United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R08-93/077
September 1993
x°/EPA Superfund
Record of Decision:
Rocky Mountain Arsenal
-------
50272-101
REPORT DOCUMENTATION 11. REPORT NO. 2. 3. Recipient's Accession No.
PAGE EPA/ROD/R08-93/077
4. Title and Subt"le 5. Report Date
SUPERFUND RECORD OF DECISION 09/23/93
Rocky Mountain Arsenal (Operable Unit 27), CO 6.
Twelfth Remedial Action
7. Author(s) 8. Performing Organization Rept. NO'
9. Performing Organization Name and Address 10 Project TaskIWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Addrass 13. Type 0' Report & Period Coverad
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Supplementary Notes
PB94-964409
16. Abstract (Llm": 200 words)
The Rocky Mountain Arsenal (Operable Unit 27) site is part of the 17,000-acre former
U.S" Army chemical warfare and incendiary munitions manufacturing and assembly plant in
Adams County, Colorado. From the 1950s until late 1969, the Army used the Rocky
Mountain Arsenal (RMA) facility to produce the nerve agent GB (isopropylmethyl-
phosphonofluoridate). Between 1947 and 1982, private industries leased major portions
of the plant facilities to manufacture various insecticides and -herbicides. Since
1970, Army facility operations primarily have involved the destruction of chemical
warfare materials. Because final remediation of the RMA site will take many years to
complete, 13 interim response actions (IRAs) were determined necessary prior to
implementing the final ROD. OU27, which is one of these 13 1RAs, contains 41 inactive
underground storage tanks (USTs) at the RMA. These USTs were used to store fuel and
raw materials used in the manufacturing processes at the facility. With the exception
of the USTs at the motor pool, all of the USTs at the RMA have been inactive since
1982, but they may be releasing hazardous substances to the environment. This ROD
addresses the 41 inactive USTs at the RMA and will facilitate the final remedy for
these USTs by mitigating the continuing release or threat of release of hazardous waste
(See Attached Page)
17. Document Analysis a. Descrlptora
Record of Decision - Rocky Mountain Arsenal (Operable Unit 27), CO
Twelfth Remedial Action
Contaminated Media: soil, debris
Key Contaminants: organics (petroleum)
b. Identifiers/Open-Ended Terms
c. COSATI FieldlGroup
18. Availability Statement 19. Security Class (This Report) 21. No.o'Pages
None 47
20. Security Class (This Page) 22. Price
None
..
(See ANSI-Z39.18)
SH Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerty NTI5-35)
-------
EPA/ROD/R08-93/077
Rocky Mountain Arsenal (Operable Unit 27), CO
Twelfth Remedial Action
Abstract (Continued)
to the environment. The primary contaminant of concern affecting the soil and debris is
petroleum, an organic.
The selected remedial action for this site includes purging and decontaminating the tanks
of any liquids and sludge using high-pressure, hot water, and detergent spray; excavating
around and removing the tanks; transporting the tanks offsite to be cut up and discarded ~
or sold as scrap; sampling and analyzing the soil directly beneath the removed tanks for
contamination; and excavating and shipping any contaminated soil offsite for treatment and
disposal. No present worth or O&M costs were provided' for this remedial action.
PERFORMANCE STANDARDS OR GOALS:
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September 23, 1993
DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOUNTAIN ARSENAL
COMMERCE cm. COLORADO 80022 -1748
REPLY TO
ATTENTION OF:
Interim Response Branch
II
-
Mr. Connally Mears
U.S. Environmental Protection Agency
. Region vm
Mail Code 8HWM-FF
999-18th Street, Suite 500
Denver, Colorado 80202-2466
Dear Mr. Mears:
00;;2.1"
This letter s s to advise you of the finalization of the Decision Documents for
the PCB an UST terim Response Actions at Rocky Mountain Arsenal. Since no
dispute was raise, the Draft Final Decision Documents that were issued on J~e 4,
1993, will serve as the Final Decision Documents. Due tOJypographical errors in the
PCB and UST Draft Final Decision Documents, the Final Decision Documents with the
appropriate white covers and corrections are enclosed. No tecbnical changes were made
to either Draft Final Decision Document. .
Point of contact for this action is Mr. Bruce M. Huenefeld at (303) 289-0239.
Sincerely,
~~
RMA Committee Coordinator
Enclosure
_.
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Copies Furnished:
..
Captain Jonathan Potter, litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022 (w/enel) ~--.-.
Mr. Bradley Bridgewater, U.S. Department of Justice, 999-18th Street,
Suite 501, North Tower, Denver, Colorado 80202 (w/enel)
Mr. Sheldon Muller, Assistant Regional Counsel, U.S. Environmental
Protection Agency, One Denver Place, Suite 500, 999-18th Street,
Denver, Colorado 80202-2405 (w/enel)
Mr. Gene Czyzewski, CDM Federal Programs Corporation, 1626 Cole Boulevard,
Suite 100, Golden, Colorado 80401 (w/enel)
Document Tracking Center, AMXRM-IDT, Room 132, Building 111, Rocky
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TECHNICAL SUPPORT FOR ENVIRONMENTAL
CLEANUP PROGRAMS AT
ROCKY MOUNTAIN ARSENAL
FINAL
ASSESSMENTIDECISION DOCUMENT
UNDERGROUND STORAGE TANK
MONITORING AND REMOVAL
Version 1.0
AUGUST 1993
CONTRACT NO. DAAA05-92-D-0002, DELIVERY ORDER 0001
TASK ORDER #92-07
r .
