United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R08-89/037
May 1990
EPA Superf und
Record of Decision:
Rocky Mountain Arsenal
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50272-101
REPORT DOCUMENTATION 1'. REPORTNO.
PAGE EPA/ROD/R08-89/037
2.
3. AeclpIent'. AcC88810n No.
4. TII8 end &btItI8
SUPERFUND RECORD OF DECISION
Rocky Mountain Arsenal (Operable
Eighth Remedial Action
7. AuIIor(.)
5. Report 1>818
05'/14/90
Unit 17), CO
6.
8. Pwfonnlng Orllenlz;8l1on R8pt. No.
.. IWformIng Org8lnlD1lon N8m8 end Addr888
10. Proj8ctlTuklWOItI Unit No.
11. Contrect(C) or Grent(G) No.
IC)
.
(G)
12. ~ Orllenlzatlon N8m8 end Adchu
U.S. Environmental Protection
401 M Street, S.W.
washington, D.C. 20460
13. Type of Report. PerIod Covered
Agency
800/000
14.
15. SUppl8m8nl8ly No-
16. Ab8nct (lIrit: 200 _rd8)
The Rocky Mountain Arsenal (RMA) (Operable Unit 17) is a part of the 17,000-acre RMA
site, which is a former U.S. Army chemical warfare and incendiary munitions
manufacturing and assembly plant in Adams County, Colorado. From the 1950s until late
1969, the U.S. Army used the RMA facility to produce the nerve agent GB (isopropyl
methyl-phosphonofluoridate). In addition, between 1947 and 1982, private industries
leased major portions of the plant facilities to manufacture various insecticides and
herbicides. Since 1970, facility operations have primarily involved the destruction of
chemical warfare materials. Because final remediation of the RMA site will take many
years to complete, thirteen Interim Response Actions (IRAs) were determined necessary
prior to implementing the final remedial action. Operable Unit 17 (CERCLA Wastewater
Treatment System) is among those IRAs specified. This ROD addresses the interim remedy
to develop and implement a program to treat contaminated wastewaters resulting from the
assessment and implementation of response actions at the RMA site. The primary
contaminants of concern affecting the wastewaters are VOCs including benzene, PCE,
toluene, and TCE; other organics including pesticides; and metals including arsenic,
chromium, and lead.
(See Attached Page)
17. Oocum8nt An8Iy8I8 .. Dncrtpto/8
Record of Decision - Rocky Mountain Arsenal (Operable Unit 17), CO
Eighth Remedial Action
Contaminated Medium: wastewater
Key Contaminants: VOCs (benzene, PCE, toluene, TCE), other organics (pesticides),
metals (arsenic, chromium, lead)
b. Id8n~T-
c. COSAl1 R8Id/Group
18. AY8118bIIty St8t8In8nt
111. SeCl8'lty CI... (1111. Report)
None
20. SeCI8'Ity CIa.. (1111. Page)
Nnn~
21. No. 01 Page.
88
22. Price
(See ANSl-Z3I.18)
&e.tMlTucliona on ".-
27214-17)
IFonnatfy NTlS-35)
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EPA/ROD/R08-89/037
Rocky Mountain Arsenal (Operable Unit 17), CO
Eighth Remedial Action
Abstract (Continued)
and are partly covered with soil or structures. Site investigations by the Army The
selected Interim Response Action for this interim remedy includes constructing a
centrally located wastewater treatment facility that will consist of a sequence of unit
processes including chemical addition/precipitation, filtration, ultraviolet
light/chemical oxidation, activated carbon adsorption, air stripping, and an activated
alumina treatment process; constructing decontamination pads at both the treatment
facility and satellite non-treatment wastewater facilities; constructing five storage
tanks with 10,000 to 12,000 gallon capacities; and incorporating offsite discharge of
the treated effluent to the sanitary sewer and offsite disposal of treatment facility
sludges and residuals. No costs were provided for this remedial action.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ARARs, 'based on Colorado Basic
Standards for Ground Water (CBSG) and State MCLs, will be applied to the design of the
treatment system and include arsenic 50 ug/l (MCL), benzene 5 ug/l (MCL), chromium
50 ug/l (MCL), lead 50 ug/l (MCL), PCE 10 ug/l (CBSG), toluene 2,420 ug/l (CBSG), and
TCE 5 ug/l (MCL).
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U.S. ARMY
MATERIEL COMMAND
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REQUESTS FOR COPIES OF THIS DOCUMENT
SHOULD BE REFERRED TO THE PROGRAM MANAGER
FOR THE ROCKY MOUNTAIN ARSENAL.
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Draft Final Decision Document
. for the CERCLA Wastewater Treatment
System Interim Response Action
at the Rocky Mountain Arsenal
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April 1990
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Prepared For:
U.S. Army Program Manager's Office For
Rocky Mountain Arsenal Contamination Cleanup
The use of trade names in this report does not constitute an official
endorsement or approval of the use of such commercial products. The
report may not be cited for purposes of advertisement.
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1 ..
DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOUNTAIN ARSENAL
COMMERCI arv. COI..OftADO 80022,2, 80
April 5 J 1990
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Mr. Connally Mears
U.S. Environmental Protection Agency
Region VIII
One Denver Place
Suite 801
999-18th Street
Denver, Colorado 80202-2405
Dear Mr. Mears:
Enclosed for your review is the Draft Final Decision Document for the CERCLA
Wastewater Treatment System Interim Response Action (IRA) at Rocky Mountain
Arsenal.
Following consideration of all comments received during the public comment
period from December 29, 1989, through January 30, 1990, the Army has revised the
Decision Document for the CERCLA Wastewater Treatment System IRA accordingly.
Organizations with standing to invoke the dispute resolution process should advise
me in writing by close of business April 30, 1990, if they wish to invoke the procedures
for dispute resolution.
Unless dispute resolution is invoked on or before April 30, 1990, the Army will
consider the Draft Final Decision Document for the CERCLA Wastewater Treatment
System IRA to be the Final Decision Document on May 1, 1990.
Sincerely,
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Donald L Campbell .
Deputy Program Manager
DISTRIBUTION:
-
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Enclosure
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Copies Furnished:
Major Lawrence E. Rouse, Headquarters, Department of the Army,
ATfN: DAJA-ELL, Pentagon, Room 1C480, Washington, D.C. 20310-2210
(w/enc1) .
Mr. Bradley Bridgewater, Acumenics Research and Technology, Inc., DOJ litigation
Support, 999-18th Street, Suite 501, North Tower, Denver, Colorado 80202
(w/encl) .
. Mr. John Barth, Assistant Regional Counsel, U.S. Environmental
Protection Agency, One Denver Place, Suite 500, 999-18th Street,
j)enver, Colorado 80202-2405 (w/enc1)
YMr. Chuck Schick, Camp Dresser and McKee, 2300-15th Street, Suite 400, Denver,
Colorado 80202 (w/enc1)
Acumenics Research and Technology, Inc., Room 132, Building 111
Rocky Mountain Arsenal, Commerce City, Colorado 80022 (w/enc1)
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1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
TABLE OF CONTENTS
INTRODUCTION. . . . . . . . . . . . . . . . . . . . .
BACKGROUND. . . . . . . . . . . . . . . . . . . . .
INTERIM RESPONSE ACTION OBJECTIVES. . . . . . . . . .
INTERIM RESPONSE ACTION ALTERNATIVES. . . . . . . . .
4 . 1 NO ACTION ALTERNATIVE. . . .' . . . . . . . . . .
4.2 MODIFICATION OF THE EXISTING SYSTEM. . . . . . .
4.3 NEW SYSTEM LOCATION AND CONFIGURATION. . . . . .
4.4 UNIT PROCESS ALTERNATIVES. . . ~ . . . . . . . .
CHRONOLOGY OF EVENTS. . . . . . . . . . . . . . . . .
SUMMARY OF THE INTERIM RESPONSE ACTION PROJECT. . . .
6.1 SELECTED ALTERNATIVES. . . . . . . . . . . . . .
6. 2 HEALTH AND SAFETY PLAN . . . . . .~. . . . . . .
IRA PROCESS. . . . . . . . . . . . . . . . . . . . .
APPLICABLE OR RELEVANT AND APPROPRIATE REOUIREMENTS FOR
THE CERCLA WASTEWATER TREATMENT SYSTEM INTERIM RESPONSE
ACTION. . . . . . . . . . . . . .
. . . . .
. . . . .
8.1 AMBIENT OR CHEMICAL-SPECIFIC. . . . . . . . . .
8.2 LOCATION-SPECIFIC ARARs . . . . . . . . . . . . .
8.3 ACTION-SPECIFIC ARARs . . . . . . . . . . . . . .
8.4 COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS. . . .
9. 0 SCHEDULE. . . . . . . . . . . . . . . . . . . . . . .
10.0 CONSISTENCY WITH THE FINAL RESPONSE ACTION. . . . . .
11.0 REFERENCES. . . . . . . . . . . . . . . . . . . . . .
LIST OF FIGURES
Ficrure No.
1 Rocky Mountain Arsenal Location
.........
COMMENTS AND RESPONSES
APPENDIX
i
Paqe
1
2
5
6
6
6
7
8
9
11
11
13
14
16
16
20
21
28
29
30
31
Paqe
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DRAFT FINAL DECISION DOCUMENT
FOR THE CERCLA WASTEWATER TREATMENT
SYSTEM INTERIM RESPONSE ACTION
AT THE ROCKY MOUNTAIN ARSENAL
1.0
INTRODUCTION"
The Interim Response Action (IRA) for the CERCLA Wastewater
Tr~atment System (CWTS) at Rocky Mountain Arsenal (RMA) is being
conducted as part of the IRA Process for RMA in accordance with the
June 5, 1987 report to the court in United states v. Shell Oil Co.,
the proposed Modified Consent Decree dated June 7, 1988, and the
Federal Facility Agreement dated February 17, 1989.
The Federal Facility Agreement states that this IRA for the
CERCLA Wastewater Treatment System is necessary and appropriate for
". . development and implementation of a program to treat
wastewater resulting from the assessment and implementation of
response actions for the site (e.g., treatment of wastewater) from
the Arsenal laboratory and treatment of decontamination water prior
to their discharge into the Arsenal sanitary sewer, or development
of other appropriate measures for the disposal or reuse of such
water." "The two basic approaches considered to meet the Federal
Facility Agreement are to modify the existing South Plants
Treatment System and to build a new treatment facility.
Alternatives for improvement of the CWTS have been reviewed
based on technical feasibility, compliance to the maximum extent
practicable with applicable or relevant and appropriate
requirements (ARARs), potential to be expanded and/or modified for
incorporation into the Final Response Action, cost-effectiveness
among alternatives affording equivalent levels of protection, and
capability to be readily implemented.
After the alternatives were reviewed according to the criteria
listed above, a new CERCLA wastewater treatment system was chosen
as the best solution for this IRA. "
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2.0
BACKGROUND
Rocky Mountain Arsenal occupies over 17,000 acres
(approximately 27 square miles) in Adams County, directly northeast
of metropolitan Denver, Colorado (see Figure 1). The RMA property
was purchased by the U.S. Government in 1942 for the purpose of
producing chemical weapons and conventional munitions for the
Second World War. Between 1953 and 1957, GB nerve agent was
produced. Munitions continued to be filled with GB at RMA until
approximately 1969. From the late 1950's to the mid-1960's, RMA
was primarily engaged in various demilitarization programs. Since
1970, the primary mission of RMA has been the disposal of chemical
warfare material. In addition to these military activities, a
major portion of the plant facilities were leased to private
industries (including Shell Chemical Co.) beginning in 1946 for the
manufacture of various insecticides and herbicides. The current
mission of RMA is contamination cleanup: there is no operational
mission. This cleanup process is expected to last into the next
decade.
On June 5, 1987 the Army, the Environmental Protection Agency,
the State of Colorado and Shell Oil Company agreed to conduct
certain Interim Response Actions at the Rocky Mountain Arsenal.
On February 1, 1988, a proposed Consent Decree was lodged in
the u.S. v. Shell oil Company with the u.S. District Court in
Denver, Colorado. The proposed Consent Decree was revised after
,public comments were received, and a modified proposed Consent
Decree was lodged with the Court on June 7, 1988. The Army and
Shell oil Company agreed to share costs of the cleanup that was to
be developed and performed under the oversight of the EPA, with
numerous opportunities for comment by the State of Colorado. A
Federal Facility Agreement was executed between the Army, Shell
Oi~ Company, EPA, the Department of Justice, the Agency for Toxic
Substances and Disease Registry, and Department of Interior on
February 17th, 1989. The long-term cleanup is a complex task that
will take many years to complete. The modified Consent Decree 'and
Federal Facility Agreement specify thirteen Interim Response
Actions (IRAs) whose implementation has been determined to be
necessary prior to implementation of the final remedial plan. This
IRA is among those specified.
In accordance with the Federal Facil i ty Agreement, an IRA
assessment was conducted between July 1988 and May 1989. That
study resulted in the submission of the CERCLA Wastewater Treatment
System Assessment (Waterway Experiment Station, 1989). The report
evaluated unit process additions to the existing South Plants water
treatment system and possible locations for the construction,of a
new system.
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BOULDER CO.
JEFFERSON CO.
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ADAMS CO.
ARAPAHOE CO.
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FIGURE 1
ROCKY MOUNTAIN ARSENAL LOCATION
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3.0
INTERIM RESPONSE ACTION OBJECTIVES
The goal of the CERCLA wastewater treatment system IRA is to
. develop and implement a program to treat contaminated wastewaters
resulting from the assessment and implementation of response
actions at the RMA. .
The following specific obj ecti-ves . for this IRA have been
selected based on the CERCLA Wastewater Treatment System Assessment
(Waterways Experiment Station, 1989). .
o
Expand the volume of wastewater that can be treated
beyond that of existing capacities, to at least 150,000
gallons per month.
o
Increase the variations of wastewater quality that can
be treated with a variety of unit process operations
capable of operating in either a batch or continuous
mode, configured such that they can be brought on-line
as needed to treat mixtures or specific wastew~ters.
o
Include storage capacity
month's treatment needs.
one
sufficient
contain
to
o
Select optimum siting of the treatment plant so as to
provide maximum utility throughout RMA.
Reduce the amount of generated wastes to a minimum.
o
CERCLA IRA criteria considered in evaluating alternatives to
achieve the above mentioned goal include:
o
Short- and long-term effectiveness;
o
Protection of human health and the environment;
o
Reduction of mobility, toxicity, or volume;
o
Compliance with ARARs to the maximum extent practicable;
Implementability;
o
o
Cost-effectiveness.
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4.0
INTERIM RESPONSE ACTION ALTERNATIVES
The CWTS IRA was originally conceived to consist of
assessments of process treatment system alternatives that could be
added to the existing South Plants water treatment system. During
the drafting of the CERCLA Wastewater Treatment System Assessment
(Waterways Experiment Station, 1989), plans to close the South
Plants "area resulted in a modification of the assessment to include
the alternative of a new system sited outside of the South Plants
area.
The basic alternatives for system modification and improvement
were considered, including possible unit process additions to the
existing treatment system.
The alternatives identified in the CERCLA" Wastewater
Assessment were evaluated based upon the extent to which they meet
the IRA objectives and CERCLA IRA criteria.
4.1
NO ACTION ALTERNATIVE
o
The South Plants treatment system has a decreased flow
rate (about two gallons per minute), and the Army has
decided to close the South Plants Area. Since IRA
activities are expected to generate substantial
quanti ties of wastewaters, the need for an increased
capacity of wastewater treatment exists. Therefore, the
no action alternative is eliminated as a valid option for
meeting the IRA goal as measured by the criteria of long-
term effectiveness and protection of human health and the
environment.
4.2
MODIFICATION OF THE EXISTING SYSTEM
Although the South Plants Area is scheduled to be closed,
special provisions could be made for continued operation of
the South Plants treatment system in its present location.
This alternative was evaluated and eliminated as a valid
option for the following reasons:
o
In order to provide the additional unit processes and
liquid storage capacity needed to adequately treat CERCLA
wastewaters, a new building and modifications to the
existing building would have to be installed. Soil would
be disturbed and substantial construction activity would
occur within the" South Plants area. The existing
building and equipment would have to be decontaminated
in order to install new equipment and to renovate
existing equipment. Thus, this alternative ranks low
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4.3
o
o
against the criteria of protectiveness of human health
and the environment.
o
Prior to implementing this option, the types and level
of contaminants in soil and on the existing building and
equipment would have to be characterized so as, to prevent
the spread of contamination and to protect the health and
safety of workers. This will be done prior to final
remediation of the South Plants. However, it is not
planned to be done in a time frame suitable for
implementation of this IRA. It" the site characterization
were accelerated, it would still delay implementation of
this IRA compared to the alternative of constructing a
new treatment facility at a site known to be
uncontaminated. Thus, this alternative also ranks low
against the criteria of implementability.
The CERCIA Wastewater Treatment System will likely be one
of the last facilities to be decommissioned as part of
the RMA Final Remedial Action. Utilities (electricity,
water supply, and a new connection to the sanitary sewer)
will have to be maintained, and access to the facility
will have to be ensured. Its continued use could
interfere with interim and final measures to
decontaminate the South Plants area.
o
o
By not selecting this alternative, the full salvage value
of the existing building, equipment, and tankage will not
be recovered. However, the exiting facility's salvage
value is sUbstantially offset by the cost of a new sewer
line that would be needed in this alternative to connect'
the existing treatment plant to the sanitary sewer (see
"Final Decision Document for the Sanitary Sewer System
Interim Response Action at Rocky Mountain Arsenal",
April, 1989). Thus, this alternative is not considered
cost-effective.
NEW SYSTEM LOCATION AND CONFIGURATION
A new centralized facility, located .out of the South
Plants, for treatment of all wastewater at RMA is a cost
effective alternative to many treatment facilities
located near the site of individual remedial actions.
In addition, the proposed decontamination pad for the
South Plants system should be relocated adjacent to the
CWTS.
Satellite Decontamination Pads still may be required and
constructed at specific remedial actions. The use of
-------
o
satellite decon pads reduces the transport
contaminated equipment throughout the base.
