United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R08-93/079
September 1993
SEPA Superfund
Record of Decision:
Rocky Mountain Arsenal
-------
50272-101
REPORT DOCUMENTATION '1. REPORT NO. 2. 3. Raclplant'. Acca..lon No.
PAGE EPA/ROD/R08-93/079
4. Tltla and Subtitle 5. Report Date
SUPERFUND RECORD OF DECISION 01/15/93
Rocky Mountain Arsenal (Operable Unit 29), CO 6.
Eleventh 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 Address 13. Type 0' Report & Period Covered
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Supplementary Notes
PB94-964411
16. Abstract (Limit: 200 words)
The Rocky Mountain Arsenal (Operable Unit 29) 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, U.S. 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. OU2 9 , which is one of these 13 IRAs, contains equipment,
buildings, and site areas contaminated with PCBs at the RMA. Types of waste identified
include PCB-contaminated soil, asphalt, powdered concrete material, liquid waste
including equipment lubricating and hydraulic oils and solvents used to decontaminate
the equipment, and personal protective equipment. Initially, OU29 focused on only
three sites at the RMA: building 321, the Coal Pulverizers/Electric Motor Assemblies
area; building 1703, the LeBlonde USA Large Lathe and Hydraulic Press area; and
facility 621B, the Storage Pad and Salvage Yard. However, in 1993, the OU was expanded
(See Attached Page)
17. Document AnalysJa a. Dnc:rlptora
Record of Decision - Rocky Mountain Arsenal (Operable Unit 29), CO
Eleventh Remedial Action
Contaminated Media: soil, debris
Key Contaminants: organics (PCBs)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Ststamant 19. Security Class (This Report) 21. No. 0' Psges
None 43
20. Security Class (This Page) 22. Price
None
(See ANSI.Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4.77)
(Formerly NTI5-35)
-------
EPA/ROD!R08-93/079
Rocky Mountain Arsenal (Operable Unit 29), CO
Eleventh Remedial Action
Abstract (Continued)
to include approximately 400 additional buildings and approximately 400 additional pieces
of equipment at the RMA. This ROD addresses the PCB-contaminated equipment, buildings,
soil, asphalt, and debris at the RMA. A future ROD will address remaining onsite
contaminated media and provide a final remedy for the PCB-contaminated waste. The primary
contaminants of concern affecting the soil and debris are organics, including PCBs.
The selected remedial action for this site includes excavating and removing
PCB-contaminated soil, asphalt, and other debris; decontaminating the PCB-contaminated
interior and exterior surface areas of specific industrial equipment, floors, and walls;
temporarily storing PCB-contaminated materials onsite; transporting all PCB-contaminated
material offsite for incineration, and off site disposal of residuals; sampling to verify
the level of cleanup; and relocating the decontaminated equipment. The estimated total
cost for the selected remedial action is $30,000, which includes O&M costs.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific performance standards for PCBs are based on TSCA regulatory levels, and
include 25 mg/kg PCBs in soil; 10 ug/cm2 PCBs on high-direct contact, soiled surfaces, and
low contact, indoor surfaces; and 100 ug/cm2 PCBs on low contact, encapsulated indoor
-------
September 23, '993
DEPARTMENT OF THE ARMY
PROGRAM MANAGER FOR ROCKY MOUNTAIN ARSENAL
COMMERCE cm. COLORADO 80022 -1748
REPLY TO
"'TTE~'T10~ OF:
Interim Response Branch
~ .
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:
OU.,2.q This letter serves to advise you of the finalization of the Decision Documents for
th~d UST Interim Response Actions at Rocky Mountain Arsenal. Since no
dispute was raised, the Draft Final Decision Documents that were issued on June 4,
1993, will serve as the Final Decision Documents. Due to ",typographical errors in the
PCB and UST Draft Final Decision Documents, the Final Decision Documents with the
appropriate white covers and corrections are enclosed. No technical 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
-------
.<#
Copies Furnished:
Captain Jonathan Potter, Litigation Attorney, Rocky Mountain Arsenal
Building 111, Commerce City, Colorado 80022 (wfend) ~. .'
Mr. Bradley Bridgewater, U.S. Department of Justice, 999-18th Street,
Suite 501, North Tower, Denver, Colorado 80202 (wfenc1)
Mr. Sheldon Muller, Assistant Regional Counsel, U.S. Environmental
Protection Agency, One Denver Place, Suite 500, 999-18th Street,
Denver, Colorado 80202-2405 (wfend)
Mr. Gene Czyzewski, CDM Federal Programs Corporation, 1626 Cole Boulevard,
Suite 100, Golden, Colorado 80401 (wfenc1)
Document Tracking Center, AMXRM-IDT, Room 132, Building 111, Rocky
Mountain Arsenal, Commerce City, Colorado 80022 (w fend)
-------
,~~~
~r"- a....... - ... ..-.;. '''.'-.. ~.;...........
_0'..
1-' ,
< -,
I .. .
':;"~3
~ '.-.
-- .
-..".-
,
,to PROGRAM MANAGER" FOR
ROCKY, )fOUNTAIN. ARSENAL
- C010urnw TO. PROTECTION OF, 'THE ENVlRONKENT - '
i'1naI Decision'Doamient . .
. for ~Element Two of ?c: IT
the CERCLA Hazardous 'WasteS . :
Interim Response Action .' 00':<'" q
at the Rocky Mountain Arsenal
Version 1.0
Document Control Number S300-02-0i.AADA
_.
..-. .
.. .
..
.. -
, ,
-. .'
.. .:--
. - -- - ~
..
..
..
.. .
-.
. .
..
. "
.-- -
..
. ..
ROY. F~ WESTON, INC. .'
215 Union Boulevard, Suite 550 '
lakewood, Colorado 80228'
.. .
. /
-. .""
;
, ..
.
.
.. ..
, -
- ..
'.. -..
- .- -
. "
REQUESTS FOR"COPIES OF THIS DOCUMENT'."
~. SHOULD. BE REFERRED TO THE PROGRAM MANAGER
FOR THE ROCKY, .MOUNTAIN ARSENAl... . .
..
.. ..
", ':<: : :
- . ~. .
~..
_..- ~.
. -. ."
"
.. -,',
.~ "".--.
..
..
" -
-------
Section
/
"
. ,
; ,
TABLE OF CONTENTS
Title
Pa2e
1
INTRODUCTION
. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . .1-1
2
BACKGROUND
. . . ". . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2-1
3
INTERIM RESPONSE ACTION OBJECTIVES. . . . . . . . . . . . . . . 3-1
4
INTERIM RESPONSE ACTION ALTERNATIVES. . . . . . . . . . . . 4-1
4.1 On-Site Storage. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4-1
4.2 On-Site/Off-Site Treatment. . . . . . . . . . . . . . . . . . . . . . . . .4-1
4.2.1 Incineration.............................. 4-2
4.2.1.1 On-Site Incineration. . . . . . . . . . . . . . . . . .4-2
4.2.1.2 Off-Site Incineration. . . . . . . . . . . . . . . . . . 4-2
4.3 On-Site/Off-Site Land Disposal. . . . . . . . . . . . . . . . . . . . . . 4-2
4.3.1 On-Site Chemical Waste Landfill. . . . . . . . " . . . . . . . . 4-3
4.3.2 Off-Site Chemical Waste Landfill. . . . . . . . . . . . . . . . . 4-3
5
COMPARISON OF ALTERNATIVES. . . . . . . . . . . . . . ~ . . . . . . 5-1
5.1 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-1
5.1.1 Overall Protection of Human Health and the Environment. 5-1
5.1.2 Compliance with ARARs . . . . . . . . . . . . . . . . . . . . . .5-1
5.1.3 Reduction of Toxicity, Mobility, or Volume. . . . . . . . . . 5-2
5.1.4 Short and Long Term Effectiveness. . . . . . . . . . . . . . .5-2
5.1.5 Implementability . . . . . . . . . . . . . . . . . . . . . . . . . . .5-2
5.1.6 Cost.................................. 5-3
5.2 Comparison of Alternatives. . . . .. . . . . . . . . . . . . . . . . . . .5-3
5.2.1 On-Site Storage. . . . . . . . '. . . . . . . . . . . . . . . . . . .5-3
5.2.2 On-Site Incineration. . . . . . . . . . . . . . . . . . . . . . . . .5-5
5.2.3 Off-Site Incineration. . . . . . . . . . . . . . . . . . . . . . . . .5-5
5.2.4 On-Site Chemical Waste Landfill . . . . . . . . . . . . . . . . .5-6
5.2.5 Off-Site Chemical Waste Landfill. . . . . . . . . . . . . . . . . 5-6
5.3 Preferred Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-'
5.4 Consistency With the Final Response Action. . . . . . . . . . . . . . 5-'
6
CHRONOLOGY OF EVENTS
. . . . . . . . . . . . . . . . . . . . . . . . . .6-1
7
IRA PROCESS
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1
FiDaI vcnioo 1.0 DecisioD Documcat for EIcmcDt Two of1bc CERCLA UqWd W- -1DIc:rim RC8pOIIItActioa
Rocky MOUDIaiD AncuI - Document CoaI:roI No. 53QG.0'2-OZ-AADA
rma-OZ02\rq1orU\aada.acp\coY-IOC.acp
Sc:pIcmber 1993
-------
TABLE OF CONTENTS (Continued)
Section
Title.