Prepared by:
EBASCO SERVICES INCORPORATED
James M. Montgomery
International Dismantling & Machinery
Hazen Rese.arch Ageiss Environmental, Inc.
DataChem B.C. Analytical
(, .
Prepared for:
PROGRAM MANAGER'S OFFICE
ROCKY MOUNTAIN ARSENAL
! '
I
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THE INFORMATION AND CONCLUSIONS PRESENTED IN THIS REPORT REPRESENT
THE OFFICIAL POSITION OF THE DEPARTMENT OF THE ARMY UNLESS EXPRESSLY
MODIFIED BY A SUSEQUENT DOCUMENT. THIS REPORT CONSmUTES THE
RELEVANT PORTION OF THE ADMINISTRATIVE RECORD FOR THIS CERCLA
OPERABLE UNIT.
, .
j"
THE USE OF TRADE NAMES IN THIS REPORT DOES NOT CONSmUTE AN OFFICIAL
ENDORSEMENT OR APPROVAL OF THE USE OF SUCH COMMERCIAL PRODUCTS.
-------
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ASSESSMENT /DECISION DOCUMENT
UNDERGROUND STORAGE TANK
MONITORING-AND REMOVAL
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Section
1.0
.
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
.
TABLE OF CONTENTS
INfR..ODUCTION ........................................ . .
BACKGROlJND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.1 DEFINITIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.2 USTs AT RMA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
INfERIMRESPONSE ACTION OBJECTIVE......................
INTERIM RESPONSE ACTION ALTERNATIVES.... ... . . . . . .... .. .
4.1 NO ACTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4.2 REMOVAL OF TANK AND OFF-SIlE DISPOSAL. . . . . . . . . . . . .
4.3 CLEAN AND FILL TANK WIlli INERT MA1ERIAL . . . . . . . . . . .
4.4 CONCLUSIONS......................................
.4.4.1 Overall Protectiveness of Hwnan Health
and Environment, Compliance with ARARs,
and Reduction of 1MV ","""""""""".""
4.4.2 Short- Tenn and Long- Tenn Effectiveness
and Iinplementability . . . . . . . . . . . . . . . . . . . . . . . . . . '.' . .
4.4.3 Cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4.4.4
Sl1II1R1aIY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
APPLICABLE OR RELEVANT AND APPROPRIATE REQT JIREMENTS ..
5.1 UST CLOSURE JUSTIFICATION. . . . . .. . . . . . . . . . . . . . . . . . .
5.2 CLASSIFICATION OF SUBSTANCES IN USTs AT RMA . . . . . . . .
5.3 CLOSURE OF USTs AT RMA . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5.4 PROPER CLOSURE REQUIREMENTS .....................
SUMMARY OF THEJNIERlM.RESPONSE ACTION. . . . . . . . . . . . . . . .
6.1 TANK REMOVAL WORK PLAN .........................
6.2 lffiALllI AND SAFE1Y PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .
REFERENCES
. . . . . . . . . . . . . . . . . . . . . . . . . . . .'. . . . . . . . . . . . . . . .
APPENDIX A: Responses to Comments
1
RMAl0428 819/93 2:36 pn ap
~
1
2
2
3
11
12
12
12
14
15
15
16
16
17
18
18
18
19
20
22
22
22
23
25
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...
.\
-. .
-.
TABLE OF CONTENTS (continued)
FIGURE 2-1
FIGURE 2-2
FIGURE 2-3
North Plants Underground Storage Tanks
South Plants Underground Storage Tanks
Rail Yard Underground Storage Tanks
ii
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...
ARAR
CDH
CERCLA
CFR
DOl
EPA
FFA
GC
IRA
m1
QA/QC
RCRA
RL
RMA
ROD
TMV
UST
. I" I
ACRONYMS AND ABBREVIATIONS
Applicable or Relevant and Appropriate Requirements
Colorado Department of Health
Comprehensive Environmental Response, Compensation and Liability Act
Code of Federal Regulations
Department of the Interior
U.S. Environmental Protection Agency
Federal Facility Agreement
gas chromatograph
Interim Response Action
milliliter
Quality Assurance/Quality Control
Resource Conservation and Recovery Act
reporting limits
Rocky Mountain Arsenal
Record of Decision
toxicity, mobility, or volume
Underground Storage Tank
RMA.0428 7(31/93 10:41 1111 ap
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1.0 INTRODUcnON
The Interim Response Action (IRA) alternatives assessment and decision process for the
underground storage tanks (USTs) at the Rocky Mountain Arsenal (RMA) will be a discrete
clement of the Chemical Process-Related Activities IRA. This UST IRA will be conducted as
part of the IRA process for RMA in accordance with the Federal Facility Agreement (FFA) and
the Technical Program Plan. As specified in the FF A, an IRA must be consistent with and
contribute to the efficient performance of the Final Remedy selected in the Record of Decision
(ROD).
Alternatives have been reviewed based on their overall protectiveness of human health and the
environment; compliance to the maximum extent practicable with Applicable or Relevant and
Appropriate Requirements (ARARs); reduction in toxicity, mobility, or volume; shon-term and
long-term effectiveness;imple~ntability; and cost-effectiveness. The preferred alternative
consists of cleaning imd removing the USTs and disposing of them by cutting them up for scrap.
1
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2.0 BACKGROUND
The Rocky Mountain Arsenal occupies more than 17,000 acres (approximately 27 square miles)
in Adams County, directly northeast of metropolitan Denver, Colorado. The property was
purchased by the United States government in 1942 and was used during World War n to
manufacture and assemble chemical warfare materials, such as mustard and lewisite, and
incendiary munitions. As part of the manufacturing process USTs were installed at .various
locations to provide storage of raw materials, act as catch and overflow basins, supply fuel, and
provide temporary storage while process systems were being cleaned. Since 1970, RMA has
primarily been involved with the destruction of chemical warfare materials. In addition to these
military activities, betWeen 1947 and 1982 major portions of the plant facilities were leased to .
private industries, including Shell Oil Company, for the manufactUre of various insecticides and
herbicides.
