PB95-964035
EPA/ROD/R04-95/251
March 1996
EPA Superfund
Record of Decision:
Alabama Army Ammunition Plant,
Area B Soils Operable Unit, AL
11/14/1994
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U. S. ARMY INSTALLATION
RESTORATION PROGRAM
INTERIM RECORD OF DECISION
ALABAMA ARMY AMMUNITION PLANT
CHELDERSBURG, ALABAMA
AREA B SOILS OPERABLE UNIT
(STUDY AREAS 6, 7, 10, AND 21)
NOVEMBER 1994
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.
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TABLE OF CONTENTS
DECLARATION OF THE INTERIM RECORD OF DECISION 1
DECISION SUMMARY 7
1.0 SITE NAME, LOCATION, AND DESCRIPTION 7
1.1 Physiography 7
1.2 Climate 7
1.3 Surface Hydrology 7
1.4 Geologic Setting 11
1.5 Land Use 11
1.6 Soils 11
1.7 Groundwater 12
1.8 Ecological System 12
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 13
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 15
4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY 15
5.0 NATURE AND EXTENT OF CONTAMINATION 16
5.1 Soils and Sediments 16
5.1.1 Combined TNT Manufacturing Area (Study Area 6- Southern
TNT Manufacturing Area and Study Area 7 - Northern TNT
Manufacturing Area) 16
5.1.2 Study Area 21 - Red Water Ditch 19
52 Industrial Sewer System 20
52.1 Study Area 6 - Southern TNT Manufacturing Area 20
522 Study Area 7 - Northern TNT Manufacturing Area 24
523 Study Area 10 - Tetryl Manufacturing Area 25
6.0 SUMMARY OF SITE RISKS 25
6.1 Exposure Assessment 25
62 Intermediate Cleanup Levels 26
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TABLE OF CONTENTS
(Continued)
7.0 DESCRIPTION OF ALTERNATIVES 26
7.1 Soils and Sediment Alternatives 26
7.1.1 Alternative 1A: Stabilization of Metals- and PAH-
Contaminated Soils and Sediments 29
7.12 Alternative 1C: Off-Site Disposal of Metals- and PAH-
Contaminated Soils and Sediments 29
7.13 Alternative ID: Incineration of Explosives-Contaminated
Soils and Sediments 29
7.1.4 Alternative 1G: Incineration/Stabilization of Metals-
and Explosives-Contaminated Soils and Sediments 30
7.1.5 Alternative II: No Action 30
12 Industrial Sewer System Alternatives 30
7.2.1 Alternative ISS1: Excavation, On-Site Flashing
and Off-Site T ^nHfilling 31
722 Alternative ISS2: Excavation, On-Site Mobile Rotary Kiln
Incineration, and Off-Site Landfilling 32
7.23 Alternative ISS3: Deactivation and Grouting of Concrete-
Encased VCP; Excavation, Decontamination or On-Site
Incineration, and On-Site Disposal of VCP 32
7.2.4 Alternative ISS7: No Action 32
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 32
8.1 Threshold Criteria 32
S2 Primary Balancing Criteria 35
83 Modifying Criteria .. 37
9.0 SELECTED REMEDY AND REMEDIATION GOALS 38
9.1 Basis for Selection 40
92 Remediation Goals 41
10.0 STATUTORY DETERMINATIONS 46
10.1 Protection of Human Health and the Environment 46
10.2 Compliance with Applicable or Relevant and Appropriate
Requirements 47
103 Cost-Effectiveness 48
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TABLE OF CONTENTS
(Continued)
10.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable 48
10.5 Preference for Treatment as a Principal Element 49
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LIST OF TABLES
Exposure Concentrations of Contaminants of Potential Concern
(COPCs) in Shallow Soil and Sediment at
Study Areas 6, 7, 10, and 21 at ALAAP Area B 17
Contaminants in Soils and Sediments that Require Remedial
Alternative Screening Based on the Ecological Risk Assessment 27
Intermediate Cleanup Levels for Soils and Sediments
Considering Multiple Exposures 28
Contaminated Soil and Sediment Volumes for Alternative 1G 42
IV
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LIST OF FIGURES
