United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-91/086
September 1991
SEPA Superfund
Record of Decision:
USA Anniston Army Depot,
AL
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60272.101
REPORT DOCUMENTA 110N 11. REPORT NO. ' I ~ 3. Reclplenta Acceulon No.
PAGE EPA/ROD/R04-91/086
4. TItle and SubIlUe 5. Report Date
SUPERFUND RECORD OF DECISION 09/26/91
USA Anniston Army Depot, AL
6.
First Remedial Action
7. Author(a) 8. Perfonnl"ll Organlz8lion RepI. No'
8. PiIrtonnl"ll Orgalnlz8lion Name and Add.... 10. ProjectlTa8k/Woril Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. ~"II Organization Name and Addreu 13. Type of Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. SuppIemenWy No..
18. Abatract (Umlt: 200 -rda)
The 15,200-acre USA Anniston Army Depot site is an active equipment rework facility
for the U.S. Army in Anniston, Calhoun County, Alabama. The site is divided into
several areas including a southeast industrial area, which is the focus of this
Record of Decision (ROD). Land use in the area is predominantly residential. An
estimated 72,000 residents in Calhoun County use Coldwater Springs, located 1.5 miles
south of the site, as their primary source of drinking water. The Army initially
used the depot to store munitions, and subsequently, to overhaul and repair combat
vehicles. Various types of liquid and solid hazardous wastes were generated,
including electroplating wastes containing metals and organic solvents from cleaning
operations. Wastes, were disposed of in various landfills, trenches, disposal pits,
and lagoons located in the southeast industrial area and throughout the site. A
number of EPA and State site investigations'have revealed contamination by VOCs,
other organic compounds, inorganics, and metals in the onsite ground water. Between
1978 and 1983, several onsite actions were taken by the Army to remove contaminated
sludge and soil. In 1990, the Army completed and began operating a ground water
pumping and treatment system. This ROD addresses an interim remedy for ground water
(See Attached Page)
17. Doa8nent AnaIy8la L Deacrlpto..
Record of Decision - USA Anniston Army Depot, AL
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (PCE, TCE), other organics (phenols), metals (chromium)
b. 1cIenlilieral00000Ended Tenne
Co COSA T1 FIekIIGrlql
18. AVIIIlabilty Statement 18. SecurIty Cia.. (Thla Report) 21. No. of Page.
None 47
20. SecurIty CI8H (This Page) 22. PrIce
None
(See AIG-Z38.18)
See /MIrUcIJ- on Reverse
(FOI1II8fIy NTls.35)
~t of Commerce
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EPA/ROD/R04-91/086
USA Anniston Army Depot, AL
First Remedial Action
Abstract (Continued)
contamination beneath the southeast industrial area as the first operable unit. Future
RODs may address further contamination in the southeast industrial portion of the site.
The primary contaminants of concern affecting the ground water are VOCs including PCE
and TCE; other organics including phenols; and metals including chromium.
The selected remedial action for this site includes continued use of the existing ground
water pumping and treatment system using air stripping to remove VOCs, followed by
charcoal filtration to remove phenols; discharging the treated ground water onsite to
surface water; and. continued operation of the dewatering and treatment system. The
estimated present worth cost for this remedial action is $945,000, which includes an
annual O&M cost of $60,000. The capital cost is estimated at $895,000.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water goals will be addressed
in the final remedial action for the site.
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tJ. S. ARMY INSTALLATION
RESTORATION PROGRAM
SUPERFUND
RECORD OP DECISION
. ANNISTON ARMY DEPOT, ALABAMA
GROUNDWATER OPERABLE UNIT
SEP 2 6 1991
SBPTEHBBR, 1991
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DECLARATION FOR THB
INTERIM ACTION RECORD
OF DECISION
SEP 2 6 1991
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DECLARATION FOR THE INTERIK ACTION
RECORD OF DECISION
SITE NAKE AND ADDRESS
Anniston Army Depot
Groundwater operable unit
SDSAN-DEL-EMD
Anniston, Calhoun County,
Alabama
36201-5080
STATEMENT OF PURPOSE
This Decision Document presents the selected interim
remedial action of the Groundwater Operable Unit of Anniston
Army Depot, developed in accordance with the Comprehensive
Environmental Response, compensation, and Liability Act
(CERCLA) as amended by the Superfund Amendments and
Reauthorization Act (SARA), and to the extent practicable,
the National Contingency Plan (NCP). This decision is based
on the Administrative Record which is on file in the
Anniston Public ,Library, the Jacksonville Public Library,
the Talladega Public Library, the Oxford Public Library and
the Public Affairs Office, Building 7, Anniston Army Depot,
Alabama, 36201.
This interim remedial action is taken to protect human
health and the environment from any threat, while final
remedial solutions are being developed.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
the Groundwater Operable Unit, if not addressed by
implementing the interim remedial action selected in this
Record of Decision (ROD), may present a current or potential
threat to public health, welfare, or, the environment.
DESCRIPTION OF THB SELECTED REMEDY
The Groundwater Operable Unit addresses groundwater under
the Southeast Industrial Area (SIA). The SIA includes the
Landfill Area, the Trench Area and the Northeast Area. The
, scope of this ROD is limited to the Groundwater Operable
Unit.
lSEP 2 6 1991
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The selected remedy for the Groundwater Operable Unit,
source control, includes the following:
- Groundwater Withdrawal
- Treatment of the Groundwater for volatile organics and
phenolics with discharge to the surface
- continued Operation of the Building 114 Dewatering and
Treatment System
STATUTORY DBTBRMINATIONS
The selected interim remedial actions are protective of
human health and the environment, comply with Federal and
State requirements that are legally applicable or relevant
and appropriate to the remedial action, and are cost-
effective. These interim remedial actions utilize permanent
solutions and alternative treatment technologies to the
maximum extent practicable for this site. The contaminated
groundwater will be withdrawn and treated. Because this
interim remedial action does not constitute the Final Remedy
for the Site, the statutory preference for remedies as a
principle element will be addressed by the Final response
action.
./
2~ ~~"'~/??7
Date
L C DENNEY
, OLONEL, OD
COMMANDER
~ ~,LJ~
LEWIS D. WALKER
DEPUTY FOR THE ENVIRONMENT, SAFETY
AND OCCUPATIONAL HEALTH
OFFICE OF THE ASSISTANT SECRETARY
OF THE ARMY
9'/2~/9/
,
Date
SEP 2 6 1991
2
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DECISION SUMMARY
SEP 2 6 1991
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1.0 SITE NAMB, LOCATION AND DESCRIPTION
Anniston Army Depot (ANAD) is an active facility occupying
approximately 15,200, acres 8 miles west of Anniston,
Alabama (Figure 1-1). Several smaller towns, such as Bynum,
Hobson City, and Coldwater surround the facility. ANAD is
bordered on the north by the Fort McClellan Army Military
Reservation.
The Groundwater Operable Unit, National Priority List (NPL)
site is located in the Southeast Industrial Area of ANAD.
ANAD is currently a major heavy equipment rework facility
for the U.S. Army.
SEP 2. 6 1991
1-1
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....
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---- .. - . - -
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2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
ANAD is currently a major heavy equipment rework facility
for the U.S. Army. ANAD's initial mission was munitions
storage which was expanded to include combat equipment
storage. It was further expanded to include the overhauling
and repair of combat vehicles.