Additional storage capacity in the form of five tanks,
each with a 10,000 to 12,000 capacity, would allow for
segregation of wastewaters requiring individual batch
treatments or for temporary storage of wastewaters
awaiting test results. These tanks would be in addition
to the 150,000 gallon bac~up storage capacity needed for
the plant.
of
4.4
UNIT PROCESS ALTERNATIVES
The CERCLA Wastewater Treatment System Assessment
identified three possible unit process additions to the South
Plants. treatment system or to be incl~ded in a new CWTS:
o
Chemical oxidation was proposed as a potential unit
process alternative to reduce loading on the activated
carbon units. The cost-effective advantage of this
option is that no contaminated residue requiring disposal
is produced.
Chemical precipitation/sedimentation was proposed to
reduce heavy metal concentrations known to be in some
wastewaters at RMA. These metals could potentially
interfere with and reduce the effectiveness of the
organic removal process.
o
o
A biological remediation step was considered as a
possible addition to the treatment system. However,
problems associated with non-continuous flow,
susceptibility to contaminants, or shock loading seem
insurmountable in the sustenance of a biological
population.
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5.0
CHRONOLOGY OF EVENTS
The significant events pertaining to the CWTS Interim Response
Action are presented below.
Date
Event
1979
170,000 gallon tank installed. Called the South
Plants Liquid Wastes Collection System. Originally
designed to collect liquids from laundry (Bldg 314)
and two labs (Bldgs 313 and 743), but the laundry
never disposed of liquids to the tank.
Stopped using the chemical sewer from South
Plants area to Basin F. LiqUids from labs then went
to the 170,000 gallon tank.
December
1981
April
1982
South Plants Liquid Treatment System installeQ,
consisting of a filter, granular activated carbon
unit, and activated alumina unit. Originally
designed for gravity driven fluid flow.
May
1982
Chemical sewer removal between the South Plants area.
and Basin F began.
State of Colorado, Shell oil tompany, u.S.
Environmental Protection Agency and U. S. Army agreed
that certain Interim Response Actions would be
conducted. .
June
1987
February
1988
Proposed Consent Decree (1988) lodged in the case
of U.S. v. Shell oil Company with the u.S. District
Court in Denver, Colorado. The Consent Decree
specified thirteen interim actions, including this
IRA, to facilitate remediation activities.
March
1988
Air Stripper and pump installed on the existing
South Plants treatment system. Pump allowed an
increased flow r.ate of two to five gallons per
minute.
July
1988 to
May
1989
CERCLA Wastewater Treatment System Assessment
performed (Waterways Experiment Station, 1989).
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Late
1988
Peroxidation Systems, Inc., ultraviolet/chemical
oxidation unit brought in to test CERCLA liquid
wastewaters from allover the Arsenal. The system
was only used for the tests and is not being used
to treat lab waters.
February
1989
Federal Facility Agreement signed.
J:uly
1989
Draft ARARs completed by the Army and sent to
relevant agencies for comment. .
,
August
1989
Comments on Draft ARARs received from the EPA,
State, and Shell.
Revised Draft Assessment completed by the Army and
sent to relevant agencies for review and comment.
October
1989
November
1989
Comments on the Revised Draft Assessment received
from the EPA, State, and Shell.
Proposed Decision Document completed by the Army and
issued to relevant agencies for review and comment.
December
1989
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6.0
.
SUMMARY OF THE INTERIM RESPONSE ACTION PROJECT
Construction of a new wastewater treatment facility and
co located decontamination pad is the selected alternative for the
CWTS Interim Response Action. This system is intended to
potentially treat all RMA CERCLA associated wastewaters, except for
those treated by the Hydrazine Blending and Storage Facility IRA
treatment systems. The decisive advantages of this approach over
the No Action and Modification of the Existing System Alternatives
are that it will not interfere with future remedial actions in the
contaminated South Plants area, and it will provide the most
expeditious means of attaining treatment objectives. (See Section
8.3.1, "Ambient or Chemical-Specific ARARs.) Specific
modifications and additional details dependent upon design analysis
will be determined during the IRA final design and discussed in the
Draft Implementation Document. .
6.1
SELECTED ALTERNATIVES
The following concept for' the CERCLA Wastewater Treatment
System is planned for implementation:
o
o
A new, centrally located wastewater treatment facility
and decontamination pad will be constructed. Additional
decontamination pads will be constructed at satellite
non-treatment wastewater facilities to reduce the
movement of contaminated trucks and equipment over long
distances. Each decontamination pad will consist of a
wash rack with a curbed concrete floor, a sump with steel
grating cover, and associated spray washing equipment.
The new water treatment facility will be constructed at
an uncontaminated location outside the South Plants Area
since the Army's future plans for this area involve its
closure. The location. for a new treatment facility will
likely be along "D" street, near the center of the
Arsenal.
In addition to the 150,000 gallon storage capacity needed
for a treatment system, five tanks will be constructed
with 10,000 to 12,000 gallon capacities. These tanks
will be used for segregation of wastewaters requiring
special treatment and for temporary storage while
awaiting test results.
A particular sequence of unit processes will be developed during
the Design Phase for this IRA. The following unit process
operations will be used at the water treatment facility:
o
-------
o
o
Chemical addition/precipitation to provide for
clarification of wastewaters containing fine suspensions
and removal of heavy metals which might interfere with
the organic removal process. Sludge will be stabilized
by dewatering or solidification, depending upon the type
of sludge generated. Solidification may be accomplished
using a simple barrel mixing system in which the sludge
and additives are mixed and allowed to cure in a drum.
Storage capacity will be required to allow for analysis
and accumulation of adequate volumes for cost-effective
transportation and disposal in accordance with EPA
criteria.
o
Filtration of wastewaters to minimize or eliminate
residual waste. Filtration will likely be accomplished
using bag filters instead of a mUlti-media filter to
minimize the generation of additional wastewater.
Filters will periodically be washed, and the resulting
residue will be combined with the precipitator sludge.
Duplicate units, each rated to .handle the anticipated
treatment rate, will be included in the system to allow
for maintenance and replacement of filter bags without
interruption to operations.
o
Ultraviolet light/chemical oxidation potentially may be
used before other organic treatment processes to reduce
the organic loading on that removal process (i.e.,
granular activated. carbon systems and air stripping
process) or serve as a pOlishing process. This process
does not generate any residue requiring further
treatment.
o
Activated carbon adsorption. This will be used to remove
almost all organics with the possible exception of those
volatile compounds which are not well-adsorbed by carbon.
Waste carbon will be transported offsite and disposed of.
Conceptually, this step will require two carbon-adsorber
columns, each capable of handling the approximate
treatment rate. Used in parallel, maintenance,
inspection, and replacement of carbon can be conducted
without an interruption of operations. When required,
these columns can also be operated in series mode to
increase contact time with the influent. Storage bins
for fresh and spent carbon will be an integral part of
the treatment system; annual carbon usage should not
exceed 5000 lbs per year.
Air stripping can be used to remove any of the residual
volatile organics surviving carbon adsorption treatment.
Stack gas monitoring will be required to verify
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o
compliance with air quality emission standards.
contaminated residue mayor may not be produced by this
process, depending upon the need for vent gas control.
The existing air stripper at the South Plants may be
sufficient for this purpose and, if so, will be
relocated to the new treatment system.
An activated alumina treatment process will be used for
wastewater contaminated with fluoride, arsenic, and other
potential contaminants as' determined practical.
Activated alumina will be used in an adsorption column
similar to the carbon adsorption columns. Spent
activated alumina will be managed offsite in accordance
with EPA criteria.
o
After receipt of analytical test results which confirm
completion of treatment, discharge of that effluent batch
to the sanitary sewer is appropriate. However,
provisions will be made to route effluent from the
"treatment system into storage tanks should additional
testing or treatment be needed, in which case this step
will be repeated.
The Army will utilize offsite disposal for management ~f "
CERCLA treatment facility sludges and residuals generated
by its operation in accordance with EPA criteria.
o
6.2
HEALTH AND SAFETY PLAN
A site-specific Health and Safety Plan for work to be
performed on the CERCLA Wastewater Treatment System will be
developed and included in the Implementation Document. This site-
specific plan will contain the details of monitoring plans, worker
protection and work modifications to be conducted in the event that
certain levels of contaminants are detected or if necessary to
ensure worker health and safety.
Analysis to determine any potential health risks to offsite
populations will also be conducted and an IRA contingency plan
developed to provide for" notification and appropriate response by
the Army and other agencies to any health threat that potentially
may arise during operation of the IRA treatment system.
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7.0
IRA PROCESS
wi th respect to this. IRA for the CWTS, the IRA process is as
follows:
..
3.
4.
1.
within 20 days after issuance of the Draft Final' Decision
Document for the CWTS IRA, an organization (including the
State if it has agreed to be bound by the Dispute
Resolution process, as required by the Federal Facility
Agreement, or DOI under the circumstances set forth in
the Federal Facility Agreement) may invoke Dispute
Resolution.
2.
After the close of the period for invoking Dispute
Resolution (if Dispute Resolution is not invoked) or
after the completion of Dispute Resolution (if invoked),
the Army shall issue a Final Decision Document for the
CWTS IRA with the supporting administrative record.
Thereafter, the Decision Document will be subj ect to
judicial review in accordance with :Sections 113 and 121
of the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended, 42 U.S.C. Sections
9613,9621.
Following issuance of the Final IRA Decision Document,
the United States Army shall be the Lead Party
responsible for designing and implementing the IRA in
conformance with the Decision Document. The Army shall
issue a Draft IRA Implementation Document to the DOI, the
State, and the other organizations for review and
comment. This Draft Implementation Document shall
include final drawings and specifications, final design
analyses, a cost estimate, and a schedule for
implementation of the IRA.
As Lead Party for design and implementation of this IRA,
the Army will issue the Final Implementation Document,
as described above, and will be responsible for
implementing the IRA in accordance with the IRA
Implementation Document.
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8.0
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR THE
CERCLA WASTEWATER TREATMENT SYSTEM INTERIM RESPONSE ACTION
8.1. AMBIENT OR CHEMICAL-SPECIFIC ARARS
Ambient or chemical-specific requirements set concentration
limits or ranges in various environmental media for specific
hazardous substances, pollutants, or contaminants.' Such ARARs
either set protective clean-up levels for the chemicals of concern
in the, designated media or indicate an appropriate level of
discharge.
The objectives of this IRA are discussed in the Assessment
Document. This IRA will be implemented prior to the final
remediation to be undertaken in the context of the Onpost Operable
Unit ROD. The list of specific contaminants has been compiled
based upon treatability test data and represents those contaminants
likely to be contained in the system influent. The media of
concern here is the wastewater treated by the proposed IRA system.
This proposed IRA treatment system will discharge treated effluent
to the sanitary sewer for eventual release after further treatment
within the RMA sewage treatment plant (STP). Discharges from the
STP are strictly regulated by the RMA NPDES Permit (currently under
revision) and must attain the specific limitations contained in
that permit prior to release from RMA. The ARARs listed below will
apply at the point of release from the CERCLA Wastewater Treatment
System (CWTS) IRA.
The current South Plants Wastewater Treatment Facility (SPWTF)
will continue to be operated prior to the implementation of the new
system pursuant to this IRA. The SPWTF will be subject to and
comply with the chemical-specific ARARs identified below and will
attain these limitations to the maximum extent practicable. The
Army has been conducting continuous s~mpling and analyses of this
system and it has been performing well. Due to recently
promulgated standards being slightly lower than detection limits
of the RMA laboratory,the Army will arrange, as soon as
practicable, for confirmatory analyses to be done on future SPWTF
effluent by contract laboratories which are certified at lower
detection limits so that attainment of these ARARs can be verified.
Because this treatment system will not provide drinking water
and is not a public water system, the standards established under
the Safe Drinking Water Act (SDWA) and the Clean Water Act (CWA)
for drinking water are not applicable to this IRA.'
The standards contained in 40 CFR section 264.94 were not
considered applicable to this treatment system because the
constituents in the influent are not from regulated units. Since
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. -
..
the standards promulgated pursuant to this regulation are identical
to those promulgated under the National Primary Drinking Water
Regulations (NPDW) pursuant to the SDWA, further discussed below,
for the same 14 compounds these standards are not considered
further. .
Consistent with the most recent EPA guidance, the National
Contingency Plan (NCP), 55 Fed. Reg. 8666, Maximum Contaminant
Level Goals contained in the NPDW are not considered either
applicable or relevant and appropriate to apply in the context of
this treatment system. EPA's Tolerances for Pesticide Chemicals
on or in Raw Agricultural Commodities (TPCRAC), 40 CFR Part 180 and
.the Food and Drug Administrations Tolerances for Pesticides in Food
administered by EPA (TPF) are not relevant and appropriate to apply
in the context of this IRA. These standards were developed for
,particular items (e.g., food and crops) which are not subject .to
watering with the effluent from this treatment system, which must
pass through the STP and is subject to the limitations of the NPDES
permit prior to release from RMA.
1-
The Colorado .Basic standards for Groundwater (CBSG) were
reviewed and are not considered applicable to the discharge from
this IRA treatment system, consistent with current EPA guidance as
contained in the NCP. These standards were developed for
groundwater and are not appropriate to apply to the effluent
discharged from this treatment system into the sanitary sewer for
transport to the STP. However, the numerical standards contained
in these recently revised regulations were considered relevant and
appropriate to apply to this IRA treatment system in order to
protect potentially impacted groundwater. The policy stated in
S~ction 3.11.5.C.4 was followed concerning stated detection limits.
I.
~
The Colorado Basic Standards and Methodologies for Surface
Water 3.1.0 (5 CCR 1002-8) (CBSM) were reviewed and not considered
applicable to this IRA treatment system, which does not discharge
effluent into surface waters. The effluent from this IRA treatment
system receives further treatment at the RMA Sewage Treatment Plant
prior to discharge to First Creek. These standards, however, are
considered relevant and appropriate to apply to this IRA treatment
system. The Army has selected the standards at 3.1.11, Table C and
the Agricultural standards from Tables II and III, for compounds
anticipated. to be in the effluent as relevant and appropriate due
to First Creek's designation as Class 2 recreation, Class 2 warm
water aquatic life and Agricultural waters. The policy contained
in CBSM 3.1.14(9) was followed concerning stated detection limits.
Federal Water Quality Criteria (FWQC) were reviewed and
considered not applicable to this IRA since they are guidelines
and not enfQrceable limitations. This IRA will discharge into the
sanitary sewer from transport to the RMA STP for further treatment.
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, ~
The discharge from the STP is limited by the effluent limitations
contained in the NPDES permit, which are developed to protect the
uses of the waterways receiving the discharge.' Consistent with the
Proposed NCP, recent information concerning compounds for which
FWQC exist was reviewed, including Reference Doses (RfD) and Unit
Risk (UR) information, to determine whether more current data
exists than that. reflected in the FWQC. Consistent with the
Proposed NCP, the more recent data was utilized and constituted liTo
Be Considered" (TBC) standards. Under these circumstances, FWQC
were not considered relevant and appropriate to apply in the
context of this IRA where more recent data existed from which a TBC
could be determined. .
In order to provide adequate protection of public health and
the environment, the Army has determined that Maximum Contaminant
Levels (MCLs) established under the Safe Drinking Water Act are
relevant and appropriate to apply within the context of this IRA.
The Army has also determined that the pretreatment standards of 40
CFR S 403.5 issued pursuant to the Clean Water Act are relevant and
appropriate to apply in the context of this IRA. The Army believes
that these limitations, in conjunction with the identified
standards. from the CBSM and CBSG, will protect the functioning of
the STP and result in an effluent which does not represent a
potential risk to human health and the environment. This effluent
will then be further treated at the RMA STP, in conjunction with
other influent streams, and be released pursuant to the NPDES
permit.
Several compounds, at present, only have MCLs proposed or have
other health effects information wi th a high degree of.
creditability available which does not come within the definitions
of applicable or relevant and appropriate requirements. These,
while not ARARs, are considered in the design of the system. These
compounds are listed separately as TBCs, consistent with the NCP.
For some compounds, no ARAR or TBC standard was identified. These
compounds include Bicycloheptadiene, p-chlorophenylmethyl sulfur
compounds, Dithiane, Dimethyldisulfide, Flouroacetic Acid, Isodrin,
Malathion, Oxathiane, Thiodiglycol, Supona, and Vapona. In order
to be protective, the Army will apply any Remedial Action
Objectives later developed in the Final Offpost EA/FS report to the
extent practicable to these compounds.