In February 1989, an FFA was entered into among the following five federal agencies: the U.S.
Environmental ProteCtion Agency (EP A), the Army, the Department of Interior (001), the
Department of Health and Human Services, and the Department of Justice, which established a
framework for implementing the RMA cleanup program. The FFA specifies 13 IRAs determined
. .
to be necessary and appropriate. Subsequently, the Chemica1Process-Related Activities IRA was
added to the origina113. The remediation of USTs is a discrete element of the Chemical
Process-Related Activities IRA.
2.1 DEFINITIONS
A UST as defined in the Resource Conservation and Recovery Act (RCRA) Part 280 is anyone
tank or combination of tanks (including underground piping connected to the tank) used to .
contain an accumulation of regulated substances, with 10 percent or more of the total volume
(including volume of underground pipes connected thereto) beneath the surface of the ground.
A tank is dermed as a stationary device designed to contain an accum~ation of regulated
substances and is constructed of non-earthen materials, such as concrete, steel, or plastic, that
provides structural support.
2
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"Regulated substances" include: (1) any substance defined in section 101(14) of the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), except any
substance regulated as hazardous waste under the RCRA Subtitle C; and (2) petroleum including
crude oil and any fraction of crude oil that is liquid at standard temperature and pressure. The
term regulated substances includes but is not limited to petroleum and petroleum derived
substances comprised of a complex blend of hydrocarbons derived from crude oil through
processes of separation, inversion, upgrading, and finishing, such as motor fuels, jet fuels,
distillate fuel oil, residual fuel oils, lubricants, petroleum solvents, and used oils.
A "hazardous substance system" is a UST system that contains a hazardous substance defined
in section 101(14) of CERCLA, but not including any substance regulated as a hazardous waste
under RCRA Subtitle C or any mixture of regulated substances and petroleum which is not a
petroleum UST system. A "hazardous waste system" is a UST system that contained or contains
a hazardous waste as defined in Subtitle C of RCRA.
2.2 USTs AT RMA
This IRA includes all USTs used in the manufacturing process of chemicals and munitions
products, operations of facilities, and maintenance of RMA. Tables 2-1, 2-2, 2-3, and 2-4
identify the tanks that are included in this IRA and their classification as petroleum, hazardous
substance/hazardous waste systems, and nonregulated substances. Figures 2-1, 2-2, and 2-3 show
tank locations in North Plants, South Plants, and the Rail Yard.
3
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Table 2-1 Petroleum Underground Storage Tanks Pa ge 1 of 1
Tank Count Tank No. Bld~. No. NorthinJt EastinJt Approximate Size (Gal)
-1 0242D. 242 180180 2183246 1,165
2 0256. 256 180085 2182817 3,500
3 NN0201.. 321 179617 2182910 12.000
4 TOOOI 329 119238 2182156 12.000
5 TOOO2 329 119238 2182167 12.000
6 TOOO2 461 118830 2184538 NA
1 TOOOI 621 111328 2172700 1,100
8 TOOO I. 629 111531 2172900 12,000
9 TOOO2. 629 111531 2172862 12,000
10 T0003. 629 111531 2172826 9,000
II TOOO4. 629 111563 2172196 NA
12 TOOO2 632 116258 2172835 40,000
13 TOOOI. 833 185561 2183405 1,000
14 T0001 836 191312 2184014 NA
15 TOOO4 836 118426 2193821 250
16 T0001 SEC 0901 110652 2172315 415
11 008540 SEC 1201 110581 2183914 1,500
18 NN2504 NN2S04 186089 2187102 NA
~
. Tank registered with state, as a petroleum tank
.. Tank possibly contained hazardous substance during operalion - Tank registered with state as a petroleum tank
... Tank is removed
NA Not Available
-------
" .. 1- --:
Table 2-2 Hazardous SubstancelHazardous Waste Underground Storage Tanks Page 1 of 1
Tank Count Tank No. BldR. No. NorthinR EastinR Approximate Size (GaJ)
1 TOOOI TFO 105 180442 2185291 NA
2 TOOO2 TFOlO5 180466 2185259 NA
3 T1578 TF0105A 180448 2185250 NA
4 Tl605 TFOlO5A 180480 2185402 NA
5 TOOOI TF-108 179920 2184594 NA
6 TI575 0316A 179892 2184099 850
7 TOOO3 0329 179244 2182729 10,000
8 TOOO I 0424 A 179400 2184444 NA
9 TI576 451 179530 2184580 880
10 Tl577 472 179349 2184731 880
II TOOO I 509 180294 2184871 NA
12 Tl582 514 180155 2184565 5.875
13 TOOOI 515 180085 2184148 4,400
14 TI583 515 180091 2184184 4.500
15 TI579 515A 179985 2184156 500
16 TI585 517 180045 2184366 8.565
17 TOOOI 521 179904 2184724 NA
18 -TOOOI 727 180084 2185429 NA
19 TI603 729 180134 2185829 500
20 TOOO5 742A 179598 2185979 NA
21 TOOl I 1803 187895 2187110 6.340
22 TOOO2 1712 187795 2186942 264
NA Not Available
-------
Table 2-3 Nonregulated Underground Storage Tanks
Page 1 of 1
Tank Count
Tank No.
BldR. No.
