United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-92/102
December 1991
Superfund
Record of Decision:
Alabama Army Ammunition
Plant (Operable Unit 1),AL
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NOTICE.
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement. but adds no further applicable information to
the content of the document. All supplemental material is, however, contained in the adminis1rative record
for this site.
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50272-1 01
REPORT DOCUMENTATION 11. REPOATNO.
PAGE EPA/ROD/R04-92/102
, 4. 'T1Ilund Subtllle
SUPERFUND RECORD OF DECISION
Alabama Army Ammunition Plant (Operable Unit 1), AL
First Remedial Action - Final
7. Aulllor(a)
I~
3. Rec:lplenfa Acce8810n No.
S. Report DaI8
12/31/91
6.
8. Performing Organization Repl No.
9. Performing Orgalnlzatlon "-e SKI ~
10. ProjectfTaskIWofIt Unit No.
11. ConIr8ct(C) or GnnI(G) No.
(C)
(G)
12. SponsorIng Org8niZlltlon Name 8nd ~
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report.. PerIod Coverod
Agency
800/000
14.
15. SupplemenI8ly Notas
PB93-96400l
16. ~ (LImit: 2OOworda)
The 2,200-acre Alabama Army Ammunition Plant (AAAP) site is located in Talledega
County, Alabama, near the junction of Talledega Creek and the Coosa River. Land use
surrounding AAAP is mixed recreational and industrial. The majority of the surface
runoff from AAAP drains west or southwest into the Coosa River. Prior to construction
of AAAP, the area consisted of farms, woodlands, and wetlands. AAAP was built in 1941
as a government-owned/contractor-operated facility that produced nitrocellulose,
nitroaromatic explosives, and 2,4,6-trinitrophenyl methyl nitramine. Support of
chemical manufacturing included the use of sulfuric acid; aniline;
N,N-dimethylaniline; and diphenylamine. Operations at AAAP were terminated in August
1945, and in 1973 several parcels of the original 13,233-acre property were sold. In
1978, the U.S. Army Toxic and Hazardous Materials Agency (USATHAMA), managing the
Army's Installation Restoration Program (IRP) , identified soil, sediment, and ground
water potentially contaminated by explosives, asbestos, and lead as a result of past
site operations. During the RI/FS, the facility was divided into two general areas:
the eastern area (Area A) and the western area (Area B). In 1985, investigations
identified soil contamination by explosives, asbestos, and lead in Area A, and ground
(See Attached Page)
17. ~t An8Iy8I8 .. DeKrfp80n
Record of Decision - Alabama Army Ammunition Plant (Operable Unit 1), AL
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: explosives (2,4,6-TNT, 2,4-DNT, 2,6-DNT, and tetryl), metals
(lead), inorganics (asbestos)
b. Identltter8lOpen-En T.....
c. COSA 11 FIeIoWroup
1a. AVIIIl8bUlty~
19. s-.rtty CI888 (Thla Report)
None
20. SecurIty CI888 (ThI8 P8g8)
Nnn<=-
21. No. 0' P8gee
52
I
22. PrIce
(See ANSI-Z3t.18)
See IM1Iucdon8 Oft R-
27'2(4-"1
(Formerty NTJS.35)
Dep8rtm..t 01 Com-ca
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EPA/ROD/R04-92/l02
Alabama Army Ammunition Plant (Operable Unit 1), AL
First Remedial Action - Final
Abstract (Continued)
water contamination by these materials in Area B. In 1986, the Army conducted clean-up
activities at Area A, which included building decontamination and demolition, soil
excavation, and stockpiling. Soil excavated from Area A was stockpiled in Area B in two
covered buildings and on a concrete slab, which was subsequently covered with a membrane
liner. A 1991 characterization study of Area B concluded that explosives, lead, and
asbestos contamination were present above regulatory limits. This ROD addresses a final
action for the contaminated soil in the Stockpile Soils Area (Area B). A final remedy
for the remainder of the AAAP facility will be proposed by the u.S. Army following
completion of the RI/FSs currently in progress. The primary contaminants of concern
affecting the soil and debris are explosives, including 2,4,6-TNT, 2,4-DNT, 2,6-DNT, and
tetryl; metals, including lead; and asbestos, an inorganic.
The selected remedial action for the stockpiled soil in Area B includes separating
between 24,300 to 25,650 cubic yards of contaminated soil and between 1,350 to
2,700 cubic yards of asbestos-containing material; incinerating onsite contaminated
soil; testing the treated soil for explosives and lead to verify compliance with the
treatment criteria and stabilizing the soil or ash, if necessary, to meet LDR"s followed
by disposing of the treated soil and stabilized material onsite at designated backfill
area; and containerizing asbestos-containing material, followed by either onsite or
offsite disposal at a regulated facility depending on the quantity of material to be
disposed of and the availability of disposal facilities. The total present worth cost
for this remedial action ranges from $10,672,400 to $16,736,100, which includes a total
O&M cost of $8,782,800 to $12,767,500 for 9 to 12 months, depending on the type of
incinerator used. The estimated cost for asbestos disposal is $319,500, based on
offsite disposal and the cost of stabilization is $250 per cubic yard. The cost for
stabilization is not i~cluded in the total estimated cost because of the unknown
quantity of material to be stabilized.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil and debris clean-up goals are
based on federal standards, including explosives 1 ug/g of 2,4,6-TNT (RCRA) and lead
5 mg/l in the TCLP extract (RCRA).
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U. S. ARMY INSTALLATION
RESTORATION PROGRAM
RECORD OF DECISION
ALABAMA ARMY AMMUNITION PLANT, ALABAMA
STOCKPILE SOILS AREA OPERABLE UNIT
DECEMBER 1991
In accordance with Army Regulation 200-2, this document is intended by the Army to
comply with the National Environmental Policy Act (NEPA) of 1969.
-------
TABLE OF CONTE:vfS
DEClARATION OF THE RECORD OF DECISION
DECISION SUMMARY
.
1.0
2.0
3.0
4.0
5.0
:J
6.0
7.0
Site name, Location, and Description
Site History
Highlights of Community Participation
Scope and Role of the Stockpile Soils Area Operable Unit
Site Characteristics
5.1
5.2
5.3
5.4
5.5
5.6
5.7
5.8
5.9
Physiography
Climate .
Surface Hydrology
Geologic Setting
Land Use
Soils
Groundwater
Ecological System
Nature and Extent of Contamination
Summary of Human Health and Ecological Risks
Description of Alternatives
7.1
7.2
7.3.
Alternative 1 - No Action
Alternative 2 - On-Facility Thermal Treatment and On-Facility
Disposal of Treated Soil/On- or Off-Facility Disposal
of Asbestos-Containing Material
Alternative 3 - Off-Facility Thermal Treatment and Off-Facility
Disposal of Treated Soil/On- or Off-Facility Disposal of
Asbestos- Containing Material
1
1
4
6
6
9
10
10
10
11 ,-
11
11
11
13
13
13
14
16
16
16
16
18
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8.0
9.0
10.0
. 11.0
TABLE OF CONTENTS (Continued)
Summary of Comparative Analysis of Alternatives
8.1
8.2
8.3
Threshold Criteria
Primary Balancing Criteria
Modifying Criteria
Selected Remedy
9.1
Remediation Goals
Statutory Determinations
10.1
10.2
10.3
10.4
Protection of Human Health and the Environment
Compliance with Applicable or Relevant and Appropriate
Requirements
Cost-Effectiveness
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable
Documentation of Significant Changes
RESPONSIVENESS SUMMARY
A'ITACHMENT 1 - Community Relations Activities at Alabama Army
Ammunitions Plant
. .
ii
18
18
19
20
20
21
21
22
22
22
23
23
24
35
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DECLARATION OF THE RECORD OF DECISION
~,
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DECLARATION OF THE RECORD OF DECISION
SITE NAME AND LOCATION
Alabama Anny Ammunition Plant
Stockpile Soils Area Operable Unit
P. O. Box 368
Childersb~rg, AL 35044-0368
STATEMENT OF PURPOSE
This decision document presents the selected' remedial act~on for the Stockpile Soils Area
Operable Unit, at Alabama Anny Ammunition Plant, ChildersJurg, Alabama, which was chosen
in accordance with the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act
of 1986 (SARA), and, to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based on the administrative record for the
site. .
This early remedial action is taken to protect human health and the environment from
unacceptable risks and is the fmal remedial action planned for the Stockpile SoilS. .
. The U.S. Environmental Protection Agency and the State of Alabama concurs with the selected
remedy.
ASSESSl\1ENT OF THE SITE
Actual or threatened releases of hazardous substances. from this site, if not addressed by
implementing the response action selected in Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The Stockpile Soils Area Operable Unit addresses the principal threats from explosives, lead,
. and asbestos containing material posed by the Stockpile Soils at the Alabama Army Ammunition'
Plant. The Stockpile Soils Area Operable Unit consists of soil stockpiled in a covered building
and on a concrete slab covered with an impermeable membrane. The scope of the ROD is
limited to the Stockpile Soils Area Operable Unit.
The seiected Remedy for the Stockpile Soils Area Operable Unit consists of the following:
.
On-Facility Thermal Treatment of Stockpile Soils
2
-------
.
On-Facility Dis;.-.)sal of'rreated Soil
.
On- or Off-Facility Disposal of Asbestos-Comaining Material
STATIJTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federn1
and State requjrements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-~ffective. This remedy utilizes permaneat solutions and alternative treatment
teclmologies to the maxlmom extent practicable, and satisfies the statutory preference for
remedies that employ treatment that reduce toxicity, mobility, or volume as a principal element.
~~.W~
IZ!31/Q/
Lewis D. Walker
Deputy Assistant St:\.;J.d.u.j of the Army
(Environment, Safety, and 0ccupati0Da1 Health)
Date
3
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RECORD OF DECISION
ALABAMA ARMY AMMUNITION PLANT, ALABAMA
STOCKPILE SOn.s AREA OPERABLE UNIT
DECEMBER 1991
~GL-
3' / br:i-m ;;.,..: ~f'/
Lieutenant Colonel T. E. Dresen
Commander. Holston Army Ammunition Plant
Commander, ..At:lMrqa Army Ammunition Plant
. .
4
Date
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DECISION SUMMARY
~,
5
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DECISION SUMMARY
1.0 SITE NAME. LOCATION. AND DESCRIPTION
MAl' is located in central Alabama in Talledega County, 4 miles north of Childersburg and 40
miles southeast of Binningham, Alabama, as shown in Figure 1. It encompasses 2,200 acres
of land near the junction of Talledega Creek and the Coosa River. This early action ROD is
limited to the soils stockpiled in a covered building, and on a concrete slab and covered with an
impermeable membrane. This II Stockpile Soils Area" is located in the western section of MAl'
as shown in Figure 2.
The climate of Talladega County is temperate. . The majority of the surface runoff from AAAP
drains either west or southwest into the Coosa River. Prior to the construction of AAAP, the
area consisted of farms, woodlands, and wetlands. Much of the western half of AAAP was
poorly drained. Small natural drainways were enlarged and rerouted to provide drainage from
the various manufacturing operations.
Potable groundwater from the dolomite aquifer of the Coosa Valley supplies the needs of the
communities, homes, farms, and industries around MAP. The majority .of the successful wells
draw water from solution cracks and cavities in the dolomite.
2.0 SITE HISTORY
AAAP was built in 1941 and operated during World War n as a Government-owned/contractor
operated facility. MAP produced nitrocellulose (NC), a single-base smokeless powder;
nitroaromatic explosives, Le., 2,4,6-trinitrotoluene (TNT), 2,4-dinitrotoluene (DNT); and
2,4,6-trinitrophenylmethylnitramine (tetryl). Supporting chemical manufacture included sulfuric
acid, aniline, N,N-dimethylaniline, and diphenylamine. Operations at AAAP were terminated
. in August 1945. The plant was maintained under standby status until 1973. In 1973, the
Department of the Army declared AAAP as an excess propetty. Since that time, several parcels
of the original13,233-acre propetty have been sold.
