generally from the southeast corner of RMA toward the South Platte River. Superimposed on the
regional gradient is a groundwater mound in South Plants The mound is created by leaking
pipes, increased recharge from unlined ditches and ponded areas, and may also be the result of
natural variations in the permeability of the alluvium and bedrock in the area. Groundwater in the
area of the mound flows radially out from the mound in all directions. A groundwater divide
occurs at the confluence of the regional flow system and the mound. As a result, groundwater
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entering RMA from the southeast is forced to turn either east or west around the South Plants
area. Water flowing south from the mound area is forced to change direction and join the
regional flow system. The groundwater flow direction in the confined Denver Formation is also
from southeast to northwest. Groundwater flow upgradient (southward) from the southern
boundary of RMA is physically impossible.
In response to your comment requesting details about an alternative water supply, please see
Paragraph 4 of the cover letter attached to these responses.
b. Structures
The Army realizes that there are remaining issues involving the selected remedy for RMA. The
concerns about the short-term risks and effects of excavation and treatment were weighed against
the potential long-term effects of containing the waste in place. The public has also been
concerned about thermal processes such as incineration because of potential emissions. The
Army's chosen remedy minimizes the short-term risks of exposure to workers and the community
because soil-borne contaminants are left in place. The cap/cover and landfill designs will comply
with applicable federal, state, and local regulations. Please see also the response for Comment
number Ic below.
The future-use structures are those necessary for operation of the Refuge and for continued
operation and maintenance of the selected remedy. The structures generally are warehouses,
bunkers, the firehouse, a new Visitor's Center, a farmhouse, operations and maintenance (O&M)
facilities in the vicinity of the present administration building, treatment system structures, and cap
and landfill O&M structures. The structures will be used for the purposes of remediation,
interpretive tours, and refuge management, including the U.S. Fish and Wildlife Service (USFWS)
repositories. The USFWS is still in the process of determining the actual number of structures
that will be necessary for Refuge management. These structures are indicated in Section 5 of the
ROD.
c. Soil
The Army understands your concern that the soil be remediated properly, and believes that the
approach of placing the nonhazardous material under the Basin A cover will adequately
immobilize contaminants, will be protective of human health and the environment for the long
term, and will provide a cost-effective method for disposal of nonhazardous materials. The
principal threat and human health exceedance soil will be disposed in the on-post hazardous waste
facility at RMA. In addition, a large volume of fill material will be required to construct the
Basin A Consolidation Area, and the RMA nonhazardous material will satisfy that need.
Furthermore, by using this nonhazardous material onsite, there will be no negative impact from a
very large number of trucks moving through the surrounding community to transport
nonhazardous waste and potential new fill material.
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Your comment references the presentation on alternative remediation technologies during the
winter of 1995, and you express concern that some of those technologies could have been used in
the selected remedy, as well as expressing a desire for a slower remediation in order to use those
technologies. The Army has received numerous public comments regarding both these issues
through various avenues. Concerns were expressed by the public about many innovative
technologies during the public process; many participants preferred proven technologies and
minimal disturbance of the site. The Army has considered those concerns in choosing what it
believes to be the best remedy for protection of human health and the environment, as well as one
that is timely and cost-effective.
2. Trust Fund
During the formulation and selection of the remedy, members of the public and some local
governmental organizations expressed keen interest in the creation of a Trust Fund, as you do in
your comment, to help ensure the long-term operation and maintenance of the remedy. The
Parties have committed to good-faith best efforts to establish such a Trust Fund, as described in
the ROD. Principal and interest from the Trust Fund would be used to cover the costs of long-
term operation and maintenance throughout the lifetime of the remedial program. These costs are
estimated to be approximately $5 million per year (in 1995 dollars).
The Parties intend that if the Trust Fund is created it will include a statement containing the
reasons for the creation of the Trust Fund, a time frame for establishing and funding the Trust
Fund, and an appropriate means to manage and disburse money from the Trust Fund. The Parties
are also examining possible options that may be adapted from trust funds involving federal funds
that exist at other remediation sites. The Parties recognize that establishing a Trust Fund may
require special congressional legislation and that there are restrictions on the actions federal
agencies can take with respect to such legislation. Because of the uncertainty of possible
legislative requirements and other options, the precise terms of the Trust Fund cannot now be
stated.
A Trust Fund group will be formed to develop a strategy to establish the Trust Fund. The
strategy group may include representatives of the Parties (subject to restrictions on federal agency
participation), local governments, affected communities, and other interested stakeholders and
will be convened within 90 days of the signing of the ROD.
3. Health Monitoring
The effects on human and wildlife health of many of the compounds produced at RMA have been
studied for many years, and this information is available at the Joint Administrative Record
Document Facility (JARDF). Studies have been completed by the Agency for Toxic Substances
and Disease Registry (ATSDR) independently and in conjunction with the Colorado Department
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of Public Health and Environment (CDPHE). These studies showed no conclusive health impact
on the communities surrounding RMA. Also, the final Public Health Assessment, produced by
ATSDR, should be complete in the summer of 1996.
A Medical Monitoring Program for the surrounding communities has also been identified as part
of the On-Post Proposed Plan. The primary goal of the Medical Monitoring Program is to
monitor any off-post impact on human health due to the RMA remediation. Elements of the
Program could include medical monitoring, environmental monitoring, or health/community
education. This Program will continue until the on-post soil remediation is completed. A Medical
Monitoring Advisory Group has been established to evaluate specific issues covered by the
Medical Monitoring Program. The Group is composed of representatives of the Army, Shell Oil
Company, the U.S. Environmental Protection Agency (EPA), CDPHE, Tri-County Health
Department, ATSDR, the USFWS, Denver Health and Hospitals, and the Site-Specific Advisory
Board. The Group also includes representatives from the communities of Montbello, Commerce
City, Henderson, Green Valley Ranch, and Denver. The Army and Shell will fund ATSDR to
conduct this effort in coordination with CDPHE. If you would like more information on the
Medical Monitoring Program or wish to participate as part of the Medical Monitoring Advisory
Group, please call Ms. Mary Seawell of CDPHE at 303-692-3327.
4. Wildlife
Your comment regarding the need for an explanation of what will be done to protect the wildlife
during remediation is noted. During the remedial design and implementation phase after the ROD
is signed, each project will include measures to minimize the impact on wildlife during
implementation; these measures will vary according to the response action being taken. In
addition, the USFWS will manage the wildlife populations and, in coordination with the Army and
other Parties, monitor the protectiveness of the implementation measures taken.
The Biological Advisory Subcommittee (BAS) is currently evaluating which chemicals to use to
evaluate wildlife health at RMA. Dioxin and furan sampling was undertaken by the CDPHE, and
these results are currently being evaluated by the BAS.
5. Overall Plan
The Army is interested in public comments and concerns and has made a substantial effort to hear
those concerns through the Restoration Advisory Board, the Site-Specific Advisory Board,
stakeholder meetings, and also through avenues of public comment such as the comments on the
On-Post Proposed Plan. The Army believes it has been consistent in representing the progress of
the remedy to the public. In fact, the Army has held more than 20 public meetings and workshops
in order to facilitate public input. Regarding your statement that the public was not invited to
participate in the drafting of the Agreement for a Conceptual Remedy, the Army and other Parties
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considered the public concerns and incorporated many as they drafted the Agreement. The Army
believes the selected remedy is responsive to the public's concerns and is protective of human
health and the environment.
In response to your last comment regarding the types of technologies reviewed, many
technologies including those previously advanced by your organization were reviewed and
considered before the selected alternative was chosen.
The May 30, 1995, letter you enclosed was also available and considered in the discussions
leading to the June 13, 1995, Agreement for a Conceptual Remedy. Responses to those
comments are attached.
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U.S. ARMY RESPONSES TO COMMENTS ON THE CONCEPTUAL AGREEMENT
COMPONENTS FROM THE SIERRA CLUB, ROCKY MOUNTAIN CHAPTER,
DATED MAY 30,1995
Global Issues
1. Lack of Detoxification
The RMA remedy was selected after considering issues such as short-term versus long-term
effects and the preferences of the Parties and stakeholders involved in the process. The remedy
includes continued water treatment at the boundaries and at existing internal systems, in situ
solidification of Former Basin F, and, subject to the results of treatability testing and technology
evaluation, use of innovative thermal technology for treatment of part of the Hex Pit material in
addition to landfilling and containment. Extensive monitoring of soil, water, and air will ensure
the safety of the public and indicate whether additional action is necessary.
2. Landfill Utilization
The new state-of-the-art, hazardous waste landfill will safely and permanently contain the waste.
Monitoring will ensure that operational requirements are met. Please refer to the response to
Comment 1 regarding treatment.
The sanitary landfills will be excavated. Human health exceedance material will be disposed in the
new landfill. The remaining debris and soil will be consolidated under the Basin A cover.
3. Trust Fund
Please see the response to Comment 2 in your January 18, 1996, letter.
4. Research and Development
Treatability studies will be conducted as part of the remedial design phase for the innovative
thermal technology selected for a portion of the Hex Pit materials. RMA will not serve as a
national site for pilot testing of innovative technologies It should be noted that several
treatability studies have been completed for or at RMA, including enhanced soil vapor extraction,
radio frequency heating, oxidation, sorption, and in situ biological treatment.
5. Arsenal Tours
RMA tours will continue during the remediation process, but will not be conducted in areas under
remediation. Visitor safety will be ensured through controlled access and monitoring.
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6. Wildlife Habitat
Please see the response to Comment 4 in your January 18,1996, letter.
7. Dioxin Testing
Dioxin and furan sampling was undertaken by CDPHE, and the analytical results are presently
being evaluated by the Biological Advisory Subcommittee. Although the Army believes that the
currently identified contaminants of concern include all contaminants representing the greatest
potential for risk, other contaminants may become a concern in the future (e.g., dioxin). In such
an instance, the contaminant will be evaluated with respect to the remedy selected, designed, or
implemented to ensure that the remedy remains protective of human health and the environment.
Site-Specific Issues
1. Basin A; The Army believes that the Basin A remedy will safely contain the waste without
the risks associated with removal. You are correct that slurry walls and active dewatenng
(through) pumping have been proposed. However, groundwater modeling of the area showed
that a slurry wall would add only minimal benefit because of the low-permeability soil in the area
It should be noted that groundwater migration out of Basin A is very slow. Migration rates will
be further reduced through installation of the Basin A cover, which will passively dewater the
area. Solidification of soil before placing it in Basin A would not reduce the risk further than
containment and passive dewatenng will.
2. Former Basin F
Treatability tests will be conducted to ensure that adequate solidification can be achieved.
Solidification, combined with capping of the entire Former Basin F site (including the Basin F
wastepile footprint), and therefore passive dewatering, will minimize contaminant migration. Due
to past and expected future lowering of the water table in this area, chemical movement is not
expected to be a problem.
3. Basin F Wastepile
Excavation will be conducted using vapor- and odor-suppression measures as necessary. In the
event that the wastepile soil fails EPA's paint filter test, moisture content will be reduced to
acceptable levels by using a dryer in an enclosed structure. Volatile organic compounds (and
possibly semivolatile organic compounds) released from the soil during the drying process will be
captured and treated; however, the main objective of this process is drying. Prior to excavation nt
the wastepile, overburden from the existing cover will be removed and set aside. The excavated
area will be backfilled with on-post borrow material and stockpiled overburden.
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4. South Plants
The excavation of 5 feet of principal threat and human health exceedance soil in the South Plants
Central Processing Area is protective of human health and the environment. Excavation to a
greater depth would cause problems such as interferences with sewer lines. The excavated area
will be backfilled and protected with an additional 5 feet of soil cover.
5. North Plants
Human health exceedance soil will be excavated to a 1-foot depth in North Plants. The entire
North Plants area will be contained under a 2-foot soil cover.
6. Pits/Trenches
Subject to the results of treatability testing and technology evaluation, approximately 1,000 bank
cubic yards (BCY) of principal threat material from the Hex Pit will be treated using an innovative
thermal technology. Solidification will become the selected remedy if evaluation criteria for the
innovative technology are not met. The remaining 2,300 BCY will be excavated and disposed in
the on-post hazardous waste landfill.
The mixture of solidification/stabilization agent to be used for the M-l Pits will be determined
through treatability testing during remedial design.
7. Chemical Sewers
For sewers located within the South Plants Central Processing Area and Complex Trenches area,
the sewer void space will be plugged with a concrete mixture to prohibit access to these lines and
to eliminate them as a potential migration pathway for contaminated groundwater. The plugged
sewers will be contained beneath the soil cover or cap in their respective sites.
8. Groundwater
(a) The containment actions in Basin A and Basin F will result in passive dewatering (lowering of
the water table through minimized infiltration). No further dewatering is necessary to achieve the
required groundwater levels.
(b) Please refer to the response to Comment la in the January 18, 1996, letter.
(c) Shutoff criteria have been developed for the boundary systems to ensure that the systems will
operate until water at the boundary has met these very specific criteria.
(d) Please refer to the response to Comment la in the January 18, 1996, letter.
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9. Surficial Soils
The Biological Advisory Subcommittee (BAS) will continue to evaluate potential impacts on
biota and recommend additional areas for remediation if necessary. In the event additional
remediation is necessary, only the areas would change, not the remedies.
10. Off-Post Operable Unit
The 160 acres of soil off-post that you refer to were tilled to a depth of approximately 12 inches
and were revegetated. A final inspection of the site will be conducted in late 1996.
11. Montbello
The Army and Shell will fund ATSDR to conduct, an RMA Medical Monitoring Program in
coordination with CDPHE. The program's nature and scope will include baseline health
assessments and be determined by the on-post monitoring of remedial activities to identify
possible exposure pathways to off-post communities, including Montbello.
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SDC MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT .
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WELL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY TfflS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
06Z969 COi XVJ 9S:CI IJU 96/92/10
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AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. '-"
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. .DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WELL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10 - 26/01/96
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12-7
Public Meeting Transcript
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PUBLIC MEETING
Condenselt1
November 18,1995
Page
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soonr MOUNTAIH aaam fi«uc MUTINO
ON ne IUKUD HJ& ran MNAL axwur
November II, 1995
Held « tht Rocky Mowuia Jama.
Buildinf Hl-A,aoanencin|«l9:10
1995, before Meline L. HumpteTy-W«tkia.,
Diplomat Rcporar and • Noun Public o
IS,
«f Colorado
of flic Suit
Page3
1 gentlemen.
2 In spite of the government shutdown, we
3 felt that this meeting was important enough to make
4 special funding arrangements for my people to be able
5 to come out here and interact with you all on the
6 proposed plan. And we were able to do that, thanks
7 to some special financial arrangements that we do
8 have and a special fund.
9 We feel that your input is critical and has
10 been. This is not the first time we have gone into
11 the public arena seeking your input and comments on
12 the final remedy of the Rocky Mountain Arsenal. And
13 that's really what we're here to address today. Your
14 input is important to us and has been over the past
15 two years that we've been in the public forum.
16 This is the official public meeting for the
17 Rocky Mountain Arsenal proposed plan under the CERCLA
18 process. And we would like to welcome you here this
9 morning. We hope you have an enjoyable experience.
20 Let's see. I guess about two years ago I
21 took you out and showed you my incinerator. I can't
22 do that today, folks. It's gone. I promised you I'd
23 start it up and operate it safely and shut it down,
14 and I'd tear it down. And it's torn down. So one
:5 less thing on the landscape for you to see.
Page 2
PROCEEDINGS
(Meeting proceedings convened
9:10 am, November 18,1995.)
MR. ZEK SAIDMAN: Let me introduce
S myself. My name is Zeik Saidman. I've been asked to
6 facilitate this meeting today, this public meeting.
7 I work for the University of Colorado-Denver at the
8 graduate school of public affairs. And I'll explain
9 a little bit more my role in a couple minutes.
I want to turn h over to Patricio, who is
l die interpreter, and he has a few minutes.
(Discussion in Spanish off the record.)
MR. ZEK SAIDMAN: Thanks, Patrick).
The participants felt that it was ~
5 the - that it was important to have a translator
6 here, and we appreciate Patricio coming by.
I'm going to go over a proposed agenda and
8 desired outcomes for today's meeting and talk, also,
about the ground rules about how to conduct a
o successful meeting.
And this is a — the desired outcomes and
2 proposed agenda I'm going to go over. And we
3 have - before we do that, we want to have a welcome
4 from Colonel Bishop.
COLONEL BISHOP: Good morning, ladies and
Page 4
l And usually, these prairie critters
2 generally put on a pretty good show, in spite of the
3 rest of it.
So please enjoy your day, give us your
5 comments. Thank you for coming out.
6 Zeik, it's all yours.
7 MR. ZEK SAIDMAN. Thank you, Colonel.
8 Again, let me go through the desired
9 outcomes for today's meeting, make sure you're in the
0 right meeting and what we are planning to do today.
Desired outcomes for today's meeting is to
2 present to the community a proposed plan to remedy
3 the situation, answer questions about the proposed
plan, and listen to and officially record community
5 comments about the proposed plan. And we have a
6 court reporter over here.
How does that sound? And I need some kind
8 of feedback from you. Does that sound like the
desired outcomes for today's meetings? Is that your
0 expectations for today? Give me a few nods out there
1 if that's okay.
Okay.
All right. To get to that - we're
4 starting a few minutes late. We'll go - I think we
s started about five, seven minutes late. We'll honor
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l that and go on the other side of the time. But we're
2 going through the agenda right now. We had the
3 interpreter's comment, welcome from Colonel Bishop.
4 I will explain my role, going through the proposed
5 agenda, desired outcome.
6 We have ground rules for successful
7 meetings. I want to share with - that with you in
8- a minute, an introduction of the panel. They'll
9 introduce themselves in a few minutes. We think
10 that will take about 15 minutes or so. Then
11 Charlie Scharmann has a video that maybe a few of you
12 have seen but probably many of you haven't, and that
13 runs about 15 minutes.
M Then Charlie will go over the highlights of
15 preferred alternatives around water, structures,
16 soil, clarification period. We look at that lasting
7 about a half an hour.
8 Then we have a break, and I saw the
9 wonderful cookies and everything on the other side,
20 so we will take about a ten-minute break. And then
21 we have an hour for formal public comment period.
22 And if we need to take longer, we're willing to take
23 longer. But we've talked to people, and they like
the time agenda. They like to know that there's an
25 ending time for this. But again, the panel and the
Page?
l Thank you. Yeah, you can say no or say, "I
2 have a problem with that."
3 AUDIENCE SPEAKER: Because you've got a
4 watch.
5 MR. ZEK SAIDMAN: I have a watch. And
6 I'm - my job is to help enforce ground rules about
7 this meeting. And simply, our experience is that
8 certain meetings run better than others if people
9 follow these rules. And let me share them with you.
10 This is a graphic representation.
ll Respect each other's time. We want
12 everybody to have a chance to be heard. And maybe
13 you've been at or viewed a meeting where people will
14 go on and on and on, and other people that want to be
15 heard don't have a chance. When we have the formal
16 comment time, my suggestion is we run about
17 three minutes apiece. And if people have to speak
18 longer, they can come back around again.
19 But I think we can make ~ everybody can
20 make cogent comments in three minutes. And of
21 course, there's public comment cards here - are
22 they over there, Cathy?
23 MS. CATHY COFFEY-WEBER: Yes.
24 MR. ZEK SAIDMAN: Public comments cards.
25 You can send in — if you have something written out,
l court reporter are willing to stay here till
2 everybody has a chance to be heard.
Okay? How does that agenda look? Does
4 that make sense to people?
Okay. All right. Let me talk about my
6 role a little bit
7 I was asked to come in. Again, I work with
8 UCD, the graduate school of public affairs at the
9 university. And I'm a neutral. I don't have any
o interest in the substantive matters of this ~ of
l these issues.
2 My job is to make the meeting run smoothly
3 and keep everything on track and focused. And if
4 it's okay with you, I'll act as a timekeeper so we
5 have a sense of how we're moving along. Is that
6 okay, that I be the timekeeper for today's meeting?
Again, your job is to say, "Okay. That
8 makes sense to me." Okay. All right.
9 AUDIENCE SPEAKER: What if we say no?
0 MR. ZEK SAIDMAN: No? Do you have a
l problem with that?
AUDIENCE SPEAKER: No. I say, what if we
3 say no?
MR. ZEK SAIDMAN: Just say no. Just say
5 no and I'll ask you why.
Page 6
Page8
l you can send that in until December 15th, I believe.
2 So there's opportunities. And we would
3 just suggest that you highlight your comments in
4 those three minutes. Does that make sense to
5 people -
6 AUDIENCE SPEAKER: Yes.
7 AUDIENCE SPEAKER: Yes.
8 MR. ZEK SAIDMAN: - in terms of time?
9 Okay. Because I know that - again, we
10 will stay here as long as we need to, but there are
11 some bus tours scheduled and those kind of things.
2 No shaggy dog stories. And that simply -
3 that doesn't mean that you couldn't bring your pet;
4 that just means that we're trying to stay on the
5 topic. We're trying to stay on the topic, which is
6 the proposed final plan. And I will occasionally
7 intervene if we feel that you're off on some other
8 topic that we can put in what we call a bin, we can
9 get to come back to that. And some people may want
:0 to talk to you; I'm sure some of the panelists
1 would. But this is on the proposed final plan. I
12 would definitely come back.
:3 This is a cowboy with a gun. And
4 basically, it's hard on the issues, easy on the
:5 people. These are complicated problems. They're
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l not ~ there's not very - there's not a lot of
2 easy answers to this thing. So hard on the issues,
3 easy on the people. You know, personal attacks, I
4 will try to intervene on those kind of things.
5 The colonel --1 didn't think it was
6 proper for me to interrupt the colonel, but we're
7 trying -- at least probably for the facilitator.
8 .When we use acronyms and jargon ~ help me out, too.
9 I might miss them but we'll try to have people
10 explain to us. Especially when you're in the
11 culture, you start using them, and people don't
12 know -- the public doesn't know what you're talking
13 about sometimes.
14 Keep side conversations to a minimum. It's
15 distracting to your neighbors and people up front if
16 you're talking and having long conversations.
17 Listen - this is an ear. Can you see
18 that now? I want to put this up a little higher.
19 Listen for understanding. Listen, panelists,
20 audience. Listen for understanding.
21 In our society we tend to think about
22 reloading versus listening. Okay. Well, let's try
23 to listen to each other.
24 And take care of your personal needs. We
25 rent coffee so you don't need a hall pass from me or
Page 11
l But we are asking people to limit their
2 comments up front to about three minutes apiece, and
3 then the next person can speak so everybody has an
4 opportunity to speak. And that person can come back
5 and speak again and speak as long as they want.
6 Is that okay with everybody?
7 Okay. All right. And I think - let's
8 see. Now we're at the point right now where I
9 introduce the panel, and the panel will give their
10 name and organizations. And when you speak, also
11 just give your name, too, and if you're with an
12 organization.
13 Charlie?
14 MR. CHARLES SCHARMANN: I'm Charlie
15 Scharmann. I'm the technical director out here for
6 the Army. I coordinate the technical aspects of the
7 cleanup program for Colonel Bishop, and I'll be
8 taking about some of those things this morning.
9 MR. ZEK SAIDMAN: Okay. Barbara.
20 MS BARBARA NABORS; Good morning. I'm
21 Barbara Nabors. I'm an engineer with the State, and
12 I serve as the coordinator for our staff at the
:3 Colorado Department of Public Health and
;4 Environment. I'm really pleased to see a lot of new
5 faces out here than we have had at some of the
Page 10
1 anything like that.
2 Okay. So does that make sense in terms of
3 running a successful meeting? Is there anything else
4 that we should add? Does everybody agree with that?
5 Again, nods. Let me ask you this: Whose
6 responsibility is it to enforce these ground rules?
7 AUDIENCE SPEAKER: YOU.
8 AUDIENCE SPEAKER: Yours.
9 MR. ZEK SAIDMAN: And everyone. It's all
10 of our responsibility. So if that's okay with
11 everybody, let's try to honor those.
12 MR. RICK WARNER: Could I make a request?
13 MR. ZEK SAIDMAN: Yeah.
14 MR. RICK WARNER: Those ground rules are
15 fine with me if you allow this meeting to go on for
16 as long as it takes, even if that's several days.
17 MR. ZEK SAIDMAN: Did you come in late?
18 MR. RICK WARNER: Yes.
19 MR. ZEK SAIDMAN: Because I mentioned that
20 several times, that anybody --
21 MR. RICK WARNER. Okay.
22 MR. ZEK SAIDMAN: - who needs to be heard
23 and feels they didn't have the chance to be heard, we
24 are going to take that opportunity. The panel is
25 willing to stay here, and so is the court reporter.
Page 12
l previous meetings. This meeting represents kind of a
2 culmination of years of work between all of the
3 parties, and so it's really important that you take
4 this opportunity to give us your comments, either
5 verbally today or later, through the mail.
The world at stake here at the Arsenal is
7 one of watchdog. We have to make sure that the broad
8 spectrum of environmental laws of the State are
9 followed and represent the citizens of Colorado.
0 MR. ZEK SAIDMAN: Thank you, Barbara.
l Can everybody hear the panelists?
2 AUDIENCE SPEAKER. YCS. Yes.
3 MR. ZEK SAIDMAN: We had a - Murphy's
4 law. We had a little technical difficulty with the
5 mics this morning. And so just put your hand up if
6 you have trouble hearing any of the people speaking.
7 Laura?
8 MS. LAURA WILLIAMS: Good morning. I'm
9 Laura Williams. I'm the team leader for the
0 Environmental Protection Agency here at the Arsenal.
And I first would like to personally acknowledge the
2 commitment and energy that each one of you
J demonstrates just by being here this morning. I know
it takes time and effort to actually come out to one
of these meetings.
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l Public involvement and comment process for
2 EPA - I'm sorry, that's Environmental Protection
3 Agency - is very important to me, as well as the
4 Agency, and so I strongly encourage each and every
5 one of you to make use of this time and to provide
6 your comments to us.
7 In fact, I know it's not fashionable to
8. support the government, but if you actually like the
9 remedy, it's all right to say so here, as well, and
10 none of us will hold it against you. So please feel
11 free.
12 The remedy that results from this proposed
13 plan mat we're discussing today is a commitment that
14 the parties you see up here today are making to clean
15 up the Arsenal. But I want you to know that it
16 doesn't end the public comment process. You're
7 welcome to provide more input as the designs continue
8 and as cleanup continues. And in fact, we would
9 welcome that partnership with the community.
20 Thank you.
21 MR. ZEDC SAIDMAN: Thank you, Laura.
22 Ray?
23 MR. RAY RAUCH: My name's Ray Rauch. I'm
4 the project leader for the Fish and Wildlife Service
5 out here at the Arsenal. I do like to thank you for
Page 15
1 Rocky Mountain Arsenal ought to be, and we appreciate
2 you all coming out this morning so we can hear any
3 additional concerns that will help us move forward
4 with the remediation.
5 MR. ZEK SAIDMAN: Thank you, panel.
6 I think now we're about on time for showing
7 the video. How many - just curious. How many of
8 you have seen the video?
9 Oh. Okay. About a third of the room.
10 Well, Charlie, I'm going to turn it over to
11 you for your presentation.
12 MR. CHARLES SCHARMANN: Okay.
13 MR. ZEK SAIDMAN: We have to hand off the
14 michere.
IS MR. CHARLES SCHARMANN: Okay.
16 Good morning again and welcome. I see some
17 familiar faces. I'm glad to see you back out here.
18 I see some new faces. I welcome you and hope you
19 continue to stay interested in the Arsenal program.
20 We have monthly meetings with what we call
21 our Restoration Advisory Board the first Thursday of
22 every month, and that's another opportunity for folks
23 to come out and just check on the status of things.
24 But this is a big milestone for us here at the
25 Arsenal for the cleanup program and, again,
Page 14
l coming out on this very nice day. I think we'd all
2 like to be outside somewhere. But this is very
3 important. It's kind of a milestone here. And I'd
4 also like to tell you why the Service is involved
5 out here.
We have two concerns out here. One, we're
7 a co-trustee for natural resources here at the
8 Arsenal. And secondly, with the refuge act passed
9 in '92, this will be a national wildlife refuge, and
0 the Service has been charged with managing as if it
l was a national wildlife refuge now, subject to the
2 cleanup.
3 Again, thank you for coming out
4 MR. ZEK SAIDMAN: Thank you, Ray.
5 Michael?
6 MR. MICHAEL ANDERSON: Good morning. My
7 name is Mike Anderson. I'm the project manager with
8 Shell Oil Company. Shell has been active in the
9 actions that have taken place out here at the Arsenal
0 over the last ten years or so. And we are committed
l to follow through on the safe and effective cleanup
2 of the Arsenal.
We have very much appreciated the
4 participation by stakeholders in participating in
5 giving us your thoughts on where the remedy for the
Page 16
l appreciate your time this morning.
2 One of the things that we're trying to do
3 today is make sure that everyone understands what
4 we're proposing to do at the Arsenal. And we're
5 going to do a couple things, try not to spend too
6 much time. I know some of you have seen the video
7 before, but I want to go over it, and I'll spend some
8 time hitting the highlights of it. And we're just
9 trying to do our best to make sure that you
0 understand the details -- or the proposal that we
1 have so that you can make informed comment, either
2 today or in writing by December 15th.
3 So again, to reemphasize, the goal is to
4 try to make sure that you do understand, you know,
5 what we're proposing.
6 In addition to myself, we have the other
7 parties here to answer questions, clarify what we're
8 proposing. We also have various technical experts
9 from the different agencies and the Army who prepared
0 the documentation that supports this decision or this
l proposal.
:2 I point out that a lot of the technical
3 work behind it -• an example of that is the report
4 sitting over on this table. I know many of you would
5 say you don't want anything to do with that level of
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1 paperwork, so we prepared a proposed plan, and it is
2 a summary of all the studies that have been done -
3 done out here.
4 So what we're going to do - let me just
5 spend a minute on where we've been and kind of where
6 we're going as a form of introduction to the video.
7 This lays out the steps of how we get toward a
8. decision and where we move once we make a decision.
9 Some of you may have seen the poster out
10 front here that's entitled "The Road to the Record of
11 Decision." And this is the same steps are shown here
12 on this slide.
13 What we have, basically, up in this area
14 here, are the - is the study phase. We do studies
15 to find out where contamination is, we do a risk .
16 assessment to see what effect the chemicals may have
17 on people or on the environment, and then we do a
18 feasibility study to look at different options.
19 And this is where we are right now. We're
20 at the proposed plan, where we have a recommended
21 preferred alternative. And if we stay on schedule,
22 we will have a final record of decision by June of
23 next year. So that kind of gives you an idea of
24 where we are in the program.
25 During -- and while we've been doing
Pagel
l proposed plan, and we'll give you an opportunity to
2 ask questions to clarify and make sure we all
3 understand what the proposed plan is.
4 So with that, Steve, we can ...
5 (Following is the text of the
6 videotape shown.)
7 FEMALE COMMENTATOR: There are many
8 chapters in the past, present, and future of the
9 Rocky Mountain Arsenal, from native prairie to ranch
10 and farmland, to manufacturing site of chemical
11 weapons and pesticides, to Superfund sites, to the
12 national wildlife refuge. The Arsenal is now
13 returning to its roots. This video focuses on an
4 important milestone, the Army's proposed plan for the
5 Arsenal's cleanup and the key role you play in the
6 Arsenal's future.
7 Following years of study, litigation, and
8 months of meetings, the Army, Shell Oil Company, the
9 State of Colorado, the U.S. Environmental Protection
20 Agency, and the U.S. Fish and Wildlife Service have
!l finalized and support an agreement for the preferred
12 remedy for the Arsenal.
3 Extensive public involvement helped shape
4 this agreement by making the parties aware of key
5 community issues. Public input ensured, among other
Page 18
l studies, we've also been doing some interim response
2 actions, as we refer to them, and these are cleanup
3 actions that everyone has decided needs to happen
4 before a final remedy.
5 After June of next year we would move into
6 design and cleanup. And then where we go from there,
7 in, hopefully, about ten years, we have the
8 Rocky Mountain Arsenal National Wildlife Refuge. So
9 that's kind of long term. That is our goal. I
10 apologize for the handwriting.
11 There we go.
12 AUDIENCE SPEAKER: Charlie, would you mind
13 slipping that up a little bit on the screen?
14 MR. CHARLES SCHARMANN: Sure. Andyoucan
15 see I'm not a...
16 So that is our long-term goal. And we keep
17 that in mind, that once we're finished with the
18 cleanup program out here, we will have, hopefully, an
19 asset for the community, one that the local community
20 can enjoy and, hopefully, will be of national pride,
21 as well.
22 With that as a form of introduction, some
23 of this will be covered in the video probably a
24 little more clearly, and after that I'll take some
25 time to just go through some of the highlights of the
Page 20
l things, that there will be no incineration of soil;
2 that there will be development of a medical
3 monitoring program to ensure that community health is
4 not affected by cleanup; that water would be supplied
5 to the South Adams County Water and Sanitation
6 District; and that people whose wells are affected by
7 the chemical DIMP have access to a new drinking water
8 supply.
Also, to avoid excavating dangerous waste,
o trenches used by the Army for hazardous waste
l disposal will be covered with concrete and capped.
2 This agreement serves as the basis for the Army's
3 on-post proposed plan for cleanup of the Arsenal.
You'll see how this critical juncture was
5 reached through a brief history of the Arsenal and
6 its role in our community and a recap of cleanup
7 activities that have been completed or are ongoing.
The Arsenal is a 27-square-mile site
9 located 10 miles northeast of downtown Denver and
0 adjacent to Commerce City and Denver's Montbello
community. Buffalo herds and native Americans once
2 shared its wild prairie. Settlers and fanners moved
3 in and worked the soil until the U.S. Government
acquired the land so the Army could produce chemical
weapons during World War D.
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1 Following the war private industry leased
2 Arsenal facilities. The largest of these, Shell
3 Chemical Company, produced pesticides from 1952 to
4 1982 at the Arsenal.
5 Waste generated by military and industrial
6 manufacturing were disposed of by commonly used
7 practices of the time. This led to contamination of
8~ ground and surface water and soil from the burying of
9 toxic waste and the use of open basins, A through F,
10 for the evaporation of liquid waste. Contamination
11 also occurred from wind dispersion, sewer line leaks,
12 and accidental spills.
13 The first sign of contamination was
14 discovered north of the Arsenal in the mid-1950s,
15 when groundwater caused crop damage on nearby farms.
16 Since the 1970s the Army and Shell have
17 systematically investigated the contamination sources
8 and have dealt with areas of major concern. Today
9 there are no chemicals or weapons produced at the
20 Arsenal, and the final cleanup plan is now proposed.
21 The Army has the lead role and is
22 responsible for the safe, effective cleanup of the
23 Arsenal. Shell assists the Army in a variety of
:4 studies and projects and shares remediation costs.
25 The State of Colorado and EPA ensure that
Page 23
l dealt with as part of the final remedial actions.
2 The more contaminated soil remaining in Basin F will
3 be solidified in place and capped.
4 In June 1995, after two years of operation,
5 the incinerator completed the destruction of more
6 than 11 million gallons of hazardous liquid drained
7 from Basin F. The incinerator has been sold and is
8 in the process of being cleaned and dismantled.
9 Other interim response actions at the
10 Arsenal include improvement of the groundwater
ll treatment systems, the closure of the hydrazine
12 rocket fuel facility, dust control, asbestos removal,
13 wastewater treatment, covering and revegetation of
14 disposal areas, and the removal of chemical- and
is weapons-manufacturing equipment.
16 The groundwater treatment facilities
17 continue to treat contaminated groundwater before it
18 leaves the Arsenal. More than 1 billion gallons of
19 water are treated each year. These systems will
20 continue to be an important part of treating
21 contamination at the Arsenal in the proposed plan.
22 To understand the cleanup process, it's
23 important to look at the systematic investigation
24 that the Army has undertaken.
25 The first questions the Army had to answer
Page 22
l State and Federal regulations are met and that public
2 health and the environment are protected. EPA makes
3 the final decision if there is a dispute.
4 The Fish and Wildlife Service manages the
5 more than 300 species of animals living at the
6 Arsenal, which will become a national wildlife
7 refuge, as mandated by Congress, when cleanup is
8 complete.
9 What is the status of the Arsenal today?
0 COLONEL BISHOP (on video): Today all the
l parties are working together to try to finalize the
2 final remedy selection for Rocky Mountain Arsenal. I
3 would like to point out that a significant amount of
4 reduction of risk to both wildlife and people has
5 already occurred through the outstanding success of
6 our interim response action program.
FEMALE COMMENTATOR: Interim response
8 actions have been used to contain or eliminate some
9 of the contamination problems while the final cleanup
0 solutions were being determined. Examples are the
l excavation of the waste disposal basin, Basin F, and
2 destruction of its liquid waste through the submerged
3 incinerator.
Sludge from the basin was excavated and
5 stored in a fully enclosed waste pile, which will be
Page 24
1 about contamination at the Arsenal were, "What and
2 where is it?"
3 More than 50,000 samples were taken in
4 ground and surface water, air, soil, and structures
5 on the Arsenal. The findings have been summarized in
6 more than 230 reports. The air quality is
7 continually monitored on the Arsenal. Today test
8 results show air quality is superior to that of
9 nearby urban areas.
0 Contaminants are found in water,
l structures, and soil. More than 320 locations of
2 suspected contamination were examined, and of those,
3 178 sites containing measurable levels of
4 contamination were identified. Most of the sites are
5 in the central sections of the Arsenal, in and around
6 manufacturing complexes and in solid and liquid waste
7 disposal areas, basins, and sewer lines. The
8 contaminants of greatest concern at the Arsenal
9 include pesticides, chemical munitions by-products,
0 heavy metals, and solvents.
1 Samples taken at the Arsenal indicate that
2 some wildlife also were affected by contamination in
3 the water and soil. The current and future cleanup
4 will eliminate ways people and wildlife can be
5 exposed to contamination.
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i MR. RAY RAUCH (on video): The overall
2 health of most wildlife at the Arsenal is very good.
3 The best thing now for the refuge and the wildlife is
4 to move forward with the cleanup.
5 FEMALE COMMENTATOR: What will be done
6 about the contamination of water, structures, and
7_ soil at the Arsenal?
8 Army experts have explored many possible
9 alternatives, which are discussed in the Army's
10 detailed analysis of alternatives. Their proposed
11 plan summarizes the Army's findings and reflects the
12 agreement of the parties on the preferred method of
13 cleaning up the Arsenal.
14 Each alternative is evaluated by these
15 criteria: Will it protect human health and the
16 environment? Does it comply with laws and
17 regulations? Will it be effective long term? Will
18 it reduce contamination? Will workers, the
19 community, and the environment be affected during
20 implementation? How reliable and doable is the
21 alternative? Is it cost-effective? How is the
22 cleanup recommendation accepted by regulatory
23 agencies and the public?
24 EPA takes its oversight responsibilities
25 very seriously. These criteria ensure that a
Page 2
1 MS. BARBARA NABORS (on video): Water
2 issues have been a very important part of these
3 cleanup decisions, and this remedy addresses
4 citizens' concerns for a safe drinking water supply.
5 FEMALE COMMENTATOR: In the proposed plan
6 the term "structures" includes buildings,
7 foundations, basements, tanks, pipelines, and other
8 man-made items.
9 Almost all of the structures will be
10 demolished. All structures contaminated with warfare
ll chemicals and significant levels of other
12 contamination will be demolished and placed in the
13 on-site hazardous waste landfill.
14 Other structures will be demolished and
IS used in Basin A as part of the fill needed to
16 construct a large cap over the basin. This cap
17 consists of multiple layers, topped by a grassy
18 cover.
19 Caps over more contaminated materials will
20 be further enhanced, and if buildings are found to be
21 contaminated with certain levels of warfare
22 chemicals, they will undergo a special caustic
23 washing treatment before being placed in the new
24 on-site hazardous waste landfill.
25 The major task facing the Army and Shell is
Page 26
l cost-effective yet protective remedy is located.
2 Different areas will need different cleanup
3 approaches, and some might be a combination of
4 methods. Here is a brief overview of the way the
5 proposed plan deals with water, structures, and
6 soil:
7 For water the proposed plan recommends
8 continued operation of the boundary and other
9 groundwater treatment systems well into the future,
10 installation of a new groundwater system for a
11 contamination plume northeast of the Army disposal
12 trenches near Basin A.
13 The Army and Shell will provide or arrange
14 for 4,000 acre-feet of water for the South Adams
15 County Water and Sanitation District. The off-post
16 DIMP chemical plume will continue to be monitored.
17 And, in addition to those who were provided
18 new drinking water initially, well owners who in the
19 future detect concentrations exceeding the State
20 standard will be provided an alternative water
21 supply.
22 Continued operation of the off-post
23 groundwater treatment system and maintaining high
24 lake levels on-post to keep contamination from moving
25 into them.
Page 28
l the soil remediation. The proposed plan recommends
2 building a state-of-the-art hazardous waste landfill
3 for soil and debris that will meet or exceed Federal
4 and State regulations.
The landfill, which will accept material
6 only from the Arsenal, will include a double-liner
7 system, liquid leak detection and collection systems,
8 and a permanent groundwater monitoring program, hi
9 addition, specially constructed triple-lined cells
0 will be included to hold the most contaminated soil.
l The landfill will have a protective cover that meets
2 regulations.
Dirt from the Basin F waste pile and highly
4 contaminated soil from the lime basins will be placed
5 in triple-lined landfill cells. Some of the dirt in
6 the waste pile is wet and will need to be dried
7 before placement in the landfill.
Contaminated soil from such areas as the
9 weapon and pesticide manufacturing areas, chemical
0 sewers, and other landfills will be excavated and
l placed in the landfill.
Soil from the waste disposal basin known as
3 the M-l basin will be treated, then placed in the
4 landfill. Treatment for the Hex pits has yet to be
5 determined. The excavated areas will be covered with
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I soil varying in thickness.
2 The Shell and Army disposal trenches will
3 have underground walls built around them and will
4 have a cap or cover meeting or exceeding Federal and
5 State regulations.
6 Areas where concentrations of contaminants
7 in soil may not present much of a threat to animals,
8- such as in the secondary basins and surficial soil,
9 along with debris from former sanitary landfills,
10 will be placed in Basin A as fill.
11 Munitions debris will be excavated and
12 placed in the hazardous waste landfill. If munitions
13 containing explosives are found and can be moved
4 safely, they will be shipped off-site for
15 detonation. If not, they will be detonated on-sitc
6 by Army specialists. The basin will then be covered
7 with concrete and a soil cap to protect wildlife.
8 The cost of the proposed cleanup, including
9 money spent to date by the Army and Shell, is
10 approximately $2 billion. Cleanup could take ten
:1 years or more, depending on the manner in which
:2 Congress allocates funds to the Army. Final cleanup
3 will ensure a healthy future for the Rocky Mountain
4 Arsenal.
In 1992 Congress directed the U.S. Fish and
Page 31
l years to come. A safe, successful cleanup will
2 provide yet another chapter in the long history of
3 the Arsenal. This next chapter will allow the
4 Arsenal to return to its roots as a place where
5 wildlife finds safe water, while affording neighbors
6 an opportunity to discover the joys of wildlife and
7 nature.
8 (Conclusion of videotape.)
9 MR. ZEK SAIDMAN: Several - where's
10 Bill? Several thousand of those videos have gone out
11 and are available.
12 MS. CATHY COFFEY-WEBER: One thousand.
13 MR. ZEK SAIDMAN: One thousand. Okay.
14 And there's a - are videos available for people.
15 MS. CATHY COFFEY-WEBER: Videos are
16 available at local grocery stores and video stores in
17 Commerce City and those stores close to the Montbello
18 community and they're free. Just ask at the video
19 counters, and they'll be made available to you.
20 MR. ZEK SAIDMAN: And I want to point out
21 that people appearing in the film have not received
22 any royalties for their parts in the video.
23 Okay. Charlie's going to talk a little bit
24 more about preferred alternatives, water, structure,
25 and soil, and then we'll have a time period for
Page 30
l Wildlife Service to manage the Arsenal as a national
2 wildlife refuge.
The Rocky Mountain Arsenal National
4 Wildlife Refuge provides important habitats - food,
5 water, and shelter ~ for a diversity of wildlife,
6 including threatened species. It also presents
7 educational and recreational opportunities for refuge
8 visitors.
The public plays an important role in the
0 ongoing cleanup process. Public meetings,
l discussions with individuals, and tours of the
2 Arsenal all provide information for the public and
3 allow them to take pan in the ongoing public comment
4 process.
The Army, Shell, EPA, the State, and
6 Fish and Wildlife Service would like your comments on
7 the proposed plan and encourage you to take an active
8 role in the cleanup activities at the Rocky Mountain
9 Arsenal.
A series of informational meetings and
l workshops will continue to allow public involvement
2 as we move toward the final record of decision, which
3 is expected in mid-1996.,
Decisions made in the coming days will help
5 shape the future of the Arsenal and its neighbors for
Page 32
l clarifying questions about what he said or anything
2 on the video.
3 Charlie?
4 MR. CHARLES SCHARMANN: Okay. Actually,
5 I'd just like to take a couple minutes and go over
6 with you some of the thinking behind the preferred
7 alternatives. Some of die discussions that have gone
8 on over the past couple years with the parties and
9 the community, I think, are fairly important, and I'd
0 like to take a chance to just go through, for each of
l the water, structures, and soil, just recap it
2 quickly and give you an idea of what some of the
3 discussions and thinking behind the cleanup
4 options is.
5 I would ask you, if you - something just
6 doesn't make sense, you need to clarify it, please
7 raise your hand. I'm going to stop after each
8 segment and see if there are any questions.
9 If you have comments, you don't like
0 something, you do like something, you have a concern,
l I would ask that those type of comments be delayed
2 until the next section after the break; we'll have a
3 period of time just to go through comments.
4 So that - I'm going to start with
5 water -- and I know this overhead is not the
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1 best - and just point out to you where you are.
2 This is 56th Avenue down here, 96th Avenue
3 to the north, Buckley Road to the east, Quebec Street,
4 and Highway 2. You either came in the Arsenal on
5 Havana, down here, or 72d Avenue, here. And we are
6 roughly right here.
7 So the idea for groundwater is to build,
8 basically, layers of protection. We have several
9 groundwater treatment systems already operating, both
10 on the Arsenal and off the Arsenal, and the idea is
11 to get layers of redundancy, if you will.
12 Most of the source areas are in the center
13 of the Arsenal, and we have a series of groundwater
4 treatment systems already in place. Basin A neck is
5 located here. Northwest boundary, north boundary,
6 and our Irondale water treatment system. We also
7 have a well that pumps water north of the Basin F -
8 this is Basin F. We have a well that pumps water
9 back to the Basin A neck area.
0 So the idea there is to go back and treat
l groundwater, in some cases, very close to the sources
2 but, at a minimum, keep contaminated groundwater from
3 leaving the Arsenal. Our boundary systems have been
4 doing that for several years. And again, we treat
5 over a billion gallons of groundwater each year.
JP35
l solution as to what supply may be available to
2 provide that 4,000 acre-feet to South Adams County.
3 There are South Adams County
4 representatives here this morning, I believe, so if
5 you have questions, you not only get the Army's
6 perspective or Shell's perspective; South Adams
7 County, I believe, will be available to talk about
8 mat, as well.
9 The other aspect of the water remedy deals
10 with the hookup or the provision of an alternate
11 supply to folks in an area that is defined by where
12 the chemical DIMP has migrated off the Arsenal
13 historically.
14 And I put up this map. This is the general
15 area. What we have - again, this is Highway 2.
16 This is 96th Avenue, 104th, 112th, 120th. Hopefully,
7 that gives you an idea as to where the area is.
8 We will be doing additional sampling out in
9 this area to better define the geographic limitations
20 as to where we are going to provide an alternate
21 supply. But this is a -• gives you a general idea
22 of where it is that we're looking at. And the idea
:3 there is, because this area has DIMP in it - and
4 you may be aware that the State of Colorado and the
5 Army have had disagreements over the years as to what
Page 34
l In addition to what we have on-site - I
2 should mention, in addition to what systems we
3 already have installed, we are planning to install
4 another one in this location, and that's by our Army
5 trenches area. And that's an additional system
6 that's part of this final remedy.
In addition to what we have on-site, many
8 of you may have seen our groundwater treatment system
9 off-site. It's located north of the Arsenal about a
0 half a mile, on Peoria, and it was installed in
l 1991. And its objective is to treat groundwater that
2 went off the Arsenal prior to our boundary systems
3 being installed.
So what we have, again, are layers of
protection there, as far as groundwater and
6 contaminated groundwater migration. If-we want to
capture it before it gets out into the community.
The video mentioned ~ and a very important
9 aspect of it - was the provision of a water supply
0 to South Adams County. Many of you are aware of
this, making arrangements for provision of
2 4,000 acre-feet to South Adams County, and South
3 Adams County, the Army, and Shell are in detailed
discussions right now. They will be ongoing over the
next several months and beyond to work out the
Page 36
l a cleanup level would be for DIMP.
2 Because of some of that, we have made
3 arrangements to make an alternative water supply
4 available to the folks in that area. And it may
5 consist of a hookup to a municipality, whether it be
6 South Adams County or Brighton - they both service
7 that - those areas - or the installation of a new
8 drinking water well. Again, that would be a safe
9 supply for folks out in that area.
0 So that --
l MR. ZEDC SAIDMAN: Charlie, would you say
2 what DIMP was again.
MR. CHARLES SCHARMANN: DIMP is an Army -
4 the by-product of Army chemical production. It's
5 diisopropyl methylaphosphonape, if that means anything
6 to you. Doesn't mean anything to me. But it is not
7 a chemical agent. It is a by-product of those - of
8 the production, operation of that, by the Army.
And we've had probably some meetings with
o many of you on that particular issue.
MR. ZEDC SAIDMAN: Okay.
MR. CHARLES SCHARMANN: That covers the
3 water. Are there any questions of clarification on
4 what we're proposing for water?
MS. CHERYL SHIM1CH: My name is
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I Cheryl Shimich. I'm from Thornton. And on page 2 of
2 that -
3 THE COURT REPORTER: I can't hear you.
4 MS. CHERYL SHIMICH: Yes. I was just
5 wondering if you'd help me understand something.
6 On page 2 of the proposal that you handed
7 out and in your video you mentioned like a billion
8" gallons of water a year is treated on those -- the
9 boundary.
10 Could you help put that in perspective for
11 me? Is that billion gallons a percentage of total
12 contaminated groundwater that you're dealing with?
13 Or do you deal with 100 percent of the contaminated
14 groundwater? Could you give me some percentages,
5 please.
6 MR. CHARLES SCHARMANN: Sure. I'll give it
7 a shot.
8 Again, what we have - that's not only our
9 boundary systems, which included Irondale, northwest,
20 and north, but it also includes our off-post system,
21 which is not on this map. But again, it's about a
22 half mile north of the Arsenal, is our treatment
13 system.
14 What we have is, starting at the source
:5 areas on the Arsenal, we have groundwater plumes with
Page 39
i Those systems - the purpose of those is
2 to go back closer to the sources. What you have is a
3 lower amount of groundwater at that location. So
4 instead of having several hundred gallons a minute,
5 you have 10 to 20 gallons a minute, and that amount
6 of water is more highly concentrated. So you can
7 treat a more highly concentrated water in a lower
8 amount, and it's a lot more effective to do that, to
9 go back toward the sources.
10 Okay? But as it moves toward the boundary,
11 it may become more dilute. You have an additional
12 volume of water to deal with, and it's a little less
13 efficient, but at the same time, it's very important
14 that we have those boundary systems operate to make
15 sure contamination doesn't move off the Arsenal.
16 And the nature of the groundwater cleanup
17 is that it doesn't happen very quickly. And many of
18 these systems will be operating tens ~ if not a
19 hundred years or more -- before we actually could
20 clean the groundwater.
21 MR. ZEK SAIDMAN: okay. Does that answer
22 your question?
23 MS. CHERYL SHIMICH: Yes, thanks.
24 MR. ZEK SAIDMAN: Any Other
25 clarifying questions to Charlie? This is the
Page 38
l contamination flowing to the -- toward the Arsenal
2 boundaries. And these boundary systems are located
3 in areas to make sure they capture all the
4 contamination before it leaves the Arsenal. So we do
5 have effective capture. We don't have groundwater
6 contamination moving off the Arsenal.
So that - as far as 100 percent, those
8 systems were designed and improved over time to make
9 sure that we don't have additional groundwater
0 contamination moving off the Arsenal.
Our off-post system is located in an area
2 where we are again capturing groundwater
3 contamination. It does not capture every portion of
4 the off-post area. They're located in a significant
5 area where we have contamination above health
6 standards, and we want to make sure that the
7 contamination in groundwater that is above health
8 standards doesn't move any further than where it is
9 right now.
So as far as on the Arsenal, what we have,
l we have a couple of systems ~ I failed to mention
2 it. We have another system down in this area where
3 we have a historical source, and we have our Basin A
4 neck system, which is in the vicinity of -• of
5 Basin A, and our South Plants areas here.
Page 40
l clarifying-questions period. Over here.
2 AUDIENCE SPEAKER: Charlie-
3 MR. ZEK SAIDMAN: Can you USC the mic.
4 AUDIENCE SPEAKER: Well, just a quick
5 question.
6 Charlie, I've got a two-page comment that
7 I'm formally going to read and some other stuff. Do
8 you want me to wait till the formal - joke.
9 MR. ZEK SAIDMAN: Yeah.
0 AUDIENCE SPEAKER: AS opposed to - and
l this addresses the Henderson area that I feel has
2 been totally let out of the negotiations.
3 MR. CHARLES SCHARMANN: Yes. And I know
4 there's some strong feelings out there as to the
5 various aspects of the - of the remedy. And if you
6 could bring that up during the comment period, that
7 would be good.
8 AUDIENCE SPEAKER: Do you pump that water
9 back into the ground? What do you do? You treat it
:o and pump it back?
:l AUDIENCE SPEAKER: YCS.
:2 MR. ZEK SAIDMAN: Can everybody hear the
3 question?
4 MR. CHARLES SCHARMANN: I'll repeat it.
5 MR. ZEK SAIDMAN: Repeat the question.
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1 MR. CHARLES SCHARMANN: The question was,
2 do we put the water back into the ground after we're
3 finished treating it.
4 AUDIENCE SPEAKER: Is that how you did when
5 you created the earthquakes in the '60s?
6 MR. CHARLES SCHARMANN: And the follow-on
7 was, is it like when we created the earthquakes back
8 in the '60s. Let roe address that.
9* As far as - after treatment of the
10 groundwater, we put the clean water back in die
11 ground so it then continues to flow off-post
12 AUDIENCE SPEAKER: Pumped underground, high
13 pressure or ~
14 MR. CHARLES SCHARMANN: It is put in the
5 ground in a very shallow - to very shallow depths,
6 less than a hundred feet.
7 The deep disposal well that was used back
8 in the '60s was 12,000 feet deep. So it's really a
9 totally different situation. That was injected way
0 below any useful water supply.
1 AUDIENCE SPEAKER: Arc you retrieving that
2 contamination?
MR. CHARLES SCHARMANN: No, we are not
4 That well was closed in 1985, following EPA
5 procedures. We basically pulled up much of the
Page 4:
1 future.
2 We also are evaluating options to provide
3 the 4,000 acre-feet to South Adams County. There are
4 a lot of different sources of water being evaluated,
5 and we have asked questions as to what water rights
6 are available.
7 Fitzsimons may be one of those that -
8 that •- it's possible but I wouldn't really want to
9 get into the specifics as to, if mat happens, how
10 would it be implemented. That - that whole
11 evaluation process is in the very early stages. It
12 could be that that is not even used as an option to
13 provide water for either the Arsenal or South Adams
14 County. So...
15 AUDIENCE SPEAKER: Thank you.
16 MR. ZEK SAIDMAN: More?
17 AUDIENCE SPEAKER: At this point has any
8 kind of determination been made whether there's going
9 to be a Stapleton contamination factor involved in
20 the cleanup on the Arsenal?
21 MR. ZEK SAIDMAN: Norm, stand up and why
22 don't you use the microphone. People in the back
23 can't hear you.
:4 AUDIENCE SPEAKER: At this point has any
:5 determination been made whether or not there will be
Page 42
1 casing and grouted the well up with a
2 cement-bentonite grout.
MR. ZEK SAIDMAN: Over there. And then
4 over here and then there. Go ahead.
AUDIENCE SPEAKER: My question deals with
6 the article that was in the newspaper this week about
7 bringing the water from Fitzsimons over here, that
8 they need so much more water over to this area for
9 the cleanup process.
And they said -- they weren't clear about
1 how that water was going to get over here. I was
2 wondering if they're going to use a high canal
3 lateral coming across 56th Avenue there at Chambers.
4 And if they do do that, could it be reopened like it
5 is in the Denver area, access for people in the
6 Montbello area?
MR. ZEK SAIDMAN: Can everybody hear that
8 question?
Okay. Charlie, maybe repeat it.
MR. CHARLES SCHARMANN: IguCSSthat
question is very specific to the additional needs for
water in the future, not only the needs that Rocky
3 Mountain Arsenal has. We need to keep water in our
4 lakes; we need water for irrigating areas that we
were re vegetating. That's already in the - in the
Page 44
1 a Stapleton factor involved in the cleanup of the
2 Arsenal, whether there's anything coining off of
3 Stapleton or whatever that could affect the cleanup?
4 MR. CHARLES SCHARMANN: Good point.
5 What Norm's talking about is some of you
6 may be familiar that this is - again, 56th Avenue --
7 going to be extended, is in the process of being
8 extended across this area.
But we have some contamination in
0 groundwater moving onto the Arsenal along the western
1 side of the Arsenal, and we have had discussions and
2 continue discussions with EPA, with various sources
3 south of the Arsenal, including Stapleton, including
4 some other industrial sites. In some cases EPA and
S the Army have recovered some money from some of those
6 Superfund sites down there.
We will continue to do that, continue those
8 discussions to try to find out where sources there
9 are and try to recover any resources that we've
0 expended on that contamination.
I can tell you that South Adams County also
2 is getting active -- or is actively talking to folks
3 down in that area and doing some tests of their own
4 to determine who, in fact, may be contributing to
S that plume that flows in that area.
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l MR. ZEDC SAJDMAN: okay. Any other
2 questions, clarifying questions? Over here. Stand
3 up so we can see if we can hear you back there.
4 THE COURT REPORTER: I can't hear anything.
5 MR. ZEK SAIDMAN: Sorry for the audio
6 problem here.
7 MS. CATHY COFFEY-WEBER: Excuse me. The
8- reporter can't hear questions from the floor. We
9 need people to come forward.
10 MR. ZEK SAIDMAN: Do you have a clarifying
11 question?
12 AUDIENCE SPEAKER: Yeah. Iwasjust
13 wondering if, in the proposed plan of choice,
14 approximately bow many of the sources of the
IS groundwater contamination is going to be cleaned up,
16 percentage-wise.
17 MR. CHARLES SCHARMANN: Did everybody hear
18 the question?
19 Okay. Anyway, how many sources will be
20 cleaned up. I'm going to be covering that under the
21 soils portion of the remedy. So if I could, I'd like
22 to defer that to that portion. If I don't answer the
23 question sufficiently, let me know and we'll address
24 it again.
25 Because the cleanup remedies between soils,
Page 47
1 But at this - at this day we're moving
2 forward to acquire the -- evaluate options for
3 4,000 acre-feet. And I guess I'd open that up to
4 South Adams County to give their view as to, you
5 know, whether that's sufficient or not.
6 But clearly, I think it's •- it's not in
7 their view. So...
8 MR. ZEK SAIDMAN: Any other water
9 questions? Okay.
10 Your next piece is on soil?
11 MR. CHARLES SCHARMANN: On structures real
12 quickly.
13 Just to let you know the major areas on the
14 Arsenal where we have structures, this area here is
15 the South Plants. This area here is our North
16 Plants. And that's where the major industrial
17 activities took place over time.
18 They also have what we call our rail yard
19 area, where we had materials coming in the Arsenal
20 and materials being snipped off the Arsenal, and we
21 have various warehouses over in this area.
22 That's kind of where most of the buildings are
23 located, out here.
24 And what we're planning to do is, in these
25 areas, there's a mixture of fairly clean buildings,
Page 46
1 structures, and water are very much interrelated, and
2 it's important to understand those connections. So
3 I'll try to address that when I talk about the soils,
4 which are the primary sources of contamination out
5 here.
6 MR. ZEK SAIDMAN: Any other water
7 questions? Maybe that's the way to do it, if - any
8 other related to water?
9 MR. ROLAND RUSSELL: Is there agreement
0 that the 4,000 feet is adequate?
MR. CHARLES SCHARMANN: Thanks, Roland.
MR. ROLAND RUSSELL: I'm sorry, I had to go
3 on record.
MR. ZEK SAIDMAN: Did everybody hear the
5 question?
MR. CHARLES SCHARMANN: Is there agreement
7 that the 4,000 acre-feet for South Adams County is
8 adequate?
You know, there isn't, as far as between
o South Adams County and the parties. The role of that
1 whole issue in the discussions on remedy was very
2 important That figure was arrived at throughout the
3 discussions. Whether it was sufficient for all
4 parties, I can tell you probably that's -- that's
5 not the case. There's disagreement on that.
Page 48
1 those that were used for administrative purposes,
2 didn't have a lot of contamination history, and those
3 structures will go into Basin A. We need a lot of
4 material that - to fill up Basin A before it is
5 eventually capped so the - that's where those
6 administrative or clean buildings will go.
7 The other categories that we have, we have
8 some buildings that were used that had a pesticide
9 history. And then there are some that the Army
0 used in its chemical agent production. In those
l two categories ~ both buildings from those
2 two categories will go into our landfill, which is
3 located roughly - will be located roughly in this
4 area here.
5 So fairly straightforward. There will be a
6 few buildings left out here. But by and large, the
7 plan is to take down most of the structures and put
8 them either into Basin A or into our new hazardous
9 waste landfill.
0 MR. ZEK SAIDMAN: Okay. Any questions
l about structures?
2 MR. CHARLES SCHARMANN: Any questions on
3 structures?
4 Yes, sir.
MR. ZEK SAIDMAN: You've got to get up to
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I the - I'm sorry. You and then you. You've got to
2 come to the mic so the court reporter can hear you.
3 Let me suggest this in terms of time:
4 We -- a lot more clarifying questions than we
5 expected. Let's go to 10:30, check in with you then,
6 and then take a break at 10:30, and then give us a
7. full hour for public comments, and I think we can
8 delay the bus for half an hour or so.
9 Is that okay with everybody? So we'll go
10 to 10:30, then we'll check in, see if everybody got
11 their clarifying questions.
12 Okay. This is on structure.
13 AUDIENCE SPEAKER: Just a quick question
14 for you, Charlie. In your proposal that you have
IS that you passed out, you described structural
6 disposal of asbestos and other contaminants as
7 ongoing. What is presently happening to that
8 material now?
9 MR. CHARLES SCHARMANN: Okay. We are --
20 as part of our interim response action program, we
l are taking down tanks and piping and, also, removing
22 asbestos from buildings and along pipelines. All
3 that material is going - currently going off-site
4 to a -- an approved landfill. And I believe
5 currently we are using CSI's -1 think that's the
PageS
1 MR. CHARLES SCHARMANN: The majority is
2 being recycled. It's only that metal piping and
3 tanks that cannot be decontaminated that is being
4 disposed of. Everything that can be decontaminated
5 is being - and can be recycled •- is being taken
6 to a smelter for recycling.
7 I think - Gary Anderson, do you have an
8 idea of what percentage --1 mean, 90-some percent
9 probably is being recycled.
10 MR. GARY ANDERSON: I'd guess approximately
11 95 percent of the metal materials are being recycled,
12 and the other 5 percent would be composed of pumps
13 and motors and things that, as you said, can be
14 decontaminated in the internal working parts.
15 MR. CHARLES SCHARMANN: This is
16 Gary Anderson, one of the project engineers that -
17 senior engineer.
18 You're here managing the various interim
19 cleanup actions that are ongoing.
20 AUDIENCE SPEAKER: Okay. Another
21 question. You said they are being recycled. How are
22 you recycling it? Are you generating additional
23 waste as you are cleaning it up and deconning it?
24 MR. CHARLES SCHARMANN: Do you want to go
25 ahead?
Page 50
l Conservation Services, Incorporated ~ landfill east
2 of here. And -- for that asbestos material.
The metal from tanks and piping and things
4 such as that is being recycled. That which can be
5 recycled is being recycled. That which cannot is
6 being -- it's either being held here on-site or
7 being taken to a hazardous waste landfill, and we use
8 Highway 36.
MR. ZEK SAIDMAN: Does that answer your
0 question?
AUDIENCE SPEAKER: Yes, it does.
MR. ZEK SAIDMAN: This gentleman over
3 here. Did you have a question?
AUDIENCE SPEAKER: Well, I think he
5 answered pan of it.
MR. ZEK SAIDMAN: Okay. Try him on the
7 part you don't think he answered.
8 AUDIENCE SPEAKER: I will.
9 MR. ZEK SAIDMAN: Clarifying question on
0 structure.
AUDIENCE SPEAKER: You mentioned how
2 some of the metals are being hauled away to the
3 landfill and other metals are being recycled. What
4 percentage is being recycled and what percentage is
being hauled away?
Page 52
1 MR. GARY ANDERSON: DO I have to Come to
2 the mic?
3 MR. ZEK SAIDMAN: Yeah, come on up here.
4 AUDIENCE SPEAKER: I'm Staying. I might
5 think of another question.
6 MR. ZEK SAIDMAN: Okay.
7 MR. GARY ANDERSON: The materials that
8 we're recycling here would be going through a defense
9 utilization marketing contract, the DRMO. The defense
o reutilization marketing office is the military's
l utilization office for recycling and, also, for the
2 disposal of hazardous materials and other kinds of
3 materials.
They have a contract in turn with Duwald
5 and Gahagen, and we send our scrap metal to them.
6 They in turn send it to a smelter. And I believe
7 they're using one of the foundries down in Pueblo.
AUDIENCE SPEAKER: The other part of the
9 question was, that percentage of the metal -
MR. ZEK SAIDMAN: You've got to come up.
1 I'm sorry.
AUDIENCE SPEAKER: - that is being
3 deconned or cleaned up, which is about 95 percent,
4 how are you cleaning it? Are you using solvents?
5 Are you using - what?
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1 MR. GARY ANDERSON: The - OUT decoo
2 efforts are a little bit dependent on what kind of
3 processes the tanks were used for. In some instances
4 we're using a hot water wash with a detergent to
5 decontaminate the surfaces.
6 We're -- after we decontaminated it, we do
7 a visual inspection, according to the regulations, and
8. look for any kind of gross contamination that might
9 be left behind. Once the ~ it's - we also use a
10 triple rinse so the surface is washed three times.
11 Once it passes a visual inspection, it's
12 sent off for recycling. We make sure that we're
13 complying with the EPA - the Federal laws, as well
u as the State laws, for the contamination process.
12 AUDIENCE SPEAKER: Okay.
6 MR. GARY ANDERSON: The extra material that
7 we generate is the wash waters that we generate from
8 this-
9 AUDIENCE SPEAKER: Secondary waste.
20 MR. GARY ANDERSON. Correct. And those
21 wash waters are treated here on post at a wastewater
22 treatment plant that we have on post, operated by the
23 Army and its contractors.
4 So we don't really generate any additional
\5 waste treating except for some suspended solids that
Page 55
I be, in some cases, pushing into the excavation that
2 has occurred of the high-level material in each
3 area. So this - let's take, for example, the South
4 Plants. We excavate this red area. We then push in
5 the area around it that is low-level material into
6 the excavation, and then that area will be capped.
7 And the same type of thing will occur in Basin A and
8 around the Basin F area.
9 When we're done, what we'll end up having
10 is a few areas - and I'll show you on another
11 map - where we will have a cap, which, in some --
12 will be different designs in different areas but may
13 consist of concrete, may consist of clay, soil, other
14 materials that - basically, the intent of that is
15 to keep water from moving through that material and
16 taking contamination and moving it in groundwater.
17 And that's what we're trying to prevent.
18 So we're trying to consolidate things into
19 the middle of the Arsenal, shrink the area that will
20 be managed long term as a containment area, and open
21 as much area to be used as the refuge - open up as
22 much area as possible.
23 In addition to just excavating and moving
24 soil into containment facilities, we will be doing
25 some treatment of soil in a couple key areas. One is
Page 54
1 we would get out of the wash water or metals that-we
2 might generate after we've done the treatment of that
3 wash water.
4 AUDIENCE SPEAKER: Okay.
5 MR. ZEK SAIDMAN: Thank you.
6 Okay. Any other structural questions?
7 Any other structural questions?
8 Okay, Charlie. Now your soil.
9 MR. CHARLES SCHARMANN: Okay. The last
0 piece to talk about here is our soil remedy, and it's
l certainly the most complex. I don't want to spend a
2 lot of time on it, but if you have questions, you
3 know, please do ask.
In general, the thinking behind our soil
5 remedy is to, basically, shrink the area that is
6 going to be managed long term by the Army and,
7 basically, move waste in outlying areas into either a
8 new state-of-the-art landfill or into Basin A or some
9 of the surrounding areas.
What we have, the high-level material is
l shown in red on this map. And that material would be
2 excavated and put into our new hazardous waste
3 landfill.
What's shown on green on this map is - is
5 generally low-level soil contamination that we will
Page 56
1 the former Basin F area, which is shown in brown
2 here. We also have a couple sites down in the South
3 Plants area where we will either be doing treatment
4 in place or excavation and treatment of some of that
5 material.
6 The treatment at former Basin F will be
7 done in place, and that will be in-place
8 solidification, where we will drill into that area
9 and inject cement, grout, a solidifying agent to make
0 sure contaminants are bound up and not moving away
l from that site.
2 And that -1 should mention again that
3 Basin F site will have a cap over it when we're
4 done.
5 To address the question about source
6 areas - so we have a mixture. I mean, we have some
7 where we're improving the containment at the site to
8 make sure that contaminants don't move away from that
9 site or we reduce the potential for that to occur.
0 In other cases we are doing some active treatment
l either, in some cases, to destroy the chemical or to
2 tie it up and solidify it, make sure it doesn't move
3 away from the site itself.
4 Does that address the question about source
5 areas? We are taking actions ~ to let you know
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l that — how contamination occurred in the past is
2 that you had liquid, in many cases, in disposal
3 basins that leaked down into the groundwater and then
4 moved. Okay. What's left behind on soils in many
5 cases are contaminants on the soil, and you want to
6 keep water from moving through that to take
7 contaminants into the groundwater and move them out
8 So actions are being taken to address the source
9 "areas and make sure they don't impact the groundwater
10 long term.
ll I can tell you, since the time that we have
12 no longer had actual liquid in the disposal lagoons,
13 we have seen a drop-off in the amount of
14 contamination getting into the groundwater, even
IS without taking actions on any sites.
16 Certainly, by taking additional action to
17 contain the material there, we hope to see even a
18 further drop-off, as far as the level of
19 contamination in groundwater on the Arsenal itself.
20 MR. ZEK SAIDMAN: Clarifying questions
21 around soil? And then again, we have the public
22 comment, where we go on the record. But any
23 clarifying questions around soil?
24 Over here and here. Come up.
25 AUDIENCE SPEAKER: Charlie, how much soil
PageS
l to know exactly what measures we need to take to keep
2 dust from -- from moving away from the site.
3 And not only the dust but, also, potential
4 odors and vapors that may come from an excavation al!
5 need to be addressed as part of the design of -- of
6 the remedy. So I can't really get specific as to
7 exactly the measures, but that's certainly going to
8 be a concern of ours as we work through the design.
9 MR. ZEK SAIDMAN: Roland?
10 MR. ROLAND RUSSELL: To what degree are you
ll going to follow regulations in addition to the
12 Federal? Are you going to comply with State and
13 local?
14 MR. ZEK SAIDMAN: Did everybody hear that?
15 AUDIENCE SPEAKER: Uh-huh.
16 MR. ZEK SAIDMAN: okay. Thank you.
17 MR. CHARLES SCHARMANN: Roland, that is OUT
8 intent. And we certainly want to work closely with
9 not only the State and Federal regulators but, also,
20 local authorities, as well, to make sure everyone is
21 comfortable with the way we are proceeding with the
22 cleanup. That's very much a priority for us.
23 MR. ZEK SAIDMAN: A question back
•A there, sir.
:5 AUDIENCE SPEAKER: Is there any direct
' Page 58
1 is planned to be excavated and moved? And also, what
2 measures will be taken for dust abatement?
3 MR. ZEK SAIDMAN: Did everybody hear that?
4 MR. CHARLES SCHARMANN: Exact volume I
5 don't have off the top of my head, Rick.
6 I believe the amount of material to go
7 into our hazardous waste landfill is on the order
8 of 1.5 million to 2 million yards, cubic yards, of
9 material.
10 And we have a more precise figure in--
11 probably in the proposed plan. If not there, then in
12 other reports. We also have some experts here that
13 may have that.
14 And that's what - that's what goes into
15 the landfill. Other material will be, as I
16 mentioned, excavated and put into either Basin A or
17 into the South Plants area or into the Basin F area.
18 I don't have a figure off the top of my head.
19 It's probably several million yards. I
20 just don't have that figure.
21 But regarding dust abatement, that is a big
22 concern of ours, as well as the community and the
23 parties. Conventional methods would be to wet the
24 material before you do large-scale excavations. We
25 will need to go through a detailed evaluation process
Page 60
1 compensation for the surrounding area, other than to
2 clean up their water and the 4,000 acre-feet, which
3 doesn't seem to be enough? But are there any other
4 compensations that are being considered?
MR. CHARLES SCHARMANN: There have been a
6 number of things raised throughout the discussions.
7 I can't say that there's any -- you're asking for
8 monetary ~
AUDIENCE SPEAKER: Well, that would be
0 one thing.
1 MR. CHARLES SCHARMANN: -issues? Okay.
2 Well, there aren't any -
3 AUDIENCE SPEAKER: The way it affects the
4 property values and things like that. That's the
5 most affected area.
MR. CHARLES SCHARMANN: There are a couple
7 of things that I might want to highlight, also, that
8 are being done to address that concern. It doesn't
9 necessarily result in a monetary payment. But one of
0 the concerns we heard from the community was a - to
l have a medical monitoring program during the cleanup
2 activities and make sure that the actions that we're
3 taking don't affect the surrounding communities.
And the State is taking the lead on that
5 with the Federal agency, the agency for toxic
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i substances and disease registry. You may not be
2 familiar with them, but they are basically the
3 Federal entity charged with that area of medical
4 monitoring.
5 So we have ongoing dialogue to talk about
6 what medical monitoring is necessary during the
7 clean -
8. AUDIENCE SPEAKER: IS that for all of
9 the people in the surrounding area, immediately
10 surrounding area?
11 MR. CHARLES SCHARMANN: That's right
12 That's to address issues of the surrounding
13 communities to the south, to the west.
14 AUDIENCE SPEAKER: I've lived in that area
15 for quite a while, and nobody --1 haven't heard
16 anybody address me about some medical benefits
J 7 possibly or anything like that.
18 MR. CHARLES SCHARMANN. Let me-
19 AUDIENCE SPEAKER: Then the other thing I
20 want to bring out is I think it impacts that
21 whole - the whole area, especially in the
22 Commerce City to Quebec Street area and the northern
23 area, towards the schools.
24 But I had - I had no compensation for
25 those son of things. And people in all of these
Page 63
l that was a very difficult issue to deal with and
2 it was raised. But it did not result in any type
3 of agreement on a monetary payment or anything
4 like that.
5 But the other thing I wanted to mention
6 that is being explored is the establishment of a
7 trust fund. And this is another difficult issue.
8 But there is a lot of concern by the community that,
9 10 years from now or 15 years from now, there may not
10 be money to deal with the long-term operation of the
ll containment sites and the groundwater treatment
12 systems that we leave behind.
13 And there was an agreement to try to set up
14 a trust fund where the interest and, potentially,
15 principal from that trust fund would be used to
16 continue the long-term operation and maintenance of
17 the facilities.
18 AUDIENCE SPEAKER: Will the cities in the
19 surrounding communities have access to that trust
20 fund to ... to improve the neighborhood? Or do
21 I -the health and welfare of the neighborhood?
22 MR. CHARLES SCHARMANN: The intent of that
23 trust fund was solely for the purpose of operation
24 and maintenance of the cleanup of structures or
25 facilities.
Page 62
i films that I've seen or slides that I've seen, there
2 was always some sort of compensation. And I feel
3 that this hasn't been addressed. And I don't know
4 if this is the right forum to bring this up, but this
5 is the ROD. I think this is the right time to bring
6 it up, myself, personally. So -1 want to throw
7 that out.
8 MR. CHARLES SCHARMANN: It may be good to
9 go ahead and ~ and put that on the record during
0 the comment period. That was raised by different
1 entities, and some of them are here this morning, and
2 they can speak about what they raised as issues.
But certainly, I think you recognize the
4 difficulty of trying to sort that out and put figures
5 on things and then determine whether impact has
6 occurred and what level of impact and things such
7 as that.
But there are some steps built into this
9 remedy to make sure that, during the implementation
0 of it, that we all can stand up and say, "This site
l is not affecting the community," that actions are
2 being taken safely. And when we're done with the
3 cleanup action, everyone, can say, "It's a safe site.
4 It's now an asset to the community."
So regarding what happened in the past,
Page 64
i AUDIENCE SPEAKER: So in essence, there's
2 no -- nothing for the community, though.
3 MR. CHARLES SCHARMANN: That's right. That
4 wasn't part of that trust fund.
5 AUDIENCE SPEAKER: Thank you.
6 MR. ZEK SAIDMAN: I would think those kind
7 of comments are pan of the public record comments.
8 But let's focus just in on the clarifying questions.
9 But thank you.
0 MS. LAURA WILLIAMS: Zeik, you have a
1 question up front
2 MR. ZEK SAIDMAN: I'm sorry, Mark.
3 Thank you.
4 AUDIENCE SPEAKER: Two questions, kind of
5 related both to the water and the soil.
6 Do we have a good estimate on how much
7 acreage will be needed for these managed areas once
8 the cleanup is completed and -- let's stick with that
9 one for now.
[0 MR. CHARLES SCHARMANN: Okay. Let me ~
l actually, that leads into the last slide I was
:2 planning to use, which is here, to show you the areas
:3 or the facilities that will be operated long term.
4 And what we have long term to manage are
5 the areas that are to be capped, the South Plants
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l area, area called the Shell trenches, area called the
2 Army complex trenches, Basin A, and Basin F. All
3 those areas will have some type of cap over top of
4 them that need to be - that would need to be
5 maintained long term.
6 In addition to those sites, we'll have a
7 new hazardous waste landfill in this area, which
8 will, again, need to be maintained long term.
9 That's from a soil remedy standpoint. From
10 water, we have our northwest boundary system, our
11 north boundary system, our Basin A neck groundwater
12 system. And the reason some of the groundwater
13 treatment systems have disappeared on this map is
14 that we feel a few of them may be able to be shut
5 down in the next several years because they have
6 accomplished the objective that we constructed them
7 for. And in the case of the Irondale area, we have
8 contamination that is being more rapidly cleaned
9 up - contamination the Army has contributed to that
0 is being more rapidly cleaned up in that area - and
l that is a system we expect to shut down probably in
2 the next four years or so.
Does that address your point, Norm, as far
4 as areas?
AUDIENCE SPEAKER: So it's maybe
Page 6
l that you may be able to ask during a break. But I
2 can tell you, in general, that across the country
3 there is a mixture of actions that are being taken.
4 And I can't say that we have found one that is
5 identical or very similar to Rocky Mountain Arsenal.
6 This is a very complex site, a very large site. So
7 trying to apply something that may have been done in
8 another site that is smaller, had different problems,
9 is sometimes difficult.
10 But clearly, across the country there have
11 been many sites that have put containment structures
12 there, caps. Lowry Landfill here locally is an
13 example of that, where they're using a combination of
14 capping, containment, and treatment.
IS And if you look across the country, there
16 will be some sites where, if they had a small amount
7 of material, they have used, you know, aggressive
8 treatment measures to get rid of that completely,
9 where they can.
20 But we really have seen a mixture across
i the country, as far as doing aggressive treatment and
22 containment measures like landfills and caps.
13 With regard to water, I can tell you that
:4 the Rocky Mountain Arsenal is one of the first sites,
5 if not the first site, where we installed a
Page 66
l not 1 1/2 square miles or -• if you were to come up
2 with an estimate that way?
MR. CHARLES SCHARMANN: Sounds reasonable,
4 you know. Which —
MR. ZEDC SA1DMAN: what was the comment,
6 Norm?
MR. CHARLES SCHARMANN: - there are
8 640 acres for a square mile so - you know, roughly
9 a thousand.
MR. ZEQC SAIDMAN: All right. A question
1 here?
AUDIENCE SPEAKER: This is a general
3 question.
When you worked out your program, were
5 there historical precedents for this? And could you
6 tell us where they were and how successful they were?
MR. CHARLES SCHARMANN: AS far as, I
8 guess ~ any particular aspect of the remedy? The
9 soils portion or the water portion or -
AUDIENCE SPEAKER: No, the general problem
that you have with a contaminated site. What other
2 geographical sites throughout the world have been
faced with this same kind of a problem?
MR. CHARLES SCHARMANN: We certainly have
5 some folks that have some more broad-based experience
Page 68
l groundwater treatment system. Our north boundary
2 system was installed as a pilot system in 1979. We
3 expanded it in 1981, and that was one of the first
4 systems of its type in the country. So in many cases
5 Rocky Mountain Arsenal is precedent setting, and
6 we're on the leading edge of cleanup actions.
MR. ZEK SAIDMAN: Let me check in with the
8 group before we take a break.
How many people have more clarifying
0 questions before public comment? How many people -
l one, two ~ one, two, three. Let's take those
2 three more questions, and let's try to wrap it up in
3 five to ten minutes, and then we'll take a break.
Okay. You and who's next? Who else raised
5 their hand? You. And you over there.
6 Okay. So let's ...
7 AUDIENCE SPEAKER: My question is, you said
8 that you're going to cap the chemicals and everything
9 in these landfills and everything, and then you say
0 that you're checking on the water and some of the
l water systems you're closing down because they're
2 okay.
Is there an ongoing project that would
4 check this over a period of time to see that the
water doesn't leak through the cement or leak through
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l the clay or anything like that?
2 MR. CHARLES SCHARMANN; can everybody hear
3 the question?
4 Okay. The question about monitoring. And
5 we have had an aggressive monitoring program, an
6 extensive monitoring program, out here since the
7 mid-'70s. And that's been expanded and approved and
8-in some cases cut back at times.
9 But we look at groundwater; we also do air
10 monitoring. We take a look at - through the
11 Fish and Wildlife Service - the animals out here.
12 So a lot of very complex monitoring program ongoing.
13 That will continue in the future. It
14 will — we will monitor around sites such as our
15 landfill to try to determine whether, in fact,
16 chemicals are - that are in that facility - are
17 getting out of that and into groundwater. So that
18 will be a key part of that landfill monitoring
9 program.
20 In addition to that, our groundwater
21 plumes, we are monitoring them extensively to track
22 movement. We have a very good handle on where they
23 are and how they're moving. The interest there is to
4 monitor them long term, to go ahead and document that
5 we are seeing improvements to groundwater quality.
Page 71
l well, Laura.
2 MR. ZEQC SAIDMAN: All right. And next
3 question?
4 AUDIENCE SPEAKER: I keep wondering, when
5 we hear about this ongoing cost and so forth and --
6 and the cost - why was an incinerator such as a
7 kiln, cement kiln, that type of thing ~ why can't
8 that be used in the cleanup once and for all, and you
9 don't have to keep coming back and monitoring what
10 was - what is still there?
11 MR. CHARLES SCHARMANN: Regarding where the
12 evaluation of treatment technologies fit in this
13 whole remedy, that was a concern that was raised
14 early on. Many people had that view, that "Let's go
15 ahead and treat it and get it done once and for all."
16 The problem we have at many of the sites
17 out here, the large sites, such as Basin A and the
18 South Plants area, is that you cannot get all the
19 contamination that is there. And in many cases
20 implementing a treatment scenario like incineration
21 of soil is very complex, very complicated, and in
22 some cases, very expensive and would take a lot
23 of time.
24 And we heard throughout the last couple
25 years some concerns about having emissions continue,
Page 70
l And certainly, we need to do that before we're able
2 to shut a system down like we did out in Irondale.
3 You need to go through a monitoring program to make
4 sure you achieve what you hoped to achieve, you know,
5 before you can shut a system down.
6 So there will be - and EPA can probably
7 speak more about this -- a compliance monitoring
8 program — the State can, as well — with the
9 landfill. There are set programs that will need to
0 take place to monitor the effectiveness of the
l remedy.
2 MS. LAURA WILLIAMS: In fact, I'd like to
3 add, Charlie, that under Superfund there's - a
4 containment remedy like this, it's a requirement
5 every five years that all that data that's being
6 collected be reevaluated just to make sure that not
7 only is it protective against the standards that were
8 in effect at the time the remedy took effect but,
9 also, is it still protective, according to new
o regulations that may have been implemented since.
l And if it's not, then there could be some additional
2 work that could be done.
3 MR. ZEK SAIDMAN: Thank you.
4 Barbara?
MS. BARBARA NABORS: You covered it very
Page 72
l too, which potentially would affect the community.
2 In general, I think folks were not interested in
3 having incineration occur out here long term.
4 And regardless of how much treatment you
5 do, you still need to rely on some type of
6 containment portion of your remedy in the form of
7 caps or landfills because you just cannot physically
8 treat all the material that's out here and render
9 it - this a pristine site. You need to take some
o of these - these containment strategies or
l measures, no matter what you do. And what we ended
2 up with was a mixture. We have some sites where
3 we're doing some treatment, and we ~ we're using
4 treatment techniques that seem to be popular or ones
5 that the community and the parties were comfortable
6 with that could - they could be done safely, and
7 they could be done timely, and they could be done in
8 a cost-effective manner.
9 So to go back to history, that's kind of
;o how it evolved, that - early on, I think we all
:j looked seriously at whether we could aggressively
2 treat, you know, the whole site. But it -
!3 practically speaking, it's not possible.
14 MR. ZEK SAIDMAN: Next?
:5 AUDIENCE SPEAKER: I was just curious if
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I you could explain how putting the cap on is going to
2 reduce the' amount of water contamination since, to
3 me, it seems like it would just redirect it and let
4 the water just go underneath and through
5 horizontally. So~
6 MR. CHARLES SCHARMANN: Did everyone hear
7 that question?
8- Okay. What we have, the cap - it's a
9 combination of things that address the total
10 contamination, whether it's in the soil or in -
ll already in the groundwater.
12 The intent is to stop water from
13 percolating through the material and continuing to
14 carry chemicals down. Okay. That we can effectively
IS stop with caps. The groundwater that's already there
16 that's contaminated, that is flowing to our
17 groundwater treatment systems, and we will capture
18 and treat that material.
19 In some areas, such as the South Plants and
20 Basin A area, by stopping water from percolating
21 down, you're going to lower the level of groundwater,
22 where that is. So you're going to reduce the amount
23 of migration that is occurring right now. You know,
24 right now there may be a certain amount of
25 groundwater contamination. As you lower the water,
Page 75
l in the various areas, so feel free to, you know,
2 address the questions to them, as well.
3 MR. ZEK SATOMAN: There are materials
4 around here. So let's take a ten-minute break.
5 (Meeting proceedings recessed
6 10:35 a.m., reconvened 10:50 a.m.)
7 MR. ZEK SATOMAN: Everybody get their
8 cookies and coffee?
9 What we say about an agenda, it's a road
10 map to follow. And we'll adjust to go down the blue
11 routes if we have to.
12 But what we're recommending right now is to
13 go to 11:30 for public comments, and then, at 11:30,
14 those people who want to take a tour of the bus - a
IS bus tour ~ because there are some people, I
16 understand, here who are invited out ~ who came out
17 to the Arsenal to see the wildlife and be a part of
18 this, but they said they would also want to sit in on
9 the public hearings.
20 So the first bus would be available at
21 11:30, but we will continue public comments - we
22 have two more buses. So if you miss the first bus,
23 you can take the third •- second or third bus if you
24 want to do it.