NorthinJt
EastinR
Approximate Size (Gal)
TOOOI
633
175999
2172998
285
"
-------
l'
Table 2-4 Registered Underground Storage Tanks Page t of t
Tank Count Tank No. BldR. No. NorthinR EastinR Approximate Size (Gal)
I 02420 2420 180180 2183246 111,165
2 0256 256 I 80085 . 2182811 3,500
3 NNT0201 321 119611 2182910 12,000
4 TOOOI 629 111531 2172900 12.000
5 TOOO2 629 111531 2172862 12.000
6 T0003 629 111531 2172826 9,000
1 TOOO4 629 111563 2112196 NA
8 TOOOI 833 185561 2183405 1,000
NA
Not Availabte
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Figure 2-1
North Plants Area Underground Storage
Tanks at Rocky Mountain Arsenol
Rocky Mountain menol
Prepared by: [balco Services Incorporated
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Figure 2-2
Soulh Planls Area Und2rground Slorage
Tanks al Rocky Mounlain Arsenal
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Rod:y Mounta," Arsenal
Prepared by: [boseo Servic.. Incofpololed
-------
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Figure 2-3
Rail Yard Area Underground Storage
Tanks at Rocky Mountain Arsenal
Rocky Mollfl\o;n _nal
-------
3.0 INTERIM RESPONSE ACTION OBJECTIVE
The objectives of an IRA include mitigating the continuing release or threat of release of
hazardous substances or wastes to the environment, providing protection of human health,
facilitating the implementation of the final remedy, and ensuring, to the maximum extent
practicable, compli~ce with legal and regulatory standards, criteria, or limitations.
The alternatives assessment for USTs, as presented in this decision document, assesses whether
immediate action at the UST sites is appropriate, evaluates several IRA alternatives, and
recommends an alternative to mitigate the threat of release from the USTs on an interim basis,
pending determination of the final remedy in the Onpost ROD.
To meet the objectives of an IRA, the identified alternatives were evaluated based on the
following criteria:
. Overall protectiveness of human health and the environment
. Compliance with ARARs to the maximum extent practicable
. Reduction of toxicity, mobility, or volume (TMV)
.
Short-term and long-term effectiveness
. Implementability
. Cost
11
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4.0 INTERIM RESPONSE ACTION ALTERNATIVES
This section evaluates the IRA alternatives for managing USTs at RMA. These alternatives
include:
. No action
. Removal of tank and off-site disposal
. Clean and fill with inert material in place
The IRA alternative assessment concludes that a long-term technical and cost benefit exists if the
USTs arc removed prior to the completion of the ROD. Removing the USTs eliminates the
potential for leakage of contaminants to the environment. In addition, by eliminating extraneous
equipment., the ROD can focus on the contamination of environmental media at RMA.
4.1 NO ACTION
With the no action alternative nothing is done to stabilize or remove the USTs, and could be
easily implemented at no cost. This option docs not comply with ARARs because USTs arc left
in the ground, some containing regulated or hazardous substances and having been inactive for
a period of greater than 12 months. This alternative has no shan-term impacts but also has no
long-term effectiveness, and docs not reduce TMV of contaminants.. Also, these tanks, which
contain hazardous substances, arc a potential threat to human health and the environment if they
leak; therefore the no action alternative is not considered protective of human health and the
environment.
4.2 REMOVAL OF TANK AND OFF-SITE DISPOSAL
This alternative consists of purging all liquids and sludges. from the tank. cleansing the tank with
high-pressure hot water detergent spray, excavating around the tank to expose it., removing the
tank from the ground, and sending the tank off site to be cut-up and discarded or sold as scrap.
After the tank is removed. at least three soil samples would be taken directly beneath the tank.
Should the samples indicate contamination of the soil, the remedial action for petroleum-
. .
12
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contaminated soils would be excavation of the soil. Pettoleum-contaminated soils would then
be transponed to an off-site facility approved to treat such soil.
. .,
If contamination is part of a larger contaminated site that will be addressed as part of the ROD,
it would be more effective to leave those soils in place. If the contamination appears to be an
isolated spot that is not planned to be addressed as part of the ROD, it would be more effective
to excavate those soils during the UST removal program.
This alternative would be protective of human health and the environment and reduce TMV since
the potential for contaminant migration is eliminated by removing the tank. It would achieve
ARARs, is readily implementable with standard consttUction equipment, and is consistent with
the final remedy since pettoleum-contaminated soils would be removed and treated, and soils
contaminated with hazardous wastes or hazardous substances would be remediated as part of the
fmal cleanup. There would be minimal shon':term impacts since the tank contents would be
removed and the tanks cleaned prior to excavation. Worker safety would be addressed through
prudent work practices and the proper use of personal protective equipment. No short-term
impacts on the community would be expected. This alternative would provide long-term
effectiveness because, in the case of petroleum-contaminated soil, the tanks are removed and
contaminated soil is treated immediately. If the soil is contaminated with hazardous substances
or wastes, the soil is capped using a liner and backfill for subsequent remediation during
implementation of the overall RMA cleanup. Costs for this alternative, while higher than the
other alternatives considered, are moderate.
\-.
13
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4.3 CLEAN AND FILL TANK wrm INERT MATERIAL
This alternative consists of purging all liquids and sludges from the tank, cleansing the tank with
high-pressure hot water detergent spray, and filling the tank with inen material. Soil borings
would be required to assess whether or not the tank has leaked and contaminated the surrounding
soil.
If the analyses from the soil borings indicate contamination of the soil, the remedial action for
petroleum-contaminated soils would require removal of the tank prior to excavating the
contaminated soil. Petroleum-contaminated soil would be transported to an off-site facility
approved to treat such soil.