The chemical-specific ARARs determined relevant
appropriate to apply in the context of this IRA are:
and
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ComDound
Acrylonitrile
Aldrin
Arsenic
Benzene
Cadmium
Carbon Tetrachloride
Chlordane
Chloride
Chlorobenzene
Chloroform
Chromium
Copper
DDT
DDE
1,4-Dichlorobenzene
1,2-Dichloroethane
1,1-Dichloroethylene
Trans-1,2-Dichloroethylene
1,2-Dichloropropane
Dieldrin
Endrin
Ethylbenzene
Fluoride
Hexachlorocyclopentadiene
Lead
Mercury
Parathion
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Vinyl Chloride
Zinc
ARAR Level
Source
2,600
0.1
50
5
10
5
0.1
250,000
300
- 100
50
200
0.1
0.1
75
5
7
7
6
0.1
0.1
680
2,000
49
50
2
0.3
10
2,420'
200
28
5
2
2,000
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
. uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
CBSM
CBSG
40 CFR S 141.11 (b)
40 CFR S 141. 61 (a)
40 CFR S 141.11 (b)
40 CFR S 141. 61 ( a)
CBSM
CBSG
CBSG
40. CFR S 141.12
40CFRS 141.11(b)
CBSM
CBSM
CBSM
CBSG
40 CFR S 14:t. 61 (a)
CBSG
40 CFR S 141. 61 (a)
CBSG
CBSG
CBSM
CBSG
CBSM
CBSG
40 CFR S 141. i1 (b)
40 CFR S 141.11 (b)
CBSM
CBSG
CBSG
40 CFR S 141. 61 (a)
CBSG
40 CFR S 141. 61 (a)
40 CFR S 141. 61 (a)
CBSM
The following standards are TBCs and may be considered in the desiqn
of this treatment system in conformance 'with CERCLA, the Federal
Facility Aqreement and the National Continqency Plan and souqht to be
attained, if practicable:
ComDound
Aldrin
Atrazine
Cadmium
Chlordane
Chloroacetic
Acid
TBC Level
Source
0.002
3
5
2
70
uq/l
uq/l
uq/l
uq/l
uq/l
EPA UR (10(-6»
54 FR 22093
54 FR 22093
54 FR 22093
EPA RfD
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Chloroform 6
Copper 1,300
DDT 0.1
1,2-Dibromo-3-chloropropane 0.2
1,1-Dichloroethane 0.4
1,1-Dichloroethylene 0.06
Dicyclopentadiene 1,050
Dieldrin 0.002
DIMP 600
Ethylbenzene
IMPA
Lead
Methylene Chloride
Methylisobutyl ketone
Parathion
Tetrachloroethylene
1,1,2-Trichloroethane
Toluene
Xylenes (Total)
Zinc
Air Emissions
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
700 uq/l
16,800 uq/l
5
4.8
1,750
210
5
0.6
2,000
10,000
7,000
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
uq/l
",
EPA RfD
53 FR 31516
EPA UR (10(-6»
54 FR 22093
EPA UR (10(-6»
EPA UR (10(-6»
EPA RfD
EPA UR (10(-6»
EPA Health
Advisory (Dee 88)
54 FR 22093
USABRDL Tech.
Rep. 8302 (Oct 84)
53 FR 31516
EPA RfD
EPA RfD
EPA RfD
54 FR 22093
EPA UR (10(-6»
54 FR 22093
54 FR 22093
EPA RfD
The standards contained at 40 CFR Part 50 were reviewed and
determined to be neither applicable nor relevant and appropriate
to this IRA. These standards apply to Air Quality Control Reqions
(AQCR), which are markedly dissimilar from the area that may be
affected by the operation of an air stripper durinq treatment by
this IRA system. The compounds to be treated by this IRA treatment
system are markedly dissimilar to the criteria pollutants regulated
by 40 CFR Part 50 and these ambient air standards are neither
desiqned for nor normally applied to specific emissions sources
such as an air strippinq system, makinq these standards
inappropriate to apply in the context of this IRA. While these
standards do not apply to' the specific emissions from the IRA
treatment system, the system will be controlled and monitored so
that emissions from it do not cause exceedances of ambient air
standards in the AQCR.
The standards contained at 40 CFR Parts 60 and 61 were
reviewed and determined not to be applicable to air stripper
operations conducted as part of the treatment by this IRA system.
These standards apply to specific sources of the listed pollutants.
For example, Subpart E of 40 CFR Part 61 applies to sources which
process mercury ore to recover mercury and other specific
processes, Subpart J of this Part applies to sources which include
equipment which contains or contacts a fluid that is at least 10
percent benzene, by weiqht and the arsenic provisions of Subparts
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N, 0 and P of this part apply to very specific plants, smelters or
facilities. Since the air stripper operations contemplated by this
IRA treatment system are. extremely dissimilar from the processes
described in 40 CFR Part 61 and the liquid concerned is also
extremely dissimilar to the liquid described in Subpart J of 40 CFR
Part 61, these standards were also not considered to be relevant
and appropriate to apply to this IRA, treatment system. However,
as discussed in Section 3 concerning action-specific ARARs, the
Army will apply best practicable control technology to air stripper
emissions.
<'
The provisions contained in 40 CFR Part 60, Subpart Kb will
be considered relevant and appropriate to apply to any storage
vessels with a capacity greater than or equal to 40 cubic meters
that is used to store volatile organic liquids in the context of
this IRA. Only limited provisions of this Subpart affect storage
vessels with a design capacity of less than 75 cubic meters.
The policy contained in OSWER Directive 9355.0-28, dated June
15, 1989 is a TBC for the operation of any air stripper in the
context of this IRA.
The provisions of 5 CCR 1001-10, Regulation 8, Section IV
concerning mercury emissions, limiting such emissions to 2300
grams/five pounds per day, are considered relevant and appropriate
to apply to this treatment system.
8.2. LOCATION-SPECIFIC ARARS
Location-specific requirements set restrictions on acti vi ties,
depending on the characteristics of the site or the immediate
environment, and function like action-specific requirements.
Alternative remedial actions may be restricted or precluded,
depending on the location or characteristics of the site and the
requirements that apply to it.
Paragraph 44.2 of the Federal Facility Agreement provides that
"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 U.S.C. 1531 et seq.), migratory
birds to the extent required by the Migratory Bird Treaty Act (16
U.S.C. 703 et seq.), and bald eagles to the extent required by the
Bald Eagle Protection Act, 16 U.S.C. 688 et seq."
While this provision' is not an ARAR, the statutes cited
therein are ARARs, applicable to this IRA and will be complied
with. Based on where this treatment system will be located the Army
believes that this IRA yill have no adverse impact on any
endangered""species or migratory birds or on the protection of
wildlife habitats. Coordination will be maintained with the u.S.
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~
Fish and wildlife Service to ensure that no such adverse impact
arises from implementation of this IRA.
The provisions of 40 CFR 6.302(a) and (b) regarding
construction that would have an adverse impact on wetlands or be
within a flood plain are considered relevant and appropriate to
apply in the context of this IRA. Based upon where this system
will be located the Army believes that there will be no adverse
impact on wetlands from the construction of this system.
Coordination will be maintained with the U.S. Fish and Wildlife
Service to ensure that any such adverse impacts are avoided or
mitigated.
The regulations at 40 CFR 230 were reviewed and determined not
to be applicable within the context of this IRA because on
discharge of dredged or fill material into waters of the United
States is contemplated. Because these regulations address only
the disposal of such materials into waters of the United States,
which is not contemplated, they are not considered to be relevant
and appropriate to apply in the context of tQis IRA.
The regulations at 33 CFR 320-330 were reviewed and determined
to be neither applicable nor relevant and appropriate because the
IRA treatment system does not involve any of the activities, or
similar to the activities, intended to be controlled by these
regulations as defined in 33 CFR S320.1(b).
8.3
ACTION-SPECIFIC ARARS
Descriotion
Performance, design, or other action-specific requirements
set controls or restrictions on activities related to the
management of hazardous substances, pollutants, or contaminants.
These action-specific requirements may specify particular
performance levels, actions, or technologies as well as specific
levels (or a methodology for setting specific levels) for
discharged or residual chemicals.
. Construction of Treatment System
Air Emissions
On the remote possibility that there may be air emissions
during the course of the construction of this treatment system,
the Army has reviewed all potential ambient or chemical-specific
air emission requirements. As a result of this review, the Army
found that there are, at present, no National or State ambient air
quality standards currently applicable pr relevant and appropriate
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to any of the volatile or semivolatile chemicals in the ground
water found in the area in which construction is contemplated.
In the context of this IRA, there is only a very remote chance
of any release of volatiles or semivolatiles and, even if such a
release did occur,. it would only be intermittent and of very brief
duration (because the activity that produced the release would be
stopped and modified appropriately if a significant air emission
was detected by the contractor's air monitoring specialist). The
Army has significant experience with the construction of extraction
and reinjection wells and has not experienced any problems from air
emissions during construction of such .facilities. This IRA does
not contemplat.e construction of wells, therefore almost eliminating
any chance of air emissions during construction. The construction
of facilities, including any decontamination pads, is not expected
to involve excavation at depths which could result in release of
volatile organics, making any ambient air quality standards neither
relevant nor appropriate to this construction activity. Monitoring
will be conducted pursuant to the site-specific Health and Safety
Plan to ensure that construction activities do not result in
releases of volatile organics which could adversely impact ambient
air quality.
The site-specific Health and Safety Plan will adequately
address these concerns. This plan to be developed for use in this
IRA will detail the site monitoring program and define any
operational modifications to be implemented in the event monitoring
detects specific levels of such emissions. This plan is developed
after the actual construction site has been chosen and is based
upon site-specific information. It will be available for review
later in the IRA process.
,
The National Emissions Standards for Hazardous Air Pollutants
(NESHAPS) were evaluated to determine whether they were applicable
or relevant and appropriate to apply in the context of construction
of this IRA. These standards were not considered applicable
because they apply to stationary sources of these pollutants, not
to construction activity. They were not considered relevant and
appropriate because they were developed for manufacturing
processes, which are significantly dissimilar to the short-term
construction activity contemplated by this IRA.
The provisions of 40 CFR 50.6 will be considered relevant and
appropriate. This standard is not applicable because it addresses
Air Quality Control Regions, which are areas significantly larger
than and different from the area of concern in this IRA. Pursuant
to this regulation, there will be no particulate matter transported
by air from the site that is in excess of 50 micrograms per cubic
meter (annual geometric mean) and 150 micrograms per cubic meter
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-.
(maximum 24-hour concentration) will not be exceeded more than once
per year.
Air stripper Operations
Since an air stripper is used in conjunction with the
treatment system, the Army will treat the provisions of Colorado
Air Pollution Control Regulation No.3, Section IV (D)(3)(a), as
relevant and appropriate and will use best practical control
technology. This regulation is not applicable because the IRA
treatment system will not be a major stationary source, as defined
in that regulation. Also considered relevant and appropriate to
operations are the provisions of S CCR 1001-14, Regulation NO.2,
concerning odor emissions.
The air stripper will be operated so that it will
exceedances of the federal ambient air standards listed
Part SO and state ambient air standards contained in S
14.
not cause
in 40 CFR
CCR 1001-
Worker Protection
The provision of 29 CFR 1910.120 are applicable to workers at
the site because these provisions specifically address hazardous
substance response operations under CERCLA. It should be noted
that these activities are presently governed by the interim rule
found at 29 CFR 1910.120 but that by the time IRA activity
commences at the site, the final rule found at S4 FR 9294 (March
6, 1989) will be operative. (The final rule became effective on
March 6, 1990.)
General Construction Activities
The following performance, design, or other action-specific
state ARARs have ben preliminarily identified by the Army as
applicable to construction activities conducted pursuant to this
IRA:
Colorado Air Pollution Control Commission Regulation No.1,
S CCR 1001-3, Part III (D) (2) (b), Construction Activities:
a.
Applicability - Attainment and Nonattainment Areas
General Requirement
b.
Any owner or operator engaged in clearing or 1'eveling of land
or owner. or operator of land that has been cleared of greater
than one (1) acre in nonatt~inment areas for which fugitive
particulate emissions will be emitted shall be required to use
all available and practical methods which are technologically
-------
feasible and economically reasonable in order to minimize such
emissions, in accordance with the requirements of Section
III.D. of this regulation.
c.
Applicable Emission Limitation Guideline
Both the 20% opacity and the no off-property transport
emission limitation guidelines shall apply to construction
activities: except that with respect to sources or activities
associated with construction for which there are separate
requirements set forth in this regulation, the emission
limitation guidelines there specified as applicable to such
sources and activities shall be evaluated for compliance with
the requirements of Section III.D. of this regulation.
(Cross Reference: Subsections e. and f. of Section III.D.2
of this regulation).
d.
Control Measures and Operatinq procedures
Control measures or operational procedures to be employed may
include but are not necessarily limited to plantinq vegetation
cover, providinq Sl :1thetic cover, waterinq, chemical
stabilization, furrows, compacting, minimizing disturbed area
in the winter, wind breaks, and other methods or techniques.
Colorado Ambient Air Quality Standards,S CCR 1001-14, Air
Quality Regulation A, Diesel-Powered Vehicle Emission Standards
for Visible Pollutants:
a. No person shall emit or cause to be emitted into the
,atmosphere from any diesel-powered vehicle any air
contaminant, for a period qreater than 10 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, with
the exception of Subpart B below.
b. No person shall emit or cause to be emitted into the
atmosphere from any naturally aspirated diesel-powered vehicle
of over 8,500 lbs qross vehicle weight ratinq operated above
',OOO,feet (mean sea level), any air contaminant for a period
qreater than 10 consecutive seconds, which is of such a shade
or density as to obscure an observer's vision to a deqree in
excess of 50% opacity. .
c. Diesel-powered vehicles exceedinq 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.
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-.
d. This standard shall, apply to motor vehicles intended,
designed, and manufactured primarily for use in carrying
passengers or cargo on roads, streets, and highways.
Colorado Noise Abatement Statute, C.R.S. Section 25-12-103:
a. Each activity to which th~s article is applicable shall
be conducted in a manner so that any noise produced is not
objectionable due to intermittence, beat frequency, or
shrillness. Sound levels of noise radiating from a property
line at a distance of twenty-five feet or more therefrom in
excess of the db(A) established for the following time periods
and zones shall constitute prima facie evidence that such
noise is a public nuisance:
~
7:00 a.m. to
next 7:00 D.m.
7:00 p.m. to
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 subsection (1) of this section may
be increased by ten db (A) for a period of not to exceed
fifteen minutes in anyone-hour period.
c. Periodic, impulsive, or shrill noises shall be considered
a public nuisance when such noises are at a sound level of
five db (A) less than those listed in Subpart (a) of this
section.
, '. d. Construc~ion projects shall be subject to the maximum
permissible noise levels specified for industrial zones for
the period wi thin 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
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encompassing noise of the environment from all sources at the
time and place of such sound level measurements.
In substantive fulfillment of Colorado Air Pollution Control
Commission Regulation NO.1, this IRA will employ the 'specified
methods ,for minimizing emission from fuel burning equipment and
construction activities. in substantive fulfillment of Colorado's
Diesel-Powered Vehicle Emission Standards, no diesel motor vehicles
associated with the construction shall be operated in a manner that
will produce emissions in excess of those specified in these
standards.
The noise levels pertinent for construction activity provided
in C.R.S. Section 25-12-103 will be attained in accordance with
this applicable Colorado statute.
Wetlands ImDlicat~
Through estimation of 'the general area where a system would
be located, the Army does not believe that any wetlands could be
adversely affected. However, until a final design is selected and
a final siting decision made, it cannot be definitively determined
that nO,impact on wetlands will occur. If the final site selection
and/or design results in an impact on wetlands, the Army will
review the regulatory provisions concerning wetlands impact and
other appropriate guidance, and will proceed in a manner consistent
with those provisions. Coordination will be maintained with the
U.S. Fish and Wildlife Service concerning any potential impacts on
wetlands.
Removal 0
There are no action-specific ARARs that pertain to the
excavation of soil during the construction of this treatment
system.
EPA is currently developing guidance concerning the Land
Disposal Restrictions (LDR). While guidance is limited, the Army
has not determined that any waste subject to LDR will be present
in the influent treated by this IRA. More guidance is scheduled
to be completed prior to the implementation of this IRA and the
Army will review these as they are released. If it is determined
that a waste subject to LDR is present, the Army will act in a
manner consistent with EPA guidance then in effect for the
management of such as the context of CERCLA cleanup actions.
Although removal of soil from the area where treatment system
will be located is a TBC, not an ARAR, it will be performed in
accordance with the procedures set forth in the Task No. 32
Technical Plan, Sampling Waste Handling (November 1987), and EPA's
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",
July 12, 1985, memorandum reqardinq "EPA Reqion VIII Procedure for
Handlinq of Materials from Drillinq, Trench Excavation and
Decontamination durinq CERCLA RI/FS Operations at the Rocky
Mountain Arsenal." In qeneral, any soils qenerated by excavation
durinq the course of this IRA, either at surface or subsurface,
will be returned 'to the location from which they oriqinated (i.e.,
last out, first in). Any materials remaininq after completion of
backfillinq that are suspected of beinq contaminated (based on
field screeninq techniques) will be properly stored, sampled,
analyzed, and ultimately disposed as CERCLA hazardous wastes, as
appropriate. .
Sludqes which remain from the treatment system will be
similarly manaqed. Such material will be screened and sampled to
determine if it constitutes hazardous waste and also the specific
material will be evaluated to determine whether any LDRs then in
effect apply to its manaqement. Any such material will be either
manaqed on-site pendinq later disposal or sent for off-site
disposal, as determined later in the IRA process when more specific
information is developed. It is not possible until later in the
'. IRA process to specifically identify requirements which will apply
to manaqement of such material, however these are qenerally
discussed below.
For material determined to be hazardous waste, substantive
RCRA provisions are applicable to their manaqement. These
substantive provisions include but are not limited to: 40 CFR Part
262 (Subpart C, Pre-Transport Requirements), 40 CFR part 263
(Transporter Standards), and 40 CFR Part 264 (Subpart I, Container
storaqe) . The specific substantive standards applied will be
determined by the factual circumstances of the accumulation,
storaqe,' or disposal techniques actually applied to any such
material.
Tanks
The Army has not identified in the influent for this IRA a
listed waste, as identified by Subpart D for 40 CFR Part 261. It
is not believed that the influent for this treatment, system will
exhibit any of the characteristics of hazardous waste identified
. in Subpart C of 40 CFR Part 261 due to the low levels of
contaminants anticipated to be contained in the influent.
Therefore, Subpart J of 40 CFR Part 265 is not considered
applicable to this IRA. However, Subpart J of 40 CFR Part 265 will
be considered relevant and appropriate to apply in the context of
this IRA to tanks which are used to store liquid prior to its
treatment by the IRA treatment system.
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8.4
COMPLIANCE WITH THE OTHER ENVIRONMENTAL LAWS
As is evident from the various portions of this document, this
IRA was prepared in substantive compliance with CFR 1502.16 (the
regulations implementing the National Environmental Policy Act of
1969).
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9.0
SCHEDULE -
Immediately following the finalized Interim Response Action
Decision Document (IRADD), the Army will begin preparation of the
design for this facility. The Draft Implementation Document
(design) is scheduled for -release on 11 January 1991.
Mobilization is expected to begin soon thereafter, and the IRA
should be finished by fall of 1991.