1 Location Map of ALAAP 8
2 Study Areas at ALAAP 9
3 Area B Soils Operable Unit Study Areas 10
4 Layout of Industrial Sewer System in Study Area 6 21
5 Layout of Industrial Sewer System in Study Area 7 22
6 Layout of Industrial Sewer System in Study Area 10 23
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LIST OF ACRONYMS AND ABBREVIATIONS
ALAAP Alabama Army Ammunition Plant
AAC Alabama Administrative Code
ADEM Alabama Department of Environmental Management
ARAR applicable or relevant and appropriate requirement
CAA Clean Air Act
CERCLA Comprehensive Environmental Response, Compensation,
and Liability Act
CFR Code of Federal Regulations
COC Contaminant of concern
COPC Contaminant of potential concern
1,3-DNB 1,3-dinitrobenzene
DNT dinitrotoluene
DOD Department of Defense
DOT Department of Transportation
EPA U.S. Environmental Protection Agency
EQ ecotoxicity quotient
ESA Endangered Species Act
ESE Environmental Science & Engineering, Inc.
°F degrees Fahrenheit
FS Feasibility study
gal gallon
GOCO govemment-owned/contractor-operated
HI hazard index
ICL Intermediate Cleanup Level
IRP Installation Restoration Program
m meter
mg/L milligrams per liter
nig/kg milligrams per kilogram
NC nitrocellulose
NCP . National Oil and Hazardous Substances Pollution Contingency Plan
NEPA National Environmental Policy Act
NPL National Priorities List
O&M operation and maintenance
OU Operable Unit
OSHA Occupational Safety and Health Act
ppm parts per million
RA risk assessment
RCRA Resource Conservation and Recovery Act
RfD reference close
RI remedial investigation
RI/FS remedial investigation/feasibility study
ROD Record of Decision
VI
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LIST OF ACRONYMS AND ABBREVIATIONS
(continued)
SARA Superfund Amendments and Reauthorization Act of 1986
TCLP toxicity characteristic leaching procedures
tetryl 2,4,6-trinitrophenylmethyhiitramine
TMV toxicity, mobility or volume
2,4,6-TNT 2,4,6-trinitrotoluene
TNT trinitrotoluene
TSCA Toxic Substance Control Act
USAGE U.S. Army Corps of Engineers
USAEC U.S. Army Environmental Center (formerly USATHAMA)
USATHAMA U.S. Army Toxic and Hazardous Materials Agency
USC United States Code
UCL95% 95 percent upper confidence level
Mg/g micrograms per gram
VCP Vitrified Clay Pipe
WESTON Roy F. Weston, Inc.
WWH World War H
yd3 cubic yard
vu
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DECLARATION OF THE FINAL INTERIM RECORD OF DECISION
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DECLARATION OF THE FINAL INTERIM RECORD OF DECISION
SITE NAME AND LOCATION
Alabama Army Ammunition Plant
Area B Soils Operable Unit - (Study Areas 6, 7, 10 and 21)
P. O. Box 368
Childersburg, AL 35044-0368
STATEMENT OF PURPOSE
This decision document presents the selected remedial action for the contaminated soils and
sediments in Study Areas 6, 7, and 21, and the Industrial Sewer System (ISS) in Study Areas
6, 7, and 10 within Area B at the Alabama Army Ammunition Plant (ALAAP), Childersburg,
Alabama. This selected remedial action 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 interim remedial action is taken to protect human health and the environment from
unacceptable risks. This interim remedial action is limited to soils and sediments in Study Areas
6, 7, and 21, and the Industrial Sewer System (ISS) in Study Areas 6, 7, and 10 located within
Area B, herein referred to as the Area B Soils Operable Unit. With the exception of soils in the
vicinity of the ISS, contaminated soils and sediments in Study Area 10 will be addressed as a
separate operable unit following completion of a sampling program to accurately delineate the
extent of contamination.