Pa2e
8
APPLICABLE OR RELEVANT AND
. ,
APPR.OPRIA.TE REQUIR.El\fEN'TS . . . . . . . . . . . . . . . . . . . . . . .8-1
8.1
8.2
Definition of Terms. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1
ARARs for Selected Alternatives. . . . . . . . . . . . . . . . . . . . . 8-3
8.2.1 Chemical-Specific Requirements. . . . . . . . . . . . . . . . . 8-3
8.2.2 Location-Specific Requirements. . . . . . . . . '. . . . . . . . . 8-4
8.2.3 Action-Specific Requirements. . . . . . . . . . . . . . . . . . . 8-5
9
REQUIR.El\fEN'TS TO BE CONSIDERED. . . . . . . . . . . . . . . . . .9-1
9.1 PCB Spill Cleanup Policy. . . . . . . . . . . . . . . . . . . . . . . . . . 9-1
9.1.1 Cleanup of Low-Concentration Spills. . . . . . . . . . . . . . 9-2
9.1.2 Cleanup of IDgh-Concentration Spills. . . . . . . . . . . . . . 9-2
9.1.2.1 Cleanup of Restricted Access Areas . . . . . . . . . 9-3
9.1.2.2 Cleanup of Outdoor Electrical Substations
and Nonrestricted Access Area . . . . . . . . . . . . 9-4
9.2 Target Decontamination Goals ..................9-4
10
REFEREN'CFS ................................... 11-1
LIST OF TABLES
Table No.
Title
Pa2e No.
5-1
Comparison of Estimated Cost of PCB Disposal Alternatives. . . . . . . . . 5-4
5-2
Summary of the Comparison of Alternatives. . . . . . . . . . . .. . . . . . . 5-8
8-1
Location-Specific ARARs for PCB Removal IRA . . . . . . . . . . . . . . . . 8-6
8-2
Action-Specific ARARs for PCB Removal IRA . . . . . . . . . . . . . . . . . 8-7
9-1
Target PCB Cleanup Standards Based on Precedents and Policies. . . . . . 9-5
Filial Vcnioo 1.0 Decilioo DocumaIt for EkmcDt Two of !be CERCLA Liquid WUIea - IDIerim RCIpOIIIC Aetioo
Rocky MCIUIIIUI An=aI - DocumaIt CoaIroI No. 5300.02-02-AADA
rmHn02\repo111\uda.ICp\coY-coe.1Cp
Septc:mber 1993
-------
ARAR
CERCLA
CFR
cm2
EPA
FFA
IRA
NCP
NIOSH
O&M
OSHA
PCB
PPE
ppm
RCRA
RIlFS
RMA
TBC
TSCA
.-
TABLE OF CONTENTS (Continued)
ACRONYMS
applicable or relevant and appropriate requirement
Comprehensive Environmental Response, Compensation, and Liability Act
Code of Federal Regulations
square centimeters
U.S. Environmental Protection Agency
Federal Facility Agreement
Interim Response Action
National Contingency Plan
National Institute of Occupational Safety and Health
Operation and Maintenance
Occupational Safety and Health Administration
polychlorinated biphenyls
personal protective equipment
parts per million
Resource Conservation and Recovery Act
remedial investigation/feasibility study
Rocky Mountain Arsenal
to be considered
Toxic Substance Control Act
~. .'
FiDaI Vcniao 1.0 DccisiaD DocumaI1 for Ekmc:Dt Two of Ibc CERClA Liquid Wutca - IDterim RcIpoaK Actiaa
Itocty MOUDIaiD Ancaa1 - DocumaI1 CaaInII No. S300-0'2.()2.AADA
rma-0202\rcporU\udLlcplcov-CDc.1cp
Scptc:mbcr 1993
-------
SECTION 1
INTRODUCTION
This Decision Document outlines remediation and management alternatives to coordinate disposal
options for polychlorinated biphenyls (PCB) wastes at the Rocky Mountain Arsenal (RMA) under
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) activities.
This Decision Document selects specific disposal options associated with Element Two under
the expansion of the Pretreatment of CERCLA liquid Wastes Interim Response Action (IRA
13). Element Two includes the approval of management options relating to remediation of
selected equipment and sites contaminated with PCB wastes.
Section 2 of this Decision Document provides a brief overview of the Interim Response Action
(IRA) currently being conducted at RMA, including an expansion of the original IRA to include
three additional elements. In July 1993, WESTON received authorization to remediate
approximately 400 additional buildings and approximately 400 additional pieces of equipment
under a separate delivery order. Section 3 identifies the objectives of Element Two of this IRA
expansion. Section 4 identifies potential alternatives that are applicable to the disposal of the
wastes generated under Element Two. A description of the preferred or selected disposal
alternative, and the evaluation process used to support this selection, as background is provided
in Section 5. Information including a list of chronological events is presented in Section 6, and
the IRA process for Element Two is identified in Section 7. A brief discussion of applicable or
relevant and appropriate requirements (ARARs) is included in Section 8. Additional
requirements to be considered are discussed in Section 9.
FiDaI Vcnicm 1.0 DccisioII DocumaI1 for EIaDcD1 Two of ~ CERCLA Liqujd WutcI - 1Dtcrim RCIpCIIIIC Ac:tiaD
1locky MOUDIaiD Ancoa1 - Doc1IIIICDt Ccab'Ol No. .s3~-02-AADA
rma-0202\rcpo1U\aadLacp--I-3.acp
September 1993
-------
SECTION 2
BACKGROUND
The "Pretreatment of CERCLA Liquid Wastes IRA" 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
versus Shell Oil Co., the proposed Modified Consent Decree dated June 7, 1988, and the
Federal Facility Agreement (FFA) dated February 17, 1989.
After the alternatives were reviewed according to the criteria listed in the above referenced
documents, a new wastewater treatment system was chosen as the best solution for this IRA.
Implementation of this IRA began in August 1991, and the new wastewater treatment system was
constructed and began operating in July 1992. On January 14, 1992, RMA submitted a
Technical Study to U.S. Environmental Protection Agency (EPA) Region vm for an expansion
of the CERCLA Liquid Wastes IRA. The Technical Study proposed to amend the "Pretreatment
of CERCLA Liquid Wastes IRA" of the FFA to encompass a broader range of wastestreams and
waste management activities for both on-post and off-post operable units. The expansion has
three elements:
. .
Element One - Management options for disposal and/or treatment of hazardous
waste that has been or will be placed in storage areas at RMA, and that has not
been addressed in another IRA. Wastestreams include: remedial investigation!
feasibility study (RIfFS) wastes; IRA wastes; miscellaneous waste from vehicle,
grounds, and building maintenance; and items found on post.
.
Element Two - Approval of management options relating to remediation of
selected equipment and sites contaminated with PCB wastes. This expansion
creates a mechanism for coordW;lting activities prior to the remediation or
disposal of such PCB items and PCB wastes.
.
Element Three - Selection and approval of an on-site facility for managing solids
that are bulk hazardous wastes. These wastes primarily consist of contaminated
soil and building rubble and must be managed appropriately until fInal remedial
action decisions are made.