25 MR. BILL THOMAS: Zeik, if I may, for those
Page 74
l the level of that groundwater, you're drying up
2 another area and, effectively, immobilizing more
3 contamination.
4 So a combination of cap, which cuts water
5 from going through the soil and taking more
6 chemicals, along with the groundwater treatment
7 systems, which treat groundwater that is already
8 mi — flowing toward them. You know, the
9 combination is what you're using to deal with that
10 total contamination issue.
ll MR. ZEK SAD3MAN: Let me suggest this:
12 We've gone about 40 ~ we've gone 40 minutes past
13 our break. The people that have questions, my
14 suggestion is to come up and ask the panel or Charlie
15 during the break. If you don't feel they've answered
16 your question as well as they could have, make that a
17 part of your public comment. Because I think people
18 have patiently been sitting here.
19 So let's take a break for ten minutes, ask
20 these guys your questions. If they don't answer them
21 satisfactorily, come back and make a public comment.
22 MR. CHARLES SCHARMANN: I would like to
23 mention one more thing. In addition to the panel
24 members and myself, we have some folks on the Army
25 technical staff that have name tags who are experts
Page 76
l who have to leave at 11:30, we have public comment
2 cards on this table here and the front table. So
3 their comments will still get recorded, okay, if they
4 want to leave at 11:30 to catch that bus.
5 MR. ZEK SATOMAN: Okay.
6 Sir.
7 AUDIENCE SPEAKER: HOW long, about, will
8 the bus tour last?
MR. BILL THOMAS: It's planned
0 approximately 30 to 45 minutes, depending on what
l kind of questions that may come up on the bus. We'll
2 have some technical folks on the bus that can answer
3 questions that you've heard here this morning. So 30
4 to 45 minutes, approximately.
MR. ZEK SAIDMAN: Okay? So the first bus
6 would be taking off around 11:30.
And, Bill, you just want them to go back to
8 the back?
MR. BILL THOMAS: Just come right out here,
0 and I'll take care of you.
1 MR. ZEK SAIDMAN: Thank you.
2 We're now beginning the formal public
3 comment period. As we said in the beginning, we
4 thought, to give everybody an opportunity to speak at
5 least the first time turn around, we would try to
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l keep it around three minutes. I will time that.
2 Again, those comments can be submitted in
3 writing till December 15th. As Bill mentioned, there
4 is the - the Arsenal reply card, plus you can send a
5 document in, also, and it's all on the front page of
6 the proposed plan.
7 So is that okay with everybody? So would
g-you come up to the mic -
9 AUDIENCE SPEAKER: Move that mic back.
10 MR. ZEOC SAIDMAN: And there's a suggestion
11 to move it back so you can address both the table and
12 the audience.
13 How's that, about that angle? I'm sorry?
14 Okay. And I just-I think the floor is
15 open for public comments and let's begin. And I will
6 flag you around three minutes when the time has
7 come.
8 Okay. Who wants to--
9 AUDIENCE SPEAKER: Can I just make a
20 suggestion to speed things up a little bit?
21 At other public meetings I've been to,
22 people have kind of lined up so that each time you
:3 don't recognize somebody and then everybody moves
:4 away-
5 MR. ZEK SAIDMAN: Okay. Queue one up.
Page 79
1 is shut down. I haven't noticed it. Maybe some of
2 you have. But it hasn't had any effect on me. And
3 maybe it saved us some money on our debt, also.
4 I speak not personally but on behalf of the
5 citizens of Commerce City and not necessarily all of
6 them but the majority of them because we've held some
7 public hearings in the city itself with regard to the
8 proposed plan and the eventual record of decision
9 that will be reached, hopefully, in May or June
10 of 1996.
11 We listened very carefully. Initially we
12 had thought that destruction of most of the
13 contaminants out here would be the best way to go.
14 However, a number of the people in our community and
is Montbello and Green Valley, Brighton, and Henderson
16 area voiced their concern about the emissions from
17 the incineration of the soils and the contaminants
18 within those soils, so we relooked at that with
19 information provided by Tri-County, mostly, since
20 they were somewhat an unbiased group. They had the
21 information available, but they weren't a direct
22 party in the Rocky Mountain Arsenal.
23 With that we came to the conclusion that
24 the proposed plan is a good direction to go in;
25 however, we have some concerns. The concerns are
Page 78
l Queue one up. Okay.
2 (Discussion off the record.)
3 MR. ZEK SAIDMAN: Thanks, Bill. Please
4 give your name, if you're with an organization, and
5 the city of residence. You don't - on the sign-up
6 sheet people put addresses but not city of
7 residence. Okay. So name, organization, city of
8 residence.
9 Mayor Busby.
0 MAYOR DAVID BUSBY: What if I said
l "Brighton"? What would you say?
2 I'm David Busby. I'm the mayor of
3 Commerce City. As far as organizations, I'm a member
4 of the coalition, which is Adams County, Commerce
5 City, School District 14, Citizens Against
6 Contamination, and one other one. R A - no, the
7 R A B isn't on the coalition.
8 AUDIENCE SPEAKER: Reeser--
9 MAYOR DAVID BUSBY: Jeannie Reeser'
o office — Tri-County. That's the other one. And I
l also am a member of the Restoration Advisory Board,
2 which meets every other month.
3 The comments I have is, first, I want to
4 thank the panics for hosting this meeting,
5 especially since, supposedly, the Federal government
Page 80
l some of the remedies that have been chosen under the
2 proposed plan, such as Basin A without a liner under
3 it. Hopefully, that the eventual plan will have a
4 slurry wall to bedrock all the way around it That's
5 just a suggestion. So that we get containment that
6 we can rely on.
7 Also, the Shell trenches, the complex
8 trenches, the Hex pits, similar-type remedies that
9 have been chosen under the proposed plan we have
0 concerns with.
l One of the others we mentioned was
2 mentioned by Roland Russell regarding the
3 4,000 acre-feet. We have a tremendous amount of
4 concern over that because the South Adams County
5 Water and Sanitation District has approximately
6 13,000 acre-feet adjudicated or have rights to access
7 in the years in the future. So 4,000 we see as a
8 very low amount that was agreed upon without our
9 input.
0 Last statement, we do support the new
l state-of-the-art, triple-lined landfill that's going
2 to be used. That will give us triple protection
3 versus the present double protection that we have in
4 landfills. And hopefully, this will minimize the
5 cost to us taxpayers - and that's each and every
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l one of us ~ for the eventual proposed plan, while
2 still protecting us and the habitat here at the
3 communities surrounding the Rocky Mountain Arsenal.
4 And that's all the comments I have. And we
5 will be putting it in writing officially from the
6 City of Commerce City before December 15th.
7 MR. ZEK SAIDMAN: Thank you, Mayor.
8- Does the panel have any comments to make on
9 anything?
10 Okay.
11 MS. BARBARA NABORS: You might just mention
12 that all of these public comments that are being
13 recorded and that are received in writing will be --
;4 appear in the record of decision in a responsiveness
5 summary, and there will be a response from the Army
6 to each and every comment And that will be
7 available in the libraries.
8 MR. ZEK SAIDMAN: Okay. Did everyone hear
9 that? A response - there will be a response in
0 writing to these -
l AUDIENCE SPEAKER: Time frame?
2 MR. ZEK SAIDMAN: Time frame, Barb?
3 MS. BARBARA NABORS: Well, let's See. It's
4 this spring. June.
MR. ZEK SAIDMAN: June.
PageS:
I half also be included in the considerations of
2 reaching the ROD.
3 Thank you.
4 MR. ZEK SAIDMAN: Did you give - Roland,
5 did you give your last name, also?
6 MS. CATHY COFFEY-WEBER: Roland Russell.
7 MR. ROLAND RUSSELL: Get it?
8 MR. ZEK SAIDMAN: Did they get it?
9 Thank you. All right.
10 Any comments from the panel? Okay.
ll Next?
12 Thank you, Roland.
13 MR.JIMERGER: My name is Jim Erger. I've
14 lived in the Henderson area for a long, long time.
15 I'm a member of the RAB and the SSAB, so the last two
6 years or so I've sat in on lots and lots of
7 meetings.
8 I have a prepared statement that I'm going
9 to read, and then I will make some additional
20 comments afterwards. And this is addressed to
21 Kevin Blose and William J. McKinney with Shell Oil.
22 "Dear sirs: I'm an actual stockholder of
23 the Rocky Mountain Arsenal pollution, having lived in
14 the Henderson area since 1933. Our family farm is
:5 located at 112th and Peoria, which is in the heart of
Page 82
l MS. LAURA WILLIAMS: June '96 is the
2 current schedule, but it may drop off a little bit
3 because of the government shutdown. So ... whether
4 or not we're up in business.
MR. ZEK SAIDMAN: All right. Okay.
6 Thank you.
7 Roland?
8 MR. ROLAND RUSSELL: Once again, thank you
9 very much for holding this meeting on a Saturday when
0 many, many people could come out. It's not always
l advisable to hold it in the evening, nor on a
2 weekday. I do appreciate everybody coining out
My comments are made in behalf of myself
4 and, also, in behalf of State Representative
5 Jeannie Reeser, who I have represented on the RAB and
6 other committees, such as the Northern Coalition.
We were not completely happy with the
8 conceptual agreement. We feel that there are many
things mat have been left out and that the
0 contamination has occurred over a tremendous period
of time since the Arsenal opened in the early 1940s.
2 We feel that the solutions should go beyond Superfund
and CERCLA law. I would request that the comments or
minutes that were arrived at in the citizen meetings
with the principals over the past year, year and a
Page 84
l the of f-post pollution area of the Rocky Mountain
2 Arsenal.
"In my neighborhood in the 1950s I've seen
4 the pollution of our water from our irrigation wells,
5 alluvial aquifer, so bad it contaminated my
6 neighbor's land, killing all growing crops for
7 years. In these same years, in the early-dawn hours,
8 a blue haze could be seen originating from the Rocky
9 Mountain Arsenal, staying close to the ground,
0 drifting from the southeast to the northwest, towards
l the South Plane Valley. We had to breathe this
2 horrible, smelly, contaminated air.
"The Arsenal has not been a good
4 neighbor. It is my opinion that the U.S. Army and
5 Shell Chemical did a first-class job of polluting the
6 Rocky Mountain Arsenal and the surrounding water and
7 lands, and they should be required to do a
8 first-class job of cleaning up their mess. This
9 cleanup must be satisfactory to the majority of the
0 stakeholders.
"In fanning communities fanners buy a farm
2 to grow crops to make a daily living. As the years
3 go by, they are paying for the farm. When they
4 retire, the farm which they bought and paid for is
5 their retirement program. However, due to the Rocky
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1 Mountain pollution and together with the stigma it
2 has caused for our neighbors, the value of our
3 property - farm property - and that of my
4 neighbors has declined drastically.
5 "I am a member of the Site Specific
6 Advisory Board and a member of the RAB. I have been
7 a member since both - since they've started and
8 have missed very few meetings. During all the
9 negotiations by the parties on the cleanup of the
10 Arsenal, oo-post and off-post, at no time was the
11 Henderson area ever represented by anyone. We were
12 completely left out.
13 "We have received all the off-post plume
14 that contains DIMP. There are over 100 citizens
15 receiving bottled water, thanks to the Colorado
6 Health Department, which spares these citizens from
7 drinking the well water that had been polluted with
8 DIMP. This has been a horrible situation for all of
9 us in the Henderson area.
20 "The water, land pollution has gone on
21 for 53 years, from 1942 to 1995. You would think
22 that the U.S. Government, via the U.S. Army, knowing
23 they caused great damage to its own citizens, would
4 lean over backwards to right the wrongs they have
5 caused. Instead, we have to get on our knees, beg
Page 87
1 "I know the Rocky Mountain Arsenal can
2 never be returned to the pristine state it was in
3 1942; however, if it is capped and contained areas
4 are fenced away from the public, the remaining 85
5 to 95 percent of the Arsenal will become the Central
6 Park of the Denver-metropolitan area, as Central Park
7 is to New York City."
8 And so that is my formal comments, but the
9 comments that I have that - I have been totally
10 frustrated the last few days, trying to ~ we're
11 going to set up a large meeting in the Henderson
12 area, hopefully at the buildings down there with -
13 the County buildings and stuff. I've got a whole
14 bunch of the ladies involved.
15 We're going to circulate petitions; we're
16 going to - instead of being sent back, run over --
17 we've taken all the polluted water that has come off
18 of the Rocky Mountain Arsenal, yet no one has come to
19 us and said, "Well, what are you going to get?" I
20 say, what part of that 4,000 acre-foot belongs to
21 Henderson?
22 You know, nobody says nothing. Where are
23 the pipelines going to go? What size? At one time
24 they were talking 3-, 2-inch, 6-inch pipelines.
25 We're saying, "We want 12-inch pipelines out there."
Page 86
l for safe water, hoping they will give us a little
2 something.
"As you know, the Shell Oil Chemical did
4 their share of polluting our air. I will give them
5 credit that they bought four to five houses just
6 north of the Arsenal on Peoria Street. I know they
7 paid market prices or above for these properties, as
8 two of these families are lifelong friends of mine
9 and were happy with the sale of them. I am hoping
0 mat the Shell Chemical will give the same
l consideration for the rest of the Henderson area.
"Therefore, it seems the solution to
3 correct the problem is to have a totally new supply
4 of water, perhaps from the city of Denver or mountain
5 water, brought to the polluted area. This new water
6 supply, along with the necessary pipelines and
7 distribution lines, should be paid for by the U.S.
8 Army and Shell.
"In other areas of the Arsenal of minor
0 pollution, I would agree with the U.S. Army that,
1 were it possible, capping and containment will
2 suffice. I would recommend the smallest amount of
3 soil you have to move the better and the smallest
4 amount of burning and thermal dispersions you do the
5 better.
Page 88
l We want a surface supply of water that either comes
2 from - like over at Rocky Flats, they're getting
3 Carter Lake water. We want either mountain water,
4 Denver water, or, say, Thornton water or Aurora
5 water.
6 We will not accept any more underground
7 water such as they've been trying to propose to bring
8 out of the Prospect Valley ~ hell, it's got radon
9 beyond the regular stuff that's in the ~ in the
0 water over in this area.
l So that's my comments.
2 MR. ZEK SAIDMAN: Thank you.
3 (Applause.)
4 MR. ZEK SAIDMAN: Next?
5 Try to - again, try to be conscious of
6 other people having an opportunity to speak, and
7 those will be put into the record.
8 MR. RICK WARNER: My name is Rick Warner.
9 I live in Broomfield. I'm with the Site Specific
0 Advisory Board. If that wasn't mentioned earlier,
l it's another board that people can come out and
2 become involved in and get information from. It's an
3 informal board. It's held the last Thursday of each
4 month in the Commerce City municipal building, and
5 sometimes we have intervening work group meetings.
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l It's a - anyone can come. Anyone can participate.
2 Anyone can sit in if they want.
3 I will probably run over three minutes so
4 please feel free to interrupt me.
5 I'd just like to say, to begin with, that
6 over the course of the last three years, some
7 progress that I would like to say that has been made
8 "is meetings of this sort. This meeting I thought
9 went a whole lot better than past presentations;
10 fewer acronyms, less propaganda, less spinning
11 towards one way or the other, a lot of clarity. I
12 think we're on our way.
3 Certainly, in the last year or so,
4 documentation and help from the various parties is a
5 lot better than it ever has been before. There's a
6 lot more openness.
7 So the - they've agreed that the public
8 needs to be involved. I'm afraid what I worry about
9 is that they still don't embrace the public role.
0 They still don't respect the public. I think you've
l heard a little bit about that from Jim. This happens
2 in many areas.
I'd like to read - there's a group called
4 the Federal Facilities Environmental Restoration
5 Dialogue Committee. It's a long name. This is a
Page 9
l contamination has contributed to the degradation of
2 human health, the environment, the economic vitality
3 in local communities. The Federal government must
4 not comply with ~ must not only comply with the
5 law; it should strive to be a leader in the area of
6 environmental cleanup, including environmental
7 concerns, ecological concerns, and health
8 requirements."
9 I can heartily agree with the statement.
10 That's -1 think that's certainly on track.
it That's exactly what I would like to see at the
12 Rocky Mountain Arsenal. I don't think we are
13 approaching that.
14 The third item here is an item they call
IS environmental justice. This is a -- not only
16 theirs, but the president of the United States has
17 issued an executive order on environmental dust for
18 all Federal agencies to follow.
19 It says simply here the Federal government
20 has an obligation to make certain efforts to reduce
21 the negative impacts of environmental contamination
22 related to Federal facility activities on affected
23 communities that have historically lacked economic
24 and political power, adequate health services, and
25 other resources.
Page 90
l committee of Federal agencies, environmental groups,
2 industry, local and city governments, health
3 departments that have gotten together and said,
4 "Things aren't working in Federal facilities. How
5 do we make them better?"
And what they've come up with is a series
7 of reports which, one, helped contribute to the
8 establishment of things like Site Specific Advisory
9 Boards, administration advisory boards. But recently
0 they've released ~ I always forget the name of
l this; I'll look h up - Principles for
2 Environmental Cleanup of Federal Facilities.
And I -- there's 14 of them. I have no
4 intention of reading all of them, but I would like to
5 read you the first one and the third one, the nature
6 of the obligation. "The Federal government has
7 caused or permitted environmental contamination.
8 They are, in fact, the largest in the country.
9 Therefore, it has not only a legal but an ethical and
0 moral obligation to clean up that contamination in a
manner that, at a minimum, protects human health and
2 the environment and minimizes burden on future
generations." 1 think that's an important part right
there, future generations.
"In many instances the environmental
Page 92
l I mention this because of the sort of
2 things that Jim's talking about here. What has
3 happened out here is, over the course of the last few
4 months, we have seen that the citizens have come and
5 said, "We want this contamination treated. We want a
6 system where it will go away, but we don't want
7 further emissions; we don't want more odors and
8 vapors to come up; we want this site cleaned up. We
9 want to feel good about the area we live in. We want
0 our water to be safe; we want our water to be safe;
l we want our water to be safe." They say that all the
2 time. I guess for a reason.
Instead, what the Federal government and
4 Shell Oil Company have done here is they have used
5 water to extort a lesser cleanup of this site and
6 still have not provided nearly enough water to
7 satisfy the needs of Commerce City and Henderson.
8 And we are now playing games with the distribution
9 system, limiting the amount of water that can be sent
0 out there. We don't really know where the plumes
l lie, what - who exactly is going to be covered, who
2 isn't going to be covered.
The very reason there's a proposed plan
4 today is because of water out there, because they
5 agreed to water. There are no details to that
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i agreement. You're agreeing to a pig in a poke if you
2 think this proposed plan has gone far enough along to
3 get what people need out of this.
4 MR. ZEK SAIDMAN: Rich, how close are you
5 to wrap-up?
6 MR. RICK WARNER: HOUTS. Is that
7 three minutes?
8. MR. ZEK SAIDMAN: Can you give us a
9 couple - yeah, it's more than three minutes. Can
10 you wrap up in a couple minutes, and then other
11 people - and then you can come back.
12 MR. RICK WARNER: Just simply, I think what
13 you want here is you want a cleanup that's going to
14 be protective now; people are involved with water
15 because the water's bad.
16 You want people - you want a cleanup
7 that's going to be protective for your children and
8 your grandchildren and my children and my
9 grandchildren. And anybody else's children and
20 grandchildren that come here.
21
This area is developing rapidly. There's
22 going to be more people here in a very short period
23 of time. They need to know the ground they live
14 on is safe, that the winds that blow their way are
:5 safe, and that the water that they're going to be
Page 95
l MR. WALDO SMITH: At the beginning of this
2 discussion I didn't feel like I should be saying
3 anything, but as a result of what I've heard, I would
4 like to introduce into the record part of my comments
5 on this cleanup exercise. And it all starts out with
6 a letter from the acting deputy assistant secretary
7 of the Army from Washington. It's addressed to my
8 colleague, Dennis Gallager.
9 "I would like to thank you and Mr. Smith
10 for your letter of August 29th to President Clinton
11 concerning a trust fund provision in the agreement as
12 a conceptual remedy for the cleanup of the Rocky
13 Mountain Arsenal."
14 And I go further in my comments by saying,
15 with specific reference to a possible trust fund, a
16 little research by a naive layman indicates some
17 interesting facets and financial aspects of the Rocky
18 Mountain Arsenal cleanup. And what I've found was
19 that, over the years, our United States Government
20 has misused the term "trust" specifically in
21 connection with Social Security. They have taken the
22 word "trust" to mean "slush." And as a result, we
23 have concern over our trust funds.
24 This is very unfortunate, that we should
25 allow this to continue. And if I have any breath
Page 94
1 using is safe.
2 (Applause.)
3 MR. ZEK SAIDMAN: other comments on the
4 plan?
5 MR. WALDO SMITH: I'd like to make a
6 comment
7 MR. ZEK SAIDMAN: Okay. Come up.
8 MR. WALDO SMITH: My name is
9 Waldo G. Smith. I'm a member of the SSAB and the
0 RAB. I'm also an aide to Councilman Dennis Gallager
1 of the First District of the City and County of
2 Denver.
MR. ZEK SAIDMAN: Is that ~ does
4 everybody know what SSAB is?
5 MR. WALDO SMITH: What's that?
6 MR, ZEK SAIDMAN: DO people know what SSAB
7 is and the two things you mentioned? I may be the
8 only person mat doesn't
MR. WALDO SMITH: SSAB is the Site Specific
0 Advisory Board to the Rocky Mountain Arsenal.
l MR. ZEK SAIDMAN: And the other thing you
2 mentioned was?
MR. WALDO SMITH: And the RAB is the
4 Restoration Advisory Board.
MR. ZEK SAIDMAN: okay. Thank you.
Page 96
l left in me at the end of this year, I'll continue to
2 pursue this problem.
3 I go on by saying that the trust fund -
4 I'm not going into the details because that's
5 annoying.
6 Please notice that at the beginning of this
7 discussion, under Item 4,1 mention escrow. The
8 scheme would not be effective in the present fiscal
9 year. The Army has been assured of its
0 appropriations for this fiscal year. This situation
11 would, hopefully, give a public-private partnership
;2 an opportunity to bolster the trust fund with
3 individual or corporate tax-exempt donations. This
4 will give the general public a direct chance to
5 rehabilitate the environment we need to protect for
6 our survival and - in parentheses - and
7 politicians. The fiscal control of the trust fund
8 should be overseen by the General Accounting Office
9 as an independent, unbiased government agency.
20 Thank you very much.
21 (Applause.)
:2 MR. ZEK SAIDMAN: Any comments from the
:3 panel? Okay.
;4 All right. Any other comments?
!5 MS. CATHY COFFEY-WEBER: Zeik, right there.
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1 MR. ZEBC SAIDMAN: I'm sorry. Okay.
2 Again, state your name, organization, if
3 you're with one, and your city of residence.
4 MR. SRINAOH IYENGAR: My name is
5 Srinadh lyengar; I come from the Highlands Ranch.
6 Myself and my son were visitors. We just came to see
7 the wildlife but got our program canceled but have
8- sat here listening to what was happening.
9 Just to tell you two bad experiences that
10 we did have -- we're now in the beginning of this
11 process. Just two weeks back I was going through the
12 Mcrritt Island Wildlife Preserve, and I was very sad
13 to read the story of one songbird that would appear
u ten years, people watched it diminish in numbers
15 slowly and finally it died. But today we say we're a
16 thriving wildlife national preserve. And I hope
17 that, in years to come, that you will come to see
18 that similar suggestion here but not hear the same
19 sad story.
20 The second thing is I moved from San Diego,
21 from an area called Tierrasannta, where one of the
22 first things we heard when I went there was there
23 were unexploded shells in that area and two children
24 were killed picking up -- picking those up.
25 And even today the discussion is still going on,
Page 95
i many of you already know, we have written comments
2 that are due by December 15th, and I'll be doing
3 detailed written comments at that time.
4 MR. ZEK SAIDMAN: Sandra, what city of
5 residence did you mention?
6 MS. SANDRA JAQUTTH: I'm sorry, Denver ~
7 I'm a citizen of Denver, Colorado. Grew up in
8 Commerce City and lived here until -- well, lived
9 here for about 30 years before I moved into Denver,
10 which is how I got involved in this process.
11 There are just a couple of things that I
12 wanted to make a point of this morning on the
13 record.
14 As some of you probably realize, there are
15 many of us here who could probably go on for hours
16 about our comments about the cleanup of the Rocky
17 Mountain Arsenal, and that brings me to the way this
8 whole thing is structured.
9 One of the comments I've made in public in
20 the past I would like to make for the record today is
21 that I'm very much opposed to the way this whole
22 document was structured. For those of you who aren't
23 involved in this process, as you read this document
:4 you would think that there are actually
5 five alternatives that are being considered for
Page 98
I after 40 years. And people are still trying to find
2 out how they can get rid of these shells. And I hope*
3 that we won't be able to hear or see those problems
4 come back.
5 Thank you.
6 MR. ZEK SAIDMAN: Thank you.
7 (Applause.)
8 MR. ZEK SAIDMAN: Any comments?
9 All right. Anybody else?
10 Okay.
11 MS. SANDRA JAQUTTH: My name is
12 Sandra Jaquith, and I've been involved in this
13 process for about 12 years. I started off as a
14 member of Citizens Against Contamination, an
15 organization based in Commerce City. We got involved
16 because there was TCE in the water in the Commerce
17 City area, and we started fighting for cleanup of
18 water, and our group continued then into a monitoring
19 process of the cleanup of the Rocky Mountain
20 Arsenal.
21 For the last year and a half I've been a
22 member of the SSAB, which is the Site Specific
23 Advisory Board, and I'm community cochairpcrson of
24 the RAB, which is the Restoration Advisory Board,
25 for the cleanup of the Rocky Mountain Arsenal. As
Page 100
l treatment or a remediation of the Rocky Mountain
2 Arsenal.
And the truth is that what they describe on
4 the second page as the agreement that they reached,
5 the parties reached back in June, really does make a
6 definite agreement about what course they are going
7 to pursue for the remedy as - at the Rocky Mountain
8 Arsenal.
Now, what we've been told is that in the
o process -- this is a legal process that they have to
l follow, the meeting they have here today, and they'll
2 listen to all of our comments. But unless there's
3 something that really will derail their agreement,
4 the agreement is also set pretty much in stone. And
5 so the alternatives that you're reviewing and
6 commenting on I think are really a misnomer. I think
7 it's really an illusion about public comment about
8 the cleanup or the remediation of the Rocky Mountain
9 Arsenal.
My second comment about this process is the
l use of the word "cleanup." And I've used it a couple
2 times this morning. And I'm sorry to have that be
3 such an easy phrase to use because there's no cleanup
4 at this site. At this point there's nothing about
a - "cover-up" is the word 1 use for it. And I
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l don't mean that just to be sarcastic about it
2 It's simply a matter of landfilling
3 contamination, some of the contamination, and putting
4 a — sometimes a very thin soil cap or cement cap
5 over the rest of it
6 One of the concerns we have is the
7 Jong-term monitoring and maintenance of those caps.
8 In our processes of discussion about maintenance,
9 they are talking about a 30-year program, and we
10 think this is a — this is contamination that will
M last for hundreds - if not thousands -- of years,
12 and we're very concerned that, if they're not going
13 to clean this up, that there be an adequate process
4 for monitoring and maintaining the remedy that they
15 have in place, which goes back to Waldo's comments
16 about a trust fund.
7 One of the things that was raised earlier
8 today by Roland Russell from Commerce City is the
9 SAPC process that we were involved in. And that was
20 the discussion that we describe on page 2 when they
21 cited their alternatives.
22 The public was — there were several of us
23 or many of us who were involved in discussion leading
:4 up to the decision of their remedy. But when the
25 parties actually decided their remedy, they went
Page 103
1 directly to the north, northwest of the Rocky
2 Mountain Arsenal, docs not have an alternative water
3 supply. We're very concerned about ail of the issues
4 of water, including the amount of water that is given
5 to SACWSD - which is the South Adams County Water
6 and Sanitation District - how many homes in the
7 plume above the Rocky Mountain Arsenal or north of
8 the Rocky Mountain Arsenal will be hooked up, how big
9 the pipes will be that connect the alternative water
10 supplies with those homes, and whether or not there
11 will be any water available and any process available
12 for expansion by Commerce City or the other
13 communities into the north and northwest area once
14 the remediation has taken place.
15 So as an outline of my major concerns, you
16 can probably see that I'm not very happy with the
17 decisions that they've come to concerning the
18 remedies of the Rocky Mountain Arsenal. I think that
19 they leave a great deal to be desired. They're
20 minimal at best.
21 And I hope that all of you who are here
22 today for the first time, with these kinds of
23 comments in mind, will take some time to reexamine
24 the document they've given you and call some of the
25 agencies on here, particularly including the State
Page 102
1 behind closed doors with their own discussions and
2 decided what the remedy would be.
One of the things that I would ask is that
4 all of the citizens' comments throughout that period
5 of the SAPC negotiations be included as part of the
6 official record so that those are also considered as
7 comments in the process of the decision of
8 remediation of the Rocky Mountain Arsenal.
And last but not least and one of the most
o important issues today ties into the whole issue of
1 the cleanup or the nonclean-up of the Rocky Mountain
2 Arsenal, and that is that the argument for doing
3 covers, rather than any other kind of treatment -
4 well, there are many, money being one of them.
And one of the others is those
6 contaminations aren't reaching anybody. But those
7 contaminants will still be going into groundwater,
8 and we have major groundwater problems out here. And
9 with that in mind, one of the big fights that you
0 heard Jim Erger talk about earlier is how much water
l will be available for the citizens of the surrounding
2 communities whose water has been affected by these
3 contaminants, contaminants that they didn't put in
4 place and that they had no control over.
It's a travesty if Henderson, which lies
Page 104
i and the EPA. I tend to think of the State as here to
2 protect your interests. And though I have
3 disagreements with them occasionally, I believe that
4 they're here for us.
5 Call somebody from Commerce City or South
6 Adams County Water District or ask to get a hold of
7 me or somebody from SSAB or RAB, and we'll be happy
8 to talk to you about some of our concerns and the
9 processes that we have had or the involvement that we
0 have had in this process.
1 MR. ZEK SATDMAN: Thank you.
2 MS. SANDRA JAQUTTH: Thank you.
3 (Applause.)
4 MR. ZEK SAJDMAN: Before the next person
5 makes a comment, I'd promised that the tour group who
6 wanted to take a bus could leave at 11:30. And,
7 Bill, maybe they'd go through that exit down there.
8 MR. BILL THOMAS: if they would, please.
9 Whoever wants to go on the bus tour this
:0 time should, for right now, just exit through there.
:l Thank you.
:2 MR. ZEK SAIDMAN: They've been patiently
3 waiting. But we have other business, and we will
4 again continue with the comments that people want
5 to make.
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1 MS. LAURA WILLIAMS: Zeik, I'd like to just
2 respond a little bit to what Sandy said before we
3 start again.
4 MR. ZEK SAIDMAN: Okay. Can we
5 reconvene.
6 Laura wanted to respond - Sandra -
7 Sandra, Laura wanted to respond to something in your
8-comments.
9 MS. LAURA WILLIAMS: I just wanted to
10 reiterate again that EPA very much wants to hear
l public input in the process. We don't consider it
12 just a little process that we go through. We take it
13 very seriously.
4 And I think that to come to a conclusion
5 that somehow mere was a cover-up, as it's been
6 discussed, unfairly characterizes what's been going
7 on at the Arsenal. We've had a very contentious
8 nature with all the stakeholders involved, lawsuits
9 between the parties going on, and so it makes sense
0 that we do have to come to some kind of agreement
i amongst ourselves before we can even come to the
2 public with any kind of a meaningful proposal on how
3 to clean up the site.
So I believe very strongly that we have
5 come to that agreement; we have commitment from all
Page 10
1 with the Army for many, many years, and we've got the
2 Klien treatment plant built at the Army's expense and
3 EPA. They did a very good job, and they worked very
4 closely with us.
5 The problem is is the Klien treatment plant
6 doesn't deal with some of the future contamination
7 that we see coming at us, and that's why we felt mat
8 the only way to put this community back is to - to
9 have a new water supply.
10 It's probably the most critical thing for
ll the Commerce City area and the Henderson area, is
12 mat the water supply be replaced. We've - we've
13 got the rights to -1 believe it's around
14 12,000 acre-feet of water. The Army and Shell are
15 saying, "We'll replace 4 of it, 4,000 acre-feet."
16 But we don't think that's enough, especially with the
17 Henderson area.
18 The main reason is, if you have
9 4,000 acre-feet of very pristine water that you can
20 mix with the Klien treatment plant water, it would
21 probably -- we'd end up with something that would be
22 acceptable to the citizens. But we've got to make
23 sure that it's a - it's very high-quality water,
14 and we've got to make sure that Henderson is
:5 dealt with.
Page 106
l the stakeholders saying, "Yes, we believe this is the
2 right way to go." And this meeting, even though it
3 is part of the formal process, is our way of coming
4 to the community and saying, "Please tell us what you
5 think of this."
So at least from the Environmental
7 Protection Agency's viewpoint, this is a very
8 important part of selecting that remedy. It's not
9 just going through the motions of pretending that
0 we're hearing what you have to say and then just
l coming up with our own decision. And I feel that ~
2 I've been involved at a lot of other Superfund sites,
3 and this is a very typical process for all Superfund
4 sites. It is not something just specific to the
S Arsenal.
MR. ZEK SAIDMAN: Thank you.
Comment? For the record. And name ~
MR. LARRY FORD: Okay. My name is
9 Larry Ford. I'm the manager of the South Adams
0 County Water and Sanitation District in the Commerce
City area. I live at 12388 Leevy Circle in
Henderson, Colorado.
I thought maybe I ought to get up and say a
few words so that you do know that the water district
is very interested in what's happening. We've worked
Page 108
1 The citizens -- there's a lot of you
2 sitting in this room -- we went forward, we got the
3 coalition formed and several other committees. We
4 got to sit at the table in the negotiations. We feel
5 we were a friend of the Army and EPA - Army and -•
6 and Shell. I think they got by with a lot less than
7 they would have got by with if they - we hadn't
8 have been at the table.
I think the State and EPA wanted much more,
0 as far as the cleanup. But we knew we had to get it
1 done. We couldn't sit here for another ten years
2 before we made a decision. We couldn't end up in
3 court
But I think the main thing was that we
5 expected that we would end up with a water supply for
6 the community that would help put our lives back
7 together, that we would ~ that we could see growth,
8 we could see things happening that hasn't happened
9 now. Maybe our property values would come back. We
0 live out here, we can't get any development, and it's
1 all because of the water.
We're not saying the Army's totally
3 responsible. We know they're not in our present
4 area. So maybe the 4,000 acre-feet doesn't look bad
5 for our area, if it's good water, but -- but what
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l about Henderson? Henderson's very important because
2 the contamination in Henderson is directly related to
3 the Army and the Rocky Mountain Arsenal.
4 So I guess I play on the Army and Shell's
S sympathy, that - you want the citizens behind you,
6 you want to get this thing wrapped up. You know,
7 look at - look at Henderson, look at some more
8 -water, and look at a good quality water so mat our
9 community can be put back together.
10 Thank you.
11 MR. ZEDC SAIDMAN: Thanks.
12 (Applause.)
13 MR. ZEK SAIDMAN: Okay. Additional
14 comments?
15 Okay. Name, organization if you're with
16 one, and the city.
7 MR. DAN MULQUEEN: My name is
18 Dan Mulqueen. I'm a resident of Denver. I'm a
9 member of the Site Specific Advisory Board and the
20 Restoration Advisory Board.
21 And as a result of the - a lot of people
22 have referred to the fact that some organizations of
23 people were involved in the SAPC steering and policy
4 committee -- subcommittee - or committee
5 negotiations. And when that came to an end and we
Page HI
l which - very strong law against burying hazardous
2 waste without treatment. There's no document that
3 containment of waste is, in the public perception,
4 far superior to dispersal through incineration.
5 But I don't think that the matrix goes far
6 enough, in that there are alternatives to just
7 untreated land disposal. I think there's
8 alternatives to incineration. I think those have to
9 be considered at greater length than has been
10 considered here.
11 Right now I think what's being considered
12 for - as waivers against land ban are things that
13 may or may not be legal, and I think they should be
14 looked at really seriously. I think just an
IS agreement, the conceptual remedy - agreement on a
16 conceptual remedy made by the parties is kind of an
17 agreement not to sue each other over these things.
18 And I think a Judge ought to look at this
19 and see whether or not RCRA is in ~ kind of being
20 sidestepped by what's called the CAMU rule, which is
21 a rule that they're - it's already been sued under
22 by the Environmental Defense Fund in Washington, and
23 there's some kind of a settlement working on that,
24 where the EPA has agreed to either rewrite or do away
25 with CAMU.
Page 110
l were finally invited out of the negotiations, we
2 did 10 or IS minutes of a round on the 20 different
3 sites or so, what objections and what concerns we had
4 about those sites.
But one issue came up for every one of
6 those sites and one issue only, and that was dioxin,
7 which is a contaminant that citizens have suspected
8 out here for a long time due to the haphazard and
9 uncontrolled burning, and it's a great health
0 concern, worldwide and locally.
And we still haven't seen any information
2 or any approach to dioxin as a contaminant. That's
3 something we think might be a serious mistake, due to
4 the fact that this will be a wildlife refuge; the
S wildlife might be impacted by it if it's here without
6 testing for it anywhere. I think there's a great
7 risk that the wildlife refuge might be
8 nonsustainable, nonsupported, and might become a
9 problem in the future. And I just - I really mink
o we need an answer to that before we go too much
l further.
We have another problem »I personally
3 have a real problem with the fact that land disposal
4 restrictions - which is something that Congress
5 instituted in 1984 in the Reagan administration,
Page 112
l Now, if this whole remedy is built on
2 supposed exemption from the land ban and that
3 exemption goes away before the remedy's even begun to
4 be implemented, where are we then? Well, let's see a
5 contingency for that.
6 Let's see some contingencies for seeing if
7 keeping the lakes full doesn't - if that
8 doesn't - it's theoretical. They say, if they find
9 enough water to keep the lakes full, then the plumes
.0 won't move around. Well, what if that's not true?
II I mean, these are the kind of things we're
.2 going to find out when they're performed. You know,
3 hopefully, it will be good enough monitoring that
4 we'll know whether or not this is successful. If
5 it's not successful, then what? I think we have the
6 right and the obligation to consider these things,
7 and the public should be able to comment on these
8 things, not just comment on what we've already seen.
9 I think we - we need to see the
20 contingencies. What happens if these things don't
l work? What happens if the rules change? What
22 happens if the laws and the exemptions to the laws
3 change or are found illegal? Then what?
14 There's a lot of money here. There should
:5 be more money. Poor - the Federal government
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i poor-mouth and - about cleaning up their own mess
2 infuriates me. When they need a B-l bomber, there's
3 no poor-mouthing. They just go get the damn money.
4 The whole government's supposedly shut down today,
5 nonessentials shut down today. Well, they found a
6 way to put this together. They found a way to cany
7 jt out Shell came up with the money to pay the
6 salaries of the people who came today.
9 Let's - you know, let's get one way or
10 the other. We either don't have the money or we do
11 have the money, but I think it should be
12 generalized.
13 And the issue of water is - is critical.
M I think we should see the water before we see the
is decision.
16 Thank you.
17 MR. ZEK SAIDMAN: Thank you.
18 Comments from ~
19 MS. BARBARA NABORS: I wanted to respond to
20 part of Dan's comment.
21 In response to the dioxin issues, that's
22 been a concern that's been expressed by Dan and other
23 stakeholders. The State went ahead and embarked on a
24 small-scale study to look at the dioxin in the tissue
25 of animals and soils here at the Arsenal, and I've
Page 11
l formal public comment process that you're seeing here
2 for the proposed plan.
3 MR. DAN MULQUEEN: Can you name that
4 process? Is that significant - the planning a
5 significant difference? Is that what -
6 MS. LAURA WILLIAMS: It's just called
7 post-record of decision changes, and there are
8 two different documents that can be produced as a
9 result of that One is the explanation of
10 significant differences, and die other one is called
11 a ROD amendment, literally amends the entire remedy.
12 MR. DAN MULQUEEN: And can you tell US
13 which of those are open to public comment?
14 MS. LAURA WILLIAMS: Sure. The ROD
15 amendment 100 percent is. The explanation of
16 significant differences is made available to the
7 public, does not incorporate public comment, quote,
8 unquote, as part of its selection, but it can be
9 developed that way.
20 AUDIENCE SPEAKER: And that's up to
21 the EPA?
22 MS. LAURA WILLIAMS: Up to the parties
23 as - as things are being developed. I would think
14 it's more a reflection of community involvement and
:5 community concern, more than it is does EPA want to
Page 114
1 been frustrated because that data isn't available
2 yet. And I know that you've been asking me
3 frequently about the whereabouts of it.
4 Part of the reason for the delay is that
5 our wildlife toxicologist, who's performing the
6 study, decided that we needed to expand the scope of
7 the analysis, and that is the reason that we haven't
8 gotten the information out yet. But I can commit to
9 you that, when we get it available, we will make that
10 available to the other - to the stakeholders.
11 MR. DAN MULQUEEN: Thank you.
12 MS. LAURA WILLIAMS: I also have a small
13 comment-
14 MR. ZEK SAIDMAN: Laura.
15 MS. LAURA WILLIAMS: -just in terms of
16 the Superfund process.
17 If there are changes in the remedy that are
18 made, if they're small changes - such as, "Well,
19 let's move the building over 1 foot" - that
20 generally does not go out to the public for
21 additional comment. However, if it is a large change
22 which says, "We can no longer landfill" or "The cap
23 is going to be changed so significantly that it's
24 totally revised," that will go out to the public for
25 additional comment, and it will go through this
Page 116
1 doit.
2 MR. ZEK SAIDMAN: Okay.
3 MR. RAY RAUCH: comments, Zeik.
4 MR. ZEK SAIDMAN: Michael, Ray. Okay.
MR. MICHAEL ANDERSON: I'd just like to
6 comment that Shell, as well as the other parties here
7 at the table, except the Colorado Department of
8 Health, are all signatories to a Federal facility
9 agreement in 1979 which had a settlement agreement
0 associated with it on how Shell would help pay for
1 cleanup activities.
Shell is not paying the Army while they're
3 on furlough. That is an incorrect statement, Dan. I
4 don't know where you got your information.
MR. ZEK SAIDMAN: Ray, did you have
6 something?
MR. RAY RAUCH: Yes. To date the service
8 has found no wildlife that attributes the death to
9 dioxin. We provided specimens to the State to look
o for dioxin residues there. So to date we don't have
any evidence of any wildlife that's been affected.
MR. DAN MULQUEEN: But you say that you -
3 you haven't found anything that you've attributed
4 dioxin as a cause of death.
MR. RAY RAUCH: Cause of death.
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1 AUDIENCE SPEAKER: But have you found
2 wildlife with tissue concentrations of dioxin?
3 MR. RAY RAUCH: No. That's what's provided
4 to the State, to look for those. But we found
5 other - the contaminants and if it's another
6 wildlife disease or trauma, hit by a car or
T something.
8 MR. DAN MULQUEEN: okay. Do you know what
9 the - what the — what kind of pathology results
10 from dioxin poisoning?
11 MR. RAY RAUCH: We didn't look for dioxins
12 on those things. We were looking for the chemicals
13 of concern.
14 MR. DAN MULQUEEN: Why are not the -
15 Charlie, why are not the dioxin, PCBs, MDMA, and -
6 one more -- are not in the human health risk
7 characterization? There's — there are four
8 chemicals that seem to be drivers that aren't listed
9 here. Do you remember what - when -- what are we
20 going to do about that?
21 MR. CHARLES SCHARMANN: Well, let me first
22 explain how we went about developing that list that's
23 in the proposed plan.
14 The contaminants of concern, that list
5 resulted from an exhaustive review of all the
Page 119
l additional work, and based on that, there may be
2 something identified to say, "Hey, maybe you need to
3 do some additional work for dioxin." But our view is
4 that that is not the case, and - but we're open, as
5 studies go on, to take a look at that.
6 MR. DAN MULQUEEN: Wasn't that» isn't
7 the part of the beauty of a burying solution, in that
8 it doesn't really matter what's there; you're just
9 burying it anyway?
10 MR. CHARLES SCHARMANN: Well, you certainly
11 have to have a material characterized to the point to
12 know what containment measures to use, and you want
13 to make sure liners ~ to the extent that you're
14 using liners -- are compatible with the waste that
15 you're putting in touch with those liners.
16 So certainly, you know, you need to have
17 some level of characterization done. We feel we have
18 extensive soil data to know, you know, what we're
19 putting in our landfill. And yes, in the case of -
20 if dioxin were there, it would be contained by the
21 facilities we're putting in, that's right.
22 MR. ZEK SAIDMAN: Let me give some
23 other -- thank you.
24 Anybody else? I mean -- opportunity to
25 ask a question.
Page 118
l chemicals that were used on Rocky Mountain Arsenal
2 and a database that -- we had to figure out exactly
3 what we expected to find out here. That's a very
4 extensive list of chemicals. Okay.
We did some screening analyses as part of
6 our investigations to find out exactly what may be
7 there, and we used that information to tell us how
8 frequently some things were detected and ~ in order
9 to get us a smaller list. That's not a list of every
0 single compound that may be at a site, but it's a
1 list of chemicals that would drive you and your
2 decisions of what remedy you pick between a -- to
3 clean a site up.
In the case of the animals, a smaller list
5 was developed because those are the chemicals most
6 likely to be found in animals out here. Based on
7 historical analysis, our view was that dioxin, if -
8 we do not have a likelihood that dioxin would be out
9 here in levels that would be of concern. And in
0 fact, much of the remedy that we've already developed
l for other chemicals also would address dioxin or
2 other chemicals that are in that area.
So because there was not a specific program
4 for it, you know, does not mean that it's not being
5 addressed by our remedy. The State is doing some
Page 120
1 And let me - Bill was asking me if
2 there's anybody else interested in the tour bus. Is
3 anybody else? Okay.
4 Bill, do we have a bus available? Do you
5 want to go now, or do you want to stay —
6 AUDIENCE SPEAKER: We want to stay.
7 MR. ZEK SAIDMAN: You want to Stay.
8 Okay.
9 MR. BILL THOMAS: So can I get a show of
0 hands how many people are interested in a tour?
1 That's fine. We have plenty of room.
2 Thank you.
3 MR. ZEDC SAIDMAN: Okay. And about a half
4 dozen, Bill, raised their hand.
5 Do you want to stay till the end of the
6 hearing? Okay.
7 All right. Let me just also get a show of
8 people who want to make comments. How many more
9 people want to make - this gentleman does over
0 here. Anybody else besides this gentleman in terms
l of comments? Okay.
2 Go ahead.
3 Name and organization, if you would.
4 MR. RON PACE: My name is Ron Pace. I'm a
5 citizen of Commerce City, and I have been for life.
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l First of all, I want to thank the board for
2 at least coining out And you have been very
3 informational, and I thank you for that
4 But to the citizens, I -1 thank you for
5 your concern. As you know -- as you see me, I'm a
6 very young person, and I am very concerned about the
7. water situations and the soil that is here at the
8 Arsenal. I've lived here my whole life, and the
9 biggest complaint that I hear, just from friends that
10 I have over, is "What's this smell? What's the
11 water?" Well, I agree with them. What is the
12 smell? What is the water?
13 And one thing I ask - and that I want to
4 take part of - is let's unite, let's get this thing
5 fixed. I want to know the organizations that I can
6 stand behind that is going to watch people like this
7 and say, "Hey, let's get this thing fixed. We can
8 work together, that's fine, but let's get it fixed."
9 I want to thank everybody for their
0 concerns, and I appreciate it from one young person
i to everybody else.
2 (Applause.)
3 MR. ZEK SAIDMAN: okay. Final comments?
4 Rich, you had some more comments?
Okay. Does anybody -- has anybody not had
Page 123
l long-term effects over a short-term period. And I
2 don't think that's reasonable.
3 And also, when they did the background
4 tests for what's north of the Arsenal, what
5 contaminants there are there, they didn't do anything
6 from the south. There are no test sites from the
7 south of the Arsenal. All of them were north.
8 There's one east, one west Where in the hell's the
9 south?
10 That doesn't make any sense, logically, for
11 scientific conclusions.
12 MR. ZEK SAIDMAN: Panel, do you want to
13 respond to that point?
14 Charlie?
15 MR. CHARLES SCHARMANN: Yeah. I guess I'd
16 like to question whether you're referring to water or
17 soil tests first.
18 MR. ROGER BAIN: Both.
9 MR. CHARLES SCHARMANN: Okay. With regard
20 to the soil tests that were done, we did a lot of
21 soil sampling on the Arsenal. And based on those
22 results, we were able to see where soil possibly had
23 blown off the Arsenal. And the trends, based on wind
24 patterns -- basically, the prominent winds are to the
5 north and to the east. And so that's where surface
Page 122
l a chance to speak who would want to speak?
MR. ROGER BAIN: I think I want to say
3 something.
MR. ZEK SAIDMAN: Do you want to say
5 something?
6 If you don't mind, Richard.
7 MR. RICK WARNER: No.
MR. ZEK SAIDMAN: Anybody else who wants
9 to speak before we repeat again?
0 Okay. You want to speak.
l Okay. Anybody else?
2 All right. And then we'll go back
3 through people who had a chance to speak already,
4 to be fair.
MR. ROGER BAIN: My name's Roger Bain. I
live in Henderson.
And one of the things - this whole
8 situation has been frustration to me. Part of
9 it's --1 didn't understand how they came up with
0 the conclusion to not clean up anything off-site. I
read the materials at the library, and I did not -
was not happy with the fact that they did their
3 tests, were short -- let's see, how do I want to say
this? They tested their like unknown pesticides on
dogs. They fed them to them for a month to determine
Page 124
l soil was blowing, and that's where we concentrated
2 our tests.
We did take soil samples on the south edge
4 of the Arsenal, and...
5 AUDIENCE SPEAKER: Not off.
MR. CHARLES SCHARMANN: Right. Not off
7 because, based on the results that were on the
8 Arsenal, we did not see results that were high enough
9 to say that it would go any further south.
I believe EPA, in response to some concerns
l of some citizens down in the Montbello area, has
2 taken some samples, but that's - to address the
3 specific concerns of folks in that area.
But based on the data we have on-site, I
5 think that the parties are in agreement that we've
6 looked at the areas where there was a chance that our
7 chemicals could have migrated.
With regard to groundwater, groundwater
9 flows from the south to the north to the northwest.
0 So that's ~ that's the reason why we concentrated
l our efforts in groundwater, you know, to the north,
2 because those are the areas that could have been
3 impacted by our Arsenal operation.
MR. ROGER BAIN: I understand that part but
5 I'm thinking of like a blank. You know, what's not
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l there is in the south or south -- on the southern
2 side. So anything that you do on the north side, you
3 do have contamination, you have a level that's
4 already there, you're not seeing that - well, maybe
5 before anything was here to the south -- you're not
6 seeing what wasn't there.
7 Does that make any sense?
8. MR. CHARLES SCHARMANN: AS a - like a
9 background sample? Is that --
10 MR. ROGER BAIN: Yeah. I mean like
11 blank-
12 MR. CHARLES SCHARMANN: Okay. We did test
13 some areas totally removed from Rocky Mountain
4 Arsenal. And in some cases we went north and east of
5 Brighton, you know, areas that would not be impacted
6 by, say, wind transport of soils and things such as
7 that And we took some samples to try to establish
8 what the ground ought to be, and in an agricultural
9 community you do have some pesticides in your
20 background samples.
21 MR. ROGER BAIN: I understand that.
22 MR. CHARLIE SCHARMANN: And we used that
13 information to see whether the Arsenal has impacted
4 the areas above what we would call background
5 levels.
Page 127
l know, we try to make ourselves available to address
2 questions. Some folks have been involved in
3 discussions over the past year, year and a half. We
4 always can do a better job of that.
5 And you know, we'll be committed to work
6 with you, whatever meetings that you want to attend
7 where we talk about the water supply issue, who gets
8 hooked up, who doesn't, you know, where pipelines go
9 and things like that.
10 A lot of that has not been even discussed
11 yet. The commitment is there to address that area.
12 How we go about doing that in terms of where the
13 waterlines are - is it South Adams County? Is it
14 Brighton? There are new wells that need to be
15 installed, things such as that. Those discussions
16 need to take place.
17 We've been working with Tri-County to try
18 to survey the area to see what some of the concerns
19 are that people want to know. There's -- we've heard
20 there were some concerns of some folks who saw that
21 survey.
22 So I guess we'd like to work with whoever's
23 interested in that, but we need to get out in that
24 area and hear some of the concerns, and that was the
25 purpose of this survey that was developed by
Page 126
So we did try to address that. Taking
2 samples south of the Arsenal, you know, wouldn't
3 necessarily be background, necessarily. You know,
4 north of the Arsenal it's highly agricultural so we
5 went into areas like -• again, I said north and east
6 of Brighton where •- that are similar but unaffected
7 by the Arsenal. So we did try to address that very
8 issue.
MS. BARBARA NABORS: You might also mention
0 that the State was concerned with the soil off of
l those, as well. And as part of the conceptual remedy
2 and the off-post RAB, there's going to be 160 acres
3 of surficial soil tilled to try and remove it from
4 the surface in the off-post area.
And I'm thinking that perhaps your comments
6 about short-term versus long-term tests had to do
7 with DIMP and water and the mink studies and that
8 sort of thing. That -- you probably know that that
9 was a major, major concern of the State.
And the Army is using our State groundwater
l standard of 8 parts per billion so we are ~ feel
2 comfortable that that issue has been resolved.
MR. CHARLES SCHARMANN: I guess one further
4 thing, address your concern and then Jim's comment
regarding being left out. And I apologize. You
Page 128
l Tri-County, was to use that as a vehicle to get out
2 there and find out, you know, what the people had on
3 their mind, what they want. Do they want to be
4 hooked up to a municipal water supply? You know, do
5 they want a monthly water bill? Things like that.
6 I mean, we don't want to force something on
7 somebody, so we need to definitely get in touch with
8 the community.
9 And, Jim, we'd like to work with you and
0 anybody else, really, who wants to get involved in
l that We need help on it.
2 MR. ROGER BAIN: Okay. I don't have other
3 questions.
4 MR. ZEK SAIDMAN: Okay. Back there, this
5 gentleman. Comment on the proposed plan, name, and
6 organization.
7 MR. MDCE WALTENBURG: My name is
8 Mike Waltenburg. I live in Commerce City. I've been
9 a 30-year resident of the area. I was stationed at
0 the Arsenal for 4 1/2 years, and I have several
l questions about carcinogenics.
2 The thing that I had some questions about
3 is, right now I've asked several questions, and I
4 have not received any direct answer on any of them.
5 I've had disturbing questions. For one, I have ~
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l right now,I don't believe any of the people on the
2 board can sit there and give ~ have a list of all
3 the names of the people that worked on the Arsenal,
4 what happened to - up to this time - on health
5 issues.
6 MS. LAURA WILLIAMS: I think EPA Can.
7. MR. MKE WALTENBURG: Do you have it
8 with you?
9 MS. LAURA WILLIAMS: I don't have it
10 with me.
11 MR. MKE WALTENBURG: HOW long would it
12 take you to give me this information?
13 MS. LAURA WILLIAMS: I don't know. I'd
4 have to check.
5 MR. MKE WALTENBURG: The Other one - the
6 other thing is the carcinogenics that the Arsenal had
7 at the time, from the inception until now, that -
8 the waterborne, the movement of the water. What
9 happened to all the little particles of dust every
0 time the wind blew out here and it picked up and went
1 to the south, went to the north, went into Commerce
2 City, and even went down into Denver?
And I -- you know, 1 don't hear any -
4 anyone saying that we have a medical program or -
5 or even an organization or even a ~ something to
Page 13
l millions of dollars overseas every year, but we live
2 in this area. I think some of this money that's
3 being spent ought to be spent at home. What we're
4 doing right now is killing ourselves talking
5 about it.
6 That's all I have to say. I - my family
7 is what I'm interested in.
8 MR. ZEK SAIDMAN: Comments from the
9 panel?
10 MR. RAY RAUCH: On - the prairie dogs I'd
11 like to address.
12 We didn't kill them off on the south. We
13 sprayed for fleas; we killed the fleas. Prairie dogs
14 were diving from die plague. That's why you saw it
is And we was outside the fence so... excuse me.
16 MR. MKE WALTENBURG: Well, I was in the
17 program at the Arsenal back in the '60s when the
18 plague was in, and we trapped some of the animals
19 that were here then. And I don't ever remember
20 putting flea powder on the hole and then closing it
21 with my foot.
22 MR. RAY RAUCH: In the '60s the Service
23 wasn't here. So I'm talking about now, what we've
24 done.
25 MR. MKE WALTENBURG: Yes. I watched the
Page 130
l fall back on for skin cancers, for any of the number
2 of things that can come up with these carcinogenics.
I don't think anybody really thinks about,
4 you know, this stuff could have happened -- you
5 could have driven by the Arsenal in a dust storm in
6 the '60s and die tomorrow from it.
And this stuff is continuing to go on.
8 Right now they're talking about putting caps on
9 them. What happened to the caps right now? Are
0 there exposed areas right now? They're talking about
l surface. I asked a question here about a year ago
2 about --1 watched them killing off the prairie dogs
3 out here. They said that they were doing that
4 because they were getting rid of the prairie dogs
5 because there was ground pollution. Excuse me. They
6 were within 200 yards of the edge of the Arsenal. If
7 there was ground pollution there, why weren't they on
8 the other side of the road?
A prairie dog, to me, does not burrow more
0 than about 18 to 20-some inches. Maybe I'm wrong.
That means that he is in the top area where I live.
2 The dust that is what he breathes I breathe.
You know, how far are they going to go with
4 the -- with this extermination thing? It's us that
are being exterminated. Very slowly. They send
Page 132
l individuals. That's fine. This is not going
2 anywhere.
But I watched them putting powder upon the
4 ground - no, they weren't spreading it around; they
5 weren't putting it tracking to kill the fleas. They
6 were putting it in the holes and closing it. When -
7 usually when you're going to take and destroy a
8 burrowing animal, that's how you do it.
And I noticed shortly after that there
o wasn't hardly -- back on Highway 2, there isn't that
l many prairie dogs left. Two or three years ago we
2 had thousands up through there. Now, perhaps maybe
3 something has come through there.
But if you want to get rid of the base food
5 for the - for the eagles and stuff, I think the
6 prairie dogs are right where you want to start. I'm
7 possibly mistaken on it.
8 - MR. RAY RAUCH. No. Prairie dogs is one of
9 the main prey species. '50s, '60s, I can't address
0 that, but I can address what the Fish and Wildlife
1 has done since the middle '80s out here, and it has
2 been spraying for fleas. So -- and we are losing
3 prairie dogs. We lost 98 percent of the prairie dogs
4 to plague this year.
MR. MKE WALTENBURG: All right.
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1 MR. ZEBC SAIDMAN: Michael, do you have
2 something you want to comment?
3 MR. MICHAEL ANDERSON: I'd just like to
4 comment there have been a number of health studies
5 done by ATSDR, by the Colorado Department of Health,
6 and most of those studies are available to indicate
7 whether or not there have been issues in terms of
8- health impacts by contaminants at the Arsenal.
9 I'd be glad to talk with you after the
10 meeting and make some of those studies available to
11 you; we can work that out through the Army. You'll
12 have a chance to look at some of these studies.
13 In addition, Shell has done some studies
u over time in terms of looking at workers at
IS pesticides plants, both in Europe and here in the
16 United States, and results of those studies are also
17 available. We'd be glad to make those results
18 available to you if you haven't seen them before.
19 MR. MIKE WALTENBURG: No, I haven't. But I
20 do have a comment to make about the pesticide and
21 the - the - what is it in Europe and whatever. I
22 understand •- we ought to have a base with mat.
23 But what happened to the study right here? I - the
24 reason I - I don't want to ~
25 MR. MICHAEL ANDERSON: There's information
Page 135
l with the amount of chemical agents that we produced,
2 stored, et cetera. And for — again, as part of
3 national security, that information was not made
4 available to the genera] public.
5 Regarding the chemicals handled, where they
6 were spilled, how much was disposed of, all that
7 information I think you may be referring to as the
8 way we handled wastes out here. All that was opened
9 and reresearched as part of our studies to find out
10 exactly where, in fact, we could have chemicals here
ll on-site.
12 So - but with regard to much of the
13 chemical agent production and storage information, I
14 just don't know off -- off the top of my head. We
15 could find that information out for you, if there is
16 still some information classified.
17 But I wanted to address your issue with
18 regard to ongoing, say, blowing of contamination,
19 things like that. And we do have an active
20 monitoring program now to try to measure exactly what
21 is going on now. And we will continue that in the
22 future to make sure that our actions don't adversely
23 affect the community.
24 Historically, if you go back years, you
25 know, it was a totally different climate or
Page 134
l available.
2 MR. MKE WALTENBURG: One of the questions
3 I do have is how much of the stuff that was on the
4 Arsenal that was - how do I want to say this? -
5 that was classified information — how much of this
6 has been unclassified now, up to this date?
7 The reason I ask is because I was stationed
8 here, and I used to mow the grass around the F lake.
9 I used to work over here in the GB - or in the GB
0 area - make sure I point my finger in the right
I direction - up here in the mustard area. I had
2 access to all of that
And that's why I was ~ I was wondering.
4 Because I know what was spilt. I know what was
5 shoveled off to the side and everything. And you
6 know - and almost all of that material was
7 carcinogenic.
8 MR. CHARLES SCHARMANN: Well ~
9 MR. MICHAEL ANDERSON: That needs to be
o brought up.
l MR. CHARLES SCHARMANN: I can address the
22 classification issue.
Much of what was classified on here -- and
4 I can't tell you exactly what information is
5 available and what's not. But much of that had to do
Page 136
l environment at that time. And maybe the records
2 aren't as good.
3 But Mike mentioned some of the studies, the
4 health studies or epidemiological studies, that were
5 done to try to determine -- make a determination on
6 whether there's been a high incidence of cancer or
7 what type of cancer, things like that, in this
8 community. And again, I believe their conclusions
9 were that they could not find that where there has
10 been high incidences of cancer above what they would
l expect background to be.
2 In the future it's something we can do
3 something about Unfortunately, we can't go
4 back 30 years and have the records. But in the
5 future we are not only monitoring the air, we will be
6 monitoring the workers, and that was the whole intent
7 of the medical monitoring program, is to use the
8 information contained on-site, as well as deal with
9 some off-site issues with the local community, to
20 make sure that we can make statements to you,
l hopefully, that you're not being affected by the
22 actions being taken at Rocky Mountain Arsenal in the
3 future.
14 So that's something we can do something
:5 about. In the past I -- unfortunately, you know,
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1 rccordkeeping, monitoring was not as good as it is
2 today so...
3 MR. ZEK SAIDMAN: Okay.
4 MS. BARBARA NABORS: 1 have a summary, a
5 citizen summary, of two of the studies that the
6 Colorado Department of Public Health was involved in.
1 And if you'd like to take this, you can have it. And
8 I believe there's a couple comments, people that you
9 could call at the health department if you have
10 questions, Mike Wilson.
11 MR. ZEK SAIDMAN: Barb, are there more
12 copies of that?
13 MS. BARBARA NABORS: That is the only one I
14 brought, but we could probably have copies made
5if...
6 MR. ZEK SAIDMAN: Do you want to - how
7 do you want to have that get out to people?
8 Norm, do you want a copy?
9 AUDIENCE SPEAKER: YCS.
20 MR. ZEK SAIDMAN: Can you get their --
il can you go up to-•
:2 MS. BARBARA NABORS: I can send one to
3 Norm. I'd be happy to do that.
4 MR. ZEK SAIDMAN: If you want to get
5 additional copies, you can keep that -- you can
Page 139
l And what we have here is over here on this
2 table you see seven volumes of dated alternative
3 analysis that you can use to judge from. And if you
4 go through that, you'll see that that references
5 about -1 don't know -- 50 or 60 other volumes.
6 Some of them meant multiple volumes. It's a lot of
7 paper to go through.
8 This just came out. What they did here is
9 they took 181 sites, and they consolidated them
10 into 25 median groups, and all of that got
11 consolidated into one large operable unit. And it's
12 incredible that ~ the reason, I guess, for that is
13 so people can't look at it too close. I don't know.
14 Anyway, for that reason I would like to
15 request that the public comment period be
16 extended 180 days so that those not well-versed in
17 this would have a reasonable chance of making
18 pertinent comments and having pertinent input into
9 this.
20 It has been explained to members of the
21 board that they really don't expect the public -
22 any son of public comment to affect the decision
23 one way or another, but it does go on the
24 administrative record, and it's only fair that people
25 get pertinent and real comments on the administrative
Page 138
I contact Barb and get those copies.
2 AUDIENCE SPEAKER: Fax it to me.
MR. ZEK SAIDMAN: Can you do that, fax it
4 to him?
5 All right. Thank you.
6 Anybody again who hasn't had a chance to
7 make a first comment? And again, trying to focus on
8 the proposed plan for the final cleanup, as much as
9 anything, in terms of discussion. That's what the
0 hearing's about. Anybody else who hasn't had a
1 chance to speak?
Okay. So Rich, did you - do you want to
3 make another comment?
4 THE COURT REPORTER: Excuse me.
5 (Discussion off the record.)
MR. ZEK SAIDMAN: The court reporter's
7 ready. Rich, do you ...
Okay. Again, let's try to focus on the
9 proposed plan.
MR. RICK WARNER: Okay. First I'd like to
l say that - and it hasn't even been mentioned here.
2 I suppose if this was one of the largest bomb
3 manufacturers in America, it would be mentioned, but
4 this is the largest military Superfund site in
5 America. It is - it - there's none bigger.
Page 140
l record.
2 Next point I'd like to make is that this
3 couple to the south - last time I talked to you
4 about Commerce City and Henderson; this time I'd hie
5 to talk about Montbcllo and Green Valley Ranch and
6 Aurora and - and Park Hill.
These are not part of the off-post study
8 areas. They are not a consideration of anything that
9 happens out here. If you lived out here ~ as you
o have, probably, for years and years - you know that
l the tumbleweeds don't pile up on your north fence;
2 they pile up on your south fence. The wind blows
3 that way.
If you take a tour here, if you just drive
5 around, you'll see many, many smokestacks out here.
6 That smoke and the debris that came out of these
7 stacks and the contaminants and pollution went to the
8 south, went to the southwest If you were watching
9 the SQI while it was burning on almost any given day,
0 you could see that plume glow all the way around, all
1 the way around.
It's true of living in the Front Range. We
3 kind of live in a vortex here, a -- of circulating
4 winds. Not enough has been looked at in the off-post
5 area. It's for that reason ~ the off-post came to
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) comment two or three years ago. We still don't have
2 a record of decision out. I've requested copies of
3 it I still have not seen the record of decision.
4 But it should have addressed things like
5 this. There were a lot of comments that were not
6 supportive of it I think that there should not be
7 an on-post decision until the off-post decision has
8" been decided. The reason for that is because, in the
9 off-post, people live. People's issues need to be
10 addressed first, rather than the blank prairie.
ll But that's that
12 MR. ZEK SAIDMAN: Any additional comments
13 you want to make? Just...
14 MR. RICK WARNER: I do have one other -
15 MR. ZEK SAIDMAN: Okay.
6 MR. RICK WARNER: - at this particular
7 three-minute stance.
8 • The trust fund was mentioned. The reason
9 the trust fund was mentioned is because this cleanup
20 does not end in nine or ten years. This is a
21 thousand-year treatment. These chemicals are going
22 to be toxic and in that ground for a thousand years.
:3 If you happen to know of a landfill anywhere in the
!4 history of mankind that has been good for a
5 thousand years - 500 years, a hundred years -
Page 143
1 parties for review. We also made it available to
2 some individuals on the Restoration Advisory Board.
3 If we have not gotten that to the Site Specific
4 Advisory Board, anyone who would like a copy - we
5 can get you a copy of, Rick, in a minute.
6 MR. RICK WARNER: Great.
7 MR. CHARLES SCHARMANN: OUT hope is that
8 that will be finalized and signed in the next month
9 or so. And we were scheduled to have a signing on
iO November 29th for that document, but due to the
11 furloughs and whatnot, that will be delayed.
12 MR. RICK WARNER: There is no additional
13 public comment on that document; is that right?
14 MR. CHARLES SCHARMANN: That's right. We
15 went through a public review process on that, and we
16 received a fair amount of public comment, and 1 think
17 some of those comments we received were ~ were
18 incorporated, obviously, or else we explained why
19 they could not be incorporated.
20 But we've gone through the public process
21 on that particular record of decision.
22 MR. RICK WARNER: That was about
23 three years -- two years ago?
24 MR. CHARLES SCHARMANN: The proposed final
25 came out in December of -- of 1993, actually. I'm
Page 142
i please let me know. I'd be -- I'd love to have that
2 information. I don't think that one exists.
The history is not something we deal with
4 here. We deal with fantasy science, which we call
5 risk analysis and modeling. In that particular
6 instance along the south, one of our own members
7 looked at their modeling data, went outside, got
8 other information, and believes he has
9 incontrovertible evidence ~ that's probably not a
0 real good word in science anyway -- that the waters
1 did flow to the south. He is in the process of
2 preparing that report now. And hopefully, it will be
3 available to the parties as soon as he is done.
But definite groundwaters and ~ and
5 contamination, vertical contamination, of the
6 aquifers in the south, too.
7 So that's it for now. Thanks.
8 MR. ZEK SAIDMAN: Thank you.
9 Comments from the panel?
0 MR. CHARLES SCHARMANN: Just - I would
l like to address the issue as far as the off-post RAB.
Rick's right. That originally came out in
3 1994 as a draft final or proposed final. It has
4 taken us this time to work out the issues and prepare
5 a final. We have prepared one that went to the
Page 144
1 sorry. Is that right, Tim?
2 MR. TIM KILAGANNON: Yeah.
3 MR. CHARLES SCHARMANN: 1993. SO the
4 public process on that - you're stretching my memory
5 here, but I think it was in the spring of '93 that we
6 had our public meeting on that.
7 MR. TIM KILAGANNON: April Of'93.
8 MR. CHARLES SCHARMANN: April of '93 is
9 when we had our public meeting. And we have had, I
0 believe, either a 60- or 90-day public review period
l for that document
2 MR. RICK WARNER: So about 2 1/2 years.
3 MR. CHARLES SCHARMANN: Yes.
4 MR. RICK WARNER: Okay.
5 MR. CHARLES SCHARMANN: I stated correctly
6 before.
7 With regard to the study area - and a lot
8 of the rationale for why it was set up the way it was
9 is presented in that off-post documentation. But
0 again, I was not saying that the wind does not blow
l to the south. And I apologize if I inferred that.
2 But the data that we have on-site of where
3 soil has blown, where it -- chemicals may be found in
:4 surface soils, is mostly to the north and to the
5 east, the higher levels. There was some detected to
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Page 14
1 the south. But again, it's a lower level, and it was
2 below health standards on-site so no further study
3 was done off-site.
4 Again, that supports the ~ why we set the
5 study area up the way we did.
6 MR. RICK WARNER: In the 30 or 40 years
7 that this was here, were those soils to the south
8 ever tilled, moved around, replanted, revegetated?
9 Was there any sort of activity that changed - could
10 have changed the depth of those contaminations, could
11 have moved them to other site places on the Rocky
12 Mountain Arsenal? I understand from people who
13 worked here that that did happen quite often down
14 there on flooding.
15 MR. CHARLIE SCHARMANN: Those activities
16 occurred across the Arsenal, not just to the south.
17 You know, I don't have - our facilities folks may
18 have a better feel for exactly where those activities
19 occurred. But again, we did not target any one pan
20 of the Arsenal that I'm aware of. And certainly, the
21 areas to the south I don't believe that - were
22 targeted any more for those kinds of activities.
23 MR. RICK WARNER: Nor, also, the areas east
24 of First Creek where all the new hotels and houses
25 are being built or where those oil wells have been
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CERTIFICATE
I, MZUME u Huunur-WATum. *
Refinered Diplomat Reporter tod Certified Realtime
Reporter, do hereby certify tint I reported by
machine ihortfaind the pnceedinp contained herein
•nd that the fcnfoinf 14« pifei eomtiiute a full,
sue nd correct nmcriot
Dtted nil 10* day of December, 1995.
MELANIE LHUMnOlEY-W ATKINS
Page 146
dug - or new developments have been planned to be
built. Nothing that be done there, either, right?
MR. CHARLES SCHARMANN: Not that I'm aware
of, Rich.
MR. ZEK SAIDMAN: okay. Other comments
from the panel?
Okay. Any other comments from people in
terms of the proposed plan?
Any - I'll ask it again. Any other
comments from people for the proposed plan?
Those who want to take a bus tour ~
another bus tour, out by the exit sign. And we thank
you for your public comments.
This meeting is adjourned.
(Meeting proceedings concluded
12:17 p.m., November 18,1995.)
* * * * *
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RESPONSES TO COMMENTS MADE AT THE PUBLIC MEETING
ON THE ROCKY MOUNTAIN ARSENAL
ON-POST PROPOSED PLAN
NOVEMBER 18,1995
The transcript from the public meeting on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan is included in the Responsiveness Summary in its entirety. Individual comments from the
transcript of the public meeting are summarized in brief below, with responses immediately
following each comment. The appropriate page and line number of the transcript are indicated for
reference, as is the commentor's name. Comments that were answered during the public meeting,
where the transcript reflects a response, are not repeated here.
Comment 1 (page 80, line 2), Mayor David Busby: Suggests that, because Basin A has no liner
under it, a slurry wall to bedrock be installed all the way around Basin A for containment.
Response: Computer modeling of the groundwater flow in the Basin A area revealed that
installation of a slurry wall would not significantly enhance the control that can be achieved by
covering the soil and other material placed in the Basin A Consolidation Area and by extracting
and treating groundwater at the Basin A Neck system. Slurry walls have been selected for the
Shell Trenches and Complex Trenches as part of the remedy, and treatment is planned for the Hex
Pit. A new groundwater extraction system for the Section 36 Bedrock Ridge Plume will be
installed to prevent migration of contaminants into the First Creek alluvial aquifer.
Comment 2 (page 80, line 13), Mayor David Busby: States that the 4,000 acre-feet agreed
upon in the Agreement for a Conceptual Remedy for the Cleanup of the Rocky Mountain Arsenal
(Conceptual Remedy) is not sufficient for South Adams County Water and Sanitation District
(SACWSD).
Response: The Army and Shell have reached an Agreement in Principle with SACWSD that
includes payment of $48.8 million by the Army and Shell to SACWSD and requires SACWSD to
supply water to consenting drinking water well owners within the diisopropyl methylphosphonate
(DIMP, an RMA byproduct) plume by January 1999. In addition, the Agreement in Principle
requires SACWSD to provide the 4,000 acre-feet of water to Commerce City and the Henderson
area by 2004. The parties involved in the water negotiations believe that the settlement is fair and
will permit SACWSD to secure an adequate water supply to satisfy Commerce City's and
Henderson's water needs. If you have any further questions regarding the water supply, please
contact Mr. Tim Kilgannon at RMA at 303- 289-0259.
Comment 3 (page 80, line 20), Mayor David Busby: Commerce City supports the new
state-of-the-art, triple-lined landfill.
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Response: Comment noted.
Comment 4 (page 82, line 17), Mr. Roland Russell: On behalf of Mr. Russell and State
Representative Jeannie Reeser, states that many things were left out of the Conceptual Remedy.
Requests that comments or minutes from citizen meetings with the Parties be included in the
remedy selection.
Response: The Army believes the public has provided significant input to the Conceptual Remedy
and the remediation process at RMA. Prior to the Conceptual Remedy, the Parties were at a
standstill and heading into litigation over the major differences seen as a basis for RMA
remediation. The Conceptual Remedy, with the help of the Colorado Lieutenant Governor and a
seasoned mediator, helped the Parties base an agreement on compromise without affecting the
protectiveness of the selected remedy. The Conceptual Remedy does not contain specifics about
the remediation process that will soon begin. The Parties are working hard to resolve the many
questions that remain, and the public has an important role in that process. In addition, the Army
has included more public participation in the selection process (more than 20 workshops and
public meetings) than what is required under the Comprehensive Environmental Response,
Conservation and Liability Act (CERCLA) by encouraging everyone to participate in the review
and selection process over the past years. Again, the Army emphasizes that the Conceptual
Remedy was not the product of one party dictating its agenda to the other parties. The
Conceptual Remedy was a compromise for all parties involved in order to provide a safe,
cost-effective, and implementable remedy. Many comments were reviewed and considered during
the process. While no one will agree on every aspect of the Conceptual Remedy, the Army
believes that the selected remedy will be fully protective of human health and the environment.
Comment 5 (page 86, line 12), Mr. Jim Erger: The solution to correct the problems caused by
the Army and Shell is to have a totally new supply of water, along with pipelines and distribution
lines, paid for by the Army and Shell.
Response: With regard to compensating homeowners and providing a new water supply, please
see the response to Comment 2, above.
Comment 6 (page 86, line 19), Mr. Jim Erger: In areas of the Arsenal with minor pollution,
capping and containment will suffice. The smallest amount of soil you have to move, the better,
and the smallest amount of burning and thermal treatment, the better.
Response: Comment noted.
Comment 7 (page 87, line 19), Mr. Jim Erger: What part of the 4,000 acre-feet of water
belongs to Henderson? Where are the pipelines going to go? What size? We want 12-inch
pipelines. We want a surface supply of water, not underground water.
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Response: With regard to water for the Henderson area, please see the response to Comment 2,
above. SACWSD will be responsible for placing and designing the pipelines.
Comment 8 (page 91, line 9), Mr. Rick Warner: The federal government must not only comply
with law but should strive to be a leader in the area of environmental cleanup.
Response: The Army is committed to seeing that RMA is a leader in environmental remediation.
Lessons learned at RMA will be shared throughout the United States; this leadership image
reflects not just on the success of the remediation Hut especially on the public involvement
process.
Comment 9 (page 92, line 25), Mr. Rick Warner: There are no details regarding the water
supply.
Response: Please see the response to Comment 2, above, regarding the water supply. Further
information will be provided as it becomes available.
Comment 10 (page 95, line 14), Mr. Waldo Smith: The public wants a Trust Fund as provided
in the Conceptual Remedy.
Response: During the formulation and selection of the remedy, members of the public and some
local governmental organizations expressed keen interest in the creation of a Trust Fund, as you
do in your comment, to help ensure the long-term operation and maintenance of the remedy. The
Parties have committed to good-faith best efforts to establish such a Trust Fund, as described in
the On-Post Record of Decision (ROD). Principal and interest from the Trust Fund would be
used to cover the costs of long-term operations and maintenance throughout the lifetime of the
remedial program. These costs are estimated to be approximately $5 million per year (in 1995
dollars).
It is the intent of the Parties that if the Trust Fund is created it will include a statement containing
the reasons for the creation of the Trust Fund, a time frame for establishing and funding the Trust
Fund, and an appropriate means to manage and disburse money from the Trust Fund. The Parties
are also examining possible options that may be adapted from trust funds involving federal funds
that exist at other remedial sites. The Parties recognize that establishing a Trust Fund may require
special congressional legislation and that there are restrictions on the actions federal agencies can
take with respect to such legislation. Because of the uncertainty of possible legislative
requirements and other options, the precise terms of the Trust Fund cannot now be stated.
A Trust Fund group will be formed to develop a strategy to establish the Trust Fund. The
strategy group may include representative of the Parties (subject to restrictions on federal agency
participation), local governments, affected communities and other interested stakeholders and will
be convened with in 90 days of the signing of the ROD. According to the U.S. Government
Manual, "The General Accounting Office [GAO] is charged with examining all matters relating to
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the receipt and disbursement of public funds." The existence of a trust fund containing
government funds and the use of such a fund is subject to GAO audit. Fiscal control of such a
such is not considered within GAO's delegated authority.
Comment 11 (page 97, line 16), Mr. Srinadh lyengar: Hopes that stories of wildlife extinction
and children being hurt or killed will not happen at RMA.
Response: The Army is firmly committed to ensuring the safety of people and wildlife during
remediation activities at RMA.
Comment 12 (page 99, line 19), Ms. Sandra Jaquith. Questions whether five alternatives were
really considered in the Feasibility Study (FS) as presented in the Proposed Plan. Also questions
the public involvement in selecting the remedy.
Response: The purpose of the FS was to generate a number of possible remediation alternatives
from the universe of alternatives and then narrow those down to select the one that could best
address the site based on the proscribed FS selection criteria. In the Detailed Analysis of
Alternatives (DAA), a component of the FS, five primary alternatives were developed, compared
to each other, and compared to the selection criteria prescribed by CERCLA. The selected
alternative was the one agreed upon in the Conceptual Remedy and described in the On-Post
Proposed Plan. Please see also the response to Comment 4, above.
Comment 13 (page 100, line 20), Ms. Sandra Jaquith: Questions the use of the word
"cleanup." Expresses concern about long-term monitoring and maintenance of the caps.
Response: Please see the response by Ms. Laura Williams, EPA, on page 105, line 9, of the public
meeting transcript, regarding public input and the use of the term "cleanup." Regarding long-term
monitoring, a 30-year monitoring program for the caps is mentioned in the Proposed Plan and the
Record of Decision (ROD) because it follows U.S. Environmental Protection Agency (EPA)
cost-estimating guidelines. However, the Army and Shell are committed to maintaining the
integrity of the remedy in perpetuity and will conduct monitoring to ensure the protectiveness of
the caps and landfills as long as necessary.
Comment 14 (page 102, line 3), Ms. Sandra Jaquith: Requests that all citizens' comments
throughout the period of Steering and Policy Committee negotiations, leading up to the
Conceptual Remedy, be included as part of the official record.
Response: The Responsiveness Summary of the ROD follows EPA guidance and includes only
the written comments and oral comments from the public meeting. All comments were reviewed
and considered in the selection of the remedy. In addition, written minutes from meetings during
the settlement process are part of the On-Post Administrative Record and can be found at the
Joint Administrative Record Document Facility.
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Comment 15 (page 102, line 25), Ms. Sandra Jaquith: Questions the amount of water to be
provided to SACWSD, how many homes will be connected to SACWSD, how large the pipelines
will be, and whether there will be water available for community expansion to the north and
northwest of RMA after remediation.
Response: Please see the response to Comment 2, above.
Comment 16 (page 107, line 5), Mr. Larry Ford: States that the Klein treatment plant does not
deal with some of the contamination expected to reach the plant in the future. States need for
water supply to be replaced. Asks what about Henderson?
Response: Please see the response to Comment 2, above.
Comment 17 (page 110, line 5), Mr. Dan Mulqueen: Requests an answer to whether dioxin is
present and what will be done if it is found.
Response: Dioxin and furan sampling was undertaken by the Colorado Department of Public
Health and Environment, and these results are currently being evaluated by the Biological
Advisory Subcommittee. Please see also the response in the public meeting transcript by
Mr. Ray Rauch, U.S. Fish and Wildlife Service (USFWS), beginning on page 116, line 17.
Comment 18 (page 110, line 22), Mr. Dan Mulqueen: Questions the selection of landfilling soil
without treatment.
Response: Many alternatives to land disposal were considered in the DAA, including innovative
and conventional treatment technologies. However, because of the large volume of contaminated
soil and the wide variety of contaminants, a combination of containment and limited treatment
was selected as a remedy because it ensured protection of human health and the environment, as
well as being implementable and cost-effective. EPA's goal in establishing the Corrective Action
Management Unit (CAMU) Rule, which was adopted by the State of Colorado in the Colorado
Hazardous Waste Management Act (CHWMA), was to "provide remedial decision makers with
an added measure of flexibility in order to expedite and improve remedial decisions" while
"existing closure regulations and requirements for [Resource Conservation and Recovery Act]
RCRA-regulated units, which require closure to occur in a manner that is protective of human
health and the environment, remain in effect." Purpose and Context of the CAMU Rule, 58 Fed.
Reg. 8659 (1993) (to be codified at 40 C.F.R Parts 260, 264, 265, 268, 270 and 271). The onsite
landfill that is central to the CAMU will meet applicable CHWMA requirements. Also, when the
ROD is signed and final, the CAMU will be in place and its application to the RMA remediation
would only be revised subject to court ruling or if it were found not to be protective of human
health and the environment.
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Comment 19 (page 112, line 6), Mr. Dan Mulqueen. Questions what will happen if the plan for
keeping the lakes full is not successful.
Response: Monitoring is ongoing to address the potential need for additional action in the lakes
area. If necessary, the remedial design will address the required actions.
Comment 20 (page 113, line 13), Mr. Dan Mulqueen: States that the issue of water is critical.
Response: Please see the response to Comment 2, above.
Comment 21 (page 121, line 4), Mr. Ron Pace: States concern about water and soil. Questions
"What is the smell?" and "What is the water?"
Response: Some odors were generated during previous RMA operations and during the Basin F
Interim Response Action, but the Army is not aware of any odors being generated onsite at this
time. Air monitoring at RMA does not indicate the presence of contaminants that could migrate
off-post. The off-post groundwater has been and will continue to be monitored, and those results
are available to the public. Please see also the response to Comment 2, above.
Comment 22 (page 129, line 23), Mr. Mike Waltenburg: Questions whether there is a medical
program or organization looking at cancer in people living near RMA.
Response: Studies on human health have been completed by the Agency for Toxic Substances
and Disease Registry (ATSDR) independently and in conjunction with CDPHE. The studies
showed no conclusive health impact on the communities surrounding RMA. Also, the final Public
Health Assessment, produced by ATSDR, will be complete in the summer of 1996. A Medical
Monitoring Program has been established to monitor any off-post impact on human health due to
the RMA remediation. This Program will continue until the soil remediation is completed. A
Medical Monitoring Advisory Group has been established to evaluate specific issues covered by
the Medical Monitoring Program. The Group is composed of representatives of the Army, Shell
Oil Company, EPA, Colorado Department of Public Health and Environment (CDPHE),
Tri-County Health Department, ATSDR, USFWS, Denver Health and Hospitals, and the
Site-Specific Advisory Board. The Group also includes representatives from the communities of
Montbello, Commerce City, Henderson, and Denver. If you would like more information on the
Medical Monitoring Program or wish to participate as part of the Medical Monitoring Advisory
Group, please call Ms. Mary Seawell of CDPHE at 303-692-3327. Please see also the responses
in the public meeting transcript by Mr. Michael Anderson, Shell, beginning on page 133, line 3,
and Ms. Barbara Nabors, CDPHE, beginning on page 137, line 4, regarding medical monitoring.
Comment 23 (page 139, line 14), Mr. Rick Warner: Requests that the public comment period
be extended 180 days.
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Response: The comment period for the On-Post Proposed Plan was extended by 30 days to
balance the concerns of those who wanted more time to comment and those who wanted no more
delays to the ROD.
Comment 24 (page 139, line 20), Mr. Rick Warner: States that public comment will not affect
the decision one way or another.
Response: The Army is interested in public comments and concerns and has made substantial
effort to hear those concerns through the Restoration Advisory Board, the Site-Specific Advisory
Board, stakeholder meetings, and avenues of public comment such as the comments on the
On-Post Proposed Plan. The Army has included more public participation than what is required
by under the CERCLA, such as conducting more than 20 open houses and public meetings to
enable those interested to voice their concerns. The Army believes the public has provided
valuable input to the remediation process at RMA and all comments were reviewed and
considered in the selection of the remedy.
Comment 25 (page 141, line 1), Mr. Rick Warner. States that there is no final Off-Post ROD.
Response: The Off-Post ROD was signed and became final on December 19, 1995.
Comment 26 (page 141, line 18), Mr. Rick Warner: Reiterates the earlier comment regarding a
Trust Fund.
Response: Please see the response to Comment 10, above.
Comment 27 (page 142, line 10), Mr. Rick Warner: Believes that groundwater does flow to
the south from RMA.