ANAD has generated various types of liquid and solid wastes
over the years, including refuse and hazardous wastes. The
hazardous wastes include electroplating wastes containing
heavy metals, and organic solvents from cleaning operations.
Previous studies show that various areas in the Southeast
Industrial Area at ANAD contained contaminants that had
migrated to tne groundwater. During a period of 1978 to
1983 action was taken at several areas to remove
contaminated sludges and soils to reclaim the areas.
The Groundwater Operable Unit addresses the groundwater
beneath certain contaminated areas. As a result of the
contaminated groundwater, the Southeast Industrial Area was
placed on the CERCLA (Superfund) National Priorities List
(NPL) in 1989. ANAD entered into a Federal Facilities
Agreement in June of 1990 with ADEM and EPA to establish a
procedural framework and schedule for developing,
implementing and monitoring appropriate response actions at
the facility in accordance with CERCLA, the National
contingency Plan (NCP), Superfund guidance and policy,
Alabama Environmental Management Act, and EPA and ADEM
guidance anc ~olicies.
The following reports describe the results of investigations
of the Groundwater Operable Unit to date:
GEOPHYSICAL AND GEOHYDROLOGIC INVESTIGATION OF ANNISTON ARMY
DEPOT, September 1981.
CONTAMIt,ANT MIGRATION SURVEY, ANNISTON ARMY DEPOT, letter, 4
March 1981.
GROUNDWATER QUALITY ASSESSMENT PLAN SOUTHEAST AREA,
September, 1981.
, STATUS REPORT, GROUNDWATER QUALITY ASSESSMENT OF THE
SOUTHEAST AREA, ANNISTON, ARMY DEPOT, October 1982.
STATUS REPORT, GROUNDWATER QUALITY ASSESSMENT OF THE
SOUTHEAST AREA, ANNISTON, ARMY DEPOT, APPENDIX A.5, WELL
LOGS, October 1982.
SEP 2 6 1991
2-1
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STATUS REPORT, GROUNDWATER QUALITY ASSESSMENT OF THE
SOUTHEAST AREA, ANNISTON, ARMY DEPOT, APPENDIX B.5,
ANALYTICAL RESULTS, October 1982. .
REMEDIAL ACTION OF HAZARDOUS WASTE SITES, ANNISTON ARMY
DEPOT, January 1984.
SOURCE IDENTIFICATION, CONTAMINANT TRANSPORT SIMULATION, AND
REMEDIAL ACTION ANALYSIS, ANNISTON ARMY DEPOT, June 1984.
SOURCE IDENTIFICATION, CONTAMINANT TRANSPORT SIMULATION, AND
REMEDIAL ACTION ANALYSIS, ANNISTON ARMY DEPOT, APPENDIX A.
DEVELOPMENT OF FLOW AND TRANSPORT MODELS, June 1984.
SOURCE IDENTIFICATION, CONTAMINANT TRANSPORT SIMULATION, AND
REMEDIAL ACTION ANALYSIS, ANNISTON ARMY DEPOT, APPENDIX B. .
FEASIBILITY STUDY AND REMEDIAL ACTION ANALYSIS, June 1984.
SOURCE IDENTIFICATION, CONTAMINANT TRANSPORT SIMULATION, AND
REMEDIAL ACTION ANALYSIS, ANNISTON ARMY DEPOT, APPENDIX C.
HYDROGEOLOGIC FIELD INVESTIGATION, June 1984.
SOURCE IDENTIFICATION, CONTAMINANT TRANSPORT SIMULATION, AND
REMEDIAL ACTION. ANALYSIS, ANNISTON ARMY DEPOT, APPENDIX D.
SAMPLING AND ANALYSIS, June 1984.
SOURCE IDENTIFICATION, CONTAMINANT TRANSPORT SIMULATION, AND
REMEDIAL ACTION ANALYSIS, ANNISTON ARMY DEPOT, APPENDIX E.
WASTE PROCESS AND SOURCE IDENTIFICATION STUDIES, June 1984.
SOURCE IDENTIFICATION, CONTAMINANT TRANSPORT SIMULATION, AND
REMEDIAL ACTION ANALYSIS, ANNISTON ARMY DEPOT, APPENDIX F.
ENVIRONMENTAL CHEMISTRY AND FATE OF CONTAMINANT,June 1984.
SOURCE IDENTIFICATION, CONTAMINANT TRANSPORT SIMULATION, AND
REMEDIAL ACTION ANALYSIS, ANNISTON ARMY DEPOT, APPENDIX G.'
HYDROGEOLOGIC AND CHEMICAL DATA, June 1984.
INVESTIGATION OF POSSIBLE PALEOCHANNELS AT THE ANNISTON ARMY
DEPOT, December 1985.
CONCEPT DESIGN REPORT, GROUNDWATER WITHDRAWAL AND TREATMENT
SYSTEMS AT THREE CONTAMINATION SITES, 14 November 1986.
OFF POST INVESTIGATION AT ANNISTON ARMY DEPOT, SUMMARY OF
PRELIMINARY RESULTS, December 1986.
FEASIBILITY STUDY FOR ANNISTON ARMY DEPOT, DRAFT SAMPLING
DESIGN PLAN A004, May 20, 1987.
PHOTOGEOLOGIC STUDY OF POTENTIAL GROUNDWATER POLLUTION
PATHWAYS BETWEEN ANNISTON ARMY DEPOT AND COLDWATER SPRING,
ALABAMA, June 1987.
SEP 2 6 1991
2-2
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DRAFT ANNISTON ARMY DEPOT ENDANGERMENT ASSESSMENT, October
1987.
THREE SOURCES GROUNDWATER COLLECTION AND TREATMENT SYSTEM,
ANNISTON ARMY DEPOT, DESIGN ANALYSIS, PRELIM:.iARY REVIEW
(60\) .
THREE SOURCES GROUNDWATER COLLECTION AND TREATMENT SYSTEM,
ANNISTON ARMY DEPOT, DESIGN ANALYSIS, FINAL REVIEW (95\), 15
June, 1987.
THREE SOURCES GROUNDWATER COLLECTION AND TREATMENT SYSTEM,
ANNISTON ARMY DEPOT, DESIGN ANALYSIS, SPECIFICATIONS, FINAL
REVIEW (95\), 15 June, 1987.
THREE SOURCES GROUNDWATER COLLECTION AND TREATMENT SYSTEM,
ANNISTON ARMY DEPOT, DESIGN ANALYSIS, FINAL (100%), 21
October 1987.
ANNISTON ARMY DEPOT GROUNDWATER, EXTRACTION OPTIMIZATION,
TECHNICAL PLAN, DATA ITEM A005, July 1988.
ANNISTON ARMY DEPOT GROUNDWATER, EXTRACTION OPTIMIZATION,
PHASE 1 INTERIM REPORT, July 8, 1988.
REMEDIAL INVESTIGATION, ANNISTON ARMY DEPOT, VOLUME 1,
January 1989.
REMEDIAL INVESTIGATION, ANNISTON ARMY DEPOT, VOLUME 2,
January 1989.
REMEDIAL INVESTIGATION, ANNISTON ARMY DEPOT, VOLUME 3,
January 1989.