In 1978, the.U.S.. Army Toxic and Hazardous Materials Agency (USATIIAMA), managing the
Anny's Installation Restoration. Program (IRJ»), oonducted a record search that concluded that
specific areas of the facility were potentially contaminated by explosives and lead compounds.
Further studies confumed contamination of the soils at AAAP with explosives compounds,
asbestos, and lead. Several investigations were conducted between 1981 and 1983 to further
define CODt~mination. In 1984, AAAP was proposed for inclusion on the .cERCLA (Superfund)
National.Priorities List (NPL).
A remedial investigation and feasibility study (RIIFS) under the Department of Defense (DOD)
IRP was initiated in 1985 to determine the nature and extent of contamination at AAAP and to
determine the alternatives available to clean up the site. For the purposes of the RIlFS, the
6
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"
TaJladega
County
Birmi gham. ~
AAAPlY
o
Montgomery
Alabama
Bon Air
D.S
,
Scale
o 0.5
1 Mile
.
~
-N-
~
416.5334
AAAP ~S
FIGURE 1
LOCATION MAP OF AAAP
7
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00
240-2991 a
~
1
At 235
Area B
Q
Area Sold in
August 1990
Nolto Scale
AMP FS
FIGURE 2 AAAP FACILITY MAP
-------
facility was divided into two general areas. Area A consisted of the eastern portion of the
facility, while Area B consisted of the western portion (Figure 2). The initial RI under the IRP
confirmed the existence of explosives, asbestos and lead contamination in the soil in Area A, and
in the soil, sediment, and groundwater in Area B. The RI for Areas A and B was completed in
1986. As a result of the findings of the RI, cleanup activities at Area A were conducted in 1986
and 1987 which included building decontamination and demolition, soil excavation, and
stockpiling. Soils excavated from Area A were stockpiled in Area B in two covered buildings
and on a concrete slab which was subsequently covered with a membrane liner. In 1987, AAAP
was placed on the NPL. In 1990, the EPA indicated that additional investigations needed to be
conducted, at Area A to ensure that no residual contamination remained. Area A was conveyed
to private buyers in August 1990, with the provision that additional investigations would be
performed.
In February 1991, a Characterization Study was conducted for the Stockpile Soils in Area B.
The Study concluded that explosives, lead and asbestos contamination were present above
regulatory limits. On 29 March 1991, a tornado demolished one of the two buildings that
contained Stockpile Soils. Soils from the demolished building were relocated on the concrete
slab and secured with the membrane liner.
The following documents outline the results of the initial assessment of the AAAP, clean up
actions conducted in Area A, and the investigations of the Stockpile Soils Area Operable Unit.
1. Installation Assessment of Alabama Army Ammunition Plant, Report 130, May
1978.
2. Alabama Army Ammunition Plant, Area A Remedial Actions, Final Report,
February 1988.
3. Stockpile Characterization Report for Alabama Army Ammunition Plant (AAAP),
Childersburg, Alabama, July 1991.
4. Feasibility Study for the Alabama Army Ammunition Plant (AAAP) Soil Stockpile
Area, October 1991.
5. Proposed Plan for Early Remedial Action of Stockpile Soils at the Alabama Army
Ammunition Plant (AAAP) Stockpile Soils Area Operable Unit, November 1991.
In accordance with the Army's Community Relations Plan (CRP), for the Alabama Army
Ammunition Plant, October 1990, the Feasibility Study and the Proposed Plan for the Stockpile
Soils Area Operable Unit were released to the public on November 21, 1991. The public
comment period started on November 21, 1991 and ended on December 23, 1991. Documents
were made available to the public at the following locations: the U.S. Environmental Protection
-------
Agency (EPA) Library, Atlanta, Georgia; the Library SeIVice, Alabama Public Information,
Montgomery, Alabama; the B.B. Comer Memorial Library and Information Center, Sylacauga,
Alabama; and the Earle A. Rainwater Memorial Library, Childersburg, Alabama. The notice
of availability of the Proposed Plan was published in Daily Home, Birmingham News, Anniston
Star, and Montgomery Advertiser on 19 November 1991. In accordance with the CRP, a public
meeting was held on December 5, 1991 to inform the public of the preferred alternative and to
seek public comments.' At this meeting, representatives from MAP, EPA, Alabama
Department of Environmental Management (ADEM), United States Anny Corps of Engineers
(USACE), USATIiAMA, and Weston SeIVices, Inc. (a remediation contractor) answered
questions' about the site and the remedial alternatives under consideration. A response to the
comments received during this period is included in the Responsiveness Summary, which is a
part of this Record of Decision.
The Proposed Plan identified Alternative 2 as the preferred remedy for the Stockpile Soils Area
Operable Unit. Alternative 2, which is described in the Feasibility Study, consists of: On-
Facility Thermal Treatment of Stqckpile Soils and On-facility Disposal of Treated Soil/On- or
Off-Facility Disposal of Asbestos-Containing Material.
AAAP, EPA, ADEM, and USATHAMA reviewed all written and verbal comments submirted
during the public comment period. Upon review of these comments, it was determined that no
significant changes to the preferred remedy outlined in the Proposed Plan were necessary.
4.0 SCOPE AND ROLE OF THE STOCKPll.E SOILS AREA OPERABLE UNIT.
,
The Stockpile Soils Area Operable Unit cleanup strategy is an early remedial action for the
Stockpile Soils at AAAP. The action is intended to be the final action for only the contaminated
soils within the Stockpile Soil Area. A Final remedy for the remaining portions of the AAAP
facility will be proposed by the U.S. Army following the completion of RI/Fss currently in
progress. No further actions are planned for the remediated Stockpile Soils.
The threats addressed in the in the early remedial action are the contaminated Stockpile Soils
contained in a covered building and on a concrete slab covered with a membrane liner. These
storage and access controls are considered inadequat~ for any permanent storage. Actual or
threatened release of hazardous substances from the contaminated Stockpile Soils, if not
addressed by implementing the selected ~ly .Remedial Action, may present a current ,or
potential threat to public health', welfare and the environment.
5.0 SITE CHARACTERISTICS
5.1 Physiography
AAAP is located in the Coosa V-aIley diStrict of the Valley and Ridge physiographic province.
The border betWeen the Valley and Ridge province and the Piedmont province is south of AAAP
between Talladega, and Tallaseehatchee Creeks:
10
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'-
I
5.2 Climate
The climate of Talladega County is temperate. Summer weather, which lasts from Mayor June
until September or October, is almost subtropical because maritime tropical air prevails along
the Bennuda high-pressure system.
Mean annual rainfall is 52 inches. The lowest average monthly rainfall (2.2 inches) occurs in
October and the highest average monthly rainfall (6.4 inches) occurs in March.
5.3 Surface Hydrology
The majority of the surface runoff from AAAF drains either west or southwest into the Coosa
River. A small portion of the southern and eastern side of AAAF drains toward Talladega
Creek, a tributary of the Coosa River. Prior to the construction of AAAP, the area consisted
of fanns, woodlands, and wetlands. Much of the western half of AAAP was poorly drained.
Small natural drainways were enlarged and rerouted to provide drainage from the various
manufacturing operations.
~,
As shown in Figure 3, two natural drainage systems conveyed surface runoff from AAAP, west
to the Coosa River. Liquid industrial wastes from the explosives manufacturing operations were
conveyed west to the Coosa River by a manmade channel. No natural ponds existed on AAAP
during its operation, however, two large storage lagoons were constructed to retain industrial
wastes. Extensive wooded swamp and open pond areas have developed in the drainage syste~ns
at AAAP since the beginning of demolition activities in 1973, primarily as a result of damming
of drainways by beavers.
5.4 Geologic Setting
The bedrock underlying AAAP has been mapped on a regional scale and has been identified as
the undifferentiated Knox Group of Upper Cambrian to Lower Ordovician age dolomite. The
dolomite underlying AAAP is thick- to medium-bedded, cherty, and penetrated by numerous
cavities, joints and fractures. The dolomite is overlain by residual soil derived from it by
weathering processes. This soil matrix consists primarily of clay, with some silt, sand, and
occasional chert boulders, and varies in thickness from less than 1 meter (m) to over 15 m.
5.5 Land Use
The AAAP is currently in an inactive caretaker status with controlled access. There is no
activity on AAAP other than occasional Army-supervised logging. The . land use surrounding
AAAP is a mixture of recreational and industrial. AAAP is bordered on the west side by a
country club, on the south by a paper products company, on the east by wooded, private
property, and on the north by a water treatment plant. .
11
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m
. ---------~- AAAP BOUN[)ARY (1888)
-~.. - DRAINAGE,PATHS
-.--.--.BOUNDARYBE~EEN
AREAS A AND B
\
__1::0 .,,, .--=-~.~_.-.~- ... -
----~
......
N
}
I
(
ifh.
5110
SOU"CES: IISAIIIAMA, 1911!1; ESE, 19118
----------.---- ---.----.
',01111 ME II ns
----- --..--
FIGURE 3 DRAINAGE PATTERNS AT AAAP
o 1,500
I ----~.-:~,
o 500
.
.
..
!
~
W(l(l"~" AIU A
J
//
3,01111 'U; I
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5.6 Soils
The soils at AAAP are generally divided into three associations. Soils of the Bodine-Minvale
association are found on the high ground of the eastern portion of AAAP. This association is
composed of deep, well-drained, steep, cherty, medium-textured soils derived from limestone
and dolomite. Most of AAAP is covered by soils of the Decatur-Dewey-Fullerton association,
which are also deep. well-drained, loam soils derived from limestone and dolomite. The soils
of the floodplains of Talladega Creek and the Coosa River have been classified as the Chewacla-
Chenneby.-McQueen association. These are deep, nearly level, alluvial loam soils which grade
from somewhat poorly-drained to well-drained and are subject to flooding.
These broad-based associations represent agricultural classifications rather than engineering
descriptions. Soil constitution within any of the three associations may range from soils
consisting primarily of sand and silt with little clay to soils comprised almost entirely of clay.
5.7 Groundwater
Potable groundwater from the dolomite aquifer of the Coosa Valley supplies the needs of the
communities, homes, fanns, and industries around AAAP. The majority of the successful wells
draw water from solution cracks and cavities in the dolomite. A few wells are completed in the
residual soil, but these wells are less productive than those drilled into the dolomite.
5.8 Ecological Systems
Prior to the construction of the ammunition plant, the area consisted primarily of cropland and
woodland. During its operational years, mud~ of AAAP consisted of maintained industrial
areas. The Anny instituted a woodland management plan following the closure operations which
extensively modified AAAP by allowing for the planting of 3,411 acres of controlled pine forest.
The . area was also changed as a result of demolition of various areas following closure
operations.
At present, many of the fonnerly maintained drainages, pathways, pine plantations, and cleared
areas have undergone considerable vegetative overgrowth. Damming of surface drainages by
beavers has modified the drainage systems; drainage has become much slower, and extensive
wooded swamp and shallow pond areas have developed. As a result of these changes, the major
ecological systems currently consist of the following types: grassland/old field association,
upland pine forest/pine plantations, oak forests, low moist pine woods, hardwood swamps,
intennittent streams, shallow ponds, and drainage ditches.
These systems support abundant populations of aquatic and terrestrial organisms. White-tailed
deer, introduced in the 1960's have become particularly abundant as have certain predators (the
red-tailed hawk, the marsh hawk, and the bobcat).