Response: For a more detailed response regarding groundwater flow patterns at RMA, please see
the Army letter responding to Mr. John Yelenick's written comments. In summary, no such
groundwater plume has been identified by the extensive groundwater monitoring programs the
Army conducts annually. Groundwater flows generally downgradient from the southeast corner of
RMA toward the South Platte River. Superimposed on the regional gradient is a groundwater
mound in the RMA South Plants. The mound is created by leaking pipes, increased recharge from
unlined ditches and ponded areas, and may also be the result of natural variations in the
permeability of the alluvium and the bedrock in the area. Groundwater in the area of the mound
flows radially out from the mound in all directions. A groundwater divide occurs at the confluence
of the regional flow system and the mound. As a result, groundwater entering RMA from the
southeast is forced to turn either east or west around the South Plants area. Water flowing south
from the mound area is forced to change direction and join the regional flow system. The
groundwater flow direction in the confined Denver Formation is also from southeast to northwest.
It is physically impossible for groundwater or contamination from RMA to flow southward from
the RMA boundary.
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12-8
Responses to Citizen Comments
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Rocky Mountain Arsenal
Reply Card
Please add my name tojhe Army's mailing list of upcoming public meetings:
Name
Address
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Phone 3*>3/?.gy~*//3;a
Please ist any questions and/or comments you have.
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROOKY MOI 'STAIN ARSENAL
COMMERCE CITY. COLOR AlV *Y:M 7-4^
June 11, 1996
REPLY TO
ATTENTION OH:
Office of the Program Manager
Mr. Bob and Ms. Kathy Bailey
8681 E. 104th Avenue
Henderson, Colorado 80640
Dear Mr. and Ms. Bailey:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
In response to your comment about a water supply for Henderson, the Army and Shell Oil
Company (Shell) have reached an Agreement in Principle, enclosed with this letter, with South
Adams County Water and Sanitation District (SACWSD) that includes payment of $48.8 million
by the Army and Shell and requires that SACWSD water be supplied to consenting drinking water
well owners within the diisopropyl methylphosphonate (DIMP, an RMA byproduct) plume by
January 1999. In addition, the Agreement in Principle requires SACWSD to provide 4,000 acre-
feet of water to Commerce City and the Henderson area by 2004. The parties involved in the
water negotiations believe that the settlement is fair and will permit SACWSD to secure an
adequate water supply to satisfy Commerce City's and Henderson's water needs. If you have any
further questions regarding the water supply, please contact Mr. Tim Kilgannon of this office at
303-289-0259 or Mr. Larry Ford of SACWSD at 303-288-2646.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
9
:ugene H. Bishop
Colonel, U.S. Army
Program Manager
Enclosure
Readiness is our Profession
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-2-
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE PENALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SDC MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
" THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
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AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. -"
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
. REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WELL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION I, ABOVE.
version 10-26/01/96
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01/26/96 FRI 13:57 FAI 703 6962940
US ARMY ENVIR LAW DIV
RMA COUNSEL
20'
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j|j JAN 19 109S
The panel's (The EPA, CDPHE, U.S. Army, Shell Oil Co., and USF&WS) proposedRecord of. '"
Decision (ROD) is not an effective solution. The proposed ROD (The great cover up) does not
.provide elimination of contaminates in Basins A and F. Covering Basins A and F make them a
landfill! Is land filling hazardous material without a liner legal? Do federal regulations
(CERCLA?) prohibit this type of action? The soils in Basins A and F must be treated and
appropriately land filled. Full LDRs must be followed throughout RMA. Basins A and F must be
decontaminated as much as possible! Not taking any treatment action for Basins A and F is
unacceptable.
According to the DAA (4-15) regarding option IV,"... high short-term risks are posed
to workers and the community during excavation, transportation, and treatment or land filling."
Treatment of the soils in Basins A and F cannot be ruled out, since there are high short-term risks
for any soil excavation! On Nov. 18,1995 Mr. Anderson of Shell Oil Company mentioned water
was going to be used to control release of vapors during excavations. Why isn't a foam agent
designed to capture vapors during excavation being used? The foam is safer than water. Option
V is reasonable because the long-term results are the most effective at maintaining cleaner
groundwater. Option V should be modified; so soils can be treated by thermal desorption and not
be incinerated.
The water treatment system at the boundaries is not doing a satisfactory job. Toluene is
still crossing the RMA boundary. This is unacceptable. What other chemical agents are crossing
the RMA boundary in treated water? Another activated carbon filter or better form of water
treatment should be installed. Clean water is essential for a healthy life style.
Clean water is priceless! The extra cost for the added treatment of soil and water is worth
h. Remember Basin A is considered the most contaminated square rnfle in the U.S. A We must
9602401-1/1
-------
pay the price for 53 years of neglect to insure safe drinking water for wildlife, and communities
surrounding RMA.
JAN 19 1395
-------
DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOl 'NTAIN ARSENAL
COMMERCE CITY. COLORAPO VO"-! 74S
June 11,1996
Office of the Program Manager
REPLY TO
ATTENTION Of.
Mr. Roger and Ms. Debra Bain
8300 E. 104th Way
Henderson, Colorado 80640
Dear Mr. and Ms. Bain:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
Hazardous materials from the Basin F wastepile will be properly disposed in the on-post
hazardous waste landfill. Highly contaminated materials from the Former Basin F will be treated
by in situ solidification. A Resource Conservation and Recovery Act-equivalent cap will then be
placed over this site. Capping is a form of waste containment, and is a remedy different from
landfilling. A cap is designed to limit rainfall infiltration and to minimize contaminant migration
from the site. Capping is not a viable solution for containment in all remediation situations, but,
for the remaining wastes in Former Basin F, capping will safely and cost-effectively contain the
waste materials. The remediation technology planned for Basin A is a cover that provides
containment of waste and minimizes rainfall infiltration. In Basin A a soil cover consisting of 6
inches of concrete and 4 feet of soil will protect people and the environment. The cap/cover
technology minimizes the short-term risks of exposure to workers and the community because
soil-borne contaminants are left in place and not excavated and exposed to the environment. The
landfill and the cap/cover designs for Basins A and F comply with federal, state, and local
regulations (including the Comprehensive Environmental Response, Compensation, and Liability
Act). Concerns about the short-term impacts of excavation and treatment were evaluated against
the potential long-term effects of containing the waste in place, and the Army believes that a
protective remedy was selected.
Water spraying is a common method used to control the spread of dust during excavation
operations. In addition, odor and vapor suppression methods such as foams or enclosures are
planned for use at those sites where odors and/or vapors may be released. Furthermore, air
monitoring will be conducted during remediation activities, and, if necessary, the excavation plan
will be modified to ensure worker and community safety.
Clean water for the public is one of the Army's primary goals that will be met by continued
operation of groundwater treatment/containment systems and by providing a supplemental water
supply to meet community needs. The Army believes that the continued treatment of
groundwater at RMA is an important part of the remediation. The RMA groundwater treatment
Readiness is our Profession
-------
-2-
systems currently treat about one billion gallons of water per year to meet all state and federal
standards. Toluene has not been found in RMA groundwater at levels of concern and is not
detected in the treated water from the North, Northwest, or Irondale boundary containment
systems.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
(-Eugene/H. Bishop
Colonel, U.S. Army
Program Manager
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
-------
Commerce City Business & Professional Association, Inc.
P.O. Box 303 • Commerce City, CO 80037-0303
"Bringing Business Together"
Officers
President
Vice President
Secretary
Treasurer
Lois Lilsey 289-4586
Dave Chambers 288-3154
Cathy Russell 288-2646
Sue Kygar 288-3936
Board of Directors
Dr. Jerome Cheney
Wes Wilson
January 12, 1996
286-8600
288-4857
*29-212l
288-6600
Charles Scharmann
Office of the Program Manager
Attn: AMXRM-RP/C. Scharmann
Rocky Mountain Arsenal
Commerce City, Colorado 80022
Dear Mr. Scharmann:
The Commerce City Business and Professional Association supports
the Henderson Coalition in its efforts to force the U.S. Army and
Shell Oil Company to replace their contaminated ground water
supply. The blight of contamination has affected our community and
that of our neighbor, Henderson. It is inconceivable that this
community must fight so hard to right the wrongs committed by the
Army and Shell.
Through attending various meetings it would seem that the Army and
Shell would gladly replace the water supply in the amounts
requested for Henderson and Commerce City, since no other financial
concessions for the real damages done to our businesses, schools,
and residents have been or will be made. That does not take into
account the very negative public image we suffer from and the very
real damages done. That does not take into account the numbers of
people who have been supplied bottled drinking water by the
Colorado Department of Public Health and Environment for the last
several years.
It would seem that, as a very small part of the overall cleanup
agreement, replacement of the contaminated supply would include a
safe, permanent, good quality water supply for Henderson and
Commerce City and would not be questioned. Instead, we have banded
together to fight for what has been taken from us and from the
generations to come.
We will continue to work to improve the image of our community, the
image so badly damaged by our "neighbors" at the Rocky Mountain
Arsenal. We will continue to plan for future growth, though our
resources have been destroyed.
9601608-1/1
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For successful consideration of the Record of Decision by our
communities and our leaders, our future growth supply which was
determined to be enough for 100,000 people for 100 years must be
provided. Without a supply for the future, our growth will
continue to be stifled and our businesses and residents will
continue to suffer.
We implore you to restore our poisoned future water supply. We
demand nothing more and will accept nothing less than replacement
in the quantities and under the terms determined by our community
leaders. It would seem that this is the very least, yet most
important, course of action that our "neighbors* at the Rocky
Mountain Arsenal can take.
Sincerely,
Litsey,'President
F.D. Chambers, Vice President
Cathy Ruraej/, Secretary
,,. ^ S. ^
M. SueKygar, Treasurer
LL
Wes Wilson, Director
Cheney, Di
L. Harlow Leeperr Director
JoeyReilly, Direct/or
/clr
-------
Commerce City Business & Professional Association, Inc.
P.O. Box 303 * Commerce City, CO. 80037-0303
Btsfaess Together*
.21*4566
288-5624
,2*8-6103
.287-5885
...287-3347
.-287-0223
-427-9484
...289-7078
.2884857
.2884821
SO* Avenue Liquors...
8Wi Drive-to Theatre..
ABATShoppe.be..
A *R Industrial Service Company..
A-l Auto Ekctric Co., be—
A-J Safes ft Service Co™
Absolute Value SalesftMarketmg...
Accen Housing. Inc...
Ace Jcwury, be..—..—
Acme Tree Service, Inc...
Adams City Liquor Store — .2174620
Atois County Library System 287-2515
Arfams County School District 14 ._. 219-3941
Adam* County School District 14 - 719-3940
ALCO Discount Store *73 .2*7-3309
AWed Intulttioo Co. Of Colo, toe .289-3326
Abate Rent-A-Fence, foe _. .287-7200
Aspen Mortuary - 2874495
BAB Auction. .289-7253
Bee Bee Que.,Inc .217-2856
BFI of Colorado. Inc „ .2174043
Bag '£' Concrete „ _. 2884428
Bag Ed'* Tavern .288-9965
Bknchard, Thomas J., MD 2*8-2615
Chaflenge Sport A Spine Center. 217-0393
Chamber* ft Son's Towing.. .288-3154
Charlotte'* Web Restaurant 287-7544
Ciy of Commerce City Parks Div „ 289-3713
City of Commerce City. 289-3612
Oenrview Motel ft Apis 2864386
Catographic, Inc 288-4796
Color Decorating „ „. 289-2880
Colorado Asphalt Services, Inc —..292-3434
Colorado Auto Auction, Inc 2874077
Colorado National Bank Northeast. 3994655
Colorado Brake ft Supply. Inc J99-2934
Colorado Charter Lines, Inc „ 287X039
..289-6213
Colorado Denver Express ...-....«.«
Colorado Down ft Feather, Inc.
Commerce City Denial Center
Commerce City Express....-.-...-.-....*-.— •
Commerce City FtenJ, be.
Commerce City: Mission Possible!
Cflramerce City Post Office....... .——«.—
Commerce City Tire ft Auto
("ftfTtfnnnity Ht*W> SWVJCeS , ,„,...
Covdova's Tire Repair be ,.
Cummins Rocky Mountain, be
Ovary Queen f33
DeTs Liquors.
Denver Pet Cemetery, Inc.—....— ».—« — .
Denver Windustrial Co —
Derby Lanes
Derby Tire Service, be — ........ .—
Digital Solutions Group, be ...-
Dvect Flooring Broken _
Dolar Genera) Store.
Donoer Diesel, be ._.
_ 289-5577
_ 2*7-2*31
2884877
288-T987
2884*59
2894497
288-2100
289-5662
—289-1086
.-288-3238
287-0201
289-1650
.....659-7439
28M177
287-2884
2884100
2»»-77?<
287-1808
—...7404776
287-2233
289-3192
287-3481
Dr. Jerome F. Cheney, DO.
Drive Line Service of Denver, he..
DSP Builders, be.—.—..-.—.—.
Dychem International, be
Earl F. Doughs* Roofing Co
Electric Power Equipment Co .—
Elite Auto ftiMf
Empire Taips..
Edunof Management Company..
First Federal Saving! Bank....
Foothills MiD ft Supply, Inc
Fraternal Order of Eagles *346l....
Frontier Truck Eqpt ft Pan* Co......
C & B Truck Leasing, he
Cahagen Iron ft Metal Co..
Gala Gardens.
GehlerftMerrigan..
General Air Service ft Supply.
Grif-Fab Corp... ..„ -
Ground Engineering Consultants, Inc..
H ft H Tire Sales ft Service
Hft H Transformer, tic
H ,O Power Equipment, Inc _.
Hast Lumber Company............... ».
Hi Lo Market - .....
Holiday Inn DM
Honnen Equipment Company
Intermountain Lift Trucks, Inc
Interstate Trailer Sales ft Service
Ivy K Barber Stylists...
J ft J Mailing Service, Inc
JR's Hair Company, he
Jxyhawk Trailers »..—.
Jean's Realty, be —
Jcrgensen Insurance Agency.
Joyce's Submarine Sandwiches
K ft K Surplus, he
Katie's Restaurant...
Ken's Commerce City Drug, Inc.....
Key Bank Commerce City North...
Key Bank Commerce City South....
Lft B Produce Trucking.
La Cats Dd Key.
Larry'* Lounge,
Latorin's, he—
taper ft Co..
Manpower Temporary Services....
Manpower Temporary Services....
Marvin A. Pngh,CPA..
Max Air Trailer Sato..
McCoy Sales Corp. DBA Parker Store.—
McDonalds Restaurant »5562
Mid America Wrecker Sales, be
Mile Hi Auto Repair, be.
Mfc Hi Travel Inc—
Mile High Greyhound Park.
Mik High Roofing ft Exterior Supply, Inc..
Mountain Slates Industrial Svc, be
Mountain States Crane Service, be.
.2*64600
—2*7-5538
....._289-0666
288-1972
2*8-2635
.....28847SI
-..287-5000
......288-4704
216-9408
219-2931
287-2069
2884861
2894311
287-4302
288-6867
..218-3383
287-2563
892-7003
287-2552
.289-1989
289-2856
-2*9-2*02
287-7561
288-1515
288-1747
.371-9494
287-7506
289-2201
.......2874375
2*7-5313
296-4842
287-7118
286-7923
289-4801
28(4000
289-1101
.287-7195
289-3253
288-3784
.....287-7411
.-.289-1178
.....295-7084
.....287-7480
....288-9292
.....2884888
—289-5555
......457-3400
7S8-2700
45I-S87S
.289-3264
7624012
.....288-9418
289-2836
—2(8-9000
.....2(84100
288-1591
......2*9-4586
.....289-4511
.....2(94511
Mr. Bill's Auto Service.
Nativity Lutheran Church ELCA.
Norm** Plinlina/C C Braftin .«-
Northeast Assistance Center.
One Slop Automotive.
Our Lady Mother of the Chuttt
Pawnbank, Incorporated.
___ 2*9
28*
..._287-
.2I9-
People's Choice Transportation, Inc —
Perez Imports --------- .„.._ --------
Phfflipj 66 Propane Company. ------- .....
Poplar Grove Care Center ..... - ................
Professional Repair Service ............. —
R-Place... ................ „ ........................... „
RAC Transport Co., be ............. ---------
Rainbo Bread Company.. ............... .....^
Rera-A-Heap Cheap.....— ........ ..... ______ ..
Rtggi Oil Co., be ........ ............. ...... ____ -.
Rocky Mountain Fire ft Safety. ..... ..
Rose Terrace Care Center. — .......... ------
Roybal's Barber Shop ................... _______
Rusty'sCafe .......................... „ ..................
Ruth Am'* Bookkeeping. ...... . ..... ---------
S A C Fire Dept -------------- ........... -------
SAC Water ft Sanitation Disrict ___________
Sand Creek Optimist Club. ............. ..........
School District 14 Credit Union, ___________
Schroeder Auto Carriers, be — ........ .....
Securny Key ft Lock. ....... ____ .......... _______
Shady Lane Mobile Home Park. ------ !.....
SheO OB Company. -------------------------------
Sheraton hn Denver Airport............ ........
Shorty's Tree Service ................................
Sir Speedy Printing Center, he .................
Stand By Power Service Co., Inc. ----------
Steven R. Gibson, P.C __________________________
Stewart ft Stevenson Power, be. --------
Stockyards Ranch Supply, Inc. ----------
Surplus Supply CcJAce Hardware..
.2*8-
219-
---------- 289-
217-
.219-
The Bank of Cherry Creek.
The Greater Rocky Mwnain Group..
The Sewer ft Plumbing Works, be...
r«npte,be..
Tnvcl Titnc..HKH..H»,HHHHMH
Triple T Appliance Repair..
True Vintage Sales ..... ...__._..
United Asphalt, be ....... .....«•«
United Parcel Service..
United Power, be
VaDey Glass Co. he ............. ______
VFW Post 14444 Currie-Totes.....
VP» Printing. ............. ..................
W J Whatley, be...... ...... ........ ____
Waste Management of Colorado...
Wattrsavcr Company, Inc ........ •-.<
Weaver Electric Co ....... . ....... ...
Worthwhile ton. .........................
Westurf Distributors, be ...........
Younger Brothers Lumber ......... ,
..430-3
.....6594
_..287-0
.._2(64i
-288-31
....-2874!
...289-1
..~289.ll
288-a
...2S9-6
...289-1!
288-21
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DEPARTMENT OF THE ARMY
PROGRAM MAW .ER FOR ROOKY MOl 'STAIN AKSL'NAI.
OOMMEROE 01TY. COLORAPO NV::.j ?•»-
June 11, 1996
REPLY TO
ATTENTION OF:
Office of the Program Manager
Commerce City Business and Professional Association, Inc.
P.O. Box 303
Commerce City, Colorado 80037-0303
Dear Officers and Board of Directors:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
The Army believes that the Agreement in Principle that the Army and Shell Oil Company
have reached with South Adams County Water and Sanitation District (SACWSD) ensures an
adequate, safe, and permanent water supply for the community. The Agreement in Principle,
enclosed with this letter, includes payment of $48.8 million to SACWSD and requires that
SACWSD water be supplied to consenting drinking water well owners within the diisopropyl
methylphosphonate (DIMP, an RMA byproduct) plume by January 1999. In addition, the
Agreement in Principle requires SACWSD to provide 4,000 acre-feet of water to Commerce City
and the Henderson area by 2004. The parties involved in the water negotiations believe that the
settlement is fair and will permit SACWSD to secure an adequate water supply for Commerce
City's and Henderson's water needs. If you have any further questions regarding the water supply.
please contact Mr. Tim Kilgannon of this office at 303-289-0259 or Mr. Larry Ford of SACWSD
at 303-288-2646.
The Army understands that there is a perception among the public that RMA
contamination has had a negative effect on the image of the surrounding communities. However.
the ongoing remediation and the future transition to a National Wildlife Refuge will continue to
have a positive influence on that image. In addition. RMA has contributed to the communities in
several other ways. The Army and the U.S. Fish and Wildlife Service provide educational
opportunities through remediation or wildlife tours, and the Army has recently received
accreditation for its environmental education program through the Colorado School of Mines and
the Denver Public Schools. Economic contributions include hiring of local contractors and labor
and providing used computer equipment to the public schools The Army is committed to seeing
that RMA is a leader in environmental remediation Lessons learned at RMA will be shared
throughout the United States; this leadership image reflects not just on the success of the
remediation but especially on the public involvement process
Readiness is our Profession
-------
-2-
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
EugeneI. Bishop
Colonel, U.S. Army
Program Manager
Enclosure
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
-------
AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE. 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
13SMOO VHH --- Aid im HIAW3 AKHV SO Ot6Z9B9 C(U IVJ »S:CT
96/9Z/TO
-------
WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR> METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT .
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
coo®
Aid MVI HIAN3 AXHV SO
0*62969 COi IVJ SS:CT IHd 96/92/10
-------
G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
too®
sn OWBM
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AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. ^
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTrTUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10-26/01/96
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January 14, 1996
On-Post Proposed Plan Comments
Program Manager
Rocky Mountain Arsenal
Atti AMCPM-PM/
Col. Eugene Bishop
Building 111-RMA
Commerce City, Colorado 80022-1748
Dear Col. Bishop:
Thank you for giving us the opportunity for making
comments to the Rocky Mountain Arsenal On-Post Closure Plan.
This comment is from a concerned citizen and should
be considered as my comments alone , eventhough, I am active
in the Site Specific Advisory Board and Restoration Advisory
Board for the Rocky Mountain Arsenal.
After rereading the past comments written by the I
public regarding the remediation plans, I am very disappointed
that the Parties have not taken much consideration for vhat
the public wants done at the Arsenal for clean up and re-
mediation. The public has asked for remediated land and
clean water. The public has asked that the contaminated
soil and leachate remain on site and treated. The Parties
are not going to remediate any portion, except the Hex Pits,.
maybe. The majority is being capped, some landfilled and
other actually removed from the site taken elsewhere.
Burying the problem just leaves it for others to
contend with later.
I wanted and was lead to believe that the Arsenal
was going to be cleaned up—not just covered up.
My opinion on the Parties solution:
1. Capping:
A. dumping dirt on top of explosives,
nerve gases, mustard gases, pesticides,
etc., then promoting public access is
totally unacceptable.
B. natural phenomina is not addressed such as:
earthquakes, floods, ground water contamination
9601615-1/1
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Page 2 Rocky Mountain Arsenal Closure Plan Comments
2. Landfill:
A properly built and managed landfill seems
to be a necessity coupled with reasearch
to provide adequate solutions.
A. site: should be near Basin A or F
not near any earthquake fault
and well above the water table.
B. construction: the liners should be
tested for the chemicals it is
containing. Individual areas
should be set aside for different
chemicals and not all mixed to-
gether. Must be built to last.
Also, must be built so that easy
access for monitoring, as well as,
removal when new technology exists
for proper neutralization.
i
C. monitoring: proper regulations maintained
with the highest skill and
technology for today and for the
future generations.
3. Solidification:
A. a medium that will not break down with age.
B. a medium that the toxins will not leach.
My solution is to neutralize the chemicals that can be
treated with todays technology, properly stored and managed.
What is not known; reaserch at Rocky Mountain Arsenal for the
answers to the currently unknown so that they can be correctly
and harmlessly processed. Fence off Sections 1,26,25,31,3^,2
from the public access with signs clearly labelling the hazard-
ous conditions that are weather-worthy for hundreds of years.
Specific research for Rocky Mountain Arsenal chemicals and
conditions oust be provided for on site immediately to reduce
the cost of remediation and make the cleanup more effective
and safer.
Lonna Fischer
SSAB/RAB
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DEPARTMENT OF THE ARMY
PROGRAM MANAO.ER I:OR ROCKY MOI 'STAIN ARSPXAI.
COMMERCE CITY. COLORAPO W::.!74-<
June 11, 1996
REPLY TO
ATTENTION OF
Office of the Program Manager
Ms. Lonna Fischer
4070 E. 129 Way
Thornton, Colorado 80241
Dear Ms. Fischer:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
The Army realizes that there are remaining issues regarding the selected remedy for RMA.
However, public concerns were definitely considered in the development of the alternatives. The
concerns about the short-term risks and effects of excavation and treatment were weighed against
the potential long-term effects of containing the waste in place. The public has also been
concerned about thermal processes such as incineration because of potential emissions. The
Army's selected remedy minimizes short-term risks of exposure to workers and the community
because soil-borne contaminants are left in place. The landfill and cap/cover designs will comply
with federal, state, and local regulations.
A common public concern during the selection process was the availability of a safe water
supply. Clean water for the public is one of the Army's primary goals that will be met by
continued boundary system operation and by providing a supplemental water supply. The Army
believes that continued treatment of water at the RMA boundary is an important part of the
remediation. The RMA boundary treatment systems currently treat about one billion gallons of
water per year to meet all state and federal standards.
Responses to your specific comments are provided below.
1. Capping:
The capping process is significantly more complex than your comment suggests. Multiple
protective layers (Resource Conservation and Recovery Act [RCRA] caps or RCRA-
equivalent caps that meet all federal, state, and local regulations) will be constructed over
the more contaminated sites, and soil covers of 1 foot or more of clean soil will be
constructed over the less contaminated sites. The cap/cover structures will be designed to
minimize rainfall infiltration and the potential for human or animal exposure. All
caps/covers will be maintained regularly and repaired if necessary. Public access to capped
Readiness is our Profession
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-2-
areas will be very limited. Natural phenomena, such as earthquakes and floods, and
introduced phenomena such as contamination, must be and are considered in siting,
design, construction, and operation of hazardous waste containment and treatment
systems.
2. Landfill:
The hazardous waste landfill will be a state-of-the-art landfill that complies with or
exceeds all federal and state siting, design, construction, operation, and closure
requirements. Measures will be taken to ensure safe disposal, and all operations will be
under the oversight of the Colorado Department of Public Health and Environment.
Siting studies have been conducted to identify the best possible location for the landfill,
with regard to both geology (soil type and whether it is near a fault) and proximity to the
water table.
The appropriate testing will be conducted for the liners. Several separate "cells" are
planned so that waste can be segregated. The landfill design will satisfy all applicable
siting and monitoring requirements.
The landfill is included in the periodic overall review of the remedy as required by the US
Environmental Protection Agency (EPA). Also, extensive monitoring in and around the
landfill itself will take place as part of the long-term landfill operation.
3. Solidification:
There has been significant technological development in the area of
solidification/stabilization chemicals as well as in test methods over the past decade, much
under EPA sponsorship. The Army agrees that tests must be conducted to ensure that
stabilization chemicals used are compatible with the waste, that the products are stable,
and that treatability goals can be met.
The Army believes that the capping/covering of much of the central portion of RMA (e.g., Basins
A and F, South Plants) is protective of human health and the environment. In addition, the RMA
National Wildlife Refuge planning efforts are considering which areas the public may access
during and after the remediation.
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-3-
Extensive testing and research already has been conducted for most of the RMA
chemicals, and monitoring, feasibility studies, and treatability studies have been conducted during
the past several years as part of the On-Post Remedial Investigation/Feasibility Study process
leading up to the Record of Decision.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Eugene/H. Bishop
Colonel, U.S. Army
. Program Manager
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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Fuller East Partnership
Fuller 45 Partnership
_ ERGERDOC
// "
General Partnerships
John J. Vandemocr
JohnB. Vfflano
Managing
8791 Circle Drive
Westminster, 00 80030
Ph. 427-7641. Fax 427-5167
Pager 687-1212
December?, 1995
Program Manager lor the Rocky Mountain Arsenal
Rocky Mountain Arsenal
Commerce City, Colorado 80022
Dear Program Manager for the Rocky Mountain Arsenal:
We are the General Managers of three general partnerships in the Henderson vicinity. The partnerships
total 146 acres which have been subdivided into 2 to 2.5 acre home sites. We have die powers of attorney
to sign for the General Partners in these partnerships. They all concure with us that the following
statement is their wish.
We the undersigned, being property owners of the area known as Henderson, Colorado, Directly North of
the Rocky Mountain Arsenal, request that the United States Army and Shell Oil CO pay for and install a
water system to provide water to the existing homes and future and water needs due to the contamination
of our water supply. The water provided to the area must replace the 2500 acre feet of contaminated water
and be of excellent quality and quality and sufficient quantity to repair the damage to our area. Since
1942 the United States Army and Shell Oil Co. have been contaminating our ia»d and water »"d must be
held accountable for their actions.
Sincerely,
;: [Three General Partnership Usts of General Partners]
9534503-1/1
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DEARMRPRESIDEKt
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FINAL REMEDY AS THEY CAtLIT ^ WELL NT GIVE US ANY.O£AN WATER.
HOWCANACXJUmilYSUOTASOl^S THE GREATESTINTHE WORLD HELP
OWKPEACB LOVWG TAXfAViNG VLAG WAVING CmZENS?WEDONOTSEEK
MUCH, BUT WATER PUKE AND SIMPLE! WE DESIRE A SUPPLY OF 2500 ACRE
FEET PER YEAR TO SUSTAIN US ^IWIILTHE MISDEEDS OF 1HE ARMY ARE NO
MORE THIS IS ESUMATED AT FORTY YEARS. THIS WE ASK IN YOUR NAME
FOR TmPEOPlX OF HE^ERSOH,CO:ilM>ERSTA)^ WHERE ALL YOUR
ENERGY MUSr;Op FQR liffiWpMOT. BWff
MAXl^R ^ JEEfiRE 1HE J^RMY 'ftiML^WIliUMMSl QF 1996 WE WOULD
SEASON, YOU AND YOUR FAMILY..
IHflSkYOO
,' HENDERSON JCO 80640
9605904-l/l-A-a
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PRI U:3I FAX 701 117 4721 AICU ^- CIDCOI
U004
December «.
Dear Resident;
In Nay of If 95 the United States Army (Army), Shell Oil
Company (Shell), Colorado Department of Public Health and
Environment (CDPHB), United state* Environmental Protection Agency
(EPA), and the United State* Fish fc wildlife Service (USFfcWS),
agreed upon a Conceptual Remedy to be ueed in the cleanup of the
Rocky Mountain Arsenal. The Conceptual Agreement meana the five
parties have agreed in principal how to cleanup the Arsenal. The
final decision, called the Record of Decision (ROD), ie to be
issued in the spring of 1996.
However, the Conceptual Agreement does not address the issue
of contamination of off-post water. The Stakeholders, which
include Commerce City and Bender con have asked for 7500 acre feet
of good quality water to replace the contaminated aupply. The
Conceptual Agreement states that the Arnty and Shell will provide a
replacement supply of only 4000 acre feet, which is not intended to
serve Henderson. In the past it was estimated that there was 2800
acre feet of ground water which could be served to the Henderson
area. We think it is important that the 3500 acre feet of water be
provided to Henderson in addition to the 4000 acre feet identified
in the Conceptual Agreement.
It is imperative that residents and property owners in
Henderson make their wishes for a clean, safe, reliable water
supply known immediately.
Statements may be mailed tot
Program Manager for the Rocky Mountain Arsenal
Rocky Mountain Arsenal
Commerce City, Colorado S0023
Zn an effort to secure a clean, safe, reliable water supply,
the Henderson Coalition was formed. The Coalition is sponsoring a
meeting for residents to voice their opinions. The Army, Shell,
EPA, CDPXB, and USF4WS have been invited to the Tuesday, December
12 meeting. The meeting will be held at 7:30 p.m. at the Adams
County Regional Park, I7S5 Henderson Road. A flier with the
details is enclosed. The Coalition is also circulating petitions
which can be signed at the December 12 meeting.
9605904-l/l-A-b
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•t/IJ/te FBI ll:,, PAX »., .„ „„ ^ ^ ^^
He need to show the policy makers that we are united in our
effort* to get a clean, eafe, reliable water supply to replace our
poieoned, contaminated supply.
Following ie the language ueed in the petition:
WE, THE OKOTRSIORED, B8XMQ JtBSX&EMTS AMD/OR PROPERTY OMRERS OF THE
AREA XMOWI AS KBVDCRSOW, COLORADO, DIRECTLY NORTH OF THE ROCKY
MOORTAJV ARSBBAL, DBMMD THAT TBS OT1TED STATES ARMY MR) SHELL OIL
OQKFAMY PAT FOR AMD XMRftLL A HATBR SYSTEM TO PROVIDE KAT» TO THE
BXI8TZM9 HCK18 AUD FDTOWS WATER KKKD8 COB TO THE COHTAMIRATICHI OF
OCR WWW SUPPLY. THI HATER PROVIDED TO THE AREA. MIST REPLACE THE
3500 ACRE PUT OF COBTAHIHATH) HATER AMD BE OF EXCELLDTT QOALITY
AHD suFTicinrr QOMTTITY TO REPAIR TUB DAMAGE TO OUR AREA. SINCE
1943 TUB OTITBD 8TATB3 ARMY AMD SHELL OIL COMPAMY HAVE BEES
ca*TA*mATrjw orm LMD AMD WATER AMD MUST BE HELD ACCOUNTABLE FOR
THEIR Acnom.
Renenber, the Army and Shell h«v« polluted and poieoned our
water for S3 year*. At no time have they agreed with the
Stakeholders that our supply should be replaced. CDPHB has
provided bottled water to members of our community for years.
If this issue is not resolved before the ROD is signed, there
will be no recourse.
It is up to u* to secure che future of our community. Write a
statement to the Program Manager of the Rocky Mountain Arsenal,
sign the petition, and attend the meeting on December 12.
Encourage your neighbors to participate. This could be the last
opportunity to recover some of the damages to our community.
Sincer*
(James L. Brgei
Henderson Coalition
Cnel.
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02/23/06 «I 11:37 FAX TO* £1T J,7« _. _ . _
AMCLL
•»«-. CBVCUJI
HENDERSON AREA RESIDENTS
Bftdgr Mtmuia AHMI! FaRitMi and CeouBlauf
fTflS Hudtnoa lM<, Brig»»B, CO
»Do« your well have PIMP? x
mWhy fevcn't the US Anny or Shell Ofl replaced the water
they have poisoned since 1942 (53 yean)? £
1.0 D
hu not included ny Mgh quality repUc«inem water
US An^, SMI OR, Tri^ouay HedtK Cotondo
, Saudi Adwiu County Wittr and Siniution.
AdMBi County CommZuloo«r» ud EPA.
Ckatrmait, 659-0549 (komt).
9605904-l/l-A-c
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TO PROGRAM MANAGER
ROCKY MOUNTAIN ARSENAL
IBEUEVETHAT YOU* FINAL DECISION CANNOT BE MADE WITHOUT
A COMPUTO OVERHAUL OF THE HENDERSON RESIDENTS WATER SUPPLY
IF WE ARE TO ONLY GET UP SERVICE THEN WE WELNEVER ACCEPT
ANY FINAL REMEDY, WE DEMAND WATER THAT YOU HAVE TAKEN FROM
US.
IF WE HAVE 2500 ACRE FEET IN OUR AQUIFER TEUTHAS BEEN DESTROYED
BY THE ARMY AND SHELL THEN NO AGREEMENT WILL BE ACCEPTS) AS
PWAL WnHOUTTHATSPECIFIC NUMBER WRTT1N IN STONE/THE TOTAL
COST OF THIS REMEDY SHOUU) NO LONGER FALL UPON US. AS WE HAVE
BORETHEPAW AND UNDUE MONETARY HARDSHIP YOU HAVE PLACED
UNTO,US SINCE IK!
THE YEARS OF LIES THAT YOU HAVE PERPETUATED UPON US HAVE BEEN
EXPOSED. Bin* WHAT OOOD DOES THAT DO US TO KNOW THE mUTH IF
WEARETOLDTOATlSDOESNOTMATreR?-raATWHATMATnE3lSISTOAT
THE GOVERNMENT CAN DO TO US WHAT FT WANTS AND ANYONE UNDER
coxifcACT wrra SAME is EXEMFT.WE REQUIRE, WE DEMAND JUST
COMPENSATION! THIS WILL BE DONE BEPOREYOU REACH THE END OF
YOURASSOOATlONWriHTHE PEOPLE OF ADAMS COUNIY. ONLYTHEKCAN
WE ALL LIVE IN PEACE AND HARMONY WTIH ONE ANOTHER AND OUR
OOVERNMBtt
THANK YOU
ROBERTS. HANSON
11001E 120 AVE
HENDOSON CO. 10640
9605904-l/l-A-d
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROOKY MOI 'STAIN ARSENAL
COMMERCE O.ITY. COLOR APO SY 2 2-!?•»•;
June 11, 1996
REPLY TO
ATTENTION OK.
Office of the Program Manager
Mr. Robert S. Hanson
11001 E. 120 Avenue
Henderson, Colorado 80640
Dear Mr. Hanson:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
The Army believes that the Agreement in Principle that the Army and Shell Oil Company
have reached with South Adams County Water and Sanitation District (SACWSD) ensures a safe
and adequate water supply for the community. The Agreement in Principle, enclosed with this
letter, includes the payment of $48.8 million to SACWSD and requires that SACWSD water be
supplied to consenting drinking water well owners within the diisopropyl methylphosphonate
(DIMP, an RMA byproduct) plume by January 1999. In addition, the Agreement in Principle
requires SACWSD to provide 4,000 acre-feet of water to Commerce City and the Henderson area
by 2004. The parties involved in the water negotiations believe that the settlement is fair and will
permit SACWSD to secure an adequate water supply to satisfy Commerce City's and Henderson's
water needs. If you have any further questions regarding the water supply, please contact
Mr. Tim Kilgannon of this office at 303-289-0259 or Mr. Larry Ford of SACWSD at
303-288-2646.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Eugene H. Bishop
Colonel, U.S. Army
Program Manager
Enclosure
Readiness is our Profession
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-2-
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS wiLL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZAT1ON OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
ZOO® laSNflOD VKH ~«- Aid MV1 HIAN3 AJWV Sll 0>6Z969 COZ IVj »S:CT IHJ 96/92/TO
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WATER' AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
coo®
AM MVI HIM® AKHV sn OWM9 «u iw SS:CT zu 96/9Z/To
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY TfflS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
vita «-«. Aia M? T»W «
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AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS* CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. "-"
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
O. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
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US ARMY ENVIR LAW DIV
RMA COUNSEL
121006
20'd "W101
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DEC-12-99 TUE 10:1X AM HUMPHREY . Z0S2S21242
9390 K. l«t Ave.
Lahwood, CO 80226
212-1242(fAX or phone)
*£^
Ruth jfwtKajB
Public Affairs Office
Rocky Mountain Arsenal
FAX 219-0582
December IS is the stated end of the comment period for the
Proposed Plan. Technically the comment period could have ended in
November, so the period has already been extended once.
ftince *y main 'interest Ts the safe and effective cleanup of
Rocky Mountain Arsenal in the shortest practical tiae period, X am
eppo»«d to *«x axtvnaion of the comment period for the Proposed
rian*
Za no way do X wish to imply lack of support for on-going
evaluation of all studies of health or environmental effects of
past and/or future actions. 'Results of studies should be «ade
public and *kould b* *xp«ct«d to iaipaet the tfeoislea-aakiBg proeesa
wh«n 4fc f!00t*s te •pacific t«at»no1«gf.*a.
laares rooai for such adjustments.
Thank you.
9534604-1/1
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JAM-ie-96 THU B4:il PI1 HUMPHREY Z832321242 P.Si
9390 W. 1st Ave, Lakewood, CO 80226
On-Poet Proposed Plan Comments
Program Manager , Rocky Mountain Arsenal
Attni AMCPM-rM/Col . Eugene H. Bishop
Colonal Blahop:
As Z have stated in tha past, X believe tha goal of
remediation at Rocky Mountain Arsenal must be protection of human
health M« the environment. Generally, Z think tha Proposed rlan
points in tha right direction. However/ there are some things
which should be spelled out in the final Record of Decision.
1. Polks in the Beaderson area which have walls contaminated
by DIMP or other materials from RHA should be provided safe water
and the needed delivery system. Tha cost should be included as one
of the costs of remediation and given high priority for completion
within the next year or two.
2. Environmental Monitoring should be combined with Health
monitoring in order to assure stakeholders that remediation ia
indeed meeting the stated goal.
I
3. I'm concerned about tha adequacy of tha five year raview
process as outlined at the Restoration Advisory Board meeting last
fall. la order to fully understand the effectiveness of the
remediation program it is imperative that tha official review
include data on all work, monitoring data, public comments or
complaints, and proposed scheduling. The first raview should take
place during 2001 with total review taking place each five yeara
after that. Oood public relations suggest an ongoing public raview
of progress, problems, and proposals such as take place at RAB
meetings.
4. Tha HEX pits seem to pose a apecial problem at this time.
If an acceptable solution can not be reached before the R.O.D.
deadlines, I recommend that they be pulled out of the On-Post
R.O.D. and become a separate operable unit!
5. A Trust Fund has been sold as a back-up guarantee for
stakeholder concerns, but is still tentative. The Trust Fund must
be guaranteed as part of the remediation 1 It must be available for
emergency use or for use in case Congress refuses to fund Operation
and Maintenance at a future time. I want remediation to be
complete as soon as possible, but not at the expense of long-term
health riftka.
6. Public involvement should go beyond what i« required,
including open houses, progress reports, and other means which will
answer questions and concerns of stakeholders. Failure to keep the
public involved in the past has led to .suspicion and opposition,
neither of which will facilitate community acceptance.
9601819-1/1
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER IVR ROCKY MOI \TAI\ ARSl.'NAI.
OE CITY. i:OI_ORAPO NY:M 74s
REPLY TO
ATTENTION OF:
June 11, 1996
Office of the Program Manager
Ms. Clara Lou Humphrey
9390 W. 1st Avenue
Lakewood, Colorado 80226
Dear Ms. Humphrey:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
Your first letter was emphatic in that the period for comments on the On-Post Proposed
Plan should not be extended for any reason. Although the Army agrees with the spirit of the letter
to the effect that the remediation process should move fluidly and unimpeded by needless delays,
several parties required more time to research the document adequately and to assess its contents.
In order to allow additional time for comment without excessively delaying the Record of
Decision (ROD), the comment period was extended by 30 days.
Your second letter contained additional comments, and responses are provided below,
numbered consistent with your comments.
1. The Army and Shell have reached an Agreement in Principle with South Adams County
Water and Sanitation District (SACWSD). The Army and Shell have committed to connecting
Henderson area well owners to the SACWSD or alternative system if their wells are located
within the detectable area of the diisopropyl methylphosphonate (DIMP, an RMA byproduct)
plume footprint north of RMA, which is currently being evaluated. The Agreement in Principle,
enclosed with this letter, includes payment of $48.8 million to SACWSD and requires that
SACWSD water be supplied to consenting drinking water well owners within the DIMP plume
footprint by January 1999. In addition, the Agreement in Principle requires SACWSD to provide
4,000 acre-feet of water to the Commerce City and Henderson area by 2004. The parties
involved in the water negotiations believe that the settlement is fair and will permit SACWSD to
secure an adequate water supply to satisfy Commerce City's and Henderson's water needs. If you
have any further questions regarding the water supply, please contact Mr. Tim Kilgannon of this
office at 303-289-0259 or Mr. Larry Ford of SACWSD at 303-288-2646.
Readiness is our Profession
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2. The primary goal of the Medical Monitoring Program is to monitor any off-post impact
on human health due to the RMA remediation. Elements of the Program could include medical
monitoring, environmental monitoring (including water, soil, and air monitoring), or
health/community education. This Program will continue until the on-post soil remediation is
completed. A Medical Monitoring Advisory Group has been established to evaluate specific
issues covered by the Medical Monitoring Program.
3. The extensive, site-wide monitoring program that is planned will provide early
detection of any problems with either soil or groundwater remediation. Additionally, the required
periodic five-year review of the remedy will evaluate whether the remedy remains protective of
human health and the environment. The Army agrees that the review should be comprehensive,
and intends to continue the dialogue with the public in a forum like the Restoration Advisory
Board, as you suggest.
4. Subject to the results of treatability testing and technology evaluation, approximately
1,000 bank cubic yards (BCY) of principal threat material from the Hex Pit will be treated by an
innovative thermal technology. Solidification will become the selected remedy if evaluation
criteria for the innovative technology are not met. The remaining 2,300 BCY of material will be
excavated and disposed in the on-post hazardous waste landfill.
5. During the formulation and selection of the remedy, members of the public and some
local governmental organizations expressed keen interest in the creation of a Trust Fund, as you
do in your comment, to help ensure the long-term operation and maintenance of the remedy. The
Parties have committed to good-faith best efforts to establish such a Trust Fund, as described in
the On-Post ROD. Principal and interest from the Trust Fund would be used to cover the costs of
long-term operations and maintenance throughout the lifetime of the remedial program. These
costs are estimated to be approximately $5 million per year (in 1995 dollars).
It is the intent of the Parties that if the Trust Fund is created it will include a statement containing
the reasons for the creation of the Trust Fund, a time frame for establishing and funding the Trust
Fund, and an appropriate means to manage and disburse money from the Trust Fund. The Parties
are also examining possible options that may be adapted from trust funds involving federal funds
that exist at other remedial sites. The Parties recognize that establishing a Trust Fund may require
special congressional legislation and that there are restrictions on the actions federal agencies can
take with respect to such legislation. Because of the uncertainty of possible legislative
requirements and other options, the precise terms of the Trust Fund cannot now be stated.
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-3-
A Trust Fund group will be formed to develop a strategy to establish the Trust Fund. The
strategy group may include representatives of the Parties (subject to restrictions on federal agency
participation), local governments, affected communities, and other interested stakeholders and
will be convened within 90 days of the signing of the ROD.
6. As stated in the response to your Comment Number 3 above, the Army intends to
continue the dialogue with the public throughout the remediation process at RMA.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
-ugene M. Bishop
Colonel, U.S. Army
Program Manager
Enclosure
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SDC MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
zoo® lasNnoo via -«• AIQ MVI HIANH wrav sn 0>6l969 m IYJ >S:CT
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
• THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
""~ AI° * •""""s"
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AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. <-"
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10 - 26/01/96
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01/26/96 FRI 13:57 FAX 703 6962940
US ARMY ENVIR LAW DIV -.-»-» RMA COUNSEL
(2)006
20'd TW101
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MO1 NTAIX AKSIINAI
CE CITY. COLOR A
June 11, 1996
REPLY TO
ATTENTION OF
Office of the Program Manager
Mr. John Humphreys
11690PeoriaSt.
Henderson, Colorado 80640
Dear Mr. Humphreys:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
The Army believes that the water supply issue for Henderson has been successfully
resolved through the Agreement in Principle that the Army and Shell Oil Company have reached
with the South Adams County Water and Sanitation District (SACWSD). The Agreement in
Principle, enclosed with this letter, includes the payment of $48.8 million to SACWSD and
requires that SACWSD supply water to consenting drinking water well owners within the
diisopropyl methylphosphonate (DIMP, an RMA byproduct) plume footprint by January 1999. In
addition, the Agreement in Principle requires SACWSD to provide 4,000 acre-feet of water to
Commerce City and the Henderson area by 2004. The parties involved in the water negotiations
believe that the settlement is fair and will permit SACWSD to secure an adequate water supply to
satisfy Commerce City's and Henderson's water needs. If you have any further questions
regarding the water supply, please contact Mr. Tim Kilgannon of this office at 303-289-0259 or
Mr. Larry Ford of SACWSD at 303-288-2646.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Eugene H. Bishop
Colonel, U.S. Army
Program Manager
Enclosure
Readiness is our Profession
-------
-2-
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
-------
AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
zoo® laswnoo VHH --- Aid mn HIANS AKHV sn otelsw c
-------
WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT .
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
coo®
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ATOV sn
0*62969 CO* IVJ SS:CT IHd 96/92/10
-------
G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
™ - u. *n «« „ sn
-------
AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. -"*
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10-26/01/96
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• IAtm* S. IAN (S _. . ,, IAft.
. EDWAIO HIM.i December 13,1995
• S U I I I 1310 •
ONE TAIOI CE NTEI
Program Manager for the Rocky
1200 • utk SHEET Mountain Arsenal
DE«VEI • co • 10202 Rocky Mountain Arsenal
Commerce City, Colorado 80022
NONE • 303-444-2717
HI • 303-444-27U
The undersigned represents James H. Imatani and Sumi Imatani, who own
a residence in Henderson, Colorado. It is our belief that the United States Army
and Shell Oil Company have caused contamination and irreparable damage to the
water system that feeds the wells from which they obtain water for subsistence.
The current plan set forth in the Conceptual Agreement fails to provide a substitute
source of water. We hereby demand that an alternative source of water be
provided in the plan for residents of the Henderson area. Otherwise, Mr. and Mrs.
Imatani will effectively lose their residence.
Your consideration is most appreciated.
Very truly yours,
BANKS & IMATANI, P.C.
Hrbds
cc: Mr. and Mrs. Imatani
Henderson Coalition, c/o Jim Erger
Banks & Imatani, P.C.
* " « ' " " S « ' l » * • ,534803-1/1
-------
REPLY TO
ATTENTION OK
DEPARTMENT OF THE ARMY
PROGRAM MANAGER 1-VR ROCKY MOl STAIN AR-TNAI.
COMMERCE CITY. COLOR APO SVZMT-t^
June 11, 1996
Office of the Program Manager
Mr. Edward Imatani
Banks & Imatani, P.C.
One Tabor Center, Suite 1310
1200 17th Street
Denver, Colorado 80202
Dear Mr. Imatani:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
The Army and Shell Oil Company have-reached an Agreement in Principle, enclosed with
this letter, with South Adams County Water and Sanitation District (SACWSD) that includes the
payment of $48.8 million to SACWSD and requires that SACWSD water be supplied to
consenting drinking water well owners within the diisopropyl methylphosphonate (DIMP, an
RMA byproduct) plume footprint by January 1999. In addition, the Agreement in Principle
requires SACWSD to provide 4,000 acre-feet of water to Commerce City and the Henderson area
by 2004. The Parties involved in the water negotiations believe that the settlement is fair and will
permit SACWSD to secure an adequate water supply to satisfy Commerce City's and Henderson s
water needs. If you have any further questions regarding the water supply, please contact
Mr. Tim Kilgannon of this office at 303-289-0259 or Mr. Larry Ford of SACWSD at
303-288-2646.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Eugene" H. Bishop
Colonel, U.S. Army
Program Manager
Enclosure
Readiness is our Profession
-------
-2-
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
-------
AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
zoo® lasMnoo vra ~- Aia *vi HIAWH AIHV sn onzasa coz ivj »S:ET IHJ se/sz/io
-------
WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST .
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT .
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
coo®
VHH
Aid MV1 HIAN3 AHHV
Om969 COi XVd SS'CT IHd 96/92/10
-------
G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
13SKnoo m _ Alfl
Sn 0>6Z969 CO* XVd 9S:CI
96/9Z/TO
-------
AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. ^
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
O. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10 - 26/01/96
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SANDKA JAQUITH
Attorney at Lout
844 Downing Street 303-832-3707
Denver, CO 80218 FAX 303-832-3708
January J47 1996
On-Post Proposed Plan Comments
Kevin Blose, Program Manager
Rocky Mountain Arsenal
Attn: AMCPM-PM/Col.Eugene H.Bishop
Building 111--RMA
Commerce City, CO 80022-1748
Re: My AMENDED COMMENTS ON THE PROPOSED PLAN FOR THE ROCKY
MOUNTAIN ARSENAL ON-POST OPERABLE UNIT
Dear Mr. Blose:
After submitting my Comments on the Porposed Plan for the
Rocky Mountain Arsenal On-Post Operable Unit, on January 19,
1996, I found six typographical errors in my text. Please find
below a corrected and amended set of my comments. I want my
Comments, as corrected and amended, to be included in the RMA On-
Post Record of Decision. If you have any questions concerning
this request, please contact me at the phone number set forth
above.
INTRODUCTION:
I am submitting the following comments as an individual.
However, throughout the comments, I do make reference to a
collective "we." The comments asserted under my collective "we1
are derived from my participation in and/or my facilitation of
the many public meetings held in relation to the subjects
addressed in these comments. Although I do not claim to speak
for the public, I would assert that I have been in direct
communication with the many citizens affected by the Arsenal
clean-up and I am in a position to pass on their concerns and
comments.
9603601-1/1
-------
GENERAL COMMENTS:
This public comment process is a fraud. This plan offers for
public comment five alternatives for remediation and a proposed
plan, which represents what is commonly called the preferred
alternative in this phase of the CERCLA process. Unlike most
preferred alternatives, this one has been accepted and agreed to
by all five of the parties to this remediation as a negotiated
compromise. (See paragraph 'A* of Conceptual Agreement.) I
believe that this pre-selected remedy is contrary to §117 of
CERCLA.
The effect of presenting a pre-selected plan instead of a
preferred alternative is to make a sham of this public comment
process. Since this proposed plan has been accepted by written
agreement as the plan for remediation, it is not really a
proposed plan. It is the final agreement of the five parties.
Since each party agrees to support the Conceptual Agreement and
Proposed Plan, how could a modification based on public comment
be made? It has been presented by the Army, the lead agency, but
it will receive little or no critical analysis from the other
parties. We have already seen the effects in public meetings. No
one seems willing to critize the plan. We, as citizens, have
been told publicly and privately that none of the key elements
(meaning those set forth in the written agreement) will be
changed unless thiere is a "train wreck*. It was explained at
the November, 1995 RAB meeting by the parties that since it is a
negotiated settlement, if one element is changed then the whole
agreement fails.
My understanding of the role of public comment on a
preferred alternative is to give the public an opportunity to
review all alternatives and to comment on why or why not the
preferred alternative is acceptable or preferrable or
appropriate. This gives the public and the other parties an
opportunity to effect changes in determining the final remedy.
Since there will be no real changes between the proposed plan and
the final remedy, we must conclude that public comment is
irrelevant and constitutes an onerous and futile burden on the
public.
We will only believe that this public comment constitutes
meaningful public participation if significant changes are made
to this proposed plan.
I am unhappy that there is essentially no clean-up, no de-
toxification of the primary contaminants, in the proposed plan
(the only possible de-toxification would come from the promise to
treat the HEX Pits with an alternative technology.) The proposed
plan offers a little solidification, some landfilling, but most ~
of the contaminants will be capped with soil and/or concrete.
This is not a clean-up, it is a cover-up.
The Rocky Mountain Arsenal ("RMA") has been described as
containing the most contaminated square mile on the planet and,
by this proposed plan, the contamination will be left in place.
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I do not believe that this is protective of human health,
wildlife, or the environment.
This remediation decision is being made without knowing what
effect the contamination has had on the surrounding communities
or the wildlife. Inadequate studies have been done in the
surrounding communities regarding how to determine whether human
health has been affected, and the studies on the effects of the
contaminants on the wildlife have not been finished (most of them
were only begun in the past five years even though the Army has
been involved in the remediation process for at least twenty
years.) It is my belief that the parties did not, and do not,
want to know how the contaminants have affected human health and
the wildlife.
Shell Oil Company has claimed throughout this process that
the contaminants do not need to be treated or de-toxified. They
have adamantly and continuously supported the cover-up of the
contamination, even though there are no long-term proven
technologies on landfills and caps. Not suprisingly, Shell has
been instrumental in thwarting the studies of the health effects
of these contaminants on wildlife. Shell has refused to support
pilot projects on innovative treatment technologies. In doing so
I believe that they have controlled and defined the final remedy
at the Rocky Mountain Arsenal, to the detriment of all people of
Colorado. It is not right that the polluters were allowed to
decide not to clean up their mess. I am ashamed and appalled
that the State of Colorado, through the Governor's office, pushed
for and supported a remedy that does not clean-up the
contamination at RMA.
The only possible explanation for this absurdity is
that Shell Oil Company refuses to allow contaminants to be
treated and de-toxified. And if Shell refuses, it is not done,
since this proposed plan is based on unanimous agreement of the
parties.
When, and by what authority, was a preferred alternative
proposed only upon unanimous agreement of the polluters? In the
original DAA, the Army recommended extensive de-toxification of
the contaminants. The EPA and the State of Colorado supported
extensive de-toxification of the contaminants. It was only Shell
Oil Company that opposed de-toxification of contaminants. The
proposed plan contains no detoxification. Shell Oil Company
determined the remedy at RMA, a minimal and non-protective
remedy. A remedy that will require diligent monitoring and
maintainance if it is to be at all effective. And there is
presently no mechanism to create a trust fund to ensure that
such funds will be available for this purpose in the future.
1. ONE OPERABLE UNIT ('OU') IS NOT SUFFICIENT:
This on-post operable unit consists of 179 or 181 separate
contamination sites (depending on how you define and count).
There is no technical reason for heaping everything into one unit
and it is likely illegal to not break it up. Certainly, such a
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classification is burdensome on those citizens who seek to
review, analylize and comment upon it.
The on-post operable unit should have been divided into
smaller, related units so that the contamination problems could
be reviewed, analyzed, and remediated in some sane and reasonable
manner. Citizens, the EPA and even the State of Colorado have
requested this hundreds of times.
One on-post operable unit is not effectively manageable.
Even the site characterizations were inadequate due to the sheer
size of the site and volume of the contaminants. And more
importantly, it is virtually impossible to provide effective,
complete, and meaningful public participation when the problem is
as enormous as the RMA.
It seems that the many problems created by the overwhelming
size and complexity of the on-post operable unit at RMA were
purposely designed. It was Shell Oil Company that specifically
refused to allow the on-post operable unit to be broken into
smaller operable units. The sheer size ensured that it could not
be analogized to other sites, whereas smaller units might have
been so analogized. By maintaining one operable unit, every
aspect of the remediation had to be simplified and minimalized in
order to make it even minimally manageable.
The State of Colorado did NOT have enough staff to
effectively review and address all issues. Nor did the EPA have
enough staff to effectively review and address all issues. Only
the polluters. Shell Oil Company and the Army could afford enough
staff to effectively manage and address all issues. And, not
surprisingly, this Proposed Plan substantially resembles Shell's
original proposal for remediation.
This site is so huge and complex, and the corresponding
Proposed Plan is so vague and simplified, that any meaningful
comment is precluded. All details of actual remediation plans
and processes, and changes thereto, should require meaningful
public comment.
2. BASIN F UASTEPILB:
When Basin F Wastepile was placed in its present location,
the public was told that it provided a temporary storage of the
highly saturated and toxic soils. The liner was designed to last
five years, and we were told that it was stored pending treatment
(which I understood would be de-toxification of the
contaminants).
The Proposed Plan recommends moving the soils of the Basin F
wastepile to the landfill, in the process, the soils will be
heated to remove excess moisture. This is ironic since one of
the primary, proven technologies for removing pesticides from the
soils is to heat them, though at a higher temperature than is
necessary for simply removing the moisture. It is ridiculous to
heat the soil to remove the moisture and not heat it enough to
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remove the contaminants for treatment. I want the contaminants
removed from the soils of the Basin F wastepile and de-toxified.
3. GROUNDWATER:
The groundwater and aquifer have been contaminated and
Proposed Plan offers some treatment of the water but, for all
intents and purposes, the water that flows under the RMA is too
contaminated to be used. This has severely impacted the
drinking water of the surrounding communities and their future
growth.
Since at least I960, the surrounding communities and their
local governmental institutions have demanded a full clean-up of
the RMA. Replacement drinking water was needed and demanded.
Then, about a year-and-a half ago, it was made clear that the
Army believed that replacement drinking water was not legally
required as part of the remedy at RMA and that the remedy would
not include replacement drinking water and de-toxification of
contaminants. Those same governmental institutions that had once
demanded clean-up suddenly supported minimal treatment including
a cover-up of the contaminants. Compare Northern Coalition's
October and December SAPC positions. Replacement drinking water
was being held hostage and the surrounding communities seemed to
choose replacement water, to protect their health, their
community reputations and property values, and future growth. In
short, they chose their survival and will pay the price of living
next to the largest hazardous waste site in America.
Every citizen or member of the public with whom I have
spoken is unhappy with the Proposed Plan but many Commerce City
residents have accepted it in order to receive replacement water.
Unfortunately, the replacement water offered in the Proposed Plan
is less than that requested and is inadequate for the needs of
the surrounding communities, including South Adams County Water
and Sanitation District (SACWSD) and the Henderson area, where
the water still contains excessive levels of DIMP.
More water should be supplied, including the 7,500 acre feet
requested by SACWSD and additional water for the people of
Henderson for drinking and agriculture, where appropriate.
The water should be of the highest quality available.
4. BOUNDARY SYSTEMS:
The boundary water treatment systems are not effective
enough, and the Colorado Basic Standards for Groundwater (CBSG)
are not being met for inorganics (chloride and sulphate) at north
boundary and chloroform at northwest boundary. Where possible,
all contaminants, including DIMP, should be treated at the source
as well as at the boundary.
No remedy is proposed for treating NDMA, the western plume,
or arsenic, especially at Basin A Neck and the M-l ponds.
Proposed remedies are necessary, including meaningful public
comment.
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5. PUBLIC ATTENDANCE AT MEETINGS:
Members of the public should be allowed to attend or observe
meetings of the parties on technical issues and other day-to day
decisions concerning the RMA remediation. The parties have
refused the many requests by members of the public to attend such
meetings. Why are the parties so dedicated to hiding their
deliberations and decision making from the public?
6. SOIL TREATMENT LIMITS:
The decisions to excavate soil to only 10 feet (5 feet at
South Plants) and to limit "cap" the volume of soil to be
remediated were arbitrary and capricious and, therefore, illegal.
They were also never open to public comment. Soil excavation
and de-toxification should go as deep, and include as much, as
is necessary and practicable to detoxify them.
7. DIOXIN:
The proposed Plan is not a protective remedy because it does
not address dioxin. Given the types of chemical production that
occurred at RMA since the 1940s, there is every reason to believe
that there are high levels of dioxins at RMA. To determine the
extent of dioxin levels there should be full and extensive
sampling, testing, analysis, and risk assessments subject to full
and meaningful public review and comment.
8. HEX PITS:
The Proposed Plan provides no specific remedy but innovative
treatment and detoxification have been promised by the parties.
This remedy needs extensive analysis and public discussion before
a remedy is chosen, open to public review and comment. In my
opinion, and the opinion of many other stakeholders, the remedy
should be treatment of the contaminants using an innovative
technology including a closed system thermal treatment,
preferrably ECOLOGIC. This is the only site at which innovative
technology and detoxification were promised in response to
citizen concerns and demands. We fully expect the parties to
honor this promise.
9. EMERGENCY PLAN:
The Proposed Plan provides no emergency plan, excavation
plan, transportation plan, or traffic plan. All are necessary
and should be designed with full and meaningful public
participation.
10. SOUTH PLANTS:
The South Plants Tank Farn Light Non-aqueous Phase Liquid
(LNAPL) plume is not specifically mentioned in the Conceptual
AGreement and the present DAA recommends no action. The July,
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1993 version of the DAA porposed to extract and treat the LNAPL
and, as late as January, 1995, Shell supported the proposed
treatment. This issue was dropped without explanation or
comment. The LNAPL constitutes principal threat waste and should
be treated to reduce contaminants.
The Conceptual Remedy provides that high levels of water
will be maintained in the lakes to prevent the South Plants Plume
from migrating into the lakes. There is evidence that the lake
water levels are not achieving hydraulic containment. The plan
is flawed and not in compliance with the Conceptual Agreement.
The South Tank Farms Plume (STFP) needs a pump and treat
system rather than relying on elevated lake levels. It is a
ridiculous waste of water rights to attempt to use a hydraulic
pressure system that is already ineffective - and it is sure to
fail completely during periods of drought. This proposed remedy
is not protective.
It is proposed that the South Plants soils be excavated to 5
feet but they should be excavated as deep as is necessary to
remove principal threat contamination. Soils will also be
excavated from the M-l Pits and solidified, so why aren't the
excavated soils from the Lime Basins not also treated? At least
solidify them, especially since they are loaded with lime - a key
ingredient for the D.C.R. solidification process.
ALL of the groundwater from South Plants should be pumped
and treated to provide some source control of groundwater. Why
allow contaminated water to flow downstream causing contaminants
to spread to clean water or to seep into lower aquafers? This
was previously recommended in the DAA and proposed during the
SAPC negotiations, but was dropped without comment or
explanation.
12. FORMER BASIN F:
The Proposed Plan recommends in-situ solidification which is
an unproven technology. There is no basis for this treatment in
the record and thus it is arbitrary and capricious. Performance
standards have not been developed. Performance standards need to
be developed, along with a contingency plan if this remedy fails.
This needs to be re-evaluated and a proper record made to support
the remedy, and should be open to full and meaningful public
review and comment.
13. LAND DISPOSAL RESTRICTIONS (LDRS):
I have grave concerns about the application of the
Corrective Action Management Unit (CAMU) rule and the Area of
Contamination (AOC) concept to avoid complying with Land Disposal
Restrictions (LDRs). The application of the AOC concept at RMA
goes well beyond the definition of AOC in the NCP preamble. The
CAMU rule is currently being challenged and is obviously Illegal.
It is wrong to use these machinations to avoid federal regulation
and LDRs.
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14. BIOTA:
There is no selected remedy, only a selected process. A
remedy needs to be chosen, with full and meaningful public
participation and comment.
This should be made a separate Operable Unit. Short tern
destruction of biota would be justified to attain long-term
habitat improvement by detoxification of contaminants.
15. TRENCHES:
The Shell Trenches are extremely toxic and must be treated
and detoxified. It is a relatively small site but constitutes
some of the worst contamination. The proposed cap and slurry are
inadequate to remedy this site and the remedy is not protective.
It is proposed that the Army Trenches be capped with
concrete. This is absolutely inadequate. The Army Trenches
contain Unexploded Ordinances (UXO) and it is ridiculous to leave
UXO next to an international airport. A feasibility study needs
to be done to remove the UXO and the soils on this site must be
treated by detoxification of the high levels of contaminants.
16. LAKE SEDIMENTS:
There is no proposed remedy for lake sediments. This site
needs to be made a separate Operable Unit for evaluation and
development of a remedy with full and meaningful public review
and comment.
In conclusion I hereby and formally request that all
stakeholder comments and documents from the SAPC negotiations as
well as all public comments from the public meeting held on the
Proposed Plan at the Rocky Mountain Arsenal on November 18, 1995,
by incorporated In written form, and in their entirety,
into these public comments.
Sincerely,
idra Jaquith
Community CO-Chairperson
Remedial Advisory Board (RAB), Rocky Mountain Arsenal
Member of RMA, Site Specific Advisory Board (SSAB)
8
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DEPARTMENT OF THE ARMY
fROuRAM MAN.V.ITR FOR RiVk'V \K"l 'NTAiN ARSI.'NAI.
EilTVi VI.ORAIV sY:: ;7-|s
June 11, 1996
REPLY TO
ATTENTION O!'
Office of the Program Manager
Ms. Sandra Jaquith
Attorney at Law
844 Downing Street
Denver, Colorado 80218
Dear Ms. Jaquith:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
Enclosed are responses to your comments in the order they appeared in your letter
If you have additional questions or concerns regarding the RMA On-Post Proposed Plan,
please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again for
your comments.
Sincerely,
EugenpH. Bishop
Colonel, U.S. Army
Program Manager
o
Enclosures
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
Readiness is our Profession
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U.S. ARMY RESPONSES TO COMMENTS FROM MS. SANDRA JAQUITH
ON THE ROCKY MOUNTAIN ARSENAL ON-POST PROPOSED PLAN
General Comments
(Pages 1-3 of the letter)
The Army believes the public comment process for the On-Post Proposed Plan is a useful tool
that can help shape and define the terms to which the parties agreed in the Agreement for a
Conceptual Remedy for the Cleanup of the Rocky Mountain Arsenal (Conceptual Remedy). As
you may recall, previous to the Conceptual Remedy, the parties were at a standstill and heading
into litigation over the major differences seen as a basis for RMA remediation. The Conceptual
Remedy, with the help of the Lieutenant Governor and an experienced mediator, helped the
parties reach a conceptual agreement based on compromise without affecting the protectiveness
of the selected remedy.
The Army also believes that the public has provided valuable input to the remediation process at
RMA. As you are aware, the Conceptual Remedy does not contain specifics about the
remediation that will soon begin. The parties are working hard to resolve the questions that
remain, and the public input is important to that process. In addition, the Army has included more
public participation in the selection process than what is required under the Comprehensive
Environmental Response, Conservation and Liability Act (CERCLA) by encouraging any
interested party to participate in the review and selection process during the past years. Many
comments were reviewed and considered during the process. While no one will agree on every
aspect of the Record of Decision (ROD), the Army believes that, with the help of the Parties and
public, the selected remedy will be fully protective of human health and the environment.
The remediation process has been ongoing for more than 15 years and has included substantial
reductions in toxicity, especially in groundwater. The Basin F Interim Response Action (IRA)
treated more than 10 million gallons of highly contaminated liquids. In addition, the sludges and
soils in contact with the contaminated liquid have been contained in the Basin F wastepile, which
will be moved as part of the final remedy to an on-post, state-of-the-art, triple-lined cell(s) of the
hazardous waste landfill. While landfills do not detoxify contaminants, they do protect people and
the environment by cutting off exposure pathways.
The health effects on people and wildlife by many of the compounds produced at RMA have been
studied for many years, and this information is available at the Joint Administrative Record
Document Facility (JARDF). Studies have been completed by the Agency for Toxic Substances
and Disease Registry (ATSDR) independently and in conjunction with the Colorado Department
of Public Health and Environment (CDPHE). These studies showed no conclusive health impact
on the communities surrounding RMA. Also, the final Public Health Assessment, produced by
ATSDR, should be complete in the summer of 1996. The U.S. Fish and Wildlife Service
(USFWS) has stated in numerous meetings that although adverse impacts have been identified in
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wildlife within highly contaminated areas, the general population of wildlife is healthy based on
the studies completed thus far. Other studies are continuing at RMA to more fully assess
potential health impacts on wildlife.
A Medical Monitoring Program for the surrounding communities has been identified as part of the
On-Post ROD to measure health effects, if any, during the remediation process.
Shell has consistently supported the remediation process in many ways. They have participated in
many innovative studies (e.g., thermal desorption, enhanced soil vapor extraction, and air
sparging) and have been instrumental in providing data that would support or dismiss various
remediation technologies. Again, the Army reemphasizes that the Conceptual Remedy was not
the product of one party dictating its agenda to the other parties. The Conceptual Remedy was a
compromise for all parties involved in order to provide a fully protective, cost-effective, and
implementable remedy.
During the formulation and selection of the remedy, members of the public and some local
governmental organizations expressed keen interest in the creation of a Trust Fund, as you do in
your comment, to help ensure the long-term operation and maintenance of the remedy. The
Parties have committed to good-faith best efforts to establish such a Trust Fund, as described in
the ROD. Principal and interest from the Trust Fund would be used to cover the costs of long-
term operation and maintenance throughout the lifetime of the remedial program. These costs are
estimated to be approximately $5 million per year (in 1995 dollars).
The Parties intend that if the Trust Fund is created it will include a statement containing the
reasons for the creation of the Trust Fund, a time frame for establishing and funding the Trust
Fund, and an appropriate means to manage and disburse money from the Trust Fund. The Parties
are also examining possible options that may be adapted from trust funds involving federal funds
that exist at other remediation sites. The Parties recognize that establishing a Trust Fund may
require special congressional legislation and that there are restrictions on the actions federal
agencies can take with respect to such legislation. Because of the uncertainty of possible
legislative requirements and other options, the precise terms of the Trust Fund cannot now be
stated.
A Trust Fund group will be formed to develop a strategy to establish the Trust Fund. The
strategy group may include representatives of the Parties (subject to restrictions on federal agency
participation), local governments, affected communities, and other interested stakeholders and
will be convened with 90 days of the signing of the ROD.
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Specific Comments
1. One Operable Unit (OU1
The Army considers the definition of one On-Post OU the best approach to manage waste
from different sites at RMA and to use alternatives that are more efficiently implemented on a
large scale. There is no legal requirement to subdivide this site into more than one OU. The
Army has, however, treated some individual contaminated sites in the IRA program.
The Army has long recognized that successful environmental restoration projects require
input of interested community residents and has conducted more than 20 open houses and public
meetings to enable those interested to voice their concerns.
2. Basin F Wastepile
The Army has consistently tested the wastepile liner systems and found them to be in
excellent condition. The Army believes that the Basin F wastepile, in its present state, will be in
good operating condition at least until such time that it is moved to the new landfill. Although the
wastepile liner itself cannot be tested without potentially disturbing its integrity, an identical liner
system under Pond A, which was in constant contact with Basin F liquid for seven years, was
tested during its closure and was found to be in excellent condition. These data provide a strong
indication that the liner system will fully contain the waste as long as it is needed.
The temperature and process for drying, which is water evaporation, is very different from
the temperature required for destruction or desorption of pesticides. As has been explained in the
public meetings, thermal desorption or incineration processes operated at high temperatures
would be needed to vaporize and destroy the pesticides Additionally, pesticides have low vapor
pressure, very low water solubility, and are immobile; they consequently pose a low risk with
regard to migration and are good candidates for containment technologies.
3. Groundwater
In response to your comment about an alternative water supply, the Proposed Plan states
that the Army and Shell are committed to providing an additional 4,000 acre-feet of water to
South Adams County Water and Saltation District (SACWSD). The Army and Shell have
reached an Agreement in Principle, enclosed with these responses, with SACWSD that includes
payment of $48.8 million to SACWSD and requires that SACWSD water be supplied to
consenting drinking water well owners within the diisopropyl methylphosphonate (DIMP, an
RMA byproduct) plume footprint by January 1999 In addition, the Agreement in Principle
requires SACWSD to provide 4,000 acre-feet of water to Commerce City and the Henderson
Area by 2004. The parties involved in the water negotiations believe that the settlement is fair
and will permit SACWSD to secure an adequate water supply to satisfy Commerce City's and
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Henderson's water needs. If you have any questions regarding the water supply, please contact
Mr. Tim Kilgannon of this office at 303-289-0259 or Mr. Larry Ford of SACWSD at
303-288-2646.
4. Boundary Systems
The boundary systems are effective with respect to all currently identified contaminants.
DIMP and chloroform are treated at the RMA boundaries to levels below their respective
standards. Remediation goals have been established for chloride and sulfate in concert with
CDPHE and the U.S. Environmental Protection Agency (EPA). N-nitrosodimethylamine
(NDMA) is currently being monitored; if this program identifies an MDMA problem, potential
modifications required to achieve the remediation goals will be included in the remedial design.
5. Public Attendance at Meetings
The Army believes that it is not practical for members of the public to attend all technical
and day-to-day operations meetings regarding the RMA remediation. The Army has found that
smaller meetings can be more focused, where decisions and progress can be made more
efficiently. However, the relevant information generated in meetings between the Parties is shared
with the public in Restoration Advisory Board and Site-Specific Advisory Board meetings and via
newsletters and other means (e.g., the Internet).
6. Soil Treatment Limits
The excavation depths of 10 feet (5 feet in South Plants) and the excavation volumes
discussed in the Proposed Plan and incorporated into the ROD are based on the Remedial
Investigation (contaminant types and concentrations in soil), the Risk Assessment (exposure
pathways and risk-based contaminant limits), and the Feasibility Study (remediation criteria and
selection of remedial alternatives). The Army believes these depths and volumes are appropriate
in light of the extensive sampling that has been performed and the identified vertical distribution ot
contaminants.
7. Dioxin
Dioxin and furan sampling was undertaken by CDPHE, and the analytical results are
presently being evaluated by the Biological Advisory Subcommittee (BAS). Although The Arm\
believes that the currently identified contaminants of concern include all contaminants
representing the greatest potential for risk, other contaminants may become a concern in the
future (e.g., dioxin). In such an instance, the contaminant will be evaluated with respect to the
remedy selected, designed, or implemented to ensure that the remedy remains protective of human
health and the environment.
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8. Hex Pit
Subject to the results of treatability testing and technology evaluation, an innovative
thermal technology will be used to treat approximately 1,000 bank cubic yards (BCY) of principal
threat material from the Hex Pits. Solidification will become the selected remedy if evaluation
criteria for the innovative technology are not met. The remaining 2,300 BCY will be excavated
and disposed in the on-post hazardous waste landfill.
9. Emergency Plan
Emergency plans are typically part of the post-ROD remedial design activities. The
Panies and the public will be kept informed of contingency plans as they are written.
10. South Plants
The reason for the elimination of light, nonaqueous-phase liquid (LNAPL) treatment is
that the extractable volume of the plume was determined to be much less than had been expected.
Shell performed a pilot-scale study for removal of LNAPL over a 6-month period and was able to
remove only about 50 gallons of LNAPL. They concluded that the volume of extractable LNAPL
was much less than previously estimated and that efficient removal and treatment could not be
achieved at that extraction rate. It appears that a significant fraction of the LNAPL is contained in
the soil pores and is not mobile. Because the LNAPL is not highly mobile, it would not be
classified as a "principal threat." Because the LNAPL cannot be efficiently reversed, the preferred
remedy is to allow the ongoing natural attenuation to continue and to monitor the plume. The
remedy, accumulation of extractable volume, and potential extraction will be reevaluated as pan
of the 5-year site review.
Water levels at Lake Ladora and Lower Derby Lake will be maintained to support aquatic
ecosystems. The biological health of the ecosystems will continue to be monitored. Lake-level
maintenance or use of other means of hydraulic contaminant or plume control will be used to
prevent South Plants plumes from migrating into the lakes at concentrations exceeding Colorado
Basic Standards for Groundwater at the point of discharge Groundwater monitoring will be used
to demonstrate compliance.
There is no evidence of significant migration beyond the South Tank Farm Plume boundary at this
time. Migration of contaminants in this area is very slow due to the hydrogeological conditions.
and contaminants appear to be attenuated by natural processes, such as biodegradation, at the
edge of the plume. Samples from the deeper aquifer show no evidence of contamination. Plume
movement will be further reduced through construction of soil covers over South Plants, which
will result in continued lowering of the water table and reducing hydraulic gradients.
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The comparative analysis for the Lime Basins indicates that the landfill alternative is more cost-
effective than a solidification alternative. Disposal in the enhanced landfill is protective of human
health and the environment.
11. Letter had omitted #11.
12. Former Basin F
In situ solidification was identified as a representative process option for Former Basin F
during the Development and Screening of Alternatives. During the Detailed Analysis of
Alternatives (DAA), solidification formed part of a remedial alternative for that site and was
retained for further evaluation. During the early stages of the DAA, in situ thermal treatment (RF
heating) appeared promising as an in situ technology and was tested in pilot scale at the Former
Basin F site. The pilot-scale test could not demonstrate effective treatmerit of pesticides, so that
technology was removed from further consideration and was replaced by in situ solidification.
Solidification/stabilization is not considered an emerging or unproven technology by EPA. As of
the end of fiscal year 1993, both in situ and ex situ solidification had been selected in numerous
RODs nationwide, although solidification is not frequently used to treat organic contaminants.
Necessary testing will be performed prior to implementation of the in situ solidification treatment
technology to ensure that stabilization chemicals are compatible with the waste, that the products
are stable, and that treatability goals can be met. If the selected process is ineffective, an
alternative technology may be adopted through the ROD amendment process. In addition, during
the remedial design/remedial action process, contingency plans and public involvement will be
important.
13. Land Disposal Restrictions (LDRi
While it is true the Corrective Action Management Unit (CAMU) rule is currently being
challenged, the EPA supports the concept, and the State of Colorado in the Colorado Hazardous
Waste Management Act (CHWMA) has adopted it. EPA's goal in establishing the CAMU Rule
was to "provide remedial decision makers with an added measure of flexibility in order to
expedite and improve remedial decisions" while "existing closure regulations and requirements
for [Resource Conservation and Recovery Act] RCRA-regulated units, which require closure
to occur in a manner that is protective of human health and the environment, remain in effect."
Purpose and Context of the CAMU Rule, 58 Fed. Reg. 8654 (1993) (to be codified at 40
C.F.R. Parts 260, 264, 265, 268, 270, and 271). The on-site landfill that is central to the
CAMU will meet applicable CHWMA requirements.
The area of contamination (AOC) is a CERCLA concept that is used to determine
whether RCRA land disposal restrictions are applicable to CERCLA response actions. The use
of the AOC concept at RMA is appropriate based on applicable laws, regulations and site
conditions.
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14.
In addition to the human health exceedance sites that will be remediated (in which biota
sites will be remediated as well), large areas of low contamination level surficial soil were
identified for remediation, as shown in Figure 9.3-1 of the ROD. Additional areas of surficial
soil contamination known as the "Area of Dispute" (see Figure 6.2-6) are currently being
monitored to evaluate whether unacceptable levels of exposure (i.e., risk) exist for the "Area
of Dispute" shown on that figure. The monitoring and evaluation process detailed in the ROD
will continue ongoing efforts by the BAS to identify areas that may pose risk to biota and to
refine the areas to be remediated. The public will be kept informed about the Parties'
findings.
15. Trenches
The selected remedies for the Shell and Army Trenches were based on a combination of
criteria described in the DAA, including short-term risks during remediation and
implementability. The combination of RCRA-equivalent caps and slurry walls selected for
these sites will effectively interrupt exposure pathways and minimize infiltration of
precipitation through remaining contaminated material. The Army believes that these remedies
will prevent exposure to or migration of contamination and that they are protective of human
health and the environment over the short and long term.
16. Lake Sediments
Approximately 38,000 BCYof lake sediments will be removed and placed in either the
on-post hazardous waste landfill or Basin A Consolidation Area as part of the selected remedy.
This action addresses the potential human health and biota risks identified to date. The
USFWS will continue monitoring the lakes to evaluate the need for additional action.
Conclusion
Public meeting comments on the Steering and Policy Committee documents are
available at the JARDF. The only comments included as part of the On-Post ROD are
comments made by the Parties and public on the On-Post Proposed Plan. However, many of
the concerns raised during public meetings are contained within the Proposed Plan comments
and Responsiveness Summary of the ROD.
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
1
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WELL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
0*62969 CO* XVd 8S:CT ISJ 96/92/10
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AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. ""
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10-26/01/96
SOD® lasMnoo via «•-«• AIQ *vi HIANH AMV sn otezges coz ivj ss'ci IHJ se/az/io
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01/26/96 FRI 13:57 FAX 703 6962940
US ARMY ENVIR LAW DIV -»-.-. RMA COUNSEL
20'd "TWiOi
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Shirley Jantach
3544 pyanna Or.
Thornton, CO (0241
Thornton realdent
On-Poat Propeaed Plan Comaenta
Program Manager
locky Mountain Arsenal
AttaiAMCPM-PM/Col. Eugene H. llahop
•ullding 111 • «KA
Commerce City, CO 10022-1741
Dec. 13, 1»«S
Gentlemen,
X appreciate the opportunity to provide comment OB the
propoaed remediation of tha Araanal.
X faal tha Army and Shall ahould aegotiato vlth tha South
Adams County Witer and Sajtitatloa District and Hoadereoa
raaidaata to raaolve raplaeaaant vatar and dlatrlhution
llnaa laaoaa. Naithar Mr. Jamea Irgar of •oaderaon aor
Mr. tarry ford of tha vatar dlatriet appaarad aatiefiad vlth
tha Army and Shall 'a plaa at tha RKA Pahlle Keating oa
Nov. ISth. Peoples vhoae llvea aad livelihoods ara affected
should have a aaat at tha table vhera deeialoaa Mutually
agreeable to all should ha negotiated.
X aupport the eetabliahmaat of a Medical Monitoring Program
and a Medical Monitoring Advlaory Creep aa described oa
pagea 11 aad 1) of tha Propoaed Plaa for the IHA Oa-Poet
Operable Unit. Xt ahould he a timeline priority that thla
program and group be fully operational and adequately
ataffed before remedial activities begin. They ahould have
reasonable advance notification of all remedial procedures
ao they can evaluate possible rlaka aad make
recommendations. Tha public ahould ha alloved to have
acceaa to information on laauea diacueaed, recommendationa
•ade, aad vether or act thoae racosmeadatloaa vere actod
upon. Thla Information ahoald be tiawly and aaaily *
accessible. People have a right to be assured their health
la being givoa top priority la reajadiatioa Mtauraa. '
Because of the eoajplexity aad scale of remediation at IMA,
I'd prefer a revlav every three yeara rather than every
five. The cycle ahould be tied to the anaouace»ent of the
•00. further, every three yeara the ROD vould be reviewed la
its entirety. AT the Oec. 7th IAS, I believe it vaa
auggeated that aa a particular aspect vaa remediated, ita five
year reviev cycle vould begin. This kind of piecesieal
revlev cycle vould aake it extreaely difficult for the
public to keep updated aad involved. X alae believe the
public's perception of vhat vaa awaat by a five year revie*
process is that the vhole remediation plaa is revisited
ovary five years.
Per me, confidence fa preferred remedlatioa proposals is
strongly tied to the ataadarda thoae proposals chose or vere
impelled to meet. The higher the ataadarda. the stricter
the requirement a. the greater the confidence X have ia the
process. Without the peraoaal technical expertise, X rely
oa my local government to repreaeat ay concerns ia these
issues. Therefore, X support staadarda aettiag sad
reatrlctioaa by atats aad county governments as those being
ia my best iatereats.
Thank you for conaiderlog these eoamwata,
•espectfully/
Shirley Mf Jentsch ft
»U!404-1/1
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER TOR ROOKY MOl'STAIN AR^KNAI.
COMMERCE CITY. COLOR APO s^o::-: n<
June 11, 1996
REPLY TO
ATTENTION OF-
Office of the Program Manager
Ms. Shirley M. Jentsch
3544DyannaDr.
Thornton, Colorado 80241
Dear Ms. Jentsch:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
The Army and Shell Oil Company (Shell) successfully negotiated with South Adams
County Water and Sanitation District (SACWSD) to arrive at an Agreement in Principle. This
agreement, enclosed with this letter, includes payment of $48.8 million to SACWSD and requires
that SACWSD provide the water to consenting drinking water well owners within the diisopropyl
methylphosphonate (DIMP, an RMA byproduct) plume footprint by January 1999. In addition,
the Agreement in Principle requires SACWSD to provide 4,000 acre-feet of water to Commerce
City and the Henderson area by 2004. The parties involved in the water negotiations believe that
the settlement is fair and will permit SACWSD to secure an adequate water supply to satisfy
Commerce City's and Henderson's water needs. If you have any further questions regarding the
water supply, please contact Mr. Tim Kilgannon of this office at 303-289-0259 or Mr. Larry Ford
of SACWSD at 303-288-2646.
The health effects on humans and wildlife to many of the compounds produced at RMA
have been studied for many years, and this information is available at the Joint Administrative
Record Document Facility (JARDF). Studies have been completed by the Agency for Toxic
Substances and Disease Registry (ATSDR) independently and in conjunction with the Colorado
Department of Public Health and Environment (CDPHE). These studies showed no conclusive
health impact on the communities surrounding RMA. The final Public Health Assessment,
produced by ATSDR, will be complete in the summer of 1996. The U.S. Fish and Wildlife
Service (USFWS) has stated in numerous meetings that although adverse impacts have been
identified in wildlife within highly contaminated areas, the general population of wildlife is healthy
based on the studies completed thus far. Also, other studies are continuing at RMA to more fully
assess any health potential impacts on wildlife.
A Medical Monitoring Program for the surrounding communities has also been identified as part
of the Proposed Plan to measure health effects, if any, during the remediation. The primary goals
of the Medical Monitoring Program are to monitor any off-post impact on human due to
Readiness is our Profession
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-2-
health the RMA remediation. This Program will continue until the soil remediation is completed.
A Medical Monitoring Advisory Group has been established to evaluate specific issues covered by
the Medical Monitoring Program. The Group is composed of representatives of the Army, Shell,
the U.S. Environmental Protection Agency (EPA), CDPHE, Tri-County Health Department,
ATSDR, the USFWS, Denver Health and Hospitals, and the Site-Specific Advisory Board. The
Group also includes community representatives from the cities of Commerce City, Henderson,
Denver, Montbello, and Green Valley Ranch. If you would like more information on the Medical
Monitoring Program or wish to participate as part of the Medical Monitoring Advisory Group,
please call Ms. Mary Seawell of the CDPHE at 303-692-3327.