REMEDIAL INVESTIGATION, ANNISTON ARMY DEPOT, VOLUME 4,
January 1989.
ASSESSMENT OF APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS ARARS) FOR ANNISTON ARMY DEPOT, ALABAMA,
January 30, 1989.
GROUNDWATER EXTRACTION OPTIMIZATION, ANNISTON ARMY DEPOT,
FINAL REPORT, DATA ITEM A011, April, 1989.
ANNISTON ARMY DEPOT, GROUNDWATER EXTRACTION OPTIMIZATION,
MONITORING PLAN, October _390.
SEP 2 6 1991
2-)
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3.0
HIGHLIGHTS OF COMMUNITY 'PARTICIPATION
The Feasibility study, Groundwater Operable unit and the
Proposed Plan, Groundwater operable Unit were released to
the public'in August 1991. Public comment period for the
Proposed Plan was August 23 - September 24, 1991. These
documents were made available to the public in the
Administrative Record located at the Anniston Public
Library, the Jacksonville Public Library, the Talladega
Public Library, the Oxford Public Library and the Public
Affairs Office, Building 7, Anniston Army Depot, Alabama,
36201. The notice of availability of the Proposed Plan was
published in the Talladeqa-Sylacauqa-Pell Citv Dailv Home on
August 23, 1991, and in the Anniston Star, the Jacksonville
~, and the Oxford Sun on August 21, 1991. A public
meeting was held on September 10, 1991. At this meeting,
representatives from ANAD, EPA, ADEM and USATHAMA 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 part of the Record of Decision.
The proposed plan identified the preferred remedy for the
Groundwater Operable Unit as Alternative 1. Alternative 1
is described in the Feasibility study (FS), Groundwater
Operable Unit as follows: groundwater withdrawal, treatment
with surface discharge, and continued operation of the
Building 114 Dewatering and Treatment System. ANAD, U.S.
EPA and ADEM reviewed all written and verbal comments
submitted during the pUblic comment period. Upon review of
these comments, it was determined that no significant
changes to the Proposed Plan preferred remedy were
necessary.
SEP 2 6 1991
)-1
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4.0
SCOPE AND ROLE OF THE GROUNDWATER OPERABLE UNIT
The overall strategy for remediation of the Southeast
Industrial Area NPL site is currently divided into the
Groundwater Operable Unit, for source control and the
remainder of the Southeast Industrial Area, which may result
in additional operable units. The interim remedial actions
selected in this ROD are applicable to the Groundwater
Operable Unit.
The Groundwater Operable Unit is a control action and is
achieved by the reduction in contaminant concentration and
reduction in contaminant mObility directly under the Trench
Area, the Landfill Area and the Northeast Area, by
groundwater extraction wells and treatment of the
contaminated groundwater. The purpose of the ongoing
Remedial Investigation/Feasibility Study (RI/FS) is to
collect necessary environmental data and information that
does not currently exist to reach a final remedial decision
on the Southeast Industrial Area NPL Site.
The overall strategies of the Groundwater Operable Unit are:
initiation of interim remedial action measures
designed to prevent further migration of contaminants
during the remedial investigation and until sufficient
information about the aquifer systems' response has
been obtained to allow final remedial decision.
The overall strategies of the ongoing RI/FS are:
establish the extent of contamination associated with
other units within the Southeast Industrial Area and
collection of additional or supplemental information
with which to better assess contaminant mobility and
system effectiveness, such as data related to vertical
changes in hydraulic conductivity, contaminant
partitioning between soil and groundwater, and the
presence of non-aqueous phase liquid.
This interim remedial action will be reevaluated at the
conclusion of the current remedial investigation and
feasibility study. The data concerning the aquifer's
response to the extraction system will be evaluated at
time. Final groundwater remedial goals and timeframes
be established at that time.
that
may
This interim remedial action will be consistent with any
planned future actions, to the extent possible.
SEP 2 6 1991
4-1
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5.0
SUMMARY or SITE CHARACTERISTICS
5.1
GEOLOGY
The geologic characteristics of the ANAD area are extremely
complex. The site lies predominantly in the Coosa Valley which
is bounded on the southeast by the Weisner Ridges, a series of
maturely dissected monoclinal mountains of strong relief
developed upon the resistant weisner Quartzite. Sharply folded
consolidated strata from northeastward trending synclines and
anticlines. Thrust faults, which generally strike northeastward
and dip southeastward, are the predominating structural features
of the area (Warman and Causey, 1962). Secondary stresses
resulting from the primary folding and thrust faulting have
caused numerous high-angle faults.
5.2
HYDROGEOLOGY
Due to the nature of the geology in the area, determining the
offpost movement of groundwater contamination from ANAD is
extremely difficult. There are a variety of different flow
conditions which could control the movement of contaminants. The
"normal" flow conditions in this area are severely affected and
altered by localized preferential conditions. The "normal" flow
condition generally consists of a gravity induced flow which is
governed by the topographic surface.
Coldwater Springs is located approximately 1.5 miles south of the
ANAD site boundary. The spring is the primary source of drinking
water for approximately 72,000 people in Calhoun County. The
average discharge is 31.2 million gallons per day which flows
from a deep seated or distant source in the thrust fault zone
(Warman and Causey, 1962). The recharge area for Coldwater
Spring, determined from potentiometric data (Scott, 1987), is
estimated to be approximately 23 square miles extending to the
northeast of the spring. The groundwater flow in this area;
however, is difficult to accurately predict and is severely
impacted by the geologic discontinuities in the area;
particularly the Jacksonville Fault. In addition, based on
recharge requirements it appears that the area is a shallow
system that supplies only part of the total spring flow and
the faulting in the area probably connects Coldwater Spring
deeper flow system that cannot be defined by the available
information.
flow
that
to a
5.3
GEOTECHNICAL CHARACTERISTICS
. In the ANAD area the groundwater flow is a1so influenced by
permeability variations caused by near surface sand and gravel
stringers, fractures, and joints in the weathered bedrock, fault
planes and associated brecciated materials, and sinkholes and
other dissolution channels. These different conditions are not
mutually exclusive and thus groundwater transport at ANAD is
likely governed by more than one type of flow.
SEP 2 6 1991
5-1
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5.4
NATURE AND EXTENT OF CONTAMINANTS
A number of sites within ANAD have been used for disposal of
various chemical wastes generated through ANAD's industrial
operations.
5.4.1 CONTAMINANT SOURCES
The principle areas of contamination in the vicinity of the SIA
include the following Solid Waste Management Units (SWMU):
a.
Z-l Disposal Area, SWMU '1,
b.
Facility 414 Lagoons, SWMU '12,
c.
A-Block Lagoon, SWMU '22,
d.
Northeast Lagoon Area, SWMU '30,
e.
Chemical Disposal Pits, SWMU '7,
f.
Building 130 Sump, SWMU '25, and
Building 114, SWMU '31.
g.
These sites are located in and around the industrial area. The
contamination sources have been removed in SWMU's '1, '12, 122,
and '25. A map of the Depot and a map showing the locations of
these sites, along with other SWMU's are presented in Figures 5-1
and 5-2.