The U.S. Environmental Protection Agency and the State of Alabama concur with the selected
remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Final Interim Record of Decision (ROD), may
present an imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The Area B Soils Operable Unit addresses the principal threats from soils and sediments in Study
Areas 6, 7, and 21, and underground industrial sewer lines in Study Areas 6, 7, and 10. The
soils and sediments and the industrial sewer lines are contaminated with explosives and lead.
Each of the study areas is identified as follows:
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• Study Area 6: Southern TNT Manufacturing Area
• Study Area 7: Northern TNT Manufacturing Area
• Study Area 10: Tetryl Manufacturing Area
• Study Area 21: Red Water Ditch
The scope of this ROD is limited to these study areas. Based on the current property use
surrounding Area B (hunting, logging and industrial activities) and future potential land use for
Area B, the U.S. Army has selected an Industrial Scenario for remediation of Area B. All
remedial investigations and remedial action efforts, property transfers, sales or leases will be
restricted to this Industrial Scenario.
The selected remedy for the Area B Soils Operable Unit consists of the following:
(A) Soils and Sediments (Study Areas 6. 7. and
• Clear, survey, and grid areas; perform soil and sediment sampling and analysis
to delineate contamination by explosives (TNT, 1,3-dinitrobenzene, and tetryl)
and lead.
• For contaminated areas: excavate soils and sediments until excavation criteria are
satisfied; screen materials; transport materials to the transportable incineration
system (TIS-20) site in Area B; treat materials by incineration and/or stabilization
until treatment and disposal criteria are satisfied.
• Decontaminate oversize materials by crushing or shredding and treatment in the
TIS-20, or by high-pressure water washing and disposal in the backfill area.
• Expand the existing on-site disposal area for final placement of treated materials.
• Backfill excavated areas in Study Areas 6 and 7 and rough grade to pre-excavated
contours; backfill Study Area 21 to the elevation of surrounding banks of the Red
Water Ditch.
• Close the disposal area in accordance with the existing approved permit
application for treated soils ("Treated Soils - Backfill Area Permit Application for
the Alabama Army Ammunition Plant Stockpile Soils Area Operable Unit",
March 1993).
• Treat contaminated process, sampling, and decontamination wastewaters in the
TIS-20 aqueous waste treatment system; reuse water for site dust, control and
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process makeup.
• Conduct confirmatory soil and sediment sampling and analysis to ensure that
excavation criteria have been satisfied.
• Excavated materials that contain asbestos (tiles, fragments, etc.) will be separated
during feed preparation activities at the HS-20 site. Details of the materials
handling procedures may be found in the Work Plan.
(B) Industrial Sewer System (Study Areas 6. 7. and 10)
• Locate and survey the existing vitreous clay pipe (VCP) sewer lines and
manholes.
• Sample overlying soils to determine compliance with excavation criteria; excavate
to depth of sewer; visually inspect interior and exterior of sewer; remove gross
contamination; treat materials in TIS-20 or other approved methods and
procedures.
• Remove nonencased sewer lines and manholes; transport materials to HS-20 site
for decontamination by high-pressure water washing or other approved methods;
dispose decontaminated materials in the backfill area.
• Sample and analyze soils around sewer lines and manholes for contamination;
excavate as necessary to achieve excavation criteria.
• Screen and transport contaminated soils and sediments to the TIS-20 site for
treatment by incineration and/or stabilization.
• Where sewer lines are encased in concrete: visually inspect interior; remove gross
contamination; treat materials in TIS-20 or by other approved methods and
procedures; water wash; grout/cement in place after decontamination.
• Where lines are crushed or broken: visually inspect and remove gross
contamination; excavate oversize (>2 inches) materials; transport oversize
materials to TIS-20 and decontaminate for disposal in on-site backfill; blend
undersize materials with surrounding soils using approved methods; transport
materials to the TIS-20 for treatment by incineration and/or stabilization.