Five-year site reviews are intended to evaluate whether the response action remains
protective of humans and the environment. Statutory five year reviews are required no less often
than each five years after the initiation of remedial action. The Army appreciates your comment
that a piecemeal review process would be undesirable. The Army intends each periodic review to
be performed on the site remedy as a whole.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Euger/e H. Bishop
Colonel, U.S. Army
Program Manager
Enclosure
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZAT1ON OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SDC MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WELL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
COZ Tfd 95 = 61 HU 96/B2/TO
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AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. •""
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
O. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
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State of Colorado **»*«,*
79S1 York #3 rV»n\/f3»r A|ricufcwe, Natural
Oem«r,a*x*do 80229 UCnVer toouree* md Ene^y
Captol: 8664865 ApprepriaUo*
Hame^W-9237 Capital Development
^•>"** Slate, Veterans and
Military Affairj
January 17, 1995
On-Poot Proposed Plan Comments
Program Manager
Rocky Mountain Arsenal
Attn: AMCPM-PM/
Col. Bishop
Building 111-RMA
Commerce City, CO 80022-1748
Dear Col. Bishop:
The proposed draft Record of Decision for clean-up activities at'
the Rocky Mountain Arsenal proposes on site disposal of non-
hazardous waste, without the normal facility construction
requirements, such as liners, etc., for such waste disposal.
Additionally, the Record of Decision fails to specifically
include a commitment to follow the normal process required for
the siting of a non-hazardous waste landfill facility.
While it is understandable that off site disposal of hazardous
waste material is probably not feasible for political, cost and
practical reasons, why would any non-hazardous waste material be
left on site without fully complying with all normal landfill
design and construction requirements? As there are reasonable
off site alternatives, this material should be disposed off site,
if possible.
If non-hatardous waste material is to be disposed of on site,
then it should either be placed in the hazardous waste landfill
facility that will be constructed on site, or in a separate non-
hazardous waste on site facility permitted in accordance with the
Solid Haste Act requirements of the State of Colorado.
The requirements of ouch an on site non-hazardous waste facility
should not be less than would be required for all other
facilities in Colorado. This includes the required public
notice, hearings, etc., by Adams County, the affected local
government.
9601817-1/1
-------
At a minimum, the Record of Decision should include the
commitment to study the relative comparative costs and benefits
of on site versus off site disposal. This study should include
allowing the public to fully participate in the making of the on
site versus off site decision and should be completed prior to
any decision being made in this area.
Thank you for your consideration.
Sincerely/
loan M. Johnson
State Senator
-------
DEPARTMENT OF THE ARMY
PKOuRAM MANAGER IV-K RiVlO MOl NTA1X ARSENAL
June 11, 1996
REPLY TO
ATTENTION OF:
Office of the Program Manager
The Honorable Joan Johnson
State Senator
7951 York #3
Denver, Colorado 80229
Dear Senator Johnson:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is a important component of the remediation process, and your participation in
the process helps maintain the dialogue between the U.S. Army and the public.
Your letter proposes either offsite disposal of nonhazardous materials or construction of
an on-site, nonhazardous waste facility in compliance with the Resource Conservation and
Recovery Act. The Army understands your concern that this material be disposal properly and
believes that the approach of placing the material under the Basin A cover will adequately
immobilize any contaminants and provide a cost-effective method for disposal of nonhazardous
materials. In addition, a large volume of fill material will be required to construct the Basin A
Consolidation Area, and the RMA nonhazardous material will satisfy that need. Furthermore, by-
using this nonhazardous material onsite, there will be no negative impact from a very large
number of trucks moving through the surrounding community. Cost for fill material is also
minimized. Therefore, the Army chose to keep the nonhazardous material onsite to be used as fill
material for the Basin A Consolidation Area.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely.
Eugent H Bishop
Colonel. U S Army
Program Manager
Readiness is our Profession
-------
-2-
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
-------
AtehoNorth
Chamber of Commerce
11990 N. Grant Street Ste. 210
Denver. Colorado 60233-1122
(303) 4504335
Fax 450-2610
1995 Board
of Directors
Diane Schmidt
Botfi Char
Steve Cramer t
AMooatti. LUC
Mel Cozzens
Mrt
Front Range
Cemnunty Cettge
Scott Lusk
Grttnbtr Corp.
Dave Dunned
PittChmr
Untted Power, me.
Wan CoughHn
Couoren*Co..hc.
Steve Cramer
Steva Cramart
Aaeoeiatea. LLC
Sherry Dlnkel
Century 21 • OWcel
« Aeaodate*. Inc.
Jerry W.Engfich
JenyW.En0fi.lTD-
Fannert Ineuranee
joeFuMon
Newel RocycMng of
Denver. Inc.
Martyn Glade
O«v*Oodln
UoWbTcxM
OebHavltond
PreveneM
SI Antfiony Hotprtil
North
Neney Judty
Attorney et Law
Walraven
KetelUpper
Oral Kilter
KartowLeeper
InAVC iNtfllOftfRVfl
elCotondo
Chart** MdUy
Church Ranch 4
Home Meea. he.
KtMeen Novak
Reiand KIHMI
UnNad Power, be.
noytf Sau
MofwertBank,
NorthQfenn
Sucan Sgrignoll
"NorthglennMal
Mtrcnanto Aaaoe.
Mart Walker
CommunlyFinl
NatfonaJBank
Sk**tr Wilson
R&MAX
Inc.
ROCKY MOUNTAIN ARSENAL WATER SUPPLY
RESOLUTION
BE IT RESOLVED that the Board of Directors of the MetroNorth Chamber of
Commerce hereby supports the efforts of the Northern Community Coalition, the
South Adams County Water and Sanitation District and the community of Henderson,
Colorado, in their efforts to secure adequate water supplies.
The water supplies should not be limited to the 4,000 acre feet identified in the
Conceptual Agreement for cleanup of the Rocky Mountain Arsenal. Rather, the
supplies should be of high quality, and adequate quantity to address the contamination
problems of both the South Adams County Water and Sanitation District and the
affected community of Henderson.
The parties and affected communities should agree upon an acceptable amount of
water. That agreement should not be delayed but should be resolved and included in
the final decision on the Arsenal cleanup.
PASSED and adopted this 22nd day of November, 1995.
Signed.
Diane J. Sdfiudt, Chair of the Beard
9533301
-------
DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROTKV MOI 'MAIN ARSI-:S-\1.
VOMMtRiT UTV. COLORADO NY:y,74-<
June 11, 1996
REPLY TO
ATTENTION OF
Office of the Program Manager
Ms. Diane J. Schmidt
MetroNorth Chamber of Commerce
11990N. Grant St., Suite 21 8
Denver, Colorado 80233-1 122
Dear Ms. Schmidt:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
The Army believes that an adequate amount of high-quality water will be provided to the
affected communities. The Army and Shell Oil Company have reached an Agreement in Principle,
enclosed with this letter, with the South Adams County Water and Sanitation District (SACWSD)
that includes payment of $48.8 million to SACWSD and requires SACWSD to supply water to
consenting drinking water well owners within the diisopropyl methylphosphonate (DIMP, an
RMA byproduct) plume footprint by January 1999. In addition, the Agreement in Principle
requires SACWSD to provide 4,000 acre-feet of water to Commerce City and the Henderson area
by 2004. The parties involved in the water negotiations believe that the settlement is fair and will
permit SACWSD to secure an adequate water supply to satisfy Commerce City's and Henderson's
water needs. If you have any further questions regarding the water supply, please contact
Mr. Tim Kilgannon of this office at 303-289-0259 or Mr. Larry Ford of SACWSD at
303-288-2646.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
<^—M
H Bishop
tugene H Bishop
Colonel. US. Army
Program Manager
Enclosure
Readiness is our Profession
-------
-2-
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
-------
AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
zoo® lasNnoo VRH -~ Aia MVI MIANH AIHV sn otezHs ecu XVH >S:CT IHJ sem/io
-------
WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
coo®
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0»6Z969 COi IVJ SS'CT IHd 96/9Z/TO
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WELL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
«V1 HIANH MHV sn „
9S=CT ISU 96/92/10
-------
AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. -"
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10-26/01/96
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01/26/96 FRI 13:57 FAX 703 6962940
US ARMY ENVIR LAW DIV
*-»-» RMA COUNSEL
2l 006
20'd "W10JL
»m|»a Wins J»I«M 1»UIO
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Q
Dan Mulqueen
1422 S. York
Denver CO 80210 January 18,1996
Proposed Plan Comments
Program Manager for Rocky Mountain Arsenal
Aim: Col. Bishop
Bidding 111-Rma
Commerce City, CO 80022-2180
CoL Bishop,
Thank you for the opportunity to comment on the Onsite Plan. The amount of
time allowed for Public Comment is not adequate to fuDy express my concerns and
questions regarding the Flan as presented, but due to the Army1! reluctance to further
extend this period, my comments are submitted on dns date.
In die interest of conservation and economy, I request mat aD of your documents
be printed on both sides. Recently, the Army distributed die Off-Poet ROD in dns format,
but die majority of information for pubfic review remains one sided and k bulky and
wasteful
I object to me preeminent role of Shell Ofl Company in die decision making at die
Arsenal. SheD's reputation and continuing world wide activities are weD documented, and
Army deference to Shell and their position are an embarrassment The Federal Facilities
Agreement was the appropriate venue to protect the taxpayer, when financial liabilities
were established, not at die point of clean-up. I object diat in many instances dns FFA is
relied upon to excuse compliance with NCP, CERCLA, and other laws in which the
citizens seek protection,
The influence of dns 20% payer on issues such as die cost of innovative treatment
on a minute area ( Hex Pits) has apparently caused die Army to back off on your pledge to
the dtizema* pan of dw Agreement on n^Q»<:epnu] Remedy. I would also Eke an
explanation for why Shell has not signed d»e Off-Post ROD. I object to die fact dot
citizens concerned for dieir communities and die environmental legacy passed to tite
children, must so often struggle against Shell, dieir contractors, lobbyists and lawyers, to
have our voices heard at die Army's table.
I object to me adherence to die Agreement on me Conceptual Remedy as a Pre-
selection of Remedy, proscribed by Congress in 42 USC 9617. As a particqunt
Stakeholder in die S APC negotiations, I do not befieve citizen concerns were included in
dte Agreement except peripherally, and diat die Parties signatory may not make every
effort to enforce die components of greatest concern to dte citizens, specifically:
components 10 D, 17,18 [Water must be provided, not simpry a piping iystera], 19,24[to
include Dioxins and Furans], 25 [ MDMA detection levels are too high, (reporting levels
must be below human health exceedence and are known to be commerciah/ available from
Southwest in San Antonio, Texas)], 27[ include Dioxins and Furans especially m die
USFWS biomonitoring programs and SFS/risk assessment process], and 28[ to add
DIMP].
9602206-1/1
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pagc2
Citizen concerns expressed prior to but not addressed in this Agreement include:
Dioxin and Furan sampling, preference for on-she treatment and applications of innovative
and leading edge technologies, the cessation of public tours promoting the Refuge until
remediation is complete, in-siru treatment of the South Plans Tank Farm Plume, and an
emergency plan for the nearby communities more comprehensive man reliance on die
"buffcr"zone. Hive these concern been documented and where? Win these concerns as
presented in the SAPC process be addressed and how?
The Agreement is incomplete in mat it does not contain a Inter-Agency Agreement
with die State of Colorado. If this Document is to follow, die citizens would request
notification as well as die opportunity to provide dieir concerns and comments during the
formation of such an agreement We understand nut this is a vital tool for keeping die
project on track as wen as maintaining accountability and generating public trust.
While aU citizens support me provision of replacement water to residents affected
by Arsenal contamination, I strongly object to die fact that citizen demands for treatment
of wastes has been traded for this water. I refer specifically to statements contained in the
transcript of me PubUc Meeting, Nov. 18,199S, by Larry Ford and omen, dut less clean-
up was accepted in exchange for an immediate source of pristine water. Based on this, if
me replacement water is not acceptable to die community does die decision on
remediation become reopened? These issues should be addressed in terms of Federal
policies and guidances pertaining to Environmental Justice, and Certification of Adherence
to these principals should be provided by each Federal Party.
I object to die use of die State CAMU authorization to sidestep RCRA Land
Disposal Restrictions. We know dvat die EPA is now in die process of ending that
Regulation effective carry in 1997, and that die state CAMU win be less stringent and thus
inappropriate then. To die public this seems to be die single driving force behind die
insistence to sign die ROD during die summer of this year.
I object to die designation of die entire contaminated area of die Arsenal as a single
AOC for purposes of application of LDRs. tt is a stretch of die imagination dut die area
described is "contiguous " or 'discreet', when diere is endless variety in contaminants, dieir
sources, and large areas of non- contaminated toil between diem. Your designation
ignores EPA guidance contained in die Superfund LDR Guide 5, as weU as OSWER
Directive 9347J-08FS, which states tiiat landfill siting must be protective of groundwater.
The Basin A area, m which you plan to heap principal dntat wastes, has a depdi to
groundwater of 0 feet in places.
Whfle die De- Watering scheme may work here, it is speculative and requires a
contingency plan to be included due to me unproven nature of tiiis action as a permanent
remedy. A contingency plan must also be developed in regards to me Hydraufic
Containment of die South Plant Plumes [keeping die lakes fuO]. This proposal is unproved
and speculative and should not go forward as a stand alone permanent remedy alternative
to treatment m this case bodi extraction and bioremidiation have been proposed in past
plans for die South Plant Plumes, and been determined feasible. The ROD should contain
these contingencies.
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page3
b it the Amy's intent to use the CAMU and/or AOC designations to avoid
sampling and characterization of wastes prior to moving soils and structures? If this is the
case, conflicts seem to occur with Worker Safety ARARS {29 CFR 191CU20[b] to [)],
and others}, at wen as with Land Use/Deed Restrictions^ CFR 264.119 and 6CCR
1007-3, section 264.119} which requires exactly these types of characterizations.
Although we may have traded off tteatment of wastes at die Arsenal, it was never mtended
that sampling would not occur, ft was our understanding out this sampling would be
complete and comprehensive, including quantification and characterization of all detected
compounds and elements .whether on the COC list, or not This action is very important
to the future generations who win assume the burden we wffl have left buried, as dearly
stated in the Principals for Environmental Cleanup of Federal Facilities [EPA].
The Structures Volume VI Report shows mat not all buildings have been sampled
and that often sampling was not complete for aH contaminates. This report does not
depict the levels of specific contaminates found, sampled for, methods, or detection levels.
This makes the information incomplete and mostly unusable as the basis for comment
The selection of sites and tests appears haphazard, for example, administration
and infirmary areas were sampled relatively extensively while some process areas,
warehouses and loading areas show no sampling whatsoever. Please explain this and the
fact that the structures inventory does not agree at an times with the structures figures and
maps provided in mis volume. For example, structure 311, does not appear on maps.
Further mis building served as a storage area for ShcD and has been rumored to have held
"secret" projects and drums of 2.4.D. The sampling of mis structure revealed
contamination which fends credence to these stories, but there seems to be no foDow
through.
Again sampling and screening must be for afl anaMes not just for those targeted,
because of the gaps in the historical record and the high fikefihood of the existence of
previously unknown tad/or unexpected contaminants. Complete sampling should enhance
the design parameters, thus increase confidence in the permanence of the remedy.
Afl no-action sites which were characterized using detection Srnhi higher (nan
action level need to be re-characterized using appropriate detection fimhs before these sites
or bufldmgs are excluded from clean up. This is particularly m regard to: Dioxins and
Furans, MDMA, Dieldren[.002ppb] and elemental and agent compounds. Given the
history of Clorine Plant wastes introduced into First Creek, via the Sand Creek Lateral,
and it being widely accepted that this activity spawn Dioxins when graphite electrodes are
used, soils and sediments associated with SCL and First Creek must be sampled for these
compounds and appropriate remediation instituted.
Over the past several yean many citizens have requested information about ,and
•ampKngfor, Dioxins and Furans on the Arsenal These requests have been rebuffed until
mis summer when the State agreed to send some archival soil and animal tissues for testing.
The results are positive and confirm citizen concern regarding the presence of these
dangerous chemicals on the Arsenal A separate Operable Unit must be performed to
include these and other missed or inadequately characterized contaminants.
-------
I object to the use of Land Use Restriction to close pathways of exposure on the
Arsenal This is contrary to mandate in the NCP which states that institutional controls
shall not substitute for active response measures as the sole remedy, unless such active
measures are determined to be not practicable. Under die Flan » unfitted Basin A win
receive additional quantities of principal threat and the ground water impacted is considered
for some pump and treat , but pathway abagiaMft 0£empjished with a prohibition on
the use of this water for potable use* JMr W0 tatJ^Jk^^osoK by inhalation of
vapors, or biota exposure ftpfR ^QuafitMni £Mft)nii*tj|L /
Also the NCP HfWtt &e%se of 10-6 as the pointoM£«fmr^J|UEPA
guidance has ewoM&n mis requirement based on land uses as a wildlife rcfuf^sftapomt
of departure oow is functionally 10-4. If mis questionable interpretation B chaflengSjTlr
overturned subsequenny[as the CAMU regulation is being now] the entire arsenal wfll havt
to be remidiated.
The danger of miserly characterization and discounting generally held standards is
that in time the ultimate costs wfll far outweigh the short term savings. Levels of
remediation are lessened due to the Refuge designation, If cleanup is not adequate to
support wildlife at very low cost, the Refuge fails and that land use becomes defunct
Under the law, non-productive Refuges may be transferred for development, and
development pressure for this area is certainly going to be great At that point a future
generation wfll grapple with the decision to complete the cleanup or to assume the risks.
The polluter's only hedge in mis scenario is to hope for the highest degree of natural
attenuation. This is an unacceptable position for the Army given the pubfic trust and your
announced commitment to "Cleanup* the Rocky Mountain Arsenal Further mere will be
fittie attenuation of elemental contaminants such as mercury, arsenic, or asbestos, and any
degradation of the significant quantity of organics wfll be at least matched by the
recombination into other dangerous and exotic compounds.
I object to the Army's failure to include the following Colorado Laws as ARARS:
The State Wildlife Act, CR.S.33-1-101 to 33-1-121; Wildlife Enforcement and Penalties
Provisions, C.R.S. 33-6-101 to 33-6-130; and Wildlife Commissicu Regulations, 2 CCR
406-0 & 406-8. Because some Army decisions and actions may result in me tiffing or
wounding of Cokndo game and non-game animals, the Army should be accountable and
adhere to the laws and penalties of the State wflfingh/.
I finalry most object to the plan for three areas which bring the mapMtiuU of the
problems mto brutal focus. These are; The Shell Trenches, The Complex Trenches, and
The Central Processing Unit AH three areas contain extremely dangerous contamination
that may or may not be fuDy characterized, and which wfll remain in place and untreated
forever, under mis plan. Even assuming mere wfll be no further spread into the
environment and no exposure results, it is very discouraging that mis is me best solution we
might achieve here. I would hope that the Army and other parlies wfll reflect on the
explanation to be offered to future generations as to why this was the very best we could
do here. I know that no justification for this legacy has been presented for future
generations but I feel strongly mat this should be clearly and prominently presented within
theFmal ROD.
CVJL- _
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER I:OR ROi'KY MOl 'STAIN ARSENAL
i.:OMMERrn CITY. COLORADO -W::.: 74S
June 11, 1996
REPLY TO
ATTENTION OF:
Office of the Program Manager
Mr. Daniel Mulqueen
1422 S. York
Denver, Colorado 80210
Dear Mr. Mulqueen:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the Army and the public.
Responses to your specific comments are provided in the enclosure.
If you have any additional questions or .concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Eugenit H. Bishop
Colonel, U.S. Army
Program Manager
Enclosures
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City. Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
Readiness is our Profession
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RESPONSES TO COMMENTS BY MR. DANIEL MULQUEEN
ON THE ROCKY MOUNTAIN ARSENAL ON-POST PROPOSED PLAN
For ease of comparing this response to your letter, the following responses reference the
applicable page and paragraph number of your letter.
Page 1, first paragraph: The Army extended the public comment period by 30 days in an
attempt to balance the concerns of those who wanted more time to comment and those who
wanted no more delays to the Record of Decision (ROD).
Page 1, second paragraph: As you noted with the two-sided page format of the Off-Post ROD,
the Army is also interested in conservation and economy and will publish the On-Post ROD in the
same format.
Page 1, third paragraph: Shell Oil Company's (Shell) role in the RMA remediation, technically
and financially, has been determined through the Army/Shell Settlement Agreement as well as the
RMA Federal Facility Agreement (FFA), which are both binding legal agreements and which are
both consistent with the Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). Shell has consistently supported the remediation process in many ways. They have
participated in many innovative studies (e.g., thermal desorption, enhanced soil vapor extraction,
air sparging) and have been instrumental in providing data that would support or dismiss a
particular remediation technology. The Army believes that Shell's technical expertise has been a
valuable asset to the On-Post Remedial Investigation/Feasibility Study (RJ/FS) process.
Page I, fourth paragraph, first sentence: The Army is committed to the remedy outlined in the
Agreement for a Conceptual Remedy for the Cleanup of the Rocky Mountain Arsenal
(Conceptual Agreement). Subject to the results of treatability testing and technology evaluation.
the Parties have agreed that 1,000 bank cubic yards (BCY) of principal threat material from the
Hex Pit will be treated by an innovative thermal technology The remaining 2,300 BCY of
principal threat material will be excavated and disposed in the on-post hazardous waste landfill.
Solidification will become the selected remedy if evaluation criteria for the innovative thermal
technology are not met.
Page I, fourth paragraph, second sentence: Shell has not signed the Off-Post ROD for two
reasons. First, the Army is the lead agency and has the responsibility to carry out the remedy
agreed upon in the ROD. It is not necessary for Shell to sign the ROD as a responsible party to
the remediation. Second, Shell is bound by the Army/Shell Settlement Agreement and the FFA,
as described above, and those legal documents provide the requirements Shell must meet.
Page 1, last paragraph: The Army is interested in public comments and concerns and has made
substantial effort to hear those concerns through the Restoration Advisory Board, the Site-
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Specific Advisory Board, and stakeholder meetings, and also through avenues of public comment
such as the comments on the On-Post Proposed Plan. The Army has conducted more than 20
open houses and public meetings to enable those interested to voice their concerns. The public
expressed concerns about many innovative technologies during the public process. Many
participants preferred proven technologies and minimal disturbance of the site; however, some
participants indicated preference for innovative technologies.
In response to your comment about an alternative water supply, the Army and Shell have reached
an Agreement in Principle, enclosed with these responses, with South Adams County Water and
Sanitation District (SACWSD) that requires that SACWSD supply water to consenting drinking
water well owners within the diisopropyl methylphosphonate (DEMP, an RMA byproduct) plume
footprint by January 1999. In addition, the Agreement in Principle requires SACWSD to provide
4,000 acre-feet of water to Commerce City and the Henderson area by 2004. The Army hopes
that the community will work with SACWSD in obtaining an acceptable w,ater supply. The
parties involved in the water negotiations believe that the settlement is fair and will permit
SACWSD to secure an adequate water supply to satisfy Commerce City's and Henderson's water
needs. If you have any further questions regarding the water supply, please contact Mr. Tim
Kilgannon of this office at 303-289-0259 or Mr. Larry Ford of SACWSD at 303-288-2646.
N-nitrosodimethylamine (NDMA) studies are underway, and lowering the analytical detection
limit is required by the Conceptual Agreement, which was signed June 13, 1995. The Army
continues to work with its laboratory on the NDMA issue. Dioxin and furan sampling was
undertaken by the Colorado Department of Public Health and Environment (CDPHE), and these
results are currently being evaluated by the Biological Advisory Subcommittee (BAS).
Page 2, first paragraph: Please see the response to Page 1, last paragraph regarding dioxin
and furan sampling. Public concerns were definitely considered in the development of
alternatives. The concerns about the short-term impacts of excavation and treatment were
evaluated against the potential long-term effects of containing the waste in place. There also was
significant public concern about thermal processes such as incineration because of potential
emissions. The Army believes the most protective remedy is one that minimizes the short-term
risks of exposure to workers and the community because soil-borne contaminants are left in place
and not excavated and exposed to the environment.
RMA tours will continue during the cleanup process, but will not be conducted in affected areas
The safety of visitors will be ensured through limited access and monitoring.
The Army assumes your comment regarding in situ treatment of the South Tank Farm Plume is a
request for treatment. There is no evidence of significant migration of the South Tank Farm
Plume beyond its plume boundaries. Migration of contaminants in this area is extremely slow dm-
to the hydrogeological conditions, and contaminants appear to be attenuated by natural processes
including biodegradation, at the edge of the plume. Samples from the deeper aquifer show no
evidence of contamination. Plume movement will be reduced further by covering the South Plants
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area, which will result in lowering of the water table and reducing hydraulic gradients. Continued
plume monitoring will provide design refinement/design characterization support for the final
remedy.
An emergency plan is typically part of the post-ROD remedial activities. The Parties and the
public will be kept informed of contingency plans as they are written.
Page 2, second paragraph: The Army believes the public comment process for the On-Post
Proposed Plan is a useful tool that can help shape and define the details of the Conceptual
Agreement. As you may recall, prior to signing the Conceptual Agreement, the Parties were at a
standstill and heading toward litigation over the major differences seen as a basis for remediation
of RMA. The Conceptual Agreement, with the help of the Colorado Lieutenant Governor and an
experienced mediator, helped the Parties reach an agreement based on compromise without
affecting the protectiveness of the selected remedy. An interagency agreement was not necessary
because the state was a signatory to the Conceptual Agreement.
The Army also believes that the public has provided valuable input to the selection of a remedy
for RMA. As you are aware, the Conceptual Agreement does not contain specifics about the
remediation that will soon begin. The Parties are working hard to resolve the many questions that
remain, and the public has an important role in that process. In addition, the Army has included
more public participation in the selection process than what is required under CERCLA by
encouraging everyone to participate in the review and selection process during the past years.
Many public comments were reviewed and considered during the process. While no one will
agree on every aspect of the Conceptual Agreement, the Army believes that, with the help of the
Parties and the public, the remedy will be fully protective of human health and the environment.
Page 2, third paragraph: The Army believes the supplemental water supply will be an extra
layer of protection to people north of RMA in the unlikely event that all the caps, liners, and
multiple groundwater treatment systems were to fail. In addition, many citizens were opposed to
the treatment technologies that were proven to treat the multi-faceted wastes in some areas on
RMA. The Army believes the selected remedy is fully protective of human health and the
environment. The Army believes the selected remedy, including the provision of a water source,
is consistent with the policies and guidelines pertaining to environmental justice.
Page 2, fourth paragraph: U.S. Environmental Protection Agency (EPA) goal in establishing the
Corrective Action Management Unit (CAMU) Rule, which was adopted by the State of Colorado
in the Colorado Hazardous Waste Management Act (CHWMA), was to "provide remedial
decision makers with an added measure of flexibility in order to expedite and improve remedial
decisions" while "existing closure regulations and requirements for [Resource Conservation and
Recovery Act] RCRA-regulated units, which require closure to occur in a manner that is
protective of human health and the environment, remain in effect." Purpose and Context of the
CAMU Rule, 58 Fed. Reg. 8659 (1993) (to be codified at 40 C.F.R. Parts 260, 264, 265, 268,
270, and 271). The onsite landfill that is central to the CAMU will meet applicable CHWMA
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landfill siting, construction, monitoring and closure requirements. The area of contamination
(AOC) is a CERCLA concept that is used to determine whether RCRA land disposal restrictions
(LDR) are applicable to a CERCLA response action.
Page 2, fifth paragraph: The extent of the AOC at RMA was based on the boundary of the area
within which EPA estimated there might be some risk to biota, primarily due to the presence of
dieldrin in surface soils in a contiguous area. The on-post hazardous waste landfill was sited
according to CHWMA criteria, as described in the CAMU Designation Document and its
appendices. Basin A will not receive soil defined as principal threat soil or human health
exceedance soil; it will only receive soil with contaminant levels below human health criteria and
structural demolition debris to be used as fill.
Page 2, last paragraph: The Army assumes that your comment about dewatering refers to the
passive dewatering of the South Plants Central Processing Area and Basin,A after soil covers are
constructed at those locations. Groundwater monitoring will continue in order to evaluate the
effectiveness of the selected remedy, including the capping and passive dewatering. Studies are
currently ongoing to address potential needs for additional action in the lakes area. It should be
noted that contaminants in the two areas are different. Please see also the response to your
comment on Page 2, first paragraph.
Page 3, first paragraph: The soil, water, structures, air, and biota have been extensively
sampled at RMA during the course of the RI/FS and have been sufficiently characterized to
implement the selected remedy. Additional contingency sampling is part of the selected remedy
and will be used if needed.
Page 3, second and third paragraphs: Representative structures were selected for sampling
and analysis to represent the worst case conditions. Section 2.4 of the Structures Volume of the
Detailed Analysis of Alternatives (DAA) provides a summary of structure material sampling and
references other documents for further detail. Historical data on structure use is sufficient to
classify individual structures according to past use and potential future use. Analytical results
from structure material sampling indicate low concentrations of contaminants and support the
conclusion that structure contamination does not pose a hazard to human health or the
environment. Major and minor structures are represented on the DAA plates, including Building
311, which appears on Plate 1.2-1 in Section 2 of the South Plants insert. Building 311 began
service as a cafeteria, and was later used for storage of soil cores. Samples taken in and around
the structure do not indicate the presence of significant levels of contamination. The preferred
alternative for this structure is demolition and disposal in the Basin A Consolidation Area.
Page 3, fourth through sixth paragraphs: The current list of structures analytes is derived from
the Remedial Investigation/Feasibility Study (RI/FS), which included a much longer list of
analytes. The fact that detection limits change during a program as extensive as RMA's is
unavoidable. The Army recognizes that some of the risk-based remediation goals are below
analytical detection limits. This fact is not unique to RMA, and that is why the term Practical
-------
Quantitation Limit (PQL) has been established. A PQL is used as the remediation goal until the
risk-based standard can be achieved by a laboratory. As stated in the response to your comment
at Page 1, last paragraph, programs are ongoing to evaluate NDMA, dioxin, and furan at RMA.
In the event other contaminants not included as contaminants of concern are identified as a
concern (e.g., dioxin) during or after design or implementation, an evaluation will be conducted as
required by CERCLA guidance (OSWER Directive 9355.3-02) to ensure that the remedial action
is protective of human health and the environment. At a minimum, evaluations will be part of the
5-year site review. There is no scientific support for your claim that dioxins were generated by
the processes at the Chlorine Plant and subsequently introduced into the Sand Creek Lateral and
First Creek.
Page 4, first paragraph: Institutional controls will not be used as a sole remedy at RMA. The
use of institutional controls, such as deed restrictions and land use restrictions to supplement
engineering controls for long-term management, is consistent with the NCP, the FFA, and the
RMA National Wildlife Refuge Act of 1992. As stated in the response to your comment on Page
2, fifth paragraph. Basin A will not receive soil or structural material for fill that exceeds
principal threat or human health exceedance criteria. The Basin A cover will reduce infiltration
and naturally lower the water table, thereby reducing contaminant leaching from the area.
Consumption of groundwater or surface water on-post will be restricted by institutional controls
in accordance with the FFA. The Integrated Endangerment Assessment/Risk Characterization
(IEA/RC) considered both human inhalation of vapors and biota exposure from use of nonpotable
water. To assess vapor inhalation, groundwater was considered as a potential source (in addition
to soil) because it may have contributed to the concentration of vapors in the soil column. The
ecological risk characterization assessed risk to biota from exposure to surface water from the
lakes (exposure to groundwater is not anticipated).
Page 4, second paragraph: Following EPA guidance, 10"4 is the action criterion below which
media do not generally need to be treated at any site, regardless of future use. Once treatment
was required due to risk, 1CT6 was used as the point of departure for evaluating the effectiveness
of the treatment technologies. The Army believes the selected remedy will be protective of
human health and the environment; this protectiveness includes the wildlife residing or foraging at
the Refuge.
Page 4, third paragraph: Please see the response to your comment at Page 4, second
paragraph, regarding protection of wildlife. Regarding mercury, arsenic, and asbestos, all three
were considered in the DAA and in the IEA/RC. All human health and biota exposures to
mercury and arsenic are addressed through landfilling or containment. Asbestos abatement is
ongoing.
Page 4, fourth paragraph: The Parties disagree on whether the substantive portions of the
Colorado Wildlife Enforcement and Penalties Provisions (C.R.S. 33-1-101 et seq. And C.R.S.
33-6-101 et seq.) and Wildlife Commission Regulations (2 CCR 406-8) are applicable or relevant
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and appropriate requirements (ARARs). The U.S. Fish and Wildlife Service in cooperation with
the Colorado Department of Natural Resources has agreed to advise the Army, as the lead
agency, with respect to the substance of state wildlife laws and regulations, to ensure that, where
indicated, such state laws and regulations are taken into account in connection with the
implementation of the selected remedy to the extent they are not inconsistent with federal laws
and regulations. The Parties each reserve all rights with respect to their respective legal and
jurisdictional arguments relating to whether the above-cited state laws and regulations relative to
wildlife should be treated ARARs. The On-Post Location-specific ARARs include the National
Wildlife Reiuge System Administration Act (16 U.S.C. 668dd et. seq.) that prohibits the taking or
possessing of any animal or nest or egg within a National Wildlife Refuge, as well as the use of a
Refuge for that purpose, except by people authorized to manage the site or unless the activities
are allowed at the site. While not considered to be ARARs, the provisions of the Endangered
Species Act, the Migratory Bird Treaty Act, and the Bald and Golden Eagle Protection Act apply
to RMA. As additional protection, Section 44.2(b) of the FFA specifically, prohibits the use of
RMA groundwater or surface water for potable use, and Section 44.2(c) specifically prohibits
consumption of all fish and game taken at RMA. The RMA National Wildlife Refuge Act of 1992
also contains these restrictions. FFA Section 44.4 gives the United States the additional authority
to impose and enforce additional restrictions as necessary for the protection of human health and
the environment.
Page 4, last paragraph: The Army believes that the Complex Trenches, Shell Trenches, and the
South Plants Central Processing Area have been adequately characterized in the RI. The areas do
have high levels of contamination, and the Army considered this fact in selecting the appropriate
remedy for those areas. The Army believes that the selected remedy will be protective of humans
and the environment.
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITfflN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SDC MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
zoo® lasmoo vm ~* Aia MVI HIANH AKHV sn OVGZSBB m xvj *S:CT IHJ 96/92/10
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
coo©
VHH
Aid an HIANH AJWV sn
Om969 COi IVJ Sfi:CT IHJ 96/9Z/TO
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
- THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
A,« .„ .^ „ „ om9M m w „, „ ^ 8e/9z/io
-------
AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. ^
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION I, ABOVE
version 10 - 26/01/96
SOD® lasNnoo via *•«•«• AIQ MVI HIANH AMHV sn omges tot TV* 95; ci IHJ 95/92/10
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State Representative ^tO5^ Member:
ALICE NICHOL Local Government Committee
891 East 71st Avenue COLORADO Transportation and Energy
Denver Colorado 80229 ** !—
Home: (303)287-7742 HOUSE OF REPRESENTATIVES
CapHol: (303) 866-2931 STATE CAPITOL
^^»* DENVER
BO203
January IS, 1996
On-Post Proposed Plan Comments
Program Manager
Rocky Mountain Arsenal
Attn: AMCPM-PM
Col. Eugene Bishop
Building 111-RMA
Commerce City, CO 80022-1748
Dear Col. Bishop:
The Proposed Plan and Conceptual Agreement on clean-up activities appears to envision
disposing of most, if not all, of the non-hazardous waste on the Rocky Mountain Arsenal without
the normal landfill liner requirements for such waste disposal. If non-hazardous waste material
is to be disposed of on site, then the appropriate approval process, as well as siting and design
standards as would be required of any private company for a non-hazardous landfill facility,
should be followed. The same rules that would apply to any private company in landfill siting
and construction, should also apply to the Army.
In fact, it is preferable that the Army dispose of all non-hazardous waste material from the
Rocky Mountain Arsenal in a properly permitted, designed, and constructed off-site non-
hazardous waste landfill. The amount of waste material left on site of the Rocky Mountain
Arsenal after clean up activities are completed should be minimized, especially if it can be
shown that an off site landfill alternative is more cost efficient than siting, permitting,
constructing, and operating an on-site properly designed and constructed non-hazardous landfill.
Given the tremendous overhead expenses that would be associated with any on site facility, it
is hard to see how any off site facility wouldn't be more cost effective.
In summary, on site disposal of non-hazardous waste from clean-up activities at the Rocky
Mountain Arsenal should only be allowed if it is cost effective, and if shown to be cost affective,
only if the disposal facility on site is properly sited, permitted, designed and constructed in
accordance with all applicable laws and other requirements. The alternative of utilizing of an
off site non-hazardous waste landfill should be seriously considered, and at the very least, the
9601816-1/1
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proposed Record of Decision should incorporate a commitment to perform a study of
comparative costs and benefits of on site versus off site disposal alternatives, before any final
decision is made in this regard.
Sincerely,
lice Nichol
State Representative
AN/jw
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REPLY TO
ATTENTION OH
DEPARTMENT OF THE ARMY
PRl\-.RA\1 MAS'AuEK hOR KOOKY MOl 'STAIN ARSENAL
COMMERCE OITY. COLOKAIV SY:: ::•)-<
June 11, 1996
Office of the Program Manager
The Honorable Alice Nichol
State Representative
891 E. 71st Avenue
Denver, Colorado 80229
Dear Representative Nichol :
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
Your letter proposes either off-site disposal of nonhazardous materials or construction of
an onsite, nonhazardous waste facility in compliance with the Resource Conservation and
Recovery Act. The Army understands your concern that this material be disposed properly and
believes that the approach of placing the matei ;al under the Basin A cover will adequately
immobilize any contaminants and provide a cost-effective method for disposal of nonhazardous
materials. In addition, a large volume of fill material will be required to construct the Basin A
Consolidation Area, and the RMA nonhazardous material will satisfy that need. Furthermore, b>
consolidating nonhazardous material onsite, there will be no negative impact from a large number
of trucks moving through the surrounding community. Cost for fill material is also minimized
Therefore, the Army chose to keep the nonhazardous material onsite to be used as fill material for
the Basin A Consolidation Area.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Eugene H. Bishop
Colonel, U.S. Army
Program Manager
Readiness is our Profession
-------
-2-
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
-------
November 14, 1995
On Post Proposed Plan Comments
Program Manager
Rocky Mountain Arsenal
Atten: AMCPM-PM
Col. Eugene H. Bishop
Building 111 • RMA
Commerce City. Colorado 80022-1748
Critique on PPRMA On Post Operable Unit
1. The PPRMA should be published in two distinct parts: Part A, Historical
Record retained in the libraries as listed on page 4 (Park Hill Library a/so has the
only final detailed analysis of Alternatives report on file as of this date) and Part
2, a portable record coordinated with the historical record.
Part 1 would be the official document which would eventually become
the Record of Decision (ROD). Part 2 would be a series of base maps at
1:24000 scale which would be visual displays of the problems areas (soils,
structures and water) coordinated with Part 1 in every decision. These maps
would be portable for exhibit and discussion at all public or parties meetings.
2. It is strongly suggested that the discussion under Range of Developed
Alternatives, Incorporation of the Conceptual Remedy on Pages 11 and 12 of
the Plan and the summary on Page 17 should be carefully heeded by the
parties.
3. The implementation of items 1 and 2 would suggest a Joint meeting with
the parties and other interested groups or persons to emphasis the need to
arrive at the best public understanding of the plan.
4. With specific reference to a possible trust fund (see enclosed
correspondence), a little research (by a naive layman) indicates some interesting
facets of the financial aspects of the RMA cleanup. The trust fund would be
supported by an original appropriation of 250 Million dollars held in escrow for
10 years at 6% producing $197,750 million. Two years hence the next
9532402-1/1
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appropriation of $125 million would be made at 6% for 10 years et cetera. This scheme
at the end of 9 years would appear as follows:
1
3
5
7
9
Capital
Int. Through
2015
Money Avail.
Already spent
250,000,000
125,000,000
125,000,000
125,000,000
125.000.000
750,000,000
593.250.000
1,343,250,000
750.000.000
2,093,250,000
End of 10 year
period
2006
2009
2011
2013
2015
Years Capital (appropriation) Int. @ 6%/10/years
197,750,000
98,875,000
98,875,000
98,875,000
98,875,000
593,250,000
at the end of 2015
Please notice that at the beginning of discussion under item 41 mentioned escrow.
The scheme would not be effective in the present fiscal year. The Army has bee
assured of its appropriations for this fiscal year. This situation would hopefully give „
public private partnership an opportunity to bolster the trust fund with individual or
corporate tax exempt donations. This would give the general public a direct chance t
rehabilitate the environment we need to protect for our survival (and politicians). Sew
comment plan item 4.1-3.
The fiscal control of trust fund should be overseen by General Accounting Offic*
as an independent unbiased government agency.
5. Will this opportunity affect the time schedule for the ROD adversely?
SSAB, MB
Enclosures
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DEPARTMENT OF THE ARMY
OFFICE OF THE ASSISTANT SECRETARY
INSTALLATIONS LOGISTICS AND ENVIRONMENT
110 ARMY PENTAGON
WASHINGTON DC 2031(H>110
October 18, 1995
Mr. Dennis Gallagher
Councilman, District One
Room 451, City and County Building
Denver, Colorado 80202
Dear Councilman Gallagher
I would like to thank you and Mr. Smith for your letter of August 29,1995,
to President Clinton concerning the trust fund provision in the Agreement for A
Conceptual Remedy for the Cleanup of Rocky Mountain Arsenal.
The Army is very proud of the Agreement reached on the cleanup of
Rocky Mountain Arsenal and we appreciate your interest in the matter. As you
know, the trust fund is one part of a multi-part agreement representing the
cooperative efforts of many parties, public and private alike.
Pursuant to the Agreement, the Army will commit its good faith, best effort
towards the establishment of the trust fund. As indicated in the Agreement,
establishment of the fund will require special Congressional legislation and the
Army is subject to certain restrictions with respect to legislative proposals. The
Army is committed to fulfilling its responsibility under the Agreement in
accordance with those restrictions.
Thank you again for the letter. Your enthusiasm for the trust fund and the
cleanup agreement is appreciated. I welcome your continued participation in the
process to dean up the Rocky Mountain Arsenal.
Sincerely,
Acting Deputy Assistant Secretary of the Army
(Environment, Safety and Occupational Health)
OASA(I,L&E)
9532402-l/l-A
Printed on
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advisory group will be convened within the next 180 days. Any health assessments
completed by COPHE and ATSDR will be formally reviewed by the Parties prior
to issuance to the Medical Monitoring Advisory Group or the public.
The primary goals of the Medical Monitoring Plan are to monitor any off-post
impact on human health due to the remediation and provide mechanisms for
evaluation of health status on an individual and community basis, until such time as
the soil remedy is completed.
19. Truat Fund
The Parties commit to good faith best efforts to establish a trust fund for the
operations and maintenance of the remedy, including habitat and surficial soils.
The Parties recognize, however, that establishment of such a trust fund requires
special legislation and there are restrictions on the actions federal agencies can take
with respect to proposing legislation and supporting proposed legislation. The
funding amount will be determined in the Final D AA and would be funded by the
U.S. Army and SbeO Oil Company.
20. Criteria for Shutting Down Groundwater Boundary "^ Off-post Containment Systems
o Existing wells within the boundary and off-post containment systems (BCS) can be
removed from production when concentrations of constituents detected in the wcffl
are less than applicable or relevant and appropriate requirements (ARARs)
established in the ROD and/or it can be demonstrated that discontinuing operation
of a well would not jeopardize the containment objective of the systems. The
containment objective of the systems will be outlined in the ROD. Weflj removed
from production and monitoring wells up-gradient and down-gradient of the BCS
will be monitored quarterly for a period of five yean to determine if contaminants
reappear, except those wells turned off for hydraulic purposes wfll not be subject
to the quarterly monitoring requirements. BCS extraction wefls removed from
production for water quality reasons wfll be placed back into production if
contaminant concentrations exceed ARARs established in the ROD. WeOswhh
concentrations less than ARARs established in the ROD can remain in production
if additional hydraulic control is required.
21. Criteria for Shutting Down Internal Containment Systems flCS)
o Existing wells within the internal containment systems (ICS) can be removed from
production when concentrations of constituents detected in the wells are less than
-11-
9S32402-1/1-B
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r rW
August 25, 1995 ~'^ '
North Denver Community Center
3627 W. 32nd Avenue
Denver, CO 80211
Honorable William Jefferson Clinton
President of the United States
Washington, D.C. 20500
*
Dear Mr. President:
The attached letter of August 4, 1995 is indeed encouraging. Just maybe, we are
witnessing democracy in action.
With reference to change, the accommodation to an innovative trust fund for the RMA
cleanup would assuredly have interesting political repercussions. This action could serve as a
demonstration of public private partnership all the way through government to the grass roots.
Specifically I visualize at least three important advantages of this concept:
1. The elimination or at least a reasonable reduction in the yearly political hassle over
appropriations for this purpose.
2. The process should be designed in such a manner so as to accommodate to an
eventual rollover into 0 and M for the ultimate project: National Wildlife Refuge.
3. The development of a public private concern for the environment necessary to our
economic security.
Item 3 above suggests that a simple short understandable platform for politicians could
be: 'We stand for a public private partnership to sustain the national security, the national
economy and the national environment with liberty, life and happiness for the good of the
U.S.A." (Paraphrase of the Declaration of Independence).
Sincerely,
Dennis J. Gallagher
Councilman 1st District . Aide to Coujfcilman Gallagher
Denver County
Enclosures ••' •_ ..-.....-
«/cc: Raymond J. Fatz, Acting Deputy-Asst. Sec. Army . '••-..-. »532402-i/i-c
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Till: 1)1 NVI-lt P()SI
Friday. November 10. 1995
fc. , '
Arsenal seeks water supply
ly RwMto Rooty
tanw Post Stfttt WrtHf
AURORA - The Rocky Mountain Am-
lal wants to take over Fitzsimons Army
liedical Center's water rights when the
tost closes doe to defense cuts.
Tbe arrangement wont cover drinking
rater for post residents or the hospital but
fonW pertain to water from the High Line
Zanal that is now being used to irrigate
ibont SO acres of farmland near Fitzsi-
noos' East Colfax Avenue gate. The land
s planted in alfalfa.
Arsenal officials wants to use the water
o help clean up contamination at the site
there Shell Oil Co. once manufactured
pesticides and the U.S. Army made chemi-
»l weapons.
Arsenal officials have asked the Army
for its rights to SIS acre feet of water. An
KTC foot provides enough water to supply
i family of four for a year, or more than
S2S.OOO gallons.
Officials to bid on Fitzsimons'
rights to help cleanup toxic land
Fitzslmons gets its drinking water from
the Denver Water Board. Although the
post is entirely within the boundaries of
Aurora, when it opened in 1918 the city
didn't have enough water to supply the
post. As Filrsimons is redeveloped for ci-
vilian use. the new users will rely on Auro-
ra's municipal water supply.
The arsenal is one of three federal agen-
cies interested in taking over parts of Fiti-
simons. Federal agencies get priority
when deciding what to do with surplus
property.
The Air Force has asked the Army for
about 125 acres of land at the 577-acre
post, including military housing and other
buildings. Tbe Department of Veterans Af-
fairs has asked the Army for the main bos-
pital and other related buildings. All three
agencies have until the end of November
to detail their plans for the site. Then the
Army must decide who gets the site and
the water rights.
The arsenal would use the water to re-
plant some areas with prairie grasses af-
ter contaminated soil is dug up and re-
moved. '
There are also several lakes at the arse-
nal which need to be kept full as part of
the cleanup efforts, and the Fitzsimons
water would help do that. Maj. Garry
Brewer, chief counsel for the arsenal, said
it will need about 3.000 acre feet of water
and doesn't have nearly that much.
The arsenal wouldn't have to pay for
Fitaimons' water rights. Brewer said. The
arsenal would simply take water from a
different point in the canal than Fitzsi-
mons does.
But fanner Raymond Hanson's alfalfa
fields would pay the price. Hanson has
fanned the area for bay for his livestock
for 15 years. The practice is common on
military bases with vacant sections that
can be farmed or grazed.
Hanson, an Aurora rancher, has been
farming surplus military land for decades.
He started (arming at the former Lowry
Air Force Base in 1*73. Since that base has
closed, and Fitzsimons Is on the way out,
his future is in question. Hanson also lost
another l.SOO-acre chunk of hay-producing
land because of development around Den-
ver International Airport.
"It's a big disappointment," said Han-
son. "Living this close to the city, it's a
way of life."
9532402-1/1-D
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U.S. ARMY
MATERIEL COMMAND
—COMMITTED TO PROTECTION OF THE ENVIRONMENT—
Proposed Plan for tke
Rocky Mountain Arsenal On-Post Operable Unit
• Citizen's Summary
What is the purpose of this
report?
The purpose of this Proposed Plan is
to identify the U.S. Department of
the Army's (Army's) preferred reme-
dial alternatives1 for contaminated
water, structures, and soil at Rocky
Mountain Arsenal so that the public
can participate in the alternative se-
lection process. The Arsenal is
located in southern Adams County,
Colorado, north of Denver.
The Army is submitting this Proposed
Plan to the public in recognition of
the importance of public involvement
in the environmental restoration of
the Arsenal. Its submittal is consistent
with Section 117(a) of the Compre-
hensive Environmental Response,
Compensation and Liability Act
(CERCLA) and with the National
Oil and Hazardous Substances Pol-
lution Contingency Plan (NCP).
Both CERCLA and the NCP require
the investigation and remediation of
contamination that poses a potential
threat to human health and the envi-
ronment Documents that detail such
investigations at the Arsenal are listed
on pages 3 and 4.
Tablt of Content*
I CStizen'i Q Summary
Community Q Participation
:;_--';., Site Q Background
Assessment of B Site Risks
Summary of I
•- ":'" Witter
Structures
Summary
Glossary
the Feasibility
Study Process
Feasibility Study
Feasibility Study
Feasibility Study
Mark Your Calendar: Opportunities for Public Involvement
Public Meeting
Saturday
November 18,1995
Location
Rocky Mountain Arsenal
Building Ill-A
Commerce City, CO 80022
Time
9:00 a.m.
Administrative Record Location
Rocky Mountain Arsenal
Building 135, Room 16
72nd Avenue and Quebec Street
Commerce City, CO 80022
Hours
Monday, Wednesday, and Friday
Noon to 4:30 p.m.
Tuesday and Thursday
5 pirn, to 9p.m.
Saturday
10 a.m. to 4 p.m.
Telephone
Phone:(303)289-0136
(800)862-0754
Public Comment Period
October 16 through
December 15,1995
Send Comments to
On-Post Proposed Plan Comments
Program Manager
Rocky Mountain Arsenal
Attn.:AMCPM-PM/
Col. Eugene H. Bishop
Building 111—RMA
Commerce City, CO 80022-1748
11tems shown In bold print an Included In the glossary on page 29.
9532402-1/1-E
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complete than the others. In addition,
most of the highly contaminated soil
is excavated and moved, which in-
volves a higher short-term risk to
workers and the surrounding commu-
nity.
SKewkfo Alternative 4 Is preferred
because tt la more effective In the
long term than SKewtde Alterna-
tive* 1,2, or 3 In reducing, through
treatment, the toxldty and mobility
of tome of the moat contaminated
soil, and la more coat effective and
hnplementable than SHewUe Alter-
native 5. In this instance, the short-
term risks of excavation and transport
are balanced by the long-term effec-
tiveness and the moderate cost of the
alternative. This results in an overall
effectiveness that is greater than that
of the other alternatives. In addition,
this alternative remediates risks to
wildlife in the central sections of the
Arsenal. The Supplemental Field
Study and USFWS biomonitoring
program address potential risks to
wildlife outside this area. The pre-
ferred soil alternative is highlighted
on Table 10 (page 25) and shown on
Figure 4 (page 27).
• Summary
The preferred alternatives rank
highest with respect to the criteria
used to evaluate the alternatives and
they are consistent with the NCF and
the statutory requirements of
CERCLA. In addition, the preferred
alternatives are required to be re-
viewed every 5 years with regard to
their protectiveness of human health
and the environment and compliance
with applicable regulations and con-
tinued on-post monitoring programs.
Areas requiring long-term operation
and maintenance (see page 11, Range
of Developed Alternatives) consistent
with the preferred alternatives are
shown in Figure 5 (page 28). On the
basis of the available information,
the Army concludes that the preferred
alternatives would (!) address the
threats to human hearth and the envi-
October1995
ronment by using a combination of
treatment and containment as princi-
pal elements to permanently reduce
the toxicity, mobility, and volume of
contaminants in structures, soil, and
groundwater; (2) comply with
ARARs; and (3) be cost effective.
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December 14, 1995
Waldo G. Smith, P.E.
3627 W. 32nd Avenue
Denver, Colorado 80211
On Post Proposed Plan Comments
Program Manager
Rocky Mountain Arsenal
Atten: AMCPM-PM
Col. Eugene H. Bishop
Building 111 >RMA
Commerce City, Colorado 80022-1748
Critique on PPRMA On Post Operable Unit
1. The PPRMA ^should be published in two distinct parts: Part I, Historical
Record retained in the libraries as listed on page 4 (Park Hill Library a/so has the
only final detailed analysis of Alternatives report on fife as of this date} and Part
2, a portable record coordinated with the historical record.
Part 1 would be the official document which would eventually become
the Record of Decision (ROD). Part 2 would be a series of base maps at
1:24000 scale which would be visual displays of the problems areas (soils,
structures and water) coordinated with Part 11n every decision. These maps
would be portable for exhibit and discussion at all public or parties meetings.
2. It Is strongly suggested that the discussion under Range of Developed
Alternatives, Incorporation of the Conceptual Remedy on Pages 11 and 12 of
the Plan and the summary on Page 17 should be carefully heeded by the
parties.
3. The implementation of Items 1 and 2 would suggest a Joint meeting with
the parties and other interested groups or persons to emphasis the need to
arrive at the best public understanding of the plan.
4. Discussion of a trust fund to support the financial funding for the RMA
clean-up brings up complications which Invite closer Investigation by the
Treasury Department and the General Accounting Office in cooperation with the
parties and other groups. Frankly, there could develop a situation which
demanded a new accounting system to accommodate to the trust fund as
ordinarily conceived as well as the present pay as you go shaky appropriations
9535206-1/1
-------
system.
Any scheme would not be effective in the present fiscal year. The Army
has been given appropriations for fiscal year 1995-96 (so I understand) in this
situation would hopefully give public private partnership an opportunity to
develop a trust with corporate or individual tax exempt donations. To avoid
conflicting methods of disbursement of funds, the appropriations would
continue to support 0 & M operations within the RMA clean-up; the revenue
generated by trust fund (Interest only) would only meet unforseen
contingencies which could stall the clean-up final completion In yr. 2008.
This accommodation to appropriations and trust fund should guarantee
(provided political maneuvering is not condoned) that the 0 & M operations of
the RMA clean-up will meet the deadline of 2008 A.D.
The fiscal control of the trust fund should be overseen by the GAO as an
independent on bias government agency.
5. Does this opportunity (R2B 11/15/95 attached) affect the time schedule
for ROD adversely?
i
SincereSy,
Wafob G. Smitt, RE.
SSAB, RAB
Enclosures
-------
DEPARTMENT OF THE ARMY
OfFICC OF THE ASSISTANT SECRETARY
MSTAUATIONS LOGISTICS AND ENVIRONMENT
110 ARMY PENTAGON
WASHINGTON DC 2011*0110
October 18, 1995
Mr. Dennis Gallagher
Councilman, District One
Room 451, City and County Building
Denver, Colorado 80202
Dear Councilman Gallagher
I would like to thank you and Mr. Smith for your letter of August 29,1995,
to President Clinton concerning the trust fund provision in the Agreement for A
Conceptual Remedy for the Cleanup of Rocky Mountain Arsenal.
The Army is very proud of the Agreement reached on the cleanup of
Rocky Mountain Arsenal and we appreciate your interest in the matter. As you
know, the trust fund is one part of a multi-part agreement representing the
cooperative efforts of many parties, public and private alike.
Pursuant to the Agreement, the Army will commit its good faith, best effort
towards the establishment of the trust fund. As indicated in the Agreement,
establishment of the fund will require special Congressional legislation and the
Army is subject to certain restrictions with respect to legislative proposals. The
Army is committed to fulfilling its responsibility under the Agreement in
accordance with those restrictions.
Thank you again for the letter. Your enthusiasm for the trust fund and the
cleanup agreement is appreciated. I welcome your continued participation in the
process to clean up the Rocky Mountain Arsenal.
Sincerely,
RayrwnYj. Ft
Acting Deputy Assistant Secretary of the Army
(Environment, Safety and Occupational Health)
OASA(I,L&E)
9S32402-1/1-A
-------
advisory group will be convened within the next 180 days. Any health assessments
completed by CDPHE and ATSDR will be formally reviewed by the Parties prior
to issuance to the Medical Monitoring Advisory Group or the public.
The primary goafs of (he Medical Monitoring Plan are to monitor any off-post
impact on human health due to the remediation and provide mechanisms for
evaluation of health status on an individual and community basis, until such time as
the soil remedy is completed.
19. Tnnf Piiiy|
The Parties commit to good fiu'th best efforts to establish a trust fund for the
operations and maintenance of the remedy, including habitat and surficial soils,
The Parties recognize, however, that establishment of such a trust fund requires
special legislation and there are restrictions on the actions federal agenda can take
with respect to proposing legislation and supporting proposed legislation The
funding amount will be determined in the Final DAA and would be funded by the
U.S. Army and SheH Oil Company.
20. Criteria for Shutting Down Groundwater Boundary and Off-post Containment Svrtema
„ s , j ^
o Existing weQs within the boundary and off-post containment systems (BCS) can be
removed from production when concentrations of constituents detected in the wefl
are less than applicable or relevant and appropriate requirements (ARARs)
established in the ROD and/or it can be demonstrated that discontinuing operatic*
of a well would not jeopardize the containment objective of the systems. The
containment objective of the systems win be outlined in the ROD. WeQs removed
from production and monitoring wells up-gndient and down-gradient of the BCS
will be monitored quarterly for a period of five years to determine if contaminants
reappear, except those wells turned off for hydraulic purposes win not be subject
to the quarterly monitoring requirements. BCS extraction wcfli removed from
production for water quafity reasons wfll be placed back into production if
contaminant concentrations frcwt ARARs frttHithed in the ROD. WeQs with
concentrations less than ARARs established in the ROD can remain in production
if additional hydraulic control b required.
21. Cftterii tor Shutting Down Internal Ctonttinment System* flCS)
o Existing wefls within the internal containment systems (ICS) can be removed from
production when concentrations of constituents detected in the wells are less than
-11-
9532402-l/l-B
-------
Aupm 25.1995 ^
North Denver Community Center
3627 W. 32nd Avenue
Denver, CO 80211
Honorable William Jefferson Clinton
President of the United States
Washington, D.C. 20500
Dear Mr. President:
The attached letter of August 4, 1995 is indeed encouraging. Just maybe, we are
witnessing democracy in action.
With reference to change, the accommodation to an innovative trust fund for the RMA
cleanup would assuredly have interesting political repercussions. This action could serve as a
demonstration of public private partnership all the way through government to the grass roots.
Specifically I visualize at least three important advantages of this concept:
1. The elimination or at least a reasonable reduction in the yearly political hassle over1
appropriations for this purpose.
2. The process should be designed in such a manner so as to accommodate to an
eventual rollover into 0 and M for the ultimate project: National Wildlife Refuge.
3. The development of a public private concern for the environment necessary to our
economic security.
Item 3 above suggests that a simple short understandable platform for politicians could
be: 'We stand for a public private partnership to sustain the national security, the national
economy and 'the national environment with liberty, life and happiness for the good of the
U.S.A.' (Paraphrase of the Declaration of Independence).
Sincerely,
Dennis J. Gallagher * Wado O; Sml
Councilman 1st District . Aide to Councilman Gallagher
Denver County
Enclosures •••'•_ •• ---..-'
• ' * • • •» . • *
*/cc: Raymond J. Fatz^ Acting Deputy-Asst. Sec. Army . '•• ••-./. 9S32402-i/i-c
-------
Tin-: DI--NVI-K IHJSI
Friday. November 10. 1995
fc. .
Arsenal seeks water supply
ly Herat* Rotovy
•sWNHW ffOW BwBff iWHwJI*
AURORA - The Rocky MomUIn Arse-
«l wants to Uke over Fltztimons Army
fodtcal Center's water rights when the
wot closes due to defense cuts.
The arrangement wont cover drinking
rater for post residents or the hospital but
rould pertain to water from the High Line
'-anal that to now being used to Irrigate
boat SO acres of farmland near Fitzsi-
not*' East Colfax Avenue gate. The land
I planted In alfalfa.
Artenal official* wants to uaa the water
o help clean up contamination at the site
there Shell Oil Co. once manufactured
wstkMes and the U.S. Army made cheml-
al weapons.
Arsenal officials have asked the Army
or Its rights to SIS acre feet of water. An
icre foot provides enough water to supply
i family of four for a year, or more than
115.000 gallons.
Officials to bid on Fitzsimons'
rights to help cleanup toxic land
Filzslmons gets Its drinking water from
the Denver Water Board. Although the
post Is entirely within the boundaries of
Aurora, when It opened In 1918 the city
didn't have enough water to supply the
post. As Fitzsimons Is redeveloped for ci-
vilian use, the new users will rely on Auro-
ral municipal water supply.
The arsenal Is one of three federal agen-
cies Interested In taking over parts of Fitz»
slmons. Federal agencies get priority
when deciding what to do with surplus
property.
The Air Force has asked the Army for
about IIS acres of land at the 677-acre
post, including military housing and other
buildings. The Department of Veterans Af-
fairs has asked the Army tor the main hus-
pltal and other related buildings. All three
agencies have until the end of November
to detail their plans for the site. Then the
Army must decide who gets the site and
the water rights.
The arsenal would use the water to re-
plant tome areas with prairie grasses af-
ter contaminated soil Is dug up and re-
' There are also several lakes at the arse-
nal which need to be kept full as part of
the cleanup efforts, and the Fltsslmons
water would help do that. Ma). Garry
Brewer, chief counsel for the arsenal, said
It will need about 3.000 acre feet of water
ami doesn't have nearly that much.
The arsenal weeJdal have u i
far
dlffereM petal tm Ike ennstl than fltaal-
IIMMHI doea.
But fanner Raymond Hanson's alfalfa
fields would pay the price. Hanson has
fanned the area for hay for Ma livestock
for if yean. The practice to common on
military bases with vacant sections that
can be farmed or grated.
Hanson, an Aurora rancher, has been
farming surplus military land for decades.
He started farming at the former Lowry
Air Force Base In 1973. Since that base has
closed, and Fitzshnons Is on the way out,
his future to In question. Hanson also lost
another l.SOO-acre chunk of hay-producing
land because of development around Den-
ver International Airport
"It's a big disappointment," said Han-
son, "Living this close to the city, It's a
way of life?
9532402-1/1-0
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46 US. COVtRNMCNT MANUAL
GENERAL ACCOUNTING OFFICE
xji r> f*—— *.»-* •*- • - —
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CHAXIU A. BOWSHEK
(VACANCY)
JAMES F. HlNCHMAN
j. DUTH PtACM
JAMES L HOWAIO
BKIAN P. Cuowirr
RCHAKO I. Foca
JOHNNY C. FINCH
JANCT L. Snail
f. KEVIN BOUND
HINKY L HMTON. jt.
KEITH O. FIAT*
GENE L. DOOAJO
Tttrr E. HUMUOI
ROMRT P. MUVMV
JAMES R. WVm
NHOA I. AfOMIt
M. THOMAS HAONfTAO
HOVVAtO N. JOHMON
JOSEPH L. DMA**. JL
FKANasGAflCM
Pm«v. Ainv
PATIICIA M. RCOCM
PAW. L JONB
Cuvt £. Coeurr
FRANCUCvMO*
RCHAitoSnNn
ANNE K. KUM
NANCY A. Mctan
GENERAL,
-------
30UJO ONUNflOOOV 1VU3N39
-------
48 U.S. GOVERNMENT MANUAL
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MICHAEL F. DiMAto
JAMCS N. IOYNH
CiAuorm BOUIOM
NCAlFlNC
THOMAS L HUGHES
MEWOfTH L AUNISON
GEORGE I. CCUJNS
STUAKT M. Few
AMTHONV |. ZACAMI
UWISLSMAU.
WHUAMM.GUY
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F. AIINOCS
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PATUOA R. GA*ONI«
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RAYMOND |. CARVEY
9535206-1/l-E
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER I;OR RlVk'Y MiH XTAIV AK-f.:\AI.
I'OMMERGEUTY. t/OLOKALV "iV::.! 74>
June 11, 1996
REPLY TO
ATTENTION'OF
Office of the Program Manager
Mr. Waldo Smith
North Denver Community Center
3627 W. 32nd Avenue
Denver, Colorado 80211
Dear Mr. Smith:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
in the process helps maintain the dialogue between the U.S. Army and the public.
In response to your query about dividing the On-Post Plan into two sections, the On-Post
Record of Decision (ROD) format follows U.S. Environmental Protection Agency (EPA)
guidelines and the format of the Off-Post ROD, and so no changes will be made to the layout of
the document.
The Army agrees with you that the proposed remediation alternative should be carefully
followed and that all parties should communicate effectively to arrive at the best possible public
understanding of the plan. The Army is proud of its success in cooperating with the State of
Colorado, Shell Oil Company, the EPA, the U.S. Fish and Wildlife Service, and local stakeholders
to arrive at a ROD to remediate RMA, and looks forward to working with stakeholders as the
remediation process extends into the future.
During the formulation and selection of the remedy, members of the public and some local
governmental organizations expressed keen interest in the creation of a Trust Fund, as you do in
your comment, to help ensure the long-term operation and maintenance of the remedy. The
Parties have committed to good-faith best efforts to establish such a Trust Fund, as described in
the On-Post ROD. Principal and interest from the Trust Fund would be used to cover the costs of
long-term operation and maintenance throughout the lifetime of the remedial program. These
costs are estimated to be approximately $5 million per year (in 1995 dollars).
It is the intent of the Parties that if the Trust Fund is created it will include a statement
containing the reasons for the creation of the Trust Fund, a time frame for establishing and
funding the Trust Fund, and an appropriate means to manage and disburse money from the Trust
Fund. The Parties are also examining possible options that may be adapted from trust funds
involving federal funds that exist at other remedial sites. The Parties recognize that establishing a
Trust Fund may require special congressional legislation and that there are restrictions on the
Readiness is our Profession
-------
-2-
actions federal agencies can take with respect to such legislation. Because of the uncertainty of
possible legislative requirements and other options, the precise terms of the Trust Fund cannot
now be stated.
A Trust Fund group will be formed to develop a strategy to establish the Trust Fund. The
strategy group may include representatives of the Parties (subject to restrictions on federal agency
participation), local governments, affected communities, and other interested stakeholders and
will be convened within 90 days of the signing of the ROD.
According to the U. S. Government Manual, "The General Accounting Office [GAO] is
charged with examining all matters relating to the receipt and disbursement of public funds." The
existence of a Trust Fund containing government funds and the use of such a fund is subject to
GAO audit. Fiscal control of such a fund is not considered to be within GAO's delegated
authority.
The Army intends to stay on the current schedule for the ROD so that the RMA
remediation can go forward.
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
-------
On Post Proposed Plan Comments December 12, 1995
Program manager
Rocky Mountain Arsenal (RMA)
Attn: AMCPM-PM/Col. Eugene H. Bishop
Building 111-RMA
Commerce City, Colorado 80022-1748
Re: Proposed Plan for the RMA; On Post Operable Unit
To all to whom this may come to affect or may concern as stakeholders of the Rocky
Mountain Arsenal, Denver, Colorado:
In May of 1974, diisopropylmethylphosphonate (DIMP) and dicyclopentadiene (DCPD) were
detected in the surface water at the northern boundry of the RMA. Later that year the
Colorado Department of Health (CDH) detected DIMP in a well north of the RMA. As a
result, the CDH issued a cease and desist order directing the RMA to immediately stop
the off-post discharge of DIMP and DCPD in surface and subsurface water.
In 1989, the nvironmental Protection Agency issued a human Health Advisory for DIMP
in drinking water of 600 parts per billion (ppb). Pursuant to a CDH request of the
COLORADO WATER QUALITY CONTROL COMMISSION (1991), the Commission elected to adopt the
CDH proposed DIMP standard of 8 ppb.
Finally, 'pursuant to the AGREEMENT FOR A CONCEPTUAL REMEDY FOR THE CLEANUP OF THE
ROCKY MOUNTAIN ARSENAL, dated June 13, 1995, the parties agreed as follows:
I
o As of the date of the On Post Record of Decision (ROD), and based on a .392 ppb
detection limit, the U.S. Army will use the last available quarterly monitoring
results to determine the DIMP plume footprint.
o The U.S. Army and Shell Oil Company will pay for the extension of, and hook-up to
the current distribution system for all existing well owners within the DIMP
plume footprint referenced above.
o Existing domestic well owners outside the DIMP plume footprint as of the data
of the On Post ROD where it is later determined that levels of DIMP are 6 ppb or
greater will be hooked up at the U.S. Army and Shell Oil Company's expense to the
South Adams County voter and Sanitation District (SACWSD) distribution system or
provided a deep well or other permanent solution.
o The U.S. Army and Shell Oil Company agree to pay for, and provide or arrange for
the provision of 4,000 acre feet of water, the details of which will be worked out
between the U.S. Army, Shell Oil Company and SACWSD.
On September 7, 1995, I learned that the intention of the U.S. Army and Shell Oil
Company, with respect to the referenced agreement provisions above intend as follow*]
o The Platt River will be designated as the northern-most perimeter for remediation Of
groundwater despite the fact that DIKP contamination has crossed north of the Platt tiva
o The distribution system hookup for "all existing well owners" within the DIMP pliM
footprint is actually intended only for dontfttie well owners. The hookup provision
does not consider or restrict other forms of exposure to contaminated groundwater.
9534704-1/1
-------
Pursuant to the FEDERAL FACILITY AGREEMENT, pg. 12, Groundwater means water in a
saturated zone or stratum beneath the surface of land or water (Note: No differentiation
between irrigation and drinking water). Page 5 paragraph 2.7 also affirms that
"Groundwater and surface water flowing beyond the Arsenal boundaries will be of a
quality that is protective of human health and the environment".
Given the extensive exposure to DIMP,wherein the quantitative exposure limitations
have changed fron 600 ppb in 1989 to 0.392 ppb in 1995 for neighboring households,
I urge that the language of "hook-up to the current distribution system for all existing
well owners within the DIMP pluoe footprint be strictly adhered to — without
limitation to the respective well use permit disclosure.
o The provision of 4,000 acre feet of replacement water will not be enough, in
quantity, to mitigate the SACWSD loss of 4,300 acre feet of shallow well water,
SACWSD loss of 700 acre feet of deep well water, and supply the anticipated DIMP plume
footprint exposure areas with an additional 2,500 acre feet.
Member: RMA Restoration Advisory Board
Member: RMA Site Specific Advisory Board
-------
On Post Proposed Plan Comments
Program Manager
Rocky Mountain Arsenal (RMA)
Attn: AMCPM-PM/Col. Eugene H. Bishop Decanter 13, 1995
Building 111 -RMA
Commerce Cry, Colorado 80022-1 748
Re: Proposed Plan for the RMA; On-Post Operable Unit
To all to whom mis may come to affect or may concern as stakeholders of the Rocky Mountain Arsenal, Denver,
Colorado:
Pursuant to the requirements of the COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION
and LIABILITY ACT (CERCLA) Sections 113 (k) (2) (B) (i-v) and 117(a), the NATIONAL OIL and HAZARDOUS
SUBSTANCES POLLUTION CONTINGENCY PLAN and the RMA FEDERAL FACILITY AGREEMENT,
I hereby submit these written comments for inclusion into the Record of Decision;
the Official Adminisfrative Record for On tt Off Post "Record
WHEREAS the remedial action objective for the RMA On-Post Operable Plan is to "Ensure that ground-
water reaching the RMA boundary will be of a quality that is protective of human health..."; 1
WHEREAS "Groundwater usage (either domestic and/or agricultural) is the primary contributor to car-
cinogenic risk, accounting for 45 to 99 percent of the total risk estimated for each zone. This indicates the major
role of the groundwater - related exposure pathways. "; 2
WHEREAS the FEDERAL FACILITY AGREEMENT stipulates mat "Response Actions will be s^ifneient
to prevent the vertical and horizontal migration of on-post contaminated groundwater and surface water so mat
off-post surface water and groundwater my be used in areas outside of the Arsenal boundaries,"; 3
WHEREAS "Groundwater means water in a saturated zone or stratum beneath the surface of land or
water."; 4
WHEREAS "Alternatives that do not meet the requirements of the FEDERAL FACILITY AGREEMENT
will be determined to not be implementable.": S
I hereby submit for your consideration, data for the RMA indicating mat men? is a high probability that
South Plants contamination is escaping the southern RMA boundary via groundwater migration ryf which the
RMA On-Post Operable Unit preferred water alternative fail* to address and mitigate.
For purposes of objectivity in presentation, I attach depictive EXHIBITS which I hereby incorporate into
these, my comments, for the Record of Decision. My comments conclude with text by- Mr. James J. Snodgrast •
Geophysitist with the UNITED STATES BUREAU of MINES who affirms the southern migration supposition
through his independent assessment of this, and other documentation.
Background:
The SOUTH PLANTS CONTAMINATION SURVEY and REMEDIAL ACTION ASSESSMENT invert-
gated seventeen suspected disposal sites (Task 2:1985 • 78 spill events) in the manufacturing complex and con-
ducted a program to sample historically documented spill sites per the historical data classification by the
UNITED STATES ARMY TOXIC and HAZARDOUS MATERIALS AGENCY (USATHAMA). High Priority was
given to sites proximate to groundwater and historically documented with records. Low Priority was designated
for sites without historical records of groundwater contamination yet still proximate to recorded spills.
The designation UNCONTAMIfrJATED SITES/NON-SOURCE AREAS was afforded to sites whirfr m»v have
been contaminated but without historical records to prove fflntttiminfltiflrii "r in the alternative, if no responsible
parry could be identified as having contaminated the given site. 6
Pg.lof4 9534704-1/1-A
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According to the STRUCTURES SURVEY REPORT, there are 982 structures on the RMA; approximately
53 percent were located on the South Plants sections #1 It 2; however, over half of the buildings and other struc-
tures' history documentation was incomplete. Low Priority and 'Uncontaminated/Non-Source" designated sites
had contamination test bore holes, whose depth reached only the surface of the water table levels under the aus-
pices that "contaminents present below 5 feet, or in the saturated zone, are considered to be related to ground-
water contamination by water table fluctuations and possible lateral migration.'' (Source: FINAL Phase I
Contamination Assessment Report, July 1988 pg. 143) Literal Tn-Depth' investigations were necessary at all of
these 'discounted' areas! Generally speaking, subsequent testing and geotechnical studies focused on the histori-
cal source sites rather man contaminent pathways, aka: "Secondary Sources/Non-Source" areas. 6
During the production phases at the RMA, the primary concern was the manufacture of the end items
on schedule... solid and slurry waste was often disposed of in the most convenient and expeditious manner,
often without regard to its contamination status. 7
EXHIBIT A, Figure SPSA 2.4-5 demonstrates Volatile Aromatic Organics (VAO's moderate aqueous sol-
ubility, high volatility) in the South Plants groundwater(1979/1983) in magnitudes in excess of Certified
Reporting Limits; EXHIBIT B, Figure SPSA 2.4-6 for VAO's (specifically emylbenzene, xylene, and toluene) in
1988/1989; EXHIBIT C, Figure SPSA 33-8 for VAO' s in the groundwater, 1988; EXHIBIT D, Figure SPSA 3.3-4
demonstrates Volatile Halogenated Organics (VHQ's • moderate to high aqueous solubility and volatility) in the
groundwater 1988.8 Per EXHIBIT E, Figure SPSA 3.3-1, we see the southern migration pathway composite for
1979/1983. Per EXHIBIT F, Figure SPSA 3.3-2, the southern migration pathway composite for 1988 is illustrat-
ed. 9
My review of available documentation indicates a southern contaminent migration flow through sec-
tions #1 and #2. EXHIBIT G, Figure C3-1 and EXHIBIT H, Plate 1 demonstrate the southern organic analyte
plums for the unconfined flow system 10. Specifically, EXHIBIT I, Figure SSA 3.5-1 demonstrates the VHO
plume (composed specifically of 1,1.1 Trichloroethane, 1,1 dichloroethylene and tricruorcethylene: See 8) in the
RMA water bearing zones. 11.
EXHIBIT J, Figure SSA 3.4-21 delineates the total area of potential contaminents in soils based on ana-
lytical results, historical information and distribution mechanisms. The southern lakes of Ladora, Derby, and
Mary and the 1964 lake setiment/solid waste trenches are encompassed. 12. The FINAL DETAILED ANALYSIS
OF ALTERNATIVES /WATER DAA affirmed The highest concentrations of contaminents are observed in wells
located beneath the South Plants Central Processing Area and within the 'A' sand or other stratigraphically
equivalent units (See: Pg. 3-7); the 'A' sands of sections 142 and south sections 11 it 12.
The southern lakes are situated on relatively thick permeable alluvial deposits. The deposits pass direct-
ly under portions of the South Plants and extend south to Lake Ladora where the deposits act as an important
semiconfined aquifer unit 13
In response to avian mortality occurring on the lake* (approximately 1,200 ducks) 14, Lower Derby,
Upper Derby aid Lake Ladora were drained and the day bottom was excavated to remove contaminated sedi-
ment (1964-1965). 15 It is important to note the absence of the day lake bottom; the absence may promote com-
munication between the potentially more permeable alluvial material (deposits of sand and gravel) and the
underlying Denver Formation.
Most of the sediment was disposed in section 112. south of Lower Derby Lake amounting to approxi-
mately 115,000 cubic yards of soil. 16 The balance, and additional solid waste products from the RMA, were dis-
posed in the trenches south of Lake Ladora. ThM* n»ivh*« w»t» not lined.
Pg-2of4
-------
Inferred volumes of contaminated lake soils include 47,000 cubic yards to only a 3 foot depth in Lake
Mary; 120,000 cubic yards to only a 3-4 foot depth in Lake Ladora; 240,000 cubic yards to only a 5 foot depth in
Lower Derby Lake; 200,000 cubic yards to only a 3-4 foot depth in Upper and east Derby Lakes and 74,000 cubic
yards to only a 3 foot depth in Rod A Gun Club Pond. A total of 15 analytes have been detected in the Lake
sediments. 17 Pursuant to the FINAL PHASE I CONTAMINATION ASSESSMENT REPORT/SOUTH PLANTS,
July 1988, pg. 145: The estimated contaminated soil vertical extent of 125 feet (Note: Groundwater level in the
South Plants area occurs at an average depth of 5 feet (a range of 2 to 10 feet) amounted to an estimated volume
of 3,085,000 cubic yards!
WATER BALANCE CALCULATIONS INDICATE THAT UPPER & LOWER DERBY LAKES HAVE
UNACCOUNTABLE LOSSES OF WATER (25 of the 26 months monitored) AND IT APPEARS THESE LAKES
RECHARGE TO THE WATER TABLE. 18 Lake Ladora and Lake Mary also recharge to the groundwater per
the Comprehensive Monitoring Program 1975 -1989. Dec. 1992 pg. -V-.
The alluvia] deposits cross-section are graphically offered in two sections:
EXHIBIT K (with a groundwater flow rate of 192,000 gpd) and EXHIBIT K-l commence at point 02011,1113
(aka:SS2) to 11006 mence to alluvial well point 02026,27,26 (aka£S2'). This cross-section is located immediately
south of Lake Ladora and north of the lake bottom excavation trenches', situate on the section #2 south/section
* 11 north boundary known as Commerce City's 64th Avenue/RMA's 6th Avenue. On the same EXHIBIT K and
K-2, point 02561 to point 01586 (aka:SS4) to point 02052 (akaSSS) to point 01024,25,26 (akarSSl fc SS7). (Note
This cross-section is located between Lake Ladora and Lower Derby situate on the section #2 east/section ffl
west boundary known in Denver as Peoria north extension) mence from alluvial well point 01024,25,26 to aflw
vial well point 12008 to point 01051 to point 01021,22,23 to point 01001 (aka:SS6). This second of two teynMRfe/
cross-sectional planes are located south of Lower Derby and north of the lake bottom excavation trench*'.
situate on the section #1 south/section #12 north boundary known as Commerce City's 64th Avenue/ACA't Afc
Avenue.
Review of these cross-sectionals confirm rgady southern migration pathways pf gajid ftfld gravel. The
the sand subcrop, with variable lateral and vertical hydraulic conductivity 13, runs directly under South
manufacturing complex that can be seen in EXHIBIT L, Plate 2 ( which also identifies additional
to the immediate north of the southern lakes • groundwater table interpositioned).
EXHIBIT M, Figure SSA 1.4-3 demonstrates the position of the coarse gravel and sand interbed* (S«r
EXHIBIT M, Plate WSA 1.4-4) positioned in Eolian deposits with embedded palecohannels situate from to
South Plants /South Lakes running through the southern RMA boundary (deposits of which may run 1
of 130 feet thick 19). The palecohannels are filled with coarse sand and gravel mat can act as conduits I
mination flow 20; however, per the Modified Preliminary i*VSffSSTTIffP* Site Investigation Report for 1
Transferred RMA. Oct. 1994 at Pg3. 2-5jv>t all of the flow is restricted to these channels. Groundwater
occurs over channel divides and through the Denver aquifer as well.
EXHIBIT N, Figure SSA 1.4-2 depicts the southern study area soils configuration showing a soutfvnt
sandy loam gradient with 1-3 percent slopes, south. Testing results indicate that Lower Derby ncharf* *
groundwater and Lake Ladora and Lake Mary receive groundwater in upgradient areas and lose it in
dient areas. The direction of flow (up or down) is probably a more reliable indicator of groundwater flow
conditions man the indicated magnitude of the gradient Interpretations of the vertical distributions at eM
nents is complicated by the heterogeneous nature of the Denver Formation resulting in variable potential
vertical (and horizontal) flow throughout the RMA .21 The heterogeneous nature ... makes chacterizatw
confined flow system (predominantly occurs in permeable sandstone, siltstone and lignite of the un
Denver formation) at the scale of the entire site-difficult. The 1994 ^classification of (59%) the original SS
designated-confined ... is not appropriate for evaluating flow within the confined flow system of RMA
rounding areas. 19 However, the potentiometric surfaces of aquifer zones in the confined flow system -
cates there is a potential for downward flow between the unconfined and confined flow system 19.
Pg.3of4
-------
EXHIBIT O, Figure SSA 1.5-6 sets forth the alluvial aquifer saturated thickness for the southern study
area. EXHIBIT P, Figure 4.4 demonstrates the general downward vertical gradient south of the South
Plants/Southern Lakes toward the southern RMA boundary. EXHIBIT P-l, Plate 5.6-1 is a graphic depiction of
the southern and western migration routes. The regional ground-water flow to the northwest is at an average
hydraulic gradient of about 20 ft./mile ( 0.00379 ft/ft ) to 32 ft/mile ( 0.0061 ft/ft ) per ANNUAL GROUND.
WATER REPORT ffiR 1990 dafgd August 1991: version 1.1 pg.37. or 4/10's of 1% to 6/10's of 1%. The bedrock
surface elevation under South Plants measures 5,270 feet dropping to 5,140 feet in a mile span to Section 11
demonstrating a gradient of 130 ft/mile (0.02462 ft/ft)or approximately 2 1/2% The southern gradient
pathway is as much as 549.6% greater man the northwest gradient (0.00379 ft/ft %change 0.02462 ft/ft.).
EXHIBIT Q, Figure 4.16 re-emphasizes this southern wayward geographic characteristic. [See: EXHIBIT K-
Supplement where South Plants Average Hydraulic Gradient at 'South Plants Study Area southern perimeter
equals 0.01 5 ].
Southern
Contaminents were detected in the water and sediments in the southern sections of sections #11 and
#12. 22 EXHIBIT R, Figure 4-1 and EXHIBIT R-l, Figure 3-1 portray the groundwater and gas analyte detec-
tions. Individual analytes do not occur repeatedly in water entering^RMA (from the southern boundary)per the
FINAL REMEDIAL INVESTIGATION SUMMARY REPORT, Version 32, January 1992 pg. A 3-82.
The topography of sections #11 and #12 contain a dozen wetlands and deep-water habitats of the
United States. South and west of RMA sections #11 & #12 is the City of Denver's new residential and industrial
4,700 acre Stapleton development, including a food storage and distribution center at east 56th and Havana
streets. '
Located immediately south of the RMA sections #11 and #12 lie approximately 2 miles square of the res-
idential community known as Montbello, where recent data indicates live births of low birth weight infants
tend to be clustered in census tracts southwest of the Arsenal where the ratio of black to white females of child-
bearing age (15-44 years) is greater man 1.0. As you move away from this area in any direction, the number of
live births of low birth weight infants and ratio of black to white females of childbearing age decreased" 23
The Army arbitrarily and consistently relies on insufficient data to conclude mat there is no evidence of
contamination or no evidence of a significant migration pathway. The lack of data collected in the Remedial
Investigation (RI) cannot be used as a basis for showing no contamination is present or that a particular pathway
does not pose a significant threat" (State of Colorado comments on DRAFT FINAL REMEDIAL INVESTIGA-
TION REPORT. March 1989; tendered May 1, 1989 pg.3.)
My comments are a call for Environmental lustio given the high probability that South Plants ffifa™-
nation is escaping the southern RMA boundary via groundwater migration - reviewed and supported by
Mr. Snodgrass - Geophysicist with the VS. Bureau of Mines (Copy of his letter dated October 13, 1995 as
EXHIBITS).
The RMA On-Post Operable Unit preferred water alternative fails to address and mitigate the high prob-
ability mat South Plants contamination is escaping the southern RMA boundary.