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10.0 CONSISTENCY WITH THE FINAL RESPONSE ACTION
The purpose of this IRA is to create a wastewater treatment
facility capable of remediatinq a variety of contaminants in
wastewaters created durinq remedial actions. Althouqh the Final
Response Actions have not been selected at this time, this IRA has
been developed to be consistent with and contribute to their
efficient performance throughout the remainder of the remedial
action process at RMA. .
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11.0 REFERENCES
Consent Decree. June 1988. United States of America, Plaintiff
vs. Shell Oil Company, Inc., Defendant. In the United States
District Court for the District of Colorado. civil Action No.
83-2379.
Waterways Experiment Station, U.S. Corps of Engineers
(Environmental Laboratory), June. 1989. CERCLA Wastewater
Treatment System and Processes Treatability Study.
Federal Facility Agreement. 17 February 1989 by United States
Army, Environmental Protection Agency, Department of Interior,
Agency for Toxic Substances and Disease Registry, Department
of Justice and Shell Oil Company.
.-
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APPENDIX
-------
d
o
JAN 3 0 1990.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
RE GION vm
999 18th STREET - SUITE 500
DENVER, COLORADO 80202-2405
..
Ref:
8HWM-FF
Mr. Donald L. Campbell
Office of the Program Manager
Rocky Mountain Arsenal
ATTN: AHXRM-PM
Commerce City, Colorado 80022-2180
Re: Rocky Mountain Arsenal (RMA)
Proposed Decision Document for
the CERCLA Wastewater Treatment
System Interim Response Action,
December 1989.
Dear Mr. Campbell:
We have reviewed the above referenced document and have the
enclosed comments. We also favor a flexible approach for the
design of this system and wish to comment further as more
information is developed in the design and implementation phases.
.Please contact Linda Jacobson at (303) 294-7093, if you have
questions on this matter.
Sincerely, .
c;J ~~
Conn~ ll-y7Mear s
EPA Coordinator for
. , .:
RMA Cleanup
cc:
Col. Dan Voss, RMA-PMO
Enge Dressler, RMA-PMO,-
Jeff Edson, CDH
David Shelton, CDH
Vicky Peters, CAGO
Major Larry Rouse
Chris Hahn, Shell
George Roe, Shell
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COMMENTS ON THE PROPOSED DECISION DOCUMENT FOR THE
CERCLA WASTEWATER TR~ATMENT SYSTEM INTERIM RESPONSE ACTION
~ . DECErmE1\" 989
1. Pages 8 and 12, the validity of the selection of the
UV/peroxide unit as an organic removal process, rather than a
polishing process, needs to be reevaluated, given the widely
ranging organic concentrations to be encountered. The Final
Assessment response to this question states that determination of
how the UV/oxidation unit will fit into the treatment train will
be addressed in the detailed design phase. However, the Proposed
Decision Document states that UV/oxidation will be used to reduce
loading to the GAC system (pages 8 and 12). Please state the
justification for the implied sequence of treatments.
2. As requested in EPA Comment 4 on the Revised Draft
Assessment, please provide us with a flow diagram for the
existing CWTS, similar to the one provided for'the proposed CWTS
in Figure 1 of the Final Asses~ment, which would be useful in
comparing alternatives. Further, we ,await receipt of the
requested schematic and "details of the wastewater 'feed
system''', pr~mised to us in the response to Comment 4 on the
Assessment.
3. Page 10, please revise the Chronology of Events to include
the receipt of comments from the parties on the Alternatives
Assessment.
4. Page 13, the design must be flexible to allow the treatment
of contaminants other than fluoride by the activated alumina.
Please state whether the activated alumina unit is to be
regenerated or disposed onsite or whether the exhausted media
will be thus managed offsite. If the unit is to be regenerated
onsite, how the spent regenerant viII be handled and ARARs for
that process should be discussed in this document. Please expand
the text to address this.
The response to the above comment in the Final Assessment
states this issue will be covered in the Proposed Decision
Document. The Proposed Decision Document states the issue is
responded to in the Final Assessment. The issue is not addressed
in ~ither document. Please address it in this response.
S. Page 16, the text does not view AWQCs as ARARs. In this
instance, treatment will be followed by surface water discharge.
Unless there are risk-based levels that are more protective,
AWQCs are ARARs as there are biot~ receptors from the discharged
surface water.
-------
o. Page 21, the Alr Quality Control Regions language in the
document needs to be revised to reflect the language developed
for other IRAs.'
7. Page 21, 40 CFR 61 Standards are relevant and appropriate
(not applicable) if contaminants emitted from the stripper are
regulated and exceed threshold quantities. These standards need
to be reevaluated for the quantity and type of compound being
emitted rather than dismissing them on a process evaluation.
8. Page 22,
Manual (OSWER
the Migratory
are ARARs.
per EPA policy, CERCLA Compliance with Other Laws
Directive 9234.1-01), the Endangered Species Act,
Bird Treaty Act, and the Bald Eagle Protection Act
9. Page 28, no "listed wastes" were identified for this IRA.
We do not agree with this assertion. As stated on page S, the
goal of this IRA is to "treat wastewaters resulting from the
assessment and implementation of response actions at the .RMA."
Given the long history of production and the wide variety of
contaminants detected on RMA, it is improbable that there are no
listed wastes to be treated from well development waters or
decontamination waters. We refer you to 40 CFR 261, Parts C and
D, for description and .li~:ting .of characteristic and listed
wastes. We wish to discuss thn;,. matter further and assist in the
. identification of RMA--.listed -wastes and potential impact of the
LDR regulations (eit~ existing or proposed).
10. Page 11, please state the justification for choosing
parallel plateset.ti1.ng... t2.,J;'. the chemical addition/precipitation
treated wastewater. Please state whether sufficient data are.
available to determine a specific type of settling technology at
this point.
. .--
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RESPONSES TO COMMENTS ON THE PROPOSED'
DECISION DOCUMENT AND ON APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS FOR THE CERCLA WASTEWATER
TREATMENT SYSTEM IRA BY THE ENVIRONMENTAL PROTECTION AGENCY
DECEMBER 1989
Specific Comments
1.
Pages 8 and 12, the validity of the selection of the
UV/peroxide 'unit as an organi~ removal process, rather than
a polishing process, needs to be reevaluated, given the widely
ranging organic concentrations to be encountered. The Final
Assessment response to this question states that determination
of how the UV/oxidation unit will fit into the treatment train
will be addressed in the detailed design phase. However, the
Proposed Decision Document states that UV/oxidation will be
used to reduce loading to the GAC system (pages 8 and 12).
Please state the justification for the implied sequence of
treatments.
RESPONSE: The Army will revise the Document, as stated in the
Final Alternatives Assessment, to state that UV/oxidation could
potentially reduce the organic loading on other organic removal
processes (i.e., GAC system and air ,stripping process) or serve as
a polishing process. Determination of how the UV/oxidation unit
will be sequenced in the treatment process train will be part of
the detailed design phase.
2.
'-
As requested in EPA Comment 4 on the Revised Draft Assessment,
please provide us with a flow diagram for the existing CWTS,
similar to the one provided for the proposed CWTS in Figure
1 of the Final Assessment, which would be useful in comparing
alternatives. Further, we await receipt of the requested
schematic and "details of the wastewater I feed system''',
promised to us in the response to Comment 4 on the Assessment.
RESPONSE: A schematic of the existing South Plants Treatment
System and how it teeds into the 170,000 gallon storage tank has
been provided to EPA under separate letter, dated February 23,
1990. This schematic also shows the flow ot wastewater through the
treatment system.
3.
Page 10, please revise the Chronology of Events to include the
receipt of comments from the parties on the Al ternati ves
Assessment.
RESPONSE:
-------
4.
Paae 13, the design must be flexible to allow the treatment
of contaminants other than fluoride by the activated alumina.
Please state whether the activated alumina unit is to be
regenerated or disposed onsite or whether the exhausted media
will be thus managed offsite. If the unit is to be
regenerated onsite, how the spent regenerant will be handled
and ARARs for that process should be discussed in this
document. Please expand the text.to address this.
The response to the above comment in the Final Assessment
states this issue will be covered in the Proposed Decision
Document. The Proposed Decision Document states the issue is
responded to in the Final Assessment. The issue is not
addressed in either document. Please address it in this
response.
RESPONSE: The Army agrees that the design of the activated
alumina unit should be flexible enough to include the treatment of
other contaminants other than fluoride if determined necessary.
For instance, wastewaters which could potentially b~ generated from
the M-1 Settling Ponds and Lime Settling Basins IRAs contain
" arsenic and would need to be treated by the activated alumina unit.
CUrrently, arsenic is being treated by activated alumina in the"
1727 Sump IRA. During the detailed design phase of the project
arsenic and any other contaminants that can be treated by activated
alumina will be addressed.
The preferred approach for handling spent activated alumina is
offsite management as stated in the response to Comment 8 on the
Revised Draft Assessment. The statement will be included in the
Draft Final Decision Document.
-
5.
Paae 16, the text does not view AWQCs as ARARs. In this
instance, treatment will be followed by surface water
. discharge. " Unless there are risk-based levels that are more
protective, AWQCs are ARARs as there are biota receptors from
the discharged surface water.
RESPONSE: Federal Water Quality Criteria (FWQC) were reviewed and
consistent with the proposed NCP, not reflected as ARARs if more
current health information was available. This IRA will discharge
into the sanitary sewer for transport to the RMA STP for further
treatment. The discharge from the STP is limited by the effluent
limitations contained in the NPDES permit.
6.
Paae 2~, the Air Quality Control Regions language in the
document naeds to be revised to reflect the language developed
for other IRAs.
RESPONSE: The Draft Final Decision Document has been revised in
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.~
7.
Paae 21, 40 CFR 61 Standards are relevant and appropriate (not
applicable) if contaminants emitted from the stripper are
regulated and exceed threshold quantities. These standards
need to be reevaluated for the quantity and type of compound
beinq emitted rather than dismissinq them' on a process
evaluation.
RESPONSE: The standards contained in 40 CFR 61 were reviewed and
determined not to be relevant and appropriate to the air stripper
operations, to be utilized as part of the treatment by this IRA
system. The Army will comply with the guidance contained in OSWER
Directive 9355.U-28 concerninq air stripper controls.
Paae 22, per EPA policy, CERCLA Compliance with .Other Laws
Manual (OSWER Directive 9234.1-01), the Endangered Species
Act, the Miqratory Bird Treaty Act, and the Bald Eaqle
Protection Act are ARARs.
RESPONSE: The Endanqered'Species Act, the Miqratory Bird Treaty
Act, and the Bald Eaqle Protection Act are identified as applicable
to this IRA in the Draft Final Decision Document.
paae 28, no "listed wastes" were identified for this IRA. We
do not aqree with this assertion. As stated on paqe 5, the
goal of this IRA is to "treat wastewaters resulting from the
assessment and implementation of response actions at the RMA. II
Given the lonq history of production and the wide variety of
contaminants detected on RMA, it is improbable that there are
no listed wastes to be treated from well development waters
or decontamination waters. We refer you to 40 CFR 261, Parts
C and D, for description and listing of characteristic and
listed wastes. We wish to discuss this matter further and
assist in the identification of RMA listed wastes and
potential impact of the LDR requlations (either existinq or
proposed).
RESPONSE: The Army will work. closely with EPA to identify wastes
which may be restricted from land disposal. . As EPA is aware,
guidance concerning this matter is still under development. If it
is determined that such waste is present, the Army will act in a
manner consistent with the EPA guidance then in effect for the
manaqement of such in the context of CERCLA cleanup actions.
8.
9.
. .;
,...
paae 11, please state the justification for choosing parallel
plate settling for the chemical addition/precipitation treated
wastewater. Please state whether sufficient data are
.available to determine a specific type of settling technoloqy
at this point.
RESPONSE: Sufficient data is not available .to determine a
specific type of settling technoloqy at this point. The text has
been chanqed to reflect that the selection of a specific settlinq
technoloqy will. occur in the desiqn phase and be based upon an
enqineering evaluation and desiqn testinq as necessary.
10.
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-30-90
TUE
17:37 CO~O DEPT OF
HEA~TH MAIN
P.02
-STATE OF COLORADO
COLORADO DEPARTMENT OF HEALTH
4210 East 11th Avenue
Denver. Colorado 80220-3716
Phone (303) 320.8333 .
Telef..:
(303) 322-9076 (Main 8uiJdins/D.n~.rl
(303) 320-1529 (P!armisan Place/O'I'I~erl
(303) 247198 (Crand Junction Re,ion.1 OHice)
January 30, 1990
110\1 Romer
Covernor
Themu M. Vemon. M.D
hKUtiv. DireClor
Hr. Donald Campbell
Office of the Project Manager
Rocky l-tountain Arsenal
AMXRM-FM, Buildina 111
Commerce City, CO 80022-2180
Re:
State Comments on the Proposed Decision Document for the CERCLA
Wastewater Treatment System IRA
Dear Mr. Campbell:
,..
Enclosed are the State's comments on the Proposed Decision Document and
Applicable or Relevant and Appropriate Regulations (ARARs) for the CERCL~
Wastewater Treatment System Interim Response Action (IRA). Based upon the
State's review of this Proposed Decision Document and Arm"v responses to State
. coaments on this .IRA's Alternative Assessment, the State is unwilli~ to
provide to the Army its position on the Army's decision at this time. State
approval or denial of the Army'S decision to construct a new wa.ste~~ter
treatment system on RMA can only be decided once the State receives adequate
responses to numerous technical questions and/or concerns it has previously
provided the Army, and those included in this comment package. In addition,
until the State is provided with sufficient information to adequatel)" evaluate
the chosen alternatives' feasibility in removina contaminants, it is
impossible for the State to concur with the Army's proposed decision on the
chosen Processes.
L.
In the State'. COI1Inents on the Alternative Assessment, important technical
issues such as 1) how the proposed. unit process operations will work; 2) the
waste water treatment plants' potential. impact on the RMA sanitary sewer
plant; 3) the ability of the unit process operations to remove contaminants
known to be in the waste "''B.ter scheduled for treatment under this IRA; 4)
adequate mani tOri~ of the effluent waste 1oI8ters to ensure canpliance with
ARARs; and 5) Army assurances that the methods of treatment Proposed will meet
ARARs were not sufficiently responded to by the Army. Instead, the State was
told that issues such as these would be addressed in the design and
implementation report. These important concerns cannot be inappropriately
postponed to a later date in the process. The State mU$t be supplied. with
adequate data, instead of the "trust us, we'll. work it out later" attitude of
the Arm7. .
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. J~:~:'-'30-'90
2.
3.
TUE
17:3'9 COLO DEPT OF HEALTH MAIN
p.e3
Mr. Donald Campbell
Page 2
January 30, 1990
In addition. to the Alternative Assessment comments \~ich the State believes
must be addressed before the Final Decision Document can be issued' Comments
#3, 4, 5a, Sb, Se, and. 5d), the State has the follo\.:ing concerns:
1.
The Arar:t proposes using the air stripper at the South Plants in this
process. The pilot testing of the air stripper presented in the CERCLA
Waste'-later Treatment System Final Assessment, consisti", of only six
before and after samples of only a few volatile organics, is inadequate
to adequately evaluate the air stripper. The State requests that
additional pilot testina be done prior to making a decision whether or
not to use this stripper. The State cannot evaluate '-'bether this unit
process ",'ill be capable of meeting ARARs for volatile organics without
more pil~t test data.
According to the Decision Document Cp.12) no contaminated residue will
be produced by the air stripping process. This appears to indicate that
no carbon adsorber will be used on the vent gas of the air stripper.
since carbon adsorbers would require regular removal and disposal or
regeneration. However, according to p. 24 of the Decision Document, the
Arm:v is bound under Colorado Air Pollution Control Regulation No.3,
Section IV CD) (3)(a) to use the best practical control technology. The
State believes that a carbon adsorber or a fume incinerator will be
requi.red to comply with this regulation.
~e 13 of the Decision Document states:
"Provisions will be made to route effluent from the treatment
system into storage tanks should additional testing or treatment be
needed. However, upon completion of treatment, effluent discharge
to the sanitary sewer is appropriate."
The State strongly disagrees with this statement, and requests that
testing of eveq batch of wastewater through the system be performed.
The data presentec1 indicates that use of the W /Chemical Oxidation is a
trial and error process. There is no reason to believe that each batch
of wastewater will contain similar chemical characteristics and
concentrations: therefore, conditions 10dlich are optimal for the
treat.ml!nt for some wa.ste~'aters will be ineffectual on other ~ste
streams. Similarly, the State has insufficient data to conclude that
air st.ripping, metals and other inoraanics removal processes will work
for all wastewaters. Furthermore, the testing must be undertaken in a
manner to ensure that ARARs. have been met throuah destruction and.
removal of contaminants and not just throuah dilution '-'bich ma.v result
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.J~N'-3e-90 TUE
r.
-J
~.i
j,
17:41
COLO DEPT OF HEALTH MAIN
P.04
Mr. Donald Campbell
Page 3
January 30, 1990
4.
The State has reviewed the AnDy'S response to our comment number 6 on
the CERCLA Waste~~ter Revised Draft Assessment ~~ich discusses the
"RMA-wide management program. It The State was told that this program
-would a address the disposal of solid residues from this ~~tewater
treatment plant. Neither of the two documents referred to, Task No. 32.
Technical Plan, Sampling Waste Handling nor the EPA Memorandura of Jul:.-
12, 1985 (included as an appendix to "Sampling Waste Handling") is
applicable to -the management and disposal of the CERCLA ~'aS waste~-later
treatment system slu.dges. As the title of the first document suggests,
this technical plan was designed to manage wastes from the RI/FS
samplini proiram.