\"
i .
!
\ '.
This Decision Document only addresses Element Two.
Filial Vc:mao 1.0 DcciaiaD J)ocUlllC:Dt for EIc:maIt Two of die CBRCLA LiqWd WutcI - IDt.crim JlClflOD" Ac:tioa
Jlocky MOUDI8iD AncaaI - J)ocumcat CaaIro1 No. 5300.02-02-AADA
rma-0202\n:porU\uda..ocp\Kc-1-3.ocp
ScpIaDbct 1993
-------
SECTION 3
INTERIM RESPONSE ACTION OBJECTIVES
The overall objectives of IRAs are to select alternatives that are: protective of human health and
the environment; cost effective; and timely. The selected alternatives, to the maximum extent
practicable, should also: be consistent Ylith and contribute to the effective performance of Final
Response Actions;. attain ARARs; and be compatible with fInal remediation decisions in the
Records of Decision.
The objective of Element Two of this IRA expansion is to develop and implement management
options for remediating selected equipment and selected sites contaminated with PCB wastes.
Element Two also creates a mechanism for coordinating activities prior to the remediation or
disposal of such PCB items and PCB waste.
..
There will be several different types of PCB-contaminated wastes addressed by this IRA. The .
types of wastes that may result from clean-up actions could inClude the following:
.
PCB-contaminated solid wastes to ~clude excavated soil and asphalt as well as
powdered concrete material generated from scabbling activities.
.
PCB-contaminated liquid waste to include equipment lubricating and hydraulic
oils and solvents used.to decont.amin~te the equipment.
.
Personal protective equipment (PPE) potentially conQiminated with PCB (tyvek
suits, gloves, booties, respirator cartridges, etc.).
i .
J :,
All waste storage and disposal activities will be conducted in compliance with all applicable
federal requirements. The State does not have authority for PCB regulations.
..
The activities involved in the PCB IRA will include the removal of PCB liquids and sludges
from the interior and exterior surface areas of specifIc industrial equipment, floor, contaminated
soil and paving material, and other debris. The.PCB IRA further includes post-cleanup sampling
to verify the level of cleanup, relocation of decontaminated equipment, and disposal of PCB-
contaminated material.
l
'"
I. ..
. .
FiDaI Vcniaa 1.0 Dcciaioo DocIllDCllt for EJcmaIt Two of !be CERCLA Liquid w- - JDtcrim ~ ACIioD
Rocky MOUDIain Ancaal - ~ CGIdlO1 No. S3oo.m-02-AADA
rmo-02-02\rcporU\uducp'--I.3.acp
ScpUmbcr 1993
-------
Initially, the PCB IRA was meant to address only three sites: Building 321 (Coal
PulverizerslElectric Motor Assemblies); Building 1703 (LeBlonde USA Large Lathe and
Hydraulic Press); and Facility No. 621B (Storage Pad, Salvage Yard). A detailed description
of these sites and remedial activities relating to these sites is found in the Implementation Letter
which will be sent to regulatory agencies by the PMRMA.
In July 1993, WESTON received authority by the PMRMA to expand the PCB IRA to include
the investigation of approximately 400 additional buildings and approximately 400 additional
pieces of equipment. These additional buildings and pieces of equipment were identified by
EBASCO and published in the Draft Final Inventory Report, Polychlorinated Biphenyl (PCB)
Inventory, Volumes I, IT, and m (EBASCO, 1991). These additional buildings and pieces of
equipment and remedial activities relating to them will be described and detailed in a separate
Implementation Letter. Currently, the PMRMA has not identified which of these additional
buildings or pieces of machinery need to be addressed in the PCB IRA.
. .
FiDaI Vena 1.0 DcciJiaa DocumcDt for EJcmcnt Two of IIIc CER.Cl.A Liquid Wutcs -1Dtcrim RCIfIOII" Adioa
Rocky MOUIItain AncuI - DocumcDt Coatn>I No. S300.m-OZ-AADA
rma-02-02\rq1orU\ud&.tep\scc-I-3.1Cp
Scptc:mbcr 1993
-------
SECTION 4
INTERIM RESPONSE ACTION ALTERNATIVES
Potential alternatives have been identified for this IRA based upon the treatment and disposal
options that are available for the various wastestreams that were identified in Section 3.
Presented in this section are the potential alternatives that represent distinct, viable approaches
to managing site problems: storage in an on-site facility; treatment in an on-site or off-site
facility; and land disposal in an on-site or off-site facility. These alternatives. constitute routine
management and disposal options common to widespread industry practices in compliance with
the Resource Conservation and Recovery Act (RCRA) and the Toxic Substances Control Act
(TSCA).
4.1
ON-SITE STORAGE
PCB-contaminated waste removed and drummed during remediation processes can be stored on
site as a management option uritil a fmal treatment or disposal alternative is identified. On-site
storage of PCB-contaminated waste cannot exceed 1 year according to 40 CFR 761. 65(a). This
waste must be stored in a unit that is designed and operated in compliance with ARARs,
including, but not limited to, the substantive requirements of TSCA, such.as those found at 40
CFR 761.65 addressing PCB storage.
4.2
ON-SITE/OFF-SITE TREATMENT
,
I :
Treatment response actions reduce or eliminate the toxicity, mobility, or volume of a chemical
constituent of a waste by altering the chemical structure or bonding with, isolating, or destroying
the contaminant. Treatment alternatives for pCB-contaminated wastes include incineration,
solidification, biodegradation, and chemical dechlorination. Of these, only incineration is a
demonstrated practical alternative for small volumes of PCB-contaminated liquids.
,. .
'..
\
\ "
..
FiDaJ VcnioD 1.0 Dcciaioo Documcut for ElcmcDt 1'1110 of Ibc CBRClA Uquid w- - IDtmm RC8pCXIIC AC1ioD
Rocky MOIIIIIaiD AncmI - Documcat CaItroI No. S300-02-02-AADA
rma-0202\rcpo1U\uda.acp\8cc-4-S.1Cp
Sc:pccmber 1993
-------
4.2.1 Incineration
Thermal destruction of PCB-contaminated waste would destroy the waste constituent
permanently. This process would eliminate the risk of the contaminant becoming released into
the environment and prevent any long term liability. All incinerators used in the destruction of
PCBs must be in compliance with TSc:A. Incinerators accept all concentrations of PCB liquid
wastes, unlike chel1.lical waste landfills which accept PCB concentrations of 500 parts per million
(ppm) or less.
4.2.1.1 On-Site Incineration
A mobile incinerator could be transported to RMA for PCB destruction. This alternative allows
for the most effective treatment of IRA wastes without the time needed to construct the unit.
The incinerator would be subject to TSCA requirements including those of 40 CFR 761.70
. .
which specify .a destrUction efficiency of 99.9999 percent as well as other design, operation, and
operation specifications.
4.2.1.2 Off-Site Incineration
PCB-contaminated liquids and solids generated by the activities of this IRA could be transported
off-site to a commercial TSCA incinerator. Since this activity involves the off-site transfer of
a CERCLA hazardous substance, the CERCLA fil21(d)(3) Off-Site Policy requirement for EPA
to approve the off-site facility must be met. In addition, all regulations applicable to the off-site
actions (rather than ARARs) must be complied with.
4.3
ON-SITE/OFF-SITE LAND DISPOSAL
All chemical waste landfills accepting PCBs must be in compliance with TSCA and can not
accept liquid waste containing PCB concentra~ons greater than 500 ppm unless stabilization or
solidification was occurred prior to disposal (40 CFR 761.75[b][8]). On-site and off-site land
disposal options are discussed below.
FiDa1 Vena 1.0 DcciaicJD Documc:Dt for EIcm=t Two of.. CBR.CLA LiquicI WUIcI- IDtcrim ~ AeIioD
Rocky MOUDIaiD Ancaa1 - DocumcDt CoaIroI No. S300-02-02-AADA
rma-0202\Rpo1U\88dLlcp\ac»4-S.1Cp
Scp1aIIbcr 1993
-------
4.3.1 On-Site Chemical Waste Landf"ill
RMA could design and construct a landfill on site in compliance with TSCA. Using TSCA
regulations of 40 CPR 761. 7S as ARARs, the landfill would require a liner over very low
penneability clay soils, monitoring systems for groundwater and surface water, a leachate
collection system, and must comply w~th various locational restrictions.