QiclosuresiEOnBITS A - S
Member RMA Restoration Advisory Board
Member RMA Site Specific Advisory Board
Chairman, South Plants Groundwater Task Force
-------
cc:
United States Environmental Protection Agency
Region Vffl
999 18th Street • Suite 500 Denver, Colorado 80202-2466
Attn: Mr. William P. Yellowtail
Ms. Laura Williams
Mr. Greg Hargreaves
United States Bureau of Mines Denver Research Center Building #20
Denver Federal Center,Denver, Colorado 80225
Attn: Mr. Linden Snyder
Mr. James Snodgrass
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South
Denver, Colorado 80222-1530
Attn: Mr. Thomas Looby
Mr-JeffEdson
Ms. Mary Seawell
State of Colorado
Office of the Attorney General
1525 Sherman Street, 5th Floor
Denver, Colorado 80203
Attn: Ms. Victoria Peters
RMA Restoration Advisory Board
% Ms. Sandra Jaquith, Co-Chairperson
844 Downing Street
Denver, Colorado 80218
RMA Site Specific Advisory Board
% Mr. Rick Warner, Chairperson
894 Dexter Drive
Broomfield, Colorado 80020
Cry of Denver
% Allegra (Happy) Haynes - District #11
4611 East 23rd Avenue
Denver, Colorado 80207
-------
References
1 FINAL DETAILED ANALYSIS OF ALTERNATIVES REPORT, Version 4.0, Executive Summary,
August 1995, Pg.l
2 TECHNICAL SUPORT FOR RMA OFF POST OPERABLE UNIT FINAL RECORD OF DECISION.
September 19,1995, pgs. 6-9
3 FEDERAL FACILITY AGREEMENT, effective February 17,1989, pg. 5 para. 2.7
4 CERCLA, 42 USC 9601(14) Section 101(14)
5 FINAL DETAILED ANALYSIS OF ALTERNATIVES REPORT, Version 4.0, Executive Summary 1^.52
6 SOUTH PLANTS CONTAMINATION SURVEY AND REMEDIAL ACTION ASSESSMENT, March 1995
7 HISTORY OF POLLUTION SOURCES AND HAZARDS AT THE ROCKY MOUNTAIN ARSENAL;
Casinir Kuznear It William L Trautmann, September 1960, pg. 12
8 FINAL REMEDIAL INVESTIGATION REPORT VOL Vm dated July 1989, SOUTH PLANTS STUDY
AREA, pgs. 2-24,2-25
9 FINAL REMEDIAL INVESTIGATION REPORT VOLVm dated July 1989, SOUTH PLANTS STUDY ARFA,
pgs. 2-24,2-25
10 FINAL DETAILED ANALYSIS OF ALTERNATIVES REPORT, WATER DAA, August 1995
I
11 FINAL REMEDIAL INVESTIGATION REPORT VOL Vm
12 FINAL REMEDIAL INVESTIGATION REPORT VOLVI
13 PROPOSED FINAL SOUTH PLANTS/BASIN A GROUNDWATER FLOW MODEL, Dec. 1994 pg. 4-2,1-6 & 54
14 STUDY OF AVIAN MORTALITY ON THREE LAKES AT RMA by George Seiple, Wildlife Research Laboratory
May 28,1952 pg.l
15 COMPREHENSIVE MONITORING PROGRAM, WATER YEAR 1975 to WATER YEAR 1989, Dec. 1992 Pg. 43
16 FINAL REMEDIAL INVESTIGATION REPORT VOLffl. SOUTHERN STUDY AREA, June 1989, Pg. 1-34,1-21,
3-76,3-24 and 1-45
17 FINAL REMEDIAL INVESTIGATION REPORT VOLDL SOUTHERN STUDY AREA, June 1989 Pg. 24
18 FINAL REMEDIAL INVESTIGATION REPORT VOLHL SOUTHERN STUDJAREA, June 1989 Pg. 1-45
19 GROUNDWATER MONITORING PROGRAM, 1993 pp. 2-14-7,4-6, ES-3
20 RECORDS SEARCH LEASED AND TRANSFERRED RMA FAOLmESAND LAND, ATTACHMENT 4, Oct
1994
21 GROUNDWATER MONITORING PROGRAM, 1993 pg. 4-tt and 4-49
22 FINAL REMEDIAL INVESTIGATION REPORT, SOUTHERN STUDY AREA, June 1989 pg. 3-85
23 REPRODUCTIVE, NEUROBEHAVIORAL AND OTHER DISORDERS IN COMMUNITIES SURROUNDING
THE RMA: AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY, Sept. 1,1995 pg. 142
-------
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SECTION 2.0
FIGURES 2.2-1 to 2.7-1
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THE INFORMATION AND CONCLUSIONS PRESENTED IN THIS REPORT REPRESENT THE
, OFFICIAL POSITION OF THE DEPARTMENT OF THE ARMY UNLESS EXPRESSLY MODIFIED IT a
j SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF TIE
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1
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XHIBIT
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RELEVANT PORTION OF THE ADMINISTRATIVE RECORD FOR THIS CERCLA
OPERABLE UNIT.
THE USE OF TRADE NAMES IN THIS REPORT DOES NOT CONSTITUTE AN OFFICIAL
ENDORSEMENT OF APPROVAL OF THE USE OF SUCH COMMERCIAL PRODUCTS. THIS
REPORT MAY NOT BE CITED FOR PURPOSES OF ADVERTISEMENT.
-------
-------
8
L
Prepared for:
U.S. Army Program Manager
for Rocky Mountain Arsenal
Prepared August 1995
PLATE 1
Summed Target Organic Analyte
Plume Map for Unconfined Flow
System
Rocky Mountain Arsenal
Prepared by: Foster Wheeler Environmental Corporation]
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Prepored for:
Progrorh Manager's Office 'or
Rocky Mounlain Arsenal Cleanup
FIGURE: SSA 3.5-1
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Plume in Woler Beoring 2one»
Rocky Mountain Arsenal
-------
•TIC 89166R01
•-'— FIGURES
2KD COPY
FILE COPY
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ROCKY MOUNTAIN ARSENAL
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REMEDIAL INVESTIGATION REPORT
VOLUME VI
SOUTHERN STUDY AREA, FIGURES
VERSION 3.3
June 1989
Contract Number DAAA15-88-D-0024
PREPARED BY
EBASCO SERVICES INCORPORATED
APPLIED ENVIRONMENTAL, INC.
CH2M HILL DATACBEM, INC.
R.L. STOLLAR AND ASSOCIATES
PREPARED FOR:
U.S. ARMY PROGRAM MANAGER'S OFFICE FOR
ROCKY MOUNTAIN ARSENAL CONTAMINATION CLEANUP
THE INFORMATION AND CONCLUSIONS PRESENTED XX HIS REPORT REPRESENT THE
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SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF THE
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E
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-------
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iT-l?~— FIGURES
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TECHNICAL SUPPORT FOR * ^
ROOT MOUNTAIN ARSENAL
Rocky Mountain Arsenal
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Commerc^Jjjty, Colorado
REMEDIAL INVESTIGATION REPORT
VOLUME VI
SOUTEERN STUDY AREA, FIGURES
VERSION 3.3
June 1989
Contract Number DAAA15-S8-D-002&
PREPARED BT
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APPLIED ENVIRONMENTAL, INC.
CB2M BILL DATACEEM, INC.
R.L. STOLLAR AND ASSOCIATES
PREPARED FOR:
U.S. ARMT PROGRAM MANAGER'S OPTIC! FOR
ROCK! MOUNTAIN ARSENAL CONTAMINATION CLEANUP
TEE INFORMATION AND CONCLUSIONS PRESENTED IN THIS REPORT REPRESENT THE
OFFICIAL POSITION OF TBE DEPARTMENT OF THE ARMT UNLESS EXPRESSLT MODIFIED BY A
SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF THE
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89166R01
FIGURES
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TECHNICAL SUPPORT FOR
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r
(~ Rocky Mountain Arsenal
Information Center
Commerce, City, Colorado
11NAL
REMEDIAL. INVESTIGATION REPORT
VOLUME VI
SOUTHERN STUDY AREA, FIGURES
VERSION 3.3
June 1989
Contract Number DAAA15-88-D-002A
PREPARED BY
EBASCO SERVICES INCORPORATED
APPLIED ENVIRONMENTAL, INC.
CB2M BILL DATACBEM, INC.
R.L. STOLLAR AND ASSOCIATES
PREPARED FOR:
U.S. ARMY PROGRAM MANAGER'S OFFICE FOR
ROCKY MOUNTAIN ARSENAL CONTAMINATION CLEANUP
THE INFORMATION AND CONCLUSIONS PRESENTED IN THIS REPORT REPRESENT THE
OFFICIAL POSITION OF THE DEPARTMENT OF THE ARMY UNLESS EXPRESSLY MODIFIED BY A
SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF THE
ADMINISTRATIVE RECORD FOR THIS CERCLA OPERABLE UNIT.
-------
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-------
89166RG4
SECTION 3.0
TABLES AND FIGURES
trie
TECHNICAL SUPPORT FOR
ROCKY MOUNTAIN ARSENAL
8
OFILECOPY
Rocky Mountain Arsenal
Information Center
Commerce City, Colorada
FINAL
REMEDIAL INVESTIGATION REPORT
VOLUME VIII
SOUTH PLANTS STUDY AREA
SECTION 3.0
TABLES AND FIGURES
VERSION 3.3
Julj 1989
Contract No. DAAA15-8S-D-0024
Prepared by:
E1ASCO SERVICES INCORPORATED
APPLIED ENVIRONMENTAL, INC.
CB2M HILL DAIACBEM, INC.
R.L. STOLLAR AND ASSOCIATES
Prepared for:
U.S. AXMT PROGRAM MANAGER'S OFFICE
FOR ROCKY MOUNTAIN ARSENAL CONTAMINATION CLEANUP
INFORMATION AND CONCLUSIONS PRESENTED IN THIS REPORT REPRESENT THE
OFFICIAL POSITION OF THE DEPARTMENT OF THE ARMY UNLESS EXPRESSLY MODIFIED II A
SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF THE
ADMINISTRATIVE RECORD FOR THIS CERCLA OPERABLE UNIT.
USE OF TRADE NAMES IN THIS REPORT DOES NOT CONSITUTS AN OFFICIAL
ENDORSEMENT OR APPROVAL OF THE USE OF SUCH COMMERCIAL PRODUCTS. THE RE?OtT
"A* NOT BE CITED FOR PUROSES OF ADVERTISEMENT.
^'WJ'T'jT K-Supplo-e**-
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FINAL-"
REMEDIAL INVESTIGATION REPORT
- VOLUME VI
SOUTHERN STUDY AREA, PLATES
'• VERSION 3.3
June 1989
Contract Number DAAA15-88-D-0024
IT:
PREPARED BY
EBASCO SERVICES INCORPORATED
APPLIED ENVIRONMENTAL, INC.
CB2M BILL DATACHEM, INC.
R.L. STOLLAR AND ASSOCIATES
PREPARED FOR:
U.S. ARMY PROGRAM MANAGER'S OFFICE FOR
ROCKY MOUNTAIN ARSENAL CONTAMINATION CLEANUP
THE INFORMATION AND CONCLUSIONS PRESENTED. IN THIS REPORT REPRESENT THE
OFFICIAL POSITION OF THE DEPARTMENT OF THE ARMY UNLESS EXPRESSLY MODIFIED I
SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF THE
ADMINISTRATIVE RECORD FOR THIS CERCLA OPERABLE UNIT. , .
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89166R01
PLATES
2KD COPY
FILE COPY
TECHNICAL SUPPORT FOR
ROCKY MOUNTAIN ARSENAL
Rocky Mountain Arsenal
Information Center
Commerce City, Colorado
FINAL""
REMEDIAL INVESTIGATION REPORT
VOLUME VI
SOUTHERN STUDY AREA, PLATES
VERSION 3.3
June 1989
Contract Number DAAA15-88-D-0024
r
=.~ PREPARED BY
EBASCO SERVICES INCORPORATED
APPLIED ENVIRONMENTAL, INC.
CB2M HILL DATACHEM, INC.
R.L. STOLLAR AND ASSOCIATES
PREPARED FOR:
U.S. ARMY PROGRAM MANAGER'S OFFICE FOR
ROCKY MOUNTAIN ARSENAL CONTAMINATION CLEANUP
:i>-
THE INFORMATION AND CONCLUSIONS PRESENTED IN THIS REPORT REPRESENT THE
OFFICIAL POSITION OF THE DEPARTMENT OF THE ARMY UNLESS EXPRESSLY MODIFIED BY A
SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF THE
ADMINISTRATIVE RECORD FOR THIS CERCLA OPERABLE UNIT.
-------
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TECHNICAL SUPPORT FOR A U-il-rf WWr' X
ROCKY MOUNTAIN ARSENAL
Rocky Mountain Arsenal
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Commerc^fjty, Colorado
REMEDIAL INVESTIGATION REPORT
VOLUME VI
SOUTHERN STUDY AREA, FIGURES
VERSION 3.3
June 1989
Contract Number DAAA15-88-D-002A
PREPARED BY
EBASCO SERVICES INCORPORATED
APPLIED ENVIRONMENTAL, INC.
CB2M HILL DATACHEM, INC.
R.L. STOUAR AND ASSOCIATES
' PREPARED FOR:
U.S. ARMY PROGRAM MANAGER'S OFFICE FOR
ROCKY MOUNTAIN ARSENAL CONTAMINATION CLEANUP
THE INFORMATION AND CONCLUSIONS PRESENTED IN THIS REPORT REPRESENT THE
OFFICIAL POSITION OF THE DEPARTMENT OF THE ARMY UNLESS EXPRESSLY MODIFIED BY A
SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF THE
ADMINISTRATIVE RECORD FOR THIS CERCLA OPERABLE UNIT.
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-------
-------
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P U ||HII1 2ND COPY
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I _ ROCKY MOUNTAIN ARSENAL
f^ Rocky Mountain Arsenal
„ Information Center
I - Commerc^ity, Colorado
I ---
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REMEDIAL INVESTIGATION REPORT
VOLUME VI
SOUTHERN STUDY AREA, FIGURES
VERSION 3.3
June 1989
P"" Contract Number DAAA15-88-D-0024
PREPARED BY
EBASCO SERVICES INCORPORATED
APPLIED ENVIRONMENTAL, INC.
CE2M HILL DATACHEM, INC.
R.L. STOLLAR AND ASSOCIATES
PREPARED FOR:
U.S. ARMY PROGRAM MANAGER'S OFFICE FOR
ROCKY MOUNTAIN ARSENAL CONTAMINATION CLEANUP
THE INFORMATION AND CONCLUSIONS PRESENTED IN THIS REPORT REPRESENT THE
OFFICIAL POSITION OF THE DEPARTMENT OF THE ARMY UNLESS EXPRESSLY MODIFIED IT A
SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF Til
ADMINISTRATIVE RECORD FOR THIS CERCLA OPERABLE UNIT.
-------
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-------
89166R01
tT'-— FIGURES
2KD COPY
TECHNICAL SUPPORT FOR A iLu-' ^v-/£* 1
ROCKY MOUNTAIN ARSENAL
Rocky Mountain Arsenal
Information Center
Commerc^ity, Colorado
REMEDIAL INVESTIGATION REPORT
VOLUME VI
SOUTHERN STUDY AREA, FICURES
VERSION 3.3
June 1989
Contract Number DAAA15-88-D-0024
PREPARED BY
EBASCO SERVICES INCORPORATED
APPLIED ENVIRONMENTAL, INC.
CH2M HILL DATACHEtt, INC.
R.L. STOLLAR AND ASSOCIATES
PREPARED FOR:
U.S. ARMY PROGRAM MANAGER'S OFFICE FOR
ROCKY MOUNTAIN ARSENAL CONTAMINATION CLEANUP
THE INFORMATION AND CONCLUSIONS PRESENTED IN THIS REPORT REPRESENT THE
OFFICIAL POSITION OF THE DEPARTMENT OF THE ARMY UNLESS EXPRESSLY MODIFIED BY A
SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF THE
ADMINISTRATIVE RECORD FOR THIS CERCLA OPERABLE UNIT.
-------
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Scale In Feet
2000
2000
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Seel* m Feet
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Prepared for:
Program Manager for
Rocky Mountain Arstnol
Contamination Cleanup
PLATE 5.6 - 1
Integrated Soil and Groundwater
Contaminant Distribution
Rocky Mountain Arsenal
Prepared by: £bo»co Services Incorporated
-------
Explanation
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Prognm Mmiptr for
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Commaroa City, Colorado
Prepared toy:
Harding Lawson Associates
Figure 4.16
Generalized Vertical Gradient
Contour Map.
Water Year 1993
GWAft FY93
-------
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October 13, 1995
Mr. John Velenick
3650 South Dahlia
Denver, CO 80237-1002
Dear Mr. Yelenick:
Thank you for discussing your project at the Rocky Mountain Arsenal (RMA)with me in July. At
the time, I was interested in pursuing a cooperative agreement for the Bureau of Mines to utilize
the RMA she for our research in geophysical characterization of contaminated mine and mill sites.
A preliminary assessment of the RMA, and review of the data available for the area in sections 11
and 12 south of the South Plant indicated that a fairly complex hydrologic regime exists in the
area, and that there is a high probability that contamination is escaping the RMA boundary in a
southerly direction. This conclusion is drawn based on the following documented information
you provided:
1. Contamination in the area of the South Plant increased significantly from the period
1979-1983 to the period 1988-1989, even though the plant was inactive.
2. Disposal ponds at the South Plant are unlined, resting on permeable alluvium at >
groundwater level in the unconfined aquifer.
3. Contaminants were detected and theorized into sections 11 and 12 in 1989, and more
recently at the southern boundary of the RMA.
4. A plume to the southwest of South Plant is documented, in addition to the
groundwater "mound" existing under South Plant which causes radial flow in all
directions.
5. While most sampling of soils and groundwater have been in the upper unconfined
aquifer, contamination has also been found in the "A" sand beneath the South Plant
central processing area.
6. Paleochannels of permeable sand occuring in the area are not well defined, and may be
influencing groundwater flow, as well as the connectivity of the upper and lower acquifers.
The aquhard above the "confined" acquifer may have been scoured allowing
communication between the upper and lower aquifers.
7. Indications from recent studies (1994) indicate that ground-water flow occurs over
channel divides (ridges) and through the lower Denver aquifer as well.
8. As recently as March of this year, the limited well coverage was insufficient to evaluate
flow within the confined aquifer.
-------
As I indicated to you in our discussions, my work for the Bureau of Mines has applied non-
destructive surface geophysical surveys to map the ground-water channeling at mine waste sites. I
have discussed the relevant aspects of the RMAmentioned above with hydrologists and geologists
at the Denver Research Center of the Bureau of Mines who concur that there is a high potential
for contamination of groundwater off the south boundary of RMA from sources in the South
Plant Area. Since the Federal Facility Agreement requires that groundwater quality at the RMA
boundary must be protective of off-post receptors, h is recommended that the area south of the
South Plant in sections 11 and 12 be evaluated to determine the source of contaminants measured
at the southern boundary in the unconfined aquifer. The deeper confined aquifer in the Denver
formation should also be sampled to detennine if, and to what extent the two aquifers are in
communication and whether contaminants are escaping the RMA in the lower ground-water
system.
I would recommend an integrated geophysical survey in sections 11 and 12 similar to the work
performed by John Nicholl, Jr. and Kathryn Cain (Proceedings, SAGEEP *92, v.l) in the
Northwest Boundary Containment System. Interpretation of such surveys will provide a better
model of the subsurface geohydrologic regime and determine the best locations for monitoring
wells to intercept possible ground-water migratory pathways.
You may not be aware that my agency has been abolished and is scheduled for closure within 90
days from October 1. This is unfortunate since I feel that we had some unique resources to use in
a geophysical characterization project such as yours; however, a cooperative effort is not feasible
with the Bureau of Mines at this time. I would be happy to discuss or elaborate on my
recommendations for additional characterization of migratory ground-water pathways at RMA.
Please feel free to call me at 236-0777 x691.
Sincerely,
- ??<•
James J. Snodgrass
/ Geophysicist
11671 W. Asbury PI.
Lakewood, CO 80228
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James J. Soodgrass
Environmental Geophysicist
11671 W. Asbury Place
Lakewood, CO 80228
Daytime: (303) 236-0777 x691 Evening: (303) 986-1868
Objective
Position as Geophysicist or Consultant in an organization responsible for environmental site
characterization and remediation planning.
Career Summary
My most recent efforts for the US Bureau of Mines developed near-surface geophysical methods
to charaaerize abandoned mine wastes for remediation planning. I completed the required OSHA
training for hazardous waste workers; consequently, my specific area of interest and expertise is
the interpretation of hydrologic and geologic conditions at contaminated sites. Prior experience
with the US Bureau of Mines entailed management of projects to develop and apply geophysical
methods for mineral exploration, and for remote detection of geologic hazards. After graduation
and command service in the Corp of Engineers, I entered private industry as a geophysicist with a
seismic exploration contractor, attaining the position of Assistant Party Chief on a seismic crew,
and enhancing my qualifications to conduct theoretical and applied research.
Experience
Geophvsicist- June. 1974 to Present
US Bureau of Mines, Denver Research Center
• Principle Investigator for the project "Geophysical Methods to Characterize Minerals-
Related Hazardous Waste Sites."
• Conceived, planned, and conducted research and applications for development of
geophysical methods to characterize mine wastes.
• Interpreted geologic and hydrologic parameters for successful long-term remediation
projects.
• Developed and demonstrated integrated geophysical approach to effect cost-efficient
drilling and sampling programs.
• Developed theoretical and physical models to interpret guided wave propagation in coal
seams.
• Developed a mine-transportable digital data acquisition system to implement seismic
surveys in underground coal mines.
• Developed and demonstrated use of shear-wave sources and detectors for coal mine
EXHIBIT
-------
seismic surveys.
• Established feasibility of in-seam seismic methods at operating underground coal mines.
• Developed and demonstrated a borehole radar probe to remotely locate faults.
• Developed a cross-borehole seismic system for application to coal exploration.
• Planned and coordinated field studies to demonstrate mining applications of borehole
geophysical techniques.
Qeophysicist- October. 1970 to June. 1974
US Bureau of Mines, Twin Cities Research Center
• Designed and implemented studies to determine seismic effects of underground mine
blasting.
• Recorded ground vibrations from underground blasting; reduced and analysed data to
correlate blasting parameters with experimental results.
Temporary Assistant-June. 1970 to October. 1970
US Bureau of Mines, Intermountain Field Operations Center
• Conducted mineral investigadons in wilderness and primitive areas, including mapping,
sampling, and records search and documentation
Assistant Party Chief-January. 1967ioMav. 1970
Geophysical Service.lnc.
• Established data quality assurance, determined processing parameters, and interpreted
seismic surveys for oil exploration.
Combat Engineer Small Unit Commander- October. 1963 to October. 1966
• Platoon Leader and Company Commander of units responsible for engineering
construction and support.
Education
Colorado School of Mines B.S.- Geophysical Engineer
Other Qualifications
1990* OSHA-required 40-hour training for hazardous waste workers
EXHIBIT
-------
Publications
1. Snodgrass, JJ. and C.M. Lepper, 1993, Geophysical Characterization of Mineral Waste Sitgg.
Proc. 15th Ann. Mtg. Assoc. of Abandoned Mine Lands Programs, Jackson, WY.
2. Snodgrass, J J., and D.L. Boreck, 1993, Rock Mass Characterization using Geophysics for
Stope Leaching. Proc. SAGEEP. San Diego, CA.
3. Snodgrass, J J., 1989, Sonic Full-Waveform Applications to Stress Evaluation in Coal Mines.
Proc. 3d Int. Symp. on Borehole Geophysics, Las Vegas, NV.
4. Snodgrass, J J. and Newman, D.A., 1985, An In Situ Technique for the Assessment of Failun?
in Coal Pillars. Proc. 26th US Symp. on Rock Mech., Rapid City, SD.
5. Snodgrass, J.J., 1985, In-Seam Seismic Surveys Using Controlled-Waveform Source
Transducers. Mining Engineering, SME-AIME, April.
6. , 1984. In-Seam Seismic Surveys Using Controlled-Waveform Source
Transducers. SME-AIME Preprint No. 84-420.
7. Leckenby, RJ., and J.J. Snodgrass, 1984, In-Seam Geophysical Techniques for Coal Mine
Hazard Detection. In Mine Ground Control, Bureau of Mines Information Circular 8973.
8. Snodgrass, J.J., and S.A. Suhler, 1983, In Situ Electromagnetic Probing of Coal Seams.
SME-AIME Preprint No. 83-356.
9. Snodgrass, J.J., 1982, A New Sonic Velocity Logging Technique and Results in Near-Surface
Sediments of Northeastern New Mexico. Bureau of Mines Technical Progress Report 117.
10. Snodgrass JJ., 1981. Drv Sonic Probe for Logging Coal and Roof Properties. Bureau of
Mines Technology News No. 114.
11. Snodgrass JJ., 1981. Development of an Engineering Model Borehole Radar System for
Void and Fault Detection. Proc. Symp. on Tunnel Detection, Colorado School of Mines, Golden
CO.
12. Snodgrass, JJ., 1976, Calibration Models for Geophysical Borehole Logging. Bureau of
Mines Report of Investigations 8148.
13. Snodgrass, JJ., and D.E. Siskind.1974, Vibrations from Underground Blasting. Bureau of
Mines Report of Investigations 7937.
14. Snodgrass, J J., and D.E.Siskind, 1974, Bureau of Mines Research on Vibrations from
Underground Blasting. Proc. 2d Rapid Excavation and Tunneling Conference, San Francisco, CA.
EX
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15. Condon, J.L., and JJ. Snodgrass, 1974. Effects of Primer Type and Borehole Diameter on
AN-FO Detonation Velocities. Mining Congress Journal.
16. Siskind, DJE., JJ. Snodgrass, R.A. Dick, and J.N. Quiring, 1973. Mine Roof Vibrations from
Underground Blasts. Pilot Knob, M$. Bureau of Mines Report of Investigations 7764.
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DEPARTMENT OF THE ARMY
PROGRAM MANAGER !-'OR ROGk'Y MO! STAIN' AKMiNA!
CITY, i -oLOR APO sv:: • :•»>
REPLY TO
ATTENTION OH:
June 11, 1996
Office of the Program Manager
Mr. John J. Yelenick
3650 South Dahlia
Denver, Colorado 80237-1002
Dear Mr. Yelenick:
Thank you for your comments on the Rocky Mountain Arsenal (RMA) On-Post Proposed
Plan. Public input is an important component of the remediation process, and your participation
helps maintain the dialogue between the U.S. Army and the public.
In response to your letter of December 12, 1995, regarding an alternative water supply,
the Army and Shell Oil Company have reached an Agreement in Principle, enclosed with these
responses, with South Adams County Water and Sanitation District (SACWSD) that includes
payment of $48.8 million to SACWSD and requires that SACWSD supply water to well owners
within the diisopropyl methylphosphonate (DIMP, an RMA byproduct) plume footprint by
January 1999. Connection of any future well owners to the SACWSD water supply requires that
the DIMP level in their water source be above the state standard. No exposure pathways to
DIMP other than drinking water have been identified as a concern to human health. In addition,
the Agreement in Principle requires SACWSD to provide 4,000 acre-feet of water to Commerce
City and the Henderson area by 2004. The parties involved in the water negotiations believe that
the settlement is fair and will permit SACWSD to secure an adequate water supply to satisfy
Commerce City's and Henderson's water needs. If you have any further questions regarding the
water supply, please contact
Mr. Tim Kilgannon of this office at 303-289-0259 or Mr. Larry Ford of SACWSD at
303-288-2646.
Responses to your comments in your letter of December 13, 1995, are enclosed.
Readiness is our Profession
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-2-
If you have any additional questions or concerns regarding the RMA On-Post Proposed
Plan, please direct them to Mr. Brian Anderson of this office at 303-289-0248. Thank you again
for your comments.
Sincerely,
Eugene/H. Bishop
Colonel, U.S. Army
Program Manager
Enclosures
Copies Furnished:
Captain Thomas Cook, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022-1748
Mr. Robert Foster, U.S. Department of Justice, 999-18th Street,
Suite 945, North Tower, Denver, Colorado 80202
Program Manager Rocky Mountain Arsenal, Attn: AMCPM-RMI-D, Document Tracking
Center, Commerce City, Colorado 80022-1748
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RESPONSES TO COMMENTS BY MR. JOHN J. YELENICK ON THE
ROCKY MOUNTAIN ARSENAL ON-POST PROPOSED PLAN
The Army appreciates your level of interest and effort in commenting on the On-Post Proposed
Plan for RMA. The regional flow of ground water, both in the shallow (unconfined) and deeper
(confined) flow systems is from southeast to northwest. The volume of shallow groundwater
flow crossing the southern boundary of RMA and flowing on-post is approximately 2,000 gallons
per minute (gpm). The central part of RMA, including South Plants, is a topographically and
hydrologically high area where all of the shallow groundwater flow is derived from within the
central area and feeds into this regional flow. Within the central sections of RMA (i.e., 1, 2, 25,
26, 35, and 36) the total amount of groundwater flow is less than 50 gpm. The South Plants
groundwater mound is a result of recharge on the topographic high in the bedrock. Groundwater
flow associated with the South Plants mound is only about 10 to 20 gpm. Of this flow, only
about 10 gpm flows south within Sections 1 and 2. This southward flow mixes with the much
higher regional flow in the vicinity of the South Lakes and then flows toward the west and
northwest boundaries.
Many statements made in your comments are correct and have been reported in whole or in part
in previous reports prepared by the Army and Shell. However, due to several omissions in your
conceptual model for groundwater flow, the final conclusion that groundwater flows off Rocky
Mountain Arsenal to the south is incorrect.
For ease of comparing this response to your December 13, 1995, letter, the following responses
reference the applicable page and paragraph of your letter.
Page 1, last paragraph: The comment has misstated the definition of high, low, and
uncontaminated site types as discussed in the RMA On-Post Detailed Analysis of Alternatives and
the Proposed Plan. High priority sites are those that had an established record of groundwater
contamination beneath or near the site and that had few records concerning soil contamination In
these cases, groundwater had already been contaminated, and additional testing was necessary to
learn more about the contamination source. Low priority sites had no records of either soil or
groundwater contamination, due to lack of study, but were considered potentially contaminated
based on records of spills and/or waste disposal at the site Uncontaminated sites were those that
could possibly have been contaminated due to their physical nature but for which preliminary
investigation revealed no reason to suspect contamination The uncontaminated designation was
not dependent upon whether a responsible party could be identified.
Page 2, first paragraph: As a general rule, soil samples were collected from above the water
table regardless of the site type designation. The sampling approach was developed by geologic,
chemical and other environmental experts from around the United States. Samples were not
generally taken from below the water table because it would be difficult to distinguish between
soil and groundwater contamination by using this approach For sites where wastes were
disposed below the water table (e.g., burial trenches in Section 36), soil samples were collected
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from the saturated zone. The relationship between the amount of contaminants present in
groundwater, pore water, and aquifer soils was studied in a special investigation. The results of
the study were used to assess potential contaminant pathways and transport mechanisms.
All sites were investigated regardless of their site type designation as high, low, or
uncontaminated. The designation was used to compute a grid spacing or boring density for each
site.
Page 2, third paragraph: The southerly flow of groundwater as shown on your Exhibit F
terminates in the vicinity of Lower Derby Lake and Lake Ladora. The reason for this termination
is discussed below in the response to Page 4, first paragraph.
Page 2, fifth paragraph: Your Exhibit J delineates potentially contaminated soil in the lake
areas. It is not clear from your comment how you believe the lake sediment contamination is
related to the contaminant levels present in groundwater upgradient in the South Plants Central
Processing Area. No groundwater plumes associated with the lakes or excavated lake sediments
have been detected. For clarification, the South Plants Central Processing Area is located in the
northwest corner of Section 1, and it is beneath this area that elevated concentrations of
contaminants occur in the groundwater (as you note in your comment). It is also in this area
where groundwater contaminants have been detected in the A sand in the Denver Formation.
Page 2, sixth paragraph: There is no uninterrupted sequence of thick saturated alluvium that
forms a pathway between the South Plants and the southern lakes, as you suggest. Saturated
portions of the alluvium comprise a portion of the unconfined aquifer in the South Plants area.
The weathered portion of the Denver Formation is also part of the unconfined aquifer. In some
portions of the South Plants, the alluvial cover is very thin or has been removed. In many areas of
South Plants, the alluvium is unsaturated; that is, the water table is below the bottom of the
alluvium, and the groundwater flows at very slow rates within the Denver Formation.
Page 2, seventh paragraph: As a clarification to your comment, the permeability of the lake
bottom affects the interchange between the surface water and the unconfined aquifer rather than
the interchange between the unconfined and confined aquifers.
Page 3, first paragraph: The Army agrees that various estimates of the volume of contaminated
soils have been computed for all source areas. This has largely been due to using different
"depths of contamination" as the basis for the estimates (e.g., 5 feet, 10 feet, 15 feet). Regardle>>
of the contaminant volume estimates for South Plants, however, this area has always been
considered a source of groundwater contamination by scientists investigating RMA.
The preferred remedy of landfilling and covering/capping materials in the South Plants addresses
all of the contamination of concern in the area. The volume of soil addressed by the remedy can
be presented differently depending on the depth used for calculating the volume to be covered/
capped.
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Page 3, second paragraph: The lakes receive water from irrigation flows, surface runoff as a
result of precipitation, and groundwater discharge. The lakes also recharge the unconfmed
aquifer. Some lake water evaporates. Chemical analyses of lake water have shown that the lake
water is uncontaminated. Therefore, leakage of water from the lakes contributes clean water to
the unconfined aquifer. The lake sediments became contaminated because certain compounds
adhered to soil particles in South Plants that were washed into the lakes during rainstorms.
Because these compounds adhere to the sediments, it is unlikely that contamination in these
sediments will create groundwater plumes.
Page 3, fourth paragraph: The southerly groundwater flow has been well-established in
numerous reports prepared by the Army. This pathway stops in the vicinity of the lakes. Please
see the response to Page 4, first paragraph, below. Your Exhibit L shows the area where the A
sand subcrops to the alluvium, which is approximately one-quarter to one-half mile north of the
South Plants.
Page 3, fifth paragraph: Alluvial deposits with thicknesses of slightly more than 100 feet are
present south of the lakes. The 13 0-foot-thick deposits to which you refer are in the Irondale
Channel on the west RMA border. The saturated thickness of the alluvial deposits is slightly more
than 60 feet in some areas of the southern sections of RMA. It is true that groundwater flow is
not always restricted by buried channels, or paleochannels, and that groundwater may flow over
channel divides; therefore, the water table elevations give the most accurate picture of
groundwater flow direction.
Page 3, last paragraph: Groundwater flows from points of higher elevation or hydraulic
pressure to points of lower elevation or hydraulic pressure, which is often called hydraulic head
The hydraulic gradient is the difference in head (or elevation) between two points, divided by the
distance between the two points. As you suggest in your comment, the hydraulic gradient must
be evaluated by hydrogeologists as a three-dimensional problem. Long-term monitoring has
shown that contamination in the confined Denver Formation is restricted to the major source
areas and underlies contaminated unconfined groundwater plumes. Because it is difficult to install
a deep well through shallow contaminated zones, some of the contamination in the Denver
Formation was introduced when wells were installed. This contamination is low in concentration
and very limited in extent. There is no evidence of contaminant plumes in the confined flow
system. Contaminant studies in one of the most permeable Denver Formation units (the A sand)
that lies beneath a large source (South Plants) have shown that, even in this unit, contamination is
localized and is not widespread.
Page 3, last paragraph, last sentence: The exchange of water between the unconfined and
confined aquifers has been studied and numerically (computer) modeled numerous times during
the past ten years. Throughout many areas of RMA, groundwater from the unconfined aquifer
recharges the confined aquifer through vertical leakage. There is no evidence of lateral migration
of contamination in the confined aquifer. Even if this were to occur, the strata of the Denver
Formation are slightly dipping to the southeast so that as one travels from the southern portions
-------
of RMA toward the Platte River, older and lower sections of the geologic column are crossed.
Because the bedrock erosional surface drops toward the Platte River, it cross-cuts the Denver
Formation, exposing'successively deeper and deeper levels of the Denver Formation to the base of
the alluvium. The result is that water in a permeable Denver zone eventually discharges into the
alluvium on its way to the Platte River. For example, water in the A sand occurs at a depth of
about 80 feet beneath the South Plants. This water discharges to the alluvium in Section 36 in the
A sand subcrop area, which is located approximately one-quarter mile north of South Plants (see
your Exhibit L).
Page 4, first and second paragraphs: This paragraph describes aquifer thickness, vertical
gradients, regional hydraulic gradient, and the slope of the bedrock surface. Although you do not
state how these features affect groundwater flow, it appears that this was your intent. Therefore,
some of the concepts that pertain to these features are summarized below.
• Aquifer Thickness: A thicker aquifer can transmit more water than a thin aquifer can
if the hydraulic gradients and the permeabilities of the thick and thin aquifers are the same.
Hydraulic gradients are lower in areas where the aquifer is thick and higher where the
aquifer is thin. Considering hydraulic gradient as the "driving force" behind groundwater
flow, it takes more driving force to push an equal amount of water through a thin aquifer
than through a thick aquifer. Variations in the aquifer thickness cause local changes in the
groundwater flow directions, but groundwater cannot flow upgradient.
• Vertical Gradient: Vertical gradient data indicate whether groundwater is moving
upward or.downward in addition to its regional flow direction, such as toward the South
Platte River. Downward gradients predominate in areas of groundwater recharge, and
upward gradients indicate areas of groundwater discharge.
If a well was installed in the South Platte River, it would show an upward gradient,
indicating that groundwater was feeding or recharging the river. It is because of this
groundwater discharge that the river can flow even during dry periods with little or no
rain.
• Regional Hydraulic Gradient: The elevation of the water table in the southeast corner
of RMA is approximately 5300 feet above mean sea level (ft M.S.L.), and the elevation of
the water table at the South Platte River is approximately 5000 ft M.S.L. Therefore,
groundwater flows "downhill" from the southeast corner of RMA toward the South Platte
River. Superimposed on the regional gradient is a groundwater mound in the South
Plants. The mound is created by leaking pipes and increased recharge from unlined
ditches and ponded areas, and may also be the result of natural variations in the
permeability of the alluvium and bedrock in the area. Groundwater in the area of the
mound flows radially out from the mound in all directions. A groundwater divide has been
created at the confluence of the regional flow system and the mound. As a result,
groundwater entering RMA from the southeast is forced to turn either east or west around
-------
the South Plants area. Water flowing south from the mound area is forced to change
direction and join the regional flow system. The groundwater flow direction in the
confined Denver Formation is also to the northwest toward the South Platte River.
• Bedrock Slope: The sloping surface of the bedrock forms the bottom of the alluvial
aquifer. Groundwater flow directions are determined by the slope of the groundwater
table (top of the aquifer) and not by the slope of the base of the aquifer. As stated above,
the thickness of the aquifer, which is controlled in some areas by the topography of the
bedrock surface, can locally alter the groundwater flow direction. However, variations in
the bedrock surface do not turn groundwater around to flow uphill against the regional
gradient.
Because of the factors reviewed above, it is clear that groundwater cannot flow upgradient
(southward) from the southern boundary of RMA. Groundwater flow southward from RMA is
physically impossible.
Page 4, third through fifth paragraphs: The Army understands your concerns about the health
of residents in neighboring communities regardless of whether the contamination is ensuing from
RMA. The effects on human health of many of the compounds produced at RMA have been
studied for many years, and this information is available at the Joint Administrative Record
Document Facility (JARDF). Studies have been completed by the Agency for Toxic Substances
and Disease Registry (ATSDR) independently and in conjunction with the Colorado Department
of Public Health and Environment (CDPHE). These studies showed no conclusive health impact
on the surrounding communities from RMA. Also, the final Public Health Assessment, produced
by ATSDR, should be complete in the summer of 1996.
A Medical Monitoring Program for the communities surrounding RMA has also been identified as
part of the On-Post Proposed Plan. The primary goals of the Medical Monitoring Program are to
monitor any off-post impact on human health due to the RMA remediation. This Program will
continue until the soil remediation is completed. A Medical Monitoring Advisory Group has been
established to evaluate specific issues covered by the Medical Monitoring Program. The Group is
composed of representatives of the Army, Shell Oil Company, the U.S. Environmental Protection
Agency (EPA), CDPHE, Tri-County Health Department, ATSDR, the U.S. Fish and Wildlife
Service (USFWS), Denver Health and Hospitals, and the Site-Specific Advisory Board. The
Group also includes community representatives from the communities of Montbello, Commerce
City, Henderson, Green Valley Ranch, and Denver. If you would like more information on the
Medical Monitoring Program or wish to participate as part of the Medical Monitoring Advisory
Group, please call Ms. Mary Seawell of CDPHE at 303-692-3327.
Page 4, sixth paragraph: The Army has collected and analyzed thousands of soil, water, air,
structure, and biota samples during the past many years and believes it has adequately
characterized the nature and extent of contamination at RMA.
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Page 4, seventh and eighth paragraphs: The Army believes that the selected remedy is
consistent with the policies and guidelines pertaining to environmental justice. The selected
remedy is protective of human health and the environment.
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AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SDC MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
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WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
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G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
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AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. -"
K, PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WELL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
O. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION i, ABOVE.
version 10-26/01/96
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Appendix A
Applicable or Relevant and Appropriate
Requirements and Information
To Be Considered
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Appendix A
Table of Contents
Section Page
List of Tables A-iii
List of Acronyms and Abbreviations A-v
Statutory Citations A-ix
A.1.0 Introduction A-1
A.2.0 Chemical-Specific Requirements A-3
A.2.1 Groundwater and Surface Water Requirements A-3
A.2.2 Chemical-Specific Requirements for Soil A-7
A.2.3 Chemical-Specific Requirements for Structures A-7
A.2.4 Chemical-Specific Requirements for Air A-8
A.3.0 Location-Specific Requirements A-8
A.4.0 Action-Specific Requirements A-10
A.5.0 Other Potential Requirements A-11
A.6.0 References A-18
A.7.0 Tables A-21
A-i
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A-ii
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List of Tables
Table
A-l List of Rocky Mountain Arsenal Target Constituents Addressed by the Groundwater Monitoring Program
A-2 List of Rocky Mountain Arsenal Target Constituents Addressed by the Surface Water Monitoring Program
A-3 ARARs for Groundwater for Northwest Boundary Containment System
A-4 ARARs for Groundwater for Irondale Containment System
A-5 ARARs for Groundwater for North Boundary of Rocky Mountain Arsenal
A-6 ARARs for Groundwater at Basin A Neck IRA Treatment System
A-7 TBCs for Groundwater
A-8 ARARs for Surface Water
A-9 TBCs for Surface Water
A-10 TBCs for Soil and Sediments
A-l 1 Location-Specific ARARs and TBCs
A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
A-13 Action-Specific ARARs and TBCs for Stockpiles of Debris/Equipment from Structures
A-14 Action-Specific ARARs and TBCs for Demolition of Structures
A-15 Action-Specific ARARs and TBCs for Trenches
A-16 Action-Specific ARARs and TBCs for Caps/Covers
A-17 Action-Specific ARARs and TBCs for Concrete Liners
A-18 Action-Specific ARARs and TBCs for Slurry Walls
A-19 Action-Specific ARARs and TBCs for Hazardous Waste Landfills
A-20 Action-Specific ARARs and TBCs for Thermal Desorption
A-21 Action-Specific ARARs and TBCs for Incineration/Pyrolysis
A-22 Action-Specific ARARs and TBCs for Off-Post Incineration of Structural Materials
A-23 Action-Specific ARARs and TBCs for Soil Heating
A-24 Action-Specific ARARs and TBCs for In Situ Vitrification
A-25 Action-Specific ARARs and TBCs for Hot Gas Decontamination of Structures and Debris
A-26 Action-Specific ARARs and TBCs for UXO Demilitarization/Chemical Agent Decontamination
A-27 Action-Specific ARARs and TBCs for Direct Solidification/Stabilization
A-28 Action-Specific ARARs and TBCs for In Situ Solidification/Stabilization
A-29 Action-Specific ARARs and TBCs for Biological Reactor Treatment
A-30 Action-Specific ARARs and TBCs for UV/Ozone and In Situ Groundwater Treatment
A-31 Action-Specific ARARs and TBCs for Solvent Extraction
A-32 Action-Specific ARARs and TBCs for Pipe Plugging
A-33 Action-Specific ARARs and TBCs for Vacuum Dusting
A-34 Action-Specific ARARs and TBCs for In Situ Steam Cleaning
A-35 Action-Specific ARARs and TBCs for Sand Blasting
A-36 Action-Specific ARARs and TBCs for Salvage of Structures
A-37 Action-Specific ARARs and TBCs for Air Stripping
A-38 Action-Specific ARARs and TBCs for GAC Adsorption
A-39 Action-Specific ARARs and TBCs for Chemical Oxidation
A-40 Action-Specific ARARs and TBCs for GAA Adsorption
A-41 Action-Specific ARARs and TBCs for On-Post Transportation of Wastes
A-42 Action-Specific ARARs and TBCs for Institutional Controls
A-43 Action-Specific ARARs and TBCs for Continued Existing Actions
A-44 Action-Specific ARARs and TBCs for Caustic Washing
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List of Tables (Continued)
Table
A-45 Action-Specific ARARs and TBCs for Soil Drying
A-46 Worker Air Exposure Standards for Chemicals Potentially Associated with Groundwater, Soil, or Structures
A-47 Worker Air Exposure Standards for Chemical Agent Constituents
A-48 Standards Pertaining to Air Emissions from Potential Remedial Actions
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List of Acronyms and Abbreviations
°F Degrees Fahrenheit
Hg/m3 Micrograms Per Cubic Meter
Hg/1 Micrograms Per Liter
A Agent
ACGIH American Conference of Governmental Industrial Hygienists
ACM Asbestos-Containing Material
ACOE Army Corps of Engineers
AEL Airborne Exposure Limit
AIR Automobile Inspection and Readjustment
AOC Area of Contamination
APEN Air Pollution Emission Notice
AR Army Regulations
ARAR Applicable or Relevant and Appropriate Requirements
Army U.S. Army
AS Agent Stabilizer
AWQC Ambient Water Quality Criteria
BDAT Best Demonstrated Available Technology
BGEPA Bald and Golden Eagle Protection Act
CAA Clean Air Act
CaCo3 Calcium Carbonate
CAMU Corrective Action Management Unit
CBSG Colorado Basic Standards for Groundwater
CBSM Colorado Basic Standards and Methodologies for Surface Water
cc Cubic Centimeter
CCR Code of Colorado Regulations
CCWE Constituent Concentration in Waste Extract
CDPHE Colorado Department of Public Health and Environment
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
CG Phosgene
cm Centimeter
cm3 Cubic Centimeter
CN Cyanide
CO Carbon Monoxide
CO2 Carbon Dioxide
COC Contaminant of Concern
CP Combustion Product
Cr Chromium
CRL Certified Reporting Limit
CRS Colorado Revised Statute
CSRG Containment System Remediation Goal
CWA Clean Water Act
CWC Draft Convention on the Prohibition of the Development, Production, Stockpiling, and Use of
Chemical Weapons and on Their Destruction
DA Draft Army
DAA Detailed Analysis of Alternatives
db(A) Decibel
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List of Acronyms and Abbreviations
(Continued)
DBCP Dibromochloropropane
DCPD Dicyclopentadiene
DDE 2,2-Bis(para-chlorophenyl)-l,l-dichlorethene
DDT 2,2-Bis(para-chlorophenyl> 1,1,1 -trichloroethane
DIMP Diisopropylmethyl phosphonate
DM Adamsite
DOD Department of Defense
DP Decontamination Product
DSA Development and Screening of Alternatives
EOD Explosive Ordnance Disposal
EPA U.S. Environmental Protection Agency
ESA Endangered Species Act
ESSVEP Enhanced Surface Soil Vacuum Extraction Process
F Fluoride
FFA Federal Facilities Agreement
FR Federal Register
FS Feasibility Study
ft Feet
ft2 Square Feet
FWQC Federal Water Quality Criteria
GAA Granular Activated Alumina
GAC Granular Activated Carbon
GB Isopropylmethyl Phosphonofluoridate
GC/MS Gas Chromatograph/Mass Spectrometer
GC Gas Chromatograph
H Mustard
HD Distilled Mustard
Hg Mercury
HL Mustard-Lewisite Mixture
HP Hydrolysis Product
Hr Hour
HRD Hardness
ICP Incomplete Combustion Product
ICP Inductively Coupled Plasma
ICS Irondale Containment System
ICtj0 Median Incapacitating Dose
IRA Interim Remedial Action
IRIS Integrated Risk Information System
kg Kilogram
kg/mo Kilograms Per Month
L Lewisite
LCtj0 Median Lethal Dose
LDR Land Disposal Restriction
MAX Maximum Peak Above the Ceiling
MBTA Migratory Bird Treaty Act
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List of Acronyms and Abbreviations
(Continued)
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
mg/1 Milligrams Per Liter
mg/m3 Milligrams Per Cubic Meter
Mg Magnesium
mm Millimeter
MFC Maximum Peak Concentration
NAAQS National Ambient Air Quality Standards
naw/gp Non-Agent Worker/General Population
NBCS North Boundary Containment System
NCP National Contingency Plan
NEPA National Environmental Policy Act
NESHAP National Emission Standards for Hazardous Air Pollutants
NFPA National Fire Protection Association
NIOSH National Institute for Occupational Safety and Health
NO2 Nitrogen Dioxide
NPDES National Pollutant Discharge Elimination System
NWBCS Northwest Boundary Containment System
OCP Organochlorine Pesticide
OERR Office of Emergency Response (EPA)
OSHA Occupational Safety and Health Administration
OSWER Office of Solid Waste and Emergency Response
OT One Time Exposure If No Other Measurable Exposure Occurs
PAM Pamphlet
Pb Lead
PCB Polychlorinated Biphenyl
PEL Permissible Exposure Limit
PM10 Particulate Matter with Diameter Less Than or Equal to 10 Micrometers
ppm Parts Per Million
PQL Practical Quantitation Limit
PRG Preliminary Remediation Goal
RCRA Resource Conservation and Recovery Act
REL Recommended Exposure Limit
rf Respirable Fraction
RISR Remedial Investigation Summary Report
RMA Rocky Mountain Arsenal
ROD Record of Decision
RTIC Rocky Mountain Arsenal Technical Information Center
SDP Stabilizer Decontamination Product
SDWA Safe Drinking Water Act
SEL Source Emission Limit
SF Square Feet
SHO Semivolatile Halogenated Organic
SOj Sulfur Dioxide
STEL Short-Term Exposure Limit
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List of Acronyms and Abbreviations
(Continued)
TBC To-Be-Considered Criteria
TEGD Technical Enforcement Guidance Document
TLV ACGffl Threshold Limit Value
TM Technical Manual
TSCA Toxic Substances Control Act
TSP Total Suspended Solids
TU Temporary Units
TWA Time-Weighted Average
UFS Unconfined Flow System
USAEC U.S. Atomic Energy Commission
USATHAMA United States Army Toxic and Hazardous Materials Agency
USC United States Code
USFWS U.S. Fish and Wildlife Service
UTS Universal Treatment Standards
UV Ultraviolet
UW Unmasked Worker
UXO Unexploded Ordnance
VAO Volatile Aromatic Organic
VHO Volatile Halogenated Organic
VOC Volatile Organic Compound
VX Ethyl S-Dimethylaminoethyl Methylphosphonothiolate
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Statutory Citations
Citation
16 USC Section 661 et seq.
16 USC Section 668 et seq.
16 USC Section 703-711
16 USC Section 1531 et seq.
42 USCS Section 7412
42 USCS Section 7502-7503
CRS Section 25-12-101 to 25-12-108
CRS Section 33-2-101 to 33-2-107
CRS Section 42-4-307(8)
Citation Name
Fish and Wildlife Coordination Act
Bald Eagle Protection Act
Migratory Bird Treaty Act
Endangered Species Act
Clean Air Act - National Emission Standards for
Hazardous Air Pollutants (NESHAPS)
Clean Air Act - Nonattainment Plan Provisions/Permit
Requirements
Colorado Revised Statutes - Noise Abatement
Colorado Nongame, Endangered, or Threatened Species
Conservation Act
Colorado Revised Statutes - Regulation of Vehicles and
Traffic
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A.1.0 Introduction
Appendix A is a compilation of chemical-, location-, and action-specific applicable or relevant and appropriate
requirements (ARARs) and to-be-considered criteria (TBCs) that are pertinent to potential remediation alternatives
at the Rocky Mountain Arsenal (RMA). This Appendix identifies ARARs and TBCs for contaminated water, soil,
and structures at RMA.
The ARARs and TBCs identified in this appendix have been compiled to comply with Section 121(d) of the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Pursuant to this section, an
ARAR is defined as "any standard, requirement, criterion, or limitation under any Federal environmental law ... or
... any promulgated standard, requirement, criterion, or limitation under a State environmental or facility siting law
that is more stringent than any Federal standard... [that] is legally applicable to the hazardous substance or pollutant
or contaminant or is relevant and appropriate under the circumstances of the release or threatened release" at the
designated site. Throughout this appendix, since selected remedial actions are presently broad in scope, ARARs
citation references are generally broad. Upon entering the design phase of each remedial action and prior to remedial
implementation, specific sections within the cited references will be identified and serve as the pertinent ARARs.
ARARs were identified according to the procedures outlined in the most recent U.S. Environmental Protection
Agency (EPA) guidance (EPA 1988; Office of Emergency Response-EPA (OERR-EPA) 1988; Office of Solid Waste
and Emergency Response (OSWER 1989b) and the National Oil and Hazardous Substances Contingency Plan (NCP)
(40 Code of Federal Regulations (CFR 300) (EPA 1990). This Appendix to the Record of Decision (ROD) identifies
the ARARs that will be attained by the selected remedies. As there are no specific ARARs that will not be attained
(in instances where chemical-specific ARARs standards are below current practical quantification limits [PQLs], and
compliance cannot therefore be confirmed, meeting these PQLs will serve as attainment of these ARARs standards),
this ROD does not identify any waivers that will be invoked. The PQLs are the Colorado Department of Public
Health and Environment's laboratory PQLs.
Federal and state regulations and guidance that were reviewed fall into one of the following three categories:
applicable requirements, relevant and appropriate requirements, and other criteria, advisories, or guidance TBC.
These requirements are defined in the NCP (40 CFR 300) as follows:
• Applicable requirements are those cleanup standards, standards of control, and other substantive
requirements, criteria, or limitations promulgated under federal environmental or state environmental or
facility siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstance found at a CERCLA site; they fulfill all jurisdictional prerequisites. Only
those state standards that are identified by a state in a timely manner and that are more stringent than federal
requirements may be applicable (40 CFR Section 300.5).
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• Relevant and appropriate requirements are those cleanup standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under federal environmental or state
environmental or facility siting laws that, while not "applicable" to a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstance at a CERCLA site, address problems or
situations sufficiently similar to those encountered at the CERCLA site that their use is well suited to the
particular site. Only those state standards that are identified in a timely manner and are more stringent than
federal requirements may be relevant and appropriate (40 CFR 300.5).
• In addition to applicable or relevant and appropriate requirements, the lead and support agencies may, as
appropriate, identify TBCs for a particular release. The TBC category consists of advisories, criteria, or
guidance that were developed by EPA, other federal agencies, or states that may be useful in developing
CERCLA remedies [40 CFR 300.400(g)(3)J.
The NCP (40 CFR 300) establishes the basic criteria for applicability of a federal or state regulation as specifically
addressing the contaminants, actions, or location of a CERCLA site. If a regulation is determined to be applicable
or relevant and appropriate, only the substantive portions of the regulation are considered to be applicable.
Substantive portions, of a requirement refer to those portions of an ARAR that pertain directly to actions or conditions
in the environment. They generally involve a quantitative limitation or performance objective. Administrative
requirements are those mechanisms that facilitate implementation of the substantive requirements, and they typically
include record keeping and reporting, documentation, issuance of permits, and approval of or consultation with
administrative bodies. On the other hand, monitoring requirements, including recording of the monitoring results
in some form, are generally considered substantive because they are usually necessary to document attainment of
cleanup levels and compliance with emission and discharge limitations.
Some regulations are not directly "applicable" to potential remediation alternatives at the RMA, but may be
considered "relevant and appropriate." As defined by the EPA in the NCP (40 CFR 300), regulations that are
relevant and appropriate must address situations sufficiently similar to those encountered at the CERCLA site such
that their usage is well suited to the particular site. Only those "relevant and appropriate" requirements that are
determined to be both relevant and appropriate must be complied with. The NCP (40 CFR 300) requires that the
following comparisons be made to determine relevance and appropriateness:
• The purpose of the requirement and the purpose of the CERCLA action
• The medium regulated or affected by the requirement and the medium contaminated or affected at the
CERCLA site
• The substances regulated by the requirement and the substances found at the CERCLA site
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• The actions or activities regulated by the requirement and the remedial action contemplated at the CERCLA
site
• Any variances, waivers, or exemptions of the requirement and their availability for the circumstances at the
CERCLA site
• The type of place regulated and the type of place affected by the release or CERCLA action
• The type and size of structure or facility regulated and the type and size of structure or facility affected by
the release or contemplated by the CERCLA action
• Any consideration of use or potential use of the affected resources in the requirement and the use or
potential use of the affected resources at the CERCLA site (40 CFR 300.400(g)(2))
Requirements that are judged both relevant and appropriate must be compiled with to the same degree as if they were
applicable, unless the ARAR meets the CERCLA criteria for a waiver under Section 121(d)(4) of CERCLA. Other
regulations, advisories, or guidance may be useful in developing protectiveness criteria for contaminants for which
there are no ARARs. These regulations fall into the TBC category. TBCs are not enforceable, but may be useful
in developing remedies. The U.S. Army (Army) will conduct a review of the remedial actions selected for RMA
every five years. Requirements that are promulgated or modified after the ROD is signed must be attained (or
waived) if determined to be applicable or relevant and appropriate and necessary to ensure that the remedy is
protective of human health and the environment (40 CFR 300.430 (f)(l)(ii)(B)).
A.2.0 Chemical-Specific Requirements
Chemical-specific ARARs set concentration limits or ranges hi various environmental media for specific hazardous
substances, pollutants, or contaminants. Such ARARs either set protective cleanup levels for the contaminants of
concern (COCs) in the designated media or indicate an appropriate level of discharge based on health- and risk-based
analyses and technological considerations. This section discusses the rationale for chemical-specific requirements
for water, soil, and structures media.
A.2.1 Groundwater and Surface Water Requirements
The CERCLA Compliance with Other Laws Manual (OERR-EPA 1988) identifies federal standards developed under
the Resource Conservation and Recovery Act (RCRA), the Safe Drinking Water Act (SDWA), and the Clean Water
Act (CWA) as ARARs. These ARARs include the following:
• SDWA Maximum Contaminant Levels (MCLs): 40 CFR 141 Subparts B and G, 40 CFR 143.3
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• SDWA Maximum Contaminant Level Goals (MCLGs): 40 CFR 141 Subpart F
• CWA Water Quality Criteria (FWQC): 33 USC Section 1313
• RCRAMCLs: 40 CFR Section 264.94
With respect to state standards, ARARs include the following when these provisions are equivalent to or more
stringent than federal requirements:
• Colorado Rules and Regulations Pertaining to Hazardous Waste: 5 Code of Colorado Regulations (CCR)
1007-3
• Colorado Basic Standards for Groundwater (CBSGs): 5CCR 1002-8
• Colorado Primary Drinking Water Regulations: 5CCR 1003-5
• Colorado Basic Standards and Methodologies for Surface Water (CBSM): 5CCR 1002-8
The SDWA establishes standards for public drinking water systems (40 CFR Parts 141 and 143). These standards
have been established as part of the National Primary and Secondary Drinking Water Regulations. SDWA MCLs
apply to "public water systems," i.e., systems that provide piped water for human consumption to at least 15 service
connections or an average of at least 25 persons daily for at least 60 days of the year (40 CFR Section 141.2).
EPA has also promulgated MCLGs in 40 CFR Sections 141.50 through 141.51. Although MCLGs are
nonenforceable health goals for public water supply systems and, therefore, not applicable to RMA, Section 121 of
CERCLA requires remedial actions to attain at a minimum MCLGs where such goals are relevant and appropriate
under the circumstances of the release or threatened release (42 USC Section 9621(dX2)(A)). EPA has nonetheless
stated that, disregarding special circumstances, "MCLs... are the appropriate standard because they represent the level
of quality for the nation's drinking water supplies" (53 FR 51441, December 21, 1988). EPA further states that
MCLGs are not relevant at most CERCLA sites because "they would impose a more restrictive requirement than
exists for the drinking water consumed by most households in the country." Therefore, EPA (53 FR 51441,
December 21, 1988) believes that MCLs are sufficiently protective in achieving the CERCLA goal of protecting
human health and the environment. However, according to the NCP (EPA 1990), MCLGs set at levels above zero
must be attained by remedial actions for groundwater and surface waters that are current or potential sources of
drinking water. Therefore, the Army has determined that non-zero MCLGs are ARARs. Where MCLGs are set at
zero, the MCL will generally be the ARAR.
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There are no EPA Integrated Risk Information System (IRIS) values per se identified in the database as ARARs.
IRIS contains a compilation of health-based values (e.g., unit cancer risks, drinking water health advisories, ambient
water quality criteria [AWQC]) that are TBCs. IRIS was consulted for values when other sources of information
were not available.
FWQC are nonpromulgated surface water guidelines developed under Section 304 of the CWA that are used by
Colorado, in conjunction with designated uses for a stream segment, to establish water quality standards under
Section 303 of the CWA (33 United States Code (USC) §1313). Although FWQC are nonenforceable, and thus
cannot be applicable, Section 121 of CERCLA states that remedial actions must attain FWQC where they are relevant
and appropriate under the circumstances of a release or threatened release (42 USC §9621(d)(2)(a)).
In determining whether FWQC are relevant, the primary factors to consider are the designated or potential uses of
the water, the media affected, and the purposes for which the potential requirements are intended. FWQC have been
established for protection of human health and for protection of aquatic life. FWQC for protection of human health
address both consumption of water and fish and consumption of fish only. FWQC for protection of aquatic life
consider both acute and chronic effects (33 USC §1313). A review of the site circumstances regarding any release
or threatened release indicates that the relevant and appropriate FWQC applicable and protective to this site are the
water criteria for the protection of aquatic life. Because Colorado has a promulgated numeric water quality standard,
the state standard is relevant and appropriate.
The state and the Army disagree as to whether state surface water quality standards as they relate to agriculture are
ARARs at RMA. The issue is not considered to be of significance because the Federal Facility Agreement (FFA)
and the Rocky Mountain Arsenal National Wildlife Refuge Act of 1992 prohibit agricultural uses of RMA, including
all farming activities such as the raising of livestock, crops, or vegetables. The Parties each preserve their legal
positions as to whether state agricultural surface water quality standards are ARARs.
ARARs and TBCs for groundwater and surface water were identified by evaluating the current lists of target
contaminants addressed by the groundwater (Table A-1) and surface water (Table A-2) monitoring programs and
identifying corresponding standards, regulations, or requirements. Tables A-l and A-2 provide a comprehensive list
of COCs at the site to use as a basis to identify ARARs and TBCs. This list is updated annually to ensure that all
COCs are monitored for on a regular basis.
Groundwater standards for RMA as designated in the ROD are referred to as Containment System Remediation Goals
(CSRGs). The CSRGs are based on the Preliminary Remediation Goals (PRGs) that were developed as part of the
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Detailed Analysis of Alternatives (DAA). Four different sets of PRGs are included in the ROD. These include three
sets of CSRGs for the three boundary systems and one for the Basin A Neck IRA system. The compounds listed
for each system were selected based on current or likely exceedances of applicable standards.
The CSRGs for the North Boundary Containment System (NBCS) and the Northwest Boundary Containment System
(NWBCS) were based on off-post health-based CSRGs for compounds for which these had been developed, CBSGs,
and MCLs for compounds for which the other two criteria did not exist.
The CSRGs for Basin A Neck IRA system are different in that health-based criteria were only used for compounds
for which there are no CBSGs or MCLs. MCLs were used if CBSGs did not exist.
The existing groundwater standards are still applicable for the Irondale Containment System (ICS).
PQLs and certified reporting limits (CRLs) were included, along with CSRGs, as currently applicable criteria for
compounds for which the CSRGs were lower than the PQLs and CRLs.
This is the same approach that was taken to identify constituent ARARs in the ROD. In the ROD, the target
contaminant list consisted of parameters monitored for in Task 44 of the remedial investigation; groundwater and
surface water analytes monitored as pan of the comprehensive monitoring program; other target United States Army
Toxic and Hazardous Materials Agency (USATHAMA) compounds; and non-target compounds detected in
groundwater that were added to the Chemical Index.
Over the years the target analyte list has changed slightly due to the addition of analytes or to the deletion of analytes
that were not detected, detected well below existing standards, detected only one time over a number of years,
detected using a gas chromatograph/mass spectrometer (GC/MS) method for quality assurance and quality control,
or are of no concern. Accordingly, the current ARARs and TBCs for groundwater and surface water differ from
those potential ARARs and TBCs that were identified in the Development and Screening of Alternatives report
(Ebasco 1992a).
Tables A-3 through A-7 contain ARARs and TBCs identified for groundwater at each groundwater treatment system.
ARARs and TBCs for surface water are identified in Tables A-8 and A-9.
Each requirement was reviewed to determine whether it was applicable or relevant and appropriate in accordance
with the CERCLA Compliance with Other Laws Manual (OSWER 1989b). If more than one ARAR was identified
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for a contaminant, the most stringent ARAR was selected. If no ARAR existed for a contaminant, the most stringent
TBC appropriate under the circumstances was selected. Finally, if the numerical values of the ARARs or TBCs are
a function of the hardness of the surface water or groundwater, the hardness value corresponding to each requirement
is given in the "HRD" (hardness) column of the table.
A.2.2 Chemical-Specific Requirements for Soil
The proposed RCRA Corrective Action Rule example action levels (55 FR 30798, July 27, 1990), LDR Universal
Treatment Standard (UTS) levels for soil, Toxic Substances Control Act (TSCA) Polychlorinated Biphenyl (PCB)
Spill Cleanup Policy (40 CFR Part 761 Subpart G), and EPA's proposed sediment criteria for the protection of
benthic organisms for dieldrin and endrin, are TBC values for soil, sediments, and lake sediments at RMA. Land
Disposal Restriction (LDR) Best Demonstrated Available Technology (BDAT) levels (40 CFR Part 268, 6CCR
1007-3 Part 268) are ARARs if placement occurs. For on-site disposal, placement occurs when wastes are moved
from one Area of Contamination (AOC) (or unit) into another AOC (or unit). Placement does not occur when wastes
are left in place or moved within a single AOC. (Section 7.1.1 of the ROD presents a more detailed discussion on
placement.)
The proposed RCRA Corrective Action Rule example action levels (55 FR 30798, July 27, 1990) are TBCs for
determining cleanup levels for soil and groundwater at RMA. The proposed rule was developed using risk-based
information to identify action levels needed at facilities that are contaminated as a result of inadequate management
of hazardous waste. Some of the COCs in this proposed rule are also contaminants found at RMA in the soil. The
types of cleanup activities contemplated by the proposed rule are similar to some of the types of cleanup activities
now being considered for RMA. Table A-10 lists the specific RCRA Corrective Action Rule levels to be considered
for soil and sediment remedial actions.
RCRA, TSCA, and laws governing asbestos also set specific values that may be ARARs or TBCs for RMA soil and
sediments. EPA proposed soil treatment standards in the UTS rule on September 14, 1993, but deferred action on
soil LDRs when that rule was finalized; consequently, UTSs are TBCs with respect to soil at RMA. TSCA
establishes guidance on action levels for PCBs in soil that are TBCs.
A.2.3 Chemical-Specific Requirements for Structures
TSCA PCB cleanup levels established for spills occurring after May 4, 1987 in addition to PCB cleanup standards
contained in EPA's "Guidance on Remedial Actions for Superfund Sites with PCB Contamination" are TBC values
for PCB contaminated structure surfaces and debris. The LDR BDAT levels are ARARs for structural debris if
placement occurs (refer to Section 7.1.1 of the ROD for discussion on placement).
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A.2.4 Chemical-Specific Requirements for Air
The CERCLA Compliance with Other Laws Manual Part II (EPA 1989) identifies federal standards developed under
the Clean Air Act (CAA). These ARARs include the following:
• National Ambient Air Quality Standards (NAAQS): 40 CFR 61
• National Emission Standards for Hazardous Air Pollutants (NESHAPs): 40 CFR 50
State standards that are equivalent or more stringent than federal requirements are also considered ARARs and these
include the following:
• Colorado Ambient Air Standards: 5 CCR 1001-5 Regulation 3, 5 CCR 1001-14
• Control of Hazardous Air Pollutants: 5 CCR 1001-8
• Odor Emission Regulations: 5 CCR 1001.4 Regulation 2
A.3.0 Location-Specific Requirements
Remedial actions may be restricted or precluded by location-specific ARARs that are contingent upon the location
or characteristics of the site and the requirements that apply to it. These regulations include the Colorado siting
requirements for hazardous waste disposal sites (6 CCR 1007-2, Part 2), laws regarding development or other
activities in wetlands or floodplains, and laws regarding preservation of historic or cultural sites. The Colorado siting
requirements are applicable to the locations, design, and design performance of any hazardous wastes disposal site.
With regard to RMA, the siting requirements are applicable to the proposed hazardous waste landfill that is to be
part of the designated Corrective Action Management Unit (CAMU). Location-specific ARARs and TBCs are listed
in Table A-ll.
In determining location-specific ARARs, the following characteristics of RMA must be taken into account:
• Absence of karst topography underlying RMA
• Absence of faults underlying RMA that have had displacement in Holocene time
• Potential presence of areas designated as national historic landmarks or national preservation areas
• Presence of wetlands as shown in the Remedial Investigation Summary Report (RISK) (Ebasco 1992b)
• Presence of 100-year floodplains associated with most drainages at RMA, as shown in the RISR (Ebasco
1992b)
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All requirements pertaining to the protection and management of floodplains and wetlands are considered potentially
applicable to the remedial activities described in this ROD. Location-specific ARARs pertaining to floodplains are
contained in Executive Order 11988 (44 Federal Register (FR) 43239, July 7, 1979; procedures codified in
regulations under the National Environmental Policy Act (NEPA), 40 CFR Part 6, and 40 CFR Section 257.3-1 (a)).
The provisions of 40 CFR Section 257.3-l(a) are applicable only to units regulated under RCRA, but are considered
relevant and appropriate requirements concerning the construction of facilities and conduct of remedial actions in
floodplain zones. Location-specific ARARs pertaining to wetlands are contained in Executive Order 1 1990 and 40
CFR Part 6. Excerpts from these requirements are provided below:
Floodplains
• "Evaluate the potential effects of actions ...[that would be taken] in a floodplain to avoid, to the
extent possible, adverse effects associated with direct and indirect development of a floodplain"
(40 CFR Section 6.302 (b)).
• "Ensure that ...(the federal agency's) planning programs and budget requests reflect consideration
of flood hazards and floodplain management, including the restoration and preservation of such
land areas as natural undeveloped floodplains ..." (40 CFR Part 6, Appendix A, Section l(a)).
• "Executive Order 11988 ...requires Federal agencies to ...prescribe procedures to implement the
policies and procedures of [the] Executive Order" (40 CFR Part 6, Appendix A, Section l(a)).
• "Where there is no practical alternative to locating in a floodplain, minimize the impact of floods
on human safety, health and ... the natural environment" (40 CFR Part 6, Appendix A, Section
"Restore and preserve natural and beneficial values served by floodplains" (40 CFR Part 6,
Appendix A, Section 3(b)(3)).
"Identify floodplains which require restoration and preservation and recommend management
programs necessary to protect these floodplains and to include such considerations as part of on-
going planning programs" (40 CFR Part 6, Appendix A, Section 3(b)(5)).
"Facilities or practices in floodplains shall not restrict the flow of the base flood, reduce the
temporary water storage capacity of the floodplain, or result in washout of solid waste, so as to
pose a threat to human life, wildlife, or land or water resources" (40 CFR Section 257.3-1 (a)).
Wetlands
• "Requires Federal agencies conducting certain activities to avoid, to the extent possible, the adverse
impacts associated with the destruction or loss of wetlands and to avoid support of new
construction in wetlands" (40 CFR Section 6.302(a)).
• "The responsible official shall either avoid adverse impacts or minimize them if no practicable
alternative to the action exists" (40 CFR Section 6.302(a)).
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Floodplains and Wetlands
• "Before undertaking an Agency action, each program office must determine whether or not the
action will be located in or affect a floodplain or wetlands" (40 CFR Part 6, Appendix A, Section
• "The Agency shall utilize maps prepared by the Federal Insurance Administration of the Federal
Emergency Management Agency ..., Fish and Wildlife Service ..., and other appropriate agencies
to determine whether a proposed action is located in or will likely affect a floodplain or wetlands"
(40 CFR Part 6, Appendix A, Section 6(a)(l)).
• If an action "is likely to impact a floodplain or wetlands, the public should be informed through
appropriate public notice procedures" (40 CFR Part 6, Appendix A, Section 6(a)(2)).
• "If the Agency determines a proposed action is located in or affects a floodplain or wetlands, a
floodplain/wetlands assessment shall be undertaken ... [that] shall consist of a description of the
proposed action, a discussion of its effect on the floodplain/wetlands, and shall also describe the
alternatives considered" (40 CFR Part 6, Appendix A, Section 6(a)(3)).
• "A public notice of the floodplain/wetlands assessment shall be made consistent with the public
involvement requirements of the applicable program" (40 CFR Part 6, Appendix A, Section
• "For all Agency actions proposed to be in or affecting a floodplain/wetlands, the Agency shall
provide further public notice announcing this decision. This decision shall be accompanied by a
Statement of Findings, not to exceed three pages. This statement should include" all items outlined
in the statute" (40 CFR Part 6, Appendix A, Section 6(a)(6)).
Requirements adopted as part of RCRA are applicable or relevant and appropriate to remedial actions conducted at
CERCLA sites. Location-specific ARARs that may be relevant and appropriate for on-post remediation are contained
in 40 CFR Section 257.3-1, which applies directly to floodplain management, and 40 CFR 264 Subpart B, which
contains EPA regulations for owners and operators of RCRA-permitted hazardous waste facilities.
The Army is in the process of conducting an archeological, architectural, historical, and prehistorical cultural resource
survey. This survey could identify structures that may be protected under the National Historic Preservation Act (36
CFR Part 800) or the Archeological Resources Protection Act (16 USC Section 469a-l). Location-specific ARARs
would be triggered if culturally significant structures are identified at RMA.
A.4.0 Action-Specific Requirements
Action-specific ARARs and TBCs are standards that establish restrictions or controls on particular kinds of remedial
activities related to management of hazardous substances or pollutants. These requirements are triggered by the
particular remedial activities, as opposed to the specific chemicals present or the location of the remediation activity.
For example, if a particular remedial action could result in emissions of regulated air pollutants, then certain air
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regulations could be ARARs for that particular remedial action. Tables A-12 through A-45 contain ARARs and
TBCs for the technologies that are part of any of the alternatives considered in the ROD for water, soil, and
structures. Each table contains ARARs and TBCs for a specific technology that may represent only one part of a
complete alternative that consists of several technologies. Therefore several ARAR tables will be applied to each
alternative. Throughout this appendix, since selected remedial actions are presently broad in scope, ARARs citation
references are generally broad. Upon entering the design phase of each remedial action and prior to remedial
implementation, specific sections within the cited references will be identified and serve as the pertinent ARARs.
A.5.0 Other Potential Requirements
In addition to the chemical-, location-, and action-specific ARARs and TBCs, there are a number of other
requirements and potential requirements that could constrain and direct remedial actions at RMA. These additional
requirements are addressed below.
Federal Facility Agreement
Provisions of the FFA regarding use restrictions, federal ownership, and access restrictions are not ARARs or TBCs;
however, compliance with these restrictions is required.
Asbestos-Containing Materials
Asbestos-containing materials (ACM) that may be found in structures or soil during remediation will be managed
in accordance with potential ARARs identified in the Asbestos Interim Remedial Action (IRA). ACM generated
during remedial activities will be disposed in a landfill that is designed and managed in accordance with ARARs
specified in the appropriate ARAR tables.
Polychlorinated Biphenyls
The methodology for PCB-contaminated materials is regulated under 40 CFR Part 761 and described EPA guidance
(OERR-EPA 1990b). The Army has undertaken several programs to identify, inventory, and dispose of its PCB
contamination in structures, equipment, and soil as described below:
• The PCB IRA program identifies and inventories PCB-contaminated materials in nonagent and structures
not owned by Shell. Contaminated equipment is disposed in a landfill that meets TSCA requirements.
Some large pieces of contaminated equipment, which have proven difficult to remove, are left in place, to
be disposed as part of the final structures cleanup. PCB-contaminated structural materials or soil are also
left in place for final cleanup under this program. The one exception is a soil removal action at the
Building 62IB salvage yard. PCB-contaminated materials that are handled in the final cleanup will be
treated and disposed of in landfills that meet TSCA requirements.
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• The Chemical Process-Related Activities ERA decontaminates and removes equipment that is potentially
agent contaminated. Decontaminated agent equipment that is also PCB-contaminated is currently stored on
post, and will be disposed of in a landfill that meets TSCA requirements.
• The electrical substation and transformer maintenance activities have resulted in the removal and proper
disposal of all PCB-contaminated equipment.
Equipment, structures, and soil for which the Army has a responsibility will be handled as follows:
• Equipment: PCB fluids will be drained and sent off post for disposal in compliance with applicable TSCA
regulations. PCB-contaminated equipment will be disposed in a landfill that meets TSCA requirements.
The action levels that will be used to classify a piece of equipment as PCB-contaminated will be taken from
40 CFR Part 761. The equipment will be disposed under one of three possible scenarios:
- Identified and disposed as part of the ongoing PCB IRA
- Identified under the PCB ERA, but disposed under the final structures cleanup
- Agent-decontaminated materials that will be disposed under the final structures cleanup
• Structural Materials: The PCB contamination in No Future Use structural materials will be identified in the
PCB IRA completion report. Based on a 50-parts per million (ppm) action level, structural materials will
be addressed La one of two ways:
- Structural materials with PCB concentrations of 50 ppm or above that exist above the ground elevation,
as well as contaminated parts of ground floor slabs and foundations that will be removed, will be
identified prior to demolition, segregated during demolition, and disposed in a landfill that meets TSCA
requirements. Similar materials with PCB concentrations below 50 ppm will not require disposal in a
TSCA landfill.
- PCB-contaminated sections of ground floor slabs or foundations that are not required to be demolished
as part of the remediation, and that have PCB concentrations of less than 50 ppm, will be left in place.
However, if such slab or foundation material has PCB concentrations of 50 ppm or greater, it will be
removed during demolition and disposed of in a landfill that meets TSCA design requirements.
Soil: Action on PCB-contaminated soil is dependent on the concentration and location as follows:
- The three PCB-contaminated soil areas identified by the PCB IRA with concentrations of 250 ppm or
greater will be removed. The limits of contamination will be determined based on visual evidence with
immunoassay field confirmation sampling (EPA method SW-846).
- There are five PCB-contaminated soil areas identified by the PCB IRA with concentrations from 50
ppm to below 250 ppm. These areas will receive a minimum 3 feet (ft) of soil cover, and the PCB-
contaminated soil there will be left in place. The soil cover will be maintained as part of the wildlife
refuge and is subject to the institutional controls of the FFA.
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- No remaining areas of PCB-contaminated soil with concentrations above 50 ppm have been identified
by the PCB IRA. If necessary, any suspected PCB soil contamination areas will be characterized
further during the remedial design. If additional PCB-contaminated soil is found with concentrations
of 50 ppm or above, the Army will determine any necessary remedial action in consultation with EPA.
Army Future Use structures have been managed for occupancy under current environmental and worker protection
regulations. There is no evidence of PCB contamination in this medium group.
Structures and equipment for which Shell has responsibility will be handled as follows:
• All Shell buildings to be demolished during the final remedy will be inspected for equipment containing
fluids potentially contaminated with PCBs prior to demolition. Suspected fluids will be drained and sent
off post for disposal in compliance with applicable TSCA regulations. Equipment that contained these fluids
as well as all other equipment will be disposed of in a landfill that meets TSCA requirements. Significant
Contamination History structures will be demolished and the resulting debris will be placed in a landfill that
meets TSCA requirements. Other Contamination History structures will be evaluated by Shell and EPA for
any visual evidence of leaks or spills. If observed in areas where potential PCB releases may reasonably
have been expected to occur, the affected structural debris will be disposed in a landfill that meets TSCA
requirements. Examples of this type of visual evidence would include stains near equipment potentially
containing PCB fluids or stains in buildings where there are numerous instances of equipment potentially
containing PCB-contaminated fluids. Further details of this work will be addressed at the remedial design
stage.
• All fluorescent light ballasts will be disposed at an off-post disposal facility in accordance with applicable
TSCA regulations.
Shell does not have responsibility for any structures within the Future Use or Agent History Medium Groups.
Protection of Wildlife
The provisions of the FFA that call for the preservation and management of wildlife at RMA are not ARARs;
however, compliance with these provisions is required. Sections 44.2(e) and (f) of the FFA specifically address
activities at RMA and provide for the following:
(e) Wildlife habitat(s) shall be preserved and managed as necessary to protect endangered species
of wildlife to the extent required by the Endangered Species Act, 16 USC Section 1531 et sea..
migratory birds to the extent required by the Migratory Bird Treaty Act, 16 USC Section 703 et
sea,., and bald eagles to the extent required by the Bald and Golden Eagle Protection Act, 16 USC
Section 668 et seq.
(f) Other than as may be necessary in connection with a Response Action or as necessary to
construct or operate a Response Action Structure, no major alteration shall be permitted in the
geophysical characteristics of the Arsenal if such alteration may likely have an adverse effect on
the natural drainage of the Arsenal for floodplain management, recharge of ground water, operation
and maintenance of Response Action Structures, and protection of wildlife habitat(s).
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The provisions of the Endangered Species Act, (ESA) [16 USC Sections 1531 et seq.: 50 CFR Section 424.02(d)(2);
50 CFR Part 402; 50 CFR Part 17] the Migratory Bird Treaty Act, (MBTA) (16 USC Section 703 et seq.: 50 CFR
10 and 11) and the Bald and Golden Eagle Protection Act (BGEPA) (16 USC Section 668 et seq.) apply to RMA.
The Army will establish remediation goals for site contaminants to maintain and enhance healthy populations of the
species subject to the ESA, MBTA and BGEPA and their habitats at RMA. Remediation goals for soil and sediment
that are consistent with the ESA, MBTA, and BGEPA will be established using a methodology agreed to by the
Army, Shell, Colorado, and EPA in consultation with the U.S. Fish and Wildlife Service (USFWS). The Army will
also consult with USFWS to determine whether any of the CERCLA activities or remedial alternatives might have
a short-term impact on a subject species or its habitat. If a determination is made that the Army's activities or
remedial alternatives could impact a subject species or its habitat, the Army will consult with the USFWS to
determine whether the activity should proceed and what, if any mitigation measures are necessary, in light of any
long-term benefits to protection of populations of the subject species.
The Parties disagree on whether the substantive portions of Colorado Wildlife Enforcement and Penalties Provisions
(Colorado Revised Statute (CRS) 33-1-101, et seq. and CRS 33-6-101, etseq.) and Wildlife Commission Regulations
(2 CCR 406-8) are ARARs. USFWS, in cooperation with the Colorado Department of Natural Resources, agrees
to advise the Army, as the lead agency, with respect to the substance of the above-referenced state wildlife laws and
regulations in order to ensure that where indicated, such state laws and regulations are taken into account in
connection with the implementation of the selected remedy to the extent they are not inconsistent with federal law
and regulations. The Parties each reserve all rights with respect to their respective legal and jurisdictional arguments
relating to whether the above-cited state laws and regulations relative to wildlife should be treated as ARARs.
Wastewater from Remedial Actions
Remedial actions at RMA could potentially generate wastewaters from structures and soil. Some of the wastewater
generated will be directed to the RMA wastewater treatment plant and treated in accordance with the CERCLA
Wastewater Treatment System IRA and the ARARs found therein.
Land Disposal Restrictions
LDRs are applicable requirements for prohibited substances in the event that placement occurs. For subject materials
that are managed within a CAMU, or moved from outside to within the CAMU for disposal, as may be established
at RMA in the selected remedy, LDRs are not required to be met because placement is not by definition occurring.
Similarly, for restricted wastes consolidated (and not otherwise managed) within an AOC, as may be established at
RMA in the selected remedy, LDRs are not required to be met because placement is not occurring (refer to
Section 7.1.1 of the ROD for discussion on placement). Except for restricted wastes consolidated within, or moved
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into a CAMU, and restricted wastes consolidated within an AOC, LDRs are applicable and require, among other
things, treatment of listed or characteristic hazardous wastes to BDAT levels prior to placement in land disposal units.
The following EPA guidance documents with respect to LDRs are considered TBCs:
• Determining When LDRs are Applicable to CERCLA Response Actions, Superfund LDR Guide 5, OSWER
No. 9347.3-OGFS (July 1989b)
• Determining When LDRs are Relevant and Appropriate to CERCLA Response Actions, Superfund LDR
Guide 7, OSWER No. 9347.3-OBFS (December 1989a)
• EPA Hazardous Waste Land Disposal Restrictions Policy, 55 FR 6640 (February 26, 1990)
Treatment standards for debris contaminated with listed hazardous waste or debris that exhibits hazardous waste
characteristics were finalized by EPA on August 18, 1992 and incorporated by reference by the state of Colorado
on October 19, 1993. The alternative debris BDAT standards were intended to make land disposal of hazardous
debris more feasible. The rule requires that debris contaminated with listed hazardous waste must be handled as if
it were hazardous until the listed waste is treated according to BDAT and then the debris can be placed in a
nonhazardous waste landfill. Debris that exhibits a characteristic of a hazardous waste must be treated according to
BDAT and may be land disposed as nonhazardous once the characteristic is removed. EPA's LDRs for waste debris
do not apply to contaminated soil, except for soil mixed with manmade debris (57 FR 958, January 9, 1992.)
LDRs will be considered action-specific ARARs if the soil, sediment, or debris is shown to be RCRA-characteristic
waste or to contain RCRA-listed waste, and the remedial alternatives involve "placement" of these RCRA hazardous
wastes.
The CAMU regulations allow for exceptions from the LDRs for remediation wastes managed at CAMUs or
temporary units. The Colorado Hazardous Waste Commission adopted state regulations with the intention that the
state regulations be interpreted in a manner consistent with the federal CAMU rule. The CAMU regulations provide
flexibility and allow for expeditious implementation of remedial decisions in the management of remediation wastes.
One or more CAMUs may be designated at a facility. Placement of hazardous remediation wastes into or within
the CAMU does not constitute land disposal of hazardous wastes so the LDRs are not triggered.
Agent Management and Disposal
Department of Defense (DOD)/Army Regulations addressing unexploded ordnance (UXO) and agent management
and disposal are ARARs for any of the possible remedial actions proposed for RMA. These include but are not
limited to the following:
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• Draft Army (DA) Pamphlet 50-6, Chapter 7 for suspected (or known) chemical munitions. Army
Regulation (AR) 50-6-Chemical Surety Program
• AR 75-15 - Emergency Disposal of Munitions (both explosive and chemical munitions) - gives Explosive
Ordnance Division (EOD) or Army Technical Escort Unit the authority to explosively dispose of munitions
too hazardous to move.
• Draft AR 385-61 - Army Toxic Chemical Agent Safety Program
• Draft AR 385-64 - Ammunition and Explosives
• AR 385-131 - Chemical Agent Safety
State RCRA Authority
The state of Colorado is authorized to administer portions of the hazardous waste management program (e.g., RCRA)
to regulate the generation, treatment, storage, and disposal of hazardous waste within Colorado. As such, the
Colorado regulations are pertinent to the management of hazardous waste. These regulations, with the exception
of LDR requirements for contaminated soil and debris, may also be relevant and appropriate in situations, i.e., where
necessary to protect human health and the environment, in which a remediation waste is "sufficiently similar" to a
RCRA-Iisted waste or when the proposed remedial action is similar to a RCRA-regulated activity. According to the
"CERCLA Compliance with Other Laws Manual," when evaluating whether Subtitle C requirements are relevant and
appropriate, the mere presence of hazardous constituents in a CERCLA waste does not mean the waste is sufficiently
similar to a RCRA hazardous waste to trigger Subtitle C as an ARAR. Judgment should be used in assessing
whether the waste closely resembles a RCRA hazardous waste, considering the chemical composition form,
concentration, and any other information pertinent to the nature of the waste.
Although the Colorado hazardous waste management regulations are similar to the federal requirements, both federal
and state general regulatory citations are provided in the ARARs tables. Only substantive portions of the regulations
require compliance with CERCLA on-site activities. It should be noted that "substantive requirements" are those
requirements that pertain directly to actions or conditions in the< environment. In addition, Table A-12 contains a
list of Colorado standards for owners or operators of hazardous waste treatment, storage, and disposal facilities that
are more stringent than the equivalent federal regulations. Since selected remedial actions are presently broad in
scope, ARARs citations with respect to hazardous waste requirements are also broad. Upon entering the design phase
of each remedial action, and prior to remedial implementation, specific sections within the cited references will be
identified and serve as the pertinent ARARs.
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Worker Protection Standards
Table A-46 presents chemical-specific worker exposure guidelines established by the Occupational Safety and Health
Administration (OSHA), the American Conference of Governmental Industrial Hygienists (ACGIH), and the National
Institute for Occupational Safety and Health (NIOSH). OSHA does not apply to federal employees; however, DOD
employees are covered by OSHA under Executive Order No. 12196, which addresses employee health and safety
standards.
The worker protection standards presented in Table A-46 address exposure standards for chemicals detected and
potentially associated with water, soil, and structures at RMA. Because ACGIH and NIOSH are not governmental
agencies, their threshold limit values (TLVs) and recommended exposure limits (RELs) are presented here as TBCs.
OSHA values are presented as ARARs for protection of workers during remediation. OSHA regulations for worker
health and safety, which are codified at 29 CFR 1910, are independently applicable to the remedial actions at RMA.