The other. docunent ci ted by the AnDy is also intended only for the
management of contaminated materials aenerated or disturbed during RI/FS
8Smpling activities. Its title is "EPA Region VIII procedure for
. handling of materials from drilling, trench excavation, and
decontamination- during CERCLA RI/FS operations at the Rocky Mountain
Arsenal." The first paragraph clarifies that "decontamination" in the
title refers to personnel or equipment. Moreover, if the Army intended
to imply that the CERCLA Waste~~ter treatment system sludges will be
managed in the same manner as "-'aStes discussed in Task 32. we believe
that the measurements for the disposal of the sludges are too vague. As
described in "Sampling Wastes Handling: on page 27, Section 3.3.5.5 =
"Miscellaneous drummed \om.Stes (contaminated trash and clothing,
unknowns, etc.) will be kept in long-term storage until the RI/FS
has been completed or until a disposal option becomes available. It
the Decision Documen~ must set forth a specific program for management
and disposal of these sludges, in accordance with State and federal
re~lations. An additional State concern is the inconsistency between
responses to State comments on the Alternative Assessment, and -
statements on pages 11 and 12 of the Proposed Decision Docl.Dnent.
Bullets 2, 3, and 4 of the Pecision Document describe unit process
operations in such a manner as to make the reader believe that each unit
process will be used to treat the influent ~te waters. Statements
such as "ultraviolet liaht/chemical oxidation will be used to destroy or .
reduce the concentrations of a variety of organic contaminants, reducing
the load on the a activated carbon adsorption treatment" and '.Air
Stripping will remove &.n7 residual volatile organics surviving carbon
adsorption treatment" implies that each of these proc~ses will be used
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.1.
- J:'~!~-30-90 TUE
17:43
COLO
DEPT OF
HEALTH
MAIN
P.(;1!5
r:-
Mr. Donald Campbell
Page 4
January 30, 1990
In response to State concerns regarding the monitoring of effluent
characteristics (State comment No. 5c on the Alternative Assessment), ho~ever,
the Army responds, "As the State is at"8.re, each batch of influent t./a5te~ater
will be characterized prior to treatment so that appropriate ~e and
sequencing of unit processes can be defined." TIle Army's response to State
conunent No. 5d on the Alternative Assessments states, '''Ihe desian and
.implementation process that will occur later in the IRA process addresses the
specific methods of treatment and monitoring to be applied..."
These two statements directly contradict the Decision Document. where it is
evident that all unit process operations have alread.v been sequenced.
Has the Army c;:oncluded how the proposed treatment s~'stem will operate to
achieve ARARs? TIle State must be assured that the Army will adequately
attempt to reach ARARs with each batch of influent wastel~ter. usini each unit
process if necessary. In addition, the Arm.v must, as stated above, implement
.an effluent monitorini program for each batch of treated wastewater, 'prior to
:-discharge into the sani tary se~er.
- .
Finally, as the Army is aware, the State continues to have several significant
concerns regarding the discharge of this treated ~~te~,~ter to the sanitary
sewer. The Army is also undoubtedly aware that the State submitted.to the
. EPA n\.m\erous conunents on the proposed NPDES permit for the Arsenal.
....
In its response to the State's comment No. 5d on the Alternative Assessnlent,
. the Army replied that "The NPDES permit, no~ under review and to be issued b,Y
EPA f9r__th~ plant, will establish appropriate discharge limitations that the
Arrn.v is required. to and will comply with." The State questions how the Army
can predict and assure compliance with the NPDES permit without knowledge of
the final dischar"e limitations. As stated in the State's comments to the
proposed NPDES permit, it is inappropriate to ass\.m\e that the CERCLA ~'8ste
water will be treated to the extent necessary to ensure that ~ES limitations
will be met. Such determinations cannot be made prior to field testing of the
system. More importantly, the proposed NPDES permit does not include
. limitations ~or the vast majority of CERCU. waste\~-ater contaminants.
Therefore, it is the State's position that a great deal of additional pilot
testing be performed, using worst-case chemical concentrations, to better
define the capabilities of the unit process operations. Once the pilot test
data is available, and a Final NPDES permit is issued, the Army should then
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,J .~:",,'- 3 a - <;I a
TUE
1'7':4~
COLa
DEF'T OF
HEALTH t'1A I N
F'. ~~6
r -
Mr. Donald Campbell
Page 5
January 30, 1990
The State requests a technical subcommittee meeting in the near future to
discuss its concerns. We believe that this meeting should be held prior to
the issuance of the Final Decision Document for this IRA.
Sincerely
~~~~
U((FJjson
RMA Project Manager
Hazardous Materials and.
Waste Management Division
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Michael Hope
Chris Hahn
Edward McGrath
John Moscato
Connally Mears
Bruce Ray
Tony Truschel
Major Lawrence
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RESPONSES TO STATE COMMENTS FROM THE
STATE OF COLORADO ON THE PROPOSED
DECISION DOCUMENT, DECEMBER 1989
General Comments
1.
Based upon the State's review of this Proposed Decision
Document and Army responses to State comments on this IRA's
Alternative Assessment, the State is unwilling to provide to
the Army its position on the Army's decision at this time.
State approval or denial of the Army's decision to construct
a new wastewater treatment system on RMA can only be decided
once the State receives adequate responses to numerous
technical questions and/or concerns it has previously provided
the Army, and those included in this comment package. In
. addition, until the State is provided with sufficient
information to adequately evaluate the chosen alternatives'
teasibili ty in removiJ:1g contaminants, it is impossible for the
State to. concur with the Army' s proposed decision on the
chosen processes.
In the State's comm~nts on the Alternative Assessment,
important technical issues such as 1) how the proposed unit
process operations will work; 2) the wastewater treatment
plants' potential impact on the RMA sanitary sewer plant; 3)
the ability of the unit process operations to remove
contaminants known to be in the wastewater scheduled for
treatment under this IRA; 4) adequate monitoring of the'
effluent wastewaters to ensure compliance with ARARs; and 5)
Army assurances that the methods of treatment proposed will
meet ARARs were not sUfficiently responded to by the Army.
Instead, the State was told that issues such as these would
be addressed in the design and implementation report. These
important concerns cannot be inappropriately postponed to a
later date in the process. .
RESPONSE: It is regrettable: that the State has chosen not to
endorse the Army's proposed decision to construct a new onsite
wastewater treatment system to replace the present system. As more
Interim Response Actions (IRAs) move into the implementation phase,
the need for greater wastewater treatment capacity and capability
at a centrally located facility is self-evident. In the simplest
of terms, the Army has recognized this need and committed through
the Proposed Decision Document to design, evaluate, construct and
operate a new treatment facility- .
In responding to earlier technical comments from the State., the
Army did not dismiss them as unworthy of a response. Rather, we
attempted' -'to explain that while they were valid questions, they
would be answered in later IRA phases, and that they went far
beyond the basic decision to build a new' treatment facility.
During the preliminary and final engineering d~sign efforts, the
State will be provided sufficient information to adequately
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contaminants. By acceptinq the above decision, the State
forever waivinq its need to judqe the desiqn and operation
facility, but rather is merely concurrinq that this IRA
proceed into the next phase, i.e., desiqnjevaluation.
The CERCLA treatment facility is envisioned by the Army to be a
lonq term project that is likely to be in operation throuqhout the
Arsenal cleanup. As such, the Orqanizations and state will have
the opportunity to review and comment not only durinq this IRA, but
also in the final Record of Decision.
is not
of the
should
In respondinq to the State's comments on the Alternative
Assessment, the Army attempted' to clarify the meaninq of these
comments. Those that deal t wi th the assessment process and
associated work performed were answered. Those that dealt with the
potential desiqn and operation of the facility, i.e., work not yet
completed, were deferred until the appropriate IRA phase was
reached. At no time was the Army attemptinq to circumvent State
concerns or imply that the state had to rely on "trust".
, ,'; !First, ,the Proposed Decision Document specified that five unit
processes should be used in the CERCLA facility. The State had
concerns about exactly how these'processes would be operated. The
Army surmises that these concerns were about sizinq, flowrates,
efficiencies and inter-relationships to other unit processes. To
provide this kind of detail, the Army would have to desiqn,
construct and startup test the facility. Clearly the document that
would contain such information would not be a Decision Document,
but rather an Implementation Document.
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Second, the Army is keenly aware of the facilities potential impact
on the RMA sanitary sewer and its operations wi thin the NPDES
"permit. In response to the State's concerns, the Army believes
that one focus of desiqn should be an investiqation into minimizinq
the discharqe of treated water into the sanitary sewer. Possible
concepts that the Army would like to investiqate are: 1) returninq
treated water that oriqinated as qroundwater to the alluvial
aquifer via one of the existinq qroundwater treatment systems: 2)
recyclinq treated decontamination pad water and usinq that treated
water to decontaminate vehicles aqain: 3) passive 'evaporation of
treated water. Obviously, until the results of such desiqn
investiqations are available,' the Army' s proposed decision to
discharqe to the sanitary sewer system remains unchanqed. If the
results of the desiqn investiqation indicate a need to chanqe the
proposed discharqe decision, the Army would reopen public
comment and the decision process for this sinqle aspect of the
CERCLA facility.
Third, the ability of the chosen unit processes to remove known
contaminants will loqically be addressed in enqineerinq desiqn and
testinq. The State will have several additional opportunities for
review and comment durinq desiqn and construction prior to any
wastewater treatment occurrinq. In terms of the technical basis
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previously used by existinq Arsenal or IRA systems. That unit
process, i.e., metals precipitation, will receive the qreatest
attention in the desiqn phase.
Finally, 'State concerns about Army assurances that compliance with
ARARs will be .met are without basis. Simply put, the Army
recoqnizes that ARARs have to be met to operate an IRA. If the
CERCLA treatment facility cannot achieve ARARs, it cannot be
operated. The state is not at risk in this approach. Rather, the
~rmy assumes risk and financial liability if the CERCLA facility
is improperly desiqned. It is in the paramount interest of the
Army to be "riqht the first time" on this IRA. The State is not
. beinq asked to blindly "trust" the Army. The State is only beinq
asked to work within the IRA process, and to review desiqn and
operational aspects of the IRA as they are developed.
Scecific comment.
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1.
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The Army proposes usinq the air stripper at the South Plants
in this process. The pilot testinq of the air stripper
presented in the CERCLA Wastewater Treatment System Final
Assessment, consistinq of only six before and after samples
of o"ly a few volatile orqanics, is inadequate to adequately
evaluate the air stripper. The State requests that additional
pilot testinq be done prior to makinq a decision whether or
not to use this stripper. The State cannot evaluate whether
this unit process will be capable of meetinq ARARs for
volatile orqanics without more pilot test data.
RESPONSE: The Army's decision made in the Proposed Decision
.~Document was that air strippinq technoloqy would be used in the
~ERCLA treatment facility. The Army did suqqest that the present
~ir stripper at the South Plants may be suitable for use in the
CERCLA treatment facility. This statement by no means guarantees
use of the existinq South Plants air stripper in the CERCIA
treatment facility. Additional enqineerinq evaluation of the
eXistinq air stripper will be performed durinq desiqn. The
enqineerinq evaluation envisioned would potentially include
additional testinq, analysis of equipment capacity, assessinq the
need for vent qas control and a cost comparison for relocation/
modification of the existinq air stripper versus a new unit. A
decision whether to utilize the existinq air stripper or desiqn and
purchase a new unit will be addressed in the desiqn phase as
explained above and would only occur after additional enqineerinq
evaluation. .
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2.
Accordinq to the Decision Document (p. 12) no contaminated
residue will be produced by the air strippinq process. This
appears to indicate that no carbon adsorbers would require
reqular removal and disposal; or reqeneration. However,
accordinq to p. 24 of the Decision Document, the Army is bound
under Colorado Air Pollution Control Requlation NO.3, Section
IV (D)(3)(a) to use the best practical control technoloqy.
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The State strongly disagrees with this statement, and requests
that testing of eve~ batch of wastewater through the system
be performed. The data presented indicates that use of the
UV/Chemical Oxidation is a trial and error process. There is
no reason to believe that each batch of wastewater will
contain similar chemical characteristics and concentrations;
therefore, conditions which are optimal for the treatment of
some wastewaters will be ineffectual on other waste streams.
Similarly, "the State has insufficient data to conclude that
air stripping, metals and other inorganics removal processes
will work for all wastewaters. Furthermore, the testing must
be undertaken in a manner to ensure that ARARs have been met
through destruction and removal of contaminants and not just
through dilution which may result from mixing before, during
and after the process.
RESPONSE: The Statement" referenced by the State was not implying
that effluent discharge to the sanitary sewer would occur without
appropriate analytical testing. The document was revised to
clarify this matter.
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4.
The State believes that a carbon adsorber or a fume
incinerator will be required to comply with this regulation.
RESPONSE: The Army's discussion regarding air stripping
technology as part of the treatment process was based on the
assumption that air stripping would most likely be used only as a
final polishing step following carbon adsorption. If air stripping
technology is used as a polishing step in the treatment process,
stack gas monitoring is likely to show very low concentrations or
no detectable. levels of known contaminants. For that reason,
carbon adsorption or fume incineration for off gas control was not
considered necessary and thus no contaminated residual was
expected. Certainly the Army agrees with use of the best practical
control technology. As discussed in the response to . comment number
1, additional engineering evaluation will be addressed in the
design phase of the project, and if off gassing controls become
necessary, best practical control technology will be used.
3.
Page 13 of the Decision Document states:
"Provisions will be made to route effluent from the
treatJDent system into storage tanks should additional
testing or treatment be needed. However, upon completion
of treatment, effluent discharge to the sanitary sewer
is appropriate.
The State has reviewed the Army's response to our comment
number 6 on the CERCLA Wastewater Revised Draft Assessment
which discusses the IIRMA-wide management program." The State
was told that this program would address the disposal of solid
residues from this wastewater treatment plant. Neither of the
two documents referred to,. Task No. 32, Technical Plan,
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1985 (included as an appendix to "Sampling Waste Handling")
is applicable to the management and disposal of the CERCLA was
wastewater treatment system sludges. As the title of the
first document suggests, this technical plan was designed to
manage wastes from the RI/FS sampling program.
The other docUment cited by the Army is also intended only for
the management of contaminated materials generated or
disturbed during RI/FS sampling activities. Its title is "EPA
Region VIII procedure for handling of materials from drilling,
trench excavation, and decontamination during CERCLA RI/FS
operations at the Rocky Mountain Arsenal." The first
paragraph clarifies that "decontamination" in the title refers
to personnel or equipment. Moreover, it the Army intended to
imply that the CERCLAwastewater treatment system sludges will
be managed in the same manner as wastes discussed in Task 32,
we believe that the measurements for the disposal of the
sludges are too vague. As described in "Sampling Wastes
Handling: on page 27, Section 3.3.5.5:
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"Miscellaneous drummed wastes (contaminated trash and
clothing, unknowns, etc.) will be kept in long-term
storage until the RI/FS has been completed or until a
disposal option becomes available."
The Decision Document must set forth a specific program for
management and disposal of these sludges, in accordance with
State and federal regulations. An additional State concern
is the inconsistency between responses to State comments' on
the Alternative Assessment, and statements on pages 11 and 12
of the Proposed Decision Document. Bullets 2, 3, and 4 of the
Decision Document describe unit process operations in such a
manner as to make the reader believe that each unit process
will be used to treat the influent wastewaters. Statements
such as "ultraviolet light/chemical oxidation will be used to
destroy or reduce the concentrations of a variety of organic
contaminants, reducing the load on the activated carbon
adsorption treatment" and "Air Stripping will remove any
residual volatile organics surviving carbon adsorption
treatment" implies that each ot these processes will be used
in unison with each other.
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In response to State concerns regarding the monitoring of
effluent characteristics (State comment No. 5c on the
Alternative Assessment), however, the Army responds, "As the
State is aware, each batch of influent wastewater will be
characterized prior to treatment so that appropriate use and
sequencing of unit processes can be defined." The Army's
response to State comment No. 5d on the Alternative Assessment
states, "The design and implementation process that will occur
later in the IRA process addresses. the specific methods of
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These two statements directly contradict the Decision
Document, where it is evident that all unit process operations
have already been sequenced.
Has the Army concluded how the proposed treatment system will
operate to achieve ARARs? The State must be assured that the
Army will adequately attempt to reach ARARs with each batch
of influent wastewater, using each unit process if necessary.
In addition, the Army must, as stated above, implement an
effluent monitoring program for ~ batch of treated
wastewater, prior to discharge into the sanitary sewer.
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Finally, as the Army is aware, the State continues to have
several significant concerns regarding the discharge of the
treated wastewater to the sanitary sewer. The Army is
undoubtedly aware that the State submitted to the EPA numerous.
comments on the proposed NPDES permit for the Arsenal.
In its response to the State's comment No. Sd on the
Alternative Assessment, the Army replied that "The NPDES
permi t, now under review and to be issued by EPA for the
plant, will establish appropriate discharge limitations that
the Army is required to and will comply with." The State
questions how the Army can predict and assure compliance with
the NPDES permit without knowledge of the final discharge
limitations. As stated in the State's comments to the
proposed NPDES permit, it is inappropriate to assume that the
CERCLA wastewater will be treated to the extent necessary to
ensure that NPDES limitations will be met. Such
determinations cannot be made prior to field testing of the
system. More importantly, the proposed NPDES permit does not
include limitations for the vast majority of CERCLA wastewater
contaminants.
Therefore, it is the State's position that a great deal of
additional pilot testing be performed, using worst-case
chemical concentrations, to better define the capabilities of
the unit process operations. Once the pilot test data is
available, and a Final NPDES permit is issued, the Army should
then reevaluate whether compliance with the NPDES permit is
viable.
The state requests a technical subcommittee meeting in the
near future to discuss its concerns. We believe that this
meeting should be held prior to the issuance of the Final
Decision Document for this IRA.
RESPONSE: The Army intends to utilize offsite disposal for
management of sludges and residuals generated by operation of the
CERCLA treatment facility. The Draft Final Decision Document will
be revised to clearly set forth the above decision on the ultimate
.disposal of CERCLA treatment facility residuals and sludges. A
detailed program for management of these solid wastes from
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the desiqn phase and provided as part of the Draft Implementation
Document. As always the state will have the opportunity to comment
on the Draft Implementation Document.
The Army has not intentionally sequenced unit process operations
in the Proposed Decision Document. As the state has suqqested, the
Army will, in an attempt to achieve ARARs, use each unit process
as necessary for the treatment of each batch of influent
wastewater. Text chanqes have been incorporated into the Draft
Final Decision Document that should avoid any impression that
,sequencinq of unit process operations has already been decided.