4.3.2 Off-Site Chemical Waste Landf"ill
PCB-contaminated solids generated by the activities of this IRA could be transported off-site to
a commercial TSCA chemical waste landfill. Since this activity involves the off-site transfer of
a CERCLA hazardous substance, the CERCLA U21(d)(3) Off-Site Policy requirement for EPA
to approve the off-site facility must be met. In addition, all regulations applicable to the off-site
actions (rather than ARARs) must be complied with.
"
FiDaI VcnioD 1.0 DcciaioD DocUIIICII1 for EIcmaI1 Twooflbt CERCLA Liquid Wutca -1DIcrim R~ActioD
Rocky MOUDI8in Anc:aaI - DocUlDCll1 CoaIroI No. 5300-02-02-AADA
rma-0202\n:poJU\udLlcp\8cc-4-5.1Cp
ScpItmbcr 1993
-------
SECTION 5
COMPARISON OF ALTERNATIVES
5.1
INTRODUCTION
Each of the alternatives described in S.ection 4 is compared in the following text against these
primary criteria as' a basis for a qualitative evaluation:
.
Overall Protection of the Human Health and the Environment.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs).
Reduction of Toxicity, Mobility, or Volume (TMV).
Short and Long Tenn Effectiveness.
Implementability .
Cost.
.
.
.
.
.
5.1.1 Overall Protection of Human Health and the Environment
This primary criteria provides a fInal check to assess whether each alternative offers adequate
protection of human health and the environment. The overall assessment. of protection draws
on the assessments conducted under evaluation criteria, especially short and long term
effectiveness and compliance with ARARs.
5.1.2 Compliance with ARARs
This evaluation criterion is used to determine whether each alternative will meet all of its
Federal and State ARARs (as defined in CERCLA fi 121) that have been identifIed in previous
stages of the Remedial InvestigationIFeasibility Study process. Section 8 of this document
summarizes the ARARs for this IRA. Additional requirements which may need to be considered
are discussed in Section 9.
"
Filial vcniaa 1.0 DccUioo Documcot fOl' EIemcDt Two «!be CERCL4. Liquid Waaea -1DIcrim IteIpoaIe ActioD
R.octy MOUDIaiD AncDaI - Documcot CoDIrol No. 53~-02-AADA
rma-0202\rq1orU\uda.acp\8ec-4-5.acp
ScpIaDbcr 1993
-------
5.1.3 Reduction of Toxicitv. Mobilitv. or Volume
This criteria addresses the actions that utilize treatment technologies that permanently and
significantly reduce the toxicity, mobility, or volume of the identified waste by the destruction
of toxic contaminants, reduction of the total mass of toxic contaminants, irreversible reduction
in contaminant mobility, or reduction of total volume of contaminated media.
5.1.4 Short and Lon!! Term Effectiveness
This evaluation criterion involves investigation of the effects of the alternative during
construction and implementation, and consideration of the risks that remain after the site has
been remediated. In general, items of concern would include the protection of the community
and workers during implementation of remedial measures, potential environmental impacts,
adequacy of controls that are used to manage treatment residuals or untreated wastes, etc. 'Tbe
principal measure of the effectiveness of an alternative for the purposes of this decision
document will be the degree to which the alternative provides for a permanent remedy for the
materials.
5.1.5 ImDlementabilitv
This criterion establishes the technical and administrative feasibility of implementing an
alternative. Technical aspects evaluated for each of the alternatives include construction and
operation activities, reliability of the technologies involved, ease of undertaking additional
remedial action, as appropriate, and monitoring after completion of activities. Administrative
concerns include establishing contact with appropriate agencies to implement remedial actions
(e.g., coordinating with agencies to construct and operate a treatment unit). Availability of
materials and equipment needed is another factor that must be considered when evaluating
implementability of an alternative. Tbe principal measure of the implementability of an
alternative for the purposes of this decision d~ument will be the relative ease with which the
alternative provides a means by which to treat, store, and/or dispose of the PCB materials
generated by the activities of this IRA.
0'
FiDaI Vcnioa 1.0 Dccisioa Documcat for E!IaDCII1 Two of !be CERcu. Liquid WUIca - IDtcrim Rcspoue Ac:IioD
, Rocky MOUIIIaiD AJ'ICDI1 - DocumcD1 CoDuol No. 5300.02-02-AADA
rma-0202\n:porb\uda.scp\8co+5.scp
SepU:mbcr 1993
-------
5.1.6 ~
A remedial cleanup program must be implemented and operated in a cost-effective manner must
mitigate the environmental and human health concerns at the site. In considering the cost-
effectiveness of the various alternatives, the following categories types of costs are briefly
evaluated:
.
Facility costs, including the costs of design, constnlction, mobilization, etc.
associated with the installation of the alternative.
.
Operation and Maintenance (O&M)/disposal costs, including the costs of post-
construction activities that ensure effective implementation of the remedy.
Included in the 0 & M costs are also the costs associated with any necessary
sampling and analysis or monitoring of the remedy. For the purposes of the
evaluation presented in this document, 0 & Ml disposal costs also include the
direct cost of off-site.treatment and/or disposal of wastes, since both facility costs
and 0 & M costs are incorporated in commercial facility treatment! disposal rates.
! .
Table 5-1 presents a comparison of the estimated costs of the alternatives. The volumes of
material slated for disposal were derived from information contained in EBASCO's Draft Final
Volumes I, n, and ill Inventory Report PCB Inventory (EBASCO, 1991). The volumes also
include estimates of material that will be generated from work associated with the latest
expansion of the PCB IRA.
i .
i
i .
\.
5.2
COMPARISON OF ALTERNATIVES
5.2.1 On-Site Stora!!e
/'
i
" .
On-site storage accomplishes the immediate o~jective of storing the PCBs in a timely manner,
allowing their removal from existing locations and elimin~ting them as a potential threat to
human health and environment. However, long-term storage requires that a storage unit be
r'o:
\ 0
I -'
Fmal VcnioD 1.0 DccUioD DocumaI1 for EIc:mcDt Two oflk CERClA Liquid Wut.ca -1DIcrim Rc8paDIe ActiaD
Rocky MOUIII8i:D Ancaal - Documeat CaauoI No. 5300-02-02-AADA
rma-0202\n:po11a\uda..8Cp~5.1Cp
Scpu:mbcr 1993
-------
. .,
tEl
S3:<
i I.~
J~r
~ (R'
ft I i
t[1
.u ~
ii
~r
'u.~
~~
sf
~a
>~
{
~
I
I
J.
f
>
i.
~:1
r:!!
Table 5-1
Comparison of the ~timated Cost of PCB Disposal Alternatives
O&M/ Total Alternative Costs
Disposal Alternative Facility Costs Disposal Costs for First Year Reference
On-Site Storage (vault) 35,000 12,~ 41,000 Roy F. Weston, Inc.
On-Site Incineration (mobile) 200,ooob 10,000 210,000 EPA. 1985. Remedial Action at Waste Disposal
Sites, EPA/62S/6-85/006.
Roy F. Weston, Inc. West Chester, PA
Off-Site Incineration 0 30,000 30,000 Aptus Environmental
On-Site Chemical Waste Landfill 40,OOOC 10,000" 50,000 EPA. 1985. Remedial Action at Waste Disposal
Sites, EPA/625/6-85/006.
Off-Site Chemical Waste Landfill 0 15,oood 15,000 USPCI
AssumutiODS
Volume of loilleonerete to be treated .. 10 eubie yardl
Volume of liquid to be treated os 7S0 gallonl
Volume of potentially eontaminated PPE .. 6 eubie yardl
a Annual eost for sampling and analYlil. COstl for taxel and freight have been eonlidered wherever applieable.
b COlli for mobilization, demobilization, and ltart-up of incinerator.
o Ineludel eOltl for exeavation, dewatering. shoring. installation of linera. groundwater monitoring systeml. ete.
d Inelude. eOII. for disposal of both 80111 and liquid.. Note that liquid I are ltabilized prior to landfill disposal. per 40 CFR 761.7S(b)(B),
-------
provided and maintained until the stored materials can be disposed,. in addition to providing a
potential risk for release while materials are stored. Long-term storage on site cannot exceed
I year, according to 40 CPR 761.65(a); therefore, it necessitates moving the materials again at
some point in the future and so the alternative offers little permanence. If facilities are available
at RMA for the storage of these materials, the alternative could be implemented relatively easily.