The extensive development of shallow beaver ponds has resulted in large populations of
13
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amphibians and aquatic reptiles and has provided habitat for wading birds and other waterfowl.
Wood ducks are abundant, year-round residents at AAAP. During faIl and winter, the ponds
support large populations of migratory waterfowl.
The Stockpile Soils Area Operable Urnt is located in a cleared well-drained area adjacent to the
western boundary of the AAAP.
5.9 Nature and Extent of Contamination
The soils. of concern in the Stockpile Soils Area Operable Unit are stockpiled in a covered
building and on a concrete slab covered with an impermeable membrane. These Stockpile Soils
are contaminated with explosives, lead and asbestos concentrations above regulatory limits.
Table 1 presents the contaminants of concern from the Characterization Study, conducted in
February 1991. The results are summarized as follows: . .
Explosives - 2,4,6- TNT, 2,4-DNT, 2,6-DNT and tetryl were detected in samples; the
total concentration of explosives was as high as 12 ppm (parts per million).
Lead - Lead concentrations in the extract of samples generated by using the Toxicity
Characteristic Leaching Procedure (TCLP) varied between 0.66 and 185 mg/I (milligrams
per liter). The average lead concentration was 17.1 mg/l.
-
Asbestos - Asbestos was present in Stockpile Soils in two forms: (1) mixed with soil in
low concentrations; and (2) large pieces or chunks with high percentages of asbestos.
Currently, approximately 27,000 cubic yards of soil is stockpiled at AAAP. The volume of
soil, excluding asbestos-containing material, is estimated to range from 24,300 to 25,650 cubic
yards. The quantity of asbestos-containing material, is estimated to range from 1,350 to 2,700
cubic yards.
During the characterization study field activities, smaIl clumps of 1/4 to 1 inch in diameter
yellowish-gray material which had the appearance of TNT was identified in Stockpile Soils.
Explosives contamination with sufficient concentration to be flammable and reactive is
considered hazardous under the Res9urce Conse~ation and Recovery Act (RCRA). Materials
that contain greater than 5 mg/l' of lead in ther TCLP extract are considered to be a hazardous
waste under RCRA. Material that contains greater than 1 % asbestos by weight is called
asbestos:.containing material (ACM) and is considered hazardous under the Toxic Substances
Control Act (TSCA). .
14
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TABLE 1
CONTAMINANTS OF CONCERN AND CONCENTRATIONS IN STOCKPILE SOILS
Contaminant Concentration
Field/Site 2,4,6- TNT 2,4-DNT 2,6-DNT Tetryl Lead in TCLP
Identification (ug/g) (ugl g) (ug/g) (uglg) Extract mgl1 ABbeBtoB (%)
Building TC4$
TC4-1 ND ND NO NO 6.5 NO
TC4-2 2.84 NO NO NO 185 NO
Building TC4A
TC4A-l 3.31 1.18 NO 6.94 34.4 NO
TC4A-2 2.32 0.65 NO 3.04 2.6 NO
TC4A-3 NO 0.95 NO NO 0.72 < 1 chryBotile
.- TC4A-4 'NO 0.70 NO NO 0.66 NO
\J1
Concrete Slab
CS-l NO NO NO NO 1.4 < 1 chryBotile
CS-2 NO NO NO NO 4.5 < 1 chryBotile
CS-3 NO NO NO NO 0.69 NO
CS-4 NO NO NO NO 1.9 < 1 chryBotile
CS-5 NO 0.75 NO NO 2.7 ND
CS-6 NO NO 0.68 NO 13.9 NO
CS-7 6.06 NO NO NO 3.9 < 1 chryBotile
CS-8 NO NO NO NO 10.1 ND
CS-9 NO NO NO NO 1.1 ND
CS-I0 (CS-8 duplicate) NO NO 0.56 NO 4.9 < 1 chryBotile
$ Building TC-4 was destroyed by a tornado after characterization Key: ug/g = microgramB/gram (parts per million)
sampling was conducted. mgl1 = milligram8 per liter
NO = Not Detected
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6.0 SUMMARY OF HUMAN HEALm AND ECOWGICAL RISKS
In summary, based on the Characterization Study, the contaminants of concern in the Stockpile
Soils Area Operable Unit are explosives, lead, and asbestos.
The early remedial action is being taken because the contaminated soils represent an actual or
threatened release of hazardous substances from the contaminated Stockpile Soils Area.
The remediation goal is the elimination of site risks by treating the contaminants of concern in
accordan'ce with applicable or relevant and appropriate requirements and regulations. Achieving
this goal will result in overall protection of human health and the environment.
No ecological risks are known to exist as a result of Stockpile Soils. Conducting the early
remedial action will eliminate threats of ecological hann by eliminating Stockpile Soils.
7.0 DESCRIPTION OF ALTERNATIVES
Three different remedial action alternatives have been developed for the treatment of Stockpile
Soils at AAAP. A brief description of the remedial alternatives that were evaluated is presented
in Subsections 7.1,7.2, and 7.3.
7.1 Alternative 1 - No Action
, -
The No Action alternative is required to be included as stipulated by CERCLA/SARA. 'No
remedial action will be performed in this alternative. The no action attemative serves as a
baseline against which other alternatives can be evaluated. Under this alternative, hazardous soil
would remain in a storage location that was approved only for temporary storage. The risks
from the contaminants of concern would continue to remain. No cost is associated with this
alternative.
Estimated Consttuction Cost
Estimated Operation and Maintenance Cost
Estimated Total Present Worth Cost
Approximate Duration
$0
$0
$0
o months
7.2
Alternative 2 - On-Facility Thermal Treatment and On-Facility,Disposal of Treated
SoiIJOn- or Off-Facility Disposal of Asbestos-Containing Material
In Alternative 2, soil will be separated from the asbestos containing material. Soil will be
transported to the on-facility thermal treatment unit for incineration. Treated material will be,
analyzed for explosives and lead to verify compliance' with the treatment criteria as described
in "Remediation Goals", in Section 9.1. The explosives will be destroyed during the
incineration process. If lead concentrations in the treated soil or fly ash exceed the allowable
regulatory standards, that material will be stabilized in compliance with land Disposal
,~.
16
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Restrictions. T~ted soil and stabilized material will be placed at the on-facility designated
backfill area at AAAP. The on-facility incinerator will be removed upon completion of the
project.
Asbestos-containing material will be containerized and transported to an on- or off-facility
disposal facility that meets the technical standards for asbestos disposal. The quantity of material
to be disposed of and the availability of disposal facilities will determine whether on- or off-
facility disposal of the asbestos-containing material will be used.
The cost 'of the remediation will depend upon the type of incinerator that will be used. The
estimated cost of asbestos disposal is approximately $319,500 based on off-facility disposal. The
cost of stabilization is approximately $250 per cubic yard of material. The cost of stabilization
is not included in the total estimated costs, as the quantity of material to be stabilized is not
known at this time. The remediation costs employing three available types of on-facility
incinerators are presented below.
Rotary Kiln Incinerator
~l
Estimated ConstnIction Cost
Estimated Operation and Maintenance Cost
Estimated Total Present Worth Cost
Approximate Duration
Approximate Waiting Period
$ 1,889,600
$ 8,782,800
$ 10,672,400
9-12 months
o months
Infrared Incinerator
Estimated Constroction Cost
Estimated Operation and Maintenance Cost
Estimated Total Present Worth Cost
Approximate Duration
Approximate Waiting Period
$ 1,889,600
$ 14,846,500
$ 16,736,100
9-12 months
o months
Fluidized Bed Incinerator
Estimated Constroction Cost ..
Estimated Operation and Maintenance Cost
Estimated Total Present Worth Cost
Approximate Duration
Approximate Waiting Period
$ 1,889,600
$ 12,767,500
$ 14,657,100
9-12 months
o months
17
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7.3
Alternative 3 - Off-Facility Thermal Treatment and Off-Facility Disposal of Treated
Soil/On- or Off-Facility Disposal of Asbestos-Containing Material.
In this alternative, soil will be separated from the asbestos containing material. Soil will be
transported to an off-facility thennal treatment unit for incineration. Treated material will be
analyzed to ensure compliance with the treatment standards, and disposed at a permitted landfill
that will accept the material. Stabilization of incinerator bottom ash and fly ash will be
perfonned, if required, prior to disposal to ensure compliance with treatment standards.. Treated
soil and stabilized material will be disposed at an off-facility landfill.
Asbestos-containing material will be containerized and transported to a disposal facility that
meets the technical standards for asbestos disposal.
Estimated Construction Cost
Estimated Operation and Maintenance Cost
Estimated Total Present Worth Cost
Approximate Duration
Approximate Waiting Period
$ 8,229,700
$ 59,909,850
$ 68,139,550
9-12 months
36-60 months
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
8.1 Threshold Criteria
Overall Protection of Human Health and the Environment
Alternative 1 does. not provide protection of human health or the environment. Risks to the
community, workers and the environment will continue to remain. Alternative 1 does not meet
the threshold criteria, is not protective and does not meet ARARs. Alternatives 2 and 3 provide
protection to the community and the workers. by reducing the risks posed during remedial
actions. Once the remedial actions are completed, there is expected to be no unacceptable
residual risk to human health or the environment.
Comp1iance with J\pplicable or Relevant and Ap,pro,priate Requirements (ARARs)
Alternative I will not comply with any of th~ ARARs. Alternatives 2 and 3 will be conducted
in accordance with afi applicabie, relevant, arid appropriate requirements and regulations. The
major laws include:
.
.0
.
.
Resource ConselVation and Recovery Act (RCRA)
Toxic Substances Control Act (TSCA)
Clean Air Act (CAA)
Alabama Department of Environmental Management (ADEM) Hazardous Waste.
Regulations
18
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i .
.
.
.
Department of Transport (DO'!) regulations
Endangered Species Act (ESA)
Occupational Safety and Health Act (OSHA)
8.2 Primary Balancing Criteria
Long- Tenn Effectiveness and Pennanence
A high residual risk is expected in Alternative 1 as no remedial actions are involved. Existing
storage and access controls are not reliable or adequate. In Alternatives 2 and 3, the magnitude
of residual risks will be removed as all of the contaminants are treated and disposed in
accordance with applicable regulations. The treatment technologies and disposal options used
are reliable and adequate for Alternative 2. There is no waiting period for on-facility
incineration. For Alternative 3, there is a 3 to 5 year waiting period for capacity in an
off-facility incinerator. Alternative 2 is preferred as the remedial actions can be completed much
earlier than in Alternative 3, thereby removing the residual risks 3 to 5 years earlier than in
Alternative 3.
Reduction of Toxicity. Mobility and Volume of Contaminants
:'
Alternative I does not address the principal threats of the Stockpile Soils nor does it satisfy the
statutory preferences for treatment. Toxicity, mobility, and volume of contaminants are
expected to remain at their present values for extended periods of time. Alternatives 2 an<:1 3
address the principal threats of the Stockpile Soils and satisfy the statutory preference for
treatment. All of the contaminants of concern are treated and disposed in accordance with
applicable regulations thereby reducing or eliminating the toxicity, mobility, and volume of the
contaminants.
Short- Tenn Effectiveness
In Alternative I, the residual risks to the community, workers and the environment will continue
to remain as no remedial actions will be conducted. In Alternatives 2 and 3, the community,
workers, and the environment will be protected during remedial actions by taking appropriate
protective measures. Alternative 2 is preferred as there is no short-tenn risk associated with
transporting contaminated soil off-facility ,on public roads. Alternative 3 will involve
transporting contaminated soil from AAAP to an off-facility incinerator.