Table A-47 presents worker air exposure standards for chemical agent constituents established by the Occupational
Safety and Health Administration (OSHA), the American Conference of Governmental Industrial Hygienists
(ACGIH), the National Institute for Occupational Safety and Health (NIOSH), and Department of the Army.
Air Emission Standards
Air emission standards that pertain to remedial actions at RMA are identified in Table A-48. The substantive
requirements necessary to control participate and fugitive dust emissions from off-site transport will be addressed
in the remedial design phase of the project.
Chemical Weapons Convention
The draft Convention on the Prohibition of the Development, Production, Stockpiling, and Use of Chemical Weapons
and on Their Destruction (CWC) provides for a declaration of the possession of any chemical weapons production
facilities and the ultimate destruction of such. The CWC was signed by 130 nations, including the United States,
in January 1993. Each nation must submit a declaration as to whether it owns or possesses any chemical weapons
or whether any chemical weapons are located in its jurisdiction or control. Chemical weapons are defined as toxic
chemicals and their precursors, munitions, and devices specifically designed to cause death or harm through the toxic
properties of the chemicals, which would be released by employment of munitions or devices.
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A.6.0 References
Army (U.S. Array)
1995 (February 1) AR [Army Regulation] 50-6, Nuclear and Chemical Weapons and Material.
1991 (May 17) DA PAM [Department of the Army Pamphlet] 50-6, Chemical Accident or Incident Response
Assistance (CAIRA) Operations.
1987 (May 22) AR 385-64, Ammunition and Explosives Safety Standards.
1985 (August 27) AR 385-61, Safety Studies and Reviews of Chemical Agents and Associated Weapon
Systems.
1978 (November 1) AR 75-15, Responsibilities and Procedures for Explosive Ordnance Disposal.
AMC (Army Materiel Command)
1987 (October 9) AMC [Army Materiel Command Regulation] 385-131, Safety Regulation for Chemical
Agents, H, HD, HT, GB, and VX.
Ebasco (Ebasco Services Incorporated)
1992a (December) Final On-Post Feasibility Study, Development and Screening of Alternatives. Prepared for
the Program Manager for Rocky Mountain Arsenal. Version 4.1, 7 v. RTIC 92363R01.
1992b (January) Final Remedial Investigation Summary Report, Version 3.2, RTIC 92017R01.
1989 (July) Water Remedial Investigation Report, Final, Version 3.3; Volume II, Appendix C. RTIC 89186RO1.
Ebasco et al.
1988 (May) Rocky Mountain Arsenal Chemical Index; Appendix C. Table C-3, Volumes I-III.
EPA (U.S. Environmental Protection Agency)
1990 (March 8) National Oil and Hazardous Substances Pollution Contingency Plan, Final Rule, 40 CFR Part
300 (Federal Register 55(46): 8666-8865). (NCP).
1989 Integrated Risk Information System (IRIS). (Note: This is an EPA computerized database.)
1988 Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA. Interim Final
(EPA/540/G-89/004).
1986 TGST Methods for Evaluating Solid Wastes: Physical/Chemical Methods, Third ed.
EPA et al.
1989 (February) Federal Facility Agreement for Rocky Mountain Arsenal. RTIC 89068R01. (FFA)
Harding Lawson Associates
1995 (December) Rocky Mountain Arsenal Offpost Operable Unit Final Record of Decision, Rocky Mountain
Arsenal, Commerce City, Colorado. Prepared for the Program Manager for Rocky Mountain Arsenal.
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OERR-EPA (Office of Emergency and Remedial Response, U.S. Environmental Protection Agency)
1990a (September) Superfund LDR Guide No. 6A. (2nd ed.) Obtaining a Soil and Debris Treatability Variance
for Remedial Actions. Fact Sheet OSWER/9347.3-06FS.
1990b (August) Guidance on Remedial Actions for Superfund Sites with PCB Contamination EPA/540/G-
90/007.
1989 (July) Superfund LDR Guide No. 5: Determining When Land Disposal Restrictions (LDRs) Are
Applicable to CERCLA Response Actions. (Fact Sheet [Final]). EPA/9347.3-05/FS.
1988 (August 8) CERCLA Compliance with Other Laws Manual. Part 1. Interim Final (Draft Report) (EPA
540/G-89/006); OSWER/9234.1-01.
OSWER (Office of Solid Waste and Emergency Response, U.S. Environmental Protection Agency)
1989a (December) Superfund LDR Guide No. 7. Determining When Land Disposal Restrictions (LDRs) Are
Relevant and Appropriate to CERCLA Response Actions (Fact Sheet). OSWER/9347.3-08FS.
1989b (August) CERCLA Compliance with Other Laws Manual, Interim Final OSWER Directive 9234.1-02.
EPA/540/G-89/009.
R.L. Stellar & Associates Incorporated
1989a (October) Comprehensive Monitoring Program, Surface Water Final Technical Plan, Version 3.1.1.
RTIC90110R01.
1989b (June) Comprehensive Monitoring Program, Groundwater Final Technical Plan, Version 3.2 RTIC
89213R02.
USATHAMA (U.S. Army Toxic and Hazardous Materials Agency)
1988 (September) U.S. Army Toxic and Hazardous Materials Agency Analyte Summary. Version 4.
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A.7.0 Tables
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Table A-1 List of Rocky Mountain Arsenal Target Constituents Addressed by the
Groundwater Monitoring Program1 Page 1 of 2
Group name/constituent
Group name/constituent
Agent degradation products
thiodiglycol
isopropyl methylphosphonic acid
Metals
cadmium
chromium
copper
lead
zinc
Volatile aromatic organic compounds
benzene
ethylbenzene
toluene
m-xylene
o- and p-xylene
Organophosporous compounds
diisopropyl methylphosphonate
dimethyl methylphosphonate
Organochlorine pesticides
2,2'bis(p-chlorophenyl)-1,1 -dichloroethylene
2,2'bis(p-chlorophenyl)-l,l,l-trichloroethane
aldrin
chlordane
dieldrin
endrin
hexachlorocyclopentadiene
isodrin
Organosulfur compounds
1,4-oxathiane
benzothiazole
p-chlorophenylmethyl sulfide
p-chlorophenylmethyl sulfone
p-chlorophenylmethyl sulfoxide
dimethyl disulfide
dithiane
Organophosphorous pesticides
atrazine
malathion
parathion
supona
vapona
Volatile halogenated organic compounds
1,3-dichlorobenzene
1,1-dichloroethane
1,2-dichloroethane
1,1-dichloroethylene
1,2-dichloroethylene (cis and trans isomers)
1,1,1-trichloroethane
1,1,2-trichlorethane
carbon tetrachloride
chlorobenzene
chloroform
methylene chloride
tetrachloroethylene
trichloroethylene
RMAM138 05/15/96 3:56pm bpw
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Table A-1 List of Rocky Mountain Arsenal Target Constituents Addressed by the
Groundwater Monitoring Program1 Page 2 of 2
Group name/constituent Group name/constituent
Volatile hydrocarbon compounds Anions
t
bicyclo[2,2,l]hepta-2,5-diene chloride
dicyclopentadiene sulfate
methylisobutyl ketone fluoride
Arsenic
Mercury
Cyanide
Dibromochloropropane
Cyanazine
n-Nitrosodimethylamine
Cations
calcium
magnesium
sodium
potassium
Nitrite/Nitrate
' This list does not include the GC/MS analyses that are performed on 10% of the samples for quality assurance/quality control
purposes.
RMAM138 05/15/96 3:56pm bpw
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Table A-2 List of Rocky Mountain Arsenal Target Constituents Addressed by the
Surface Water Monitoring Program1 Page 1 of 2
Group name/constituent
Group name/constituent
Agent degradation products
thiodiglycol
isopropyl methylphosphonic acid
Metals
cadmium
chromium
copper
lead
zinc
Volatile aromatic organic compounds
benzene
ethylbenzene
toluene
m-xylene
o- and p-xylene
Organophosphorous compounds
diisopropyl methylphosphonate
dimethyl methylphosphonate
Organochlorine pesticides
2,2'bis(p-chlorophenyl)-1,1 -dichloroethylene
2,2'bis(p-chlorophenyl)-1,1,1 -trichloroethane
aldrin
chlordane
dieldrin
endrin
hexachlorocyclopentadiene
isodrin
Organosulfur compounds
1,4-oxathiane
Benzothiazole
p-chlorophenylmethyl sulfide
p-chlorophenylmethyl sulfone
p-chlorophenylmethyl sulfoxide
dimethyl disulfide
dithiane
Organophosphorous pesticides
atrazine
malathion
parathion
supona
vapona
Volatile halogenated organic compounds
1,1-dichloroethane
1,2-dichloroethane
1,1-dichloroethylene
1,2-dichloroethylene (cis and trans isomers)
1,1,1 -trichloroethane
1,1,2-trichlorethane
carbon tetrachloride
chlorobenzene
chloroform
methylene chloride
tetrachloroethylene
trichloroethylene
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Table A-2 List of Rocky Mountain Arsenal Target Constituents Addressed by the
Surface Water Monitoring Program1 Page 2 of 2
Group name/constituent Group name/constituent
Volatile hydrocarbon compounds Anions
bicyclo[2,2,l]hepta-2,5-diene chloride
dicyclopentadiene sulfate
methylisobutyl ketone fluoride
Arsenic Cations
Mercury calcium
Cyanide magnesium
sodium
Dibromochloropropane potassium
n-Nitrosodimethylamine Nitrite/Nitrate
1 This list does not include the GC/MS analyses that are performed on 10% of the samples for quality assurance/quality control
purposes.
RMAM139 05/15/96 3:57pm bpw
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Table A-3 ARARs for Groundwater for Northwest Boundary Containment System
Page 1 of 1
Parameter
Arsenic (total)
Chloroform
Dieldrin
Diisopropylmethyl
phosphonate
Endrin
Trichloroethylene
Abbrev Cone
AsTOT 50*
50*
CHCL3 6
DLDRN 0.002
0.1**
DIMP 8
ENDRN 2
0.2
TRCLE 5*
5*
App
N
N
N
N
N
N
N
N
N
N
Rel
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Apr Units Hrd
Y u.g/1
Y ng/l
Y ug/1
Y ug/1
Y ^ig/1
Y ug/1
Y ng/1
Y ng/1
Y fig/1
Y ug/l
Source
40 CFR 141.1 1, Federal primary MCL
5 CCR 1002-8,
5 CCR 1002-8,
5 CCR 1002-8,
5 CCR 1002-2,
Table A)
5 CCR 1002-8,
40 CFR 141.61
5 CCR 1002-8,
40 CFR 141.61
5 CCR 1002-8,
Colorado Groundwater Standard
Colorado Groundwater Standard
Colorado Groundwater Standard
State Discharge Permit System PQLs (referenced in CBSG
Colorado Groundwater Standard
, Federal primary MCL
Colorado Groundwater Standard
, Federal primary MCL
Colorado Groundwater Standard
* The containment system remediation goal for this parameter (identified in Section 9 of the ROD) is more stringent than the ARAR and is listed in Table A-7 as a TBC.
** PQL Detection levels for Gas Chromatography/Mass Spectrometry.
Hg/l Indicates micrograms per liter.
RMA/ARARS/1453
-------
Table A-4 ARARs for Groundwater for Irondale Containment System
Page 1 of 1
Parameter
Abbrev Cone App Rel Apr Units Hrd Source.
Dibromochloropropane DBCP
Trichloroethylene TRCLE
0.2 N Y Y ug/l 40 CFR 141.61, Federal primary MCL
0.2 N Y Y ug/l 5 CCR 1002-8, Colorado Groundwater Standard
5 N Y Y ug/l 40 CFR 141.61, Federal primary MCL
5 N Y Y ug/l 5 CCR 1002-8, Colorado Groundwater Standard
ug/l Indicates micrograms per liter.
RMA/I454 05/15/96 3:58pm bpw
-------
Table A-5 ARARs for Groundwater for North Boundary of Rocky Mountain Arsenal
Page 1 of 3
Parameter
1 ,2-Dichloroethane
1 ,2-Dichloroethylene
Aldrin
Arsenic (total)
Atrazine
Benzene
Carbon Tetrachloride
Abbrev
12DCLE
12DCE
ALDRN
AsTOT
ATZ
C6H6
CCL4
Cone
5
0.4*
I**
70
70
0.002
O.I**
50+
50*
3*
3
5*
5*
5
0.3
I**
App
N
N "
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Rel
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Apr
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Units Hrd
Hg/l
Hg/l
Hg/l
Hg/l
Hg/l
Hg/l
ug/l
Mg/l
"g/l
fig/'
"g/l
ug/l
Ug/l
ug/l
ug/l
ug/l
Source
40CFR 141.61,
5 CCR 1002-8,
5 CCR 1002-2,
Table A)
Federal primary MCL
Colorado Groundwater Standard
State Discharge Permit
System PQLs (referenced
in CBSG
40 CFR 141.61, Federal primary MCL
5 CCR 1002-8,
5 CCR 1002-8,
5 CCR 1002-2,
Table A)
40 CFR 141.61
5 CCR 1002-8,
40 CFR 141.61
5 CCR 1002-8,
40 CFR 141.61
Colorado Groundwater
Colorado Groundwater
State Discharge Permit
, Federal primary MCL
Colorado Groundwater
Standard
Standard
System PQLs (referenced
Standard
in CBSG
, Federal primary MCLG
Colorado Groundwater
, Federal primary MCL
5 CCR 1002-8, Colorado Groundwater
40 CFR 141.61
, Federal primary MCL
5 CCR 1002-8, Colorado Groundwater
5 CCR 1002-2, State Discharge Permit
Table A)
Standard
Standard
Standard
System PQLs (referenced
in CBSG
' Containment System Remedial Goal for this parameter (identified in Section 9 of the ROD) is more stringent than the ARAR and is listed in Table A-7 as a TBC.
* Asterisk indicates concentration below the lowest USAEC Certified Reporting Limit.
** PQL Detection levels for Gas Chromatography/Mass Spectrometry.
Hg/l Indicates micrograms per liter.
RMA/ARARS/1455
-------
Table A-S ARARs for Groundwater for North Boundary of Rocky Mountain Arsenal
Page 2 of 3
Parameter
Chloride
Chloroform
Dibromochloropropane
Dieldrin
Diisopropylmethyl
phosphonate
Endrin
Fluoride
Methylene Chloride
Sulfate
Tetrachloroethylene
Trichloroethylene
Abbrev
Cl
CHCL3
DBCP
DLDRN
DIMP
ENDRN
F
CH2CL2
SO4
TCLEE
TRCLE
Cone
250,000
6
0.2
0.2
0.002
0.1**
8
2
0.2
4,000
2,000
5
5
250,000
5
5
5+
App
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Rel
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Apr
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Units Hrd
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Source
5 CCR 1002-8, Colorado Groundwater Standard
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.61, Federal primary MCL
5 CCR 1002-8, Colorado Groundwater Standard
5 CCR 1002-8, Colorado Groundwater Standard
5 CCR 1002-2, State Discharge Permit System PQLs (referenced in CBSG
Table A)
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.61, Federal primary MCLG
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.61, Federal primary MCLG
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.61, Federal primary MCL
5 CCR 1002-8, Colorado Groundwater Standard
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.61, Federal primary MCL
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.61, Federal primary MCL
f Containment System Remedial Goal for this parameter (identified in Section 9 of the ROD) is more stringent than the ARAR and is listed in Table A-7 as a TBC.
* Asterisk indicates concentration below the lowest USAEC Certified Reporting Limit.
** PQL Detection levels for Gas Chromatography/Mass Spectrometry.
Hg/l Indicates micrograms per liter.
RMA/ARARS/1455
-------
Table A-5 ARARs for Groundwater for North Boundary of Rocky Mountain Arsenal
Page 3 of 3
Parameter
Abbrev Cone App Rel Apr Units Hrd Source
Toluene
Xylenes
5+ N Y Y ng/l
MEC6H5 1,000 N Y Y ng/l
1,000 N Y Y ug/l
XYLEN 10,000* N Y Y
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.50, Federal primary MCLG
5 CCR 1002-8, Colorado Groundwater Standard
5 CCR 1002-8, Colorado Groundwater Standard
' Containment System Remedial Goal for this parameter (identified in Section 9 of the ROD) is more stringent than the ARAR and is listed in Table A-7 as a TBC.
* Asterisk indicates concentration below the lowest USAEC Certified Reporting Limit.
** PQL Detection levels for Gas Chromatography/Mass Spectrometry.
Hg/1 Indicates micrograms per liter.
RMA/ARARS/1455
-------
Table A-6 ARARs for Groundwater at Basin A Neck IRA Treatment System
Page 1 of 2
Parameter
1 ,2-Dichloroethane
I , I -Dichloroethylene
I , I , I -Trichloroethane
Arsenic (Total)
Atrazine
Benzene
Carbon Tetrachloride
Chlorobenzene
Chloroform
Dichlorodiphenyltrichloroethane
Abbrev
12DCLE
IIDCE
1HTCE
AsTOT
ATZ
C6H6
CCL4
CLC6H5
CHCL3
DDT
Cone
5
0.4*
I**
7
7
200
200
50
50
3
3
5
5
5
0.3
I**
1 00
1 00
6
O.I
App
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Rel
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Apr
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
* Asterisk indicates concentration below the lowest USAEC Certified
** PQL Detection levels for Gas Chromatography/Mass Spectromelry
Hg/l Indicates micrograms per liter.
Units Hrd
Mg/l
Mg/l
re/i
Mg/l
Mg/l
Mg/l
Mg/l
ME/I
Mg/l
Mg/l
Mg/l
re/i
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Source
40 CFR 1 4 1.6 1, Federal primary MCL
5 CCR 1002-8, Colorado Groundwater Standard
5 CCR 1002-2, State Discharge Permit System PQLs (referenced in
CBSG Table A)
40 CFR 141.61, Federal primary MCLG
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.61, Federal primary MCLG
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.11, Federal primary MCL
5 CCR 1003-1, Colorado Groundwater Standard
40 CFR 141.50, Federal primary MCLG
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.61, Federal primary MCL
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.61, Federal primary MCL
5 CCR 1002-8, Colorado Groundwater Standard
5 CCR 1002-2, State Discharge Permit System PQLs (referenced in
CBSG Table A)
40 CFR 141.50, Federal primary MCLG
5 CCR 1002-8, Colorado Groundwater Standard
5 CCR 1002-8, Colorado Groundwater Standard
5 CCR 1002-8, Colorado Groundwater Standard
Repotting Limit.
RMA/ARARs/1456
-------
Table A-6 ARARs for Groundwater at Basin A Neck IRA Treatment System
Page 2 of 2
Parameter
Dieldrin
Endrin
Hexachlorocyclopentadiene
Mercury
Tetrachloroethylene
Trichloroethylene
Abbrev
DLDRN
ENDRN
CL6CP
Hg
TCLEE
TRCLE
Cone
0.002
0.1**
2
0.2
50
50
2
2
5
5
5
5
App
N
N
N
N
N
N
N
N
N
N
N
N
Rel
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Apr
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Units Hrd
Hg/l
Hg/l
Mg/l
ug/l
ug/l
Mg/1
Jig/1
Hg/l
Jig/1
Hg/l
Jig/I
ug/l
Source
5 CCR 1002-8, Colorado Groundwater Standard
5 CCR 1002-2, State Discharge Permit System PQLs (referenced in
CBSG Table A)
40 CFR 141.50, Federal primary MCLG
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.50, Federal primary MCLG
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.51, Federal primary MCLG
5 CCR 1003-1, Colorado primary drinking water standard
40 CFR 141.61, Federal primary MCL
5 CCR 1002-8, Colorado Groundwater Standard
40 CFR 141.61, Federal primary MCL
5 CCR 1002-8, Colorado Groundwater Standard
Asterisk indicates concentration below the lowest USAEC Certified Reporting Limit.
PQL Detection levels for Gas Chromatography/Mass Spectrometry
Indicates micrograms per liter.
RMA/ARARs/1456
-------
Table A-7 TBCs for Groundwater
Page 1 of 1
Parameter
Arsenic
Benzene
Isopropyl Methylphosphonic acid
N-nitrosoditnethylamine
Methylisobutyl Ketone
Parathion
Trichloroethylene
Isodrin
Dicyclopentadiene
1 ,4-Oxathiane
Dithiane
Chlorophyenylmethyl sulfide
Chlorophyenylmethyl sulfone
Chlorophyenylmethyl Sulfoxide
Malathion
Xylenes
Abbrev
AsTOT
C6H6
1MPA
NDMA
MIBK
PRTHN
TRCLE
ISODR
DCPD
OXAT
DITH
CPMS
CPMSO2
CPMSO
MLTHN
XYLEN
Cone
2.35*
3*
700
0.0007+
2000
200
3*
0.06*
46*
160*
18+
30*
36*
36+
100*
1000*
Units
Mg/1
Mg/1
Mg/1
Mg/1
Mg/I
Mg/1
Mg/I
Mg/I
Mg/I
Mg/1
Mg/I
Mg/I
Mg/l
Mg/I
Mg/1
Mg/1
Hrd Source
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Health-based value from off-post ROD (Harding Lawson Associates 1 995)
EPA Lifetime Health Advisory, 1992
Risk-based level, Integrated Risk Information System (EPA 1995)
Proposed Corrective Action Rule, 55 FR 30798, Appendix A, July 27, 1990
Proposed Corrective Action Rule, 55 FR 30798, Appendix A, July 27, 1990
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Health-based value from off-post ROD (Harding Lawson Associates 1995)
Containment System Remediation Goals identified Section 9 of the ROD.
Indicates micrograms per liter.
Mg/1
RMA/ARARS/II35
-------
Table A-8 ARARs for Surface Water
Parameter
1,1,1 -Trichloroethane
1 , 1 ,2-Trichloroethane
1 , 1 ,2-Trichloroethane
1,2-Dichloroethane
Dichloroethylenes
Aldrin
Arsenic (V)
Arsenic (V)
Benzene
Cadmium
Carbon Tetrachloride
Chlordane
Chloroform
Abbrev
111TCE
112TCE
112TCE
I2DCLE
DCE
ALDRN
AsV
AsV
C6H6
Cd
CCL4
CLDAN
CHCL3
Cone
18,400
9,400
18,000
9,400
20,000
20,000
118,000
11,600
3
1.5
48
150
850
360
5,300
5,300
4.3
4.3
35,200
35,200
1.2
1,240
1,240
App
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Rel
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Apr
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Units Hrd
Hg/l
Hg/1
Hg/l
ug/1
ug/1
Hg/l
ug/1
.ug/i
ug/1
ug/i
ug/i
ug/i
ug/i
ug/1
ug/i
ug/i
Hg/l 550+ mg/l
ug/1 550+ mg/l
ug/1
Ug/l
Ug/l
Ug/l
Mg/l
Hardness value based on one-tailed 95% upper tolerance calculation of data in
* Asterisk indicates concentration below the lowest USAEC Certified Reporting
Hg/l Indicates micrograms per liter.
Page 1 of 5
Source
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
the RMA Environmental Database.
Limit.
RMA/ARARS/1136
-------
Table A-8 ARARs for Surface Water
Page 2 of 5
Parameter
Chloroform
Chromium (HI)
Chromium (III)
Chromium (VI)
Chromium (VI)
Copper
Copper
Cyanide (Free)
Cyanide (Free)
DDT (Total)
DDT (Total)
* Hardness
* Asterisk
Hg/l Indicates
Abbrev
CHCL3
CrIH
Crlll
CrVI
CrVI
Cu
Cu
CYNF
CYFN
PPDDT
PPDDT
Cone
28,900
28,900
836
836
7,015
7,015
11
II
16
16
51
51
88
88
5.2
22
5
*0.001
0.001
0.1
•1.1
0.55
App
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Rel
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Apr
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Units
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
ug/l
Mg/l
Mg/l
ug/l
Ug/l
ug/l
ug/l
Jig/1
ug/l
Mg/l
Mg/l
ug/l
Mg/l
Mg/l
Mg/l
Mg/l
Hrd
550* mg/l
550+ mg/l
550+ mg/l
550* mg/l
550* mg/l
550+ mg/l
550' mg/l
5504 mg/l
value based on one-tailed 95% upper tolerance calculation of data in
indicates concentration below the lowest USAEC Certified Reporting
micrograms per liter.
Source
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
State Discharge Permit System PQLs [5 CCR 1002-2: 6.9.2(13) Table 1]
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
the RMA Environmental Database.
Limit.
RMA/ARARS/1136
-------
Table A-8 ARARs for Surface Water
Page 3 of 5
Parameter
DDE
Dieldrin
Dieldrin
Endrin
Endrin
Ethylbenzene
Fluoride
Hexachlorocyclopentadiene
Hexachlorocyclopentadiene
Lead
Lead
Abbrev
PPDDE
DLDRN
DLDRN
ENDRN
ENDRN
ETCGH5
F
CL6CP
CL6CP
Pb
Pb
Cone
1,050
1,050
*0.0019
0.0019
0.1
*2.5
1.3
*0.0023
0.0023
0.1
*0.18
0.09
32,000
2,000
*5.2
5
*7
7
27.9
43.6
715
1,504
App
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Rel
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Apr
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Units Hrd
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Mg/l
Hg/l 550' mg/I
ug/1 550' nig/I
Hg/l 550+ mg/I
jig/I 550* mg/I
* Hardness value based on one-tailed 95% upper tolerance calculation of data in
* Asterisk indicates concentration below the lowest USAEC Certified Reporting
pg/1 Indicates micrograms per liter.
Source
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
State Discharge Permit System PQLs [5 CCR 1002-2: 6.9.2(13) Tables]
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
State Discharge Permit System PQLs [5 CCR 1002-2: 6.9.2(13) Tables]
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
State Surface Water Standard, 5 CCR 100, Table 2 Health based stds
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
the RMA Environmental Database.
Limit.
RMA/ARARS/1136
-------
Table A-8 ARARs for Surface Water
Page 4 of 5
Parameter
Malathion
Mercury
Mercury
Parathion
Parathion
Tetrachloroethylene
Tetrachloroethylene
Toluene
Trichloroethylene
Trichloroethylene
Zinc
Zinc
Abbrev
MLTHN
Hg
Hg
PRTHN
PRTHN
TCLEE
TCLEE
MEC6H5
TRCLE
TRCLE
Zn
Zn
Cone
*0.1
0.1
0.2
0.012 v
0.1
2.4
2.4
•0.013
*0.065
840
840
5,280
5,280
17,500
17,500
21,900
21,900
45,000
45,000
439
449
485
496
App
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Rel
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Apr
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Units
ug/1
ug/1
ug/1
ug/1
ug/i
ug/1
Mg/l
ug/1
ug/1
ug/1
ug/1
ug/1
US/I
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/I
Hrd Source
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
State Discharge Permit System PQLs [5 CCR 1002-2: 6.9.2(13) Tables]
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
State Surface Water Standard, chronic toxicity to freshwater aquatic life
Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
State Surface Water Standard, acute toxicity to freshwater aquatic life
550* mg/l Federal Water Quality Criteria, chronic toxicity to freshwater aquatic life
550* mg/l State Surface Water Standard, chronic toxicity to freshwater aquatic life
550* mg/l Federal Water Quality Criteria, acute toxicity to freshwater aquatic life
550* mg/l State Surface Water Standard, acute toxicity to freshwater aquatic life
* Hardness value based on one-tailed 95% upper tolerance calculation of data in the RMA Environmental Database.
* Asterisk indicates concentration below the lowest USAEC Certified Reporting Limit.
Ug/1 Indicates micrograms per liter.
RMA/ARARS/H36
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Table A-8 ARARs for Surface Water Page 5 of 5
Parameter Abbrev Cone App Rel Apr Units Hrd Source
Diisopropylmethyl DIMP 8 N Y Y ug/l State Surface Water Standard, Human Health Based Water Supply
Phosphonate
* Hardness value based on one-tailed 95% upper tolerance calculation of data in the RMA Environmental Database.
* Asterisk indicates concentration below the lowest USAEC Certified Reporting Limit.
Hg/l Indicates micrograms per liter.
RMA/ARARS/M36
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Table A-9 TBCs for Surface Water
Page 1 of 1
Parameter
Ethylbenzene
Methylene chloride
Abbrev
ETC6H5
CH2CL2
Cone
4000
680
*5
App Hrd Source
Ug/l Proposed Corrective Action Rule, 55 FR 30798, Appendix
A, July 27, 1990
ug/l EPA Integrated Risk Information System
ug/l Proposed Corrective Action Rule, 55 FR 30798, Appendix
Methylisobutyl ketone
n-Nitrosodimethylamine
Xylenes (Total)
MIBK
NNDMEA
XYLEN
2000
0.007
10.0
70000
"g/l
wfl
A, July 27, 1990
Proposed Corrective Action Rule, 55 FR 30798, Appendix
A, July 27, 1990
EPA Integrated Risk Information System
5 CCR 1002-2, State Discharge Permit System PQLs [5
CCR 1002-2 Section 6.9.2(13) Table 1]
Proposed Corrective Action Rule, 55 FR 30798, Appendix
A, July 27, 1990
* Asterisk indicates concentration below the lowest USAEC Certified Reporting Limit.
Hg/l Indicates micrograms per liter.
RMA/ARARS/1137
-------
Table A-10 TBCs for Soil and Sediments
Page 1 of 1
Chemical Compound
RCRA Proposed Corrective Action Rule Levels (ppm)2
VHOs
1,2-Dichloroethane
1,1-Dichloroethylene
1,1,2,2-Tetrachloroethane
1,1,1 -Trichloroethane
1,1 ^-Trichloroethane
Carbon tetrachloride
Chlorobenzene
Chloroform
Methylene chloride
Tetrachloroethylene
Trichloroethylene
Toluene
8
10
40
7,000
100
5
2,000
100
90
10
60
20,000
VAO
Ethylbenzene
Xylenes
8,000
200,000
SHOs
Hexachlorocyclopentadiene
600
OCPs
Aldrin
Chlordane
DDE
DDT
Dieldrin
Endrin
Parathion
0.04
0.5
2
2
0.04-9.033
20-4.033
500
Arsenic
Mercury
PCBs
80
20
50*
ICP Metals
Cadmium
Chromium (VI)
40
400
1 The following COCs currently do not have proposed RCRA Corrective Action Rule Levels:
Benzene
Chloroacetic acid Isodrin
Dibromochloropropane Lead
Dicyclopentadiene
2 Source: EPA proposed Corrective Action Rule for solid waste management units (55 FR 30798; July 1990)
3 Source: EPA proposed Water Quality Criteria for the Protection of Benthic Organisms for Dieldrin and Endrin (these are
only applicable to lake sediments and not to soils)
* Based on TSCA regulatory threshold value and not RCRA Subpart 5 standards
ICP Indicates inductively coupled plasma. VAO Indicates volatile aromatic organic.
OCP Indicates organochlorine pesticide. VHO Indicates volatile halogenated organic.
SHO Indicates semivolatile halogenated organic.
RMAU140 06/06/96 10:53am bpw
-------
Table A-11 Location-Specific ARARs and TBCs
Pagel of 4
Location
Citation
Requirements
Areas prone to surface movement
Within 100-year floodplain
Wetlands
Area affecting stream or river
Historically or culturally
significant properties owned or
controlled by a federal agency
40CFR264.18(a)
6CCR 1007-3,264.18(a)
40 CFR 257.3-1 (a)
40CFR264.18(b)
6 CCR 1007-3, 264.18(b)
Executive Order 11988
40 CFR 6.302 (b)
40 CFR 6, Appendix A, Section 3(a),
3(b)(l),&3(b)(4)
44 FR 43239 (July 24, 1979)
42 U.S.C. Section 1344
40 CFR Parts 230, Subpart H
33 CFR 320-330
Executive Order 11990
40 CFR 6.302 (a)
40 CFR 6, Appendix A, Section 3(a) &
3(c)
16 USC Part 661-663
40 CFR 6.302 (e) and (g)
16USC1274£ksejjr
16USC470aaeL_seg,.
36 CFR 800
44 FR 6068
New treatment facilities, storage facilities, or hazardous waste disposal facilities should
not be within 200 ft of a fault. Facilities should not be located in areas prone to
earthquakes, floods, fire, or other disasters that could cause a breakdown of the public
water system.
Facilities should be designed, constructed, operated, and maintained to prevent
washout of any hazardous waste by a 100-year flood. Floodplain management
requirements exist to avoid adverse impacts associated with the occupancy and
modification of floodplains.
The discharge of dredged or fill material into the waters of the United States is
prohibited without a permit. Protection of wetlands is required to avoid adverse
impacts associated with the destruction and modification of wetlands.
Fish or wildlife resources that may be affected by actions resulting in control or
structural modification of any natural stream or body of water should be protected.
Federal agencies taking such actions must consult with the U.S. Fish and Wildlife
Service. The Wild and Scenic Rivers Act established requirements for water resource
projects affecting wild, scenic or recreational rivers in the National Wild and Scen'ic
Rivers system.
The National Historic Preservation Act identifies procedures for protection of
Historically and Culturally Significant Properties, including Colorado's delegated
responsibilities under the act.
RMA ARARS 1/96
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Table A-11 Location-Specific ARARs and TBCs
Page 2 of 4
Location
Citation
Requirements
Prehistoric, historic, or
archeological sites owned or
controlled by a federal agency
Historical, prehistorical and
archeological resources and State
Register of Historic Places Act
36 CFR 60
36 CFR 63
Proposed 36 CFR 66
36 CFR 296
43 CFR 3
43 CFR 7
CRS§ 24-80-401 eLseq,
CRS §24-80. i-i
Department of Interior regulations for determining site eligibility for the National
Register of Historic Places and standards for data recovery should be complied with.
Consultation with the Colorado Historic Society, the State Archeologist, and State
Register of Historic Places is required before an action is taken.
Cultural resource owned or
controlled by a federal agency
35 FR 8921
Archeological or historic site
owned or controlled by a federal
agency
Historically significant property
owned and managed by the U.S.
Army
Army Regulation 420
32 CFR 650.181 to 193
Technical Manual 5-801-1
Technical Note 78-17
32 CFR 229
Executive Order 11593:
Any federal agency controlling culturally significant resources is the designated leader
in the preservation of those resources. This order ensures that all culturally significant
resources located on an agency's property are protected.
The federal agencies are responsible for identifying, evaluating, and nominating (where
appropriate) to the National Register of Historic Places all culturally significant
resources found on their land.
The Archeological and Historic Preservation Act of 1974 requires that a federal agency
notifies the Secretary of Interior of any agency project that will destroy a significant
archeological site. The Secretary of the notifying agency may support data recovery
programs to preserve the resource.
U.S. Department of the Army has procedures and standards for preserving historically
significant properties and procedures for implementing the Archeological Resources
Protection Act. Department of the Army Regulations 420 prescribe Army policy
procedures and responsibilities for compliance with the National Historic Preservation
Act of 1966, as amended, for maintaining the preservation of historically significant
sites, the hiring of qualified personnel to manage the sites, and the conduct of state-of-
the-art standards for preservation, personnel, and projects for accomplishment of the
historic preservation program.
This regulation also requires that each installation prepare a historic preservation plan
or have documentation on file indicating that no resources appropriate for such
management planning exist.
RMA ARARS 1/96
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Table A-11 Location-Specific ARARs and TBCs
Page 3 of 4
Location
Citation
Requirements
Archeological resources on U.S.
Department of the Army
installations
Prehistoric, historic, or
archeological sites owned or
controlled by the U.S. Army
Prehistoric, historic, or
archeological sites owned or
controlled by the U.S. Army
16USC470aagL_segi
!6USC470a
36 CFR 800
43 CFR 3
43 CFR 7
36 CFR 296
Executive Order No. 11593, May 13,
1971,36 FR 8921, Section 2(b).
The Archeological Resources Protection Act of 1979 establishes criminal and civil
penalties for anyone damaging archeological resources. This act also allows the
Secretary of the Army to issue excavation permits for archeological resources.
The National Historic Preservation Act of 1966 requires the Secretary of the Interior to
inventory, evaluate, and nominate (where appropriate) significant properties to the
National Register of Historic Places.
Preservation of American Antiquities: Provides for the protection of historic or
prehistoric remains of any object of any antiquity on federal lands.
Protection of Archeological Resources: Provides for the protection of archeological
resources located on public lands.
According to Executive Order No. 11593, each federal agency shall exercise caution to
ensure that any such property that might qualify for inclusion is not inadvertently
transferred, sold, demolished, substantially altered, or allowed to deteriorate
significantly.
16 USC 470 aa et. seg^
36 CFR 60.6
National Historic Landmark
Program
36 CFR 65
Based on the historical and field inventory information, the significance of all
identified sites should be evaluated following criteria set forth in 36 CFR 60.6 and in
accordance with the Preservation Office before conducting any ground-altering
activity with guidelines from the Colorado State Historic Preservation Office. The act
also requires the Army agency to consult with the Advisory Council on Historic issues
that may affect those significant properties. A federal agency should take into account
the effect of the project on any National Register-listed or eligible property and is
directed to complete an appropriate data recovery program before such a site is
damaged or destroyed.
The National Historic Landmark Program was established to identify and designate
National Historic Landmarks and encourage the long range preservation of nationally
significant properties that illustrate or commemorate the history and prehistory of the
United States.
RMA ARARS 1/96
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Table A-11 Location-Specific ARARs and TBCs
Page 4 of 4
Location
Citation
Requirements
Colorado Requirements for Siting 6 CCR 1007-2, Part 2
of Hazardous Waste Disposal Site
National Wildlife Refuge System
Administration Act
16USC668ddet. Seq.
50CFR25
State siting requirements control the location, design, and design performance of
hazardous waste disposal sites. Such disposal sites must be located and designed in a
manner that ensures long-term protection of human health and the environment.
Disposal sites must be designed to prevent adverse effects on:
• Groundwater
• Surface water
• Air quality
Public health and the environment
The National Wildlife Refuge Administration Act prohibits the taking or possessing
any fish, bird, mammal, or other wild vertebrate or invertebrate animals or part or nest
or egg thereof within any such area; or enter, use, or otherwise occupy any such area
for any purpose; unless such activities are performed by persons authorized to manage
such area or unless such activities are permitted.
RMA ARARS 1/96
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 1 of 13
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPart I910
29CFRI9l0.l20(b)to(j)
29CFR1926SubpartP
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
29 CFR 1926 Subpart P provides guidelines for workers engaged in
activities related to construction and utilization of trenches and
ditches.
RMA ARARS 1/96
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 2 of 13
Action
Citation
Requirements
Worker exposure
AR-385-lO
AR 385-64
AMC-R395-100
DAA Pam 40-8 fTBC]
FM 3-21 [TBC]
TM 10-277 [TBC]
Army Corps of Engineers (ACOE)
Guidance on Safety Concepts for UXO
[TBC]
ACG1H 1991-1992 [TBC]
NIOSH 1990 [TBC]
29CFR 1910.1000
If unexploded ordnance (UXO) is encountered during excavation,
workers must comply with the substantive requirements of AMCR
385-100, AR 385-10, AR 385-64, as well as guidance provided in
DA Pam 40-8, FM 3-21, TM 10-277 and ACOE guidance for UXO
regarding health and safety of workers associated with ammunition,
explosives, and chemical agents.
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
In addition to the chemicals listed in Table A-46, excavation at
Basin F is expected to encounter ammonia. The ammonia fumes
will be neutralized using an acidified scrubber that utilizes
hydrochloric acid. Worker exposure standards for these chemicals
are as follows:
Ammonia ACGIH-TWA = 25 ppm, 17 mg/m3
Short-Term Exposure Limit (STEL) =
35 ppm, 24 mg/m3
NIOSH-REL = 25 ppm, 18 mg/m3
STEL = 35 ppm, 27 mg/m3
OSHA-Pertnissible Exposure Limit (PEL) =
50 ppm, 35 mg/m3
Hydrogen Chloride ACGIH-ceiling = 5 ppm, 7.5 mg/m3
NIOSH-ceiling = 5 ppm, 7 mg/m3
OSHA-ceiling = 5 ppm, 7 mg/m3
If chemical agent is encountered during excavation, workers must
comply with the chemical-specific exposure guidelines for chemical
agents and breakdown products outlined in Table A-28 of this
document.
RMA ARARS l/%
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 3 of 13
Action
Citation
Requirements
Air Emission Control
Particulate emissions during excavation
and backfill
5 CCR 1001-3, Regulation 1,
Section HI (D)
5 CCR 1001-5, Regulation 3
5 CCR 1001-2, Section II
Emission of hazardous air pollutants
Volatile organic chemical emissions
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-9, Regulation?
(OSHA regulations and other health and safety requirements are
actually independently applicable requirements, not ARARs and
TBCs. ACG1H and NIOSH values are provided as guidelines.)
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. In addition, no off-site transport of
participate matter is allowed. A fugitive dust control measure will
be written into the workplan in consultation with the state for the
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado Air Pollution Emission Notice (APEN) requirements.
• Emission of certain hazardous air pollutants is controlled by
NESHAPs. Excavation and backfill of soils could potentially cause
emission of hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Volatile organic compound (VOC) regulations apply to ozone
nonattainment areas. The air quality control area for RMA is
currently nonattainment for ozone. Storage and transfer of VOCs
and petroleum liquids are controlled by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
RMA ARARS 1/96
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 4 of 13
Action
Citation
Requirements
Odor emissions
5 CCR 1001-4, Regulation 2
Air emissions from diesel-powered
vehicles associated with excavation and
backfill operations
5 CCR 1001-I5, Regulation 12
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
I) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Colorado Diesel-Powered Vehicle Emission Standards for Visible
Pollutants apply to motor vehicles intended, designed, and
manufactured primarily for use in carrying passengers or cargo on
roads, streets, and highways, and state as follows:
1) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing 7,500 pounds
and less, empty weight, any air contaminant, for a period greater
than five (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 40% opacity.
2) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing more than
7,500 pounds, empty weight, any air contaminant, for a period
greater than (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 35% opacity, with the exception of subpart "C".
3) No person shall emit or cause to be emitted into the atmosphere
from any naturally aspirated (non-turbocharged) diesel-powered
motor vehicle weighing more than 7,500 pounds, empty weight,
operated above 7,000 ft (mean sea level) any air contaminant for
a period greater than five (5) consecutive seconds, which is of
such a shade or density as to obscure an observer's vision to a
degree in excess of 40% opacity.
RMA ARARS 1/96
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 5 of 13
Action
Citation
Requirements
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5CCR1001-I4
CRS Section 42-4-307(8)
Smoke and opacity
Waste Characterization
Asbestos waste storage management
5 CCR 1001-3, Regulation 1, Sect H.A
6 CCR 1007-2, Part B, Section 5.4
4) Any diesel-powered motor vehicle exceeding these requirements
shall be exempt for a period of 10 minutes if the emissions are a
direct result of a cold engine start-up and provided the vehicle is
in a stationary position.
5) These standards shall apply to motor vehicles intended,
designed, and manufactured primarily for travel or use in
transporting persons, property, auxiliary equipment, and/or cargo
over roads, streets, and highways.
Excavation and backfilling of soils must be conducted in a manner
that does not cause adverse impacts on visibility. Visibility
impairment interferes with the management, protection,
preservation, or enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the Automobile
Inspection and Readjustment (AIR) Program area is a standard
visual range of 32 miles. The averaging time is 4 hours. The
standard applies during an 8-hour period from 8:00 a.m. to 4:00
p.m. each day (Mountain Standard Time or Mountain Daylight
Time, as applicable). The visibility standard applies only during
hours when the hourly average humidity is less than 70%.
Excavation and backfilling of soils must be conducted in a manner
that will not allow or cause the emission into the atmosphere of any
air pollutant that is in excess of 20% opacity.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos storage.
RMA ARARS 1/96
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 6 of 13
Action
Citation
Requirements
Asbestos waste handling management
Solid waste determination
Determination of hazardous waste
40CFR6l,SubpartM
5 CCR 10001-10, Regulation Part B,
Section S.B.IIl.c.8
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
Prevent discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing wastes; deposit
asbestos-containing waste as possible at disposal site; mark
transport vehicle appropriately during loading and unloading
operations.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos handling, transportation, and storage.
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
•• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Wastes generated during soil excavation activities must be
characterized and evaluated according to the following method to
determine whether the waste is hazardous:
Determine whether the waste is excluded from regulation under
40 CFR 261.4
Determine whether the waste is listed under 40 CFR 261
RMA ARARS 1/96
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 7 of 13
Action
Citation
Requirements
Solid waste classification
6 CCR 1007-2, Section 1
• Determine whether the waste is identified in 40 CFR 261 by
testing the waste according to specified test methods or by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
I) "Industrial wastes", which includes ail solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
RMA ARARS 1/96
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Table A-12 Action-Specific ARARs and TBCs for Conventionai Excavation/Backfill
Page 8 of 13
Action
Citation
Requirements
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6CCR 1007-3 Part 264
40 CFR Part 268
6CCR 1007-3 Part 268
6CCR 1007-3
Parts detailed below
Part 264.13
6 CCR 1007-3 Sect 264.13
Part 264.90
6 CCR 1007-3 Sect 264.90
5) "Inert material", which includes solids that are not soluble in
water and therefore non-putrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community,
commercial, and special wastes are expected from soil excavation at
RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
If soil excavation at RMA generates hazardous wastes, the wastes
must be treated, stored or disposed in accordance with RCRA
regulations, including LDRs-UTS (if placement occurs).
Some of the Colorado standards for owners and operators of
hazardous waste treatment, storage, and disposal facilities are more
stringent than the equivalent federal regulations. The standards that
are more stringent are detailed below.
General waste analysis requirements
Groundwater Monitoring Standards
RMA ARARS 1/96
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 9 of 13
Action
Citation
Requirements
Part 264.97 (g)(3)
6 CCR 1007-3 Sect 264.97(g)(3)
Part 264.98 (c)
6 CCR 1007-3 Sect 264.98(c)
Part 264.99 (C)(3)(i)(iii)
6 CCR 1007-3 Sect 264.99(C)(3)(i)(iii)
Part 264.100 (e)(2)
6 CCR 1007-3 Sect 264.100(e)(2)
Part 264.171-173
6 CCR 1007-3 Sect 264.171-173
Part 264.101 (c)(l)
6 CCR 1007-3 Sect264.101(c)(l)
Part 264.190 (c)
6 CCR 1007-3 Sect 264.190(c)
Part 264.251 (c)&(d)
6 CCR 1007-3 Sect 264.25 l(c) & (d)
Part 264.273 (c) & (d)
6 CCR 1007-3 Sect 264.273(c) & (d)
Part 264.312 (b)
6 CCR 1007-3 Sect 264.312(b)
Part 264.314 (a)
6 CCR 1007-3 Sect 264.314(a)
Part 264.314(f)
6 CCR 1007-3 Sect 264.314(0
General groundwater monitoring requirements
Groundwater detection monitoring program
Groundwater compliance monitoring program
Corrective action program
Applicability of the requirements of containers
Corrective action for solid waste management units
Applicability of the requirements for tanks or tank systems
Design and operating requirements for waste piles
Design and operating requirements for land treatment
Special requirements for ignitable and reactive wastes in landfills
Special requirements for bulk and containerized liquids in landfills
Liquid waste prohibition
RMA ARARS l/">6
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 10 of 13
Action
Citation
Requirements
Part 264.340 (a)(1)& (2)
6 CCR 1007-3 Sect 264.340(a)(l) & (2)
Part 264.16 (a)(l)
6 CCR 1007-3 Sect 264.16(a)(l)
Part 264.31 (a)
6 CCR 1007-3 Sect 264.31 (a)
Part 264.51 (a)
6 CCR 1007-3 Sect 264.51 (a)
Part 264.52 (a)
6 CCR 1007-3 Sect 264.52(a)
Part 264 Subpart cc [TBC]
6 CCR 1007-3 Part 264 Subpart cc
Treatment and disposal of hazardous debris 40 CFR 268.45
6 CCR 1007-3, Part 268.45
Management of Remediation Wastes
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Applicability of incinerator requirements
Personnel training
Facility design and operation requirements
Purpose and implementation of contingency plans
Content of contingency plans
Air emission standards for tanks
Hazardous debris generated during soil excavation activities must
be treated using specific technologies to extract, destroy, or
immobilize hazardous constituents on or in the debris if placement
occurs. In certain cases, after treatment the debris may no longer be
subject to RCRA Subtitle C regulation.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs and minimum technology requirements
for remediation wastes managed at CAMUs. These regulations
provide flexibility and allow for expedition of remedial decisions in
the management of remediation wastes. One or more CAMUs may
be designated at a facility. Placement of hazardous remediation
wastes into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 11 of 13
Action
Citation
Requirements
Temporary Units (TU)
6CCR 1007-3 Sect 264.553
40 CFR 264.553
Groundwater Injection
Reinjection of treated groundwater
RCRA Section 3020 (b)
OSWER Directive 9234.1-06 [TBC]
40 CFR 124, 144, 146, 147 (Subpart G),
and 148
Stormwater Management
Discharge of Stormwater to on-post surface 40 CFR Parts 122-125
waters
Dredged Material Management
Discharge of Dredged Materials
Certification of Federal Licenses and
Perm its (401 Certification)
40 CFR 230 Subpart B
33 USC Section 1341
Section 401 of Clean Water Act
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Reinjection of treated groundwater must be managed in accordance
with the guidelines in OSWER Directive 9234.1-06. Wells must be
constructed and installed and managed in compliance with the
substantive requirements of 40 CFR 124,144, 146,147 (Subpart
G), and 148.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
Dredging operations in wetland areas must be managed in
accordance with the applicable requirements based on the impacts
resulting from specific dredged material discharges associated with
sediment removal activities.
Provides for state review of facility operations for the purposes of
assuring that applicable effluent limitations or other limitations or
other applicable water quality requirements will not be violated.
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill
Page 12 of 13
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
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Table A-12 Action-Specific ARARs and TBCs for Conventional Excavation/Backfill Page 13 of 13
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
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Table A-13 Action-Specific ARARs and TBCs for Stockpiles of Debris/Equipment from Structures
Page 1 of9
Action
Citation
Requirements
Waste Characterization
Solid waste determination
Determination of hazardous waste
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 261.2
6 CCR 1007-3 Sect261.2
40 CFR 261.4 (a)
6 CCR 1007-3 Sect 261.4(a)
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
Drums, debris, and equipment from structures that stockpiled must
be evaluated to determine whether it may be recycled or reused or
whether it is a solid waste.
A solid waste is any discarded material that is not excluded by 40
CFR 261.4 (a) or that is not excluded by a variance granted under
40 CFR 260.30 and 260.31. Discarded material includes
abandoned, recycled, and waste-like materials. These materials
may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Solid wastes including drums, debris, and equipment from
structures that are temporarily stored in stockpiles must be
evaluated according to the following method to determine whether
the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
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Table A-13 Action-Specific ARARs and TBCs for Stockpiles of Debris/Equipment from Structures
Page 2 of 9
Action
Citation
Requirements
Solid waste classification
6 CCR 1007-2, Section I
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods or by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
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Table A-13 Action-Specific ARARs and TBCs for Stockpiles of Debris/Equipment from Structures
Page 3 of 9
Action
Citation
Requirements
Waste Management
Asbestos waste storage management
Asbestos waste handling management
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community, and
commercial wastes are expected from sstockpiles at RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos storage.
Prevent discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing wastes; deposit
asbestos-containing waste as possible at disposal site; mark
transport vehicle appropriately during loading and unloading
operations.
5 CCR 1001-8, Regulation Part B, Section Asbestos waste will be managed according to applicable substantive
8.B.HI.C.8 . requirements for asbestos handling, transportation, and storage.
6 CCR 1007-2, Part B, Section 5.4
40CFR61,SubpartM
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Table A-13 Action-Specific ARARs and TBCs for Stockpiles of Debris/Equipment from Structures
Page 4 of 9
Action
Citation
Requirements
PCB storage
PCB decontamination standards
Treatment, storage, or disposal of
hazardous wastes in waste piles
40CFR761.65
40CFR761.79
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
Treatment and disposal of hazardous debris 40 CFR 268.45
6 CCR 1007-3, Part 268.45
Design and operating requirements for
waste piles that contain hazardous wastes
40 CFR 264.251
6 CCR 1007-3 Sect 264.251
Storage facilities must be constructed with adequate roofs, walls;
have impervious floors with curbs (no floor drains expansion joints
or other openings); be located above 100 year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing non-
liquid PCBs, such as contaminated soil, rags, debris need not
comply with above requirements.
Containers must be dated when they are placed in storage.
All storage areas must be properly marked and stored articles must
be checked for leaks every 30 days.
PCB containers to be decontaminated by triple rinsing of internal
surfaces with solvent containing <50 ppm PCB.
Wastes stored in stockpiles that are determined to be RCRA
hazardous wastes must be stored, treated, and disposed in
compliance with all substantive requirements of Part 264 as
indicated in Exhibit 1-3 of the CERCLA Compliance with Other
Laws Manual including 40 CFR Part 264 Subpart 6 and LDRs-UTS
if placement occurs.
Hazardous debris must be treated using specific technologies to
extract, destroy, or immobilize hazardous constituents on or in the
debris. In certain cases after treatment, the debris may no longer be
subject to RCRA Subtitle C Regulation.
[Refer to Table A-20 for citations and requirements relevant to both
on-post and off-post solid waste landfills.]
Waste piles that contain hazardous wastes must:
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Tabte A-13 Action-Specific ARARs and TBCs for Stockpiles of Debris/Equipment from Structures
Page 5 of 9
Action
Citation
Requirements
Incompatible wastes in waste piles
Closure and post-closure care of waste
piles
6 CCR 1007-3
40 CFR 264.257
6 CCR 1007-3 Sect 264.257
40 CFR 264.17 (b)
6 CCR 1007-3 Sect 264.17(b)
40 CFR 264.258
6 CCR 1007-3 Sect 264.258
• Have a liner that is designed, constructed, and installed to
prevent migration of wastes out of the pile into adjacent soil,
groundwater, or surface water.
• Be constructed with materials to prevent failure, physical contact
with the waste, and that will endure stress of installation and
daily operation.
• Be placed on a foundation that provides support to prevent
failure of the liner.
• Be installed to cover all surrounding earth likely to be in contact
with the waste or leachate.
• Have a leachate collection system.
• Have a run-on control system capable of preventing flow onto
the active portion of the pile during peak discharge from at least
a 25-year storm.
• Have a run-off management system to collect and control at least
the water volume resulting from a 24-hour, 25-year storm.
• Be covered or managed properly if the pile contains any
particulate matter which may be subject to wind dispersal.
Colorado regulations are more stringent than federal requirements
by requiring that run-on and run-off control systems are designed
and operated to collect and control the water volume resulting from
a 24-hour, 100-year storm.
Incompatible wastes must not be placed in the same pile unless 40
CFR 264.17 (b) is complied with. Incompatible wastes must be
separated from other materials.
At closure, the owner or operator must remove or decontaminate all
waste residues and manage them as hazardous wastes.
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Table A-13 Action-Specific ARARs and TBCs for Stockpiles of Debris/Equipment from Structures
Page 6 of 9
Action
Citation
Requirements
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Worker Protection
Health and safety protection
29 CFR Part 1910
29 CFR 1910.120 (b) to (j)
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
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Table A-13 Action-Specific ARARs and TBCs for Stockpiles of Debris/Equipment from Structures
Page 7 of 9
Action
Citation
Requirements
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
Stormwater Management
Discharge of stormwater to on-post surface
waters
Air Emissions
Standard for asbestos waste disposal
40 CFR Parts 122-125
40 CFR 61 SubpartM
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable requirements, not ARARs or
TBCs. ACGIH and NIOSH values are provided as guidelines.)
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
Prevent discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing waste; deposit
asbestos-containing waste as soon as possible at disposal site; mark
transport vehicles appropriately during loading and unloading
operations.
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Table A-13 Action-Specific ARARs and TBCs for Stockpiles of Debris/Equipment from Structures
Page 8 of 9
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sould levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
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Table A-13 Action-Specific ARARs and TBCs for Stockpiles of Debris/Equipment from Structures Page 9 of 9
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
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Table A-14 Action-Specific ARARs and TBCs for Demolition of Structures
Page 1 of 10
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPart 1910
29CFR1910.120(b)to(j)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH1990[TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120(b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under the RCRA and the CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, the ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
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Table A-14 Action-Specific ARARs and TBCs for Demolition of Structures
Page 2 of 10
Action
Citation
Requirements
Demolition
Air emissions during demolition
5 CCR 1001-3, Regulation 1,
Section HI (D)
5 CCR IOOJ-5, Regulation 3
5 CCR 1001-2, Section II
Standard for asbestos waste disposal
Emission control for opacity
Emission of hazardous air pollutants
Volatile organic chemical emissions
40CFR61SubpartM
5 CCR 1001-3
Regulation I, Section II
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-9, Regulation 7
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. In addition, no off-site transport of
paniculate emissions is allowed. A fugitive dust control measure
will be written into the work plan in consultation with the state for
the remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Prevent discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing wastes; deposit
asbestos-containing waste as soon as possible at disposal site; mark
transport vehicle appropriately during loading and unloading
operations.
Demolition of structures shall not cause the emission into the
atmosphere of any air pollutant that is in excess of 20% opacity.
Emission of certain hazardous air pollutants is controlled by
NESHAPs. Demolition of structures could potentially cause
emission of hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
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Table A-14 Action-Specific ARARs and TBCs for Demolition of Structures
Page 3 of 10
Action
Citation
Requirements
Odor emissions
5CCR 1001-4, Regulation 2
Air emissions from diesel-powered
vehicles associated with demolition
5 CCR 1001-15, Regulation 12
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with IS more volumes of odor-free air
Colorado Diesel-Powered Vehicle Emission Standards for Visible
Pollutants apply to motor vehicles intended, designed, and
manufactured primarily for use in carrying passengers or cargo on
roads, streets, and highways, and state as follows:
I) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing 7,500 pounds
and less, empty weight, any air contaminant, for a period greater
than five (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 40% opacity.
2) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing more than
7,500 pounds, empty weight, any air contaminant, for a period
greater than (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 35% opacity, with the exception of subpart "C".
3) No person shall emit or cause to be emitted into the atmosphere
from any naturally aspirated (non-turbocharged) diesel-powered
motor vehicle weighing more than 7,500 pounds, empty weight,
operated above 7,000 ft (mean sea level) any air contaminant for
a period greater than five (5) consecutive seconds, which is of
such a shade or density as to obscure an observer's vision to a
degree in excess of 40% opacity.
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Table A-14 Action-Specific ARARs and TBCs for Demolition of Structures
Page 4 of 10
Action
Citation
Requirements
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
4) Any diesel-powered motor vehicle exceeding these requirements
shall be exempt for a period of 10 minutes if the emissions are a
direct result of a cold engine start-up and provided the vehicle is
in a stationary position.
5) These standards shall apply to motor vehicles intended,
designed, and manufactured primarily for travel or use in
transporting persons, property, auxiliary equipment, and/or cargo
over roads, streets, and highways.
Demolition of structures must be conducted in a manner that does
not cause adverse impacts on visibility. Visibility impairment
interferes with the management, protection, preservation or
enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as applicable). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Waste Characterization
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR 261
6 CCR 1007-3 Part 261
Wastes generated during the demolition of structures must be
characterized. Solid wastes must be evaluated according to the
following method to determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
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Table A-14 Action-Specific ARARs and TBCs for Demolition of Structures
Page 5 of 10
Action
Citation
Requirements
Solid waste determination
40 CFR 260
6CCR ! 007-3 Part 260
40 CFR 261.2
6CCR 1007-3 Sect 261.2
40 CFR 261.4 (a)
6 CCR 1007-3 Sect 261.4(a)
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
Solid waste classification
6 CCR 1007-3, Section 1
Drums, debris, and equipment from structures that stockpiled must
be evaluated to determine whether it may be recycled or reused or
whether it is a solid waste.
A solid waste is any discarded material that is not excluded by 40
CFR 261.4 (a) or that is not excluded by a variance granted under
40 CFR 260.30 and 260.31. Discarded material includes
abandoned, recycled, and waste-like materials. These materials
may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
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Table A-14 Action-Specific ARARs and TBCs for Demolition of Structures
Page 6 of 10
Action
Citation
Requirements
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
mounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other solids, including those that the Colorado
Department of Health may identify by regulation.
If present, only small quantities of industrial, community, and
commercial wastes are expected from slurry wall installation at
RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
RMA ARARS 1/96
-------
Table A-14 Action-Specific ARARs and TBCs for Demolition of Structures
Page 7 of 10
Action
Citation
Requirements
Waste Management
Asbestos waste storage management 6 CCR 1007-2, Part B, Section 5.4
Asbestos waste handling management 40 CFR 6I, Subpart M
PCB storage
PCB decontamination standards
Treatment, storage, or disposal of
hazardous waste
5 CCR 1001-10, Regulation Part B,
Section g.B.III.c.8
40 CFR 761.65
40 CFR 761.79
40 CFR Part 264
6 CCR 1007-3 Part 264
Asbestos waste will be managed according to applicable substantive
requirements for asbestos storage.
Prevent discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing wastes; deposit
asbestos-containing waste as possible at disposal site; mark
transport vehicle appropriately during loading and unloading
operations.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos handling, transportation, and storage.
Storage facilities must be constructed with adequate roofs, walls;
have impervious floors with curbs (no floor drains expansion joints
or other openings); be located above 100 year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing non-
liquid PCBs, such as contaminated soil, rags, debris need not
comply with above requirements.
Containers must be dated when they are placed in storage.
All storage areas must be properly marked and stored articles must
be checked for leaks every 30 days.
PCB containers to be decontaminated by triple rinsing of internal
surfaces with solvent containing <50 ppm PCB.
If structure demolition at RMA generates hazardous wastes, the
wastes must be treated and stores in accordance with RCRA
regulations.
RMA ARARS 1/96
-------
Table A-14 Action-Specific ARARs and TBCs for Demolition of Structures
Page 8 of 10
Action
Citation
Requirements
40 CFR Part 264 Subpart L
6CCR1007-3SubpartL
40 CFR Part 268
6 CCR 1007-3 Part 268
40 CFR Part 264 Subpart I
6 CCR 1007-3 Part 264 Subpart I
6 CCR 1007-3
Treatment and disposal of hazardous debris 40 CFR 268.45
6 CCR 1007-3 Sect 268.45
Corrective Action Management Units
Temporary Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Wastes stored in stockpiles that are determined to be RCRA
hazardous wastes must be stored, treated, and disposed in
compliance with RCRA regulations, including LDRs-UTS if
placement occurs.
Applicability of substantive requirements for containers.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed in Appendix A, Table A-12.
Hazardous debris encountered during slurry wall installation must
be treated using specific technologies to extract, destroy, or
immobilize hazardous constituents on or in the debris. In certain
cases after treatment, the debris may no longer be subject to RCRA
Subtitle C regulation.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
RMA ARARS 1/96
-------
Table A-14 Action-Specific ARARs and TBCs for Demolition of Structures
Page 9 of 10
Action
Citation
Requirements
On-post land disposal of hazardous wastes
Stormwater Management
Discharge of stormwater to on-post surface
water
Noise abatement
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
EPA/540/G-89/006 [TBC]
40 CFR Parts 122-125
Colorado Revised Statute, Section 25-12-
103
Based upon a determination of whether the disposal technique
constitutes placement, LDRs-UTS may be applicable. If placement
occurs, the on-site disposal facility must comply with the
substantive requirements of 40 CFR 264 (6 CCR 1007.3 Part 264)
and 40 CFR Part 268 (6 CCR 1007-3 Part 268).
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sould levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 DJH, nexll;QOj».m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
RMA ARARS 1/96
-------
Table A-14 Action-Specific ARARs and TBCs for Demolition of Structures
Page 10 of 10
Action
Citation
Requirements
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RM A ARARS 1/96
-------
Table A-1S Action-Specific ARARs and TBCs for Trenches
Action
Citation
Worker Protection
Health and safety protection 29 CFR Part 1910
29CFR 1910.120 (b) to (j)
29CFR1926SubpartP
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSHI990[TBC]
29 CFR 1910.1000
RMA ARARS 1/96
Page 1 of 6
Requirements
29 CFR I910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
29 CFR 1926 Subpart P provides guidelines for workers engaged in
activities related to construction and utilization of trenches and
ditches.
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NFOSH are outlined in Table A-46.
-------
Table A-1S Action-Specific ARARs and TBCs for Trenches
Page 2 of 6
Action
Citation
Requirements
Air Emissions
Air emissions during trench construction
5 CCR 1001-3, Regulation I,
Section III (D)
5 CCR lOOt-5, Regulation 3
5 CCR 1001-2, Section II
Emission control for opacity
Emission of hazardous air pollutants
Volatile organic chemical emissions
5 CCR 1001-3
Regulation 1, Section II
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-9, Regulation 7
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are presented as
guidelines.)
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. No off-site transport of paniculate matter
allowed. A fugitive dust control measure will be written into the
work plan in consultation with the state for each remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Trench construction shall not cause the emission into the
atmosphere of any air pollutant that is in excess of 20% opacity.
Emission of certain hazardous air pollutants is controlled by
NESHAPs. Trench construction could cause volatization of some
organic and metal contaminants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
RMA ARARS 1/96
-------
Table A-15 Action-Specific ARARs and TBCs for Trenches
Page 3 of 6
Action
Citation
Requirements
Odor emissions
5CCR 1001-4, Regulation 2
Air emissions from diesel-powered
vehicles associated with trench
construction
5 CCR 1001-15, Regulation 12
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use area—odors detected after the odorous air
has been diluted with IS more volumes of odor-free air
Colorado Diesel-Powered Vehicle Emission Standards for Visible
Pollutants apply to motor vehicles intended, designed, and
manufactured primarily for use in carrying passengers or cargo on
roads, streets, and highways, and state as follows:
I) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing 7,500 pounds
and less, empty weight, any air contaminant, for a period greater
than five (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 40% opacity.
2) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing more than
7,500 pounds, empty weight, any air contaminant, for a period
greater than (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 35% opacity, with the exception of subpart "C".
RMA ARARS 1/96
-------
Table A-15 Action-Specific ARARs and TBCs for Trenches
Action
Citation
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
RMA ARARS 1/96
Page 4 of 6
Requirements
3) No person shall emit or cause to be emitted into the atmosphere
from any naturally aspirated (non-turbocharged) diesel-powered
motor vehicle weighing more than 7,500 pounds, empty weight,
operated above 7,000 ft (mean sea level) any air contaminant for
a period greater than five (5) consecutive seconds, which is of
such a shade or density as to obscure an observer's vision to a
degree in excess of 40% opacity.
4) Any diesel-powered motor vehicle exceeding these requirements
shall be exempt for a period of 10 minutes if the emissions are a
direct result of a cold engine start-up and provided the vehicle is
in a stationary position.
5) These standards shall apply to motor vehicles intended,
designed, and manufactured primarily for travel or use in
transporting persons, property, auxiliary equipment, and/or cargo
over roads, streets, and highways.
Trench construction must be conducted in a manner that does not
cause adverse impacts on visibility. Visibility impairment interferes
with the management, protection, preservation, or enjoyment of
federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as applicable). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
-------
Table A-15 Action-Specific ARARs and TBCs for Trenches
Page 5 of 6
Action
Citation
Requirements
Stormwater Management
Discharge of storm water to on-post surface
waters
Noise abatement
40 CFR Parts 122-125
Colorado Revised Statute, Section 25-12-
103
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 D.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
RMA ARARS 1/96
-------
Table A-1S Action-Specific ARARs and TBCs for Trenches
Action
Citation
RMA ARARS I/96
Page 6 of 6
Requirements
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
-------
Table A-16 Action-Specific ARARs and TBC s for Caps/Covers
Action
Citation
Worker Protection
Health and safety protection
29CFRPart 1910
29CFR 1910.120 (b) to (j)
RMA ARARS 1/96
Page 1 of 6
Requirements
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
* Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable requirements, not ARARs and
TBCs. ACGIH and NIOSH values are presented as guidelines.)
-------
Table A-16 Action-Specific ARARs and TBC 8 for Caps/Covers
Page 2 of 6
Action
Citation
Requirements
Construction of Caps/Covers
Design/installation of caps/covers
Air Emission Control
Participate emissions during cap/cover
installation
Final Covers on Hazardous Waste
Landfills and Surface Impoundments
EPA/530/SW-89/047 [TBC]
5 CCR 1001-3, Regulation I,
Section III (D)
5 CCR 1001-5, Regulation 3
Emission control for opacity
Emission of hazardous air pollutants
5 CCR 1001-3, Regulation 1; Section II
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
Caps and covers must be designed and installed to prevent wind
dispersal of hazardous wastes. They should be designed,
constructed, and installed as specified in EPA/530/SW-89/047.
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. Excavation and backfilling of soils
conducted in a manner that will not allow or cause the emission in
excess of 20% opacity. In addition, no off-site transport of
paniculate matter is allowed. A fugitive dust control measure will
be written into the work plan in consultation with the state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Installation of caps/covers shall not cause the emission into the
atmosphere of any air pollutant that is in excess of 20% opacity.
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Installation of caps/covers could potentially cause
emission of hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
RMA ARARS 1/96
-------
Table A-16 Action-Specific ARARs and TBC s for Caps/Covers
Page 3 of 6
Action
Citation
Requirements
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
Odor emissions
5 CCR 1001-4, Regulation 2
Air emissions from diesel-powered 5 CCR 1001-15, Regulation I2
vehicles associated with installation of
caps/covers
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
I) For residential and commercial areas—odors detected odorous air
has been diluted with seven more volumes of odor-free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Colorado Diesel-Powered Vehicle Emission Standards for Visible
Pollutants apply to motor vehicles intended, designed, and
manufactured primarily for use in carrying passengers or cargo on
roads, streets, and highways, and state as follows:
1) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing 7,500 pounds
and less, empty weight, any air contaminant, for a period greater
than five (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 40% opacity.
2) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing more than
7,500 pounds, empty weight, any air contaminant, for a period
greater than (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 35% opacity, with the exception of subpart "C".
RMA ARARS 1/96
-------
Table A-16 Action-Specific ARARs and TBC s for Caps/Covers
Action
Citation
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
RMA ARARS 1/96
Page 4 of 6
Requirements
3) No person shall emit or cause to be emitted into the atmosphere
from any naturally aspirated (non-turbocharged) diesel-powered
motor vehicle weighing more than 7,500 pounds, empty weight,
operated above 7,000 ft (mean sea level) any air contaminant for
a period greater than five (5) consecutive seconds, which is of
such a shade or density as to obscure an observer's vision to a
degree in excess of 40% opacity.
4) Any diesel-powered motor vehicle exceeding these requirements
shall be exempt for a period of 10 minutes if the emissions are a
direct result of a cold engine start-up and provided the vehicle is
in a stationary position.
5) These standards shall apply to motor vehicles intended,
designed, and manufactured primarily for travel or use in
transporting persons, property, auxiliary equipment, and/or cargo
over roads, streets, and highways.
Installation of caps/covers must be conducted in a manner that does
not cause adverse impacts on visibility. Visibility impairment
interferes with the management, protection, preservation, or
enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
-------
Table A-16 Action-Specific ARARs and TBC s for Caps/Covers
Page S of 6
Action
Citation
Requirements
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
RMA ARARS 1/96
-------
Table A-16 Action-Specific ARARs and TBC s for Caps/Covers
Action
Citation
RMA ARARS I/96
Page 6 of 6
Requirements
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
-------
Table A-17 Action-Specific ARARs and TBC s for Concrete Liners
Page 1 of S
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPartl9lO
29CFRl910.120(b)to(j)
Worker exposure
29CFRl926SubpartP
ACGIHl991-1992[TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through Q) provides guidelines for workers
involved in hazardous waste operations land emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
29 CFR 1926 Subpart P provides guidelines for workers engaged in
activities related to construction and utilization of trenches and
ditches.
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
RMA ARARS 1/96
-------
Table A-17 Action-Specific ARARs and TBC s for Concrete Liners
Page 2 of 5
Action
Citation
Requirements
Air Emission Control
Particulate emissions during installation of
concrete liners
5 CCR 1001-3, Regulation I,
Section III (D)
5 CCR 1001-5, Regulation 3
Emission control for opacity
5 QCR 1001-3, Regulation 1, Section II
In addition to the chemicals listed in Table A-46, workers installing
the concrete liners will be exposed to Portland cement dust. Worker
exposure standards for Portland cement are the following:
Portland cement
ACGIH-TWA
NIOSH-REL
OSHA-TWA
10 mg/m3*
10mg/m3 (total),
5 mg/m3 (resp)
15 mg/m3 (total),
5 mg/m3 (resp)
* value is for total dust containing no asbestos land less than
1% crystalline silica
(OSHA regulations and other health and safety requirements are
actually independently applicable requirements, not ARARs and
TBCs. ACGIH and NIOSH values are presented as guidelines.)
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. Mixing of concrete material must be
conducted in a manner that will not allow or reuse emissions into
the atmosphere of any air pollutant in excess of 20% opacity. In
addition, no off-site transport of particulate matter is allowed. A
fugitive dust control measure will be written in the work plan in
consultation with the state for this remediation activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Construction of concrete liners shall not cause the emission into the
atmosphere of any air pollutant that is in excess of 20% opacity.
KM A ARARS 1/96
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Table A-17 Action-Specific ARARs and TBC s for Concrete Liners
Page 3 of 5
Action
Citation
Requirements
Emission of hazardous air pollutants
Visibility protection
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Concrete liner installation could potentially cause
emission of hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Concrete liner installation must be conducted in a manner that does
not cause adverse impacts on visibility. Visibility impairment
interferes with the management, protection, preservation, or
enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
RMA ARARS 1/96
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Table A-17 Action-Specific ARARs and TBC s for Concrete Liners
Page 4 of S
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a.
"Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
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Table A-17 Action-Specific ARARs and TBC s for Concrete Liners
Page 5 of S
Action
Citation
Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
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Table A-18 Action-Specific ARARs and TBCs for Slurry Walls
Action
Citation
Worker Protection
Health and safety protection
29 CFR Part 1910
29CFR 1910.120 (b) to 0)
29CFR1926SubpartP
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990
29 CFR 1910.1000
RMA ARARS 1/96
Page 1 of 9
Requirements
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through 0) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
29 CFR 1926 Subpart P provides guidelines for workers engaged in
activities related to construction and utilization of trenches and
ditches.
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
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Table A-18 Action-Specific ARARs and TBCs for Slurry Walls
Page 2 of 9
Action
Citation
Requirements
Air Emissions
Air emissions during slurry wall
construction
5 CCR 1001-3, Regulation I,
Section III (D)
5 CCR 1001-5, Regulation 3
5 CCR 1001-2, Section II
Emission control for opacity
Emission of hazardous air pollutants
Volatile organic chemical emissions
5 CCR 1001-3,
Regulation I, Section II
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-9, Regulation 7
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. Slurry wall construction must be conducted
in such a manner that will not allow or cause emissions into the
atmosphere of any air pollutants in excess of 20% opacity. In
addition, no off-site transport of particulate matter is allowed. A
fugitive dust control measure will be written in the work plan in
consultation with the state for this remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Slurry walls shall not cause the emission into the atmosphere of any
air pollutant which is in excess of 20% opacity.
Emission of certain hazardous air pollutants is controlled by
NESHAPs. Slurry wall construction could cause volatization of
some organic and/or metal contaminants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
RMA ARARS 1/96
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Table A-18 Action-Specific ARARs and TBCs for Slurry Walls
Page 3 of 9
Action
Citation
Requirements
Odor emissions
5CCR 1001-4, Regulation 2
Air emissions from diesel-powered
vehicles associated with slurry wall
construction
5 CCR 1001-15, Regulation 12
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Colorado Diesel-Powered Vehicle Emission Standards for Visible
Pollutants apply to motor vehicles intended, designed, and
manufactured primarily for use in carrying passengers or cargo on
roads, streets, and highways, and state as follows:
!) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing 7,500 pounds
and less, empty weight, any air contaminant, for a period greater
than five (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 40% opacity.
2) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing more than
7,500 pounds, empty weight, any air contaminant, for a period
greater than (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 35% opacity, with the exception of subpart "C".
RMA ARARS 1/96
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Table A-18 Action-Specific ARARs and TBCs for Slurry Walls
Page 4 of 9
Action
Citation
Requirements
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
Waste Characterization
Solid waste determination
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
3) No person shall emit or cause to be emitted into the atmosphere
from any naturally aspirated (non-turbocharged) diesel-powered
motor vehicle weighing more than 7,500 pounds, empty weight,
operated above 7,000 ft (mean sea level) any air contaminant for
a period greater than five (5) consecutive seconds, which is of
such a shade or density as to obscure an observer's vision to a
degree in excess of 40% opacity.
4) Any diesel-powered motor vehicle exceeding these requirements
shall be exempt for a period of 10 minutes if the emissions are a
direct result of a cold engine start-up and provided the vehicle is
in a stationary position.
5) These standards shall apply to motor vehicles intended,
designed, and manufactured primarily for travel or use in
transporting persons, property, auxiliary equipment, and/or cargo
over roads, streets, and highways.
Slurry wall construction must be conducted in a manner that does
not cause adverse impacts on visibility. Visibility impairment
interferes with the management, protection, preservation, or
enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as applicable). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
RMA ARARS 1/96
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Table A-18 Action-Specific ARARs and TBCs for Slurry Walls
Action
Citation
6 CCR 1007-3 Sect 261.2
40CFR26I.4
6 CCR 1007-3 Sect 261.4
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
CCR 1007-3 Part 261
Solid waste classification
6 CCR 1007-2, Section 1
RMA ARARS 1/96
Page 5 of 9
Requirements
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Wastes generated during slurry wall construction must be
characterized. Solid wastes must be evaluated according to the
following method to determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
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Table A-18 Action-Specific ARARs and TBCs for Slurry Walls
Action
Citation
RMA ARARS 1/96
Page 6 of 9
Requirements
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community, and
commercial wastes are expected from slurry wall installation at
RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
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Table A-18 Action-Specific ARARs and TBCs for Slurry Walls
Page 7 of 9
Action
Citation
Requirements
Waste Management
Treatment, storage, or disposal of
hazardous waste
40 CFR Part 264
6 CCR 1007-3 Part 264
6 CCR 1007-3
On-post land disposal of hazardous wastes 40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
EPA/540/G-89/006 [TBC]
Treatment and disposal of hazardous debris 40 CFR 268.45
6 CCR 1007-3, Part 268.45
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
If slurry wall construction at RMA generates hazardous wastes, the
wastes must be treated and stored in accordance with RCRA
regulations.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed in Appendix A, Table A-12.
Based upon a determination of whether the disposal technique
constitutes placement, LDRs-UTS may be applicable. If placement
occurs, the on-site disposal facility must comply with the
substantive requirements of 40 CFR 264 (6 CCR 1007-3, Part 264)
and 40 CFR 268 (6 CCR 1007-8, Part 268).
Hazardous debris encountered during slurry wall installation must
be treated using specific technologies to extract, destroy, or
immobilize hazardous constituents on or in the debris. In certain
cases after treatment, the debris may no longer be subject to RCRA
Subtitle C regulation.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs and minimum technology requirements
for remediation wastes managed at CAMUs. These regulations
provide flexibility and allow for expedition of remedial decisions in
the management of remediation wastes. One or more CAMUs may
be designated at a facility. Placement of hazardous remediation
wastes into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
RMA ARARS 1/96
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Table A-18 Action-Specific ARARs and TBCs for Slurry Walls
Page 8 of 9
Action
Citation
Requirements
Temporary Units
6CCR 1007-3 Sect 264.553
40 CFR 264.553
Stormwater Management
Discharge of storm water to on-post surface
waters
Noise abatement
40 CFR Parts 122-125
Colorado Revised Statute, Section 25-12-
103
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
RMA ARARS 1/96
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Table A-18 Action-Specific ARARs and TBCs for Slurry Walls
Action
Citation
RMA ARARS I/96
Page 9 of 9
Requirements
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
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Table A-19 Action-Specific ARARs and TBCs for Hazardous Waste Landfills
Page 1 of 8
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPartl9lO
29 CFR 1910.120 (b) to 0)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable requirements, not ARARs and
TBCs. ACGIH and NIOSH values are provided as guidelines.)
RMA ARARS 1/96
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Table A-19 Action-Specific ARARs and TBCs for Hazardous Waste Landfills
Page 2 of 8
Action
Citation
Requirements
Landfill Design/Operation
On-post hazardous waste landfill
design/operation
40 CFR 264
6CCR 1007-3 Part 264
40 CFR 268
6CCR 1007-3 Part 268
Off-post hazardous waste landfill operation 40 CFR 264
6 CCR 1007-3 Part 264
OSWER Directive 9834.II
TCSA-PCB design standards
6CCR 1007-3
40CFR761SubpartD
Waste Management
Asbestos waste disposal management 6 CCR 1007-2, Part B, Section 5.0
Asbestos waste storage management
6 CCR 1007-2, Part B, Section 5.4
On-post hazardous waste landfills shall be designed and operated in
compliance with the applicable substantive requirements of 40 CFR
264 (6 CCR 1007-3, Part 264), including Subparts A, B, C, D, F, G,
I, J, and N. If the landfill is located outside the AOC from which
the hazardous waste was derived or is not in a designated CAMU,
placement has occurred and the landfill must comply with LDRs-
UTS in 40 CFR 268 (6 CCR 1007-3, Part 268).
Off-post hazardous waste landfills shall be RCRA-permitted
facilities and shall operate in compliance with all requirements of 40
CFR 264. The facilities shall also be in compliance with OSWER
Directive 9834.11 regarding off-site disposal of hazardous waste
from CERCLA sites. All RCRA requirements such as manifesting
and LDRs-UTS will apply to all off-site shipments of hazardous
waste, including any hazardous waste debris.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
On-post hazardous waste landfills shall be designed and operated in
compliance with applicable substantive requirements of 40 CFR 761
Subpart D.
On-Post hazardous waste landfill shall be designed and operated in
compliance with applicable substantive requirements for asbestos
waste disposal sites.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos storage.
RMA ARARS 1/96
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Table A-19 Action-Specific ARARs and TBCs for Hazardous Waste Landfills
Page 3 of8
Action
Citation
Requirements
Asbestos waste handling management
5 CCR 10001-10, Regulation Part B,
Section S.B.IH.c.8
40CFR61,SubpartM
PCB storage
40CFR761.65
PCB chemical waste landfllling standards 40 CFR 761.75
Asbestos waste will be managed according to applicable substantive
requirements for asbestos handling, transportation, and storage.
Prevent discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing wastes; deposit
asbestos-containing waste as possible at disposal site; mark
transport vehicle appropriately during loading and unloading
operations.
Storage facilities must be constructed with adequate roofs, walls;
have impervious floors with curbs (no floor drains expansion joints
or other openings); be located above 100 year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing non-
liquid PCBs, such as contaminated soil, rags, debris need not
comply with above requirements.
Containers must be dated when they are placed in storage.
All storage areas must be properly marked and stored articles must
be checked for leaks every 30 days.
Landfill must be located in thick, relatively impermeable soil
formation or on soil with high clay and silt content, synthetic
membranes must be used when these conditions cannot be met. In
addition, other structural requirements include avoidance of location
in a floodplain; required run-on/run-ofF structures if below the 100
year floodplain, and ground/surface water monitoring for specified
parameters.
The landfill must include a leachate monitoring system.
PCB wastes must be segregated from wastes not chemically
compatible with PCBs.
RMA ARARS 1/96
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Table A-19 Action-Specific ARARs and TBCs for Hazardous Waste Landfills
Page 4 of 8
Action
Citation
Requirements
PCB decontamination standards
Treatment, storage, or disposal of
hazardous wastes in containers and tanks
Corrective Action Management Units
40CFR761.79
40 CFR 264 Subpart I
6 CCR 1007-3 Part 264 Subpart I
40 CFR 264 Subpart J
6 CCR 1007-3 Part 264 Subpart J
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
PCB containers to be decontaminated by triple rinsing of internal
surfaces with solvent containing <50 ppm PCB.
Applicability of the substantive requirements for containers.
Applicability of the substantive requirement for tanks or tank
systems.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
RMA ARARS 1/96
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Table A-19 Action-Specific ARARs and TBCs for Hazardous Waste Landfills
Page 5 of 8
Action
Citation
Requirements
Air Emission Control
Emission of particulates
5 CCR 1001-3, Regulation I,
Section III (D)
5 CCR 1001-5, Regulation 3
Emission control for opacity
Emission of hazardous air pollutants
Volatile organic chemical emissions
5 CCR 1001-3, Regulation 1, Section II
5 CCR 1001-10, Regulation 8
40CFRPart61
5 CCR 1001-9, Regulation 7
Emissions
42 USC Section 7502-7503
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. No off-site transport of paniculate matter is
allowed. A fugitive dust control measure will be written into the
work plan in consultation with the state for this remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements will be necessary.
On-post landfilling shall not cause the emission into the atmosphere
of any air pollutant that is in excess of 20% opacity.
Emission of listed hazardous air pollutants is controlled by
NESHAPs. On-post landfilling may cause emission of hazardous
air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for alt areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
RMA ARARS l/%
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Table A-19 Action-Specific ARARs and TBCs for Hazardous Waste Landfills
Page 6 of 8
Action
Citation
Requirements
Air Emissions
Standard for asbestos waste disposal
40CFR6I SubpartM
Odor emissions
5 CCR 1001-4, Regulation 2
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
Prevent discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing waste; deposit
asbestos-containing waste as soon as possible at disposal site; mark
transport vehicles appropriately during loading and unloading
operations.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
On-post landfilling must be conducted in a manner that does not
cause adverse impacts on visibility. Visibility impairment interferes
with the management, protection, preservation, or enjoyment of
federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
RMA ARARS 1/96
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Table A-19 Action-Specific ARARs and TBCs for Hazardous Waste Landfills
Page 7 of 8
Action
Citation
Requirements
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Wastewater Treatment/Disposal
Noise abatement
40 CFR 262
6CCR 1007-3, Part 262
40 CFR 264
6 CCR 1007-3, Part 264
Colorado Revised Statute, Section 25-12-
103
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
Wastewater that is determined to be a hazardous waste must be
treated in accordance with the provisions of RCRA.
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
RMA ARARS 1/96
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Table A-19 Action-Specific ARARs and TBCs for Hazardous Waste Landfills Page 8 of 8
Action Citation Requirements
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS I/96
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Table A-20 Action-Specific ARARs and TBCs for Thermal Desorption
Page 1 of 10
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPart I910
29CFR19l0.120(b)-(j)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) provides guidelines for workers involved in
hazardous waste operations and emergency response actions on sites
regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
In addition to the compounds listed in Table 1, off gases from the
rotary kiln incinerators may contain gaseous hydrogen chloride,
hydrogen bromide, and hydrogen fluoride. These gases will be
removed during further treatment of the off gases, including a
caustic quench system using sodium hydroxide. The worker
exposure standards for these compounds are as follows:
RMA ARARS 1/96
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Table A-20 Action-Specific ARARs and TBCs for Thennal Desorption
Page 2 of 10
Action
Citation
Requirements
Thermal Desorption Unit Operation
Determination of operational readiness
Operation of thermal desorption unit
40CFR270.19
6 CCR 1007-3 Sect 270.19
40 CFR 270.62 (b)
6 CCR 1007-3 Sect 270.62(b)
40 CFR 264
6 CCR 1007-3 Part 264
Hydrogen bromide
Hydrogen chloride
ACGIH-Ceiling = 3 ppm, 9.9 mg/m3
NIOSH- Ceiling = 3 ppm, 10 mg/m3
OSHA- PEL = 3 ppm, 10 mg/m3
ACGIH- Ceiling =
NIOSH-Ceiling =
OSHA-Ceiling =
Hydrogen fluoride ACGIH- Ceiling
NIOSH-REL
OSHA-PEL
5 ppm, 7.5 mg/m3
5 ppm, 7 mg/m3
5 ppm, 7 mg/m3
3 ppm, 2.6 mg/m3
3 ppm, 2.5 mg/m3
15-min ceiling =
6 ppm, 5 mg/m3
3 ppm
Sodium hydroxide
ACGIH-Ceiling = 2 mg/m3
NIOSH-Ceiling = 2 mg/m3
OSHA-PEL = 2 mg/m3
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are presented as
guidelines.)