Should soil contamination exist beneath tanks containing hazardous substances or wastes, the
contaminated soil would be left in place and capped, addressed in the Feasibility Study or as an
addendum to the ROD, and remediated as pan of the overall contaminated soils remediation at
RMA.
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This alternative would be protective of human health and the environment and reduce TMV since
the potential for contaminant migration is IJ:JW;mi7ed by removing the remaining liquid in the
tank and the potential for leaching out of the tank is e1;m;nated by filling it with an inen
material. If soil contamination exists, however, the tank would need to be removed before the
contamination can be addressed. Thus, cost savings would not be realized in this case. This
alternative would achieve ARARs, and is readily implementable with standard construction
equipment. It is consistent with the final remedy since petroleum-contaminated soils would be
removed and treated, and soils contaminated with hazardous wastes or hazardous substances
would be remediated as part of the final remedy. There are minimal shan-term impacts since
the tank contents would be removed and the tanks cleaned prior to filling With an inen material.
Worker safety would be addressed through prudent work practices and the proper use of personal
protective equipment. No shan-term impacts on the community would be expected. This
alternative would provide long-term effectiveness because, in the case of petroleum-contaminated
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soil, the tanks are cleaned and filled with an inert material and contaminated soil is treated
immediately. If the soil is contaminated with hazardous substances or wastes, the soil is left as
is for subsequent remediation during implementation of the overall RMA cleanup.
This alternative complicates the remediation of contaminated soil because the tank is still in the
ground. It is less costly to decommission the tank by filling it with inert material, but in the long
term, if contamination is present or the tank impedes the soil remediation plan for RMA, the tank
may have to be removed, thus creating additional costs.
4.4 CONa..USIONS
The three alternatives were evaluated according to the following criteria in Sections 4.1 - 4.3:
. Overall protectiveness of human health and the environment
. Compliance with ARARs
. Reduction of TMV
. Shan-term.and long-term effectiveness
. Implementability
. Cost
The comparative analysis of the alternatives relative to these items is presented below.
4.4.1
~Protecqveness oU!uman~th and Environment. Compliance with ARARs.
and'Reduction of TMV
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Removing the tanks, or cleaning and filling the tanks with inert material provide equal protection
of human health and the environment because all product remaining in the tanks is removed.
These tWO alternatives comply with ARARs because 40 CPR 280.70(c) states that these are the
only tWo permitted closure options for USTs. Both of these alternatives reduce the TMV of
contamination, although tank removal makes it easier to verify the degree of soil contamination
under the tanks, and easier to remcdiatc any contaminated soils. Because product may remain
in some tanks, and contaminated soil may be present beneath some tanks, no action is not as
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proteCtive of human health and environment, it does not achieve ARARs, and it does not reduce
TMV.
4.4.2 Short-Term and~ectiveness and ImDlementabilitv
Shon-term effectiveness-the period of time required to achieve protection and the potential
adverse impacts during implementation-is similar for the tank removal and cleaning/filling
alternatives, although greater worker protection against physical hazards would be required for
tank removal. Neither of these alternatives is expected to adversely impact the environment,
RMA personnel, or the community. Because no action does not involve any remedial activities
there are potential impacts should the no action alternative be selected.
Removal of the tanks has slightly greater long-term effectiveness than the option of cleaning and
filling the tanks with inen material. If contamination exists in the soil beneath the tanks, they
would already have been removed and the petroleum-contaminated soil would be treated
immediately. In addition, removal of the tanks will ensure that their presence does not hinder
the implementation of the overall RMA cleanup. Oean and fill with inert material is a viable
alternative, however, it is not the best alternative for RMA. Both these alternatives are superior
to the no action alternative for long-term effectiveness.
All alternatives are easily implementable. The tank removal and the cleaninglfilling alternatives
are both permanent solutions as required by 40 CPR 300.430 (f) (I). Both the tank removal and
cleaninglfilling alternative can be performed using standard commercially-available equipment.
If contamination is present in soils beneath the tanks, the tank removal alternative would be more
implementable with respect to remediation of these soils.
4.4.3 Cost
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No action is the lowest cost alternative. Removal of the tanks is more costly than cleaning and
filling with inert material, but if contam;nation is present in soils under the tanks or the tanks are
in the way of the overall RMA cleanup, the tanks would have to be removed. The initial cost
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savings provided by cleaning and filling with inen material may be eroded in the long term. and
this alternative could actually cost more than removing the tanks.
4.4.4 Summary
No action is only superior in terms of cost. Tank cleaning and filling is a viable alternative, but
if contaminated soils are found beneath the tanks, this alternative may cost more in the long term
than tank removal. Removing the tanks would prevent any future potential for leakage and
contribute to the efficient implementation of the final remedy. Removal of the tanks is therefore
the prefeITed alternative.
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5.0 APPLICABLE OR RELEVANT AND APPROPRIATE RE UIREMENTS
These ARARs address the removal of USTs prior to the issuance of an ROD for the Onpost
Operable Unit of RMA. The response action described in this document is interim, subject to
further remediation, if required and identified in the Onpost ROD.
5.1 UST CLOSURE JUSTIFICATION -
The USTs at RMA, except for the tanks in the motor pool (629-1-2-3, and -4), have been out of
service since 1982.
Regulation 40 CPR 280-70 requires that USTs, managing petroleum or CERCLA hazardous
substances) and temporarily closed for more than 12 months must be permanently closed. unless
they meet cenain specific performance standards for new UST systems (as defmed in 40 CPR
280.20) or upgrading requirements (as defmed in 40 CPR 280.21). Upgrading existing tanks is
not an option at RMA because there are no future uses planned for the tanks.