• Portions (10 percent) of decontaminated VCP will be tested to ensure adequate
decontamination. Although not expected, if adequate decontamination cannot be
demonstrated using Webster's Reagent (due to porosity of pipe), a portion of the
decontaminated pipe will be crushed and analyzed for parameters outlined in the
excavation criteria. If Webster's Reagent is used, there is no numerical
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quantifiable decontamination criterion. A change of color will indicate that TNT
is present at concentrations above 15 /ig/cm2.
• If decontamination cri. -ria are exceeded, the piping will be decontaminated again,
tested, and disposed in the backfill area if criteria are satisfied. Decontaminated
piping that fails to meet the decontamination criteria after two water-washings will
be crushed, blended with contaminated soils, treated in the TIS-20 and disposed
in the on-site backfill area.
• Conduct confirmatory soil sampling around and below removed pipe to ensure
that excavation criteria are satisfied.
Excavation criteria for contaminated soils and sediments are: >647 ppm TNT, >5,000 ppm
tetryl, > 1 ppm 1,3-DNB and >500 ppm total lead. Excavation will proceed until excavation
criteria are achieved or one of the following is encountered: groundwater, bedrock, or
foundations or other major subsurface obstructions. For soils treated in the TIS-20 and
stabilized, disposal criteria are: < 1 ppm TNT and below the toxicity characteristic leaching
procedure (TCLP) criteria for RCRA metals. For soils not treated in the TIS but stabilized,
disposal criteria are: less than explosives excavation criteria and less than TCLP criteria for
metals.
Due to the nature of contamination of soils, sediments and the industrial sewer system by
explosive compounds, sampling, excavation, and handling procedures in the field will be dictated
by safety considerations as determined by the U.S. Army or its designated explosives expert(s).
As such, the general remedial actions will be performed in accordance with the plans developed
by the explosives experts.
STATUTORY DETERMINATIONS
This interim action is protective of human health and the environment, complies with Federal
and State requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This interim action is intended to fully address the statutory
mandate for permanence and treatment to the maximum extent practicable. This action
constitutes the final remedy for contaminated soils and sediments in Study Areas 6, 7 and 21,
and the industrial sewer system in Study Areas 6, 7 and 10 within Area B, and addresses the
statutory preference for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element. Subsequent actions are planned to fully address the threats posed
by the conditions at other areas within this operable unit.
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X37S8
P.I
P. 2
FINAL INTERIM RECORD OF DECISION
ALABAMA ARMY AMMUNITION PLANT
CHILDERSBURG, ALABAMA
AREA B SOILS OPERABLE UNIT
(STUDY AREAS 6, 7,10, AND 21)
OCTOBER 1994
Lieutenant Colonel B. L. Martin
Commander, Holston Army Ammunition Plant
Amy Amonnntion Plant
mr
//at/
Date
FAX TBANSMITTAL
101
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DECISION SUMMARY
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DECISION SUMMARY
1.0 SITE NAME. LOCATION. AND DESCRIPTION
Alabama Army Ammunition Plant (ALAAP) is located in Talladega County in east-central
Alabama, 40 miles southeast of Birmingham and 70 miles north of Montgomery (Figure 1). The
nearest town is Childersburg, which is 4 miles south of ALAAP. This interim remedial action
is limited to soils and sediments in Study Areas 6, 7, and 21, and the industrial sewer system
(ISS) in Study Areas 6, 7, and 10 located within Area B, herein referred to as the Area B Soils
Operable Unit. The boundary of Area B is shown in Figure 2. An enlarged portion of Area
B showing Study Areas 6, 7, 10, and 21 is presented in Figure 3.
1.1 Physiography
ALAAP is located in the Coosa Valley district of the Valley and Ridge physiographic province.
The border between the Valley and Ridge province and the Piedmont province is south of
ALAAP between Talladega and Tallaseehatchee Creeks.
1.2
Talladega County's climate is temperate. The weather during fall, winter, and spring is
controlled by frontal systems and contrasting air masses. Summer weather, which lasts from
May or June until September or October, is almost subtropical because maritime tropical air
prevails along the Bermuda high-pressure system.