This ROD will address source areas of defined groundwater
contamination at ANAD. The Trench Area includes SWMU '1; the
Northeast Area includes SWMU #7, 25, 30 and 31; and the landfill
area includes SWMU , 12 and 22. These areas are shown in Figure
5-3.
SEP 2. 6 1991
5-2
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FIGURE 5-1
SEP 2 6 1991
POOR QUALITY;
ORIGINAL
ANNISTON ARMY DEPOT
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WITHIN THI S SOLID WASTE
.-a lA, AHHISTON A~~~N~~:OMTENT UNITS
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ANNIS TON AA
MY DEPOT
SEP 2 6 1991
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ANNISTON
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or
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ANNISTON ARMY DEPOT
Figure :;-3
LOCA TION OF C EOPHVSICAL SURVEY LINES
AND OFFPOST MONITOR WELLS
IOV8(L ilL "u. SEP 2 6 1991
. . ..... . .
-..- -.---.--..
.-- ..--
5-5
Ann/stan, AI:Jbam.
ORIGINA~
-------
SWMU .1
The Z-l Disposal Area was one of the primary chemical disposal
areas at ANAD and was heavily used from 1971 to 1981. The
facility consisted of a series of seven trenches, covering
approximately 2 acres, located immediately north of the tank test
track. The trenches were used for the disposal of a variety of
chemical wastes, including wastewater treatment sludges, plating
and quenching bath sludges, spent cyanide solutions, paint
residues, spent halogenated and nonhalogenated solvents,
corrosive wastes, and reactive wastes. During 1982 and 1983 the
area was reclaimed and contaminated materials were excavated and
transported to an off-post site disposal facility.
SWMU '12
The lagoons associated with Facility 414.were located immediately
northwest of the Sewage Treatment Plant (STP). The disposal area
was used from 1960 to 1978 and consisted of a series of three
lagoons, each approximately 140 ft. by 220 ft. Abrasive dust
wastes containing cadmium and possibly lead, metal plating and
cleaning solutions, fuels, oils, various solvents, and residues
from the IWTP were disposed in the lagoons. The liquid from the
lagoons was removed in 1978, and pumped to the A-block lagoon.
The sludges from the liquid lagoons and contaminated soils were
excavated and disposed of off-post in conjunction with the
reclamation operations performed for the Z-1 Disposal Area.
SWMU '22
The A-Block Lagoon was a lined surface impoundment located to the
west of the STP. The liner consisted of 20-mil polyolefin
material. The lagoon was used for the temporary storage of
liquid wastes removed from the Facility 414 Lagoons and various
other liquid chemical wastes generated by metal cleaning, plating
and painting operations. The facility was in use from 1978 until
1981, when the lagoon was emptied, the liner and the sludge
removed, and the area backfilled, regraded and grassed.
SWMU '30
The Northeast Lagoon Area was located in the northeastern portion
of the SIA adjacent to Building 513. It contained a series of
lagoons which were operated during the 1950's to early 1960's.
No visible evidence of the lagoons currently remains, and no
listing of specific wastes disposed of within the facility is
.avai1able.
SEP 2. G ,ggt
5-6
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SWMU '7
A series of Chemical Disposal pits have been used. One area is
located in the north end of the SIA and was used during 1960 for
the disposal of chemicals including paint stripper: alkaline
corrosion removers: lead, zinc, and cadmium-containing compounds:
phosphoric acid and a variety of chemically treated materials.
The exact location of this unit is unknown, and no surficial
evidence of the unit currently exists.
SWMU '25
An 8,000 gallon sump located outside the southwest corner of
Building 130 was used in the past to drain vats of paint stripper
containing methylene chloride and phenol. This sump and adjacent
contaminated soil were .excavated in conjunction with the work.
performed on the Z-1 landfill and the lagoons.
SWMU '31
Building 114, the metal plating and finishing shop, contains the
principle metal treating operations in the shop area. A
dewatering system was installed underneath the basement when this
building was expanded in.1982. The groundwater is currently.
pumped to a treatment .system and treated for volatiles organic
compounds (volatiles). The volatiles in the groundwater are
believed to originate from areas located hydraulically upgradient
from Building 114 within the SIA.
5.4.2
CONTAMINANTS or CONCERN
Hazardous substances detected in the groundwater samples for the
site are listed in Table 5-1. Due to the number of contaminants
detected at ANAD, it was necessary to select a limited number of
chemicals that pose the greatest potential health and
environmental risK at the site. To provide a focus for remedial
action goals, contaminants of concern were identified in the
Baseline RisK Assessment of the RI report. The following factors
were considered in the selection of the contaminants of concern:
Concentration, frequency of occurrence and persistence
Distribution in the groundwater
Regulatory criteria and toxicity
SEP 2 6 t99t
tj-7
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Table 5-1
HAZARDOUS SUBSTANCES DETECTED IN
GROUNDWATER AT ANNISTON ARMY DEPOT
ARSENIC
CADMIUM
CHROMIUM, TOTAL
CHROMIUM, HEXAVALENT
MOLYBDENUM
NICKEL
ZINC
ANTIMONY
SELENIUM
THALLIUM
TRICHLOROFLUOROMETHANE
CARBON TETRACHLORIDE
CHLOROFORM
METHYLENE CHLORIDE
TETRACHLOROETHYLENE
TRICHLOROETHYLENE
C/T-l,2-DICHLOROETHYLENE
l,l-DICHLOROETHYLENE
l,l-DICHLORETHANE
l,l,l-TRICHLOROETHANE
1,l,2-TRICHLOROETHANE
BENZENE
ETHYLBENZENE
TOLUENE
PHENOL
PENTACHLOROPHENOL
2-METHYLPHENOL
)- AND 4-METHYLPHENOL
Using these factors, the contaminants of concern identified for
the Groundwater Operable Unit are:
CHROMIUM, TOTAL
CHROMIUM, HEXAVALENT
CARBON TETRACHLORIDE
CHLOROFORM
METHYLENE CHLORIDE
TETRACHLOROETHYLENE
TRICHLOROETHYLENE
C/T-l,2-DICHLOROETHYLENE
l,l-DICHLOROETHYLENE
l,l,l-TRICHLOROETHANE
PHENOL
SEP 2. 6 199\
5-8
-------
A summary of the number of samples with detections and the
concentrations found for wells in the Trench, Landfill, and
Northeast Areas, as well as offpost wells are presented in Tables
5-2, 5-3, 5-4, and 5-5. The compounds most widely distributed in
the groundwater included VOC's, metals and phenols. Of the
contaminants of concern identified in the RI, trichloroethylene
(TCE), 1,2-dichloroethyene (T12DCE), hexavalent chrome and phenol
were the most widely distributed and typically at higher
concentrations than other constituents. They are considered to
be representative of the distribution of constituents at the
site.
Table 5-2
The CONTAMINANTS OF CONCERN
Number
2t
SamDles
Number
2t
~
Maximum
Concen
ug/l
Minimum
Cone en
ug/l
Off Installation
contamination
CHROMIUM, TOTAL 26 2 13 7
CHROMIUM, HEXAVALENT 24 4 9 J
CARBON TETRACHLORIDE 26 0
CHLOROFORM 26 0
METHYLENE CHLORIDE 26 0
TETRACHLOROETHYLENE 26 0
TRICHLOROETHYLENE 26 6 9 2
C/T-l,2-DICHLOROETHYLENE 0 0
l,l-DICHLOROETHYLENE 26 0
l,l,l-TRICHLOROETHANE 26 0
PHENOL 6 2 151 76
SEP 2 6 '99\
5-9
-------
Table 5-3
The CONTAMINANTS OF CONCERN
Number
Q!