Implementability
All three alternatives can be implemented. However, Alternative I is eliminated as it does not
satisfy the threshold criteria of Protection of Human Health and the Environment and compliance
with ARARs. Alternative 2 is preferred to Alternative 3 due to (1) Ease of implementation as
there is no off-facility transport of contaminated soil; and (2) There is no waiting period for
on-facility incineration. Off-facility incineration has a 3 to 5 year waiting period.
19
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Cost
Alternative I will not involve any cost, however, it does not satisfy the threshold criteria of
Protection of Human Health and the Environment and compliance with ARARs. For Alternative
2, the total cost of remedial actions employing the three types of on-facility incinerators are: (1)
Rotary Kiln Incinerator - $10,672,400; (2) Infrared Incinerator - $16,736,100 and; (3)
Fluidized Bed Incinerator $14,657,100. For Alternative 3, the total cost of remedial action is
$68,139,550. The total cost for remedial action in Alternative 2 employing one of the three
types of on-facility incinerators ranges between 15 - 25 % of the cost associated with remedial
action in'Alternative 3. Therefore, Alternative 2 is strongly preferred to Alternative 3 on the
basis of cost.
8.3 Modifying Criteria
ADEM/EP A Acceptance
BPA and ADEM have concurred with the choice of Alternative 2.
Community Acce,ptance
Public comments on the selected remedial action were minimal. The majority of the comments
requested additional information about the safety of the remedial action, and the status and the
results of the environmental studies ongoing at the remainder of AAAP. These concerns a~
to have been addressed. The only opposition was to spending funds to mitigate soil stockpiles
that appeared to pose little threat to human health or the environment. The public appears to
have no concern about the implementation of the remedy other than its cost.
9.0 SELECTED REMEDY
The selected alternative (Alternative 2) calls for implementation of an ~y remedial action to
protect human health and the environment from the Stockpile Soils at AAAP'~ This action is
intended to be the final action for only the contaminated soils in the Stockpile Soils Area
Operable Unit. A Final Remedy for the remaining portions of the AAAP facility will be
proposed following the completion of the other Remedial Inyestigations and Feasibility Studies
currently in progress. - . .
Based upon the CERCLA requirements, the detailed analysis of the alternatives, and public
comments, AAAP, in consultation with EP A and ADEM has determined that Alternative 2 is
the most appropriate remedy for the Stockpile Soils Area Operable Unit. .
The complete remedy for the Stockpile Soils Area Operable Unit for sOurce control includes;
.
On-Facility Thermal Treatment of Stockpile Soils
20
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.
On-Facility Disposal of Treated Soil
.
On- or Off-Facility Disposal of Asbestos~Containing Material
The cost of the remediation will depend upon the type of incinerator that will be used for the
treatment of Stockpile Soils. The remediation costs employing three types of on-facility
incinerators are presented below.
Rotary Kiln Incinerator
Estimated Construction Cost
Estimated Operation and Maintenance Cost
Estimated Total Present Worth Cost
$ 1,889,600
$ 8,782,800
$ 10,672,400
Infrared Incinerator
Estimated Construction Cost
Estimated Operation and Maintenance Cost
Estimated Total Present Worth Cost
$ 1,889,600
$ 14,846,500
$ 16,736,100
Fluidized Bed Incinerator
:.
Estimated Construction Cost
Estimated Operation and Maintenance Cost
Estimated Total Present Worth Cost
$ 1,889,600
$ 12,767,500
$ 14,657,100
9.1
Remediation Goals
The selected remedy will meet the following treatment standards for the contaminants of concern
in the Stockpile Soils:
.
Explosives - Deactivation of explosives, as required by RCRA. A treatment
standard of I microgram per gram. (p.glg) of 2,4,6- TNT will be used to demonstrate
deactivation;
.
Lead - Concentration less than 5 mg/l in the TCLP extract, as required by RCRA;
.
Asbestos Containing Material - Containerize appropriately and dispose at a facility
that meets the technical standards for asbestos disposal, as required by TSCA.
10.0
STATUTORY DETERMINATIONS
The selected remedy satisfies the requirements under Section 121 of CERCLA to:
.
Protect human health and the environment.
21
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.
Comply with ARARs.
.
Be cOst-effective.
.
Utilize permanent solutions and alternative treatment technologies or resource.
recovery technologies to the maximum extent practicable.
.
Satisfy the preference for treatment as a principal element.
10.1
Protection of Human Health and the Environment
The selected remedy protects human health and the environment through treatment and disposal
of soils in the Stockpile Soils Area Operable Unit. .
During the remediation activities, adequate protection will be provided to the community by
reducing the short-term risks posed by air emissions from the thermal treatment unit, and by the
.dust and asbestos fibers potentially generated during material handling activities. In addition,
wOlkms will be provided with personal protection equipment during all phases of remediation
activities. .
Long-term protection to the human health and environment will be provided by leaving no
residual risk from the contaminants and by reducing or eliminating the iinpact on the
environment. .
Controls employed in this alternative are adequate and reliable. There are 00 unacceptable shOIt-
term or long-term impacts on human health or the environment in this alternative.
10.2
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy complies with all Applicable or Relevant and Appropriate Requirements.
All ARARs will be satisfied in this alternative. All of the contaminants of concern at the
Stockpiled Soil, Le., explosives, lead and asbestos are expected to meet required regulatory
treatment/disposal standards prior to disposal.
10.3
Cost-Effectiveness
'.
The selected remedy for the Stockpile Soils Area Operable Unit has been determined to provide
overall effectiveness proportionate to its costs. While providing overall protection of public
health and the environment, this alternative is substantially less expensive than the other remedial
alternative" that provides the same results. The estimated total present worth costs for the
selected remedy (based on the type of on-facility incinerator) are as follow~:
.
Rotary kiln incineration
$10,672,400
22
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.
Infrared incineration
$16,736,100
.
Fluidized bed incineration
$14,657,100
10.4
Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
The selected remedy meets the statutory requirements to utilize permanent solutions and
treatment technologies to the maximum extent practicable to achieve remediation goals. The
rationale for selecting this remedy is based on the comparative analysis of the evaluation criteria.
The criteria used in selecting the remedy include:
.
Long- Term Effectiveness and Permanence: No waiting period is involved for
implementation of the selected remedy.
.
Short-Term Effectiveness: Selected remedy does not involve off-facility
transportation of contaminated soils, thereby, e1iminating the risks due to spillage
and dust emissions. The community, workers, and the environment will be
protected during remedial actions by implementing appropriate protective measures.
.
Implementability: Ease of implementation - no waiting period, and no off-facility
transportation of contaminated soils.
Cost: The cost of the selected remedy is substantially less expensive, an estimated
15-25 % less than the cost of the other remedial alternative.
~,
.
11.0
DOCUMENTATION OF SIGNIFICANT CHANGES
No significant changes to the Proposed Plan were made.
23
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RESPONSIVENESS SUMMARy
- .
24
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RESPONSIVENESS S1:.JMMARY
1.0 OVERVIEW
The public IUction to the selected remedy is mainly acceptance, though a small number of
commenters questioned the need for the remedial action and expenditure of the funds. This
appears to be due to the fact that the contamination from this operable unit bas been contained
for the last'several years and bas caused no known exposure. More public concern has been for
the possibility of off-post groundwater contamination. Studies have not discovered evidence of
such contamination. However, this infonnation has not reached all of the public, although
remedial investigation documents have been published in the local libraries and a public meeting
was held in August 1991 to discuss the AAAP site in general. Responses to the comments
received appear to have addressed public concerns, and continued community relations activities
will be held to increase the public awareness of the conclusions at AAAP.
2.0 BACKGROUND ON COMMUNITY INVOLVEMENT
:.t
General community interest in the AAAP site has historically not been great. Since the site was
declared excess to Anny needs in 1973, more interest has come from private groups or industry
hoping to develop portions of the site. The southern part of the site (Le., the fonner
nitrocellulose manufacturing area) was sold to the Kimberly Clark Corporation in the late 1970;s
and a paper products plant was constructed. In the mid-1980's, in response to interest in
purchasing the eastern part of MAP, this section was remediated by the Anny and the
contaminated soil was stockpiled in the western part of AAAP, creating the Soil Stockpile
Operable Unit.
Studies to fInd the existence and extent of contamination in the western part of MAP (i.e.,
former main industrial area) have been published in the local libraries. Almost no public
comments have been received. Following a period of minor community relations activities, a
public meeting was held in August 1991 to discuss the conclusions of the past years' studies for
the entire site. Despite notices being placed in 4 local newspapers, only 2 persons from the
news media attended the meeting.
Notice of the public comment period and meeting for the Soil Stockpile Operable Unit was
placed in 4 local newspapers on November 19, 1991 and the comment period extended from
November 21 through December 23, 1991. The public meeting was held at the Central Alabama
Community College located about 5 miles from the AAAP site. Fourteen persons from the
public and media attended the meeting. The questions asked were mainly intended to get more
detailed infonnation on the proposed remedy, also to determine the contamination hazards of the
site in general, and to a small degree to question why this action was being taken now if there
is no major concern with the stockpile and other parts of MAP may require remediation in the
future.
25
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-.
3.0 SUMMARY OF PU'BUC COMMENTS AND AGENCY RESPONSE
At the public meeting held on 5 December 1991, the public was given the opportunity to
comment and ask questions on the Proposed Plan. The following is a summary of the
questions/comments raised by the public, Army/regulators' responses given at the meeting, and
supplemental answers, where applicable:
Ql.
Could there be nitrates in the water in the Childersburg area that are contributing to the
high cancer rate in the community?
Answer at the Meeting: (ADEM) TNT and degradation products do not volatilize.
Nitrates have been found in monitoring wells at the base but there is not much
groundwater in the area. Contamination has not left the site. In 1980, the wells were
tested and there was 10,000 parts per million (ppm) of something (maybe TNT) in well
P1O. In 1982 or 1983 the wells were tested again and there was 4,000 ppm in PIO.
Buildings were tom down in 1978. The high levels in tbe monitoring wells in 1980 may
have been from the 1978 activities at the site.
Suwlemental Answer: The P10 well located on-post was sampled in 1982. The results
indicated that the groundwater was contaminated with TNT with a concentration of
15,000 ppm. No evidence of off-post contamination by chemicals produced or found Qn
AAAP has been found in the studies conducted. .
Q2.
Has testing been limited to AAAP boundaries?
Answer at the Meeting: (ADEM) Monitoring wells are scattered all the way to the
Coosa River. Work activities were conducted in Area A and stUdies were conducted in
. Area B. The site bas been tested to the Coosa River.
Suwlemental Answer: Residential drinking water wells at 6 locations around AAAP,
including those known to be closest to AAAP, have been tested and no contamination has
been found.
Q3.
Are portions of the stockPiles considered reactive contamin~ted waste?
Answer at the Meeting: (WSI) Overall, the explosives concentrations in the soil are
low. There are chunks of material that are. potentially high in explQsives concentrations.
Samples of the material show that concentrations are low in the chunks but the potential .
for high explosives concentration still exists.
Suwlemental Answer: The soil in general is not considered a reactive hazardous waste
because the explosives concentrations found were very low (less than 12 parts per
million). Soil with these concentrations would not be considered reactive by the Anny.
26
...-:-'
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'J
However, because a small number of small pieces of material that appeared to look like
explosives was found in the soils, there is the possibility that such material exists at a low
abundance throughout the stockpile. Such pieces of explosives would be considered a
reactive hazardous waste, and they cannot easily and completely be removed. Therefore,
the thermal treatment remedial action will satisfy EP A -developed operating criteria as if
the entire soil stockpile being remediated is a reactive hazardous waste.
Q4.
What will AAAP do with the chunks that are found?
Answer at the Meeting: (WSI) WSI will stage the material for disposal by AAAP.