Tanks that contain hazardous waste are regulated under 40 CPR 264 Subpart J. Existing
hazardous waste tanks are required to have secondary containment meeting the requirements of
40 CPR 264.193 or must be assessed to-determine if they leak or are unfit for service. The
assessment must be reviewed and certified by an independen~ 'qualified. registered engineer.
According to 40 CPR 264.196, if a tank is unfit for use or has had a leak or spill, it must be
- immediately filled with inert material.
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5.2 CLASSIFICATION OF SUBSTANCES IN USTs AT RMA
A vailab1e information on the contents of the USTs at RMA indicates - that the tanks currently
contain peuoleum products, CERCLA hazardous substances, RCRA hazardous wastes, and non-
regulated substances. Tanks containing peuoleum products and CERCLA hazardous substances
are normally subject to UST regulations in 40 CPR Part 280. However, because many of the
tanks have been out of service for ~ore than 10 years, the materials remaining in the tanks can
be considered discarded materials, and therefore RCRA solid waste. The contents of the tanks
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must be analyzed to determine if the tanks that contain petroleum productS, CERCLA hazardous
substances, or unregulated substances also contain RCRA hazardous wastes. This determination
must be made using the information contained in 40 CFR 261 Subparts C and D. Hazardous
waste tanks are subject to regulation under RCRA according to 40 CFR 264 Subpart J.
5.3 CLOSURE OF USTs AT RMA
If analysis of the materials in the USTs reponedly holding petroleum or CERCLA hazardous
substances indicates that the material is not a RCRA hazardous waste, the tanks may be
permanently closed under the requirements of 40 CPR 280.71. This closure requires the removal
of all liquids and sludges from the tank. The tanks may be pennanently taken out of service by
either removing th~ tank from the ground or filling the tank with inen solid material. Before
permanent closure is complete, sampling to measure for the presence of a release where
contamination is mostly likely to occur at a UST site must be conducted according to 40 CPR
280.72. If contaminated .;oils or groundwater, or free product is discovered, corrective action
must be taken in accordance with 40 CPR 280 Subpart F and Colorado UST Regulations CRS
25-18, 7"CCR 1101-14, and 6 CCR 1007-5. Corrective actions may include, but not be limited
to, the fonowing:
. Remove regulated substance to prevent further release
. Prevent further migration of release into surrounding soils and groundwater
. Monitor and mitigate fire and safety hazards posed by vapors or free product
. Remedy hazards posed by exposed contaminated soil
. Remove free product from the soil or groundwater to minimize spread of contamination
. Conduct investigation of release extent if
- Free product is found
- Groundwater contamination is known or suspected
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. Clean up contaminated soil and groundwater
. Implement cOITective action plan
Colorado UST regulations (CRS 25-18, 7 CCR 1101-14, and 6 CCR 1007-5) are essentially the
same as the requirements in 40 CFR Part 280.
In portions of RMA (e.g., South Plant and North Plant) where final remedial actions may include
removal of soil and groundwater contamination, a waiver of the soil and groundwater corrective
action requirements in 40 CFR 280 Subpart F may be invoked as provided in CERCLA Section
121 (d)(4)(A). A separate waiver must be invoked for each ARAR that will not be attained. In
those areas where the waiver is requested, the known soiVgroundwater contamination should be
similar to the contents of the UST. Outside those areas where remedial actions are planned, soil
and groundwater remediation will take place as part of the UST closure procedures.
The closure requirements of 40 CFR 264.197 are applicable for tanks containing hazardous
wastes and for tanks reportedly holding petroleum or hazardous. substances that should be
classified as RCRA hazardous waste based on chemical analysis. All waste and equipment will
be managed as hazardous waste, including contaminated soil. If it is not possible to remove all
contaminated soil from a hazardous waste tank site, post-closure care of the site as a landfill will
be required.
5.4 PROPER CLOSURE REQUIREMENTS
Sampling of soil (and possibly groundwater) must be completed at the location where
contamination from the UST is most likely to be present, as required in 40 CFR 280.72(a), before
the UST site can be considered closed. If sample analysis indicates no media contamination is
present, the UST site isconsidcred closed. If contamination is detected in the soil or
groundwater and the UST site is located in an area where no CERCLA remedial action is
proposed, corrective action must be taken to bring the contamination to acceptable levels. If the
media are contaminated and the UST site is located in an area where CERCLA remedial actions
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are proposed. soil and groundwater cleanup activities related to the UST can be part of the final.
remedial action under a waiver provided for by CERCLA Section 121(d)(4)(A).
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6.0 SUMMARY OF THE INTERIM RESPONSE ACI'lON
Removal of the USTs is the chosen alternative. This is an easily implementable and
cost-effective solution that is protective of human health and the environment and that provides
long-term effectiveness because the threat of release from USTs is eliminated.
All USTs identified in Tables 2-1. 2-2. and 2-3 at RMA will be removed under this IRA. The
work is to be implemented in phases. Phase 1 is the removal of the eight USTs registered with
the State of Colorado as petroleum storage tanks. Phase 2 is the removal of the remaining
petroleum storage tanks not registered with the State of Colorado. The remaining phases will
be implemented when other work in these areas has been completed, thus allowing the removal
of the USTs.
6.1 TANK REMOVAL WORK PLAN
A work plan will be developed that outlines the steps' to be taken in removing each underground
storage tank. This plan will include guidelines on purging the remaining liquids in the tank.
cleaning the tank, and disposing of fuel product, cleaning water. piping, tank, and contaminated
soil. The plan will follow the state regulations regarding soil sampling tank removal.