SamDles
Number
Q.!
lJiil
Maximum
Concen
ug/l
Minimum
Concen
ug/l
Trench Area
CHROMIUM, TOTAL
CHROMIUM, HEXAVALENT
CARBON TETRACHLORIDE
CHLOROFORM
METHYLENE CHLORIDE
TETRACHLOROETHYLENE
TRICHLOROETHYLENE
C/T-l,2-0ICHLOROETHYLENE
l,l-OICHLOROETHYLENE
l,l-OICHLOROETHANE
l,l,l-TRICHLOROETHANE
PHENOL
37
4
39
39
42
39
40
36
39
39
41
39
* Prior to source removal actions
SEP 2. 6 199\
5-10
15
1
2
2
17
9
37
30
14
12
18
14
36*
8
4*
23466*
6,631,300*
342,847*
344,827*
10,684*
27,397*
2141*
225,733*
786*
7
2
235
5
1
5
2
2
2
3
4
-------
Table 5-4
CONTAMINANTS OF CONCERN
Number
2!
SamDles
Number
Qt
Hit..i
Maximum
Concen
ug/l
Minimum
Concen
ug/l
Northeast Area - Buildina 130
CHROMIUM, . TOTAL 10 0
CHROMIUM, HEXAVALENT 5 1 5
CARBON TETRACHLORIDE 9 0
CHLOROFORM . 9 4 1882* 2
METHYLENE CHLORIDE 9 4 24.00960* 27
TETRACHLOROETHYLENE 9 6 103* 1
TRICHLOROETHYLENE 9 9 32291* 15
C/C/T-l,2-DICHLOROETHYLENE 6 5 9966* 56
l,l-DICHLOROETHYLENE 9 3 7* 1
1,1-DICHLOROETHANE 9 3 2255* 1071
1,1,1-TRICHLOROETHANE 10 7 9051* 4
PHENOL 10 4 117878* 15123
Northeast Area - Building 114
CHROMIUM, TOTAL 43 25 540 9
CHROMIUM, HEXAVALENT 12 10 583 104
CARBON TETRACHLORIDE 45 11 3 1
CHLOROFORM 45 22 7 1
METHYLENE CHLORIDE 45 24 48 4
TETRACHLOROETHYLENE. 45 17 5 1
TRICHLOROETHYLENE 45 34 2422 2
C/T-l,2-DICHLOROETHYLENE 45 19 134 1
l,l-DICHLOROETHYLENE 45 1 8
l,l-DICHLOROETHANE 43 2 5 5
l,l,l-TRICHLOROETHANE 45 5 199 2
PHENOL 33 10 98 4
* Prior to source removal actions
SEP 2 6 1991
5-11
-------
Table 5-5
CONTAMINANTS OF CONCERN
Number
Q!
Samples
Number
Q!
Hili
Maximum
Concen
ug/l
Minimum
Concen
ug/l
Landfill Area
CHROMIUM, TOTAL 20
CHROMIUM, HEXAVALENT 5
CARBON TETRACHLORIDE 16
CHLOROFORM 16
METHYLENE CHLORIDE 19
TETRACHLOROETHYLENE 13
TRICHLOROETHYLENE 20
C/T-l,2-DICHLOROETHYLENE 12
l,l-DICHLOROETHYLENE 16
1,1-DICHLOROETHANE 16
1, 1, I-TRICHLOROETHANE 20
PHENOL 17
* Prior to source removal actions
5.4.3
GROUNDWATER CONTAMINATION
7
2
2
5
1
2
15
12
1
9
4
1
80*
151*
7*
6*
6*
1*
222*
2137*
1
78*
13*
14*
9
11
2
1
1
2
J
"
1
4
Figure 5-3 shows the Landfill, Trench and Northeast Areas of the
Southeast Industrial Area of ANAD. The distribution of the
contaminants of concern showing the plume are shown in Figure
5-4, for Total Phenols, Figure 5-5 for the Hexavalent Chromium
and Figure 5-6 for the TCE, and Figure 5-7 for T12DCE.
In 1985 a groundwater study was conducted. It was recommended
from this study that a pump and treat system be installed in the
Groundwater Operable Unit areas. This system was completed and
began operation in September 1990. This system involves the
withdrawa~ of groundwater from the Groundwater Operab2 '.. Unit
areas. Treatment is provided to the contaminated gro~ iwater by
the removal of the volatile organics through air strippers and
the removal of phenolic compounds through charcoal filtration.
The treated groundwater is then discharged to the surface, which
flows to Dry Creek in compliance with ADEM NPDES Discharge Limits
under Permit AL0002658.
In addition to this system, the Building 114 dewatering and
treatment system has been in operation since 1985. A dewatering
sump was originally installed underneath the basement of Building
114 to remove excess groundwater for structural reasons. The
SEP 2 6 1991
5-12
-------
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ANNISiCN ARM'!' OE?OT
ANNISTCN. "\US,,,MA
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SEP 2 6 1991
5-13
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SEP 2 5 1991
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I CCNS1TT\JENT CONTOUR 'lAAP - TCE -
I
. ~ CI: .,..
AHNISTON ARMY OE?OT
.AJNE 1988
AHNISiON. ALA8,AMA
- -'
r.,1 , .'~. I !'7\.l
....... ." . .. - ~
SEP 2. 6 1991
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SEP 2 6 1991
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ANNI~N ARMY OE?'Ji
),AIJ' - t-1.2 OCt - JUNE 198e
:1
ANNISiON. ,,\US,l.M,I.
S-16
P~-.~ ,-.., 'A IITY
'-.'\..":\ '-{L'h- .
ORiGINAL
-------
groundwater is currently pumped to a treatment system where the
volatile organics are removed by air strippers. The volatile
organics in the groundwater are believed to originate from areas
located hydraulically upgradient from Building 114. Additional
treatment will be added for Chromium.
SEP 2 6 1991
5-17
-------
6.0
SUKKARY OF SITE RISKS
The actual or threatened release of hazardous substances, if
not addressed by implementing the action selected in this
ROD, may present a current or potential threat to public
health, welfare, or the environment.
6.1 EXPOSURE ASSESSMENT
The most significant risk of exposure to off-post
populations is potential groundwater transport of
contaminants to drinking water supplies. The use of
contaminated groundwater for domestic and agricultural
purposes in unknown. The possibility of contaminated ground
water migrating off-post or of future development of
contaminated groundwater supplies is unknown. The catfish
farm ponds are a commercial (agricultural) operation and,
therefore, are a high exposure pathway, although the
exposure point concentrations are reasonably small. These
compounds do discharge into Dry Creek, which is an important
route of exposure for environmental populations. Other off-
post potential exposure pathways such as dermal contact with
contaminated surface water, ground water or soil; inhalation
of volatiles and ingestion of contaminated crops or
livestock are likely to be small.