(USATIIAMA) Small quantities of chunks ~ expected, if any. The chunks may be
open-burned on a concrete pad at the site if allowed by the regulators. The pad will be
cleaned after burning.
Q5.
What does the Anny consider a small amount?
Answer at the Meeting: (USATIIAMA) During a site visit, USATIIAMA
representatives saw 1 piece (chunk) of material, but suspect that there are more. A small
amount would be 1-10 pounds. 100 pounds would be a lot.
Q6.
Weren't private wells in the Kymulga area tested?
Answer at the Meeting: (ADEM) Yes, no residences had contamination.
Q7.
Was 1NT the contaminant found in the PIO well (10,000 ppm)?
Answer at the Meeting: (ADEM) It isn't known at this time.
Supplemental Answer: See supplemental answer for Question 1.
Q8.
What type of incinerator will be used and how about smoke? Will it have concrete vats
to catch what comes out of the incinerator?
-
Answer at the Meetine: (WSI) The rotary kiln and secondary combustion chamber are
used to volatilize and thennally destroy contaminants from the soil. The gas conditioning
system is used to cool and clean the exhaust gas. The gas that exits the stack is water
and carbon dioxide. A continuous monitoring system of the stack gas monitors the gas
to be sure it is within regulatory limits. There is an automatic waste feed shut-off if the
. stack gases are not within regulatory limits. The incinerator a not a net generator of
water. There are no chlorides in the stockpiled material. A scrubber will not be used.
The gas treatment for this system will be a baghouse.
Sup,p1emental Answer: The incinerator to be used will be a rotary kiln type. In this type,
27
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a long cylindrical heated kiln is turned slowly while in the horizontal position. Soil is
introduced at 'one end, and works its way through the rotary kiln chamber, where the
explosives are volatilized. The kiln exhaust gas subsequently passes through the
secondary combustion chamber where thernial destruction of volatilized explosives takes
place. The soil discharges the kiln, and is tested to confmn that explosives are below
hazardous levels, .and is then placed in a backfill area on the AAAP site. After the gas
is cooled by a water quench, it passes through a baghouse to remove solid particles and
then exits through a stack. Any visible smoke in the stack is steam from the water
quench. The stack gas is monitored to be sure it meets the maximum allowable levels
of paniculates, carbon dioxide and carbon monoxide, and minimum required levels of
oxygen.
Q9.
What temperature is necessary to destroy the contaminants?
Answer at the Meeting: (WSI) RCRA requires l800oP.
QlO. Will the incinerator be able to get to nothing left?
Answer at the Meeting: (WSI) The soil stream is heated up in the kiln to remove the
contaminants and transfer them into the gas stream. The soil is left with very little
contaminants and it is tested when it is discharged. The gas stream with the volatilized
contaminants is heated further in the secondary combustion chamber. The minimum gas
retention time in the secondary combustion chamber is 1 second as required by RCRA.
The gases then go ipto the spray chamber for cooling and the baghouse for paniculate
removal. The gases exiting the stack will be tested by a stack test program to be sure
that the gases meet the regulatory limits for explosives and particulate. The regulations
state that at least 99.99 % of the contaminants entering the incinerator must be removed
in the incinerator. The CEM system will continuously monitor the stack gas to be sure
the limits are maintained during operations.
Additional comment to the same question: A community member stated that if the
incinerator were to have almost nothing coming out of the stack and it still left a blanket
of powder on th~ ground, the public would be very upset.
(WSI) If a blanket of IIiaterial was building on the ground, the incinerator would have
$everal other operating parameters out of compliance and would be shut down well
before the blanket could form.
Q 11. How about water from the incinerator? Will it be contaminated?
Answer at the Meetine: (WSI) Fly ash from the incinerator comes out from several .
places. The fly ash will be collected in bins and sampled to be sure it meets the
regulatory criteria. If it does not pass the criteria for lead, it will require stabilization.
The bottom ash is collected separately. It is also sampled to be sure it meets the
28
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treatment criteria. The bottom ash is not expected to be a problem.
Supplemental Answer: The incineration system does not generate any water. The only
water collected for treatment during on-site activities are decontamination water collected
from the decontamination pad. rainwater collected from the containment structures or
concrete sumps, and aqueous laboratory wastes. The water will be treated in the aqueous
waste treatment system and tested for explosives. If the water treatment criteria have
been met, the treated water will be used to moisten the treated soil and as dust control
on the transport roadways and backfill area.
Ql2.
Does the fly ash get recycled?
Answer at the Meeting: (WSI) The fly ash bins are sampled and tested to be sure the
treatment criteria are met. The fly ash will be recycled if the explosives concentration
exceeds the treatment level. The fly ash will be stabilized if the lead concentrations
exceed the regulatory level.
Q13. Is there any other work ongoing at the site?
'./
Answer at the Meeting: (USATIIAMA) If accepted, incineration will be done on-site.
Site-wide studies are being conducted for the rest of the site.
Q14. Since everyone agrees that incineration is the way to go, how soon will it happen? '
Answer at the Meeting: (USATIIAMA) If accepted, USATIIAMA is required by law
to begin 15 months from the ROD acceptance.
Supplemental Answer: The Anny must start the incineration and related activities within
15 months of the acceptance of the Record of Decision.
Q 15. Has the ground water been tested against drinking water standards?
Answer at the Meetine: (ADEM) Some later tests were done for other contaminants
that are included in the drinking water s~dards, like chromium.
Q16. Will the results of those tests be published?
Answer at the Meetine: (ADEM) Once the state gets the results and they are approved
and finali7ed, they will be placed in the library.
29
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Q 17. Are there additional contaminants in Area B that have not been addressed?
Answer at the Meeting: (US EP A) The topic of discussion tonight is the stockpile area.
Other areas on the site are being or have been studied, such as the old manufacturing
area, ron-off areas (red water/pink water ditches), sewer lines, etc. Steps are being taken
toward total cleanup of the installation.
Q18. The costs shown on the Fact Sheet are high and there is considerable work to do. The
community thinks the stockpile area presents less harm than exposed areas leaching in
to the ground. Should the other areas be addressed rust?
Answer at the Meeting: (USATHAMA) Other areas that are being studied may be
combined with the present project.
Supplemental Answer: The other areas of the site may require from 1 to 3 years to study
and decide on a solution. If there is no exposure' to the public, and the cost to clean the
sites for unrestricted public use is high, it may be acceptable to the Army and the public
to not disturb the sites and to retain the site as the AAAP with minimal activity. The'
future of the site is still being worked out, but we know there is a problem with the
stockpile now, and the budget and contractual process is in place to clean up that site in
an year or two. The stockpile site is not very secure in the long term as shown by the
tornado event at building TC4 and the need for maintenance of the . cover over the s
-------
Supplemental AnSwer: No hazardous waste landfill is contemplated for AAAP as part of
the remediation of the stockpile. No incinerated material is expected to be classified as
hazardous waste.
Q21. The local paper stated that the cost for off-site landfilling is $68.000,000. Is this true?
Answer at the Meeting: (WSI) No, the $68 million refers to the off-site incineration and
subsequent landfilling. On-site incineration is cheaper since commercial incinerators
usually take in small quantities of materials from many customers. They are not
accustomed to accepting a large quantity of material just dropped on their doorstep. The
off-site incinerators would probably only accept small quantities at a time (truck by
truck). If the concentration of explosives goes up, the waste may not be able to go off-
site since off-site incinerators don't usually accept explosives.
Q22. What level of worker protection is expected for the project?
Answer at the Meeting: (WSI) Level C worker protection is expected for initial
activities in contaminated areas. It is expected that after appropriate sampling and
monitoring, and approval, the level of protection will be downgraded to Level D.
','
Level D protective equipment consists of typical construction site attire, including cotton
or chemical resistant coveralls. The difference between typical construction activities and
Level D activities on the site is that protective equipment does not usually leave the site,
coveralls are laundered or disposed of on-site. Level C protection includes chemical
resistant coveralls, boots, safety glasses, hard hat, and respiratory protection.
Q23. What type of asbestos is present on the site?
Answer at the Meeting: (ADEM) Not much asbestos is present; it is mostly roof
shingles and there may be some pipe insulation.
(WSI) If the material contains asbestos in concentrations exceeding I %, it is considered
asbestos-containing material. Asbestos has been found in the soil in concentrations less
than I % and chunks of highly concentrated materials are present. The majority of the
chunks of asbestos is non-friable.
Q24. If incineration is accepted, how long will it take?
Answer at the Meetin2: (WSI) Site preparation, foundations, erection, checkout will .
require at least 3 months, operation will require about 6 months, and demobilization will
require 2 months.
Q25. Does WSI own the incinerator? Is it working now?
31
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L
I
I
Answer at the Meeting: (WSI) Yes, WSI does own the incinerator. It is a new
incinerator so it is currently being manufactured. WSI owns another incinerator which
has completed projects on two sites in Illinois and is currently working on a third project.
Q26. What area of Illinois has the incinerator operated?
Answer at the Meeting: (WSI) The fIrst site was PCB-contaminated soil in Beardstown,
Illinois. The second site was lagoon sludge and soil contaminated with organic and
inorganic compounds in Chicago, Illinois.
Q27. Is there a brand name of the incinerator? Is it custom-built?
Answer at the Meeting: (WSI) The incinerator is custom-designed and built to WSI
specifications. One contractor is supplying most of the equipment up to the baghouse,
another supplier is supplying the baghouse.
. Q28. What is the hourly rate of production?
Answer at the Meeting: '(WSI) The rate of production is based on the material handling
characteristics, density, and the water content of the soil. It is expected that operation
will be conducted at 20 tons per hour. The expected range of operation is 15 to 25 tons
per hour. The expected operating efficiency is 65%. The incinerator will operate.24
hours per day, 7 days per week. .
Q29. Does WSI expect to rerun material?
Answer at the .Meeting: (WSI) No, based on past experience, very little will be
recycled. At the Chicago site, about 1-2% of the material required retreating.
The public took the opportunity to call Army representatives following December 5,1991 public
meeting. The following is a summary of the public questions and Army responses (by Joseph
Ricci and Catherine Stalcup of the U.S. Army Toxic and Hazardous Materials Agency) during
December 17-19, 1991. .
Q1.
'.
What is the cost of burning and what will .the impact be?
Answer: For stockpile there is no impact, the incineration would not be releasing
anything to the air. Joe Ricci then read the fIgures listed in the Proposed Plan of the cost
to do each alternative.
Q2.
I have a concern. with groundwater, and the effect on it.
Answer: The groundwater has been tested. There were studies conducted in April 1991 ,
. and the wells tested were clean.
32
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Q4.
Q5.
Q6.
'.'
Q7.
Q8.
Q9.
Q3.
My concern was because the terrain leads to the rivers. If no contamination can go
through then why go through the process?
Answer: You can't just leave it sit there. Its already been dug up and there were
explosives in the soil. There are two areas. Area A, which had explosives, and Area
B, which has more. The contaminants in the groundwater are not gening off post, but
it does need to be cleaned up.
Have you tested river water downstream?
Answer: Yes, studies have been done on the Coosa River for clean water.
So much money is involved, I worry about the economy and unnecessary spending.
Answer: I understand, but in some cases we do need cleanup. Its been in the soil for
a long time.
Since it has been there for a long time, with no effect on the groundwater, why clean it
up now? Does the gunpowder have a time release, after about 40 yrs? Will it release
substances that it hasn't already?
Answer:
problem.
Compounds break down in time. I don't think time release would be a
I feel like we go off the deep end sometimes.
Answer: We try very hard to have good justification for Remediation.
Do you know what will be done with Area B?
Answer: A Feasibility Study is being conducted to assess necessary remediation for Area
B.
What will the total cost of incinerati<;m cleanup be?