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6.2 HEALTIl AND SAFETY PLAN
A Health and Safety Plan has been developed for the prevention of occupational injuries and
illnesses during field activities at RMA. This plan addresses health and safety requirements of
contractors and their authorized subcontractors. Compliance with this plan will be compulsory.
and the contractors will be responsible for self-enforcement and compliance. The Health and
Safety Plan was developed taking into consideration known hazards as well as potential risks.
Comprehensive environmental monitoring and site-specific personal protection are combined in
an effort to best protect workers. A site-specific Health and Safety Plan for work to be
performed during implementation of this IRA will be developed.
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7.0 INTERIM RESPONSE ACTION PROCESS
With respect to the IRA for the Process Equipment Removal, Addendum 003: UST Removal
and Monitoring at RMA, the IRA process for the USTs is summarized as follows:
. The organizations and DOl shall have the opportunity to participate, at the RMA
Committee level, in the identification and selection of ARARs that may be applicable to
IRAs.
. The Army shall issue the proposed Decision Document for the UST Removal IRA, for
a 30-day public comment period. The proposed Decision Document is supponed by an
administrative record.
. Promptly after the close of the comment period. the Army shall transmit to the other
organizations, DOl, and the State a Draft Final IRA Decision Document for the UST
Removal.
. Within 20 days after the issuance of a Draft Final IRA Decision Document for the UST
Removal, an organization (including the State if it has agreed to be bound by the Dispute
Resolution process, as required by the FF A, or DOl under the provisions set forth in the
FFA) may invoke Dispute Resolution.
. Af~ 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 IRA Decision Document to the other organizations, the DOl, and the State. The
Army shall also notify the public of the availability of the Final IRA Decision Document
with the supporting administrative record. Only preliminary design work for the IRA may
be conducted prior to the issuance of the Final IRA Decision Document.
.
The IRA Decision Document for the UST RemOval will be subject to judicial review in
accordance with Section XXXIX of the FFA except where such review is barred by
Sections 113 and 121 of CERCLA, as amended, 42 U.S.C. Sections 6913 and 9621.
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. Following issuance of the final IRA Decision Document, the Army shall be the Lead
pany responsible for designing and implementing the IRA in conformance with the
Decision Document. The Army shall issue draft IRA Implementation Letters to the DOl,
the State, and the other organizations for review and comment. The draft Implementation
Letter shall include a final workplan, the identified tanks, a cost estimate, if applicable,
and IRA deadlines for implementation.
. If any organization (including the State) or the 001 believes that the IRA is being
designed or implemented in a manner that will not meet the objectives for the IRA set
forth in the Final IRA Decision Document, or is otherwise not being properly
implemented, it may so advise the others and shall recommend how the IRA should be
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properly designed or implemented. Any organization (including the State, if it has agreed
to be bound by the process of Dispute Resolution, as required by the FFA, or the DOl
under the circumstances defined in the FFA) may invoke Dispute Resolution to resolve
the disagreement.
. As Lead Party for the design and implementation of this IRA, the Army shall issue the
final Implementation Letters, as described above, and shall be responsible for
implementing any particular phase of this IRA in accordance with the Respective IRA
Implementation Letter. It is estimated that this IRA will be implemented in at least three
phases. The first phase would be the removal of eight USTs registered with the State of
Colorado as petroleum storage tanks. This would be followed by a second phase that
addressed remaining petroleum storage tanks. Following the first tWo phases, a third
phase would be implemented to address USTs that were used to contain hazardous
substances.
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8.0 CONSISTENCY WITH THE FINAL REMEDIAL ACTION
The FFA states that all IRAs shall "to the maximum extent practicable. be consistent with and
contribute to the efficient performance of Final Response Actions" (paragraph 22.5).
The selected alternative, removing the USTs, will be consistent with and contribute to the
efficient performance of any Final Response Action selected in the Onpost ROD.
25
RMM)428 7131193 10:41 1m ap
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9.0 REFERENCES
40 CFR Part 264 Subpart 1. Tank Systems
40 CFR Part 280. Technical Standards and Corrective Action Requirements for
Owners/Operators of Underground Storage Tanks (UST)
40 CFR Part 261 Subpart C. Characteristics of Hazardous Waste
40 CFR Part 261 Subpart D. Lists of Hazardous Wastes
6 CCR 1007-3 Part 264 Subpart 1. Tanks
6 CCR lOO7-Sn CCR 1101-14. Underground Storage Tanks
R11C 89068ROl
Federal Facility Agreement for the Rocky Mountain Arsenal
R11C 88131ROl
Rocky Mountain Arsenal, Final Technical Program Plan, FY88-FY92, Remedial Investigation
Feasibility Studiesllnterim Response Actions
R11C 88162ROl
Synopsis of Proposed Consent Decree in the United States v. Shell Oil Company
26
JlMM)428 7131193 10:411D1 ap
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APPENDIX A
COMMENTS ON THE
DRAFf ASSESSMENT/DECISION DOCUMENT
UNDERGROUND STORAGE TANK
MONITORING AND REMOVAL
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COMMENTS ON THE
DRAFT ASSESSMENTIDECISION DOCUMENT
UNDERGROUND STORAGE TANK
MONITORING & REMOV AL
General Comment:
Response:
Specific Comments:
Comment:
Response:
Comment:
Response:
Comment:
Response:
TY:bl
813/93
It was EPA's understanding that when the document was
modified and the revised pages were sent out, Appendix A
should have been removed. No mention was made of this in the
letter.
EP A is correct, Appendix A should have been removed from the
document.