A preliminary classification of the groundwater in the
vi -~nity of Anniston Army Depot, utilizing Guidelines for
Ground-Water Classification under the EPA Ground-Water
Protection strategy, December 1986, indicates that, at a
minimum, the groundwater should be considered a Class IIB
aquifer. There is also some indication that a more
stringent classification of Class I may be warranted.
Remediation goals for Class I and II groundwater should be
set at maximum contaminant levels CMCLs), non-zero maximum
contaminant level goals (MCLGs) or other health protective
levels, as directed by the National Contingency Plan. A
comparison of groundwater data at Anniston Army Depot with
the health protective groundwater criteria indicates that
the groundwater contamination levels exceed the criteria
levels. The health protective groundwater criteria for
hazardous substances detected at Anniston Army Depot are
listed in Table 6-1.
Class I aquifers are defined as irreplaceable groundwater
that is currently used by a substantial population or that
supports an ecologically vital habitat.
Class IIB aquifers are defined as groundwater that is a
potential source of drinking water which is capable of
yielding a quantity at 150 gallons/day and a quality of
water with a total-dissolved-solids (TDS) concentration of
less than 10,000 mg/l, which can be used without treatment,
SEP 2 6 1991
6-1
-------
Table 6-1
. HEALTH PROTECTIVE CRITERIA FOR
HAZARDOUS SUBSTANCES DETECTED IN THE GROUNDWATER
INORGANIC CONSTITUENTS
ARSENIC
ANTIMONY
CADMIUM
CHROMIUM, TOTAL
MOLYBDENUM
NICKEL
SELENIUM
THALLIUM
ZINC
VOLATILE ORGANIC COMPOUNDS
BENZENE
CARBON TETRACHLORIDE
CHLOROFORM
1,1-DICHLOROETHANE
1,1-DICHLOROETHYLENE
C!s-1,2-DICHLOROETHYLENE
Trans-l,2-DICHLOROETHYLENE
ETHYLBENZENE
METHYLENE CHLORIDE
TETRACHLOROETHYLENE
TOLUENE
TRICHLOROETHYLENE
1, 1, l-TRICHLOROETHANE
1,1,2-TRICHLOROETHANE
. TRICHLOROFLUOROMETHANE
(mq/l )
0.05 MCLp
0.01/0.005 MCLp
0.005 MCL
0.1 MCL
0.003 RfD
0.1 MCLp
0.05 MCL
0.002/0.001 MCLp
5 SMCL
(mq/L)
0.005
0.005
6.0
0.07
0.007
0.07
0.1
0.7
0.005
0.005
1.0
0.005
0.2
0.005
2.0
MCL
MCL
CSF
RfD
MCL
MCL
MCL
MCL
MCLp
MCL
MCL
MCL
MCL
MCLp
RfD
SEMIVOLATILES ORGANIC COMPOUNDS
PHENOL
PENTACHLOROPHENOL
SEP 2 6 1991
(mq/ 1 )
4.0
0.001
RfD
MCLp
6-2
-------
Abreviations from Table 6-1
MCL Maximum Contaminant Level. Maximum permissible level
of a contaminant in water which is delivered to any user
of a public system.
MCLp Maximum contaminant Level, proposed.
CSF Carcinogenic Slope Factor. The concentration
represents a 10E-6 risk level and a 2 liter daily
consumption rate by a 70 kg individual. The CSF for
Chloroform is 6.1E-3 mg/kg-day.
RfD Reference Dose. The concentration represent a 2 liter
daily consumption rate by a 70 kg individual. The
concentration also reflects a 20\ relative source
contribution from exposure to site groundwater. An
additional safety factor of 10 is incorporated into the
concentration for 1,1-DICHLOROETHANE to reflect its
classification as a Class C carcinogen. The following
RfDs were used to determine the acceptable groundwater
concentration: MOLYBDENUM ~ 4E-3 mg/kg-day
1,1-DICHLOROETHANE 2 1E-1 mg/kg-day
TRICHLOROFLUOROMENTHANE ~ 3E-1 mg/kg-day
PHENOL - 6E-1 mg/kg-day
SMCL Secondary Maximum contaminant Levels.
SEP 2 6 1991
6-)
-------
or which can be treated using methods reasonably employed in
a public water-supply system.
6.2 ECOLOGXpAL EVALUATION
The number of livestock potentially endangered by drinking
contaminated groundwater and surface water is unknown, but
consists primarily of poultry, dairy cattle, beef cattle and
hogs. Springs and shallow wells in the general area are
used for domestic and small farm needs, but the extent and
potential for groundwater contamination is not fully
defined. Dry Creek has been classified as a Fish and.
Wildlife Stream by the State of Alabama, but the potentially
endangered environmental population has not be identified.
Aquatic life observed in Coldwater Spring include the pygmy
sculpin, water snake, crayfish and various aquatic insects.
The pygmy sculpin is only found in the habitat of the Spring
and is listed as a Threatened species by the U.S. Fish and
Wildlife Service.
It is beyond the scope of this interim action to establish
final cleanup goals at this time.
This interim remedial action is taken to prevent further
plume migration from identified source areas and initiate
cleanup while the remedial investigation and feasibility
study are being completed. Also, this interim remedial
action is being taken to obtain information concerning the
response of the aquifer to remediation measures to define
the final cleanup goals that are practicable for Anniston
Army Depot.
SEP 2 6 1991
6-4
-------
7.0 DESCRIPTION 0' ALTERNATIVES'
The following is a description of the alternatives evaluated
in the FS for Groundwater Operable Unit.
7.1 Alternative 1 - Groundwater withdrawal, Treatment, with
Surface Water Discharge, and continued operation cf the
Building 11~ Dewatering and Treatment System.
This Alternative involves the withdrawal of groundwater from
the Groundwater Opera~le Unit areas. Treatment is provided
to the contaminated groundwater by the removal of the
volatile organics through air strippers and the removal of
phenolic compounds through charcoal filtration. The treated
groundwater is then discharged to the surface, which flows
to Dry Creek in compliance with ADEM NPDES Discharge Limits
under Permit AL0002658.
In addition to the removal and treatment of groundwater this
alternative also calls for the continued operations of the
Building 114 dewatering and treatment system. A dewatering
sump was originally installed underneath the basement of
Building 114 to remove excess groundwater for structural
reasons. The groundwater is currently p~~ped to a treatment
system where the volatile organics are removed by air
strippers. The volatile organics in the groundwater are
believea to originate from areas located hydraulically
upgradient from Building 114.
Estimated
Estimated
Estimated
Estimated
capital Costs: $895,000
Annual Operation and Maintenance
Present Worth: $945,000
Months to Fully Implement: 0
Costs: $60,000
7.2 Alternative 2 - Groundwater withdrawal, Treatment, with
Reinjection, and continued Operation of the Building 11~
Dewatering and Treatment System.
This alternative involves the groundwater removal by
extraction wells and treatment of groundwater from the
Groundwater Operable Unit areas. Treatment is provided to
the contaminated groundwater by the removal of the volatile
organics through air strippers and the removal of phenolic
compounds through charcoal filtration. The treated
groundwater is then reinjected in a combination of either or
both upgrad ~nt and downgradient from the extraction wells
back into the ground.