Although permit applications are not necessary for RMA remedial
actions, the operational readiness information will be provided in
CERCLA documents leading to incineration alternatives.
The thermal desorption unit shall be operated to comply with
substantive requirements of 40 CFR 264, including, but not limited
to the following Subpart O requirements:
• Stack emission
• Monitoring
• Inspections
RMA ARARS 1/96
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Table A-20 Action-Specific ARARs and TBCs for Thermal Desorption
Page 3 of 10
Action
Citation
Requirements
6CCR 1007-3
Waste Characterization
Solid waste determination
Determination of hazardous waste
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
• Testing of the emergency waste feed cutoff system
Colorado incinerator regulations are broader in scope than the
federal regulations. The Colorado regulations include boilers and
industrial furnaces as regulated units under Subpart O.
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Thermal desorption of soils will generate salt cake, metal fines, and
other solids. These wastes and all others generated must be
characterized and evaluated according to the following methods to
determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
RMA ARARS 1/96
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Table A-20 Action-Specific ARARs and TBCs for Thermal Desorption
Page 4 of 10
Action
Citation
Requirements
Solid waste classification
6 CCR 1007-2, Part 1, Section I
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain the following five solid
waste categories:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
RMA ARARS 1/96
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Table A-20 Action-Specific ARARs and TBCs for Thermal Desorption
Page 5 of 10
Action
Citation
Requirements
Waste Management
PCB storage
40CFR761.65
PCB incineration standards
40CFR761.70
PCB decontamination standards
Treatment, storage, or disposal of
hazardous wastes
40CFR761.79
40 CFR Part 264
6 CCR 1007-3 Part 264
If present, only small quantities of industrial, community,
commercial, and special wastes are expected from thermal
desorption of soils at RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Storage facilities must be constructed with adequate roofs, walls;
have impervious floors with curbs (no floor drains expansion joints
or other openings); be located above 100 year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing non-
liquid PCBs, such as contaminated soil, rags, debris need not
comply with above requirements.
Containers must be dated when they are placed in storage.
All storage areas must be properly marked and stored articles must
be checked for leaks every 30 days.
Incineration requirements for non-liquid PCB apply to PCB
concentrations >50 ppm and include specified dwell times;
combustion efficiency of 99.9999%; process record/monitoring
requirements; automatic shut-off standards; a maximum mass air
emission of 0.001 g PCB per kg of PCB entering the incinerator.
PCB containers to be decontaminated by triple rinsing of internal
surfaces with solvent containing <50 ppm PCB.
Wastes that are determined to be RCRA hazardous wastes must be
stored and treated, in compliance with RCRA regulations.
RMA ARARS 1/96
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Table A-20 Action-Specific ARARs and TBCs for Thermal Desorption
Page 6 of 10
Action
Citation
Requirements
On-post land disposal of hazardous wastes 40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
EPA/540/G-89/005 [TBC]
6 CCR 1007-3
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Air Emissions
Emission of Particulates
Based upon a determination of whether the disposal technique
constitutes placement, LDRs-UTS may be applicable. If placement
does occur, the disposal facility must comply with the substantive
requirements of 40 CFR Part 264 (6 CCR 1007-3, Part 264) and 40
CFR Part 268 (6 CCR 1007-3, Part 268).
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
40 CFR 60 Subpart E
5 CCR 1001-8, Regulation 6, Part B (VII)
The thermal desorption unit shall operate in compliance with
substantive requirements of 40 CFR 60 Subpart E and the
corresponding state requirements. In addition, no off-site transport
of paniculate matter is allowed.
RMA ARARS 1/96
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Table A-20 Action-Specific ARARs and TBCs for Thermal Desorption
Page 7 of 10
Action
Citation
Requirements
Performance testing
Emission control for opacity
Emission of hazardous air pollutants
Volatile organic chemical emissions
5CCR100l-2SectionIl-C
5 CCR 1001-3, Regulation I,
Section III (D)
5 CCR 1001-5, Regulation 3
Performance tests shall be conducted and reduced in accordance
with applicable reference test materials.
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control measure will be
written into the work plan in consultation with the state for this
remedial action.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
5 CCR 1001-3, Regulation 1, Section III.B Performance standards regarding particulate matter (<.10 gram of
particulate matter per standard cubic foot) and performance testing
in accordance with Appendix A of Air Quality Control Commission
Regulation 6.
5 CCR 1001-3, Regulation 1, Section II
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-9, Regulation 7
42 USC Section 7502-7503
Thermal desorption of soils shall not cause the emission into the
atmosphere of any air pollutant that is in excess of 20% opacity.
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Thermal desorption will cause volatization of some
organic and/or metal contaminants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
RMA ARARS 1/96
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Table A-20 Action-Specific ARARs and TBCs for Thermal Desorption
Page 8 of 10
Action
Citation
Requirements
PM10/CO Emissions
Visibility protection
42 USC Section 7502-7503
40 CFR 51.300-307
40 CFR 52.26-29
5CCR 1001-14
CRS Section 42-4-307(8)
Odor emissions
5 CCR 1001-4, Regulation 2
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Thermal desorption of soils must be conducted in a manner that
does not cause adverse impacts on visibility. Visibility impairment
interferes with the management, protection, preservation, or
enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
RMA ARARS 1/96
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Table A-20 Action-Specific ARARs and TBCs for Thermal Desorption
Page 9 of 10
Action
Citation
Requirements
Stormwater Management
Discharge of stormwater to on-post surface
waters
Noise abatement
40 CFR Parts 122-125
Colorado Revised Statute, Section 25-12-
103
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
RMA ARARS 1/96
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Table A-20 Action-Specific ARARs and TBCs for Thermal Desorption
Page 10 of 10
Action
Citation
Requirements
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Incineration/Pyrotysis
Page 1 of 11
Action
Citation
Requirements
Worker Protection
Health and safety protection
29 CFR Part 1910
29 CFR 1910.120 (b) to 0)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
* Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
In addition to the compounds listed in Table A-46 will be removed
during further treatment of the off gases, including a caustic quench
system using sodium hydroxide. The worker exposure standards for
these compounds are as follows:
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Incineration/Pyrolysls
Page 2 of 11
Action
Citation
Requirements
Operation of Incinerators
Determination of operation readiness
40CFR270.19]
6 CCR 1007.3 Sect 270.19
40 CFR 270.62 (b)
6 CCR 1007-3 Sect 270.62(b)
Hydrogen bromide
ACGIH-Ceiling =
NIOSH-Ceiling =
OSHA-PEL
Hydrogen chloride
ACGIH-Ceiling =
NIOSH-Ceiling =
OSHA- Ceiling =
Hydrogen fluoride
ACGIH-Ceiling =
NIOSH-REL
OSHA-PEL
Sodium hydroxide
ACGIH- Ceiling =
NIOSH-Ceiling =
OSHA-PEL
3 ppm, 9.9 mg/m3
3 ppm, 10 mg/m3
3 ppm, 10 mg/m3
5 ppm, 7.5 mg/m3
5 ppm, 7 mg/m3
5 ppm, 7 mg/m3
3 ppm, 2.6 mg/m3
3 ppm, 2.5 mg/m3
15-min ceiling = 6 ppm, 5 mg/m3
3 ppm
2 mg/m3
2 mg/m3
2 mg/m3
If chemical agent is incinerated on post, the agent must be managed
to comply with the exposure standards shown in Table A-28 of this
document.
OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.
Although permit applications are not necessary for RMA remedial
actions, operational readiness information will be provided in
CERCLA documents leading to incineration alternatives.
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Incineration/Pyroiysis
Page 3 of 11
Action
Citation
Requirements
Incinerator operations
40 CFR 264
6CCR 1007-3 Part 264
Waste Characterisation
Solid waste determination
6 CCR 1007-3
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
On-post rotary-kiln incinerators must be operated in compliance
with all substantive requirements of Part 264 including, but not
limited to the following Subpart O requirements:
• Waste-specific performance standards
• Stack emission standards
• Monitoring
Off-post incinerators must be RCRA-permitted and comply with all
requirements of 40 CFR 264 Subpart 0.
Colorado incinerator regulations are broader in scope than the
federal regulations. The Colorado regulations include boilers and
industrial furnaces as regulated units under Subpart 0.
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Incineratlon/Pyrolysis
Page 4 of 11
Action
Citation
Requirements
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
Solid waste classification
6 CCR 1007-2, Section 1
Incineration/pyrolysis of soils will generate oversize soil, debris,
metallic waste, ash, and salt cake. These wastes and all others
generated must be characterized and evaluated according to the
following method to determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain the following five solid
waste categories:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes means all solid wastes
generated by the noncommercial and nonindustrial activities of
private individuals of the community including solid wastes
from streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes," which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Incineration/Pyrolysis
Page 5 of 11
Action
Citation
Requirements
Waste Management
PCB storage
40CFR76I.65
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
riot limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community,
commercial, and special wastes are expected from
incineration/pyrolysis of soils at RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Storage facilities must be constructed with adequate roofs, walls;
have impervious floors with curbs (no floor drains expansion joints
or other openings); be located above 100 year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing non-
liquid PCBs, such as contaminated soil, rags, debris need not
comply with above requirements.
Containers must be dated when they are placed in storage.
All storage areas must be properly marked and stored articles must
be checked for leaks every 30 days.
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Incineration/Pyrolysis
Page 6 of 11
Action
Citation
Requirements
PCB incineration standards
40CFR761.70
PCB decontamination standards
Treatment, storage, or disposal of RCRA
hazardous waste
40CFR761.79
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
EPA/540/G-89/006 [TBC]
6 CCR 1007-3
Treatment of UXO containing chemical AMC-R 385-131
agent
Treatment and disposal of hazardous debris 40 CFR 268.45
6 CCR 1007-3, Part 268.45
Incineration requirements for non-liquid PCB apply to PCB
concentrations >50 ppm and include specified dwelt times;
combustion efficiency of 99.9999%; process record/monitoring
requirements; automatic shut-off standards; a maximum mass air
emission of 0.001 g PCB per kg of PCB entering the incinerator.
PCB containers to be decontaminated by triple rinsing of internal
surfaces with solvent containing <50 ppm PCB.
Wastes that are determined to be RCRA hazardous wastes must be
stored, treated, and disposed in compliance with RCRA regulations.
If the soil is treated in a central incineration/pyrolysis facility at
RMA that is outside the AOC from which the soil came, any waste
returned to the AOC after treatment will be subject to LDRs-UTS
since placement of the waste will have occurred.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
UXO shall be incinerated as described in AMC-R 385-131 to a 5X
level of decontamination so that it can be released from DOD
control.
Hazardous debris generated during incineration/pyrolysis activities
must be treated using specific technologies to extract, destroy, or
immobilize hazardous constituents on or in the debris if placement
occurs. In certain cases, after treatment the debris may no longer be
subject to RCRA Subtitle C regulation.
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Incineration/Pyrolysis
Page 7 of 11
Action
Citation
Requirements
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Air Emissions
Emission of particulates
40 CFR 60 Subpart E
5 CCR 1001-8, Regulation 6, Part B (VII)
5 CCR 1001-3, Regulation 1,
Section HI(D)
5 CCR 1001-5, Regulation 3
Emission control for opacity
5 CCR 1001-3, Regulation I, Section II
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Incineration/pyrolysis activities must operate in compliance with the
particulate emission standards for incinerators in 40 CFR 60
Subpart E and the corresponding state requirements.
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control measure will be
written in the work plan in consultation with the state for the
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Incineration/pyrolysis operations shall not cause the emission into
the atmosphere of any air pollutant that is in excess of 20% opacity.
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Inclneratlon/Pyrolysts
Page 8 of 11
Action
Citation
Requirements
Performance Testing
Emission of hazardous air pollutants
Odor emissions
5 CCR 1001-2 Section II
5 CCR 1001-10, Regulation 8
40CFRPart61
5 CCR 1001-4, Regulation 2
Volatile organic chemical emissions
42 USCS Section 7412
5 CCR 1001-9, Regulation?
PMio/CO emissions
42 USC Section 7502-7503
5 CCR 1001-5, Regulation 3
Performance tests shall be conducted and reduced in accordance
with applicable reference test methods.
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Incineration/pyrolysis will cause volatization of some
organic and/or metals contaminants.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Incineratlon/Pyrolysis
Page 9 of 11
Action
Citation
Requirements
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5CCR I001-I4
CRS Section 42-4-307(8)
Emission of particulates
5 CCR 1001-3, Regulation 1, Sect HI.B
Stormwater Management
Discharge of Stormwater to on-post surface 40 CFR Parts 122-125
waters
Incineration /pyrolysis operations must be conducted in a manner
that does not cause adverse impacts on visibility. Visibility
impairment interferes with the management, protection,
preservation, or enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Performance standards regarding particulate matter (<0.1 grams of
paniculate matter per dry standard cubic foot) and performance
testing in accordance with Appendix A or Air Quality Control
Commission Regulation No. 6.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Incineration/Pyrolysis
Page 10 of 11
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
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Table A-21 Action-Specific ARARs and TBCs for Inclneration/Pyrolysis Page 11 of 11
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
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Table A-22 Action-Specific ARARs and TBCs for Off-Post Incineration of Structural Materials
Page 1 of 2
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPart 1910
29 CFR 1910.120 (b) to 0)
Worker exposure
ACG1H1991-1992 [TBC]
N1OSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through 0) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACG1H, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable requirements, not ARARs or
TBCs. ACGIH and NIOSH values are provided as guidelines.)
RMA ARARS 1/96
-------
Table A-22 Action-Specific ARARs and TBCs for Off-Post Incineration of Structural Materials
Page 2 of 2
Action
Citation
Requirements
Off-Post Incinerator
Incinerator facility operations
Air Emissions
Emission of Participates
Waste Management
Off-site disposal of hazardous waste
Off-site shipment of hazardous waste
40CFR264
6 CCR 1007-3 Part 264
OSWER Directive 9834.11 [TBC]
6 CCR 1007-3
5 CCR 1001-3, Regulation 1, Sect III.B
40 CFR Part 268
6 CCR 1007-3 Part 268
40 CFR Part 262
6 CCR 1007-3 Part 262
The off-post facility must have a RCRA permit to operate under the
requirements of 40 CFR 264 including Subpart O. The facility
should also be approved under the conditions of OSWER Directive
9834.11 for off-site disposal of hazardous wastes from a CERCLA
site.
Colorado incinerator regulations are broader in scope than the
federal regulations. The Colorado regulations include boilers and
industrial furnaces as regulated units under Subpart 0.
Performance standards regarding particulate matter (O.I gram of
particulate matter per dry standard cubic foot) and performance
testing in accordance with Appendix A of Air Quality Control
Commission Regulation No. 6.
All off-site shipments of hazardous waste to approved TSDF must
be accompanied by required LDR certifications and analysis.
Any shipments of hazardous waste off-site must be in compliance
with generator standards such as manifests, packaging/labeling, and
placarding requirements.
RMA ARARS 1/96
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Table A-23 Action-Specific ARARs and TBCs for Soil Heating
Action
Citation
Worker Protection
Health and safety protection 29 CFR Part 1910
29CFR1910.120(b)to(j)
Worker exposure
ACGIH 1991-1992 [TBC]
N10SH 1990
29 CFR 1910.1000
RMA ARARS 1/96
Page 1 of 9
Requirements
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
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Table A-23 Action-Specific ARARs and TBCs for Soil Heating
Page 2 of 9
Action
Citation
Requirements
Waste Characterization
Solid Waste Determination
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
In addition to the chemicals listed in Table A-46, the Enhanced
Surface Soil Vacuum Extraction Process (ESSVEP) generates
hydrochloric acid vapors in the off gases. Worker exposure
standards for hydrogen chloride are as follows:
Hydrogen chloride
(ceiling)
ACGIH-TWA = 5 ppm, 7.5 mg/m3
N1OSH-REL
OSHA-PEL
= 5 ppm, 7 mg/m3 (ceiling)
= 5 ppm, 7 mg/m3 (ceiling)
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and N1OSH values are provided as
guidelines.)
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
RMA ARARS 1/96
-------
Page 3 of 9
Requirements
Soil heating will generate wastewater, off gases, and possibly spent
carbon. These wastes and all others generated must be
characterized and evaluated according to the following method to
determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40CFR261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
Table A-23 Action-Specific ARARs and TBCs for Soil Heating
Action
Citation
Determination of hazardous waste
40 CFR 262 II
6CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
Solid waste classification
6 CCR 1007-2, Section 1
RMA ARARS 1/96
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Table A-23 Action-Specific ARARs and TBCs for Soil Heating
Action
Citation
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
6CCR 1007-3
RMA ARARS 1/96
Page 4 of 9
Requirements
4) "Special wastes," which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community, and
commercial wastes are expected from soil heating operations at
RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Wastes that are determined to be RCRA hazardous wastes must be
stored, treated, and disposed in compliance with RCRA regulations,
including LDRs-UTS if placement has occurred.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
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Table A-23 Action-Specific ARARs and TBCs for Soil Heating
Page 5 of 9
Action
Citation
Requirements
Wastewater
40 CFR Part 122
40 CFR Part 125
40 CFR Part 129
Management of Remediation Wastes
Corrective action management units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Any wastewater generated during soil heating will be routed to the
on-post RMA wastewater treatment plant if it is not hazardous
waste and will not interrupt the existing treatment system. If
wastewater is routed to the on-post treatment plant, it must be
treated in accordance with NPDES requirements.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
RMA ARARS l/%
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Table A-23 Action-Specific ARARs and TBCs for Soil Heating
Page 6 of 9
Action
Citation
Requirements
Air Emissions
Emission of participates
Emission control for opacity
Emission of hazardous air pollutants
Odor emissions
5 CCR 1001-3, Regulation 1,
Section III (D)
5 CCR 1001-5, Regulations
5 CCR 1001-2, Section II
5 CCR 1001-3, Regulation 1, Section II
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-4, Regulation 2
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control measure will be
written into the work plan in consultation with state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Soil heating operations shall not cause the emission into the
atmosphere of any air pollutant that is in excess of 20% opacity.
Emission of certain hazardous air pollutants is controlled by
NESHAPs. Soil heating will cause volatization of some organic
and/or metal contaminants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
RMA ARARS 1/96
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Table A-23 Action-Specific ARARs and TBCs for Soil Heating
Action
Citation
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
PMIO/CO emissions
Visibility protection
42 USC Section 7502-7503
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
Stormwater Management
Discharge of Stormwater to on-post surface 40 CFR Parts 122-125
waters
RMA ARARS 1/96
Page 7 of 9
Requirements
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Soil heating must be conducted in a manner that does not cause
adverse impacts on visibility. Visibility impairment interferes with
the management, protection, preservation, or enjoyment of federal
Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as applicable). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
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Table A-23 Action-Specific ARARs and TBCs for Soil Heating
Page 8 of 9
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance.of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential 55 db(A) 50 db(A)
Commercial 60 db(A) 55 db(A)
Light Industrial 70 db(A) 65 db(A)
Industrial 80 db(A) 75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
-------
Table A-23 Action-Specific ARARs and TBCs for Soil Heating
Action
Citation
RMA ARARS 1/96
Page 9 of 9
Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
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Table A-24 Action-Specific ARARs and TBCs for In Situ Vitrification
Page 1 of 9
Action
Citation
Requirements
Worker Protection
Health and safety protection 29 CFR Part 1910
29 CFR 1910.120 (b) to 0)
Worker exposure
ACGIH 1991 -1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
In addition to the chemicals listed in Table A-46, ethylene glycol
will be used as a coolant in the vitrification process. Worker
exposure standards for this chemical are as follows:
Ethylene glycol ACGIH-TWA = 50 ppm, 127 mg/m3 (ceiling)
RMA ARARS 1/96
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Table A-24 Action-Specific ARARs and TBCs for In Situ Vitrification
Page 2 of 9
Action
Citation
Requirements
Air Emissions
Emission of participates
5 CCR 1001-3, Regulation 1,
Section III (D)
5 CCR 1001-5, Regulation 3
Emission control for opacity
5 CCR 1001-3, Regulation 1, Section II
Emission of hazardous air pollutants 5 CCR 1001 -10, Regulation 8
40CFRPart61
42 USCS Section 7412
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
(OSHA regulations and other safety and health requirements are
actually independently applicable requirements, not ARARs and
TBCs. ACGIH and NIOSH values are provided as guidelines.)
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control measure will be
written into the work plan in consultation with state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
In situ vitrification of soils shall not cause the emission into the
atmosphere of any air pollutant that is in excess of 20% opacity.
Emission of listed hazardous air pollutants is controlled by
NESHAPs. In-situ vitrification of soils may cause volatilization of
some contaminants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
RMA ARARS 1/96
-------
Table A-24 Action-Specific ARARs and TBCs for In Situ Vitrification
Page 3 of 9
Action
Citation
Requirements
PMIO/CO emissions
Visibility protection
42 USC Section 7502-7503
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
Odor emissions
5 CCR 1001-4, Regulation 2
Air emissions from diesel-powered 5 CCR 1001-15, Regulation 12
vehicles associated with in-situ vitrification
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
In situ vitrification must be conducted in a manner that does not
cause adverse impacts on visibility. Visibility impairment interferes
with the management, protection, preservation, or enjoyment of
federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Colorado Diesel-Powered Vehicle Emission Standards for Visible
Pollutants apply to motor vehicles intended, designed, and
manufactured primarily for use in carrying passengers or cargo on
roads, streets, and highways, and state as follows:
1) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing 7,500 pounds
and less, empty weight, any air contaminant, for a period greater
than five (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 40% opacity.
RMA ARARS 1/96
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Table A-24 Action-Specific ARARs and TBCs for In Situ Vitrification
Page 4 of 9
Action
Citation
Requirements
Waste Characterization
Solid waste determination
40 CFR 260
6CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
2) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing more than
7,500 pounds, empty weight, any air contaminant, for a period
greater than (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 35% opacity, with the exception of subpart "C".
3) No person shall emit or cause to be emitted into the atmosphere
from any naturally aspirated (non-turbocharged) diesel-powered
motor vehicle weighing more than 7,500 pounds, empty weight,
operated above 7,000 fit (mean sea level) any air contaminant for
a period greater than five (5) consecutive seconds, which is of
such a shade or density as to obscure an observer's vision to a
degree in excess of 40% opacity.
4) Any diesel-powered motor vehicle exceeding these requirements
shall be exempt for a period of 10 minutes if the emissions are a
direct result of a cold engine start-up and provided the vehicle is
in a stationary position.
5) These standards shall apply to motor vehicles intended,
designed, and manufactured primarily for travel or use in
transporting persons, property, auxiliary equipment, and/or cargo
over roads, streets, and highways.
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
RMA ARARS 1/96
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Table A-24 Action-Specific ARARs and TBCs for In Situ Vitrification
Page S of 9
Action
Citation
Requirements
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Sect 262. II
40 CFR Part 261
6 CCR 1007-3 Part 261
Solid waste classification
6 CCR 1007-2, Section I
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike.
In situ vitrification will generate grubbed vegetation and debris.
These wastes and all others generated must be characterized and
evaluated according to the following method to determine whether
the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR 261
• Determine whether the waste is identified in 40 CFR 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes solid wastes generated by
the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
RMA ARARS 1/96
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Table A-24 Action-Specific ARARs and TBCs for In Situ Vitrification
Page 6 of 9
Action
Citation
Requirements
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
EPA/540/G-89/006 [TBC]
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community,
commercial, and special wastes are expected from in situ
vitrification at RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Wastes that are determined to be RCRA hazardous wastes must be
stored, treated, and disposed in compliance with RCRA regulations,
including LDRs-UTS if placement occurs.
RMA ARARS 1/96
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Table A-24 Action-Specific ARARs and TBCs for in Situ Vitrification
Page 7 of 9
Action
Citation
Requirements
6CCR 1007-3
Treatment and disposal of hazardous debris 40 CFR 268.45
6 OCR 1007-3, Part 268.45
Management of Remediation Wastes
Corrective action management units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
Hazardous debris generated during in situ vitrification activities
must be treated using specific technologies to extract, destroy, or
immobilize hazardous constituents on or in the debris. In certain
cases after treatment, the debris may no longer be subject to RCRA
Subtitle C regulation.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
RMA ARARS 1/96
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Table A-24 Action-Specific ARARs and TBCs for In Situ Vitrification
Page 8 of 9
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of Five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be.made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
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Table A-24 Action-Specific ARARs and TBCs for In Situ Vitrification Page 9 of 9
Action Citation Requirements
' f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements.'"
RMA ARARS 1/96
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Table A-25 Action-Specific ARARs and TBCs for Hot Gas Decontamination of Structures and Debris Page 1 of 8
Action Citation Requirements
Worker Protection
Health and safety protection
29 CFR Part 1910
29CFR 19l0.120(b)to(j)
Worker exposure
ACG1H i 991-1992 [TBC]
N1OSH1990[TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR I910.120(b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• Cm-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical—specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
RMA ARARS 1/96
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Table A-25 Action-Specific ARARs and TBCs for Hot Gas Decontamination of Structures and Debris Page 2 of 8
Action Citation Requirements
Waste Characterization
Solid waste determination
Determination of hazardous waste
Solid waste classification
40 CFR 260
6CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
CR 1007-3 Sect 261.4
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
6 CCR 1007-2, Section 1
'A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike.
Wastes generated during structure decontamination activities must
be characterized. Solid wastes must be evaluated according to the
following method to determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR 261
• Determine whether the waste is identified in 40 CFR 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain the following five solid
waste categories:
RMA ARARS 1/96
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Table A-25 Action-Specific ARARs and TBCs for Hot Gas Decontamination of Structures and Debris Page 3 of 8
Action Citation Requirements
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes solid wastes generated by
the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community, and
commercial wastes are expected from hot gas decontamination at
RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
RMA ARARS 1/96
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Table A-2S Action-Specific ARARs and TBCs for Hot Gas Decontamination of Structures and Debris Page 4 of 8
Action Citation Requirements
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
Wastewater
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
6 CCR 1007-3
40 CFR Part 122
40 CFR Part 125
40 CFR Part 129
Management of Remediation Wastes
Corrective action management units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Wastes that are determined to be RCRA hazardous wastes must be
stored, treated, and disposed in compliance with RCRA regulations,
including LDRs-UTS if placement occurs.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
Any wastewater generated during hot gas decontamination of
structures will be routed to the on-post RMA wastewater treatment
plant if it is not hazardous waste and will not interrupt the existing
treatment system. If wastewater is routed to the on-post treatment
plant, it must be treated in accordance with NPDES requirements.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
RMA ARARS 1/96
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Table A-25 Action-Specific ARARs and TBCs for Hot Gas Decontamination of Structures and Debris Page S of 8
Action Citation Requirements
Air Emission Control
Particulate emissions
Emission control for opacity
Odor emissions
Emission of hazardous air pollutants
5 CCR 1001-3, Regulation 1,
Section III (D)
5 CCR 1001-5, Regulation 3
5 CCR 1001-2, Section II
5 CCR 1001-3,
Regulation 1, Section II
5 CCR 1001-4, Regulation 2
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control measure will be
written into the work plan with state for this remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements will be necessary.
Hot gas decontamination operations shall not cause the emission
into the atmosphere of any air pollutant that is in excess of 20%
opacity.
Colorado odor emissions regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Emission of certain hazardous air pollutants is controlled by
NESHAPs. Decontamination of structures could potentially cause
emission of hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
RMA ARARS 1/96
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Table A-2S Action-Specific ARARs and TBCs for Hot Gas Decontamination of Structures and Debris
Page 6 of 8
Action
Citation
Requirements
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
PM10/CO emissions
Visibility protection
42 USC 7502-7503
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
Stormwater Management
Discharge of stormwater to on-post surface
waters
40 CFR Parts 122-125
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Hot gas decontamination of structures must be conducted in a
manner that does not cause adverse impacts on visibility. Visibility
impairment interferes with the management, protection,
preservation, or enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as applicable). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
RMA ARARS 1/96
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Table A-25 Action-Specific ARARs and TBCs for Hot Gas Decontamination of Structures and Debris
Page 7 of 8
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
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Table A-2S Action-Specific ARARs and TBCs for Hot Gas Decontamination of Structures and Debris Page 8 of 8
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
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Table A-26 Action-Specific ARARs and TBCs for UXO Demilitarization/Chemical Agent Decontamination
Page 1 of 7
Action
Citation
Requirements
Detonation of UXO Containing High
Explosives
UXO detonation
On-post detonation of UXO
Off-post detonation of UXO
Chemical Agent Decontamination
Agent decontamination
Worker Protection
Health and safety protection
AR75-I5
40 CFR 264
6 CCR 1007-3 Part 264
40 CFR Part 264 Subpart X
6 CCR 1007-3 Part 264 Subpart X
40 CFR 264 Subpart X
6 CCR 1007-3 Part 264 Subpart X
AR 385-61
AR95-I5
AR385-10
AR 385-61
AR 385-64
AMC-R 385-100
DA PAM 385-61
Technical Manual (TM) 10-277 [TBC]
AR 50-6
High explosives will be detonated in compliance with the substantive
requirements of AR 7515 regarding demilitarization of class V
materials.
On-post detonation of UXO must comply with the substantive
requirements of Part 264 including the environmental performance
standards described in 40 CFR 264.601 (6 CCR 1007-3, Section
264.601) and substantive portions of the monitoring, analysis,
reporting, and corrective action requirements of 40 CFR 264.602 (6
CCR 1007-3, Section 264.602).
Off-post facilities used for detonation of UXO must be RCRA-
permitted units that have been permitted under 40 CFR 264 Subpart
X.
Decontamination of chemical agent-contaminated material will
comply with the requirements of AR 385-61 and AR 50-6.
Workers shall comply with the substantive requirements of AMC-R
385-100, AR 385-10, AR 385-61, and AR 385-64.
RMA ARARS 1/96
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Table A-26 Action-Specific ARARs and TBCs for UXO Demilitarization/Chemical Agent Decontamination Page 2 of 7
Action Citation Requirements
29 CFR Part 1910
29CFR 1910.120 (b) to (j)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to the
handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
In addition to the chemicals listed in Table A-46, workers involved
in the demilitarization of HE- or agent-filled UXO will be exposed
to several unique chemicals. Worker exposure standards for
explosives are as follows:
RMA ARARS l/%
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Table A-26 Action-Specific ARARs and TBCs for UXO Demilitarization/Chemical Agent Decontamination Page 3 of 7
Action Citation Requirements
• Aluminum (Pyro powder)
ACGIH-TWA = 5 mg/m3 (Pyro-powder)
OSHA-PEL = 15 mg/m3 total, 5 mg/m3 resp (ASAL)
Lead Azide (Colloidal - as Pb)*
Nitroglycerin
ACGIH-TWA = 0.05 ppm, 0.46 mg/m3 (skin)
NIOSH-REL =0.1 ppm (skin)
OSHA-Ceiling = 0.2 ppm, 2 mg/m3 (15 min ceiling)
* Source: Hazardous Component Safety Data Sheet (ARRADCOM
Form 29)
Picric Acid
ACGIH-TWA = 0.1 mg/m3
NIOSH-REL =0.1 mg/m3,
STEL = 0.3 mg/m3 (skin)
OSHA-PEL = 0.1 mg/m3 (8 hr TWA - skin)
RDX (Cyclonite) ACGIH-TWA = 1.5 mg/m3 (skin)
Tetryl
ACGIH-TWA =1.5 mg/m3
NIOSH-REL = 1.5 mg/m3 (skin)
OSHA - PEL = 1.5 mg/m3 (8 hr TWA - skin)
2,4,6-Trinitrotoluene
(TNT) ACGIH-TWA = 0.5 mg/m3 (skin)
NIOSH-REL = 0.5 mg/m3 (skin)
OSHA-PEL =1.5 mg/m3
* Source: Hazardous Component Safety Data Sheet (ARRAD
COM Form 29)
RMA ARARS 1/96
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Table A-26 Action-Specific ARARs and TBCs for UXO Demilitarization/Chemical Agent Decontamination
Page 4 of 7
Action
Citation
Requirements
Ait Emissions
Worker exposure standards for chemical agents and their
breakdown products are found in Table A-47 of this document.
(OSHA regulations and other health and safety requirements are
actually independently applicable requirements, not ARARs and
TBCs. ACGIH and NIOSH values are provided as guidelines.)
Emission of particulates
5 CCR 1001-3, Regulation 1,
Section III (D)
5 CCR 1001-5, Regulation 3
Emission of hazardous air pollutants
Volatile organic chemical emissions
5 CCR 1001-10, Regulations
40CFRPart61
42 USC Section 7412
5 CCR 1001-9, Regulation 7
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control program will be
written into the work plan in consultation with the state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Emission of listed hazardous air pollutants is controlled by
NESHAPs. UXO demilitarization could potentially cause emission
of hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
RMA ARARS 1/96
-------
Table A-26 Action-Specific ARARs and TBCs for UXO Demilitarization/Chemical Agent Decontamination
Page 5 of 7
Action
Citation
Requirements
PM,,/CO emissions
Visibility protection
42 USC Section 7502-7503
40 CFR 51.300-307
40 CFR 52.26-29
5CCR 1001-14
CRS Section 42-4-307(8)
Odor emissions
5 CCR 1001-4, Regulation 2
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Demilitarization of UXO must be conducted in a manner that does
not cause adverse impacts on visibility. Visibility impairment
interferes with the management, protection, preservation, or
enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
RMA ARARS 1/96
-------
Table A-26 Action-Specific ARARs and TBCs for UXO Demilitarization/Chemical Agent Decontamination
Page 6 of 7
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
' noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
-------
Table A-26 Action-Specific ARARs and TBCs for UXO Demilitarization/Chemical Agent Decontamination Page 7 of 7
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
-------
Table A-27 Action-Specific ARARs and TBC s for Direct Solidification/Stabilization
Page 1 of 9
Action
Citation
Requirements
Worker Protection
Health and safety protection
29 CFR Part 1910
29CFR 1910.120 (b) to (j)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
In addition to the chemicals listed in Table A-46, soil
solidification/stabilization will use Portland cement and possibly
calcium silicate, calcium hydroxide, and calcium oxide. Worker
exposure limits for these compounds are provided below:
RMA ARARS l/%
-------
Table A-27 Action-Specific ARARs and TBC s for Direct Solidification/Stabilization
Page 2 of 9
Action
Citation
Requirements
Calcium hydroxide ACGIH-TWA
OSHA-TWA
Calcium oxide
Calcium silicate
ACGIH-TWA
N1OSH-REL
OSHA-PEL
ACGIH-TWA
OSHA-PEL
5 mg/m3
: I5mg/m3(totaldust),
5 mg/m3 (resp)
; 2 mg/m3
: 2 mg/m3
= 5 mg/m3
= 10 mg/m3*
= 15 mg/m3 (total dust),
5 mg/m3 (resp)
Portland cement* ACGIH-TWA
NIOSH-REL
10mg/m3
I0mg/m3(total),
5 mg/m3 (resp)
OSHA-TWA =15 mg/m3 (total),
5 mg/m3 (resp)
* values are for total dust containing no asbestos and less than I %
crystalline silica
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
RM/V ARARS 1/96
-------
Table A-27 Action-Specific ARARs and TBC s for Direct Solidification/Stabilization
Page 3 of 9
Action
Citation
Requirements
Waste Characterization
Solid waste determination
Determination of hazardous waste
40 CFR 260
6CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
CCR 1007-3 Part 261
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Direct soil solidification/stabilization will generate oversize soil
debris and metallic wastes. These wastes and all others generated
must be characterized and evaluated according to the following
method to determine whether the waste is hazardous:
• Determine whether the waste is excluded form regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
RMA ARARS 1/96
-------
Table A-27 Action-Specific ARARs and TBC 9 for Direct Solidification/Stabilization
Page 4 of 9
Action
Citation
Requirements
Solid waste classification
6CCR 1007-2, Section 1
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories,
which include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community,
commercial, and special wastes are expected from direct
solidification/stabilization at RMA.
RMA ARARS 1/96
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Table A-27 Action-Specific ARARs and TBC s for Direct Solidification/Stabilization
Page 5 of 9
Action
Citation
Requirements
Waste Management
Treatment and storage of hazardous wastes 40 CFR Part 264
6 CCR 1007-3 Part 264
On-post land disposal of hazardous wastes 40 CFR Part 264
6 CCR 1007-3 Part 264
EPA/540/G-89/006 [TBC]
40 CFR Part 268
6 CCR 1007-3 Part 268
6 CCR 1007-3
Management of Remediation Wastes
Corrective Action Management Units
40CFR264,SubpartS
6 CCR 1007-3, Part 264 Subpart S
No special testing requirements are specified for solid wastes. The
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Wastes that are determined to be RCRA hazardous wastes must be
stored and treated in compliance with RCRA regulations, including
the tank requirements in 40 CFR 264 Subpart J.
Based upon a determination of whether the disposal technique
constitutes placement, the LDRs-UTS may be applicable. If
placement does occur, the disposal facility must comply with the
substantive requirements of 40 CFR Part 264 (6 CCR 1007-3 Part
264) and 40 CFR Part 268 (6 CCR 1007-3 Part 268).
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
RMA ARARS 1/96
-------
Table A-27 Action-Specific ARARs and TBC s for Direct Solidification/Stabilization
Page 6 of 9
Action
Citation
Requirements
Air Emissions
Emission of Particulates
5 CCR 1001-3, Regulation I,
Section III (D)
5 CCR 1001-5, Regulation 3
Emission control for opacity
Emission of hazardous air pollutants
Volatile organic chemical emissions
5 CCR 1001-3, Regulation 1, Section I!
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-9, Regulation 7
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control program will be
written into the work plan in consultation with the state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Direct solidification/stabilization of soils shall not cause the
emission into the atmosphere of any air pollutant that is in excess of
20% opacity.
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Direct solidification/stabilization of soils could
potentially cause emission of hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
Direct soil solidification/stabilization must be conducted in a
manner that does not cause adverse impacts on visibility. Visibility
impairment interferes with the management, protection,
preservation, or enjoyment of federal Class I areas.
RMA ARARS 1/96
-------
Table A-27 Action-Specific ARARs and TBC s for Direct Solidification/Stabilization
Page 7 of 9
Action
Citation
Requirements
5 CCR 1001-14
CRS Section 42-4-307(8)
Odor emissions
5 CCR 1001-4, Regulation!
Stormwater Management
Discharge of storm water to on-post surface 40 CFR Parts 122-125
waters
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
RMA ARARS 1/96
-------
Table A-27 Action-Specific ARARs and TBC s for Direct Solidification/Stabilization
Page 8 of 9
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be .made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
-------
Table A-27 Action-Specific ARARs and TBC s for Direct Solidification/Stabilization Page 9 of 9
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
-------
Table A-28 Action-Specific ARARs and TBCs for In Situ Solidification/Stabilization
Page 1 of 6
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPart 1910
29 CFR 1910.120 (b) to 0)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by. OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
In addition to the chemicals listed in Table A-46, soil
solidification/stabilization will use Portland cement and possibly
calcium silicate, calcium hydroxide, and calcium oxide. Worker
exposure limits for these compounds are provided below:
RMA ARARS 1/96
-------
Table A-28 Action-Specific ARARs and TBCs for In Situ Solidification/Stabilization
Page 2 of 6
Action
Citation
Requirements
Waste Characterization
Solid waste determination
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
Calcium hydroxide ACGIH-TWA
OSHA-TWA
Calcium oxide
Calcium silicate*
Portland cement*
ACGIH-TWA
NIOSH-REL
OSHA-PEL
ACGIH-TWA
OSHA-PEL
= 5 mg/m3
= 15 mg/m3 (total dust),
5 mg/tn3 (resp)
= 2 mg/m3
= 2 mg/m3
= 5 mg/m3
= 10 mg/m3
= 15 mg/m3 (total dust),
5 mg/m3 (resp)
ACGIH-TWA
NIOSH-REL
10 mg/m3
10 mg/m3 (total),
5 mg/m3 (resp)
OSHA-TWA = 15 mg/m3 (total),
5 mg/m3 (resp)
* values are for total dust containing no asbestos and less than 1 %
crystalline silica
(OSHA regulations and other health and safety requirements are
actually independently applicable requirements, not ARARs and
TBCs. ACGIH and NIOSH values are provided as guidelines.)
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
RMA ARARS 1/96
-------
Table A-28 Action-Specific ARARs and TBCs for In Situ Solidification/Stabilization
Page 3 of 6
Action
Citation
Requirements
Determination of Hazardous Waste
40CFR262.il
6 CCR 1007-3 Sect 262. II
40 CFR Part 261
6 CCR 1007-3 Part 261
Air Emissions
Emission Participates
5 CCR 1001-3, Regulation 1
Section lll(D)
5 CCR 1001-5, Regulation 3
Emission control for opacity
5 CCR 1001-3, Regulation 1, Section II
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Wastes generated during pipe plugging activities must be
characterized. Solid wastes must be evaluated according to the
following method to determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR 261
• Determine whether the waste is identified in 40 CFR 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control program will be
written into the work plan in consultation with the state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
In situ solidification/stabilization of soils shall not cause the
emission into the atmosphere of any air pollutant that is in excess of
20% opacity.
RMA ARARS 1/96
-------
Table A-28 Action-Specific ARARs and TBCs for In Situ Solidification/Stabilization
Page 4 of 6
Action
Citation
Requirements
Emission of hazardous air pollutants
Volatile organic chemical emissions
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USC Section 7412
5 CCR 1001-9, Regulation 7
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Direct solidification/stabilization of soils could
potentially cause emission of hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
In situ soil solidification/stabilization must be conducted in a
manner that does not cause adverse impacts on visibility. Visibility
impairment interferes with the management, protection,
preservation, or enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
RMA ARARS 1/96
-------
Table A-28 Action-Specific ARARs and TBCs for In Situ Solidification/Stabilization
Page S of 6
Action
Citation
Requirements
Odor emission
5 CCR 1001-4, Regulation 2
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Stormwater Management
Discharge of Stormwater to on-post surface
waters
Noise abatement
40 CFR Parts 122-125
Colorado Revised Statute, Section 25-12-
103
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
RMA ARARS 1/96
-------
Table A-28 Action-Specific ARARs and TBCs for In Situ Solidification/Stabilization Page 6 of 6
Action Citation Requirements
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
-------
Table A-29 Action-Specific ARARs and TBCs for Biological Reactor Treatment
Page 1 of 8
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPartl9lO
29CFR !9I0.120(b)toG)
Worker exposure
ACGIH 1991-1992 [TBC]
N1OSH 1990 [TBC]
29CFR 1910.1000
(These regulations are commonly considered location-specific
ARARs, but may impact the remedial actions taken. They are
included in this table for the convenience of the reader.)
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
20 CFR 1910.120 (b) through 0) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
RMA ARARS 1/96
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Table A-29 Action-Specific ARARs and TBCs for Biological Reactor Treatment
Page 2 of 8
Action
Citation
Requirements
Air Emissions
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
PM|o/CO emissions
Emission of hazardous air pollutants
Odor emissions
42 USC Section 7502-7503
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-4, Regulation 2
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirments.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Emission of certain hazardous air pollutants is controlled by
NESHAPs.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
I) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
RMA ARARS 1/96
-------
Table A-29 Action-Specific ARARs and TBCs for Biological Reactor Treatment
Page 3 of 8
Action
Citation
Requirements
Waste Characterization
Solid waste determination
Determination of hazardous waste
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
40CFR262.il
6 CCR 1007-3262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
waste! ike
Biological reactor treatment of groundwater at RMA will create
wastes consisting of spent biomass, iron and manganese
precipitates, suspended solids, and recovered dicyclopentadiene
(DCPD). These and all other wastes generated in this process must
be evaluated according to the following method to determine if the
waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
RMA ARARS 1/96
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Table A-29 Action-Specific ARARs and TBCs for Biological Reactor Treatment
Page 4 of 8
Action
Citation
Requirements
Solid waste classification
6CCR 1007-2, Section 1
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
I) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
RMA ARARS 1/96
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Table A-29 Action-Specific ARARs and TBCs for Biological Reactor Treatment
Page 5 of 8
Action
Citation
Requirements
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
6 CCR 1007-3
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
Only small quantities of industrial, community, and commercial
wastes, along with inert material, are expected to be generated
during biological reactor treatment of groundwater at RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Wastes from biological reactor treatment of groundwater that are
determined to be RCRA hazardous wastes must be treated, stored,
and disposed in compliance with RCRA regulations, including
LDRs-UTS if placement occurs, and with task requirements in 40
CFR 264 Subpart J.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
RMA ARARS 1/96
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Table A-29 Action-Specific ARARs and TBCs for Biological Reactor Treatment
Page 6 of 8
Action
Citation
Requirements
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Reinjection of treated groundwater
RCRA Section 3020 (b)
OSWER Directive 9234.1-06 [TBC]
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
Reinjection of treated groundwater must be managed in accordance
with the guidelines in OSWER Directive 9234.1-06. Wells must be
constructed and installed and managed according to the
requirements of 40 CFR 124, 144, 146, 147 (Subpart G) and 148.
RMA ARARS 1/96
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Table A-29 Action-Specific ARARs and TBCs for Biological Reactor Treatment
Page 7 of 8
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sould levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
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Table A-29 Action-Specific ARARs and TBCs for Biological Reactor Treatment Page 8 of 8
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
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Table A-30 Action-Specific ARARs and TBCs for UV/Ozone and in Situ Groundwater Treatment
Page 1 of 8
Action
Citation
Requirements
Worker Protection
Health and safety protection
29 CFR Part 1910
29CFR 1910.120 (b) to (j)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990
29 CFR 1910.1000
29 CFR Part 1910 provides guidelines for workers engaged in
activities requiring protective health and safety measures regulated
by OSHA. Requirements provided in 29 CFR 1910.120 apply
specifically to the handling of hazardous waste/materials at
uncontrolled hazardous waste sites.
20 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46. In
addition to the chemicals in Table A-46, the ultraviolet (UV)/ozone
treatment will potentially utilize hydrogen peroxide and ozone. The
worker exposure standards for these compounds are given below:
RMA ARARS l/%
-------
Table A-30 Action-Specific ARARs and TBCs for UV/Ozone and In Situ Groundwater Treatment
Page 2 of 8
Action
Citation
Requirements
Air Emissions
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
PM10/CO emissions
Emission of hazardous air pollutants
42 USC Section 7502-7503
5 CCR 1001-5, Regulation 3
5 CCR 1001-10, Regulation 8
40CFRPart6l
Hydrogen peroxide
ACGIH-TWA
NIOSH-REL
OSHA-PEL
Ozone
= I ppm, 1.4 mg/m3
= I ppm, 1.4 mg/m3
= I ppm, 1.4 mg/m3
ACGIH-Ceiling = 0.1 ppm, 0.20 mg/m3
NIOSH-Ceiling = O.I ppm, 0.20mg/m3
OSHA-PEL = 0.1 ppm, 0.2 mg/m3
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Emission of certain hazardous air pollutants is controlled by
NESHAPs.
RMA ARARS 1/96
-------
Table A-30 Action-Specific ARARs and TBCs for UV/Ozone and In Situ Groundwatcr Treatment
Page 3 of 8
Action
Citation
Requirements
Odor emissions
42 USCS Section 7412
5 CCR 1001-4, Regulation 2
Waste Characterization
Solid waste determination
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
I) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
waste! ike
RMA ARARS 1/96
-------
Table A-30 Action-Specific ARARs and TBCs for UV/Ozone and in Situ Groundwater Treatment
Page 4 of 8
Action
Citation
Requirements
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
Solid waste classification
6 CCR 1007-2, Section 1
UV/ozone treatment of groundwater will create wastes consisting
primarily of inorganic sludges. These and all other wastes
generated in this process must be evaluated according to the
following method to determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
I) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
RMA ARARS 1/96
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Table A-30 Action-Specific ARARs and TBCs for UV/Ozone and In Situ Groundwater Treatment
Page 5 of 8
Action
Citation
Requirements
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
6 CCR 1007-3
4) "Special wastes," which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
Only small quantities of industrial, community, and commercial
wastes, along with inert material, are expected to be generated
during UV/ozone treatment of groundwater.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Wastes from UV/ozone treatment that are determined to be RCRA
hazardous wastes must be treated, stored, and disposed in
compliance with RCRA regulations, including land disposal
restrictions LDRs-UTS if placement occurs.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
RMA ARARS 1/96
-------
Table A-30 Action-Specific ARARs and TBCs for UV/Ozone and In Situ Groundwater Treatment
Page 6 of 8
Action
Citation
Requirements
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater Management
Discharge of storm water to on-post surface 40 CFR Parts 122-125
waters
Reinjection of treated groundwater
RCRA Section 3020 (b)
OSWER Directive 9234.1-06 [TBC]
40 CCR 124, 144, 146, 147 (Subpart G),
and 148
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
Reinjection of treated groundwater must be managed in accordance
with the guidelines in OSWER Directive 9234.1-06. Wells must be
constructed and installed and managed according to the substantive
requirements of 40 CFR 124, 144, 146, 147 (Subpart G), and 148.
RMA ARARS 1/96
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Table A-30 Action-Specific ARARs and TBCs for UV/Ozone and In Situ Groundwater Treatment
Page 7 of 8
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
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Table A-30 Action-Specific ARARs and TBCs for UV/Ozone and In Situ Groundwater Treatment Page 8 of 8
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
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Table A-31 Action-Specific ARARs and TBCs for Solvent Extraction
Page 1 of 6
Action
Citation
Requirements
Worker Protection
Health and safety protection
29 CFR Part 1910
29CFR 1910.120 (b) to 0)
Worker exposure
Air Emissions
Emission of hazardous air pollutants
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
5 CCR 1001-10, Regulation 8
40 CFR Part 61
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Solvent extraction could potentially cause emission of
hazardous air pollutants.
RMA ARARS 1/96
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Table A-31 Action-Specific ARARs and TBCs for Solvent Extraction
Page 2 of 6
Action
Citation
Requirements
Volatile organic chemical emissions
42 USCS Section 7412
5 CCR 1001-9, Regulation 7
PM|o/CO emissions
Visibility protection
42 USC Section 7502-7503
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Solvent extraction must be conducted in a manner that does not
cause adverse impacts on visibility. Visibility impairment interferes
with the management, protection, preservation, or enjoyment of
federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours, The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
RMA ARARS 1/96
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Table A-31 Action-Specific ARARs and TBCs for Solvent Extraction
Page 3 of 6
Action
Citation
Requirements
Emission of Particulates
5 CCR 1001-3, Regulation I, Section
H!(D)
5 CCR 1001-5, Regulation 3
Odor Emissions
5 CCR 1001-4, Regulation 2
Management of Remediation Wastes
Waste Management
Correction Action Management Units
40CFR264SubpartJ
6 CCR 1007-3 Part 164 Subpart J
40 CFR 264 Subpart S
6 CCR 1007-3 Part 264 Subpart S
. Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control program will be
written into the work plan in consultation with the state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-free
air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Applicability of the substantive requirements for tanks.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
RMA ARARS 1/96
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Table A-31 Action-Specific ARARs and TBCs for Solvent Extraction
Page 4 of 6
Action
Citation
Requirements
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Wastewater
Discharge of liquid wastes
Waste Management
Treatment, storage, or disposal of
hazardous wastes
40 CFR Part 122
40 CFR Part 125
40 CFR Part 129
40 CFR Part 262
6 CCR 1007-3 Part 262
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 264, Subpart aa, bb, and cc
6 CCR 1007-3 Part 264, Subpart aa, bb,
andcc
40 CFR 264, Subpart J
6 CCR 1007-3 Sect 264, Subpart J
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
Any wastewater generated during solvent extraction will be routed
to the on-post RMA wastewater treatment plant if it is not hazardous
waste and will not interrupt the existing treatment system. If
wastewater is routed to the on-post treatment plant, it must be
treated in accordance with NPDES requirements.
Wastewater that is determined to be hazardous must be treated in
accordance with provisions of the RCRA.
Wastes that are determined to be RCRA hazardous wastes must be
stored and treated, in compliance with RCRA air emission
regulations.
Applicability of all substantive requirements for tanks or tank
systems.
RMA ARARS 1/96
-------
Table A-31 Action-Specific ARARs and TBCs for Solvent Extraction
Page 5 of 6
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
KM A ARARS 1/96
-------
Table A-31 Action-Specific ARARs and TBCs for Solvent Extraction Page 6 of 6
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS I/96
-------
Table A-32 Action-Specific ARARs and TBCs for Pipe Plugging
Action
Citation
Worker Protection
Health and safety protection
29CFRPart 1910
29CFR 1910.120 (b) to 0)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29CFR 1910.1000
RMA ARARS l/9fi
Page 1 of 8
Requirements
29 CFR I910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
-------
Table A-32 Action-Specific ARARs and TBCs for Pipe Plugging
Page 2 of 8
Action
Citation
Requirements
Air Emissions
Emissions of particulates
5 CCR 1001-3, Regulation 1, Sect IH.D
5 CCR 1001-5, Regulation 3
Odor emissions
5 CCR 1001-4, Regulation 2
Emission control for opacity
Volatile organic chemical emissions
5 CCR 1001-3, Regulation 1, Sect II
5 CCR 1001-9, Regulation 7
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control measure will be
written into the work plan in consultation with the state for the
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-free
air
2) For all other land use ares—odors detected after the odorous air
has been diluted with IS more volumes of odor-free air
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
RMA ARARS 1/96
-------
Table A-32 Action-Specific ARARs and TBCs for Pipe Plugging
Page 3 of 8
Action
Citation
Requirements
Emission of hazardous air pollutants
Waste Characterization
Solid waste determination
Determination of hazardous waste
5 CCR 1001-10, Regulation 8
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Vacuum dusting could potentially cause emission of
hazardous air polutants.
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Wastes generated during pipe plugging activities must be
characterized. Solid wastes must be evaluated according to the
following method to determine whether the waste is hazardous:
Determine whether the waste is excluded from regulation under
40 CFR 261.4
Determine whether the waste is listed under 40 CFR 261
RMA ARARS 1/96
-------
Page 4 of 8
Requirements
• Determine whether the waste is identified in 40 CFR 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
Table A-32 Action-Specific ARARs and TBCs for Pipe Plugging
Action
Citation
Solid waste classification
6CCR 1007-2, Section 1
RMA ARARS 1/96
-------
Table A-32 Action-Specific ARARs and TBCs for Pipe Plugging
Action
Citation
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
6 CCR 1007-3
Treatment and disposal of hazardous debris
40 CFR 268.45
6 CCR 1007-3, Part 268.45
RMA ARARS 1/96
Page 5 of 8
Requirements
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community, special,
and commercial wastes are expected from pipe plugging activities at
RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
If pipe plugging in structures at RMA generates hazardous wastes,
the wastes must be treated, stored or disposed in accordance with
RCRA regulations, including LDRs-UTS if placement occurs.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
Hazardous debris generated during pipe plugging activities may be
treated using specific technologies to extract, destroy, or immobilize
hazardous constituents on or in the debris. In certain cases, after
treatment the debris may no longer be subject to RCRA Subtitle C
regulation.
-------
Table A-32 Action-Specific ARARs and TBCs for Pipe Plugging
Page 6 of 8
Action
Citation
Requirements
Management of Remediation Wastes
Corrective Action Management Units
40CFR264,SubpartS
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Stormwater Management
Discharge of storm water to on-post surface 40 CFR Parts 122-125
waters
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
RMA ARARS 1/96
-------
Table A-32 Action-Specific ARARs and TBCs for Pipe Plugging
Page 7 of 8
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sould levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS !M>
-------
Table A-32 Action-Specific ARARs and TBCs for Pipe Plugging
Action
Citation
RMA ARARS 1/96
Page 8 of 8
Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
-------
Table A-33 Action-Specific ARARs and TBCs for Vacuum Dusting
Page 1 of 8
Action
Citation
Requirements
Worker Protection
Health and safety protection
29 CFR Part 1910
29CFR 1910.120(b)toG)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120(b) through 0) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
RMA ARARS 1/96
-------
Table A-33 Action-Specific ARARs and TBCs for Vacuum Dusting
Page 2 of 8
Action
Citation
Requirements
Air Emissions
Emission of Particulates
5CCR 1001-3, Regulation I,
Section (II (D)
5 CCR 1001-5, Regulation 3
Emission control for opacity
Visibility protection
5 CCR 1001-3, Regulation I, Section II
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
Emission of hazardous air pollutants
5 CCR 1001-10, Regulation 8
40 CFR 61
42 USCS Section 7412
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control program will be
written into the work plan in consultation with the state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Vacuum dusting shall not cause the emission into the atmosphere
of any air pollutant which is in excess of 20% opacity.
Vacuum dusting must be conducted in a manner that does not cause
adverse impacts on visibility. Visibility impairment interferes with
the management, protection, preservation, or enjoyment of federal
Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Vacuum dusting could potentially cause emission of
hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
RMA ARARS 1/96
-------
Table A-33 Action-Specific ARARs and TBCs for Vacuum Dusting
Page 3 of 8
Action
Citation
Requirements
Volatile organic chemical emissions
5CCR 1001-9, Regulation?
Odor emissions
5 CCR 1001-4, Regulation 2
Waste Management
PCB storage
40CFR761.65
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Storage facilities must be constructed with adequate roofs, walls;
have impervious floors with curbs (no floor drains expansion joints
or other openings); be located above 100 year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing non-
liquid PCBs, such as contaminated soil, rags, debris need not
comply with above requirements.
Containers must be dated when they are placed in storage.
All storage areas must be properly marked and stored articles must
be checked for leaks every 30 days.
RMA ARARS 1/96
-------
Table A-33 Action-Specific ARARs and TBCs for Vacuum Dusting
Page 4 of 8
Action
Citation
Requirements
Solid waste determination
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 160.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 161.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Sect 262. II
40 CFR Part 261
6 CCR 1007-3 Part 261
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Vacuum dusting of structures at RMA will create wastes consisting
of filters with dust particles and debris. These wastes and all other
solid wastes generated in this process must be evaluated according
to the following method to determine whether the waste is
hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
RMA ARARS 1/96
-------
Table A-33 Action-Specific ARARs and TBCs for Vacuum Dusting
Page 5 of 8
Action
Citation
Requirements
Solid waste classification
6 CCR 1007-2, Section 1
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
RMA ARARS 1/96
-------
Table A-33 Action-Specific ARARs and TBCs for Vacuum Dusting
Page 6 of 8
Action
Citation
Requirements
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6CCR 1007-3 Part 264
40 CFR Part 268
6CCR 1007-3 Part 268
6CCR 1007-3
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
If present, only small quantities of industrial, community, and
commercial wastes are expected from vacuum dusting of structures
at RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Vacuum dusting wastes that are determined to be RCRA hazardous
wastes must be stored, treated, and disposed in compliance with
RCRA regulations, including land disposal restrictions LDRs if
placement occurs.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs-UTS and minimum technology
requirements for remediation wastes managed at CAMUs. These
regulations provide flexibility and allow for expedition of remedial
decisions in the management of remediation wastes. One or more
CAMUs may be designated at a facility. Placement of hazardous
remediation wastes into or within the CAMU does not constitute
land disposal of hazardous wastes so the LDRs-UTS are not
triggered.
RMA ARARS 1/96
-------
Table A-33 Action-Specific ARARs and TBCs for Vacuum Dusting
Page 7 of 8
Action
Citation
Requirements
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Stormwater Management
Discharge of stormwater to on-post surface
waters
Noise abatement
40 CFR Parts 122-125
Colorado Revised Statute, Section 25-12-
103
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
RMA ARARS 1/96
-------
Table A-33 Action-Specific ARARs and TBCs for Vacuum Dusting
Page 8 of 8
Action
Citation
Requirements
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
-------
Table A-34 Action-Specific ARARs and TBCs for In Situ Steam Cleaning
Page 1 of 10
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPart I9IO
29CFRl9lO.I20(b)to(j)
Worker exposure
ACGIH 1991-1992[TBC]
NIOSH 1990[TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through 0) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines)
RMA ARARS 10/94
-------
Table A-34 Action-Specific ARARs and TBCs for In Situ Steam Cleaning
Page 2 of 10
Action
Citation
Requirements
Air Emissions
Emission of Particulates
Emission control for opacity
Odor emissions
5 CCR 1001-3, Regulation 1,
Section III (D)
5 CCR 1001-5, Regulation 3
5 CCR 1001-2, Section II
5 CCR 1001-3, Regulation 1, Section II
Emission of hazardous air pollutants 5 CCR 1001 -10, Regulation 8
40CFR61
42 USCS Section 7412
5 CCR 1001-4, Regulation 2
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control program will be
written into the work plan in consultation with the state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Steam cleaning of structures shall not cause the emission into the
atmosphere of any air pollutant that is in excess of 20% opacity.
Emission of certain hazardous air pollutants is controlled by
NESHAPs. Steam cleaning may cause volatization of some
contaminants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Colorado Odor Emission Regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air •
RMA ARARS 10/94
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Table A-34 Action-Specific ARARs and TBCs for In Situ Steam Cleaning
Page 3 of 10
Action
Citation
Requirements
Air emissions from diesel-powered
vehicles associated with construction or
demolition
5 CCR 1001-15, Regulation 12
Colorado Diesel-Powered Vehicle Emission Standards for Visible
Pollutants apply to motor vehicles intended, designed, and
manufactured primarily for use in carrying passengers or cargo on
roads, streets, and highways, and state as follows:
1) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing 7,500 pounds
and less, empty weight, any air contaminant, for a period greater
than five (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 40% opacity.
2) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing more than
7,500 pounds, empty weight, any air contaminant, for a period
greater than (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 35% opacity, with the exception of subpart "C".
3) No person shall emit or cause to be emitted into the atmosphere
from any naturally aspirated (non-turbocharged) diesel-powered
motor vehicle weighing more man 7,500 pounds, empty weight,
operated above 7,000 ft (mean sea level) any air contaminant for
a period greater than five (5) consecutive seconds, which is of
such a shade or density as to obscure an observer's vision to a
degree in excess of 40% opacity.
4) Any diesel-powered motor vehicle exceeding these requirements
shall be exempt for a period of 10 minutes if the emissions are a
direct result of a cold engine start-up and provided the vehicle is
in a stationary position.
5) These standards shall apply to motor vehicles intended,
designed, and manufactured primarily for travel or use in
transporting persons, property, auxiliary equipment, and/or cargo
over roads, streets, and highways.
RMA ARARS 10/94
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Table A-34 Action-Specific ARARs and TBCg for In Situ Steam Cleaning
Page 4 of 10
Action
Citation
Requirements
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5CCR 1001-14
CRS Section 42-4-307(8)
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
42 USC 7502-7503
Waste Management
PCB storage
40 CFR 761.65
Steam cleaning must be conducted in a manner that does not cause
adverse impacts on visibility. Visibility impairment interferes with
the management, protection, preservation, or enjoyment of Federal
Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as applicable). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control disposal of VOCs by
evaporation or spilling unless reasonably available control
technologies are utilized.
Storage facilities must be constructed with adequate roofs, walls;
have impervious floors with curbs (no floor drains expansion joints
or other openings); be located above 100 year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing non-
liquid PCBs, such as contaminated soil, rags, debris need not
comply with above requirements.
RMA ARARS 10/94
-------
Table A-34 Action-Specific ARARs and TBCs for In Situ Steam Cleaning
Page S of 10
Action
Citation
Requirements
Solid waste determination
40 CFR 260
6CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Sect 262. II
40 CFR Part 261
6 CCR 1007-3 Part 261
Containers must be dated when they are placed in storage.
All storage areas must be properly marked and stored articles must
be checked for leaks every 30 days.
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Steam cleaning will generate wastewater from condensate and
potential spent filter media. These wastes and all others generated
must be characterized. The wastes must be evaluated according to
the following method to determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
RMA ARARS 10/94
-------
Table A-34 Action-Specific ARARs and TBCs for In Situ Steam Cleaning
Page 6 of 10
Action
Citation
Requirements
Solid waste classification
6CCR 1007-2, Section I
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes" which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
RMA ARARS 10/94
-------
Table A-34 Action-Specific ARARs and TBCs for In Situ Steam Cleaning
Page 7 of 10
Action
Citation
Requirements
Wastewater
Treatment, storage or disposal of hazardous
wastes
40 CFR Part 122
40 CFR Part 125
40 CFR Part 129
40 CFR Part 262
6CCR 1007-3 Part 262
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community, and
commercial wastes, along with inert material are expected from
steam cleaning of structures at RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Any wastewater generated during steam cleaning will be routed to
the on-post RMA wastewater treatment plant if it is not hazardous
waste and will not interrupt the existing treatment system. If
wastewater is.routed to the on-post treatment plant, it must be
treated in accordance with NPDES requirements.
Wastewater that is determined to be hazardous must be treated in
accordance with provisions of the RCRA.
Wastes that are determined to be RCRA hazardous wastes, such as
spent filter media from steam cleaning, must be stored, treated, and
disposed in compliance with RCRA regulations, including LDRs if
placement occurs.
RMA ARARS 10/94
-------
Table A-34 Action-Specific ARARs and TBCs for In Situ Steam Cleaning
Page 8 of 10
Action
Citation
Requirements
6CCR 1007-3
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Stormwater Management
Discharge of Stormwater to on-post surface 40 CFR Parts 122-125
waters
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
•more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs and minimum technology requirements
for remediation wastes managed at CAMUs. These regulations
provide flexibility and allow for expedition of remedial decisions in
the management of remediation wastes. One or more CAMUs may
be designated at a facility. Placement of hazardous remediation
wastes into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
RMA ARARS 10/94
-------
Table A-34 Action-Specific ARARs and TBCs for In Situ Steam Cleaning
Page 9 of 10
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to "
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 10/94
-------
Table A-34 Action-Specific ARARs and TBCs for In Situ Steam Cleaning Page 10 of 10
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 10/94
-------
Page 1 of 9
Requirements
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
Table A-35 Action-Specific ARARs and TBCs for Sand Blasting
Action
Citation
Worker Protection
Health and safety protection 29 CFR Part 1910
29 CFR 1910.120 (b) to (j)
Worker exposure
ACGIH 1991-1992
NIOSH 1990[TBC]
29 CFR 1910.1000
RMA ARARS 1/96
-------
Table A-3S Action-Specific ARARs and TBCs for Sand Blasting
Page 2 of 9
Action
Citation
Requirements
Air Emissions
Emission of particulates
Emission control for opacity
Emission of hazardous air pollutants
Odor emissions
5 CCR 1001-3, Regulation 1,
Section HI (D)(2)(j)
5 CCR 1001-5, Regulation 3
5 CCR 1001-3, Regulation I, Section II
5 CCR 1001-10, Regulation 8
40CFR61
42 USCS Section 7412
5 CCR 1001-4, Regulation 2
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control program will be
written into the work plan in consultation with the state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Sand blasting shall not cause the emission into the atmosphere of
any air pollutant that is in excess of 20% opacity.
Emission of certain hazardous air pollutants is controlled by
NESHAPs. Sand blasting could potentially cause emission of
hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
I) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air.
RMA ARARS 1/96
-------
Table A-3S Action-Specific ARARs and TBCs for Sand Blasting
Page 3 of 9
Action
Citation
Requirements
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5CCR 1001-14
CRS Section 42-4-307(8)
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
PM)(/CO emissions
42 USC 7502-7503
Waste Management
Asbestos waste storage management 6 CCR 1007-2, Part B, Section 5.4
Asbestos waste handling management 40 CFR 61, Subpart M
Sand blasting must be conducted in a manner that does not cause
adverse impacts on visibility. Visibility impairment interferes with
the management, protection, preservation, or enjoyment of federal
Class I areas.
The Colorado Ambient Air Quality Standards for the AIR Program
area is a standard visual range of 32 miles. The averaging time is
four hours. The standard applies during an 8-hour period from 8:00
a.m. to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as applicable). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos storage.
Prevent discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing wastes; deposit
asbestos-containing waste as possible at disposal site; mark
transport vehicle appropriately during loading and unloading
operations.
RMA ARARS 1/96
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Table A-3S Action-Specific ARARs and TBCs for Sand Blasting
Page 4 of 9
Action
Citation
Requirements
PCB storage
5 CCR 1001-10, Regulation Part B,
Section S.B.III.c.8
40CFR761.65
Solid waste determination
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6CCR 1007-3 Sect 261.4
Asbestos waste will be managed according to applicable substantive
requirements for asbestos handling, transportation, and storage.
Storage facilities must be constructed with adequate roofs, walls;
have impervious floors with curbs (no floor drains expansion joints
or other openings); be located above 100 year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing non-
liquid PCBs, such as contaminated soil, rags, debris need not
comply with above requirements.
Containers must be dated when they are placed in storage.
All storage areas must be properly marked and stored articles must
be checked for leaks every 30 days.
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
waste-like
RMA ARARS 1/96
-------
Table A-35 Action-Specific ARARs and TBCs for Sand Blasting
Action
Citation
Determination of hazardous waste
40CFR262.il
6CCR 1007-3 Sect 262.11
40 CFR Part 261
6CCR 1007-3 Part 261
Solid waste classification
6 CCR 1007-2, Section I
RMA ARARS 1/96
Page 5 of 9
Requirements
Sand blasting structures at RMA will create wastes that consist of
dust, abrasives such as sand or pellets, debris, and possibly used
filters. These wastes and all other solid wastes generated in this
process must be evaluated according to the following process to
determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
-------
Table A-3S Action-Specific ARARs and TBCs for Sand Blasting
Action
Citation
Treatment, storage, or disposal of
hazardous wastes
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 168
6 CCR 1007-3
RMA ARARS 1/96
Page 6 of 9
Requirements
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community, and
commercial wastes are expected from sand blasting of structures at
RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Wastes that are determined to be RCRA hazardous wastes, such as
spent filter media, abrasives and debris, must be stored, treated, and
disposed in compliance with RCRA regulations, including LDRs.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
-------
Table A-35 Action-Specific ARARs and TBCs for Sand Blasting
Page 7 of 9
Action
Citation
Requirements
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs and minimum technology requirements
for remediation wastes managed at CAMUs. These regulations
provide flexibility and allow for expedition of remedial decisions in
the management of remediation wastes. One or more CAMUs may
be designated at a facility. Placement of hazardous remediation
wastes into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
RMA ARARS 1/96
-------
Table A-3S Action-Specific ARARs and TBCs for Sand Blasting
Page 8 of 9
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
-------
Table A-35 Action-Specific ARARs and TBCs for Sand Blasting
Action
Citation
RMA ARARS 1/96
Page 9 of 9
Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
-------
Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 1 of 14
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPart I9IO
29CFRI9lO.I20(b)to(j)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through 0) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
RMA ARARS IW6
-------
Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 2 of 14
Action
Citation
Requirements
Air emissions during salvage
5 CCR 1001-3, Regulation I,
Section III (D)
5 CCR 1001-5, Regulation 3
5 CCR 1001-2 Section II
Emission control for opacity
Emission of hazardous air pollutants
Odor emissions
5 CCR 1001-3,
Regulation 1, Section II
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-4, Regulation 2
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control program will be
written into the work plan in consultation with the state for this
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Salvage of structures shall not cause the emission into the
atmosphere of any air pollutant that is in excess of 20% opacity.
Emission of certain hazardous air pollutants is controlled by
NESHAPs. Salvage of structures could potentially cause emission
of hazardous air pollutants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 3 of 14
Action
Citation
Requirements
Air emissions from diesel-powered
vehicles associated with salvage
5 CCR 1001-! 5, Regulation 12
Colorado Diesel-Powered Vehicle Emission Standards for Visible
Pollutants apply to motor vehicles intended, designed, and
manufactured primarily for use in carrying passengers or cargo on
roads, streets, and highways, and state as follows:
1) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing 7,500 pounds
and less, empty weight, any air contaminant, for a period greater
than five (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 40% opacity.
2) No person shall emit or cause to be emitted into the atmosphere
from any diesel-powered motor vehicle weighing more than
7,500 pounds, empty weight, any air contaminant, for a period
greater than (5) consecutive seconds, which is of such a shade or
density as to obscure an observer's vision to a degree in excess
of 35% opacity, with the exception of subpart "C".
3) No person shall emit or cause to be emitted into the atmosphere
from any naturally aspirated (non-turbocharged) diesel-powered
motor vehicle weighing more than 7,500 pounds, empty weight,
operated above 7,000 ft (mean sea level) any air contaminant for
a period greater than five (5) consecutive seconds, which is of
such a shade or density as to obscure an observer's vision to a
degree in excess of 40% opacity.
4) Any diesel-powered motor vehicle exceeding these requirements
shall be exempt for a period of 10 minutes if the emissions are a
direct result of a cold engine start-up and provided the vehicle is
in a stationary position.
5) These standards shall apply to motor vehicles intended,
designed, and manufactured primarily for travel or use in
transporting persons, property, auxiliary equipment, and/or cargo
over roads, streets, and highways.
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 4 of 14
Action
Citation
Requirements
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5CCR 1001-14
CRS Section 42-4-307(8)
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
PM|o/CO emissions
42 USC 7502-7503
Salvage of structures must be conducted in a manner that does not
cause adverse impacts on visibility. Visibility impairment interferes
with the management, protection, preservation, or enjoyment of
federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as applicable). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 5 of 14
Action
Citation
Requirements
Waste Characterization
Solid waste determination
Determination of hazardous waste
40 CFR 260
6 CCR 107-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Wastes generated during structure salvage activities must be
characterized. Solid wastes must be evaluated according to the
following method to determine whether the waste is hazardous:
Determine whether the waste is excluded from regulation under
40 CFR 261.4
Determine whether the waste is listed under 40 CFR 261
Determine whether the waste is identified in 40 CFR 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 6 of 14
Action
Citation
Requirements
Solid waste classification
6 CCR 1007-2, Section 1
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 7 of 14
Action
Citation
Requirements
Waste Management
Asbestos waste storage management 6 CCR 1007-2, Part B, Section 5.4
Asbestos waste handling management 40 CFR 61, Subpart M
PCB storage
5 CCR 10001-10, Regulation Part B,
Section S.B.IH.c.8
40 CFR 761.65
If present, only small quantities of industrial, community, and
commercial wastes are expected from structure salvage activities at
RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos storage.
Prevent discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing wastes; deposit
asbestos-containing waste as possible at disposal site; mark
transport vehicle appropriately during loading and unloading
operations.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos handling, transportation, and storage.
Storage facilities must be constructed with adequate roofs, walls;
have impervious floors with curbs (no floor drains expansion joints
or other openings); be located above 100 year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing non-
liquid PCBs, such as contaminated soil, rags, debris need not
comply with above requirements.
Containers must be dated when they are placed in storage.
All storage areas must be properly marked and stored articles must
be checked for leaks every 30 days.
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 8 of 14
Action
Citation
Requirements
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
6 CCR 1007-3
Treatment and disposal of hazardous debris 40 CFR 268.45
6 CCR 1007-3, Part 268.45
Management of Remediation Wastes
Corrective action management units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
If demolition of structures at RMA generates hazardous wastes, the
wastes must be treated, stored, or disposed in accordance with
RCRA regulations, including LDRs.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
Hazardous debris generated during structure salvage activities must
be treated using specific technologies to extract, destroy, or
immobilize hazardous constituents on or in the debris. In certain
cases, after treatment the debris may no longer be subject to RCRA
Subtitle C regulation.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs and minimum technology requirements
for remediation wastes managed at CAMUs. These regulations
provide flexibility and allow for expedition of remedial decisions in
the management of remediation wastes. One or more CAMUs may
be designated at a facility. Placement of hazardous remediation
wastes into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 9 of 14
Action
Citation
Requirements
Tanks and Containers
Residues of hazardous waste in empty
containers
40CFR261.7
6CCR 1007-3 Sect 261.7
A container or inner liner removed from a container that has held
any hazardous waste is empty if:
I) All wastes have been removed that can be removed using the
practices commonly employed to remove materials from that
type of container (e.g., pouring, pumping, and aspirating), and
2) No more than one inch of residue remains on the bottom of the
container or inner liner, or
3) a) No more than 3% by weight of the total capacity of the
container remains in the container or inner liner if the container
is less than or equal to 110 gallons in size, or
b) No more than 0.3% by weight of the total capacity of the
container remains in the container or inner liner if the container
is greater than 110 gallons in size.
A container that has held a hazardous waste that is a compressed gas
is empty when the pressure in the container approaches
atmospheric.
A container or an inner liner removed from a container that has held
an acute hazardous waste listed in 40 CFR 261.31,261.32, or
261.33(e) is empty if:.
I) The container or inner liner has been triple rinsed using a solvent
capable of removing the commercial chemical product or
manufacturing chemical intermediate, or
2) The container or inner liner has been cleaned by another method
that has been shown in the scientific literature, or by tests
conducted by the generator, to achieve equivalent removal, or
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 10 of 14
Action
Citation
Requirements
Closure of tanks and tank systems
40 CFR 264.197(a)
6 CCR 1007-3 Sect 264.197(a)
40CFR261.3(d)
6 CCR 1007-3 Sect 261.3(d)
40 CFR 264.310
6 CCR 1007-3 Sect 264.310
40 CFR 264.l98(a)
6 CCR 1007-3 Sect 264.198(a)
40 CFR 264.176
6 CCR 1007-3 Sect 264.176
40 CFR 264.198(b)
6 CCR 1007-3 Sect 264.198(b)
NFPA Flammable and Combustible
Liquids Code 1990[TBC]
3) In the case of a lined container, the inner liner that prevented
contact of the commercial chemical product or manufacturing
chemical intermediate with the container, has been removed.
Any hazardous waste remaining in an empty container or an inner
liner removed from an empty container is not considered a
hazardous waste and is not subject to the RCRA regulations.
Any hazardous waste in a container or inner liner removed from a
container that is not empty is subject to RCRA hazardous waste
regulations.
At closure of a tank system, all waste residues, contaminated
containment system components, contaminated soils, and structures
and equipment contaminated with wastes must be removed,
decontaminated, and managed as hazardous wastes unless 40 CFR
261.3(d) applies (i.e., unless residues and contaminated materials
are not hazardous wastes). If the owner or operator demonstrates
that not all soils can be practically removed or decontaminated as
required, then the tank system must be closed in accordance with
requirements that apply to landfills.
Ignitable or reactive waste should not be placed in tank systems
unless the waste is treated, rendered, or mixed before or
immediately after placement in the tank system, or unless the waste
is stored or treated in such a way that it is protected from any
material or condition that may cause the waste to ignite or react.
Facilities where ignitable or reactive waste is stored or treated in a
tank should comply with requirements for the maintenance of
protective distances between the waste management area and any
public ways, streets, alleys, or an adjoining property line that can be
built upon as provided in Tables 2-1 through 2-6 of the 1990
National Fire Protection Association (NFPA) Flammable and
Combustible Liquids Code.
RMA ARARS 1/96
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Tabie A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 11 of 14
Action
Citation
Requirements
40CFR264.199
6 CCR 1007-3 Sect 264.199
40CFR264.17
6 CCR 1007-3 Sect 264.17
40 CFR 265.20 l(d)
6 CCR 1007-3 Sect 265.20 l(d)
40 CFR 265.20 l(e)(l)
6 CCR 1007-3 Sect 265.201(e)(l)
40CFR265.201(e)(2)
6 CCR 1007-3 Sect 265.20l(e)(2)
NFPA Flammable and Combustible
Liquids Code 1990 [TBC]
40 CFR 264.111(a) and (b)
6 CCR 1007-3 Sect 264.11 l(a),(b)
Incompatible wastes, or incompatible wastes and materials, must
not be placed in the same tank system unless 40 CFR 264.17 is
complied with.
Hazardous waste must not be placed in a tank system that has not
been decontaminated and that previously held an incompatible
waste or material unless 40 CFR 264.17 is complied with.
Generators that accumulate between 100 and 1,000 kg/mo of
hazardous waste in tanks must, upon closure, remove all hazardous
wastes from tanks, control equipment, and discharge confinement
structures.
Generators of between 100 and 1,000 kg/mo of hazardous waste
must not place ignitable or reactive waste in tanks unless the waste
is treated before or immediately after placement in a tank or the
waste is stored or treated in such a way that it is protected from any
material or condition that may cause the waste to ignite or react.
Ignitable or reactive waste must not be placed in the tank unless the
tank is used solely for emergencies.
Facilities where ignitable or reactive wastes are treated or stored in
covered tanks are required to comply with the buffer zone
requirements for tanks contained in Tables 2-1 through 2-6 of the
1990 NFPA Flammable and Combustible Liquids Code.
A facility must be closed in a manner that minimizes the need for
further maintenance and controls, minimizes, or eliminates to the
extent necessary to protect human health and the environment post
closure escape of hazardous wastes, hazardous constituents,
leachate, contaminated runoff, or hazardous waste decomposition
products to the groundwater or surface waters or to the atmosphere.
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 12 of 14
Action
Citation
Requirements
Wastewater Treatment/Disposal
40CFR264.197
6 CCR 1007-3 Sect 264.197
40CFR264SubpartG
6 CCR 1007-3 Part 264 Subpart G
The closure plan and closure activities for tank systems must meet
all of the substantive requirements provided in 40 CFR 264 Subpart
Gand40CFR264.197.
Discharge of wastewater to the treatment
plant
40 CFR Part 122
40 CFR Part 125
40 CFR Part 129
40 CFR Part 262
6 CCR 1007-3 Part 262
40 CFR Part 264
6 CCR 1007-3 Part 264
Any wastewater generated during cleanup or remedial actions will
be directed to the on-post RMA wastewater treatment plant and
treated in accordance with NPDES requirements.
Wastewater that is determined to be a hazardous waste must be
treated in accordance with the provisions of RCRA.
6 CCR 1007-3
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Decontamination and Disposal Standards AMC-R 385-131 [TBC]
for Chemical Agents
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with stormwater management requirements.
Army regulations provide standards for decontamination of items
exposed to chemical agents. Material, equipment, and clothing that
has been decontaminated to the 3X level may be landfilled in a
RCRA-approved hazardous waste landfill.
Items may not be released from government control until they have
been decontaminated to the 5X level.
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures
Page 13 of 14
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
RMA ARARS 1/96
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Table A-36 Action-Specific ARARs and TBCs for Salvage of Structures Page 14 of 14
Action Citation Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
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Table A-37 Action-Specific ARARs and TBCs for Air Stripping
Action
Citation
Worker Protection
Health and safety protection
29 CFR Part 1910
29 CFR 1910.120 (b) to 0)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
RMA ARARS 1/96
Page 1 of 8
Requirements
29 CFR 19IO provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
20 CFR 1910.120 (b) through 0) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
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Table A-37 Action-Specific ARARs and TBCs for Air Stripping
Page 2 of 8
Action
Citation
Requirements
Air Emissions
Volatile organic chemical emissions 5 CCR 1001-9, Regulation 7
PM|o/CO Emissions
Emission of hazardous air pollutants
Odor emissions
42 USC Section 7502-7503
5 CCR 1001-5, Regulation 3
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-4, Regulation 2
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Emission of certain hazardous air pollutants is controlled by
NESHAPs.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that measured in excess of the following limits:
RMA ARARS 1/96
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Table A-37 Action-Specific ARARs and TBCs for Air Stripping
Page 3 of 8
Action
Citation
Requirements
Air stripper emissions
Emission control for opacity
Visibility protection
OSWER Directive 9355.0-28
June 15,1989 [TBC]
5 CCR 1001-3, Regulation I, Section II
40 CFR 51.300-307
5 CCR 1001-14
CRS Section 42-4-307 (8)
Waste Characterization
Solid waste determination
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
"Control of Air Emissions from Superfund Air Strippers at
Superfund Groundwater Sites"
Air stripping of VOCs from groundwater shall not cause the
emission into the atmosphere of any air pollutant that is in excess of
20% opacity.
Air stripping from groundwater must be conducted in a manner that
does not cause adverse impacts on visibility. Visibility impairment
interferes with the management, protection, preservation, or
enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AFR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as applicable). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
RMA ARARS 1/96
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Table A-37 Action-Specific ARARs and TBCs for Air Stripping
Action
Citation
6CCR 1007-3 Sect 261.2
40CFR261.4
6CCR 1007-3 Sect 261.4
Determination of hazardous waste
40CFR262.II
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
Solid waste classification
6 CCR 1007-2, Section I
RMA ARARS 1/96
Page 4 of 8
Requirements
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled materials which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-1 ike material is material that is considered inherently
wastelike
Air stripping of VOCs from groundwater will create wastes
consisting of sludges and spent filters. These and all other wastes
generated in this process must be evaluated according to the
following method to determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories,
which include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
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Table A-37 Action-Specific ARARs and TBCs for Air Stripping
Action
Citation
RMA ARARS I/9A
Page 5 of 8
Requirements
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community, and
commercial wastes, and inert material are expected from air
stripping treatment of groundwater at RMA.
No special testing requirements are specified for solid wastes. The
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
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Table A-37 Action-Specific ARARs and TBCs for Air Stripping
Page 6 of 8
Action
Citation
Requirements
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6CCR 1007-3 Part 264
40 CFR Part 268
6CCR 1007-3 Part 268
6 CCR 1007-3
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Wastes from air stripping treatment of groundwater that are
determined to be RCRA hazardous wastes must be treated, stored,
and disposed in compliance with RCRA regulations, including
LDRs if placement occurs, and tank requirements in 40 CFR 264
Subpart J.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs and minimum technology requirements
for remediation wastes managed at CAMUs. These regulations
provide flexibility and allow for expedition of remedial decisions in
the management of remediation wastes. One or more CAMUs may
be designated at a facility. Placement of hazardous remediation
wastes into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
RMA ARARS 1/96
-------
Table A-37 Action-Specific ARARs and TBCs for Air Stripping
Page 7 of 8
Action
Citation
Requirements
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Reinjection of treated groundwater
RCRA Section 3020 (b)
OSWER Directive 9234.1-06 [TBC]
40 CFR 124, 144, 146, I47(Subpart G),
and 148
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
Reinjection of treated groundwater must be managed in accordance
with the guidelines in OSWER Directive 9234.1-06. Wells must be
constructed and installed and managed according to the substantive
requirements of 40 CFR 124, 144, 146, !47(SubpartG), and 148.
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
RMA ARARS 1/96
-------
Table A-37 Action-Specific ARARs and TBCs for Air Stripping
Action
Citation
RMA ARARS 1/96
Page 8 of 8
Requirements
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
-------
Table A-38 Action-Specific ARARs and TBCs for GAC Adsorption
Page 1 of 7
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPart I910
29CFR1910.l20(b)toO)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH1990[TBC]
29CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
20 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and the N1OSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
RMA ARARS 1/96
-------
Table A-38 Action-Specific ARARs and TBCs for GAG Adsorption
Page 2 of 7
Action
Citation
Requirements
Air Emissions
Volatile organic chemical emissions 5 CCR 1001-9, Regulation 7
Emissions
Emission of hazardous air pollutants
Odor emissions
42 USC Section 7502-7503
5 CCR 1001-5, Regulation 3
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-4, Regulation 2
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Estimated emissions from the proposed remedial activity per
Colorado A PEN requirements.
Emission of certain hazardous air pollutants is controlled by
NESHAPs.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that measured in excess of the following limits:
I) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air-
has been diluted with 15 more volumes of odor-free air
RMA ARARS 1/96
-------
Table A-38 Action-Specific ARARs and TBCs for GAC Adsorption
Page 3 of 7
Action
Citation
Requirements
Waste Characterization
Solid waste determination
40 CFR 260
6CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.3!. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled materials which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Groundwater treatment at RMA using granular activated carbon
(GAC) adsorption will create wastes consisting of spent carbon and
carbon fines. These and all other wastes generated in this process
must be evaluated according to the following method to determine
whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
RMA ARARS 1/96
-------
Table A-38 Action-Specific ARARs and TBCs for GAG Adsorption
Page 4 of 7
Action
Citation
Requirements
Solid waste classification
6 CCR 1007-2, Section!
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
1) "Industrial wastes", which includes all solid wastes, resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids including those that the
Colorado Department of Health may identify by regulation.
RMA ARARS 1/96
-------
Table A-38 Action-Specific ARARs and TBCs for GAC Adsorption
Page 5 of 7
Action
Citation
Requirements
If present, only small quantities of industrial, community, and
commercial wastes and inert material are expected from GAC
treatment of groundwater at RMA.