Answer: I don't know. For stockpile incineration on post is $10.5 million to $16.7
million. Offpost facilities for incineration would be about $70 million. Using the rotary
kiln incinerator would be $10.5 million.
QlO. I can not see after 40 years that now we have to get rid of it. If it was a health hazard
it has affected the wildlife.
Answer: We wanted to release Area A to be sold, and by law it must be cleaned up to
prevent problems in the future.
33
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Qll. If you don't mow there is a problem, why spend money? I am against Government
handouts and spending. I think: the public should speak out.
Answer: The comment period is open now to submit any comments. (Gave Joe Ricci's
address). When writing, address your comments to the Proposed Plan for Stockpile
Soils.
Ms. Stalcup asked if he would like to be placed on the mailing list for any handout
materials. He said he would, so his address was taken. He was also given our phone
number and was told he could call if he had any questions in the future.
4.0 REMAINING CONCERNS
Remaining concerns appear to be with existence of health risks off-post and the need to know
more about the operation of the thermal treatment remedial action selected. The flI'St concern
has been partially addressed. Phone calls were made to some commenters to provide additional
information about the results of the remedial investigation. The discussions of these phone calls
are presented in the preceding section. Additional information promised to the commenters will
be provided by mail. To provide more information about the thermal treatment remedial action,
copies of the remedial desi~ documents will be placed in the information repositories.
34
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ATTACHMENT 1
COMMUNITY RELATIONS ACTIVITIES
AT ALABAMA ARMY AMMUNITION PLANT
35
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1------
COl\ilMUNITY RELATIONS ACTIVITIES
AT ALABAMA ARMY AMMUNITION PLANT
To date, communication with local community regarding past and ongoing environmental studies
at AAAP has consisted of:
1.
A public meeting was held in April 1985 to announce plans to conduct a Remedial
Investigation/Feasibility Study at AAAP.
2.
A public meeting was held in September 1986 in Childersburg, Alabama, to brief
the public on a (a) the fmdings of the completed Remedial Investigation; (b) the
initiation of the Area A decontamination and/or cleanup effort; and (c) the status
of the ongoing feasibility study. '
3.. Mr. Ronnie Wynn, AAAP caretaker, spoke to the Sylacauga Rotary Club in July
1990 on the status of AAAP. Mr. Wynn has also offered site tours to interested
citizens in the AAAP community.
4.
Community interviews were conducted with community leaders and residents
adjacent to AAAP (July 23-26, 1990).
5.
A public meeting .was held at the Central Alabama Community College in August
1991 to discuss the results of the site-wide remedial investigation.
6.
A public comment period on the Proposed Plan for the Soil Stockpile Operable Unit
was held from November 21, 1991 to December 23, 1991.
7.
A public meeting was held at the Central Alabama Community. College on
December 5, 1991 to discuss the Proposed Plan for the Stockpile Soils Area
Operable Unit. .
. .
Other communication techniques the Army has used to provide the public and media with
updated infonnaDon on AAAP include, producing fact sheets, mailing out news releases and
letters of invitatiOD, providing site tours, and storing AAAP documents in repositories for public
review. . ..
36
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I ~<
ATTACHED
*
EPA letter of concurence
*
ADEll letter of concurence
*
Community Relations Items
Public Meetina Aqenda
Hand-outs, Description of Base Realiqnment and
Closure Proqram
Proposed Plan
-------
V
DEC 3 1 1991
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 3O365
4WD-RCRAFFB
OVERNIGHT MAIL
Lewis 0. Walker, Deputy Assistant Secretary
of the Army for Environment, Safety and
Occupation Health
Room 2 ESS 7
The Pentagon
Washington, D.C. 20310-0110
Re: Early Remedial Action Record of Decision for the Stockpile
Soils Area Operable Unit at the Alabama Army Ammunition NFL
Site, Alabama
Dear Mr. Walker:
The U.S. Environmental Protection Agency (EPA) Region IV has
reviewed the above referenced decision document and concurs with
the findings and the proposed early remedial actions .
It is understood that this decision is for an early remedial
action for only the stockpiled soils and that a final remedial
action decision will be submitted following the completion of the
current remedial investigation and feasibility studies associated
with Area-A and Area-B at the NFL Site.
Sincerely yours,
Patrick M. Tobin
Deputy Regional Administrator .
cc: Jim Warr, Assistant Deputy Director, ADEM
Daniel E. Cooper, Chief Special Projects, ADEM
Commander's Representative, Volunteer Army Ammunition Plant,
ATTN: Mr. James Fry, P.O. Box 22601, Chattanooga, Tennessee
37422-2607
Commander, U.S. Army Toxic & Hazardous Materials Agency,
ATTN: CETHA-BC (Mr. Joseph Ricci), Aberdeen Proving Ground,
MD 21010-5401
Printed on Recycled Paper
-------
\.~!A~-
.... ,--
-ADEM
Leigh Pegues, Director
1751 Cong.W.l.
DIck onson Drive
Montgomery, AL
36130
2051271.7700
Field OHICes'
IJ~;~ 205. !:..::~=;::; S
225 aomoor Circle
8Irm,"gl'l~m. Al
35209
205/942.6168
p a 800 953
Decatur. Al
',I
35602
205' 353.1713
2204 Penmeter Road
Mobile. Al
36615
205 i 479-2336
- IIi!II
ALABAMA-
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT-
..
.~. '''~.:~
"'~~iT ~':
--
Guy Hunt
Governor
December 30,
1991
Lewi~ D Walker, Deputy A~~~~tant
Army ~nv~ronment, Safety and
Occupational Health
Room 2!:557
The Pentagon
Wa~hington, D.C. 20310-0110
Secretary
F.e:
!:arly R~edial Action Record of Deci~ion for the Stockpile
Soils Area Operable Unit at the Alabama Ar.my Ammunition NPL
Site, Childersburg, Alabama
Dear Mr. Walker:
The Alabama Department of !:nvironmental Management has
reviewed the above document in conjunction with negotiation~
among the U.S. !:nvironmental Protection Agency, U.S. Army Toxic
and Hazardous Materials Agency and AD~, and concurs that
incineration of the Stockpile Soils appears to be an
environmentally sound alternative for remediation.
We would call to your attention that this Department's
position remains that appropriate pre-construction Permits for
the incineration facilities are required. Given that the
incinerator is a source of air emi~~ion~, an Air Permit should
be obtained before construction may begin. Should it be
determined that the facility will remediate material defined as
a hazardous "'a~te under Division 14 of the Department's
Administrative code, a Part B Permit appl~cation should also be
3ubmitted to AD!:M.
It is understood that this decision document is applicable
only to the Stockpile Soils Operable Unit and that a final
remedial action decision ."ill be submitted following the
completion of the current Remedial Investigation/Feasibility
Study for Operable Units Area-A and Area-B at the Alabama Army
~~ur.i~i=~ Plant.
Since)L ~
rector
ment of Environmental Management
,..,...
Patrick M. Tobin, Deputy Regional Administrator, USEPA
Region IV, 345 Courtland St N.E. Atlanta, GA 30365
Commander, USATHMA, ATTN:CETHA-BC (Joseph Ricci)
Aberdeen Proving Ground, Me 21010-5401
-------
AGENDA
PUBLIC MEETING
ALABAMA ARMY AMMUNITION PLANT
December 5, 1991
Welcome and Administrative Notes
(Introduction of Panel Members)
Alabama Department of Environ-
mental Management (ADEM)
u.s. Environmental Protection
Agency (EPA) Region IV
Introduction of Stockpile
Soils Area Operable Unit
Discussion of Proposed Plan for
Stockpile Soils Area Operable
Unit
QUESTION AND ANSWER PERIOD
CLOSING REHAlUtS
7 p.m.
Ms. Catherine Stalcup
Public Affairs Representative
U.S. Army Toxic and Hazardous
Materials Agency (USATHAMA)
Mr. Joseph Downey
Special Projects
Mr. James Barksdale
Remedial Project Manager
Mr. Joseph Ricci
Project Officer
U.S. Army Toxic and Hazardous
Materials Agency (USATHAMA)
Mr. Tim Forden
Vice President, Operations
Weston Services, Inc.
Hs. Catherine Stalcup
Hoderator
. .
-------
PRESENTATION FOR
PUBLIC MEETING
SOIL STOCKPILE AREA
ALABAMA ARMY AMMUNITION PLANT
GENERAL OVERVIEW OF PROCESS
SITE BACKGROUND
NATURE AND EXTEND OF CONTAMINATION
SUMMARY OF SITE RISKS
CLASSIfICATION OF SOILS
FINDINGS OF FEASIBILITY STUDY (FS)
REMEDIATION GOAL
EVALUATION OF ALTERNATIVES
IDENTIFICATION OF ALTERNATIVES
:.t
SUMMARY OF FINDINGS
DETAILED DESCRIPTION OF PREFERRED ALTERNATIVE
SUMMARY OF PROPOSED PLAN
1
I
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USATHAMA
n"rn
~
u.s. Army Toxic and Hazardous
Materials Agency
JS Army Corps
oi Engineers
Aberdeen Proving Ground, Maryland 21010-5401
I BASE REALIGNMENT
I AND CLOSURE
I PROGRAM
AL\B~'\1A AR.1\1Y A.1\1MUNITION
PIA.'i
I ,.-\lubama Arm\' .-\mmunition Plant !'-\.'~,.AP). for-
I, -
I ;;;€';ly the Alabama Ordnance Works. is located in
II ('\;lldfT~,bur!;. AI.. approximate)y 40 miles southeast of
B!;mtn(:oam. The plant was established in 1941 on
:0,:23:; acres of land located near the junction of the
T ui1aaega Creek and the Coosa River. It was govern-
:i'1E'f1t-(lwned'contractor operated I,GOCOi.
TOE: plant was operated dur:ing World War II to
prOQUcl' T11trocellulose. smokeless powder. high explo-
: -;','t-, ,:nd industria] chemicals. In August 1945. opera-
\ ',: :-:- '.\E'rr,- tE'rminated at.-\.-\AP and the plant converted
::, -~undby ~tatus,
!:;,mE'di:ltely following termination of operations.
i :~:~ :,;kratl!1!; contractor proceeded to decontaminate
i ~dcntn\'r\'. \:quipmem. buildings. and gTound areas
I t::';;;r1L: ~1 ii\'e to six month period ending January 1946.
" .\t'wr completing the decontamination and a complete
~!ly;;ical im'entory. the government released the con-
-,ructinl; and operating contractor. E.l, DuPont de
\,pmours and Co.. in a final settlement in September"
1946,
During the period from April 1955 through October
1957. Associated Contractors and the Rust Engineering
Co. under contract rehabilitated several explosives pro-
duction lines to incorporate the latest proven produc-
t:on developments and techniques. Seventy-five per-
cent of the rehabilitation had taken place before work
was stopped due to lack of funds. The plant was
maintained in various stages of standby status until the
early 1970s. . ,
In 1973. the Department of the Army declared
AAAP excess to its needs. I n the same year the
General Services Administration tGSA) d~clin~d to
accept 1.620 acres of the former manufacturing area
because the area could not be certIfied as free from
contamination.
In 1977. a 1.354-acre parcel was ~oid to Kjmber\y-
Clark Corporation. a new!';print, pulp and forest prod-
ucts company, Contained within the parcel were the
:\itrocellulose and Smokeless Powder :\Ianufacturi ng
Areas. In order to allow the go\'ernment to remove
equipment and to decontam inate these manufacturi ng
facilities. a :272-acre area was leased back to the gov.
ernment until August 1982. This area is refeTTed to as
the Leaseback Area.