~he Army is aware of the state's concerns reqardinq the discharge
of treated wastewater to the sanitary sewer. Please refer to the
Army's response to the state's qeneral comment.
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RESPONSES TO STATE COMMENTS FROM THE
STATE OF COLORADO ON APPLICABLE
OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR
THE CERCLA WASTEWATER TREATMENT SYSTEM
DECEMBER 1989
General Comments
1.
It is the state's position that these comments are submitted
without waiving the State's legal position on the independent
enforceability of RCRA/CHWMA to this IRA. Liquid received at
the CERCLA Wastewater Treatment System will contain listed
hazardous wastes regulated under the Colorado Hazardous Waste
Management Act (CHWMA) and applicable regulations (6 CCR 1007-
3). Therefore, any treatment or storage or disposal of the
liquids requires a CHWMA permit. Anyon-site disposal site
would be required to meet the requirements for the siting of
a hazardous waste disposal site found in the CHWMA
regulations. Any off-site disposal would have to be
accomplished at a permitted facility; transportation would be
subject to, and have to meet the manifest requirements and the
transporter requirements contained in the CHWMA regulations.
See specific comments below.
RESPONSE: As the state is aware, the Army is proceeding
consistent with CERCLA in the conduct of this IRA. ARARs are
identified consistent with the provisions of CERCLA Section 121,
42 U.S.C. S 962"1.
SDecific Comments
1.
Paae 16. DaraaraDh 2: The Army should identify ARARs for each
contaminant that will be present in the wastewater to be
treated as part of this Interim Response Action. Toward this
end, this paragraph should provide specific sources for its
"list of specific contaminants" that is the basis of this
ARARs analysis, and substantiation for its assertion that this
list represents those contaminants "likely to be found in the
system influent." At a minimum, the Army's ARARs analysis
should include (a) 1,3-Difluorobenzene, as indicated on page
83 of the June 1989 "Draft Final Report, CERCLA Wastewater
Treatment System Needs Assessment and Processes Treatability
Study" and (b), manganese, as indicated on page 89 of the same.
report, and (c) all degradation products from any of the
previously mentioned contaminants that may reasonably be
expected to be found in the wastewater to be treated.
RESPONSE: The list of specific contaminants has been compiled
based upon treatability test data and represents those contaminants
likely "to be contained in the system influent. The Draft Final
Decision Document addresses ARAR and TBC levels to be attained for
listed contaminants. . When no ARAR or TBC level can be identified
for a compound, such as 1,3-Diflourobenzene, no such level is
indicated. The Army can only rely on published material to
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determine ARAR and TBC levels and can not create these without
basis.
2.
Paae 16. DaraaraDh 2: The paragraph seems to imply that the
RMA sewage treatment plant offers a second, more thorough
cleanup of the contaminants found in the CERCLA Wastewater.
The document states, "This proposed IRA treatment system will
discharge treated effluent to the sanitary sewer for eventual
release after further treatment within the RMA sewage
treatment plant. . ." The document states that discharges
from the STP are "strictly regulated" by the RMA NPDES Permit,
currently under revision. However, as documented by the State
comments regarding the proposed NPDES Permit revision, the
permit does not include limitations for many of the
contaminants found in CERCLA wastewater. In addition, neither
the proposed permit nor the Statement of Basis for the permit,
prescribe further treatment of most of the contaminants likely
to be discharged from the Wastewater [t]reatment System. The
approach taken by the Army is contrary to the applicable
regulations under the. NPDES program which requires- that
effluent limitations be established for upstream discharges.
Only by regulating all point-source discharges can EPA ensure
that pollutants are being treated, not merely diluted, to
acceptable concentrations.
As explained in State comments on the proposed permit, it is
the State's position that the Wastewater Treatment System is
not a remedial action selected in compliance with section 121
of CERCLA, and therefore is not exempt from permitting
requirements.
;RESPONSE: As the State is aware, the EPA is currently revising
the NPDES permit for the RMA sewage treatment plant. The effluent
limitations and monitoring requirements will be finally established
by EPA in the near future. The NPDES permit is not intended to
duplicate the. treatment standards contained within this IRA
Decision Document. The extensive analysis and detailed treatment
standards developed pursuant to CERCLA for this IRA provide
limitations for the specific effluent from the IRA treatment
system. It is also clear that many of the contaminants in the
effluent will be treated by the operations conducted by the sewage
treatment. plant. The Army is proceeding pursuant to CERCLA with
this IRA and pursuant to CERCLA Section 121(e), 42 U.S.C. S 9621(e)
no federal, state or local permit is required.
3.
Page 16. Daraara"Qh 5: The text states, "consistent with the
most recent EPA guidance, the Proposed National Contingency
Plan (ltNCP"), 53 Fed. Reg. 51394, 51441, Maximum Contaminant
Level Goals contained in the NPDW are not considered either
applicable or relevant and appropriate to apply in the context
of this treatment system." However, the proposed NCP, which
the Army treats as presently applicable, states, "EPA
recognizes that there may be special circumstances where
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than MCLs, as wi th multiple contaminants or pathways of
exposure. In such cases, EPA will make a site-specific
determination whether risk posed by such multiple contaminants
. or pathways is in excess of 10-4 and, therefore, of the need
for more stringent standards, considering MCLGs, EPA's policy
on use of appropriate risk ranges for carcinogens, levels of
quantification, and other pertinent guidelines." The Army
should therefore consider MCLGs.
RESPONSE: Maximum contaminant level goals (MCLG) were reviewed
after issuance of the final NCP by EPA. Consistent with the
guidance contained in the NCP, no non-zero MCLGswere identified
as being more stringent than the standards identified in the Draft
.Final Decision Document.
4.
paqe 17. DaraaraDh 4: The Army ignores Federal Water Quality
criteria (FWQC) by stating that the TCBs are more "recent".
In its response to the State's Comment 6 on the Draft ARARs
for the CERCLA Wastewater Treatment System, the Army cited the
proposed NCP as authority for disregarding FWQC.
The proposed NCP states, "EPA recommended Rfd' s and cancer
potency factors. . . should be used when an FWQC does not
reflect current information." 53 Fed. Reg. 51394, 51442. The
State is concerned that the Army may have ignored FWQC where
no Rfd's or cancer potency factors existed. The Army should
review the FWQC to detemine[sic] if no more current standard
exists. If the FWQC is the only standard fo~ the specific
contaminant, FWQC must, at a minimum, be met.
CERCLA itself provides that a remedial action is to "require
a level or standard of control which at least
attains. . . water quality criteria established under sec~ion
304 or 303 of the Clean Water Act, where such goals or
criteria are relevant and appropriate under the circumstances
or the release or threatened release." (Section 121(d) (2».
Rather than requiring adherence to water quality criteria,
CERCLA provides that the criteria "at least" be attained.
Overall, CERCLA remedies must "attain a degree of
cleanup. . . and of control of further release at a minimum
which assures protection of human health and the environment."
(See section 121 (d) (1) of CERCLA.) Many of the AWQC for
aquatic life are in fact "lowest observed effect levels,"
meaning that they are not stringent enough to be fully
protective. . Therefore, at least in these. instances, the
cleanup goal should be more stringent than the AWQC.
RESPONSE: The Army bas proceeded consistent with EPA guidance
concerning the use of FWQC in CERCLA cleanup actions. The Army
believes that, consistent with the NCP, the most recent data
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Paae 17. DaraaraDh 5: The text states that Maximum
Contaminant Levels (MCLS) offer "adequate protection of public
health and the environment." The State disagrees that MCLs
are protective enough of public health and the environment.
Many MCLs, arsenic, for example, represent excess cancer risks
significantly greater that lOE-6. Congress acknowledged this
fact and for this reason provided that CERCLA cleanups should
meet MCLGs which are statutorily required to be truly
protective.
RESPONSE: The Army has proceeded consistent with the NCP
concerning thi~ issue. See response to Specific Comment 3.
6.
Paae 18. DaraaraDh \: The text states that the effluent from
the CERCLA Wastewater Treatment System" will be further
treated at the RMA STP." This statement is unsubstantiated
and should be deleted. See the State's specific comment 2.
RESPONSE:
See response to specific comment 2.
7.
Paae 18. DaraaraDh 2: The Army proposes to "apply any
Remedial action Objectives later developed in the Final Off-
post EA/FS report to the extent practicable to these
compounds" The State reserves the right to cOmment on these
objectives once they are identified.
RESPONSE: The State will have the -.opportunity to comment during
the preparation of the Final Off-post EA/FS. .
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.8.
Paae 18. DaraaraDh ~: The State appreciates the Army's
acknowledgment that the Colorado Basic Standards and
Methodologies (CBSM) and Colorado Basic Standards for
Groundwater (CBSG) are relevant and appropriate for this IRA.
Unfortunately, in many instances, the Army has failed to
identify the correct numerical standards pursuant to those
regulations. Instead it has identified the Practical
Quantification Limits (PQLs). PQLs are detection limits which
are based upon technical and economic viability. Since they
are not strictly health-based, they do not represent the
appropriate numbers to be applied as ARARs. The Army must
recognize the standards listed in these regulations, not the
PQLs. (Please note that the report erroneously cites Section
3.11.4.C.4. This citation should be corrected to read:
3.11.S.C.4.) To the extent that USATHAMA Certified Reporting
Limits (CRLs) exceed these standards, efforts must be made to
lower the CRL: in the mean time, effluent concentrations of
these chemicals must be below CRLs.
The following chemicals had PQLs listed instead of the
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Chemical Standard R2L Source
. " Aldrin .002 .1 CBSG
Chlordane .03 CBSG
,-
.004* 10.0 CBSG
1,2- .56 6.0 CBSG
dichloropropane
dieldrin .002 .1 CBSG
*human health qroundwater standard
RESPONSE: The Army believes it has applied the PQLs as discharge
standards, consistent with the Colorado Regulations. The
referenced citation has been corrected.
9.
Paae 18. DaraaraDh 3: The Army' s Report must provide
rationale for its selection of chemical specific ARARs. The
most conservative ARAR from any of the acknowledged regulatory"
sources or "to be considereds" must be desiqnated. CUrrently,
the Army appears to have chosen from the sources arbitrarily.
In addition, since First Creek, as noted by the Army at page
17, is classified for recreational and warm water aquatic as
well as agricultural uses, all of those standards are
applicable, and the most conservative must be incorporated
into the Army' s document. Chemicals for which the Army failed
to desiqnate lower aquatic (life) standards include the
following:
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Chemical Armv ARAR/TBC; Aauatic
chlordane 10/2 .0043
DDT .1 .001
dieldrin .1/.002 .0019
endrin .1 .0023
malathion none .1
parathion 210 .013
chromium 50 chronic: 11(for
hexavalent
chromium which is
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<
.A
copper
200
chronic e=(0.8545
[In (hardness)] -
1.465
mercury
2
chronic 0.1
(aquatic) or FRV
(fish) (6) III: .01
zinc
2000
chronic
(hardness - [200
mg/1]) - e5
(aquatic)
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As indicated above, the ARARs designated by the Army for
metals are not protective of. aquatic life. This is of
particular concern to the state since the proposed NPDES
permit contains no effluent limitations for metals.
RESPONSE: For chlordane, DDT, dieldrin, and endrin; See the
response to Comment 8. Malathion was not listed in the Final Draft
Decision Document because it was not likely to be contained in the
system influent. The Draft Final Decision Document was revised in
. response to this comment.
10.
Page 18. DaraqraDh 3: The Army fails to list any standards
for Methylene Chloride; however, the Cancer Assessment Group
has established a health-based number of 4.8 ug/l which should
be considered.
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:'RESPONSE: The Draft Final Decision Document was revised in
. response to this comment.
.11.
Paqe 18. l;)aragraDh 3: The Army failed to address State
narrative standards which were identified as ARARs. These
narrative standards include:
CBSH section 3.1.11 (c) (color, odor, other nuisance);
CBSM Section 3.1.11 (d) (free from toxics); and
CBSH Section 3.1.8 (antidegradation).
These standards should be applied to any chemicals for which
the state has not promulgated numerical standards. In
particular, application of section 3.1.11 (c) will probably
result in a significantly lower standard for DCPD which is
known to be a highly odoriferous compound.
RESPONSE.:. The Army believes that the application of the many
numerical ARAR standards identified in the Draft Final Decision
Document combined with the design efforts concerning TBCs, operates
to satisfy the state's narrative standards. The Army believes that
no more extensive or efficient water treatment system can be
-------
....
12.
,-
Paae 18. DaraaraDh :t: The Army has designated 100 ug/l as its
ARAR for chloroform. As the State has pointed out innumerable
times, this number is not relevant and appropriate because it
is based Upon the technical feasibility of removing
trihalomethanes from domestic water treatment systems. Such
considerations are irrelevant to this IRA. Since this limit
is not protective of human health, it cannot be designated as
an ARAR. The State has previously proposed .19 ug/l as an
appropriate health-based number.
RESPONSE: A TBC for chloroform has been included based on the EPA
health risk information. Both the identified ARAR and TBC are
below any State standards identified in either the CBSM or CBSG.
,.-
13.
, ..
Paae 20. 9ara~raDh t: The text states that the TBC level for
DIMP is 600 ug/l, .based on an EPA Health Advisory. As the
Army is aware, the State is currently in the process of
promulgating a state~wide DIMP standard. The number is
expected to be significantly lower than the EPA Health
Advisory number. The Army should anticipate the promulgation
of a State standard in the design and implementation of the
treatment system.
RESPONSE: The Army is not aware of the State formally proposing
any statewide DIMP standard. If any such standard is promulgated,
it will be evaluated in the CERCLA process.
. ..
,.
w
14.
Paae 21. DaraaraDh 1: The document states that standards of
40 C.F.R. Part 50, the National Primary and Secondary Ambient
Air Quality Standards, are considered neither applicable no
relevant and appropriate to the IRA. These standards are
clearly ARARs because the area affected by operation of the
IRA is within an Air Quality Control Region. The ~document
should be revised to reflect this.
. ,
The National Primary and Secondary Ambient Air Quality
Standards contained in 40 CFR parts 50.4, 50.8, 50.9, and
50.11 for sulfur oxides, carbon monoxide, ozone, and nitrogen
oxides, respectively, are applicable, regardless of whether
an air stripper is involved.
The federal and state ambient air standards for particulate
matter are also applicable. Section 50.6 of 40 CFR prohibits
particulate emissions th~t would contribute to an exceedance
in the ambient air of 50 micrograms per cubic meter annual
arithmetic mean, or 150 micrograms per cubic meter for any 24-
hour average for no more than one day per year. COlorado's
regulations prohibit particulate emissions that would
contribute to an exceedance in the ambient air of 75
micrograms per cubic meter in any 24-hour period (not to occur
more than once each year). Colorado also has a secondary
standard of 60 micrograms Per cubic meter as a guide to be
used in assessing implementation plans to achieve the 24-hour
-------
The Colorado ambient lead standard is 1.5 micrograms per cubic
meter as a monthly average (see 5 CCR 1001-10, section VI);
and the federal standard is 1.5 micrograms per cubic meter as
a calendar quarter (three month) average. The state standard
is therefore an ARAR.
RESPONSE: The Draft Final Decision Document contains a detailed
analysis of the reasons these ambient air standards are not
applicable or relevant and appropriate to this treatment system.
15.
.. .4
Paae 21. DaraaraDh i: The document states that the standards
contained in 40 CFR Parts 60 and 61 are not ARARs due to the
dissimilarity between the NESHAP sources and the IRA
operations. However, Colorado regulations that are more
stringent that 40 CFR Parts 60 and 61 are ARARs. For example,
the Colorado mercury regulation, 5 CCR 1001-10, Regulation 8,
section IV, applies to "any. . . source using mercury in any
form" and is therefore' more stringent than its federal
counterpart.
RESPONSE: The Draft Final Decision Document contains a detailed
analysis of the reasons why 40 C.F.R. Parts 60 and 61 are not
ARARs. As the State noted in Specific Comment 16, the State
mercury standard is identified as an ARAR.
16.
Paae 21. DaraaraDh 5: Although the document correctly lists
Colorado Regulation 8 concerning mercury emissions as an ARAR,
the document fails to list Colorado Regulation 7 concerning
VOCs.
!J
Any new source of VOC air emissions in an ozone nonattainment
areas such as the Arsenal must use emission controls
representing Reasonably Available Control Technology (RACT)
as determined by the Air POllution Control Division of CDH.
If the Division is unable to determine RACT, then the source
may not emit more than 204 kilograms (450 pounds) of VOCs per
hour or more than 1,361 kilograms (3,000 pounds) of VOCs per
day. (See S CCR 1001-9, Regulation NO.7, sections III and
IV.) Any storage or transfer of VOCs that may be involved in
the air stripper or other aspects of this IRA must also meet
the requirements of 5 CCR 1001-9, Regulation NO.7, Sections
III and IV.
Although the State is commenting on chemical-specific, action-
specific and location-specific ARARs, the State reserves the
right to comment on more specific ARARs regarding emissions
further in the process. When the Army further identifies the
specific processes to be used in the CERCLA Wastewater
. Treatment System. For example, the Army states that the
CERCLA Wastewater Treatment will include a metal precipitation
unit. This does not provide enough information for
-------
RESPONSE: Colorado Regulation No.7 Section III and IV were
reviewed and considered not to be applicable or relevant and
'appropriate to this treatment system. The State may comment on
specific processes during the design phase of this IRA. The VOC
emission levels cited by the State far exceed anticipated emissions
from any air stripper included in this IRA treatment system.
Paae 23 . DaraaraDh 2: It is unclear why the document
references the Army's "significant experience" with the
construction of extraction and reinjection wells. The CERCLA
wastewater treatment system does not involve any extraction
and reinjection wells. This statement should be deleted.
RESPONSE: Wells represent excavation at depth, which increases
the potential for air emission.
17.
18.
Paae 23. DaraqraDh 3: The document states, "[t]this IRA'does
not contemplate construction of wells, therefore almost
eliminating any chance of air emissions during construction."
The implication that only well construction causes air
emission is misleading. The statement should therefore be
omitted. .