The relative cost of managing the w~ on site is also somewhat high (Table 5-1).
5.2.2 On-Site Incineration
The advantages to stationing the incinerator on site would be that hazardous waste transportation
liabilities and costs would be eliminated and that RMA personnel or contractors could manage
the incinerator instead of relying on the expertise of an outside company. Several drawbacks
that exist when employing mobile incineration as an alternative include: on-site incineration is
not cost effective for the small quantities of PCBs; and may not be feasible in a timely manner.
On-site incineration is effective in that it provides for a permanent elimination of the PCB
contaminants. This alternative is not easily implementable because of the difficulty and duration
of the activities necessary to bring the mobile incinerator on-line and ready to treat the IRA
wastes. When the costs of using the on-site incinerator alternative are compared with those of
the other alternatives, this alternative is found to be relatively more expensive.
5.2.3 Off-Site Incineration
Off-site incineration is a suitable alternative to employ in part because the off-site incinerator
would possess a current TSCA permit for destroying PCB-contaminated wastes. However, some
risks can be associated with off-site transportation of wastes.
This alternative is effeCtive in that it provides for a permanent elimination of the PCB
contaminants. Off-site incineration is very ~ily implementable since, although IRA wastes
might be temporarily stored pending destruction, the wastes merely need to be sent to an existing
FiDaI Venioa 1.0 Dcciaioa DocumaIt for EIaDaIt Two of 1bc CERCLA Liquid Wut.c:a - IDtcrim Reapcme Actioa
Rocky MOUDtaiD Ancaal - DocUlDCllt Cootro1 No. S3C»-02-OZ-AADA .
rma-O'202\rcpona\uda.Icp~S.1cp
ScpI.c:mber 1993
-------
commercial incineration facility that is currently incinerating other similar wastes. The relative
cost of the alternative is lower than the other alternatives except off-site landiilling.
5.2.4 On-Site Chemical Waste Landflll
An on-site landiill would eliminate hazardous waste transportation liabilities and costs, and the
RMA would retain control and manage the landiill. Disadvantages to this alternative include:
the significant costs and time necessary to design and construct a TSCA landfill; the liability of
not destroying the IRA wastes that are to be placed in the landiill; and the limitation under
TSCA that it not accept liquid wastes that contain PCBs at concentrations greater than 500 ppm.
In addition, pretreatment and/or stabilization to eliminate the presence of free liquids will add
cost and time in disposing of liquid wastes on site.
This alternative is effective in that.it provides for a permanent disposal, although not destruction,
of the PCB contaminants. The alternative is not very implementable because of the difficulty
and duration of the activities necessary to make the chemical waste landfill ready to accept the
IRA wastes. When estimated costs are compared, the relative costs associated with this
alternative are high, second only to on-site incineration.
5.2.5 Off-Site Chemical Waste Landf'ill
Off-site landiilling is cost-effective and expeditious, given the small quantity of material
involved; however, the RMA maintains liable for the disposal of PCBs and their disposal long
after the chemical waste landfill is closed. In addition, wastes containing greater than 500 ppm
PCBs cannot be disposed of in a land disposal facilities; this may limit the utility of this option.
This alternative is effective in that it provides for a permanent disposal, although not destruction
of the PCB contaminants. Off-site disposal in a chemical waste landfill is very easily
implementable since the wastes merely need t~ be sent to an existing commercial facility that
is currently landfilling other similar wastes. The relative cost of the alternative is lower than
all the other alternatives.
, .
FiDa1 VcnicD 1.0 DeciaicD Documcat for ElcmcDt Two of tbe CERCLA Liquid w.- - IDtcrim R.capaIIIC ActiaD
Rocky MOUDI8iD AncII81 - Doc_t CoDIroI No. S300.02.a2-AADA
rma-0202\rcporb\uda.ocp'"-4-5.ocp
Scptcmbcr 1993
-------
5.3
PREFERRED ALTERNATIVES
Table 5-2 presents a summary of the results of the comparison performed in Section 5.2. As
can be seen in the tablet off-site incineration and off-site landfilling are the most preferable
alternatives for disposal of the IRA-generated PCB-cont:.minated wastes. Because incineration
offers the desirable benefit of destroying the PCB contaminants of concern, it will be used
wherever practicable. Contaminated liquids and solid material are very amenable to
incineration; howevert incineration of similarly contaminated solids generally less desirable since
the cost of such treatment is commonly much higher.
5.4
CONSISTENCY WITH THE FINAL RESPONSE ACTION
This Decision Document outlines management alternatives, as well as mechanismst to coordinate
disposal options for hazardous wastes generated. at RMA as a result of CERCLA activities. This
IRA was developed to be consistent with and contribute to a final response action's efficient
performance throughout the remainder of the remedial action process at RMA.
I .
I .
! .
;.
,
(.
-,,".
t "
r.
,
I
!' :
. .
,.'
~..'-
Filial VenioD 1.0 Dccisioo DocumaIt for EJcmcm Two of the CERCLA Liquid Wutco - Jnt.crim RCIpOIISC Actioo
Rocky Mountain AncDaI - Doo;umcat CaIIroI No. S300-02.02.AADA
rma-0202\rcporta\aada..acp\acc-4-S .1Cp
ScpIcmber 1993
-------
Table 5-2
Summary of the Comparison of Alternatives
Disposal Alternative Effectiveness Implementabllity Cost Rating
On-Site Long-Term Storage Poor Good Moderate Least
Preferred
On-Site Incineration Good Poor Poor Least
Preferred
Off-Site Incineration Good Good Good Most
Preferred
On-Site Chemical Waste Landfill Moderate Poor" Poor Not
Preferred
Off-Site Chemical Waste Landfill Moderate Good Good Preferred
T
~ .
r ..
\
Filial Vcnioa 1.0 Dceisioo DocUlllCll1 for EJcmcm Two of 1bc CERClA LiqWcI WUIcI - lDIaim RCIpOIISC ActioD
Rcd;y MOUIIIUI AncDal - DocumCIIt CoDII'O! No. 53OO-m-02-AADA
rma-0202\rcpo1U\uda.1Cp\8ce-4-5.ac:p
September 1993
-------
SECTION 6
CHRONOWGY OF EVENTS
The significant events pertaining to Element Two of the expanded CERCLA Liquid Wastes IRA
are presented below.
Date
Event
Summer 1984
In support of activities conducted under RI and IRA programs at
RMA, storage of wastes in warehouses began.
June 1987
State of Colorado, Shell Oil Company, EPA, and U.S. Army
agreed that certain mAs would be conducted.
February 1988
Proposed consent decree lodged in the case of United States versus
Shell Oil Company with the U.S. District Court in Denver,
Colorado. The consent decree specified 13 interim actions,
including the CERCLA Liquid Wastes IRA, to facilitate
remediation activities.
June 1988
Proposal modified Consent Decree.
February 1989
FFA was developed to establish a procedure by which the
organizations would cooperate in the assessment, selection, and
implementation of Response Actions resulting from the release or
threat of release of hazardous substances, pollutants or
contaminants at or from the Arsenal. (Prior to the effective data
of the FFA, participation by the Army, EPA, Department of the
Interior, Agency for Toxic Substances and Disease Registry, and
Shell in the RIfFS and IRAs were governed by the February 1988
and June 1988 proposed Consent Decrees.)
June 1989
Formal Waste Management Program for storing investigation-
derived wastes began.
June 1990
Final IRA Decision Document for CERCLA Liquid Wastes IRA.
June 1991
Final IRA Implementation Document was issued and construction
began.
. .
Fia8I VeniaD 1.0 Dccisiclll DocumaIt for EIc:maIt Two of !be CERCLA Liquid Wuta -l1IJ.crim RCIpOIIIC A;tioa
Rocky MOUDIain AncuaI - Doc:umcm CoaIroI No. 5300.c2-02-MDA
rma-0202\rcporU\uda..acp\Jcc.6. 7 .acp
ScpIaDbcr 1993
-------
January 14, 1992
Final Technical Study document regarding a proposed Technical
Study for an expansion of the CERCLA Liquid Wastes IRA to
include three new elements (Hazardous Waste Disposal, PCB
Waste Disposal, and Bulk Waste Management) was submitted to
EPA Region VIll. The FFA requirements of paragraph 22.16
were followed in the modification of the CERCLA IRA.