In 1978. a records search concL!",d that specific
areas of.-\.-\AP were potential1y contar.ilOated b.\' exp io-
sive materials and lead compounds,' This led to a 1979-
1981 ExploratOry Survey. which indicated that. explo-
sives-related contaminants and lead were present iri
certain areas above applicable criteria. '
\C~
'\@
\ 80"'"
;'-
I """"' ;
-+-.'.,.'7 \ ;
! ; AJ.ApI:/', :
. \
~"?I
i ! ""U'''' i I
\j"0
Scaat
: 5 : : ~ . .....
1
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DECEMBER 1991
-------
AAAP ENVIR01'l'ME~TAL STt:DIES
Dunngthe exploratcry survey. twenty-one specific
study areas were sampled and analyzed for possIble
conummatlon. Survey resuJts mdlcated that expio.
slves-re!a~d contammants and lead were present In
certaIn areas aoove appl1cabie cnu:na. The maJontv of
the comamInatlon was found m tne Industrial Area.
where sods. sewers. sedIments. and a portIon of the
wau:r table aquIfer were round to be contamInated. As
a result. the Army Inltlate<1 addltlonal studIes to deter.
mIne the extent and exact lOCation of contammatlOn
1n 1982. the Leaseback .-\rea was decontamInated
and returned UJ Kimberlv Clark. Decontammatlon
consisted of asbestos removal and decomamInatlon or
bud dIngs. sumps. sewers. and contamlOated 50115
In 1982 tc 1983. a confirmatorv survev was Inltl'
ated. to venfv and quamirv the extent of contamInation
ldentlfied 10 the explOrawn survev The confirmatory
survey determined that though regIons of sod. sedl'
ment and sun"ace water were contaminated wnh
mtroaromatlc resIdues I T)'"T. D)'"T. Tetry! J and lead. no
m1gratlOn was expected Devond the boundary by sub-
surface and sun'ace water.
:;.
In Octcber 1984. AAAP was proposed for the CS
EnV1ronmental ProtectIon Agency's tEPA) ),"atlOnal
Priontles List. In 1985. CS.-\THA...\IA began additIonal
studies. culm matIng In a Remedial Investigation/Fea-
slb..;ty Study i RLFS) The Rl determines the extent
ami nature of contam1natlOn at a sIte: the FS evaluates
the mformatlon from the RI to determine the alterna-
tlYes avadable UJ clean up the sIte. The RIfFS documen-
tatIon was coordmated ...nth the state of Alabama and
EP A RegIon IV
For the RLFS. AAAP was divided into two major
reg1ons: Area A and Area B (see map). Area A consIsts
of the eastern portion of the sIte. which Includes: the
~agazIne Area. the Old Burning Ground. the Small
Arms BallistIcs Range. the Cannon Range. the OJd
Wel1. and a portIon ofthe Propellant ShiPPIng Area.
Area B consIsts of the wes~rn portion of the Sl~.
which Includes: the SanItary Landfill and Lead Facil.
ity. Manhattan Project Area. Red Water Storage Basin.
Southern T~r :\lanufactunng Area. ~orthern TIT
Manufactunng Area. Acid/Organic Manufacturing
Area. Aniline Sludge BasIn. Tetryl Manufacturing Area.
Flashing Ground. the ma)onty of the Propellant Ship.
pIng Area. BlendingTower Area. Lead Remelt Facility.
Rifle Powder Finishmg Area and the Demolition Land-
fill.
The Rl confinned that sous In Area A were con-
tammated WIth mtroaromatlc (non.reactlve' contami-
natIon. asbestos and lead. In additIon. the RI con-
firmed the followlngforms of eon tam mati on at Area E.
which eXJst In varYIng degrees In the sad. sediment.
surface water and ground water: expiosl\'e resIdue
. reactive J contamInation. mrroaromatlc ilon.reaCtl\f
contammatlon. asbestcs and lead.
The RI for Areas A and B was comPleted In 19!:36
C]ea nup of.-\rea A' s co nta mlnated so I i re:r.OVl rc::
from .-\rea A to tern porary swrage stn.: c: ure- I:" .-\ re a B
began In .-\ugust 1986 and was completee:"'1 Dece::l~f'
1987
In ,Julv 1987. .-\...\.-\1' was olaced 0;1 EP.-\" ~,"::':::-:J.
Pnonues LI st : :\"'PLJ, a l1st of CI \ 111an a nei reee r," -.:e'
ranked accordmg to the nsks they pose :0 ;-;'..::"':"..J:"
health and the envIronment.
.-\t the request ofEPA RegIon 1\'. 3(10\:'C:-.J ?~~-
work was InItiated at Area B In SeptemDer ~U_';:" :
was completed in 1990. The Suppiemenu; R.i r.:'~
for Area B. finalIzed :n Apnl 199~. :om-:r7":1e: :-.
angIna] RI l nformatlOn -. that certa \ n por::o:". s .)r' .~.'- ,;
B contained soil and groundwater contamlnauo:". ;-'"
nsk related to this contamInatIon 15 currem!\ ::;,,::-=
assessed and a draft report. the Rlsk .-\sse:, 3m P": :., .:-
submItted for regulatory reV1ew 10 Octocer i:?C;\
draft FS wll] be Issued upon finalizatIOn CT' :~t' F.:o"
Assessment.
In December 1988. A.AAP was 1dentliied ;'C' ..
sure In the Report of the Defense Secretan 5 Co rT.:7'. J-.
SlOn on Base Realignment and Closure
In December 1989. a Federal FaC1lltv .-\".crreemert
I FFAi was sIgned by EPA RegIon IV. the .-\rmv and the
Alabama Department ofEnV1ronmental \!anagerren:
,.-\1)E\1) specifying the process and schedule to com.
p!ete the remedial actions. FolloWIng a pubilc ,E'Vle""
. period. the agreement became effectIve In :.tarcn1990
In Julv 1990. onsite sampling was conauctea 0::
the under~ound sewer lines at Area B as pan of .1
separate RlIFS effort initiated by the C.S. .-\rmv Eng'..
neer DivIsIon. Huntsville. The RI and FS reports for
this study were finalized in September 1991. The RI
report fo~nd that the sewer lines contaIned expios1\e
residue and the soil surrounding the hnes was -also
contaminated with explosives. The remedIation oftne
sewer hnes and surroundingsoil will be Inciuded 1:'1 tne
Area B remediation schedule. tA, remedIation scneci.
ule Wl11 be determined at the time a Record of DecIsIon
is sIgned!.
DECEMBER 1991
-------
L-
.-\1so in 1990. the EPA indicated that additional
investigations needed to be conducted at Area A to
ensure that no residual contamination remained.
Area A \\ ~onveyed to private buyers in August of
that year. ..:ter a :\lay auction. with the provision that
additional investigations will be performed by the
:\rmy. A task to perform these investigations was
awarded in .June 1991. Although the Army believes
all contamination was removed in 1986. should an~'
residual contamination be found. it will be removed.
Onsite work commenced in July 1991 and was com-
pleted in Au~st 1991. The contaminated soil re-
moved from Area A in 1986. was stored in a stockpile
in .-\rea B until an appropriate remedial technology
could be selected, it is referred to as the Stockpi Ie .
Soils '. In 1991. the Army. EPA and ADE~I agreed to
remediate. or clean up. this soil as a separate task. or
Operable Cnit. \\;thin the overall remedial plan for
.-\. -\AP.
In October 1991. the Arm~' issued the Final Fea.
-Ioilit\" for the Stockpile Soils Area Operable Cnit.
In Xovember 1991. the Proposed Plan for the Stock.
pde Soils Area Operable Cnit was finalized. The
pubiic comment period for the Proposed Plan began in
XO\"fmoer 1991. In December 1991. 3.S part of the
Arm~"s public participation program. the Army held a
public meeting to discuss the Alternatives listed in the
Propoi'ed Plan.
Throughout the entire environmental studies pro.
('t';,,;. thi:: Army has coordinated with all appropriate
-tate and federai agencies. which indude ADE:\I and
the. EP:\.
PI RLIC [~\"()L \'F.'IF.~T
Thli' fact :'>heet is part of the Army's program to
"~ep members of the community surrounding AAAP
and federal and state officials informed of activities
involved in the investigation of the facility. Through.
out the investigation, the Army will hold public meet.' .
in~s. and publish additional fact. sheets and news
re leai'es.
To keep the public inf<>rmed and updated. the
Army has established information repositories. which
offer fact sheets. news releases. the Public Involve-
ment and Response Plan. and other pertinent docu-
ments. at four locations:
"C.S. Environmental Protection Agency
Library
345 Courtland Street. XE
Atlanta. GA 30365
(404) 347-4216
Library Service
Alabama Public Information
6030 :'.Ionticello Drive
:\lontgomery. AI. 37130
:205; 277.7330
B.B. Comer :.Iemorial Library
and Information Center
310 Xorth Broadway
S.\"lacauga. AL 35150
'205 j 249-0961
Earle A. Rainwater ~lemorial Lbrary
The .-\1abama Room
112 9th Avenue.. SW
Childersburg, AI. 35044
':205; 378-7239
The Army encourages the public to visit the infoI"
mation repositories and attend the public meetings to
become more knowledgeable about the ongoing- inves-
tigations at AA...-\P. Additional information can be
obtained by contacting the C.S. Army Toxic and
Hazardous :-'Iaterials Agency Public Affairs Office. at
1301; 671-2556: the Army Armament. ~funitions and
Chemical Command Public Affairs Office. at 1309,
782-5838: and. the Commander's Representa:ti~'e at
Volunteer Army Ammunition Plant. at 1615 I 855-
7109.
If .,"ou would like to be placed on a mailing list to
receive more information about .~~-\P. please send
your mailing address to:
C.S. Army Toxic and Hazardous :.Iaterials Agency
Bld~. E4480. ATT~: CETHA.PA
Aberdee n Provl ng Ground. ~ID 210 1 0-5401
DECEMBER 1991
-------
I
~.
If you would like to receive information about upcoming public meetings and
related material, please complete the form below and mail t,o:
l"S .-\rmy Toxic and Hazardous :-'lateria]s Agency
Bldg E-H80. ATT::\ CETH.-\-PA
.\berdeen PrO\lng Ground.:\fD :21010-o-Wl
,---------------------------------------------------------------------------------------------------------------------------
REQUEST FORM FOR ADDITIONAL INFORMATION
Nam.(.):
a(""l ::::ar:~Cl..jlar:y r"lteres!e:
ntor~atlon an ~1'1e fOllOWIng
r ~eceIY1n;
a::CIt:cnai
Addr... :
! ~
I :
! ;
I :
Clly:
Slat.:
Zip:
Tel.phon. (optional):
I .. -_........... -- --- -- ----- -- -_.. ..--- -- ----- -------
PLEASE DETACH AND lUlL -----__--_m_--____---_U------------------
DECEMBER 1991
-------
m
Proposed Plan Summary ,Fact Sheet
Alabama Army Ammunition Plant
Childersburg, Alabama .
December 1991
US Army Corps
of Engineers
AlabamaArmy Ammunition Plant Proposes Cleanup Plan
The Alabama Army AmmunitionPlant Currently, approximately 27,000 cubic yards
(AAAP) in consultation with the Alabama of soil are stockpiled. The remediation goal
Department of Environmental Management is the elimination offacility risks by treating
(ADEM) and the U.S. Environmental Protec- the contaminants of concern in accordance
tion Agency (EP A) recentl y reviewed options with federal and state requirements and regu-
to address the soil stockpile area contamina- lations. Achieving this goal will result in
tion at AAAP in Childersburg. Alabama. protection of'huma'n health and the environ-
The Army initiated the Remedial Inves- ment. -
tigationlFeasibility Srudy (RIfFS) process in Proposed Plan Alternatl ves
1985 under the DepanmentofDefense Instal- Three remedial action alternativesbave
lation Restoration Program (IRP). AnRI isa been developed for the treattnentofthe stock-
long-term study to identify the nature and piledsoilatAAAP. Abriefdescriptionofthe
extent of contamination, and the FS evaluates remedial alternatives is presented in the fol-
remedial alternatives for site conditions. lowing paragraphs.