Figure 2-1: The legend shows a tank TOOOI as both a hazardous
substance waste underground storage tank and a nonregulated
underground storage tank, but the figure indicates only a tank
TOOll (different number) as a hazardous substance waste
underground storage tank. There was some confusion over this
figure in the meeting on May 20, 1993, but the figure was not
modified. It was EP A's understanding from the meeting that
there are two 'hazardous waste storage tanks in the North Plants
and they should be removed as part of this IRA. Please clarify.
The legend for the tank classification has been 'modified to reflect
tanks as shown on the figure.
There are two (2) hazardous substance/waste tanks in North
Plants. These tanks will be removed by Tennessee Valley
Authority (TV A).
Figure 2-2: The legend shows a tank TOOOI as both a hazardous
substance waste underground storage tank and a nonregulated
underground storage tank, but the figure shows only tank TOOOI
as a hazardous substance waste underground storage tank.
Please clarify.
The legend for the tank classification has been modified to reflect
tanks as shown on the figure.
Figure 2-3: The legend shows a tank TOOOI as both a hazardous
substance waste underground storage tank and a nonregulated
underground storage tank, and the figure shows two different
types of tank with the same number 'plus a tank TOG01'" as a
petroleum underground storage tank. Please clarify.
The legend for tank classification has been modified to reflect
tanks as shown on the figure. The asterisk (II<) next to a tank is
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Comment:
Table 2-1: Three tanks were added to the bottom of this list
since the previous version. Tanks TOOO3, TOOO2, and TOOOI
are shown as having been removed. When, how, and under
what process were these tanks removed?
Three tanks were added to the table. These tanks were removed
prior to 1988 and the Army is currently preparing a work plan to
perform proper closure at tank locations.
Response:
Comment:
Page 23, Section 6.0, Second paragraph, last sentence: The
reference to Appendix A, the site assessment for the Phase I
tanks, should be removed since the Appendix should have been
removed (see general comment above).
All references to Appendix A have been removed from the
document.
Response:
Response to Fish and Wildlife Service Comments
Response:
All open pits and trenches should be signed or roped off so that
other field workers on the Arsenal are aware of hazards. The
Service would like to be notified immediately in the event of any
wildlife conflicts during the field work.
The workplan for UST removal states that all excavations for
UST removal must be fenced off with a 6 foot high chain link
fence to prevent unauthorized entry by personnel and to prevent
wildlife from entering the excavation.
Comment:
Comment:
Backfill material should be free of contaminants, and at least the
top two feet should consist of topsoil suitable for eventual
revegetation with grasses, forbs, and shrubs.
Where appropriate, backfill material will consist of 2 feet of
topsoil suitable for eventual revegetation with grasses, forbs,
and shrubs.
Response:
. Response to Colorado Department of Health Comments
Comment:
1) The NCP (40 CFR 3oo.430(f)(3) requires that the Army
hold a pubic. meeting regarding the remedy selected for this
interim response action. At the Committee meeting on May 13,
1993, the Army stated that they would not schedule a meeting,
but would hold a meeting if it was requested by the public, or if
there were a significant number of public concerns raised. The
fact sheet issued by the Army on UST removal, the sheet states
that a meeting will not be held. At a minimum a letter explaining
that a public meeting will be held if necessary should be sent to
those who received the fact sheet.
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8/3/93
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Comment:
The Army disagrees with the State's legal interpretation of the
NCP regarding the necessity of holding a public meeting for this
IRA. Nevertheless, the Army reaffIrms the position that a public
meeting could be held if sufficient public interest in this IRA
exists. The Fact Sheet does not contain any discussion about
holding or not holding a public meeting. The language used in
the cover letter of the Fact Sheet sent to the public does not
preclude a request for a public meeting on this IRA by a
concerned citizen. To date, no written or verbal comment on
this IRA have been received from the public.
2) Please clarify all potential contents of USTs in the North
Plant area. Figure 2-1 indicates that some of the tanks to be
removed from this area contain or had contained hazardous
substances/wastes. In the USTIPCB subcommittee meeting on
May 20, 1993, the Army stated that there are no tanks containing
hazardous substances/wastes schedule to be removed from the
North Plants area.
Response:
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Comment:
There are two (2) USTs in North Plants which contain
hazardous substances/wastes. These USTs will be removed by
Tennessee Valley Authority (TV A).
3) Table 2-1 references building numbers, yet those building
numbers are not on any of the maps. Please put building
numbers on the maps to ensure the ease all necessary
information is present for public review.
Response:
Comment:
Table 2-1 references building numbers not on the maps. To add
legible building numbers to the maps would require the map size
to be 36" x 48". The building numbers were not put on the
maps.
4) On page 23 there is a reference to Appendix A, the site
assessment for the Phase 1 tanks. Has this Appendix been
removed from the document issued to the public libraries, as
indicated by the Army during the RMA Committee meeting on
June to, 1993? If so, this reference should be removed. If not,
how does this Appendix assist or clarify the review process?
Response:
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Comment:
The reference to Appendix A has been deleted from page 23.
5) Section 4.4.2 discusses the short-term and long-term
effectiveness and implementability. However, it does not
acknowledge that the remedy "shall utilize permanent solution"
to the "maximum extent practicable" 40 CPR 3oo.430(f)(1).
Thus, the principal measure of the effectiveness of an alternative
is the degree to which it provides for an alternative is the degree
to which it provides for a permanent remedy. Please revise
accordingly.
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Response:
Section 4.4.2 has been revised to reflect the alternative selected
does provide a permanent solution as stated in 40 CFR
300.430(f)( 1).
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