Average daily temperatures in Talladega County are 75 degrees Fahrenheit (°F) for the high and
50°F for the low. Summer high temperatures are commonly 90°F or above; occasionally,
maximum temperatures exceed 100°F. Temperatures below 32 F occur approximately 60 days
per year, primarily in December and January.
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. Talladega
County has two rainy seasons per year. The whiter rainy season is December to April, with the
majority of the rain associated with the passage of frontal systems. The .summer rainy season
is May through September, with the highest rainfall occurring in June and July. Summer rains
are normally convective thunderstorms.
13 Surface Hydrology
The majority of the surface runoff from ALAAP drains either west or southwest into the Coosa
River. A small portion of the southern and eastern side of ALAAP drains toward Talladega
Creek, a tributary of the Coosa River. Prior to the construction of ALAAP, the area consisted
of farms, woodlands, and wetlands. Much of the eastern hah0 of ALAAP was poorly drained.
Small natural drainways were enlarged and rerouted to provide drainage from the various
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lOngina^oundary
Coosa River
Talladega Creek
Alabama Army
Ammunition Plant
(Present Boundary)
1986 Boundary
County
Birmitaham.TV
Tallaseehatchee Creek
Childersburg
Montgomery
Alabama
94P-3385
ALAAPFS
FIGURE 1
LOCATION MAP OF ALAAP
U.S. ARMY CORPS OF ENGINEERS
HUNTSVILLE DIVISION
ALABAMA ARMY AMMUNITION PLANT
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KEV
AAAP BOUNDARY
SIUOV AREA BOUNDARIES
- — DRAINAGES
INSTALLATION DIVISIONS
— -— AREA A AND B BOUNDARIES
01 StUOVAREA
3
FIGURE 2
STUDY AREAS AT ALAAP
SOURCES: U9ATHAMA, IMS; E8E.
U.S. ARMY CORPS OF ENGINEERS
HUNTSVILLE DIVISION
ALABAMA ARMY AMMUNITION PLANT
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FLASHING
GROUND AREA
KEY
AAAPBoundaiy
........ Study Area Boundaries
^M«*^_ Drainages
• »••• Installation Divisions
•••^ Area A and B Boundaries
; | Study Areas
-M-
AreaBSote
Operable Unit
Study Areas
1500
1500
1500
1500
Scale In Feet
FIGURE 3
AREA B SOILS OPERABLE UNIT
STUDY AREAS 6,7,10, AND 21
U.S. ARMY CORPS OF ENGINEERS
HUNTSVILLE DIVISION
ALABAMA ARMY AMMUNITION PLANT
94P-3403 6/3O/94
10
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manufacturing operations.
As shown in Figure 2, two natural drainage systems conveyed surface runoff from ALAAP, west
to the Coosa River. Liquid industrial wastes from the explosives manufacturing operations were
conveyed west to the Coosa River by a man-made channel (Red Water Ditch). No natural ponds
existed on ALAAP during its operation; however, two large storage lagoons were constructed
to retain industrial wastes. Extensive wooded swamp and pond areas have developed in the
drainage systems at ALAAP since the beginning of demolition activities in 1973, primarily as
a result of damming of drainways by beavers.
The U.S Army Corps of Engineers has completed a wetlands delineation study at ALAAP.
Based on their inspection of 12 July 1994, they concluded that a Department of the Army permit
pursuant to Section 404 of the Clean Water Act will not be required to remove contamination
from the man-made ditches excavated from uplands. The property is a nonwetland upland area
based upon the 1987 Wetlands Delineation Manual.
1.4 Geologic Setting
The bedrock underlying ALAAP 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 ALAAP is thick- to medium-bedded; cherty; and penetrated by numerous
cavities, joints, and fractures. The dolomite is overlain by residual soil derived from the
weathering process. This soil matrix consists primarily of clay, with some silt, sand, and
occasional chert boulders, and varies in thickness from less than 3 feet to more than 80 feet,
1.5 Land Use
ALAAP is currently hi an inactive caretaker status with controlled access. The only activity
occurring on ALAAP is occasional Army-supervised logging. The land surrounding ALAAP
is a mixture of recreational and industrial. ALAAP 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. The current and future land use of the ALAAP
property in Area A is expected to consist of hunting grounds and occasional logging of wooded
areas. Area A was auctioned and conveyed to private buyers in 1990 and is currently used for
hunting grounds and occasional logging.