RESPONSE:
See response to Specific Comment No. 17.
19.
...;;
Paae 24. DaraqraDh 2: This paragraph should be clarified to
indicate that applicable regulations prohibit the
transportation of particulate matter that will result in an
ambient concentration above amounts set by federal and state
regulations, not simply that there will be no emissions above
these levels. Also, the figures in this paragraph should be
corrected to indicate that the federal regulation (40 CFR
50.6) prohibits contribution to an exceedance of 50 micrograms
per cubic meter annual arithmetic mean, or 150 micrograms per
cubic meter for any 24-hour average for more than one day per
year, and that the state regulation prohibits contribution to
an exceedance of 75 micrograms per cubic meter annual
geometric mean or 160 micrograms per cubic meter in any 24-
hour period (not to occur more than once per year). Colorado
also has a secondary standard of 60 micrograms per cubic meter
as a guide to be used in assessing implementation plans to
achieve the 24-hour standard. (5 CCR 1001-14.)
The wastewater treatment IRA must not violate the provisions
of 5 CCR 1001-4 which prohibit emission of odorous air
contaminants from any single source in excess of specified
limits.
RESPONSE:' The Draft Final Decision document has been revised in
-------
,oJ
20.
Paae 24. DaraaraDh 3: In its section on air stripper
operations, the document fails to list Colorado Regulations
7, for VOCs, and Regulation 8 for mercury.
RESPONSE: The Army will utilize the emission levels for VOCs as
defined in OSWER Directive 9355.0-28, "Control of Air Emissions
from Superfund Air Strippers at Superfund Groundwater Sites." The
Draft Final Decision Document reflects the State's Regulation 8 for
mercury in the chemical-specific ARAR section, as it was in the
Proposed Decision Document.
21.
Paae 24. DaraaraDh 5: The text states that "the provisions
of 29 CFR 1910.120 are applicable to workers at the site
because these provisions specifically address hazardous
substance response operations under CERCLA." Although 29 CFR
1910.120 appears applicable, it is not applicable solely by
reason of specifically addressing hazardous substance response
operations under CERCLA. As stated in Colorado's General
Comment No. 30 and Specific Comment No. 162 concerning the
Oft-post EA/FS, the term "applicable" in the phrase
"applicable or relevant and appropriate requirements" is not
limited to those requirements specifically addressing a CERCLA
site. The NCP's definition of "applicable requirements" is
"those federal requirements that would be leqally applicable,
whether directly, or as incorporated by a federally authorized
state program if the response actions were not undertaken
pursuant to CERCLA section 104 or 106." Thus, "applicable"
actually refers to those requirements that would govern
independently of CERCLA, making the Army's interpretation of
"applicable" directly contrary to the EPA's definition in the
NCp.. The Army's reliance on the proposed NCP is misplaced:
until it becomes final the current NCP is the law and must be
followed.
RESPONSE: The final NCP has been sent to the Federal Register and
the Army is proceeding consistent with that document.
22.
Paae 24. DaraaraDh ~: The Army rejects certain Colorado air
regulations as "applicable" requirements because "they
specifically do not address a remedial action or circumstance
under CERCLA." As stated in the preceding comment concerning
page seven, paragraph one, "applicable" requirements are not
so narrowly defined.
RESPONSE: The Draft Final Decision Document was revised in response
to this comment.
23.
.Paae 27. Daraaraph 14: The text states, "the Army has not
determined that any listed waste subject to LDR [land disposal
restrictions] will be present in the influent treated by this
IRA." The Army should, however,-.~make .such a determination,
first by identifying what contaminants will be present in the
-------
RCRA and the regulations at 40 CFR part 268 apply to each
contaminant.
RESPONSE: The EPA is currently developing guidance concerning the
Land Disposal Restrictions (LDR) and their affect on CERCLA cleanup
activities. If it is determined that a land disposal restricted
waste is present, the Army will act in a manner consistent with EPA
guidance then in effect for the management of such as the context
of CERCLA cleanup actions. The State' s recommendation is more
appropriately conducted during the implementation phase of this
IRA.
24.
Paae 28 . DaraaraDh i: The paragraph deals wi th ARARs
regarding [sic] the disposal of solid residues from the
wastewater treatment plant. The document states that,
[s]ludges which remain from the treatment system will be
similarly managed," referring to the preceeding[sic] paragraph
on soil removal, [sic] However, neither of the two documents
cited in the above paragraph, Task No. 32, Technical Plan,
Sampling Waste Handling nor the EPA Memorandum of July 12,
1985 (included as an appendix to "Sampling Waste Handling")
is applicable to the management and disposal of the CERCLA
wastewater treatment system sludges. As the title of the
fi.rst document suggests, the technical plan was designed to.
manage wastes from the RI/FS sampling program.
The other document cited by the Army is also intended only for
the management of contaminated materials generated or
disturbed during RI/FS sampling activities. Its title is "EPA
Region VIII procedure for handling of materials from drilling,
trench excavation, and decontamination during CERCLA RI/FS
operations at the Rocky Mountain Arsenal." The first
paragraph clarifies that "decontamination" in the title refers
to personnel or equipment. Moreover, if the Army intended to
imply that the CERCLA Wastewater treatment system sludges will
be managed in the same manner as wastes discussed in Task 32,
we believe that the measurements for the disposal of the
sludges are too vague. As described in "Sampling Wastes
Handling: on page 27, Section 3.3.5.5.
?
Miscellaneous drummed wastes (contaminated
trash and clothing, unknowns, etc.) will be
kept in long term storage until the RI/FS has
been completed or until a disposal option
becomes available. .
The Decision Document must set forth a specific program for
disposing of these sludges. This program must comply with
State and federal regulations pertaining to the management of
. hazardous waste. .
RESPONSE: The Draft Final Decision Document outlines how sludges
-------
25.
Paae 28. paraaraDh 3: The text states that for material
determined to be hazardous waste, substantive RCRA provisions
are applicable to their management. The liquid received at
the CERCLA Wastewater Treatment System will contain waste from
RCRA units; therefore, it is the State's position that the
procedural as well as substantive provisions of CHWMA apply.
See General Comment 1. Therefore any treatment, storage or
disposal of the 1 iquids requires a CHWMA permit. In addition,
the solid residue from the wastewater treatment plant must be
treated as a hazardous waste. Any residue from the treatment
of a listed hazardous waste remains a hazardous waste unless
delisted.
RESPONSE: The Army disagrees that administrative. provisions of
the CHWMA apply to this IRA. EPA guidance clearly supports the
Army's position. As stated in the Draft Final Decision Document,
the Army will manage hazardous substances consistent with the EPA
guidance then in effect for such actions at CERCLA sites.
26.
Paae 28. Daraaraph 4: The text states, "It is not believed
that the influent for this treatment system will exhibit any
of the characteristics of hazardous waste identified in
Subpart C of 40 CFR Part 261 due to the low levels of
contaminants anticipated to. be contained in the influent."
The State reiterates its. position that this statement is
unsubstantiated and should therefore be deleted. For example,
numerous groundwater samples contain concentrations of endrin
in quantities qreater than 20 ppb; therefore it would be a
characteristic hazardous waste under 261.24(b).
RESPONSE: Based upon the Army's experience in operatinq the
current South Plants Wastewater Treatment Facility and the
characteristics of the influent to that system, the Army does not
expect that the system influent treated by this IRA will exhibit
the characteristics of hazardous waste identified in Subpart L of
-------
Shell 011 Company
January 30. 1990
Office of the Program Manager for Rocky Mountain Arsenal
ATTN: AMXRM-PM: Mr. Donald L. Campbell
Rocky Mountain Arsenal. Building 111
Commerce City. Colorado 80022-2180
. Dear Mr. Campbell:
./
@
One Sh811 plaza
i' 0 Box 4320
Moulton. ':'exlS ;';'2~O
Enclosed herewith are Shell Oil's comments on Proposed Decision Document.
CERCLA Wastewater Treatment System IRA.
Sincerely.
Mk
. G. E. Roe .
Technical Manager
Denver Site Project
. /ajg
Enclosure
cc: (w/enclosure)
Office of the Program Manager for Rocky Mountain Arsenal
ATTN: AMXRM-PM: Col. Daniel R. Voss
Bldg. E-4460
Aberdeen Proving Ground. MD 21010.5401
Office of the Program Manager for Rocky Mountain Arsenal
ATTN: AMXRM-IA: Mr. Enge Dressler
Rocky Mountain Arsenal. Building III
Commerce City. CO 80022-2180
Office of the Program Manager for Rocky Mountain Arsenal
ATTN: AMXRM-RP: Mr. Kevin T. Blose
Rocky Mountain Arsenal. Building III
Commerce City. CO 80022-2180
-------
cc: Mr. Bradley S. Bridgewater
Department of Justice
c/o Acumenics Research & Technology
999 18th Street
Suite 501, North Tower
Denver, CO 80202
Department of the Army
Environmental Litigation Branch
Pentagon Room rC480
ATTN: DAJA-ELL: Major Lawrence E. Rouse
Washington, DC 20310-2210
Victoria L. Peters, Esq.
Assistant Attorney General
CERClA Litigation Section
1560 Broadway, Suite 250
Denver, CO 80202
Mr. Robert L. Duprey
Director, Hazardous Waste Management Division
U.S. Environmental Protection Agency, Region VIII
One Denver Place
999 18th Street, Suite 500
Denver, CO 80202-2405
Mr. Connally Mears, 8HWM-SR
EPA Coordinator for Rocky Mountain Arsenal
US EPA, Region VIrI, Superfund
999 18th Street, Denver Place, Suite 500
Denver, CO 80202-2405
Mr. Thomas P. Looby
Assistant Director
Colorado Department of Health
4210 East 11th Avenue
Denver, CO 80220
Mr. Jeff Edson
Hazardous Materials and Waste Management Division
Colorado Department of Health
4210 East 11th Avenue
Denver, CO 80220
-------
2.
~
~qE~L ~;~ CQ~MEN~S ON ~RO~O~ED DE~ISI~N D~UMENt
C£RCLA WASTEWATER TR AMENT YST M I
GENERAL COMMENt
Shell concurs with the Army's decision to design, construct, and
operate a new wastewater treatment system, instead of extensive
modifications to the existing system in the South Plants area.
SPECIFIC COMMENT~
1.
Section 1.0 would be clearer if another short paragraph were
added to summarize the decision. The second paragraph
describes the project as installation of a new system, while
the third paragraph then mentions investigation of various
alternatives to expand the existing system. Another
paragraph would then state the decision to proceed with a
new system. Otherwise, the reader does not come to the
final choice until much later.
The. FFA (22.1(m» does not narrowly specify an assessment of
the need for a new facility, as the second paragraph states.
The FFA provides for ". . . a prog~am to treat
wastewater. . . or development of other appropriate
measures for the disposal or reuse of such water." It is
sU9gested that the second paragraph begin with the
appropriate words for the FFA, and then follow with
descriptions of the two basic approaches described
(modification of eXisting, and new facility).
01/30/90
-------
3.
Section 2.0 contains only two sentences (the last paragraph)
that relate to the title "History of the RHA )lastewater
Treatment System." The other three paragraphs should be
deleted, or the section retitled and the last paragraph put
elsewhere. . We suggest the former approach, and the material
in Section 5.0 included. This would supply all the
background information before the objectives and
alternatives sections.
4.
Page 5, third paragraph. The criteria listed do not
to the"specific objectives" of the second paragraph,
rather to the goal stated in the first paragraph.
relate
but
5.
. Page 5, third paragraph, third bullet.
Change "and" to
"or."
6.
Page 6, third paragraph.
"CERCLA."
Insert "IRA objectives and" before
7.
Suggest 4.1 be retitled "Shutdown of Existing System within
South Plants Area" since that is in fact what is described
instead of no action. This alternative would not achieve
the IRA goal, o.r the specific objectives; hence they should
be referenced, not the criteria.
8.
The third paragraph is unclear. Recommend rewording that
more clearly states the offsets. In a nutshell, any
potential for avoiding new capital by the reuse of old
equipment is more than offset by the cost of the new sewer,
and the high costs of both engineering and field work needed
to fit a new design to a mixed assortment of mismatched
equipment. Salvage value is a separate issue that will
presumably be evaluated by the South Plants closure effort;
01/30/90
-------
9.
10.
~
i.e., whether equipment should be cleaned up and sold or
simply scrapped as is, if possible.
Section 4.3 would be better titled "New System Installation"
since it 1s following the other tw~ alternatives just
described and evaluated in 4.1 and 4.2. This would also
avoid the implication that the sequence of the process
alternatives in Section 4.4 is in fact the chosen process
sequence.
In Section '6.1, the discussion of unit processes does not
clarify what process sequence is proposed, and how the
storage tanks fit into the sequence. The Assessment
Document indicated the intent to provide capability for
multiple configurations, including the sequence of the ~hree'
primary organic contaminant removal processes; UV-chemical
oxidation, air stripping, and carbon adsorption. This
Decision Document proposes a specific sequence (UV-chemical
oxidation/carbon adsorption/air stripping> for these three,
while the sequence of the other processes and tankage are
not clarified. . Please add technical and/or economic
rationale for the selection of the sequence indicated or
revise to provide for the flexibility of multiple
configurations.
The following comments relating to the selected unit
processes are offered for your consideration:
.
Of the three processes, air stripping is the least
costly in terms of operating expenditure. Cost
optimization would indicate utilization of this process
as the first treatment step for removal of volatile
organic compounds contained in the wastewater.
01/30/90
-------
01/30/90
Likewise, activated carbon adsorption is traditionally
the second least costly process and should be used as
the second treatment step for removal of the bulk
remaining organic contaminants in the wastewater. The
most costly to operate and maintain, UV/chemical
oxidation, usually finds application as the tinal
polishing step that mayor may not be required
depending on the exact characteristics of the
wastewater.
Aside from economic considerations, the recommended use
of UV/chemical oxidation to precede activated carbon
adsorption seems. questionable because of the lack of
information regarding the effect of residual oxidant. on
the adsorption efficiency of activated carbon.
The poor results obtained from UV/chemical oxidation
pilot treatment of a concentrated wastestream such as
South Plants groundwater also indicates this process to
be a poor choice for use as a primary organic
containment removal process. Without more concrete
information regarding the types of wastes the CERCLA
system may be required to treat, the primary
contaminant removal. processes should exhibit greater
removal efficiencies than was demonstrated by the
UV/chemical oxidation process.
.
The discussion on air stripping (bottom of page 12)
indicates that gas monitoring will be required to
verify compliance with air quality emission standards.
Considering the diversity of wastewaters to be treated
by the system, we suggest adding capability to treat
the stripper offgas if required.
-------
01/30/90
~
.
Chemical precipitation for heavy metal removal will
result in treated water with greater scale forming
potential. To avoid fouling of downstream processes by
scale formation, provisions should be included in
system design to adjust pH and/or add a scale inhibitor
following precipitation, if this is not already
included.
.
Backwashing and handling of used filter bags
potentially exposes operators to organic contaminants
in the wastewater and is labor intensive. In liqht of
this, the use of media filters that do not require
operator contact for backwashing needs further
consideration. Also, as stated, the media filter
backwash wastewater is easily treated through the
clarifier already proposed for inclusion in the
treatment system. Furthermore, the cost for disposal
of used filter bags needs to be considered in the
overall evaluation.
-------
RESPONSES TO COMMENTS FROM SHELL OIL COMPANY
ON THE PROPOSED DECISION DOCUMENT
DECEMBER 1989
General Comments
1.
Shell concurs with the Army's decision to design, construct,
and operate a new wastewater treatment system, instead of
extensive modifications to the existing system in the South
Plants area. .
RESPONSE:
'Comment noted.
Scecific Comment~
1.
Section 1.0 would be clearer if another short paragraph were
added to summarize the decision. The second paragraph
describes the project as installation of a new system, while
the third paragraph then mentions ,investigation of various
alternatives to expand the existing system. Another paragraph
would then state the decision to proceed with a new system.
Otherwise, the reader does not come to the final choice until
much later.
RESPONSE: A paragraph summarizing the decision to build a new
treatment system has been added to Section 1.0 of the Draft Final
Decision Document.
2.
"
The FFA (22.1(m» does not narrowly specify an assessment of
the need for a new facility, as the second paragraph states.
The FFA provides for ". . . a program to treat wastewater
. . . or development of other appropriate measures for the
disposal or reuse of such water." It is suggested that the
second paragraph begin with the appropriate words for the FFA,
and then follow with descriptions of the two basic approaches
described (modification of existing, and new facility).
RESPONSE:
3.
The text has been changed to reflect this comment.
Section 2.0 contains only two sentences (the last paragraph)
that relate to the title "History of the RMA Wastewater
Treatment System." The other three paragraphs should be
deleted, or the section retitled and the last paragraph put
elsewhere. We suggest the former approach, and the material
in Section 5.0 included. This would supply all the background
information before the objectives and alternatives sections.
RESPONSE: All decision documents have typically included general
background information about the Arsenal that goes beyond the IRA
in question. However, Section 2.0 has been renamed "Background"
-------
.t
#
4.
Page 5, third paragraph. The criteria listed do not relate
to the "specific objectives" of the second paragraph, but
rather to the goal stated in the first paragraph.
./
RESPONSE:
The text has been changed to reflect this comment.
5.
Page 5, third paragraph, third bullet.
Change "and" to "or."
RESPONSE: The text has been changed to reflect this comment.
6. Page 6, third paragraph. Insert "IRA objectives and" before
"CERCLA."
RESPONSE: The text has been changed to reflect this comment.
Suggest 4.1 be retitled "Shutdown of Existing System Within
South Plants Area" since that is in fact what is described
instead of no action. This alternative would not achieve the
IRA goal, or the specific objectives: hence they should be
referenced, not the criteria.
RESPONSE: The Army disagrees with this comment. The existing
South Plants treatment system would not be shut down but rather
left in service as is. Deciding whether this objective achieves
the IRA goal and specific objectives is the purpose of the Proposed
Decision Document, but does not warrant dismissal of an alternative
to be considered.
7.