In addition to the removal and treatment of groundwater this
alternative also calls for the continued operations of the
Building 114 dewatering and treatment system. A dewatering
SEP 2 6 199\
7-1
-------
sump was installed underneath'the basement of Building ~14
to remove excess groundwater for structural rea'sons. The
groundwater is currently pumped to a treatment system where
the volatile organics are removed by air strippers. The
volatile otganics in the groundwater are believe to
originate from areas located hydraulically upgradientfrom
Building 114 in the northeast section of the SIA.
Estimated
Estimated
Estimated
Estimated
capital Costs: $2,502,800
Annual Operation and Maintenance
Present Worth: $2,664,800
Months to Fully Implement: 30
Costs: $172,000
7.3 Alternative 3 - Groundwater Withdrawal, Treatment and '
strategioally Plaoed Grout curtains, and continued Operation
ot the Building 114 Dewatering and Treatment System.
This alternative involves the removal of the groundwater by
extraction wells. Treatment is provided to the contaminated
, groundwater by the removal of the volatile organics through
air strippers and the removal of phenolic compounds through
charcoal filtration. In addition, a grout curtain is'placed
to keep highly contaminated pockets of groundwater from
migrating beyond the Groundwater Operable Unit areas and to
reduce the amount of groundwater running into the
Groundwater Operable Unit areas.
In addition to the removal and treatment of groundwater this
alternative also calls for the continued operations of the
Building 114 dewatering and treatment system. A dewatering
sump was installed underneath the basement of Building 114
to remove excess groundwater for structural reasons. The
groundwater is currently pumped to a treatment system where
, the volatile organics are removed by air strippers. The
volatile organics in the groundwater are believe to
originate from areas located hydraulically upgradient from
Building 114 in the northeast section of the SIA.
Estimated
Estimated
Estimated
Estimated
Capital Costs: $29,628,200
Annual Operation and Maintenance
Present Worth: $29,924,300
Months to Fully Implement: 48
Costs: $306,100
7.4 Alternative 4 - Limited Aotion Alternative, with continued'
operation ot the Building 114 Dewatering and Treatment
syste..
This' alternative calls for only the continued operations of
the Building 114 dewatering and treatment system. A
dewatering sump was installed underneath the basement of
Building 114 to remove excess groundwater for structural
SEP 2 6 1991
7-2
-------
reasons. The groundwater is currently pumped to a treatment
system where the volatile organics are removed by air .
strippers. The volatile organics in the groundwater are
believe to originate from areas located hydraulically
upgradient from Building 114 in the northeast section of the
SIA.
Estimated
Estimated
Estimated
Estimated
Capital Costs: $0
Annual Operation and Maintenance
Present Worth: $162,150
Months to Fully Implement: N/A
Costs: $10,000
No other interim remedial action is taken under Alternative
4. All remedial action is deferred until the current RI/FS
is completed.
7.5
Alternative 5 - No Action Alternative.
This alternative calls for no action at the Groundwater
Operable unit.
Estimated
Estimated
Estimated
Estimated
Capital Costs: $0
Annual Operation and Maintenance Costs: $0
Present Worth: $0
Months to Fully Implement: N/A
SEP 2 6 1991
7-3
-------
8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
8.1
overall Protection of Human Health and the Environment
Based on the Risk Assessment, it is known that the
groundwater is contaminated in the Groundwater Operable unit
areas of concern in excess of the Maximum Concentration
Limits (MCLs). Alternatives 4 and 5 offer no protection for
human health or the environment. Long term protection is
provided with Alternatives 1, 2, and 3. However, long term
monitoring would be required to assure permanence of the
remedial action.
8.2 compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Alternative 1 is an interim remedial action and may not
fully comply with all ARARs applicable to Anniston Army
Depot. However, Alternative 1 will comply with Action
Specific and Location Specific ARARs. Chemical Specific
ARARs will not be determined until completion of the RI/FS.
MCLs/MCLGs or ADEM cleanup standards will not be ARARs for
these actions because they are beyond the scope of the
interim remedial. action. Alternative 2 would require
additional Action Specific ARARs because of the additional
standards of treatment for reinjection into the ground. The
Alternative 3 may require additional ARARs for the
installation of the grout curtains. The Limited Action and
the No Action Alternative, Alternatives 4 and 5, meet no
ARARs. The final remedial action will comply with all
ARARs.
8.3
Long-term Bffectiveness and Permanence
Long-term Effectiveness of any of the presented alternatives
is currently unknown. However, the prevention of further'
plume migration has been started. Alternatives 4 and 5 .
offer no effectiveness, while the placement of a grout
curtain, as in Alternative 3 or reinjection may complicate
the understanding of the groundwater. Alternatives 1, 2 and
3 will require long-term monitoring following construction.
Alternative 1 offers the best option to start controlling
the contaminated groundwater.
8.4 Reduction of Toxicity, Mobility or Volume Through
I Treatment
Alternatives 4 and 5 offer no reduction of toxicity,
mobility o~ volume. Alternatives 1, 2 and 3 will provide an
unknown reduction of contaminants. However, Alternatives 2
and 3 provide no addition reduction of toxicity, mobility or
volume for their additional expense to implement. The
interim remedial action chosen will be used to restrict the
SEP 2 6 1991
8-1
-------
plume migration until a final action is determined under the
RI/FS process.
8.5
Short Term Effectiveness
Alternatives 2 and 3 will create some additional risk to
workers, associated with the additional construction of
injections wells or grout curtains. Alternative 1 may not
achieve final cleanup levels for the ground water, although
it is effective in the short term in preventing further
degradation and initiating reduction in toxicity, mobility
or volume, consistent with the scope and purpose of the
interim remedial action.
8.6
Implementability
Alternatives 4 and 5 are not administratively implementable,
because Anniston is not currently seeking an ARAR waiver.
Technically, Alternatives 1, 2 and J may be designed and
implemented. However Alternatives 2 and 3 may require
additional administrative steps due to the additional
construction of injection well or grout curtains.
8.7
Cost
The cost to implement an interim remedial action is
significantly less for Alternative 1 than the other
alternatives in which action is required.
8.8 ADEM/EPA Acceptance
EPA and ADEM have concurred with the choice of
Al ternative 1.
8.9
community Acceptance
Few comments on the selected remedy were received. It is
believed that the community is supportive of the selected
interim remedial action.
SEP 2 6 1991
8-2
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9.0
SELECTED REMEDY
This alternative calls for implementation of an interim
action to protect human health and the environment. The
goals ot this interim remedial action are to halt the spread
of a contaminant plume, remove contaminant mass and to
collect data on aquifer and contaminant response to
remediation measures. The ultimate goal of remediation will
be determined in the final remedial action for this site.
This interim remedial action will be monitored carefully to
determine the feasibility of aChieving this goal with this
method and to ensure that hydraulic control of the
contaminated plume is maintained. At the conclusion if the
current remedial investigation and feasibility study, ANAD
in consultation with the U.S. EPA and ADEM, may arrive at a
final decision for the site. A final ROD for ground water,
which specifies the ultimate goal, remedy and anticipated
remediation timeframe, will be prepared at that time. Upon
completion of the RIfFS, this interim system may be
incorporated into the design of the site remedy specified in
the final action ROD. .