Spring 1993
Draft Decision Document submitted to regulatory agencies.
FiDaJ Venioa 1.0 Decisica Documi:zIt for EIcmaIt Two of ~ CEllClA Liquid WUICI - 1Dt.crim JlClpOllle A~
Jlocky MOUDIaiD Ancaa1 - Doc:umc:ot Coa!rol No. 53()().()2-'12-AADA
rma-'l202\rcporU\uda.1Cp~7 .1Cp
Sc:pIcmbcr 1993
-------
SECTION 7
IRA PROCESS
The process for Element Two of this IRA is as follows:
1.
Opportunities for public participation in the development and approval of Element
Two of this IRA expansion will be provided before issuance of the Decision
Document. There will be notice and opportunity for written comment on the
Draft Decision Document; however, a public meeting will not be scheduled.
After the close of the comment period for this draft final version, a final version
will be prepared.
2.
The Draft Final Decision Document will be subject to dispute resolution. At the
close of the period for invoking dispute resolution, if dispute resolution is not
invoked, or after the completion of dispute resolution, the Anny shall issue a
Final Decision Document.
3.
After the issuance of the Final Decision Document, each specific proposal for
disposing andlor treating PCB items or waste, or for the remediation of selected
PCB equipment or sites, will be initiated with an Implementation Letter to the
regulatory agencies. This letter will describe: the PCB waste site or equipment
involved; the origin and storage site of the waste; and the alternative from the
Final Decision Document that will be used (including the method and location of
disposal andlor treatment andlor remediation). Any orvni7.~tion wishing to
invoke dispute resolution regarding an Implementation Letter must do so within
30 calendar days after receiving the document. .
4.
As Lead Party for the design and implementation of this IRA, the Anny will
prepare the Implementation Letter, as described above, and will be responsible
for implementing the IRA in accordance with the IRA Implementation Letter.
Filial Vcnioo 1.0 Dccisioo DccIllDCD1 for Eicmalt Twoof1bc CERCl.A LiqWd w- - JDt.erim Rcapcme ActicID
Rocky MOUDWa AnaIaI - DcclllDa1t Coatrol No. 5300-02-OZ-AADA
rma-OZ02\reporta\uda.1Cp\8ec+7.8Cp
ScptaDbcr 1993
-------
SECTION 8
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Attaining applicable or relevant and appropriate requirements (ARARs) to the maximum extent
practicable when peIforming IRAs is required by Section 22.6 of the FFA. This section dermes
the ARARs for the alternatives descri~ in Section 5.
8.1
DEFINITION OF TERMS
"Applicable requirements," as dermed in 40 CFR 300.5, mean:
those cleanup standards, standards of control, and other substantive requirements,
criteria, or limitations promulgated under federal environmental or state
environmental or facility siting laws that specifically address a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance
found at a CERCLA site. Only those state standards that are identified by a state
in a timely manner and that are more stringent than federal requirements may be
applicable.
"Relevant and appropriate requirements," also dermed in 40 CFR 300.5, mean:
\' ;
those cleanup standards, standards of control, and other substantive requirements,
criteria, or limitations promulgated under federal environmental or state
environmental or facility siting laws, that, while not 'applicable' to a hazardous
substance, pollutant, contaminant, remedial action, location, or other circumstance
at a CERCLA site, address problems or situations sufficiently similar to those
encountered at the CERCLA site that their use is well suited to the particular site.
Only those state standards that are identified in a timely manner and are more
stringent than federal requirements may be relevant and appropriate.
I'
f
" .
k
\.:
According to CERCLA U21(d)(2), in order to be considered an ARAR, a state requirement
must have been "promulgated." As defined in 40 CFR 300.400(g)(4) of the National
Contingency Plan (NCP), the term "promulgated" means that the requirement is of general
applicability and is legally enforceable.
-
c
FiD8! VenioD 1.0 Dcciaioo Documc:ot for EIcmaIt Two of !be CERCLA Liquid w- -1DIcrim R~ AcUOD
Rocky MOUDIaiD AncmI - Documc:ot Coauol No. 5300-02.m-AADA
nna-0202\rcpor1a\ada.ICp\8cc-S-l0.1Cp
ScpIcmbcr 1993
-------
In general, there are three categories of ARARs. These categories are:
.
Ambient or chemical-specific requirements.
Location-specific requirements.
Performance, design, or other action-specific requirements.
.
.
Each category is discussed in more detail in the following paragraphs.
Ambient or chemical-specific requirements set health- or risk-based concentration limits in
various environmental media for specific hazardous substances or pollutants. These
requirements set protective cleanup levels for the chemicals of concern in the designated media,
or may act as action-related requirements in indicating a safe level of air emission or wastewater
discharge.
Location-specific ARARs are limits placed on the concentration of hazardous substances or the
conduct of activities solely because they occur in certain locations. These may. restrict or
preclude certain remedial actions or may apply only to certain portions of a site. Examples of
location-specific ARARs that pertain to the IRA are federal and state siting laws for hazardous
waste facilities (40 CFR 264.18, fault zone, and floodplain restrictions), and federal regulations
requiring that actions minimize or avoid adverse effects to wetlands (40 CFR Part 6 Appendix A
and 40 CFR Parts 230-231).
Performance, design, or other action-specific requirements set controls or restrictions on
particular kinds of activities related to management of hazardous substances or pollutants. These
requirements are not triggered by the specific chemicals present at a site, but rather by the
particular IRA activities that are part of this plan. Action-specific ARARs are technology-based
performance standards, such as the Best Available Technology standard of the Federal Water
Pollution Control Act. Other examples include RCRA treatment, storage, and disposal
standards, and Clean Water Act pretreatment standards for discharges to publicly owned
treatment works.
FiDa1 Venioa 1.0 Dccisioa DocIIaxm for Ek:maIt Two of !be CERCLA Liq1IicI WUICI - lDIcrim RCIpCIIIIC ActicD
Rocky MouataiD AnaW - DocIIaxm CGaIroI No. 53CJ0..02-02.AADA
rma-02Q2\rcpor1a\a8da.Icp\lec-8-10.1cp
SepIcmbcr 1993
-------
RCRA land disposal restrictions for certain contaminants (40 CFR Part 268.40) are also action-
specific ARARs for the disposal of secondary wastes generated during water treatment. Any
wastes, hazardous or not, are subject to CERCLA section 121(d)(3), also known as the "off-site
policy." The "off-site policy" requires that CERCLA wastes be shipped off site only to facilities
in compliance with applicable federal and state laws.
As explained in the NCP (see 55 FR 8666), Occupational Safety and Health Administration
(OSHA) requirements for worker protection in hazardous waste operations and emergency
response (29 CPR 1910.120) are applicable to workers involved in hazardous substance-related
activities, as well as other OSHA requirements related to specific circumstances or activities.
Even though these requirements are not environmental in nature, and therefore, are not
considered ARARs, they must be satisfied. However, because these requirements are not
ARARs, they will not be further addressed in this decision document.
8.2
ARARs FOR THE SELECTED ALTERNATIVES
The following subsections identify the ARARs that will be attained to the maximum extent
practicable in performing this IRA.
8.2.1 Chemical-Specific Reauirements
i .
This IRA is intended to mitigate the threat posed to human health and the environment by a
single contaminant, namely PCBs. These PCBs have been identified in and around certain
equipment and in contaminated asphalt and soils. Under these conditions, there are no chemical-
specific requirements for the environmental medium of concern, namely soils, that must be
attained. There are, however, a number of ARARs that must be addressed for the PCBs as a
result of actions to be taken as a part of this IRA. These ARARS are identified in Section 8.2.3
as action-specific requirements.
.
,. .
1'-.'
,..;.
,
!