The third paragraph is unclear. Recommend rewording that more
clearly states the offsets. In a nutshell, any potential fo~
avoiding new capital by the reuse of old equipment is more..
than offset by the cost of the new sewer, and the high costs ~
of both engineering and field work needed to fit a new design'
to a mixed assortment of mismatched equipment. Salvage value
is a separate issue that will presumably be evaluated by the
South Plants closure effort: i.e., whether equipment should
be cleaned up and sold or simply scrapped as is, if possible.
RESPONSE: The document has been reworded to more clearly state
the offsets in cost between the unrecovered salvage value and the
new sewer connection. Salvage value must be included when
evaluating an alternative's cost-effectiveness.
8.
section 4.3 would be better titled "New System Installation"
since it is following the other two alternatives just
described and evaluated in 4.1 and 4.2. This would also avoid
the implication that the sequence of the process alternatives
in Section 4.4 is in fact the chosen process sequence.
RESPONSE: The Army disagrees with this comment. The present
title is meant to convey that a decontamination pad is planned as
part of the CERCLA Wastewater Treatment System. We do not feel
that the title implied equipment configuration.
-------
10.
Comments related to Section 6.1 and selected unit processes.
RESPONSE: The text has been changed to reflect flexibility of
multiple configurations in the unit processes. Text that may have
implied a particular sequence of unit processes in the treatment
system has been deleted.
The Army appreciates your suggested wording for the selected unit
processes. Each comment has been considered in revising the
decision document and will be addressed during the design phase of
-------
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E4wud 1 McOndt
January 30, 1990.
Mr. Donald L. Campbell
Office of the Program Manager
for Rocky Mountain Arsenal
ATTN: AMXRM-PM: Mr. Donald L. Campbell
Rocky Mountain Arsenal, Building 111
Commerce City, Colorado 80022-2180
Re:
Shell Oil Company Comments on ARARs Evaluation
for the Proposed Decision Document for the
CERCLA Wastewater Treatment System IRA
Dear Mr. Campbell:
Shell Oil Company ~ubmits the following comments on
the ARARs evaluation in the Proposed Decision Document for the
CERCLA Wastewater Treatment System IRA, dated December 1989.
~
With respect to the chemical-specific ARARs that the
Army has proposed as relevant and appropriate, Shell continues
to object to all ARAR levels based on CAG methodology,
including those for aldrin, benzene, carbon tetrachloride,
DDT, DDE, 1,2-dichloroethane, 1,l-dichloroethylene,
1,2-trichloroethane, trichloroethylene, and vinyl chloride.
Shell further objects to 10-6 risk level for reasons set forth
in earlier comments.
With respect to the ARAR level for acrylonitrile,
Shell questions why the standard should not apply at the point
of discharge to First Creek, since that standard is intended
to protect aquatic life. Shell also questions why the ARARs
levels for DDT, DDE, 1,2-dichloropropane, ethyl benzene,
-------
Hr. Donald L. Campbell
January 30, 1990
paqe 2
be relevant and appropriate since First Creek has not been
desiqnated as a water supply seqment.
Shell objects to standards based on MCLs, because no
one will use qroundwater for drinking at the point where the
Army proposes to apply the standards. These standards cover
all chemicals listed under Table A of the surface water
standards, as well as aldrin, arsenic, benzene, cadmium,
chlordane, chromium, carbon techrachloride, chloroform,
1,4-dichlorobenzene, 1,2-dichloroethane, 1,1-dichloroethylene,
trans-1,2-dichloroethylene, lead, mercury,
1, 1, 1-trichloroethane, trichloroethylene, and vinyl chloride.
For the same reason, we question the chlorobenzene standard,
which is based on the EPA lifetime drinking water health
advisory, and the chloride level, which is based on a
secondary drinkinq water standard.
The standards for copper, fluoride, and zinc should
also apply at the boundary since there will be no exposure
through aqricultural uses internal to the Arsenal boundaries
for the IRA.
Shell objects to the ARAR levels listed for dieldrin
and endrin because they are not based on either surface or -
groundwater standards. Shell supports 0.03 ug/l for dieldrin,
which is based on the World Health Organization guideline for
drinkinq water quality.
With respect to TBCs, Shell has already commented on
its position that "TBCs" are not supported by CERCLA. It also
. -6
objects to UR est1mates at 10 based on CAG methodology.
Shell further disagrees with the use of RfDs as ARAR levels
without conducting a risk assessment, and to proposed
standards being considered for clean up.
The CERCLA Wastewater Treatment
desiqned to treat orqanic compounds, and
these compounds to the current certified
(CRLs) .
System is beinq
will be able to treat
Reportinq Limits
Shell reiterates its comment regarding 40 C.F.R. Part
60, Subpart Kb (storaqe vessels).
The Army states that it-will -apply best practicable
control technoloqy to air stripper emissions, which means that
it will use vapor phase carbon adsorption technoloqy. -
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Mr. Donald L. Campbell
January 30, 1990
Page 3
text at page 8 where the Army indicates that it will only
monitor the stack gases.
Shell reserves the right to comment on how any
guidance regarding the land disposal restrictions would be
applied in the context of this IRA. It hereby incorporates
comments submitted on the Supplemental Notice and Request for
Comment Regarding the Applicability of Land Disposal
Restrictions to CERCLA Response Actions (54 Fed. Reg. 41,566
(Oct. 10, 1989», which were attached to our December 22, 1989
Comments on the Proposed Decision Documents for M-1 Settling
Basins, Motor Pool Area, Rail Classification Area, and Lime
Settling Basins.
Very truly yours,
~ g/h(~ /cwJ
Edward J. McGrath
EJMjlsb
cc: Colonel Daniel R. Voss
Office. of the Program Manager for Rocky Mountain Arsenal-
ATTN: AMXRM-PM . ~
Commerce City, Colorado 80022-2180
Mr. David Parks
Interim Response Division
Office of the Program Manager for Rocky Mountain A~senal
ATTN: AMXRM-IA
Commerce City, Colorado 80022-2180
Mr. Brian L. Anderson.
Technical Operations Division
Office of the Program Manager for Rocky Mountain Arsenal
ATTN: AMXRH-TO
Commerce City, Colorado 80022-2180
Bradley S. Bridgewater, Esq.
Department of Justice
999 - 18th street
suite 501, North Tower
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Mr. Donald L. Campbell
January 30, 1990
Page 4
VIA FEDERAL EXPRESS:
Major Lawrence E. Rouse
U.S. Army Environmental Law Division
655 15th Street, N.W., Suite 930
Washington, DC 20005
Victoria L. Peters, Esq.
Office of Attorney General
CERCLA Litigation Section
1560 Broadway, Suite 250
Denver, Colorado 80202
Mr. Jeff Edson .
Hazardous Materials and Waste Management
Colorado Department of Health -- .:
4210 East 11th Avenue
Denver, Colorado 80220
Division
Mr. Robert L. Duprey ....
Director, Hazardous Waste Management Division
U.S. Environmental Protectio~g'ency, Region VIII
One Denver Place .
999 - 18th Street, Suite 500
Denver, Colorado 80202-240~-
w
--
Mr. Connally Mears, Director
Air and Waste Management Divi~on
U.S. Environmental Protection Agency,
One Denver Place ----
999 - 18th Street, Suite 500
Denver, Colorado 80202-2405
Mr. Thomas P. Looby
Assistant Director
Colorado Department of Health
4210 East 11th Avenue
Denver, Colorado 80220
Region VIII
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...
RESPONSES TO COMMENTS FROM SHELL OIL COMPANY
. ON APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS FOR THE CERCLA WASTEWATER
TREATMENT SYSTEM IRA
DECEMBER 1989
SDecific Comments
1.
With respect to the chemical-specific ARARs that the Army has
proposed as relevant and appropriate, Shell continues to
object to all ARAR levels based on CAG methodology, including
those tor aldrin, benzene, carbon tetrachloride, DDT, DDE,
1,2-dichlorethane, 1,1-dichloroethylene, 1,2-trichloroethane,
trichloroethylene, and vinyl chloride. Shell further objects
to 10.6 risk level tor reasons set forth in earlier comments.
RESPONSE: The Army is aware of Shell's position concerning CAG
methodology and considers this an issue which Shell, if they
desire, should pursue with the appropriate. divisions within EPA
headquarters which have responsibility for developing methodology
for standard setting. The Army will continue to follow the
standards developed by EPA and apply EPA guidance in developing
.approaches to the Arsenal cleanup. The Army believes that use of
a 10.6 risk level, as a point ot departure is consistent with
current EPA guidance, as reflected in the proposed NCP.
2.
With z:espect to the ARAR level tor acrylonitrile, Shell
questions why the standard should not apply at the point of
discharge to First Creek, since that standard is intended to
protect aquatic life. Shell also questions why the ARARs
levels for DDT, DDE, 1,2-dichloropropane, ethylbenzene,
tetrachloroethylene, toluene, and 1, 1, 2-trichloroethane should
be relevant and appropriate since First Creek has not been
designated as a water supply segment.
RESPONSE: The ARAR levels for the compounds identified by Shell
in this comment are all derived from State standards which were
more stringent than any identified Federal standard. The
determination that such standards are relevant and appropriate in
the context of this IRA is consistent wi th EPA guidance as
contained in the NCP.
3.
Shell objects to standards based on MCLs, because no one will
use .groundwater for drinking at the point where the Army
proposes to apply the standards. These standards cover all
chemicals listed. under Table A of the surface water standards,
as well as aldrin, arsenic, benzene, cadmium, chlordane,
chromium, carbon techrachloride, chloroform, 1,4-
dichlorobenzene, 1,2-dichloroethane, 1,1-dichloroethylene,
trans-1,2-dichloroethylene, lead, mercury, 1,1,1-
trichloroethane, trichloroethylene, and vinyl chloride. For
the same reason, we question the chlorobenzene standard, which
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and the chloride level, which is based on a secondary drinking
water standard.
RESPONSE: The Army believes that the approach taken in this IRA
concerning the identification of MCLs and similar state standards
as relevant and appropriate is consistent with the current EPA
guidance concerning this matter as reflected in the NCP.
4.
T~e standards for Copper, fluoride, and zinc should also apply
at the boundary since there will be no exposure through
agricultural uses internal to the Arsenal boundaries for the
IRA.
RESPONSE:
See responses to Comments #2 and '3.
5.
Shell objects to the ARAR levels listed for dieldrin and
endrin because they are not based on ei ther surface or
groundwater standards. Shell supports 0.03 ug/1 for dieldrin,
which is based on the World Health Organization guideline for
drinking water quality.
RESPONSE: The standards identified by Shell are derived from
promulgated state regulations and the Army believes that these
standards are relevant and appropriate in the context of this IRA,
consistent with EPA guidance as contained in the NCP.
6.
With respect to TBCs, Shell has already commented on its
position that "TBCs" are not SUjported by CERCLA. It also
objects to UR estimates at 10. based on CAG methodology.
Shell further disagrees with the use of RfDs as ARAR levels
without conducting a risk assessment, and to proposed
standards being considered for clean" up.
RESPONSE: Shell's comment regarding TBCs is noted and Shell is
referred to previous Army responses to this concern. The UR
estimate of 10.6 is a point of departure utilized consistent with
EPA guidance. See also response to Comment #1.
7.
The CERCLA Wastewater Treatment System is being designed to
treat organic compounds, and will be able to treat these
compounds to the current Certified Reporting Limits (CRLs).
RESPONSE: The CERCLA Wastewater Treatment System will also.
include treatment for inorganics and metals.
8.
Shell reiterates its comment regarding 40 C.F.R. Part 60,
Subpart Kb (storage vessels).
RESPONSE: No response is necessary at this time. More specific
information will be available later in the IRA process.
9.
The Army states that it will apply best practicable control
technology to air stripper emissions, which means that it will
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/
.(
use of this technology is inconsistent with the text at page
8 where the Army indicates that it will only monitor the stack
gases.
RESPONSE: The text on Page 12, last bullet, has been changed to
state: "Stack gas monitoring will be required to verify compliance
with air quality emission standards.. contaminated residue mayor
may not be produced by this process, depending on the need for vent
gas control."
10.
Shell reserves the right to comment on how any guidance
regarding the land disposal restrictions would be applied in
the context of this IRA. It hereby. inc.orporates comments
submitted on the Supplemental Notice and Request for Comment
Regarding the Applicability of Land Disposal Restrictions to
CERCLA Response Actions (54 Fed. Reg. 41, 566 (Oct. 10,
1989», which were attached to our December 22, 1989 Comments
on the Proposed Decision Documents for M-1 Settling Basins,
Motor Pool Area, Rail Classification Area, and Lime Settling
Basins.
RESPONSE: The Army appreciates Shell's provisions of the comments
they provided to EPA concerning the applicability of land disposal.
restrictions to CERCLA response actions. As She;Ll is aware,
guidance in this area is under development. The Army will act
consistent with the EPA guidance then in effect concerning this
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1.
.
.).
United States Department of the Interior
FISH AND WILDLIFE SERVICE
FISH AND WILDLIFE ENHANCEMENT
ROCKY MOUNTAIN ARSENAL FIELD OFFICE
BUILDING 111
COMMERCE CITY, COLORADO 80022.2180
TAJCE
Pm~
AMERKA
.
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IN REPLY REFER TO: .
January 30, 1990
Donald l. Campbell
Deputy Program Manager
Rocky Mountain Arsenal
Building III
Commerce City, CO 80022-2180
Dear Mr. Campbell;
We have reviewed the Proposed Decision Document for the CERClA Wastewater
Treatment System Interim Response Action (IRA) at Rocky Mountain Arsenal. Our
comments are as follows.
.J
We support the reconsideration of modifying the existing South Plant
Treatment System as a viable alternative to meet the IRA objectives. This
alternative would eliminate the need to disturb and contaminate an existing
undisturbed, uncontaminated site. Destruction of existing wildlife habitat
should be avoided when possible. The South Plants area is already
contaminated and would appear to be a logical place to store and process
contaminated wastewater.
-
Regardless of where the facility is placed, the construction of
additional holding tanks raises a concern about the potential breach of a tank
or tanks and release of toxic materials in the wastewater into the surrounding
environment. Apparently, EPA requires that containment capacity (berm
protection) need only protect for breach of one of the. three tanks, using the
tanks located at Basin F as an example. We maintain that if the storage tanks
are located where leakage could move downhill from an area near to or at the
South Plants that complete berm protection for all stored liquids be provided.
. This would prevent the unlikely, nevertheless catastrophic, possibility of all
tanks breaching and flooding into one or more of the lakes.
It is our understanding that transfer of the wastewater treatment plant
discharge to the Sewage Treatment Plant will be via a closed system. Please
correct us if this is an incorrect assumption. We request chemical and
biological assurances that discharge of the wastewater, after it passes
through the Sewage Treatment Plant, will not cause unacceptable acute or
chronic toxjc effects or a toxic response as a result of biomagnification
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Thank you for,providing us with the opportunity to review the subject
document.
Sincerely,
6 GdL-
Donald R. Gober
RMA Coordinator
'-
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RESPONSES TO COMMENTS FROM THE UNITED STATES
FISH AND WILDLIFE SERVICE ON THE PROPOSED DECISION
DOCUMENT, DECEMBER 1989
Comments
We support the reconsideration of modifying the existing South
Plant Treatment System as a viable alternative to meet the IRA
objectives. This alternative would eliminate the need to
disturb and contaminate an existing undisturbed,
uncontaminated site. Destruction of existing wildlife habitat
should be avoided when possible. The South Plants area is
already 'contaminated and would appear to be a logical place
to store and process contaminated wastewater. .
Regardless of where the facility is placed, the construction
of additional holding tanks raises a concern about the
potential breach of a tank or tanks and release of toxic
materials in the wastewater into the surrounding environment.
Apparently, EPA requires that containment capaci ty (berm
protection) need only protect for breach of one of the three
tanks, using the tanks located at Basin F as an example. We
maintain that if the storage tanks are located where leakage
could move downhill from an area near to or at the South
Plants that complete berm protection for all stored liquids
be provided. This would prevent the unlikely, nevertheless
catastrophic, possibility of all tanks breaching and flooding
into one or more of the lakes.
It is our understanding that transfer of the wastewater
treatment plant discharge to the Sewage Treatment Plant will
be via a closed system. Please correct us if this is an
incorrect assumption. We request chemical and biological
assurances that discharge of ,the wastewater, after it passes
through the Sewage Treatment Plant, will not cause
unacceptable acute or' chronic toxic effects or a toxic
response as a result of biomagnification stemming from the
presence of contamination in the discharge water.
RESPONSES: The Army's decision to locate the new CERCLA facility
outside of the South Plants area was based on several factors.
These considerations were evaluated in the decision process against
the habitat concerns you raised. Specifically, the Army's concerns
were based upon potential worker and off-post community exposure
associated with South Plants soil excavation or building renovation
which may be a part of modifying the existing system. Additionally,
the Army was concerned about compatability with South Plants
abandonment in support of eventual cleanup. Ul timately , the
decision to construct a new facility northwest of the intersection
of 7th Avenue and "D" Street was guided by these concerns. This
location is adjacent to the South Plants and the Army will work
with the Fish and Wildlife Service to minimize impacts on wildlife
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With regards to your concerns about secondary
containment, the Army intends to provide complete berm protection
for influent storage tanks. This decision is driven by process
considerations. The segregation of various influent wastewaters
is contemplated as a method of simplifying treatment operations.
Within this concept of segregated influent wastewater, the Army
believes it will. be beneficial to provide separate and complete
berm protection for each storage tank. The same logic does not,
however, apply to effluent storage. The Army does not believe that
leakage of treated water from effluent storage tanks constitutes
as significant a risk. Secondary containment for effluent storage
tanks will therefore be consistent with EPA guidance. We also
believe your concern of catastrophic flooding into the lower lakes
is precluded by the proposed facility location previously
mentioned.
The Army will utilize a closed system for discharge
of treated water. The proposed decision is for discharge to the
sanitary sewer system. In response to State concerns, the Army
will evaluate as part of the design process, alternative disposal
options. Please see the response given to the State I s general
comment.
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