Based upon considerations of the requirements of CERCLA, the
detailed analysis of the alternatives, and public comments,
ANAD in conSultation with U.S. EPA and ADEM have determined
that the most appropriate remedy for the Groundwater
Operable Unit is Alternative 1.
The complete remedy for the Groundwater Operable Unit, for
source control includes:
- Groundwater Withdrawal
- Treatment of the Groundwater for volatile organics and
phenolics with discharge to the surface
- continued Operation of the Building 114 Dewatering and
improvements to the Treatment System
In 1985 a groundwater study was conducted that recommended
a pump and treat system be installed in the Groundwater
Operable Unit areas. This system was completed and began
operation in September 1990. This system involves the
withdrawal of groundwater from the Groundwater Operable Unit
areas. Treatment is provided to the contaminated
groundwater by the removal of the volatile organics through
air strippers and the removal of phenolic compounds through
charcoal filtration. The treated groundwater is then
discharged to the surface, which flows to Dry Creek in
compliance with ADEM NPDES Discharge Limits under Permit
AL0002658.
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The estimated cost of the selected remedy is as follows:
Estimated
Estimated
Estimated
Estimated
Capital Costs: $895,000
Annual Operation and Maintenance
Present Worth: $945,000
Konths to Fully Implement: 0
Costs: $60,000
9.1
REMEDIATION GOALS
This selected interim action does not specify final cleanup
levels because such goals are beyond the scope of the
action. These remediation goals will be addressed in the
final remedial action record of decision.
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10.0 STATUTORY DETERMINATIONS'
Under its legal authorities, the EPA's prim~ry
responsibility at Superfund sites is to undertake remedial
actions "that achieve adequate protection of human health and
the environment. In addition, section 121 of CERCLA
establishes several other statutory requirements and
preferences. These specify that when complete, the selected
remedial action for this site must comply with applicable or
relevant and appropriate environmental standards established
under Federal and State environmental laws unless a
statutory waiver is justified. The selected remedy also
must be cost-effective and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally,
the statute includes a preference for remedies that employ
treatments that permanently and significantly reduce the
volume, toxicity, or mobility of hazardous waste as their
principal element. The following sections discuss how the
selected remedy meets these statutory requirements.
10.1 PROTECTION OF HUMAN HEALTH AND THE
ENVIRONHENT
The selected remedy protects human health and the
environment through collection and treatment of groundwater
in the Groundwater Operable Unit Area.
10.2 COMPLIANCB WITH APPLICABLE OR RELEVANT AND
APPROPRIATB REQUIREMENTS.
The chosen alternative is an interim remedial action and may
not fully comply with all ARARs applicable to Anniston Army
Depot. However, this alternative will comply with Action
Specific and Location Specific ARARs. Chemical Specific
ARARs will not be determined until completion of the RI/FS.
The final remedial action will comply with all ARARs.
10.3
COST-EFFECTIVENESS
The selected remedy for the Groundwater Operable Unit has
been determined to provide overall effectiveness
proportional to its costs. The selected remedy is
protective of public health and the environment and is
substantially less expensive than the same action with
reinjection, and substantially less expensive that the
addition of strategically placed grout curtains.
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10.4 UTILIZATION OF PERMANENT SOLUTIONS AND
ALTERNATIVE TREATMENT TECHNOLOGIES (OR RESOURCE
RECOVERY TECHNOLOGIES) TO THE MAXIMUM EXTENT
PRACTICABLE
The treatment applied to the extracted groundwater is
permanent and meets the current requirements for the
National Pollutant Discharge Elimination System Permit.
Alternative treatment technologies were evaluated but were
not found to be cost effective.
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL
ELEKEN'r
This interim remedial action does not address all potential
threats posed by the site. One known threat is migration of
the groundwater contamination plume. This interim remedial
action will initiate control of the source of the
groundwater contamination plume. While a final action level
is not established for the groundwater during this interim
remedial action, the extracted groundwater treatment meets
the NPDES permit requirements.
10.6
DOCUMENTATION OP SIGNIPICANT CHANGES
No significant changes from the proposed plan were made.
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COMMUNITY RELATIONS
RESPONSIVENESS SUMMARY
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COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
1.0
OVERVIEW
ANAD, along with u.s. EPA and ADEM held a public meeting on
September 10, 1991, at the Headquarters Building Auditorium
at Anniston Army Depot to discuss the results of the RI/FS,
present the proposed plan and solicit comments and questions
from the public. The majority of questions and comments
received during the public comment period were received
during the public meeting.
2.0
BACKGROUND ON COMMUNITY INVOLVEMENT
An active community relations program providing information
and soliciting input has been conducted by ANAD for the
Groundwater Operable Unit. The public has been informed
since the early 1980's of the actions being taken at ANAD.
Interviews of citizens in the Anniston Area were conducted
in early 1991 to identify community concerns. No
significant concerns that required focused response were
identified. Most comments received were concerning the
Chemical Demilitarization Program, which is an incinerator
that will be built to destroy Chemical Munitions. The local
media has been informed throughout the 1980's concerning
remedial actions and our placement on the NPL. In addition
all documents concerning the Groundwater Operable Unit can
be found in the Anniston PUblic Library, the Jacksonville
Public Library, the Talladega Public Library, the Oxford
Public Library, and the Anniston Army Depot, Public Affairs
Office.
3.0
SUMMARY OF PUBLIC COMMENT AND AGENCY RESPONSE
3.1
Publio Meeting
Comments and questions raised during the Public Meeting held
on September 10, 1991 are summarized below.
3.1.1
Technical Comments and Questions
1. Questions from a member 0: the press dealt mainly with
the Remedial Investigation/Feasibility Study Workplans and
the work that will lead to the Final ROD. There was one
question concerning the proposed plan. It dealt with the
contaminant levels presented in the sliaes during the public
meeting. He questioned whether the average contaminant was
an average from the whole spectrum of testing from the time
the wells were installed until the present.
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ANAD Response: The average was from the whole spectrum of
testing. There are some wells that are monitored quarterly
and that some wells were just sampled in the 1982-1985
timeframes. A document has been compiled that lists all
results. frqm all testing done in the areas of concern.
3.1.2
other Comments and Questions
Comments and questions raised during the public meeting that
were not technical ,in nature are summarized below.
1. A county commissioner from Calhoun Calhoun asked EPA and
ADEM if ANAD was on target with the cleanup efforts that
were presented at the meeting.
ADEM's Response:
Yes.
2. The county commissioner commented that he felt that the
low turnout for the meeting was an indication that the
residence of Calhoun county had confidence in ANAD.
He said that the pollution was the result of hazardous waste
disposal methods that were acceptable for many years, and
that ANAD made positive steps to cleanup the pollution
before they were placed on the National Priorities List.
He commend ANAD for the cleanup efforts. He said that ANAD
was a "good corporate neighbor" and that he supported our
efforts. He stated that things should be done like they are
supposed to be and that he had a lot of confidence that ANAD
would do what is right.
ANAD's Response:
No response was necessary.
3.2
Public Comment Period
Comments and questions received during the public comment
period that ran from 23 August to 24 september are
summarized below.
3.2.1
Technical Comments and Questions
No technical comments and questions were received during the
public comment period.
3.2.2
other Comments and Questions
No other comments and questions were received during the
public comment period.
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