No special testing requirements are specified for solid waste. The
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6CCR 1007-3 Part 264
40 CFR Part 268
6CCR 1007-3 Part 268
6 CCR 1007-3
Management of Remediation Wastes
Corrective action management units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Wastes from GAC water treatment that are determined to be RCRA
hazardous wastes must be treated, stored, and disposed in
compliance with RCRA regulations, including LDRs-UTS if
placement occurs, and tank requirements in 40 CFR 264 Subpart J.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs and minimum technology requirements
for remediation wastes managed at CAMUs. These regulations
provide flexibility and allow for expedition of remedial decisions in
the management of remediation wastes. One or more CAMUs may
be designated at a facility. Placement of hazardous remediation
wastes into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
RMA ARARS 1/96
-------
Table A-38 Action-Specific ARARs and TBCs for GAG Adsorption
Page 6 of 7
Action
Citation
Requirements
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Storm water Management
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Reinjection of treated groundwater
Noise abatement
RCRA Section 3020 (b)
OSWER Directive 9234.1 -06 fTBC]
40 CFR 124, 144, 146, 147 (Subpart G),
and 14S
Colorado Revised Statute, Section 25-12-
103
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
Reinjection of treated groundwater must be managed in accordance
with the guidelines in OSWER Directive 9234.1-06. Wells must be
constructed and installed and managed according to the substantive
requirements of 40 CFR 124, 144, 146,147 (Subpart G) and 148.
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
RMA ARARS 1/96
-------
Table A-38 Action-Specific ARARs and TBCs for GAC Adsorption
Page 7 of 7
Action
Citation
Requirements
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
-------
Table A-39 Action-Specific ARARs and TBCs for Chemical Oxidation
Page 1 of 7
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPart I9IO
29CFR !9lO.I20(b)to(j)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to the
handling of hazardous waste/materials at uncontrolled hazardous waste
sites.
20 CFR 1910.120 (b) through (j) provides guidelines for workers involved
in hazardous waste operations and emergency response actions on sites
regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site workers
•_ Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by OSHA,
ACGIH, and the NIOSH are outlined in Table A-46.
Chemical oxidation treatment of groundwater uses ozone and may use
hydrogen peroxide to oxidize organic contaminants. The worker
exposure standards for these compounds are given below.
RMA ARARS 1/96
-------
Table A-39 Action-Specific ARARs and TBCs for Chemical Oxidation
Page 2 of 7
Action
Citation
Requirements
Air Emissions
Volatile organic chemical emissions 5 CCR 1001-9, Regulation 7
PM)0/CO emissions
Emission of hazardous air pollutants
42 USC Section 7502-7503
5 CCR 1001-5, Regulation 3
5 CCR 1001-10, Regulation 8
40CFRPart61
Hydrogen peroxide
ACG1H-TWA
N1OSH-REL
OSHA-PEL
Ozone
ACGIH-Ceiling
NJOSH-Ceiling
OSHA-PEL
I ppm, 1.4 mg/m3
I ppm, 1,4 mg/m3
1 ppm, 1.4 mg/m3
= 0.1 ppm , 0.20 mg/m3
= 0.1 ppm, 0.20 mg/m3
= 0.1 ppm, 0.2 mg/m3
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not ARARs
or TBCs. ACGIH and NIOSH values are provided as guidelines.)
VOC regulations apply to ozone nonattainment areas. The air quality
control area for RMA is currently nonattainment for ozone. Storage
and transfer of VOCs and petroleum liquids are controlled by these
requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control technologies
are utilized.
New or modified major stationary sources in a nonattainment area are
required to comply with the lowest achievable emission rate. Estimated
emissions from the proposed remedial activities per Colorado APEN
requirements.
Emission of certain hazardous air pollutants is controlled by
NESHAPs.
RMA ARARS 1/96
-------
Table A-39 Action-Specific ARARs and TBCs for Chemical Oxidation
Page 3 of 7
Action
Citation
Requirements
Odor emissions
42 USCS Section 7412
5 CCR 1001-4, Regulation 2
Emission control for opacity
Visibility protection
5 CCR 1001-3, Regulation 1, Section
II
40 CFR 51.300-307
5 CCR 1001-14
CRS Section 42-4-307 (8)
National standards For site remediation sources that emit hazardous air
pollutants are scheduled for promulgation by the year 2000. Standards
will be developed for 189 listed hazardous air pollutants.
Colorado odor emission regulations require that no person shall allow
emission of odorous air contaminants that result in detectable odors that
are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-free
air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air.
Chemical oxidation of organic compounds from groundwater shall not
cause the emission into the atmosphere of any air pollutant that is in
excess of 20% opacity.
Chemical oxidation of organic compounds from a groundwater must be
conducted in a manner that does not cause adverse impacts on
visibility. Visibility impairment interferes with the management,
protection, preservation, or enjoyment of federal Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program area
is a standard visual range of 32 miles. The averaging time is 4 hours.
The standard applies during an 8-hour period from 8:00 a.m. to 4:00
p.m. each day (Mountain Standard Time or Mountain Daylight Time,
as applicable). The visibility standard applies only during hours when
the hourly average humidity is less than 70%.
RMA ARARS 1/96
-------
Table A-39 Action-Specific ARARs and TBCs for Chemical Oxidation
Page 4 of 7
Action
Citation
Requirements
Waste Characterization
Solid waste determination
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
Determination of hazardous waste
40 CFR 262.11
6 CCR 1007-3 Sect 262.4
40 CFR Part 261
6 CCR 1007-3 Part 261
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded material
includes abandoned, recycled, and waste-like materials. These
materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled materials which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
Chemical oxidation of organic compounds will create wastes consisting
primarily of sludges. This and all other wastes generated in this
process must be evaluated according to the following method to
determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under 40
CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste in
light of the materials or the process used
RMA ARARS 1/96
-------
Table A-39 Action-Specific ARARs and TBCs for Chemical Oxidation
Page 5 of 7
Action
Citation
Requirements
Solid waste classification
6 CCR 1007-2, Section 1
If a generator of wastes has determined that the wastes do not meet the
criteria for hazardous wastes, they are classified as solid wastes. The
Colorado solid waste rules contain five solid waste categories, which
include the following:
I) "Industrial wastes," which includes all solid wastes resulting from
the manufacture of products or goods by mechanical or chemical
processes.
2) "Community wastes", which includes all solid wastes generated by
the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from streets,
sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated by
stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community and
industrial wastes.
4) "Special wastes," which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in water
and therefore nonputrescible, together with such minor amounts and
types of other materials that do not significantly affect the inert
nature of such solids. The term includes, but is not limited to, earth,
sand, gravel, rock, concrete that has been in a hardened state for at
least 60 days, masonry, asphalt-paving fragments, and other inert
solids, including those that the Colorado Department of Health may
identify by regulation.
If present, only small quantities of industrial, community, and
commercial wastes, and inert material are expected from chemical
oxidation treatment of groundwater at RMA.
RMA ARARS 1/96
-------
Table A-39 Action-Specific ARARs and TBCs for Chemical Oxidation
Page 6 of 7
Action
Citation
Requirements
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
6 CCR 1007-3
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264,553
40 CFR 264.553
No special testing requirements are specified for solid wastes. The
management and disposal rules are strictly oriented toward imposing
minimum engineering and technology requirements.
Wastes from chemical oxidation of organic compounds in groundwater
that are determined to be RCRA hazardous wastes must be treated,
stored, and disposed in compliance with RCRA regulations, including
LDRs if placement occurs, and tank requirements in 40 CFR 264
Subpart J.
Some of the Colorado standards for owners and operators of hazardous
waste management, storage, and disposal facilities are more stringent
than the equivalent federal regulations. These standards are detailed on
Appendix A, Table A-12.
The CAMU regulations allow for exceptions from otherwise generally
applicable LDRs and minimum technology requirements for
remediation wastes managed at CAMUs. These regulations provide
flexibility and allow for expedition of remedial decisions in the
management of remediation wastes. One or more CAMUs may be
designated at a facility. Placement of hazardous remediation wastes
into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for the
treatment/storage of remediation waste, and will be limited to one year
of operation with a one year extension upon approval by the regulatory
authority.
RMA ARARS 1/96
-------
Table A-39 Action-Specific ARARs and TBCs for Chemical Oxidation
Page 7 of 7
Action
Citation
Requirements
Stormwater Management
Discharge of stormwater to on-post surface
waters
Reinjection of treated groundwater
40 CFR Parts 122-125
RCRA Section 3020 (b)
OSWER Directive 9234.1-06 (TBC]
40 CFR 124, 144,146, 147 (Subpart
G), and 148
Stormwater runoff, snow melt runoff, and surface runoff and drainage
associated with industrial activity (as defined in 40 CFR 122) from
RMA remedial actions that disturb 5 acres or more and that discharge
to surface waters shall be conducted in compliance with the stormwater
management regulations.
Reinjection of treated groundwater must be managed in accordance
with the guidelines in OSWER Directive 9234.1-06. Wells must be
constructed and installed and managed according to the substantive
requirements of 40 CFR 124, 144, 146, 147 (Subpart G) and 148.
RMA ARARS 1/96
-------
Table A-40 Action-Specific ARARs and TBCs for GAA Adsorption
Page 1 of 6
Action
Citation
Requirements
Worker Protection
Health and safety protection
29 CFR Part 1910
29CFR 1910.120 (b) to (j)
Worker exposure
ACGFH 1991-1992 [TBC]
NIOSH 1990
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to the
handling of hazardous waste/materials at uncontrolled hazardous waste
sites. A key concern in granular activated alumina (GAA) adsorption
treatment of groundwater is the handling of corrosives (acids and caustics)
used in GAA treatment and regeneration.
20 CFR 1910.120 (b) through (j) provides guidelines for workers involved
in hazardous waste operations and emergency response actions on sites
regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
A key concern in GAA treatment is the handling of corrosives used
for pH adjustment in GAA treatment and regeneration. The
principal corrosives used in GAA process are sulfuric acid and
sodium hydroxide. In addition, calcium hydroxide may be used to
precipitate iron and hardness prior to treatment. The worker
exposure standards for these compounds are given below:
RMA ARARS 1/96
-------
Table A-40 Action-Specific ARARs and TBCs for GAA Adsorption
Page 2 of 6
Action
Citation
Requirements
Air Emissions
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
Sodium hydroxide
ACGIH-Ceiling = 2 mg/m3
NIOSH-Ceiling = 2 mg/m3 (15-min)
OSHA-Ceiling = 2 mg/m3 = 2 mg/m3
Sulfuric acid
ACGIH-TWA
NIOSH-REL
OSHA-PEL
Calcium hydroxide
ACGIH-TWA
OSHA-TWA
1 mg/m3; STEL = 3 mg/m3
I mg/m3
1 mg/m3
5 mg/m3
15 mg/m3 (total dust),
5 mg/m3 (resp)
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are provided as
guidelines.)
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment for ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
RMA ARARS 1/96
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Table A-40 Action-Specific ARARs and TBCs for GAA Adsorption
Page 3 of 6
Action
Citation
Requirements
PMIO/CO Emissions
Emission of hazardous air pollutants
Odor emissions
Waste Characterization
Solid waste determination
42 USC Section 7502-7503
5 CCR 1001-5, Regulation 3
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-4, Regulation 2
40CFR260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Emission of certain hazardous air pollutants is controlled by
NESHAPs.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned or incinerated
RMA ARARS 1/96
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Table A-40 Action-Specific ARARs and TBCs for GAA Adsorption
Page 4 of 6
Action
Citation
Requirements
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
Solid waste classification
6 CCR 1007-2, Section 1
• Recycled materials which is
- used in a manner constituting disposal
- bumed for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
wastelike
GAA adsorption will create wastes consisting primarily of
regeneration sludge. This and all other wastes generated in this
process must be evaluated according to the following method to
determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories,
which include the following:
I) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
RMA ARARS 1/96
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Table A-40 Action-Specific ARARs and TBCs for GAA Adsorption
Page 5 of 6
Action
Citation
Requirements
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community, and
commercial wastes, and inert material are expected from GAA
treatment of groundwater at RMA.
No special testing requirements are specified for solid wastes. The
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Wastes from GAA adsorption that are determined to be RCRA
hazardous wastes must be treated, stored, and disposed in
compliance with RCRA regulations, including LDRs-UTS if
placement occurs, and tank requirements in 40 CFR 264 Subpart J,
RMA ARARS T/96
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Table A-40 Action-Specific ARARs and TBCs for GAA Adsorption
Page 6 of 6
Action
Citation
Requirements
6CCR 1007-3
Management of Remediation Wastes
Corrective Action Management Units
40CFR264,SubpartS
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
Reinjection of treated groundwater
RCRA Section 3020 (b)
OSWER Directive 9234.1-06 [TBC]
40 CFR 124, 144, 146, 147 (Subpart G),
and 148
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs and minimum technology requirements
for remediation wastes managed at CAMUs. These regulations
provide flexibility and allow for expedition of remedial decisions in
the management of remediation wastes. One or more CAMUs may
be designated at a facility. Placement of hazardous remediation
wastes into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
Reinjection of treated groundwater must be managed in accordance
with the guidelines in OSWER Directive 9234.1-06. Wells must be
constructed and installed and managed according to the substantive
requirements of 40 CFR 124, 144, 146, 147 (Subpart G) and 148.
RMA ARARS l/%
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Table A-41 Action-Specific ARARs and TBCs for On-Post Transportation of Wastes
Page 1 of 3
Action
Citation
Requirements
Transportation of Hazardous Waste
On-post transportation
5 CCR I001-I5, Regulation 12
5 CCR 1001-4, Regulation 2
5 CCR 1001-3, Regulation 1
Section III (D) (2)
5 CCR 1001-5, Regulation 3
AH on-post shipments of hazardous waste may be required to meet
the provisions of 5 CCR 1001,40 CFR Parts 52 and 81, and AR 50-6
including, but not limited to the following:
1) Transportation of wastes in diesel-powered vehicles may be
subject to state opacity and visibility standards.
2) Loading, unloading, or transportation of wastes may cause odors
or emissions from contaminants that exceed state odor
limitations.
3) Transportation on unpaved roadways may be subject to state
requirements to reduce particulate emissions resulting from the
use of the roadway.
Air Emissions
Emission of hazardous pollutants
AR 50-6 Chapter 4 [TBCJ
5 CCR 1001-10, Regulation 8
5) This regulation describes procedures to be followed during the
transportation of Chemical Surety Materials.
Emission of listed hazardous air pollutants is controlled by
NESHAPs. On-Post transportation will cause volatilization of some
contaminants.
RMA ARARS 1/96
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Table A-41 Action-Specific ARARs and TBCs for On-Post Transportation of Wastes
Page 2 of 3
Action
Citation
Requirements
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
PMIO/CO Emissions
42 USC Section 7502-7503
5 CCR 1001-5, Regulation 3
Waste Management
Asbestos waste storage management
6 CCR 1007-2, Part B, Section 5.4
Asbestos waste handling management 40 CFR 61, Subpart M
5 CCR 1001-10, Regulation Part B,
Section 8.B.IH.C.8
New or modified major stationary sources in nonattainment area are
required to comply with the lowest achievable emission rate.
Estimated emissions from proposed remedial activity per Colorado
APEN requirements. A fugitive dust control measure will be
written into the work plan in consultation with the state for the
remedial activity.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos storage.
Prevent discharge of visible emissions during collection, processing,
packaging, or transporting any asbestos-containing wastes; deposit
asbestos-containing waste as possible at disposal site; mark
transport vehicle appropriately during loading and unloading
operations.
Asbestos waste will be managed according to applicable substantive
requirements for asbestos handling, transportation, and storage.
RMA ARARS 1/96
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Table A-41 Action-Specific ARARs and TBCs for On-Post Transportation of Wastes
Page 3 of 3
Action
Citation
Requirements
PCB storage
40CFR761.65
PCB incineration standards
40CFR761.70
PCB chemical waste landfilling standards 40 CFR 761.75
PCB decontamination standards
40 CFR 761.79
Storage Facilities must be constructed with adequate roofs, walls;
have impervious floors with curbs (no floor drains expansion joints
or other openings); be located above 100 year floodplain (applies to
PCBs at concentrations of 50 ppm or greater)
Temporary storage (<30 days) of PCB containers containing non-
liquid PCBs, such as contaminated soil, rags, debris need not
comply with above requirements.
Containers must be dated when they are placed in storage.
All storage areas must be properly marked and stored articles must
be checked for leaks every 30 days.
Incineration requirements for non-liquid PCB apply to PCB
concentrations >50 ppm and include specified dwell times;
combustion efficiency of 99.9999%; process record/monitoring
requirements; automatic shut-off standards; a maximum mass air
emission of 0.001 g PCB per kg of PCB entering the incinerator.
Landfill must be located in thick, relatively impermeable soil
formation or on soil with high clay and silt content, synthetic
membranes must be used when these conditions cannot be met. In
addition, other structural requirements include avoidance of
location in a floodplain; required run-on/run-off structures if below
the 100 year floodplain, and ground/surface water monitoring for
specified parameters.
The landfill must include a leachate monitoring system.
PCB wastes must be segregated from wastes not chemically
compatible with PCBs.
PCB containers to be decontaminated by triple rinsing of internal
surfaces with solvent containing <50 ppm PCB.
RMA ARARS 1/96
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Table A-42 Action-Specific ARARs and TBCs for Institutional Controls
Page 1 of 2
Action
Citation
Requirements
Access Restrictions
Access controls
40CFR264.14
6 CCR 1007-3 Sect 264.14
Land Use/Deed Restrictions
Land use and deed restrictions for former
hazardous waste disposal units
40 CFR 264.119
6 CCR 1007-3 Sect 264.119
Monitoring
Groundwater monitoring
40 CFR 264 Subpart F
6 CCR 1007-3 Part 264 Subpart F
2 CCR 402-2, Rule 10RCRA
Groundwater Monitoring
TEGD [TBC]
6 CCR 1007-3
Access controls will be provided that will prevent unknowing entry
and minimize unauthorized entry of persons or livestock onto active
portions of RMA. These may include 24-hour surveillance or a
barrier (either natural or artificial) and a means of controlling
access.
If RMA ceases to be federal government property, a notation on the
deed must indicate that nt eland was previously used to manage
hazardous wastes and its use is restricted under 40 CFR 264 Subpart
G regulations. A record of the type, location, and quantity of
hazardous waste managed at each disposal unit must also be
supplied to the local zoning authority or through authority over
local land use.
Groundwater monitoring will be conducted for the presence of
hazardous constituents in the groundwater downgradient from solid
water management units. Monitoring wells should be constructed
and installed according to the requirements of 2 CCR 402-2, Rule
10 and the guidance in the RCRA Groundwater Monitoring
Technical Enforcement Guidance Document (TEGD).
Colorado groundwater regulations specify requirements for
determining background groundwater quality.
RMA ARARS 1/96
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Table A-42 Action-Specific ARARs and TBCs for Institutional Controls
Page 2 of 2
Action
Citation
Requirements
Air Emissions
Emission of participates
5 CCR 1001-3, Regulation I, Sect IH(D)
5 CCR 1001-5, Regulation 3
Odor emissions
5 CCR 1001-4, Regulation 2
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. A fugitive dust control program will be
written into the work plan in consultation with the state for this
remedial activity.
Estimated emission from the proposed remedial activity per
Colorado APEN Requirements.
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-free
air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
RMA ARARS 1/96
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Table A-43 Action-Specific ARARs and TBCs for Continued Existing Actions
Page 1 of 1
Action
Citation
Requirements
Monitoring
Groundwater monitoring
Air Emissions
Odor emissions
Emissions of hazardous air pollutants
Volatile organic chemical emissions
APEN
40 CFR 264 Subpart F
6 CCR 1007-3 Part 264 Subpart F
2 CCR 402-2, Rule 10
RCRA Groundwater Monitoring TEGD
[TBC]
6 CCR 1007-3
5 CCR 1001-4, Regulation 2
5 CCR 1001-10, Regulation 8
5 CCR 1001-9, Regulation 7
5 CCR 1001-5, Regulation 3
Groundwater monitoring will be conducted for the presence of
hazardous constituents in the groundwater downgradient from solid
waste management units. Monitoring wells should be constructed and
installed according to the requirements of 2 CCR 402-2, Rule 10 and
the guidance in the RCRA Groundwater Monitoring TEGD.
Colorado groundwater regulations specify requirements for
determining background groundwater quality.
Colorado odor emission regulations require that no person shall allow
emission of odorous air contaminants that result in detectable odors
that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-free air
2) For all other land use ares—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Emission of listed hazardous air pollutants is controlled by NESHAPs.
Soil flushing will cause volatization of some contaminants.
VOC regulations apply to ozone nonattainment areas. The air quality
control area for RMA is currently nonattainment of ozone. Storage
and transfer of VOCs and petroleum liquids are controlled by these
requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
Estimated emissions from the proposed remedial activity per Colorado
APEN requirements
RMA ARARS 1/96
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Table A-44 Action-Specific ARARs and TBCs for Caustic Washing
Page 1 of 8
Action
Citation
Requirements
Worker Protection
Health and safety protection
29CFRPartl9lO
29CFR1910.l20(b)toG)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSHI990[TBC]
29 CFR 1910.1000
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) through (j) provides guidelines for workers
involved in hazardous waste operations and emergency response
actions on sites regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
In addition to the chemicals listed in Table A-46,
peroxide/hypochlorite treatment involves the use of hydrogen
peroxide and sodium hypochlorite. Hypochlorite the treatment is
neutralized using hydrochloric acid. Worker exposure standards for
these chemicals are:
RMA ARARS 1/96
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Table A-44 Action-Specific ARARs and TBCs for Caustic Washing
Page 2 of 8
Action
Citation
Requirements
Air Emissions
Emission of hazardous air pollutants
Volatile organic chemical emissions
5 CCR 1001-10, Regulation 8
40CFRPart61
42 USCS Section 7412
5 CCR 1001-9, Regulation 7
Hydrogen peroxide
ACGIH-TWA
NIOSH-REL
OSHA-PEL
Sodium hypochlorite
ACGIH-TWA
NIOSH-REL
OSHA-PEL
STEL
= 1 ppm, 1.4 mg/m^
= 1 ppm, 1.4 mg/m->
= I ppm 1.4—'-1
0.1 ppm (ceiling), 0.20 mg/m^ (ceiling)
O.I ppm (ceiling), 0.20 mg/m' (ceiling)
0.1 ppm, 0.2 mg/m-'
0.3 ppm, 0.6 mg/m-*
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGHI and NIOSH values are provided as
guidelines.)
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Soil flushing will cause volatization of some
contaminants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
RMA ARARS 1/96
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Table A-44 Action-Specific ARARs and TBCs for Caustic Washing
Page 3 of 8
Action
Citation
Requirements
PMIO/CO Emissions
Odor emissions
42 USC Section 7502-7503
5 CCR 1001-5, Regulation 3
5 CCR 1001-4, Regulation 2
Waste Characterization
Solid waste determination
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
• New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Estimated emissions from proposed remedial activities per Colorado
APEN requirements.
Colorado Odor Emission Regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
• Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
• Recycled materials which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
• Waste-like material is material that is considered inherently
waste! ike
RMA ARARS 1/96
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Table A-44 Action-Specific ARARs and TBCs for Caustic Washing
Page 4 of 8
Action
Citation
Requirements
Determination of hazardous waste
40CFR262.il
6 CCR 1007-3 Sect 262. II
40 CFR Part 261
6 CCR 1007-3 Part 261
Solid waste classification
6 CCR 1007-2, Section I
Wastes generated during soil excavation activities must be
characterized. Solid wastes must be evaluated according to the
following method to determine whether the waste is hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR 261
• Determine whether the waste is identified in 40 CFR 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain five solid waste categories.
The waste categories include the following:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
RMA ARARS 1/96
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Table A-44 Action-Specific ARARs and TBCs for Caustic Washing
Page S of 8
Action
Citation
Requirements
Waste Management
Treatment, storage, or disposal of RCRA
hazardous waste
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
6 CCR. 1007-3
Treatment, storage, or disposal of RCRA 40 CFR 264, Subpart I, Subpart J
hazardous wastes in containers 6 CCR 1007-3, Part 264 Subpart I,
Subpart J
Treatment and disposal of hazardous debris 40 CFR 268.45
6 CCR 1007-3, Part 268.45
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community,
commercial, and special wastes are expected from
peroxide/hypochlorite treatment of debris at RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
If peroxide/hypochlorite treatment at RMA generates hazardous
wastes, the wastes must be treated, stored, or disposed in accordance
with RCRA regulations, including LDRs.
Some of the Colorado standards for owners and operators of
hazardous waste management, storage and disposal facilities are
more stringent than the equivalent federal regulations. These
standards are detailed on Appendix A, Table A-12.
Applicability of the substantive requirements for containers and
tanks.
Hazardous debris treated with peroxide or hypochlorite must be
treated to extract, destroy, or immobilize hazardous constituents on
or in the debris. In certain cases after treatment, the debris may no
longer be subject to RCRA Subtitle C regulation.
RMA ARARS 1/96
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Table A-44 Action-Specific ARARs and TBCs for Caustic Washing
Page 6 of 8
Action
Citation
Requirements
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
StormwaterManagement
Discharge of Stormwater to on-post surface 40 CFR Parts 122-125
waters
Wastewater Treatment/Disposal
Discharge of wastewater to the treatment
plant
40 CFR 262
6 CCR 1007-3 Part 262
40 CFR 264
6 CCR 1007-3 Part 264
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs and minimum technology requirements
for remediation wastes managed at CAMUs. These regulations
provide flexibility and allow for expedition of remedial decisions in
the management of remediation wastes. One or more CAMUs may
be designated at a facility. Placement of hazardous remediation
wastes into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the Stormwater management regulations.
Wastewater that is determined to be a hazardous waste must be
treated in accordance with the provisions of RCRA.
RMA ARARS 1/96
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Table A-44 Action-Specific ARARs and TBCs for Caustic Washing
Page 7 of 8
Action
Citation
Requirements
Noise abatement
Colorado Revised Statute, Section 25-12-
103
The Colorado Noise Abatement Statute provides that:
a. "Applicable activities shall be conducted in a manner so any
noise produced is not objectionable due to intermittence, beat
frequency, or shrillness. Noise is defined to be a public nuisance
if sound levels radiating from a property line at a distance of
twenty-five ft or more exceed the sound levels established for
the following time periods and zones:
7:00 a.m. to 7:00 p.m. to
Zone next 7:00 p.m. next 7:00 a.m.
Residential
Commercial
Light Industrial
Industrial
55 db(A)
60 db(A)
70 db(A)
80 db(A)
50 db(A)
55 db(A)
65 db(A)
75 db(A)
b. In the hours between 7:00 a.m. and the next 7:00 p.m., the noise
levels permitted in Requirement a (above) may be increased by
ten decibels for a period of not to exceed fifteen minutes in any
one-hour period.
c. Periodic, impulsive, or shrill noises shall be considered a public
nuisance when such noises are at a sound level of five decibels
less than those listed in Requirement a (above).
d. Construction projects shall be subject to the maximum
permissible noise levels specified for industrial zones for the
period within which construction is to be completed pursuant to
any applicable construction permit issued by proper authority or,
if no time limitation is imposed, for a reasonable period of time
for completion of the project.
e. For the purpose of this article, measurements with sound level
meters shall be made when the wind velocity at the time and
place of such measurement is not more than five miles per hour.
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Table A-44 Action-Specific ARARs and TBCs for Caustic Washing
Page 8 of 8
Action
Citation
Requirements
f. In all sound level measurements, consideration shall be given to
the effect of the ambient noise level created by the
encompassing noise of the environment from all sources at the
time and place of such sound level measurements."
RMA ARARS 1/96
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Table A-45 Action-Specific ARARs and TBCs for Soil Drying
Action
Citation
Worker Protection
Health and safety protection
29 CFR Part 1910
29CFR1910.I20(b)-(j)
Worker exposure
ACGIH 1991-1992 [TBC]
NIOSH 1990 [TBC]
29 CFR 1910.1000
RMA ARARS 1/96
Page 1 of 7
Requirements
29 CFR 1910 provides guidelines for workers engaged in activities
requiring protective health and safety measures regulated by OSHA.
Requirements provided in 29 CFR 1910.120 apply specifically to
the handling of hazardous waste/materials at uncontrolled hazardous
waste sites.
29 CFR 1910.120 (b) provides guidelines for workers involved in
hazardous waste operations and emergency response actions on sites
regulated under RCRA and CERCLA.
Specific provisions include the following:
• Health and safety program participation required by all on-site
workers
• Site characterization and analysis
• Site control
• On-site training
• Medical surveillance
• Engineering controls
• Work practices
• Personal protective equipment
• Emergency response plan
• Drum handling
• Sanitation
• Air monitoring
Chemical-specific worker exposure guidelines established by
OSHA, ACGIH, and NIOSH are outlined in Table A-46.
(OSHA regulations and other health and safety requirements are
actually independently applicable regulatory requirements, not
ARARs or TBCs. ACGIH and NIOSH values are presented as
guidelines.)
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Table A-45 Action-Specific ARARs and TBCs for Soil Drying
Page 2 of 7
Action
Citation
Requirements
Soil Dryer Unit Operation
Determination of operational readiness
Operation of Miscellaneous Unit
Waste Characterization
Solid waste determination
40CFR270.19
6 CCR 1007-3 Sect 270.19
40 CFR 270.62 (b)
6 CCR 1007-3 Sect 270.62(b)
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR 264 Subpart X
6 CCR 1007-3 Part 264 Subpart X
40 CFR 260
6 CCR 1007-3 Part 260
40 CFR 260.30-31
6 CCR 1007-3 Sect 260.30-31
40 CFR 261.2
6 CCR 1007-3 Sect 261.2
40 CFR 261.4
6 CCR 1007-3 Sect 261.4
Although permit applications are not necessary for RMA remedial
actions, the operational readiness information will be provided in
CERCLA documents leading to incineration alternatives.
The soil drying unit shall be operated to comply with the
substantive requirements of Part 264 including the miscellaneous
regulation in 40 CFR 264 Subpart (40 CFR 260.30, Part 264
Subpart X) environmental performance standards.
A solid waste is any discarded material that is not excluded by a
variance granted under 40 CFR 260.30 and 260.31. Discarded
material includes abandoned, recycled, and waste-like materials.
These materials may have any of the following qualities:
Abandoned material may be
- disposed of
- burned or incinerated
- accumulated, stored, or treated before or in lieu of being
abandoned by being disposed, burned, or incinerated
Recycled material which is
- used in a manner constituting disposal
- burned for energy recovery
- reclaimed
- speculatively accumulated
Waste-like material is material that is considered inherently
wastelike
RMA ARARS l/%
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Table A-45 Action-Specific ARARs and TBCs for Soil Drying
Page 3 of 7
Action
Citation
Requirements
Determination of hazardous waste
40CFR262.il
6CCR 1007-3 Sect 262.11
40 CFR Part 261
6 CCR 1007-3 Part 261
Solid waste classification
6 CCR 1007-2, Part 1, Section 1
Soil-generated waste must be characterized and evaluated according
to the following methods to determine whether the waste is
hazardous:
• Determine whether the waste is excluded from regulation under
40 CFR 261.4
• Determine whether the waste is listed under 40 CFR Part 261
• Determine whether the waste is identified in 40 CFR Part 261 by
testing the waste according to specified test methods and by
applying knowledge of the hazardous characteristics of the waste
in light of the materials or the process used
If a generator of wastes has determined that the wastes do not meet
the criteria for hazardous wastes, they are classified as solid wastes.
The Colorado solid waste rules contain the following five solid
waste categories:
1) "Industrial wastes", which includes all solid wastes resulting
from the manufacture of products or goods by mechanical or
chemical processes.
2) "Community wastes", which includes all solid wastes generated
by the noncommercial and nonindustrial activities of private
individuals of the community including solid wastes from
streets, sidewalks, and alleys.
3) "Commercial wastes", which includes all solid wastes generated
by stores, hotels, markets, offices, restaurants, and other
nonmanufacturing activities, with the exclusion of community
and industrial wastes.
4) "Special wastes", which includes any solid waste that requires
special handling or disposal procedures. Special wastes may
include, but are not limited to, asbestos, bulk tires, or other bulk
materials, sludges, and biomedical wastes.
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Page 4 of 7
Requirements
5) "Inert material", which includes solids that are not soluble in
water and therefore nonputrescible, together with such minor
amounts and types of other materials that do not significantly
• affect the inert nature of such solids. The term includes, but is
not limited to, earth, sand, gravel, rock, concrete that has been in
a hardened state for at least 60 days, masonry, asphalt-paving
fragments, and other inert solids, including those that the
Colorado Department of Health may identify by regulation.
If present, only small quantities of industrial, community,
commercial, and special wastes are expected from thermal
desorption of soils at RMA.
No special testing requirements are specified for solid wastes; the
management and disposal rules are strictly oriented toward
imposing minimum engineering and technology requirements.
Wastes that are determined to be RCRA hazardous wastes must be
stored and treated, in compliance with RCRA regulations.
Based upon a determination of whether the disposal technique
constitutes placement, LDRs-UTS may be applicable. If placement
does occur, the disposal facility must comply with the substantive
requirements of 40 CFR Part 264 (6 CCR 1007-3 Part 264) and 40
CFR Part 268 (6 CCR 1007-3 Part 268).
Some of the Colorado standards for owners and operators of
hazardous waste management, storage, and disposal facilities are
more stringent than the equivalent federal regulations.
These standards are detailed on Appendix A, Table A-12.
Table A-4S Action-Specific ARARs and TBCs for Soil Drying
Action
Citation
Waste Management
Treatment, storage, or disposal of
hazardous wastes
On-post land disposal of hazardous wastes
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 264
6 CCR 1007-3 Part 264
40 CFR Part 268
6 CCR 1007-3 Part 268
EPA/540/G-89/005 [TBC]
6 CCR 1007-3
RMA ARARS 1/96
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Table A-45 Action-Specific ARARs and TBCs for Soil Drying
Page S of 7
Action
Citation
Requirements
Management of Remediation Wastes
Corrective Action Management Units
40 CFR 264, Subpart S
6 CCR 1007-3, Part 264 Subpart S
Temporary Units
6 CCR 1007-3 Sect 264.553
40 CFR 264.553
Air Emissions
Emission of Particulates
5 CCR 1001-3, Regulation 1,
Section III(D)
5 CCR 1001-5, Regulation 3
Emission control for opacity
5 CCR 1001-3, Regulation 1, Section II
The CAMU regulations allow for exceptions from otherwise
generally applicable LDRs and minimum technology requirements
for remediation wastes managed at CAMUs. These regulations
provide flexibility and allow for expedition of remedial decisions in
the management of remediation wastes. One or more CAMUs may
be designated at a facility. Placement of hazardous remediation
wastes into or within the CAMU does not constitute land disposal of
hazardous wastes so the LDRs are not triggered.
Design, operating, or closure standards for temporary tanks and
container storage areas may be replaced by alternative requirements.
The TU must be located within the facility boundary, used only for
the treatment/storage of remediation waste, and will be limited to
one year of operation with a one year extension upon approval by
the regulatory authority.
Colorado air pollution regulations require owners or operators of
sources that emit fugitive particulates to minimize emissions
through use of all available practical methods to reduce, prevent,
and control emissions. In addition no off-site transport of
particulate matter is allowed. A fugitive dust control measure will
be written in the work plan in consultation with the state for the
remedial activity.
Estimated emissions from the proposed remedial activity per
Colorado APEN requirements.
Soil drying of soils shall not cause the emission into the atmosphere
of any air pollutant that is in excess of 20% opacity.
RMA ARARS 1/96
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Page 6 of 7
Requirements
Emission of listed hazardous air pollutants is controlled by
NESHAPs. Soil drying will cause volatization of some
contaminants.
National standards for site remediation sources that emit hazardous
air pollutants are scheduled for promulgation by the year 2000.
Standards will be developed for 189 listed hazardous air pollutants.
VOC regulations apply to ozone nonattainment areas. The air
quality control area for RMA is currently nonattainment of ozone.
Storage and transfer of VOCs and petroleum liquids are controlled
by these requirements.
New or modified major stationary sources in a nonattainment area
are required to comply with the lowest achievable emission rate.
Disposal of VOCs is regulated for all areas, including ozone
nonattainment. The regulations control the disposal of VOCs by
evaporation or spilling unless reasonable available control
technologies are utilized.
Soil drying must be conducted in a manner that does not cause
adverse impacts on visibility. Visibility impairment interferes with
the management, protection, preservation, or enjoyment of federal
Class I areas.
The Colorado Ambient Air Quality Standard for the AIR Program
area is a standard visual range of 32 miles. The averaging time is 4
hours. The standard applies during an 8-hour period from 8:00 a.m.
to 4:00 p.m. each day (Mountain Standard Time or Mountain
Daylight Time, as appropriate). The visibility standard applies only
during hours when the hourly average humidity is less than 70%.
Table A-4S Action-Specific ARARs and TBCs for Soil Drying
Action
Citation
Emission of hazardous air pollutants 5 CCR 1001 -10, Regulation 8
40CFRPart6l
42 USCS Section 7412
Volatile organic chemical emissions
5 CCR 1001-9, Regulation 7
42 USC Section 7502-7503
Visibility protection
40 CFR 51.300-307
40 CFR 52.26-29
5 CCR 1001-14
CRS Section 42-4-307(8)
RMA ARARS 1/96
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Page 7 of 7
Requirements
Colorado odor emission regulations require that no person shall
allow emission of odorous air contaminants that result in detectable
odors that are measured in excess of the following limits:
1) For residential and commercial areas—odors detected after the
odorous air has been diluted with seven more volumes of odor-
free air
2) For all other land use areas—odors detected after the odorous air
has been diluted with 15 more volumes of odor-free air
Stormwater runoff, snow melt runoff, and surface runoff and
drainage associated with industrial activity (as defined in 40 CFR
122) from RMA remedial actions that disturb 5 acres or more and
that discharge to surface waters shall be conducted in compliance
with the stormwater management regulations.
Table A-45 Action-Specific ARARs and TBCs for Soil Drying
Action
Citation
Odor emissions
5 CCR 1001-4, Regulation 2
Stormwater Management
Discharge of stormwater to on-post surface 40 CFR Parts 122-125
waters
RMA ARARS 1/96
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Table A-46 Worker Air Exposure Standards for Chemicals Potentially Associated with Groundwater, Soil, or Structures
Page 1 of 7
Chemical Name
Exposure Standards
Aldrin
Arsenic (organic)
Asbestos
Atrazine
Benzene
Cadmium
Caprolactam (vapor)
Carbon Tetrachloride
Chlordane
ACGIH-TWA= 0.25 mg/m3 (skin)
NIOSH-REL=0.25 mg/m3 (skin)
OSHA-PEL=0.25 mg/m3 (8 hr TWA) (skin)
ACGIH-TWA=0.1 mg/m3
OSHA-PEL=10.0 :g/m3 (8 hrTWA)
ACGIH-TLV Amosite=0.5 fibers/cm3
Chrysolite=2 fibers/cm3
Crosidolite-0.2 fibers/cm3
Other Forms=2 fibers/cm3
NIOSH-REL=0.1 fibers/cm3
OSHA-REL=0.2 fibers/cnt3 (8 hr TWA)
OSHA action leveHU fibers/cm3
ACGIH-TWA=5 mg/m3
ACGIH-TWA=0.1 ppm, 0.3 mg/m3 skin, Suspected human carcinogen
NIOSH-REL=0.1 ppm, STEL=1 ppm (15 min)
OSHA-PEL=1.0 ppm (8 hr TWA), STEL=5.0 ppm (15 min ceiling).
ACGIH-TWA*=0.01 mg/m3 (total), 0.002 mg/m3 (resp), Suspected human carcinogen
NIOSH-REL-Reduce exposure to lowest feasible concentration
OSHA-PEL rume=0.1 mg/m3 (8 hr TWA), 0.3 mg/m3 (ceiling)
OSHA-PEL dust=0.2 mg/m3 (8 hr TWA), 0.6 mg/m3 (ceiling)
ACGIH-TWA*=5 ppm, 23 mg/m3; STEL=10 ppm, 46 mg/m3
ACGIH-TWA=5 ppm, 31 mg/m3 (skin); STEL=10 ppm, 63 mg/m3, Suspected human carcinogen
NIOSH-STEL=2 ppm (60 min), 12.6 mg/m3
OSHA-PEL=10 ppm, 8 hr TWA; 25 ppm (ceiling);
200 ppm (peak concentration, max duration 5 min/in any 4 hrs.)
ACGIH-TWA=0.5 mg/m3 (skin)
NIOSH-REL=0.5 mg/m3 (skin)
OSHA-PEL=0.5 mg/m3 (8 hr TWA) (skin)
RMA ARARS 1/96
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Table A-46 Worker Air Exposure Standards for Chemicals Potentially Associated with Groundwater, Soil, or Structures
Page 2 of 7
Chemical Name
Exposure Standards
Chlorobenzene
Chloroform
Chromium (Cr-metal; compounds)
Copper
Cyanides (as CM)
Dibutyl Phthalate
1,2-Dibromo-3-chloropropane (DBCP)
1,1-Dichloroethane
ACGIH-TWA=10 ppm, 46 mg/m3
OSHA-PEL=75 ppm, 350 mg/m3, (8 hr TWA)
ACGIH-TWA=10 ppm, 49 mg/m3, Suspected human carcinogen
NIOSH-STEL=2 ppm, 9.78 mg/m3 (60 min)
OSHA-Ceiling=50 ppm, 240 mg/m3
ACGIH-TWA=0.5 mg/m3 [metal, Cr(H) and Cr (III) compounds]
0.01 mg/m3 [CrVI compounds] Insoluble, NOC 0.05 mg/m3 [Cr(VI) compounds],
Human carcinogen for water-insoluble compounds
NIOSH-REL= 1 :g/m3 (10 hr TWA) [carcinogenic Cr(VI) compounds];
0.5 mg/m3 [metal, Cr(II) and Cr(III) compounds]
OSHA-PEL= 1 mg/m3 (8 hr TWA) [metal and insoluble salts];
0.5 mg/m3 (8 hr TWA) [soluble salts];
ACGIH-TWA fume=0.2 mg/m3
ACGIH-TWA dust =1 mg/m3
NIOSH-REL fiime 0.1 mg/m3 (10 hr TWA)
NiOSH-REL dust=l mg/m3 (10 hr TWA)
OSHA-PEL fiime=0.1 mg/m3 (8 hr TWA)
OSHA-PEL dust =1 mg/m3 (8 hr TWA)
ACGIH-Ceiling=5 mg/m3 (skin); TWA=4.7 mg/m3
NIOSH-Ceiling=4.7 ppm, 5 mg/m3 (10 min)
OSHA-PEL=5 mg/m3 (8 hr TWA)
ACGIH-TWA=5 mg/m3
NIOSH-REL=5 mg/m3 (10 hr TWA)
OSHA-PEL=5 mg/m3 (8 hr TWA)
OSHA-PEL=lppb (8 hr TWA)
ACGIH-TWA*= 100 ppm, 405 mg/m3
NIOSH-REL=100 ppm, 400 mg/m3
OSHA-PEL=100 ppm, 400 mg/m3 (8 hr TWA)
RMAARARSl/96
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Table A-46 Worker Air Exposure Standards for Chemicals Potentially Associated with Groundwater, Soil, or Structures
Page 3 of7
Chemical Name
Exposure Standards
1,2-Dichloroethane
1,1 -Dichloroethylene
1,2-Dichloroethylene (Trans)
Dichlorvos (Vapona) DDVP
DDT
Dicyclopentadiene
Dieldrin
Diethyl Phthalate
1,1 -Dimethylhydrazine
Endrin
ACGIH-TWA=10 ppm, 40 mg/m3
OSHA-PEL=50 ppm (8 hr TWA); 100 ppm (ceiling); 200 ppm (maximum concentration)
ACGIH-TWA=5 ppm, 20 mg/m3; STEL=20 ppm, 79 mg/m3
ACGIH-TWA=200 ppm, 793 mg/m3
NIOSH-REL=200 ppm, 740 mg/m3 (10 hr TWA)
OSHA-PEL=200 ppm, 790 mg/m3 (8 hr TWA)
ACGIH-TWA=0.1 ppm, 0.90 mg/m3 (skin)
NIOSH-REL=1 mg/m3 (10 hr TWA) (skin)
OSHA-PEL=1 mg/m3 (8 hr TWA) (skin)
ACGIH-TWA=1 mg/m3
NIOSH-REL=0.5 mg/m3
OSHA-PEL=1 mg/m3 (8 hr TWA) (skin)
ACGIH-TWA=5 ppm, 27 mg/m3
OSHA-TWA=5 ppm, 30 mg/m3 (8 hr TWA)
ACGIH-TWA=0.25 mg/m3 (skin)
NIOSH-REL=0.25 mg/m3
OSHA-PEL=0.25 mg/m3 (skin)
ACGIH-TWA=5 mg/m3
ACGIH-TWA=0.01 ppm, 0.025 mg/m3(skin)Suspected human carcinogen
NIOSH-Ceiling=0.06 ppm, 0.15 mg/m3 (120 min)
OSHA-PEL=0.5 ppm, 1 mg/m3
ACGIH-TWA=0.1 mg/m3 (skin)
NISOH-REL=0.1 mg/m3 (10 hr TWA) (skin)
OSHA-PEL=0.1 mg/m3 (8 hr TWA) (skin)
RMA ARARS 1/96
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Table A-46 Worker Air Exposure Standards for Chemicals Potentially Associated with Groundwater, Soil, or Structures Page 4 of 7
Chemical Name Exposure Standards
Ethyl Benzene
Fluoride (as F)
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hydrazine
4-Hydroxy-4-methyl-2-pentanone
Lead (dust & fumes)
Magnesium
(as Mg Oxide fumes )
Malathion
Mercury (as Hg)
(inorganic)
ACGIH-TWA=100 ppm, 434 mg/m3; STEL=125 ppm, 543 mg/m3
NISOH-REL=100 ppm, 435 mg/m3 (10 hr TWA); STEL-125 ppm, 545 mg/m3
OSHA-PEL=100 ppm, 435 mg/m3 (8 hr TWA)
ACGIH-TWA=2.5 mg/m3
NIOSH-REL=2.5 mg/m3 (10 hr TWA)
OSHA-PEL=2.5 mg/m3 (8 hr TWA)
ACGIH-TWA=0.02 ppm 0.21 mg/m3, Suspected human carcinogen
ACGIH-TWA=0.01 ppm, 0.11 mg/m3
OSHA PEL=0.01 ppm, 0.1 mg/m3
NIOSH-REL=0.01 ppm, 0.013mg/m3
ACGIH-TWA*=0.1 ppm, 0.13 mg/m3 (skin), Suspected human carcinogen
NIOSH-Ceiling=0.03 ppm, 0.04 mg/m3 (120 min ceiling)
OSHA-PEL=1 ppm, 1.3 mg/m3 (8-hr TWA)
ACGIH-TWA=50 ppm, 238 mg/m3
ACGIH-TWA=0.05 mg/m3
NIOSH-REL (inorganic) 0.1 mg /m3 (10 hr TWA);
OSHA-PEL=50 :g/m3
ACGIH-TWA=10 mg/m3
OSHA-PEL= 15 mg/m3 (8 hr TWA) (resp)
ACGIH-TWA=10mg/m3 (skin)
NIOSH-REL=10 mg/m3 (10 hr TWA)
OSHA-PEL=15 mg/m3 (8 hr TWA)
ACGIH- TWA vapor=0.025 mg/m3 (skin)
NIOSH-REL vapor=0.05 mg/m3 (10 hour TWA) (skin)
OSHA-Ceiling=0.1mg/m3 (skin)
RMAARARS 1/96
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Table A-46 Worker Air Exposure Standards for Chemicals Potentially Associated with Groundwater, Soli, or Structures Page 5 of 7
Chemical Name Exposure Standards
Methylene Chloride
Methylisobutyl Ketone
(Hexone)
Parathion
PCB (42% chlorine)
PCB (54% chlorine)
Pentachlorophenol
Phenol
1,1,2,2-Tetrachloroethane
ACGIH-TWA=50 ppm, 174 mg/m3, Suspected human carcinogen
NIOSH-REL=Reduce exposure to lowest feasible limit
OSHA-PEL=500 ppm (8 hr TWA); 1000 ppm (ceiling);
2000 ppm, (peak concentration, maximum duration 5 min/2 hr)
ACGIH-TWA=50 ppm, 205 mg/m3; STELX75 ppm, 307 mg/m3
NIOSH-REL=50 ppm, 205 mg/m3, (10 hr TWA); STEL=75 ppm, 300 mg/m3
OSHA-PEL=100 ppm, 410 mg/m3 (8 hr TWA)
ACGIH-TWA=0.1 mg/m3 (skin)
NIOSH-REL=0.05 mg/m3 (10 hr TWA) (skin)
OSHA-PEL=0.1 mg/m3 (8 hr TWA) (skin)
ACGIH=1.0 mg/m3 (skin)
NIOSH=0.001 mg/m3
OSHA=1 mg/m3 (skin)
ACGIH=0.5 mg/m3 (skin)
NIOSH=0.001 mg/m3
OSHA=0.5 mg/m3 (skin)
ACGIH-TWA=0.5 mg/m3 (skin)
NIOSH-REL=0.5 mg/m3 (10 hr TWA) (skin)
OSHA-PEL=0.5 mg/m3, (8 hr TWA) (skin)
ACGIH-TWA=5 ppm, 19 mg/m3 (skin)
NIOSH-REL=5 ppm, 19 mg/m3 (10 hr TWA); Ceiling=15.6 ppm, 60 mg/m3 (15 min) (skin)
OSHA-PEL=5 ppm, 19 mg/m3 (8 hr TWA) (skin)
ACGIH-TWA=1 ppm, 6.9 mg/m3 (skin)
NIOSH-REL=1 ppm, 7mg/m3 (10 hr TWA) (skin)
OSHA-PEL=5 ppm, 35 mg/m3 (8 hr TWA) (skin)
RMAARARS 1/96
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Table A-46 Worker Air Exposure Standards for Chemicals Potentially Associated with Groundwater, Soil, or Structures
Page 6 of 7
Chemical Name
Exposure Standards
Tetrachloroethylene
(Perchloroethylene)
Toluene
1,2,4-Trichlorobenzene
1,1,1 -Trichloroethane
(Methyl chloroform)
1,1,2-Trichloroethane
Trichloroethylene
Trimethyl Benzene
Xylene - o,m,p
Xylene - M ("," diamine)
Zinc (as zinc oxide)
ACGIH-TWA=25 ppm, 170 mg/m3; STEL= 100 ppm, 685 mg/m3
NIOSH-REL=Minimize workplace exposure concentrations; limit number of workers exposed
OSHA-PEL=100 ppm (8 hr TWA); 200 ppm (ceiling);
300 ppm (peak concentration, maximum duration 5 min/2 hrs)
ACGIH-TWA*=50ppm, 188mg/m3
NIOSH-REL=100 ppm, 375 mg/m3 (10 hr TWA); STEL=150 ppm, 560 mg/m3 (15 min)
OSHA-PEL=200 ppm (8 hr TWA);
300 ppm (ceiling); 500 ppm (peak concentration-for 10 minutes)
ACGIH-Ceiling=5 ppm, 37 mg/m3
ACGIH-TWA=350 ppm, 1910 mg/m3; STEL=450 ppm, 2460 mg/m3
NISOH-Ceiling-350 ppm, 1900 mg/m3 (15 min ceiling)
OSHA-PEIX350 ppm, 1900 mg/m3 (8 hr TWA)
ACGIH-TWA=10 ppm, 55 mg/m3 (skin)
OSHA-PEL=10 ppm, 45 mg/m3 (8 hr TWA) (skin)
ACGIH-TWA=50 ppm, 269 mg/m3; STEL=100 ppm, 537 mg/m3
NIOSH-REL=25 ppm (10 hr TWA)
OSHA-PEL=100 ppm (8 hr TWA); 200 (ceiling); 300 ppm (peak concentration, maximum duration 5 min/2
hrs)
ACGIH-TWA=25 ppm, 123 mg/m3
ACGIH-TWA=100 ppm, 434 mg/m3; STEL=150 ppm, 651 mg/m3
NIOSH-REL=100 ppm, 434 mg/m3 (10 hr TWA); STEL-150 ppm, 655 mg/m3 (15 min ceiling )
OSHA-PEL=100 ppm, 435 mg/m3
ACGIH-Ceiling=0.1 mg/m3 (skin)
ACGIH-TWA dust=10 mg/m3 - containing no asbestos and <1% crystalline silica
ACGIH-TWA fume=5 mg/m3; STEL=10 mg/m3
NIOSH-REL fume=5 mg/m3 (10 hr TWA), STEL=10 mg/m3 (15 min ceiling)
OSHA-PEL dust=15 mg/m3; 5 mg/m3 (resp)
OSHA-PEL fiime=5 mg/m3 (8 hr TWA)
RMA ARARS 1/96
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Table A-46 Worker Air Exposure Standards for Chemicals Potentially Associated with Groundwater, Soils, or Structures Page 7 of 7
Notes:
ACGIH American Conference of Governmental Industrial Hygienists
OSHA Occupational Safety and Health Administration
NIOSH National Institute for Occupational Safety and Health (NIOSH-TWA
is the time-weighted concentration for a 10-hour day and a 40-hour
work week)
STEL Short-Term Exposure Limit
TWA Time Weighted Average
PEL Permissible Exposure Limit
MAX Maximum Peak Above the Ceiling
REL Recommended Exposure Limit
resp respirable
hr hounds)
min minute(s)
ppm parts per million
mg/kg milligrams per kilogram
mg/m3 milligrams per cubic meter
u.g/m3 micrograms per cubic meter
proposed change
change is proposed, not quantified
all forms except alkyl vapor
RMA ARARS 1/96
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Table A-47 Worker Air Exposure Standards for Chemical Agent Constituents*
Page 1 of 7
Chemical Name
Acetic Acid
Acetylene
Acetylene chloride
[acetylene monochloride]
Acetylene Dichloride**
[ 1 ,2-dichloroethylene]
Adamsite (DM)
[10 chloro-5,10-dihydrophenarsazine]
Ammonia
Arsenic (Inorganic Compounds as As -
including arsenous oxide, arsenic
oxychloride, arsenic trichloride, arsenic
trioxide, sodium arsenite)
Bis(2-chlorovinyl)chloroarsine
Calcium Chloride
Calcium Sulfate
Exposure Standards
ACGIH-TWA = 10 ppm, 25 mg/m3
ACGIH-STEL = 15 ppm, 37 mg/m3
NIOSH-REL = 1 0 ppm, 25 mg/m3
NIOSH-STEL =15 ppm, 37 mg/m3
OSHA-PEL = 10 ppm, 25 mg/m3 (8 hr TWA)
ACGIH -TWA = simple asphyxiant
Animal toxicity data only3
ACGIH-TWA =200 ppm, 793 mg/m3
NIOSH-REL = 200 ppm, 790 mg/m3
OSHA-PEL = 200 ppm, 790 mg/m3
LCtso 1 =11 000-44000 mg-min/m3 (inhal)
ICt5o ! = 370 mg-min/m3 (inhal)
ACGIH-TWA =25 ppm, 1 7 mg/m3
ACGIH-STEL = 35 ppm, 24 mg/m3
NIOSH-REL = 25 ppm, 1 8 mg/m3
NIOSH-STEL = 35 ppm, 27 mg/m3
OSHA-PEL = 50 ppm, 35 mg/m3
ACGIH-TWA =0.01 mg/m3
NIOSH-Ceiling = 0.002 mg/m3 (15 min ceiling)
OSHA-PEL =10fig/mJ(8hrTWA)
Animal toxicity data only3
Animal toxicity data only3
ACGIH-TWA =10 mg/m3***
OSHA-PEL = 1 5 mg/m3 (8 hr TWA - total dust)
= 5 mg/m3 (8 hrs TWA - rf)
Source Associated Agent
SDP GB
HP, ICP L
ICP L
ICP HL, L
A DM
SDP GB
HP,CP,ICP HL,L
L
DP HD
DP HD
RMA ARARS 1/96
-------
Table A-47 Worker Air Exposure Standards for Chemical Agent Constituents*
Chemical Name
Carbon Dioxide
Exposure Standards
ACGIH-TWA = 5000 ppm, 9000 mg/m3
ACGIH-STEL = 30000 ppm, 54000 mg/m3
NIOSH-REL =5000 ppm, 9000 mg/m3
NIOSH-STEL = 30000 ppm, 54000 mg/m3
OSHA-PEL =5000 ppm, 9000 mg/m3 (8 hr TWA)
Page 2 of 7
Source Associated Agent
CP, DP CG, GB, HD, HL
Chlorine
Chloroacetic Acid
Chloroform**
1,2-Dichloroethane**
{ethylene dichloride]
Diethyldisulfide
Diisopropylcarbodiimide (DIPC)
Distilled Mustard (HD)
[2,2-dichIoro-diethyl sulfide;
bis(2-chloro-ethyl) sulfide]
ACGIH-TWA = 0.5 ppm, 1 .5 mg/m3
ACGIH-STEL = 1 ppm, 2.9 mg/m3
NIOSH-REL =0.5 ppm, 1 .5 mg/m3
NIOSH-STEL = 1 ppm, 3 mg/m-*
OSHA-Ceiling = 1 ppm, 3 mg/m3
Animal toxicity data only3
ACGIH-TWA = 10 ppm, 49 mg/m3
NIOSH-STEL = 2 ppm, 9.78 mg/m3 (60 min)
OSHA-Ceiling = 50 ppm, 240 mg/m3
ACGIH-TWA =10 ppm, 40 mg/m3
OSHA-PEL = 50 ppm (8 hr TWA); 100 ppm (ceiling);
200 ppm (5 mins/3 hr)
NIOSH-REL =1 ppm, 4 mg/m3
NIOSH-STEL = 2 ppm, 8 mg/m3
MPC = 200 ppm
CP
HL,L
DP, ICP, SDP
ICP
HD
GB.HD
HD
Animal toxicity data only3
Animal toxicity data only3
MPC
= 1500 mg-min/m3 (inhal)
= 10000 mg-min/m3 (s/m-vapor)
= 7.0 gm/70 kg man (s/m-Hquid)
= 200 mg-min/m3 (eye injury)
= 2000 mg-min/m3 (s/m @ 70°-80°F)*
= 2 mg-min/m3 (eye)
= 5 mg min/m3 (s/m)
ICP
AS
A
HD
GB
HD
RMAAKARS 1/96
-------
Table A-47 Worker Air Exposure Standards for Chemical Agent Constituents*
Page 3 of 7
Chemical Name
Distilled Mustard (continued)
Ethanethiol
[ethyl mercaptan]
Ethyl Chloride
[chloroethane]
PEL2
Ceiling2
SEL2
AEL4
ACGIH-TWA
NIOSH-Ceiling
OSHA- Ceiling
ACGIH-TWA
OSHA-PEL
Exposure Standards Source Associated Agent
= 0.003 mg/m3 uw (8 hr TWA)
= 0.003 mg/m3 (uw)
= 0.003 mg/m3 (naw/gp)
= 0.003 mg/m3 (1 hr TWA)
= 0.003 mg/m3
= 0.5 ppm, 1.3 mg/m3 ICP HD
= 0.5 ppm, 1 .3 mg/m3 (15 min ceiling)
= 10 ppm, 25 mg/m3
= 1000 ppm, 2640 mg/m3 ICP HD
= 1000 ppm, 2600 mg/m3 (8 hr TWA)
Fluoride (Inorganic Compounds - including ACGIH-TWA = 2.5 mg/m3
calcium fluoride and sodium fluoride) NIOSH-REL = 2.5 mg/m3
OSHA-PEL = 2.5 mg/m3 (8 hr TWA)
GB
H
HT
Hydrogen Chloride
Hydrogen Fluoride
Hydrogen Sulfide
AEL4 = 0.0001 mg/m3 (8hr TWA)
AEL4 = 0.2 mg/m3 (any period)
AEL4 = 0.003 mg/m3
AEL4 = 0.003 mg/m3
ACGIH- Ceiling = 5 ppm, 7.5 mg/m3
NIOSH- Ceiling = 5 ppm, 7 mg/m3
OSHA- Ceiling = 5 ppm, 7 mg/m3
ACGIH- Ceiling = 3 ppm, 2.6 mg/m3
NIOSH-REL = 3 ppm, 2.5 mg/m3
NIOSH-Ceiling = 6 ppm, 5 mg/m3 (15 min)
OSHA-PEL =3ppm,(8hrTWA)
ACGIH-TWA =10 ppm, 14 mg/m3
ACGIH-STEL = 15 ppm, 21 mg/m3
NIOSH- Ceiling= 10 ppm, 15 mg/m3 (10 min)
OSHA- Ceiling = 20 ppm
OSHA-MPC = 50 ppm (10 min OT)
DP
HP.CP
CP,HP
ICP
GB
CG, HD, HL, L
GB
HD
RMAAKARS 1/96
-------
Table A-47 Worker Air Exposure Standards for Chemical Agent Constituents*
Page 4 of 7
Chemical Name
Exposure Standards
Source
Associated Agent
Isopropyl Alcohol
Lewisite (L)
[dichloro(2-chlorovinyl)arsine]
Mercury Alkyl Compounds
(including dimethyl mercury and
methyl mercury salts)
Methyl Chloride
[chloromethane]
Methylene Chloride*
Mustard-Lewisite Mixture
ACGIH-TWA
ACGIH-STEL
NIOSH-REL
NIOSH-STEL
OSHA-PEL
LCtso
Ceiling2
SEL2
= 400 ppm, 983 mg/m3
= 500 ppm, 1230 mg/m3
= 400 ppm, 980 mg/m3
= 500 ppm, 1225 mg/m3
= 400 ppm, 980 mg/m3 (8 hr TWA)
= 1200-1500 mg-min/m3 (inhal)
=• 100000 mg-min/m3 (s/m)
< 300 mg-min/m3 (eye injury-vapor)
> 1500 mg-min/m3 (s/m)
= 0.0001 mg/m3(uw)
= 0.0001 mg/m3 (naw/gp)
- 0.0001 mg/m3 (1 hr TWA)
HP
GB
HL,L
ACGIH-TWA =0.01 mg/m3
ACGIH-STEL =0.03 mg/m3
NIOSH-REL = 0.01 mg/m3 (skin)
NIOSH-STEL = 0.03 mg/m3 (skin)
OSHA-Ceiling =0.01 mg/m3
HL.L
ACGIH-TWA
ACGIH-STEL
NIOSH-REL
OSHA-PEL
OSHA-Ceiling
OSHA-MPC
ACGIH-TWA
NIOSH-REL
OSHA-PEL
OSHA-Ceiling
OSHA-MPC
LCtso
= 50 ppm, 103 mg/m3 (skin)
= 100 ppm, 207 mg/m3 (skin)
= reduce to lowest feasible concentration
= 100ppm(8hrTWA)
= 200 ppm
= 300 ppm (5 min/3 hr)
= 50 ppm, 174 mg/m3
= reduce to lowest feasible concentration
= 500 ppm, 1765 mg/m3 (8 hr TWA)
= 1000 ppm, 3530 mg/m3
= 2000 ppm, 7060 mg/m3 (5 min/2 hrs)
= 1500 mg-min/m3 (inhal)
> 10000 mg-min/m3 (s/m)
= 200 mg-min/m3 (eye injury)
= 1500-2000 mg-min/m3 (s/m)
ICP
ICP
HD
HL
RMA ARARS 1/96
-------
Table A-47 Worker Air Exposure Standards for Chemical Agent Constituents*
Page S of 7
Chemical Name
Phosphoric Acid
[orthophosphoric acid]
Phosphorus Pentoxide
[POX, phosphoric anhydride]
Sarin (GB)
[isopropyl methylphosphono fluoridate;
methyisopropo oxyfluoro-phosphine oxide]
Sulfur
Sulfur Dioxide
Exposure Standards Source
ACGIH-TWA = 1 mg/m3 ICP
ACGIH-STEL = 3 mg/m3
NIOSH-REL = I mg/m3
NIOSH-STEL =3 mg/m3
OSHA-PEL = 1 mg/m3 (8 hr TWA)
Animal toxicity data only3 CP
LCtso' (resp) = 100 mg-min/m3 (resting) A
= 70 mg-min/m3 (mild activity)
ICtso' (resp) = 75 mg-min/m3 (resting)
= 35 mg-min/m3 (mild activity)
TWA2 = 0.000 1 mg/m3 (uw - 8 hr TWA)
= 0.000003 mg/m3 (naw/gw - 72 hr TWA)
Ceiling2 = 0.0001 mg/m3 (naw/gw)
SEL2 = 0.0003 mg/m3 (1 hr TWA)
Eye irritation3 = 6 ppm ICP
ACGIH-TWA =2 ppm, 5.2 mg/m3 CP
ACGIH-STEL = 5 ppm, 13 mg/m3
NIOSH-REL = 2 ppm, 5 mg/m3
NIOSH-STEL = 5 ppm, 10 mg/m3
OSHA-PEL = 5 ppm, 13 mg/m3 (8 hr TWA)
Associated Agent
GB
GB
GB
HD
HD
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane* *
[acetylene tetrachloride]
beta-Thiodiglycol
[thiodiethylene glycol]
Tributylamine (TBA)
Animal toxicity data only3
ACGIH-TWA =1 ppm, 6.9 mg/m3
NIOSH-REL = 1 ppm, 7 mg/m3 (skin)
OSHA-PEL = 5 ppm, 35 mg/m3 (8 hr TWA - skin)
Animal toxicity data only3
Animal toxicity data only3
ICP
ICP
DP, HP
AS
HD
HD
HD.HL
GB
RMAARARSI/96
-------
Table A-47 Worker Air Exposure Standards for Chemical Agent Constituents*
Page 6 of 7
Chemical Name
Exposure Standards
Source
Associated Agent
1,1,1 -Trichloroethane* *
[methyl chloroform]
1 , 1 ,2-Trichloroethane*
Vinyl Chloride*
[chloroethylene; ethylene monochloride]
VX
ACGIH-TWA = 350 ppm, 1910 mg/m3
ACGIH-STEL = 450 ppm, 2460 mg/m3
OSHA-PEL = 350 ppm, 1900 mg/m3 (8 hr TWA)
NIOSH-Ceiling =350 ppm, 1900 mg/m3 -15 min
ACGIH-TWA
OSHA-PEL
ACGIH-TWA
NIOSH-REL
OSHA-PEL
OSHA-Ceiling
AEL
AEL
: 10 ppm, 55 mg/m3 (skin)
•• 10 ppm, 45 mg/m3 (8 hr TWA - skin)
= 5 ppm, 13 mg/m3
= Lowest reliably detectable concentration
= 1 ppm, 2.6 mg/m3 (8 hr TWA)
= 5 ppm, 13 mg/m3 (15 min)
= 0.00001 mg/m3 (TWA)
•- 0.02 mg/m3 (any period)
ICP
ICP
ICP
HD
HD
Note:
**
***
****
1
2
3
4
A
ACGIH
AEL
AS
CG
CP
DIPC
DM
DP
GB
Also follow all monitoring and detection and other standards in AMC-R 385-131, Safety Regulation for Chemical Agents H, HD, HT, GB, and VX.
The values presented in this table are commonly considered chemical-specific ARARs or independently applicable requirements. They are provided
for completeness and the convenience of the reader.
Exposure information appears in DSA
Value is for total dust containing no asbestos and less than 1% silica
Skin absorption increases above 80°F (e.g., ICtso = 1000 mg-min/m3 at 90°F)
Reference: Chemical Agent Data Sheets, Volume I, Edgewood Arsenal Special Report EO-SR-74001, December 1974 [TBC]
Reference: AR 385-64 [ARAR] and DA Pamphlet 40-8 [TBCJ
Reference: N.I. Sax, Dangerous Properties of Industrial Materials, 6th Ed., 1984
Reference: AMC-R 385-131, Safety Regulation for Chemical Agent, H, HD, HT, GB, and VX
Agent
American Conference of Governmental
Industrial Hygienists
Airborne Exposure Limit
Agent stabilizer
Phosgene
Combustion product
Diisopropylcarbodiimide
Adamsite
Decontamination product
Sarin
H
HD
HL
HP
hr
HT
ICP
L
LCt50
MAX
Mustard
Distilled mustard
Mustard-Lewisite mixture
Hydrolysis product
Hour
Mustard
Incomplete combustion product
Median incapacitating dose
Lewisite
Median lethal dose
Maximum peak above the ceiling
RMA ARARS 1/96
-------
Table A-47 Worker Air Exposure Standards for Chemical Agent Constituents*
Page 7 of 7
vx
mgfttr
min
MFC
naw/gp
NIOSH
OSHA
OT
Nerve Agent PEL
Milligrams per minute per cubic meter ppm
Milligrams per cubic meter REL
Minutes resp
Maximum peak concentration rf
Non-agent worker/general population s/m
National Institute for Occupational Safety and Health SDP
(NIOSH-TWA is the time-weighted concentration for SEL
a 10-hour day and a 40-hour work week) STEL
Occupational Safety and Health Administration TBA
One time exposure if no other measurable exposure TWA
occurs uw
Permissible exposure limit
Parts per million
Recommended exposure limit
Respirable
Respirable fraction
Skin exposure/masked worker
Stabilizer decontamination product
Source emission limit
Short-term exposure limit
Tributylamine
Time weighted average
Unmasked worker
RMAARARSI/96
-------
Table A-48 Standards Pertaining to Air Emissions from Potential Remedial Actions
Page 1 of 3
Parameter Concentration Units
Asbestos NA NA
Benzene (Fugitive 10,000 ppm
Emission)
Beryllium 10 grams
Beryllium .01 ug/m3
Hydrogen Sulfide 142 ng/m3
Lead 1.5 ug/m3
Mercury (from Sludge 1,600 grams/day
Incineration)
Odor 7 Volume
Odor 15 Volume
Standard
No visible emissions allowed unless specified alternative waste
management procedures followed.
Machine reading indicates leak; Readings of less than 500 ppm above
background are not considered action events; Colorado Air Pollution
Control Regulations; National Emission Standard.
Over a 24 hour period; National Emission Standard; Colorado Air
Pollution Control Regulations
30 day average, at least 3 years of data available; National Emission
Standard; Colorado Air Pollution Control Regulations
1 hour average; Colorado Air Pollution Control Regulations.
Average over one month period; Colorado Air Pollution Control
Regulations.
Monitor emissions at least once a year by EPA Method 105; Below
Federal limit of 3,200 grams/day; Colorado Air Pollution Control
Regulations; National Emission Standard.
Residential commercial areas, dilution with volumes of odor-free air;
Colorado Air Pollution Regulations.
AH other land use areas, dilution with volumes of odor-free air; Colorado
Air Pollution Control Regulations.
Citation
40 CFR 61 Subpart M
5 CCR 1001-10
Regulation 8, Part B
5 CCR 1001
Regulation 8, Section VIII
40CFR61.110
40 CFR 61. 32
5 CCR 1001
Regulation 8, Section III
40 CFR 61. 32
5 CCR 1001
Regulation 8, Part A
5 CCR 1001-10
Regulation 8, Part C,
Section II
5 CCR 1001-10
Regulation 8, Part C,
Section I
5 CCR 1001
Regulation 8, Part A
40 CFR 61. 52
5 CCR 1001
Regulation 2
5 CCR 1001
Regulation 2
RMA ARARS 1/96
-------
Table A-48 Standards Pertaining to Air Emissions from Potential Remedial Actions
Page 2 of 3
Parameter
Concentration
Units
Standard
Citation
Opacity
20%
No operation with emissions exceeding 20% opacity; Colorado Air
Pollution Control Regulations. Fugitive dust measures will be written
into the project work plans in consultation with the state. Nuisance
guidelines and "no off-property" transport guidelines apply to certain
sources of fugitive particulate matter emissions.
5 CCR 1001
Regulation 1, Section II
Ambient Air Quality Lead - 1.5
Standards
TSP 75 & 260
Hg/m (max. Sources cannot cause or contribute to an exceedance of a national or
arithmetic Colorado Ambient Air Quality Standard.
mean average
over a calendar
quarter)
Hg/m Sources cannot cause or contribute to an exceedance of a national or
(primary std- Colorado Ambient Air Quality Standard.
annual
(geometric
mean), 24-hr )
PM - 150 & 50 ug/m (24 hr Sources cannot cause or contribute to an exceedance of a national or
average Colorado Ambient Air Quality Standard.
concentration
& annual
arithmetic
mean,
respectively)
Ozone-235 ug/m3 (1 hr Sources cannot cause or contribute to an exceedance of a national or
averaging Colorado Ambient Air Quality Standard.
time)
5 CCR 1001-5, Regulation
3
5 CCR 1001-14
5 CCR 1001-14
5 CCR 1001-14
5 CCR 1001-14
RMAARARSI/96
-------
Table A-48 Standards Pertaining to Air Emissions from Potential Remedial Actions
Page 3 of 3
Parameter
Concentration
Units
Standard
Citation
CO -10 & 40
NO2- 100
SO2-700
-10,50, and 300
• 80,365,1300
mg/m (8 hr Sources cannot cause or contribute to an exceedance of a national or
and 1 hr Colorado Ambient Air Quality Standard.
averaging time,
respectively)
ug/m (annual Sources cannot cause or contribute to an exceedance of a national or
average) Colorado Ambient Air Quality Standard.
ug/m (3 hr Sources cannot cause or contribute to an exceedance of a national or
max once in Colorado Ambient Air Quality Standard.
any 12 month
period)
Sources cannot cause or contribute to an exceedance of a national or
Colorado Ambient Air Quality Standard.
Incremental
stds for
Category II
ug/m3 (annual
arithmetic
mean, 24-hour
maximum, and
3-hour
maximum)
ug/m (annual Sources cannot cause or contribute to an exceedance of a national
mean, 24 hr secondary ambient air quality standard.
second
maximum, and
secondary 3 hr
second
maximum)
5 CCR 1001-14
5 CCR 1001-14
5 CCR 1001-14
5 CCR 1001-14
40 CFR 50.4 and 50.5
ppm parts per million
Ug/m' micrograms per cubic meter
mg/m^ milligrams per cubic meter
RMA ARARS 1/96
-------
-------
Appendix B
Agreement in Principle
Regarding a Water Supply Between
the Army, Shell, and SACWSD
-------
-------
AGREEMENT IN PRINCIPLE REGARDING A WATER SUPPLY BETWEEN
SOUTH ADAMS COUNTY WATER AND SANITATION DISTRICT (SACWSD),
THE ARMY AND SHELL OIL COMPANY
1. PAYMENT BY THE ARMY AND SHELL WILL BE IN THREE ANNUAL
INSTALLMENTS, $16 MILLION, $16 MILLION, AND $16.8 MILLION. THE FIRST
PAYMENT TO BE MADE WITHIN 90 DAYS OF 1 OCTOBER 1996. SUBJECT TO
THE AVAILABILITY OF FUNDS.
2. .PAYMENT OF THE ABOVE SUM IS CONDITIONED ON ADHERENCE TO THE
FOLLOWING TERMS. OTHER TERMS AND CONDITIONS WILL BE THE
SUBJECT OF FURTHER NEGOTIATION.
A. PAYMENTS WILL BE HELD IN TRUST FOR SACWSD. TRUSTEE TO
BE CHOSEN BY THE ARMY & SHELL WITH SACWSD CONCURRENCE. ANY
INTEREST THAT ACCRUES MUST BE RETURNED TO THE ARMY AND SHELL.
B. SACWSD MUST HOOK UP OWNERS OF DOMESTIC WELLS IN THE
DIMP FOOTPRINT WHO CONSENT TO BE INCLUDED IN THE SOUTH ADAMS
COUNTY WATER AND SANITATION DISTRICT AND WHO CONSENT TO BE
HOOKED UP; AND SUCH HOOK UPS WILL BE COMPLETED NOT LATER THAN
THE 24TH MONTH AFTER THE DATE OF THE INITIAL PAYMENT FOR THOSE
WHO CONSENT BY THE 20TH MONTH AFTER THE INITIAL PAYMENT.
THOSE WHO REQUEST TO BE HOOKED UP AFTER THE 20TH MONTH WILL
BE HOOKED UP WITHIN A REASONABLE TIME. AS NOTED IN G, BELOW,
SACWSD WILL NOT BE RESPONSIBLE FOR HOOKING UP MORE THAN 130
HOMES. SACWSD ALSO IS NOT RESPONSIBLE FOR EXTENDING THE MAIN
WATER DISTRIBUTION SYSTEM BEYOND THE DIMP FOOTPRINT AS
FINALLY DETERMINED IN THE ON-POST ROD. THE MAIN WATER
DISTRIBUTION SYSTEM FOR THE HENDERSON AREA (12" DIAMETER PIPE
SYSTEM) WILL BE COMPLETED BY THE 24TH MONTH AFTER THE INITIAL
PAYMENT. SACWSD WILL RECEIVE FROM THE TRUST ACCOUNT $3,950 FOR
EACH HOME CONNECTED IN THE NEW SERVICE AREA AND $2,265 FOR
EACH HOME CONNECTED IN THE OLD SERVICE AREA, UP TO A TOTAL OF
130 HOMES. ATTACHED IS THE MAP THAT SHOWS THE LATEST DIMP
PLUME WHICH IS TO BE UPDATED PRIOR TO THE FINALIZATION OF THE
ON-POST ROD.
C. SACWSD MUST CONTRACT FOR WATER RIGHTS OR SUPPLY BY
NOT LATER THAN SIX MONTHS AFTER THE DATE OF THE FINAL PAYMENT.
D. PAYMENTS FROM THE TRUST TO SACWSD MUST BE TIED
DIRECTLY TO THE ACQUISITION AND DELIVERY OF 4000 ACRE FEET OF
znnfft imunm VBH -«-,- Arn xnwv
-------
WATER AND THE HOOK UP OF WELL OWNERS IN THE HENDERSON AREA.
ALL EXPENDITURES BY SACWSD PAID FROM THE TRUST ACCOUNT WILL
BE SUBJECT TO AUDIT BY THE ARMY AND SHELL. UP TO $43 MILLION MAY
BE SPENT ACQUIRING AND DELIVERING THE 4000 ACRE FEET OF WATER
AND UP TO $4.65 MILLION MAY BE SPENT ON HOOK UPS IN THE
HENDERSON AREA. THE REMAINING $1.15 MILLION IS TO OFFSET
INFLATION OR CONTINGENCIES. ANY EXPENDITURES CHALLENGED BY
THE ARMY, SHELL, OR THE TRUSTEE WILL BE SUBMITTED TO THE
ALTERNATIVE DISPUTE RESOLUTION (ADR) METHOD DESCRIBED IN E,
BELOW.
E. AN INDEPENDENT QUALIFIED AGENT, WHO IS A SENIOR WATER
RESOURCE EXPERT WITH EXPERIENCE IN ACQUIRING AND DELIVERING
WATER, WILL BE SELECTED BY SACWSD, WITH THE CONCURRENCE OF
THE ARMY AND SHELL, TO DIRECT THE SELECTION, ACQUISITION, AND
IMPLEMENTATION OF A WATER SUPPLY ON BEHALF OF SACWSD THAT
CAN BE OPERATIONAL BY 1 OCTOBER 2004. THE TERMS OF THE AGENCY
WILL BE AGREED UPON SACWSD, THE ARMY AND SHELL. THE ARMY AND
SHELL WILL CONCUR WITH THE DESIGN OF AND SUBSEQUENT BID
PACKAGES FOR THE WATER DELIVERY SYSTEM. THE CONSTRUCTION
FIRM OR FIRMS TO CONSTRUCT THE PROJECT OR PROJECTS WILL BE
SELECTED BY COMPETITIVE BID BASED ON A SOLICITATION PROCESS
CONCURRED IN BY THE ARMY AND SHELL. THE COSTS ASSOCIATED WITH
IMPLEMENTING THIS SECTION WILL BE PAID FROM THE TRUST ACCOUNT.
ANY DISAGREEMENT ARISING REGARDING THE IMPLEMENTATION OF THIS
SECTION WILL BE SUBMITTED TO A FORM OF ADR CONSISTING OF
SUBMISSION OF THE DISPUTE TO THREE WATER RESOURCE EXPERTS; ONE
SELECTED BY THE ARMY AND SHELL; ONE SELECTED BY SACWSD; AND
ONE SELECTED BY THE INDEPENDENT AGENT OR BY THE AGREEMENT OF
THE TWO SIDES IF THERE IS NO INDEPENDENT AGENT. THE COST OF ADR
WILL BE BORNE BY THE PARTIES WITH EACH SIDE PAYING FOR ITS
EXPERT AND EACH SIDE PAYING 50% OF THE COST OF THE EXPERT FOR
THE INDEPENDENT AGENT.
F. ALL FUNDS REMAINING IN THE TRUST ACCOUNT AT THE
COMPLETION OF THE WATER PROJECT OR ON 1 OCTOBER 2004,
WHICHEVER OCCURS FIRST, WILL REVERT TO THE ARMY AND SHELL.
REVERSION INCLUDES ANY SAVINGS REALIZED BY SACWSD FROM COST
SHARING PROJECTS WITH OTHER ENTITIES. REVERSION MAY BE DELAYED
WHERE UNKNOWN OR UNEXPECTED CONDITIONS OR CIRCUMSTANCES
PREVENT COMPLETION OF THE PROJECT BY 1 OCTOBER 2004. WHETHER,
AND FOR HOW LONG, REVERSION SHOULD BE DELAYED WILL BE SUBJECT
TO THE METHOD OF ADR DESCRIBED IN E, ABOVE.
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-------
• G. SACWSD AGREES TO SATISFY THE OBLIGATIONS CONTAINED IN
ITEMS 16 AND 17 OF THE AGREEMENT ON A CONCEPTUAL REMEDY FOR
THE CLEAN UP OF ROCKY MOUNTAIN ARSENAL. THE PAYMENTS TO
SACWSD WILL CONSTITUTE COMPLETE SATISFACTION OF THE ARMY AND
SHELL'S OBLIGATIONS CONTAINED IN ITEMS 16 AND 17 AND COMPLETE
SATISFACTION OF ALL COSTS ASSOCIATED WITH THE TERMS AND
CONDITIONS NECESSARY TO EXECUTE THESE OBLIGATIONS. ALL COSTS
NECESSARY TO EXECUTE THE REQUIREMENTS OF THIS AGREEMENT,
UNLESS OTHERWISE EXPRESSLY STATED, WILL BE PAID OUT OF THE
TRUST ACCOUNT. SACWSD WILL NOT BE RESPONSIBLE FOR MONITORING
REQUIREMENTS TO BE PERFORMED BY THE ARMY AND SHELL IN
ACCORDANCE WITH ITEM 17 AND SACWSD WILL NOT BE RESPONSIBLE
FOR HOOKING UP MORE THAN THE FIRST 130 WELL OWNERS. ANY
ADDITIONAL HOOK UPS REQUIRED UNDER THE TERMS OF ITEM 17 WILL BE
THE RESPONSIBILITY OF THE ARMY AND SHELL.
H. SACWSD WAIVES AND RELEASES THE ARMY AND SHELL FROM
ALL RESPONSE COSTS AND CLAIMS FOR DAMAGES FOR ALL RMA
CONTAMINANTS AND POLLUTANTS IN THE SACWSD WATER THAT ARE
KNOWN OR DETECTED PRIOR TO, OR AT THE TIME OF, THE SIGNING OF
THE ON-POST RECORD OF DECISION (ROD). PAYMENT OF RESPONSE
COSTS, IF ANY, OWED TO SACWSD AT THE TIME OF THE SIGNING OF THE
ON-POST ROD WILL BE DETERMINED BY AGREEMENT OF THE PARTIES
PRIOR TO SIGNING THE FINAL AGREEMENT CONTEMPLATED BY THIS
AGREEMENT IN PRINCIPLE..
I. ANY REUSABLE RETURN FLOWS ASSOCIATED WITH ANY WATER
SOURCE ACQUIRED WILL BE MADE AVAILABLE TO SACWSD FOR
REPLACEMENT OF DEPLETIONS UNDER ITS EXISTING AUGMENTATION
PLAN FOR THE FIRST THREE YEARS FOLLOWING THE INITIAL DELIVERY
OF WATER FROM THE NEW WATER SOURCE IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED, OTHERWISE RETURN
FLOWS ASSOCIATED WITH THE NEW WATER SOURCE, AND ANY WATER
UNUSED BY SACWSD FROM THE WATER SOURCE ITSELF, SHALL BE MADE
AVAILABLE AT ARMY AND SHELL EXPENSE FOR THE REMEDIATION OF
RMA FOR NOT LESS THAN 10 YEARS, IN ANNUAL AMOUNTS TO BE
DETERMINED ACCORDING TO REASONABLE NEED. THE FINAL PERIOD TO
BE AGREED UPON. AFTER REMEDIATION, ALL RETURN FLOWS WILL
RETURN TO THE USE OF SACWSD. EACH PARTY WILL BE RESPONSIBLE
FOR ANY NECESSARY APPROVALS. DISPUTES ARISING OVER THE
IMPLEMENTATION OF THIS SECTION WILL BE SUBMITTED TO ADR AS
DESCRIBED IN E, ABOVE.
J. SACWSD WILL WARRANT AND OTHERWISE DEMONSTRATE IT IS
AUTHORIZED AND QUALIFIED TO ENTER INTO THIS AGREEMENT, ACQUIRE
VHH «•«•* Aid MVT
en/
-------
AND PROVIDE WATER AND HOOK UP WELL OWNERS, SUBJECT TO THOSE .
WELL OWNERS' CONSENT TO INCLUSION WITHIN THE DISTRICT. SACWSD
WILL BE RESPONSIBLE FOR PERMITTING, ADJUDICATION, AND OTHER
REQUIREMENTS OF STATE AND FEDERAL LAW. """
K. PARTICIPATION BY THE ARMY AND SHELL, OR BY THEIR
REPRESENTATIVES, IN OVERSIGHT IN NO WAY CONSTITUTES AN EXPRESS
OR IMPLIED WARRANTY OR REPRESENTATION REGARDING THE
ADEQUACY, SUITABILITY, OR LEGALITY OF SACWSD OR THE
INDEPENDENT AGENT'S ACTIONS TO OBTAIN OR PROVIDE WATER.
L. ALL PARTIES RESERVE ANY RIGHTS THEY MAY HAVE
REGARDING NONPERFORMANCE BY THE OTHER PARTIES.
M. THIS AGREEMENT IS SUBJECT TO COMPLIANCE WITH ALL
APPLICABLE LAWS AND WILL BECOME EFFECTIVE AND BINDING WHEN
INCORPORATED BY REFERENCE IN THE ON-POST ROD.
N. THE AMOUNT AGREED UPON IS SUBJECT TO APPROPRIATE
CREDITS FOR ANY ARMY AND SHELL CONTRIBUTIONS TO WATER OR
INFRASTRUCTURE, SUBJECT TO SACWSD APPROVAL. APPROVAL WILL
NOT BE WITHHELD UNREASONABLY. DISPUTES WILL BE SUBMITTED TO
THE METHOD OF ADR DESCRIBED IN E, ABOVE.
0. ALL PARTIES WILL PUBLICLY SUPPORT THIS AGREEMENT.
P. ALL O&M COSTS ASSOCIATED WITH THE ACQUISITION AND
DELIVERY OF WATER AND WITH THE HOOK UP OF WELL OWNERS WILL BE
SACWSD'S RESPONSIBILITY. THE ARMY WILL SUPPORT ANY NECESSARY
AMENDMENTS TO ALLOW THE KLEIN FUND ALSO TO BE USED FOR O&M
COSTS FOR THE NEW WATER SYSTEM.
Q. QUARTERLY PROGRESS REPORTS WILL BE MADE BY SACWSD, OR
ITS REPRESENTATIVE, TO THE RMA COUNCIL.
R. THE ARMY OR SHELL WILL PAY, IF NECESSARY, WITHIN 30 DAYS
AFTER SIGNATURE OF THE ROD, A SUM NOT TO EXCEED $1 MILLION TO
PURCHASE AN OPTION ON WATER AGREED TO BY SACWSD, THE ARMY
AND SHELL. THIS SUM WILL BE CREDITED AGAINST THE FIRST ANNUAL
PAYMENT UNDER SECTION 1, ABOVE.
version 10 - 26/01/96
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