FiDal Vcnioo 1.0 DccisioD DocIllllCllt for E1cm=t Two of ~ CERCLA Liquid WuteI - IDterim RC8pODIC Actioa
Rocky MOUDIaiD Ancua1 - DocIIIIICIIt CoIIuol No. S300-02-02-AAJ)A
rma-0202\rcpo1U\aaducp\8ec-ll-l0.1Cp .
Scptcmbcr 1993
Page 8-3
I"
-------
8.2.2 Location-Specific Requirements
The FFA, in Sections 44.2(e) and (t), specifically addresses location-specific requirements and
provides that:
Wildlife habitat(s) shall be presexved and managed as necessary to protect endangered
species of wildlife to the extent required by the Endangered Species Act, 16 U.S.C.
Sections 1531 ~., migratory birds to the extent required by the Migratory Bird
Treaty Act, 16 U.S.C. 703 ~., and bald eagles to the extent required by the Bald
Eagle Protection Act, 16 U.S.C. Section 668~.
Other than as may be necessary in connection with a Response Action or as necessary
to construct or operate a Response Action Structure, there shall be no change permitted
in the geophysical characteristiGs of RMA that has a significant effect on the natural
drainage at RMA for floodplain management, recharge of groundwater, operation and
maintenance of Response Action Structures, and protection of wildlife habitat(s).
. .
. The activities of this IRA will be carried out in accordance with the FF A. As provided by the
Endangered Species Act, the U.S. Fish and Wildlife Sexvice will be consulted regarding
anticipated IRA activities to ensure that these activities are protective of wildlife.
In addition to the provision in the FF A, several requirements exist that pertain to the protection
and management of floodplains and wetlands. These requirements include: Executive Order
11988 (44 FR. 43239, July 24, 1979); regulations promulgated pursuant to the National
Environmental Policy Act; 40 CFR. Part 6; 40 CFR. 264. 18(b); and 40 CFR. 761.65(b). IRAs
may require the use of temporary storage areas for contaminated materials. The temporary
storage areas may have to be constructed for this pUIpOse. The siting of any such storage
structure will be protective of floodplains and wetlands to greatest extent practicable. If
possible, this IRA will make use of existing ~ facilities for the temporary storage of PCB-
contaminated materials.
.
FiDa1 Vcnioo 1.0 Dccisioo Docum=t for ElcmcDt Two of !be CBRCLA Liquid w- - IJIIcrim RcapoIIK Ac:IiaD
Rocky MCUDtaiD AnaW - ~ Cootro1 No. S30042-02-AADA
rma-0202\reporU\uda.ICp\8cc-8-10.1Cp
ScptaDbcr 1993
-------
Other location-specific requirements that the IRA will attain to the greatest extent practicable are
identified in Table 8-1.
8.2.3 Action-Specific Requirements
As discussed in Section 5, this IRA generally involves on-site activities relating to the
decontamination of PCB-contaminated equipment and surfaces as well as the removal of PCB-
contam~ted asphalt and soil. Accordingly, these on-site activities are . controlled almost
exclusively by the substantive requirements of TSCA and the regulations found in 40 CFR
Part 761. Action-specific requirements provided by TSCA and its associated regulations are
summarized in Table 8-2.
Although not anticipated, if RCRA hazardous wastes are generated as a part of the IRA, the
substantive hazardous waste requirements of 40' CFR Parts 260 to 268 and the correlating
Colorado Hazardous Waste Regulations, when stated as more stringent than RCRA, will become
action-specific ARARs. Especially noteworthy among these regulations is the requirement of
the land disposal restrictions (40 CFR 268.32) requiring that liquid hazardous wastes containing
PCBs in concentrations greater than or equal 50 ppm be treated prior to land disposal. Because
hazardous waste generation is not intended to be a part of this IRA, no further discussion of the
RCRA requirements as action-specific requirements is needed in this decision document.
.
.-
FiD8I Vcniall.0 Dceisioo DocUIIICIIt for Ek:maIt Two of tilt CERCL.A Liquid Wutca -lDt.crim R~ ActiaD
Rocky MOUDIaiD AncDal - Doc_I CoaIrol No. 5300-m-m-AADA
rma-m02\rq1ort1\uda.Icp~lO.1Cp
September 1993
-------
Table 8-1
Location-Specific ARARs for PCB Removal IRA
I LOCATION I CITATION r;;QUlREMENT I
Fault zones 40 CPR 264.18(a) RCRA regulations specify that
hazardous waste treatment, storage,
or disposal must not take place
within 200 feet of a Holocene fault.
Siting of Hazardous Waste Colorado Hazardous Waste Act, Outlines siting criteria for hazardous
Disposal Sites Sections 25-15-101, 203, 208, 302 waste disposal sites.
Siting within an area where action 36 CPR Part 65, National Historic Planned actions must avoid
. may cause irreparable harm, loss, Preservation Act threatening significant scientific,
or destruction of significant prehistorical, historical, or
articles. archeological data.
Siting on or near historic property 36 CPR Part 800, National Action to preserve historic
owned or controlled by federal Historic Preservation Act properties; planning of action to
agency. minimize harm to National Historic
Landmarks, included in or eligible
for the National Register of Historic
Places.
.
. .
I.
I
FiDaJ Vcnioa 1.0 Dccgioc Documcat for EIcmcot Two of Ibe CERClA Liquid Wutca - Interim Rcapcme ACIioc
Rocky Mounlain Ancu1 - Documc:Dt Coatrol No. 5300.02-02-AADA
rma-0202\rcpo1U\uda.acp\l=-S-10.1cp
September 1993
-------
Table 8-2
Action-Specific ARARs for PCB Removal IRA
I ACTION I CITATION ! REQUIREMENT !
PCB Storage and Disposal 40 CPR 761.60 Specifies storage and disposal
requirements for different types of
PCB materials and equipment
including mineral oil, other liquids,
non-liquid PCBs, and PCB
transformers, capacitors. and hydraulic
machines.
Design Requirements for PCB Storage 40 CPR 761.65 Specifies design requirements for: the
Units prevention of contact with rain water;
adequate curbing (min. 6-); prevention
of liquid migration from storage unit
(lack of valves, drains, joints, etc.,
and unit surfaces must be impervious).
Decontamination of PCB Containers 40 CPR 761.79 Specifies procedures to be followed in
and movable equipment decontAmintlt1J1g containers and other
equipment and provides requirements
for disposal of materials gene~ in
decontaminAtion.
. .
FiDa1 Venion 1.0 Decision 1>ocumaIt far Ekm=t Two of 1be CER.CLA Liquid w- - 1Dtcrim RcapoDIc ACIioD
Rocky MouataiD AncaaI - Documcut CaIIJoI No. 5300.0z.02-AADA
11D8-0202\n:po1ta\aada.acp\8cc-8-10.acp
ScpIcmbcr 1993
-------
SECTION 9
REQUIREMENTS TO BE CONSIDERED
In addition to ARARs, EPA has developed a category of requirements known as "to be
considered" (TBCs). This includes nonpromulgated criteria, advisories, guidance documents,
and proposed standards issued by fede~ and state governments. The PCB Spill Cleanup Policy
(40 CFR 761, Subpart G) is a TCB for this IRA.
9.1
PCB S~L CLEANUP POLICY
The PCB Spill Cleanup Policy establishes criteria EP A will use to determine the adequacy of
cleanup for PCB spills at greater than or equal to 50 ppm PCB, occurring after May 4, 1987,
and where reponing and cleanup is initiated within 24 hours. Whenever a PCB-contaminated
area is discovered and not cleaned up within the period specified in the cleanup policy or the
spill is an existing spill, EPA must approve the cleanup plan on a case-by-case basis. The PCB
spills at the RMA are existing spills, spills which occurred prior to May 4, 1987, and are
excluded from this policy. As such, the EPA must approve the cleanup plan on a case-by-case
basis following general guidelines established by each EP A regional office. With the exemption
for timely cleanup, regulatory requirements for the cleanup of PCB spills have never been
established. However, this policy does establish guidelines for spill cleanup and can be used as
a general framework for this IRA. The following describes the PCB Spill Control Policy.
There are two types of PCB spills. "Low concentration PCBs" are PCB spills that are tested
and found to contain less than 500 ppm PCBs, or those materials that EP A assumes to be at
concentrations between 50 and 499 ppm (Le., untested mineral oil dielectric fluid). "High
Concentration PCBs" are PCB spills that contain greater than or equal to 500 ppm PCBs.