Allernati,'e 1 -- No Action. The EPA
Superfund program requires that the "No
Action" alternative be evaluated at every site
to establish a baseline for comparison. Under
this alternative, no remedial action will be
performed. No cost is associated with this
alternative.
Alternative 2 - On-Facility Thermal
Treatment and On-Facility Disposal of
TreatedSoiVOn-orOff-Facility Disposal of
Asbestos-Containing MateriaL Soil will be
separated from the asbestos-containing mate-
rial and transponed to the on- facility thermal
For the pwposes of the RIfFS, the facility
was divided into two general areas: Area A
and Area B. The Rl was completed in 19 86 and
conc luded thatthe site is contaminated with
explosives. lead. and asbestos in the soil in
Area A. and in the soil,sediment,andground-
waterin Area B.
As a result of the findings of the RIIFS,
cleanup activities at Area A were conducted
in 1986 and 1987 which included building
decontanuna tion and demolition, and soil ex-
cavation and stockpiling. Soil excavated
from ..\rea A was stockpiled in Area B in two
covered buildings and 00. a concrete slab which
was subsequently covered with a synthetic
liner.
In February 1991, another environmental
stud y. known as the Characterization StUdy,
was conducted for the stockpiled soil in Area
. B. The Study concluded tbat explosives, lead.,
and asbestos contamination were present
above regulatory limits.
On March 29. 199 1 ,atomadodemolisbed
one of the two buildings tbat contained stock-
piled soil. Soils from the demolished building
were relocated on the concrete slab and cov-
ered with a synthetic liner.
Storage of the stockpiled soils is a tem-
porary action to contain the contamination
while a fmal remedy is identified. evaluated.,
and approved. The preferred final remedy is
described in the Proposed Plan document.
The Proposed Plan addresses the con-
taminated stockpiled soils contained in the
covered building and on the concrete slab.
AMP Facility Map
4
"f
At. 235
Not to Scale
1 .
. treatment unit for incineration. Asbestos-
containing materia I will be transponed to an
approved disposal facility. The on-facility
incinerator will be removed upon completion
of the project. Costs for Alternative 2 range
ftom S) 0 toS 16 million. depending on the rype
of incinerat or used.
Alternative 3 -- Off-Facilit}. Thermal
Treatment and Off-Facility Disposal 01
TreatedSfJilandAsbestos-ContJIin;ng Male-
riaL The contaminated soi I will be separa ted
from the asbestos-containing material and
transported to an off- facility incinerator. As-
bestos-containing material will be tr:lnSpOned
toanapproveddisposal facility. Total coSt fvr
Alternative 3 is approximately S68 million.
PreferredAlternati ve
Alternative 2 is proposed ~ the preferred
remedial action. Alternative 2 has been se-
lected based OD the following eval uation en-
teria: protection of human health and the
environment; state and federal requirements
and regulations; long-term effectiveness; reo
duction of toxicity. mobility, and volume of
contamination; shon-terme ffectiveness: ease
ofimplementation; and cost.
~ Area Sold in
t:...::::..J August 1990
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AAAP is located in northeastern
Alabama in Talledega County, 4 miles
from Childersburg and 40 miles south-
east of Birmingham. Alabama. The
facilay encompasses 2.200 acres of
land near the junctlon of Talledega
Creekand theCoosa River.
AAAP was built m 1941 andoper-
ated dunng World War II as a govern-
ment-owned!contractoroperated facil-
ity. The facility produced explosives
and cherrucals. Operations at AAAP
were terminated in August 1945. The
plant was maintained under standby
status until 1973 when the Anny
delcared tbe facility as excess prop-
erty. Since tbat time. several parcels
Site Background
of the original 13 .23 3-acre property
have been sold. In 1978, the Anny
concluded that specIfic areas of the
facility were potentlaUy contaminated
byexploslvesandleadoompounds. Fur-
ther studies confirmed contaminatlon
of the soil v.1th explosIves. asbestos.
lead. and otber orgaruc compounds.
Several Investigatlons were con-
ducted between 1981 and 1983 to fur-
ther define conUlmnatlOn. In 1984.
AAAP was proposed for inclusion on
EP A's National Priori ties List (NFL)
and was included on the Itst in 1987
The NPL is the list ofpnority (con-
taminant) releases for long-term reme-
dial evaluation and response.
. ....
j
. N.
J
x-
os . ';
AAAP Location .\lap
Opportunity for Public Involvement
address or call 1-800-826-3461 (ask for Ext. Earle A. Rainwater \1emonJI Llbnr\
3261 at EdgewoodArea) or dial (41 0) 671- The Alabama Room
32610r(410)671-3461. I I 29thAvenueSW
Documents relating to Rl/FS and Pro- Childersburg.Alabarna350+t
posed Plan activities as the AAAP site are Phone: (205) 3 78- ~239
organized and presented in the Information B.B. Comer Memorial Library
repositories. The public is invited to review and InformationC enter
copies of applicable documents at these re- 3 ION. Broadway
positories. Sylacauga,Alabama35 I 50
A report addressing public comments Phone: (205) 249-0961
will be prepared following the comment pe- I.ibrary Service
riod. The report will be submitted with the Alabama Public Informanon
selected early remedial action plan, called 6030 Monncello Drive
the RecordofDecision(ROD). Afterapproval Montgomery, Alabama 3 7130
by the Army, EPA. and ADEM. the ROD will Phone: (205)277-7330
be placed in the In formation repositories for EP A I.ibrary
A list of typical questions is mcluded at public review The AAAP infonnation re- 345Counland Street NE
the endofthis fact sheet. For more infonna- positories are located at the following four Atlanta, Georgia30365
tion contact the representatives at the above locations: Phone: (404) 347 -4216
If you would like to receive information about actlvltles at the AAAP facility, please complete this form and mall to
U.S. AnnyToxiqnd Hazardous Materials Agency
Bldg.E4480.ATrN CETHA-PA
Aberdeen Provmg Ground. MD 210 I 0- 540 I
r------------------------------------------,
I RequestFormforAdditiona/lnformation I
I Name(s): II I am particularly interested inreceivmg addlllonal 1
I ~ information on the following:
I
I Address:
I
I City:
I State:
I
I Zip:
I Telephone (optiooal):
I Please detach and mail I
~------------------------------------------~
2 .
'.<
Commellts from the public are consid-
ered by the Anny to select final remedial
actIOns for the site. Interested individuals are
encouraged to present comments on the FS
and Proposed Plan documents dunng a public
meetmg or submit their comments in writing.
The public comment period is from Novem-
ber21 to December23, 1991. Written com-
mentS and questions, postmarlced no later than
December 23, 1991, should be sentte:
Commander
U.S. Army Toxic and Hazardous
Materials Agency
Attn: CETHA-BC-B
Aberdeen Proving Grouod,MD 21 01 0-5401
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,- -
Responses to Frequently Asked Questions
1. JJr1ro prepares the proposed
plan?
The "lead agency" prepares the proposed plan
in coordination with the suppon agencies. For
Army installations such as MAP. the Anny
is the "lead agency". and the EP A and AD~M
are the support agencies.
2. W'hat require$ the Army to
prepare a proposed plan?
The National Contingency Plan, which imp le-
mentS the Comprehensive EnvironmentalRe-
sponse. Compensation. and Liability Act
(Superfund). requires the preparation ofthe
proposed plan. EPAguidancealsocontains
the requirment fortheproposed plan. as well
as recommended content and format.
3. ~Jr1rat is contained in a proposed
plan?
The propos.ed plan contains the lead agency's
proposed remedial action for a site. which it
has seleCted from among the alternatives that
are compared in the Feasibility Study (FS).
The proposed plan also contains a shon de-
scription of the site and the otheralternatives.
4. When does a proposed plan
have to be developed?
The proposed plan is developed as the FS is
being finalized.
5. JJ1,y does a proposed plan have
to be developed?
In orderto have a singe document that clearly
states the proposed remedial action at a site
so the public can undemand and comment on
it.
6. Who approves the proposed
plan? .
The EP A. the ADEM. and the Army approve
the proposed plan that is published for public
comment. Following public comment. the
selected remedial action is documented in the
Record ofDecision (ROD) which will contain
a Responsiveness Summary addressing pub-
lic COmments. The ROD and Responsiveness
Summary will be approved by the Army with
the concurrance ofEP A and ADEM.
7. How is the publicinvolved with
theproposedplan?
The proposed plan is provided to information
repositories near the site so the public can
review and comment on it for a minimum of30
days. The public is encouraged to comment on
the proposed pla.nandattend a public meeting
bya public notice published in the local news-
papers. The proposed plan is discussed at a
public meeting held near the site during the
commentperiod.
8. What kind of installations
require a proposed plan?
Installations that are listed on the National
. Priority List (NPL) require a proposed plan.
This list is commonly known as the Superfund
list. Funding for an Army site. like AAAP,
does not come from Superfund. but from the
Army itself. However. being listed on the
NPL requires that the same types of docu-
ments be prepared as for sites that are funded
by Superfund. These documents include the
FS and proposed plan. Non-NPL sites may
also have a proposed plan. though this is not
required.
9. Does the preferred alternative
listed in the proposed plan
necessarily mean that it wi/I be
the o',e chosen?
No. it means that it is the preferned alterna-
tive based on consideration of various criteria
like protecti veness of human health and the
environment. ability to satisfy Federal and
State requirements, long- and shon-term ef-
fectiveness, and cost. But. community accep-
tance is also a required factor that must be
considered in selecting the remedial action.
Any communityconcems obtained during the
comment period must be addressed in con-
junction with the otherrequired factors before
the remedial alternative is selected.
. .
10. What if the EPAIstate do not
agree with the Am,y's proposed
alternative?
Any such disagreements are worked out dur-
ing preparation and review of the FS and
proposed plan. The publishedFS and proposed
plan have been approved by the EP A. ADEM.
and the Army.
. 3 .
11. What if the publk does not
agree with the proposed plan?
Public concerns with the proposed plan can be
discussed at the public meeting. All com-
ments are addressed in writing by the Army in
a Responsiveness Summary that is reviewed
by the EP A and ADEM. and is published along
with the Record of Decision (ROD) in the
information repositories. A news release
informs the public that the ROD and Respon-
siveness Summary are available.
12. To whom do I write to have my
comments addressed?
To the address shown on the cut-out form in
this fact sheet.
13. Will there be more than on e
proposed plan developed for
MAP? . .
Yes. the proposed plan being reviewed now
covers only the soil in the stockpile. At least
one other proposed plan will be published for
the remainder of AAAP.
14. Who is conducting the work at
MAP?
The U.S. ArmyCorpsofEngineers is conduct-
ing the cleanup of the stockpile soils for
AMP.
15. U'hen would the preferred
cleanup alternative be
performed?
Itiscurrentlyexpectedthatthe cleanup could
be conducted in 1992andlor 1993.
16. Where would the cleanup work
occur? .
Under the preferred alternative. the work
would occur on AAAP. immediatel yadjacent
to the soi I stockpiles.
17. How is it proposed to cleanup
the stockpile soils?
The preferred alternati\'e is to remove and
properly dispose of asbestos-containing ma-
terial and tosetupa transponable incinerator
011 the site temporarily to bum the explosives
out of the stockpiled soils. The cleaned soil
would remain on AAM. and the incinerator
would be dismantled and removed from the
site.
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