, .
Filial VcniOD 1.0 Dccwioo DoclllllCDt for B1cmcat Two of tbe CERCLA Liquid W- - mrmm ReIpODIC Actioa
Rocky MOUDWD Anc:D8l - DocIllDCll1 CoIIIroI No. 5300-02-02-AADA
nD8-0202\rcpot1a\uda.""\scc-S-10.",,
ScpIcmbcr 1993
-------
9.1.1 Cleanuu of Low-Concentration Suills
Low concentration spills are spills with less than 1 pound of PCB material or less than 270
gallons of untested mineral oil. The following procedures must be performed:
.
Solid surfaces must be double washed/rinsed; except that all indoor residential
surfaces other than vault areas must be cleaned to 10 micrograms! 1 00 square
centimeters (cm2) as measured by standard commercial wipe tests.
.
Soil within spill area must be excavated and the ground restored to its original
configuration by backfilling with clean soil (soil containing less than 1 ppm
PCBs). The excavated soil must include all visible traces of the spill plus a
buffet of I lateral foot around the visible traces.
.
This cleanup must be completed within 48 hours after the responsible party was
notified or became aware of spill except for delays of emergency or adverse
weather.
.
The cleanup must be documented with records, which must be maintained for 5
years.
.
Responsible party or designated agent certifies that cleanup requirements have
been met and information in record is correct. The certification should be kept
for 5 years.
9.1.2 Cleanuu of Hi2h-Concentration Suills
High concentration spills are spills that contain PCB oil greater than or equal to 500 ppm or low-
concentration spills involving 1 pound or more PCB materials (270 gallons or more of untested
mineral oil). The following procedures must be performed:
.
The cleanup must be initiated within 24 hours (or within 48 hours for PCB
transformers) after responsible party was notified or became aware of spill except
for delays of emergency or adverse weather.
.
Notify the National Response Center and the EPA Regional Office if the spill is
10 pounds or more PCB by weight. Spills of 10 pounds or less must be cleaned
up in accordance with this policy, but EP A notification is not required.
Notifications must be made within 24 hours of discovery.
Filial Venioa 1.0 Dceiaioa Docum=t for Elcmea1 Two of ~ CBRCLA Liquid w- - IDIcrim JlcspoDIe A=aa
Rocky MOIIIIIIiD Ancoal - DocumaIt CoaII'oI No. 53C1O-02-02-AADA
rma-0202\Jq1ona\aada.acp\lcc-8-10.acp
Scp1.cmber 1993
-------
.
Cordon off or restrict the area encompassing any visible traces of spill material
plus a 3-foot buffer beyond visible traces. Place clearly visible signs advising
persons to avoid area.
.
Record and document the area of visible contamin~tion. Note the extent of the
visible trace area and center of the visible trace area. If there are no visible
contamination, this should be noted and the EP A Regional office contacted for
guidance in completing statistical sampling of the spill area to establisb spill
boundaries.
.
Initiate the cleanup of visible traces of fluid on hard surfaces and the removal of
visible traces of contamination on soil and other media.
.
If there was delay in reaching site and there are insufficient visible traces of PCBs
remaining at the spill site, the responsible party must estimate the area of the spill
and immediately cordon off the area of suspect contamination. The responsible
party must then utilize a statistically based sampling scheme to identIfy the
boundaries of the spill area as soon as practicable.
.
EPA, while not placing a time limit on the cleanup completion, expects the
decontamination and cleanup to be achieved promptly in all cases and will
consider promptness of completion when determining if responsible party made
good faith efforts to cleanup spill in accordance with this policy.
.
'Records must include information as requested in 40 CFR 761. 12S(c)(S).
9.1.2.1 Cleanup of Restricted Access Areas
Additional standards for Restricted Access' Areas apply as per 40 CFR 761. 12S(c)(3), including
the following:
.
.
t,', .
.
\ '
Verify by post-cleanup sampling.
High-contact solid surfaces = 10 micrograms/1oo cm2.
Low-contact, indoor, impervious solid surfaces = 10 micrograms/1oo cm2
Low-contact, indoor, nonimpervious solid surfaces = 10 micrograms/loo cm2 or
100 micrograms/loo cm2 and encapsulated.
. ,
.
Low-contact, outdoor
micrograms/loo cm2. ,
surfaces
(imperviouslnonimpervious)
100
-
FiDaJ Vcnica 1.0 Dccisica DocumcDt for E1c:m=t Two of die CERClA Liquid Wutca - lmcrim Jtc8poaIe Actica
Rocky MOUDI&iD AnaIal - Doc~ CoaIroI No. ,530().02-02-AADA
rma-0202\rcpor18\aada.ICp\8cc-S-l0.1Cp
September 1993
-------
.
Contaminated soil = 25 ppm.
9.1.2.2 Cleanup of Outdoor Electrical Substations and Nonrestricted Access Areas
There are additional requirements which must be met for spills at outdoor electrical substations
and for spills in nonrestricted access areas as defmed in 40 CFR 761.125(c)(2) and 40 CFR
761. 125(c)(4).
9.2
TARGET DECONTAMINATION GOALS
The target decontamination goals for the PCB IRA will be based on the PCB cleanup standards
established from precedents and policies (Table 9-1).
..
FiDaI Venioo 1.0 Dccilioo DocumaIt for EIaacD1 Two of !be CBRCLA Liquid W- - bIerim RCIpOIIIC Ac:Iioo
Roc:ty MOUDIaiu AnaIal - Doc:umcDt Coauol No. S300-02~-AADA
11D8~02\rc:porU\uda.ICp\lcc-8-1 0.1Cp
ScpIaIIbcr 1993
-------
Table 9-1
Target PCB Cleanup Standards Based on Precedents and Policies
I MEDIAILOCATION ILEVELIRANGE I SOURCE I
Surface
. Public Access/Contact 10 IŁg/loo cm2 EPN
. Secure Industrial 10 IŁglloo cm2 EPN
. ReStricted Access 100 IŁglloo cor EPN
Air 1 IŁg/fIiJ NIOSH"
1 mg/fIiJ when CI < 42 $ OSHA"
0.5 mg/m3 when CI >54$ OSHA"
Soil/Solids
. Exposed 10 ppm EPAa
. Covered/Sealed Below Surface 25 ppm EPAa
Metal PartslEquipment
. Contact Surfaces 10 IŁglloo cm2 EPAa
. As Scrap 2 ppm, 10 IŁg/l00 cur EPAd
a 40 CFR 761.125, Requirements for PCB Spill Cleanup Policy.
b mOSH, Occuoational Exnosure to Polychlorinated Biohenvls (PCBs), US Department of Health
Education and Welfare, September 1977.
" OSHA, Threshold Limit Values and Biological Exposure Indices, 1990-1991.
d Letter from Suzanne Rudzinski, EPA Office of Toxic Substances, to Toni Allen, Attorney for Edison
Electric Institute. September 9, 1986.
FiDaJ VenioD 1.0 DcciIioo Documcat for EJcmcat Two of !be CERClA Liquid WUICI - IDtcrim RapaaIc A;Iioo
Rocky MOUDIaiD AncIIaI - Documa1t CoaIro1 No. 5300-02-02-AADA
rma-0202\Rporta\aada.acp\acc-S-l0.acp
ScpIaDbcr 1993
-------
SECTION 10
REFERENCES
EBASCO Services, Inc., et al. 1991. Litigation Technical Support and Services, Rocky
. Mountain Arsenal Draft Final 'Volume I, Draft Fmal Volume n, and Final Volume m
. 'Inventory Report, Polychlorinated Biphenyl (PCB) Inventory, May 1991.
- '-
'- -
..-- '
. .
. -
4
. .
- .
- ,
. ~.
-
F"8181 VcnioD 1.0 JSCciIiaD ~ far ~ Two « ~ CDCLA. Liquid WUICI - IaIcrim ItapaaIc Actiaa
. aa;ty MCIaIIIIIiD A.-l- Doc:1-= CaIIraI No. S3CJ0..Q2-02-AADA -,
, """' rma-02O%\RpaIU~\8cc-I-lo.lCp -
. ,
ScpcaDbcr 1993
------- |