Based on the current property use surrounding Area B (hunting, logging and industrial activities)
and future potential land use for Area B, the U.S. Army has selected an Industrial Scenario for
remediation of Area B. All remedial investigations and remedial action efforts, property
transfers, sales or leases will be restricted to this Industrial Scenario.
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1.6 Soils
The soils at ALAAP (Areas A and B) are generally divided into three associations. Soils of the
Bodine-Minvale Association are found on the high ground of the eastern portion of ALAAP.
This association is composed of deep, well-drained, steep, cherty, medium-textured soils derived
from limestone and dolomite. Most of ALAAP 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 that 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 at ALAAP may include three associations ranging from soils
consisting primarily of sand and silt (with little clay) to soils comprised almost entirely of clay.
1.7 Groundwater
Potable groundwater from the dolomite aquifer of the Coosa Valley supplies the needs of the
communities, homes, farms, and industries around ALAAP. The majority of the successful
wells draw water from the solution cracks and cavities in the dolomite. A few wells are
completed in the residual soil; however, these wells are less productive than those drilled into
the dolomite.
1.8 Ecological System
The environment at ALAAP has been disturbed three times in the past 40 years. Prior to the
construction of the facility, the area consisted primarily of cropland and woodland. The first
major change occurred during the operational years, when much of ALAAP consisted of
maintained industrial areas. In the second major change, the Army instituted a woodland
management plan, following closure of manufacturing operations, that extensively modified
ALAAP by allowing 3,411 acres of controlled pine forest to be planted. More recently, the
third major change occurred as a result of selected remediation of soils on the site and
demolition of various areas.
Currently, many of the formerly-maintained drainages, pine plantations, and cleared areas have
undergone considerable vegetative overgrowth. Much of the planted pine has been harvested,
and reforestation has occurred through natural revegetation. Damming of surface drainages by
beavers has modified the 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 associations,
upland pine forests/pine plantations, oak forests, low moist pine woods, hardwood swamps,
intermittent streams, shallow ponds, and drainage ditches.
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These systems support abundant populations of aquatic and terrestrial organisms. White-tailed
deer, introduced in the 1960s, 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
amphibians and aquatic reptiles. The East Beaver Pond provides roosting for waterfowl.
2.0 Site History and Enforcement Activities
ALAAP was established on 13,233 acres of land near the junction of Talladega Creek and the
Coosa River. The plant was built in 1941 and operated during World War H (WWTJ) as a
government-owned/contractor-operated (GOCO) facility. ALAAP produced nitrocellulose (NC),
single-based smokeless powder, and nitroaromatic explosives (i.e., trinitrotoluene (TNT);
dinitrotoluene (DNT); and 2,4,6-trinitrophenylmethylnitramine (tetryl)). Activities at ALAAP
included the manufacture of explosives; DNT; and chemicals including sulfuric acid, aniline,
N,N-dimethylaniline, and diphenylamine. Spent acids were recycled and wastes resulting from
these operations were disposed. In August 1945, operations were terminated at ALAAP, and
the plant was converted to standby status.
The plant was maintained in various stages of standby status until the early 1970s. In 1973, the
Army declared ALAAP excess to its needs. Since that time, several parcels of the original
property were sold or returned to their previous owners. In 1977, a 1,354-acre parcel was sold
to Kimberly Clark, Inc. for construction of a paper products plant. Area A, encompassing 2,714
acres, was auctioned in May 1990. Future land uses for these properties are expected to consist
of hunting grounds and wooded areas for occasional logging.
In 1978, the U.S. Army Environmental Center (USAEC) (formerly U.S. Army Toxic and
Hazardous Materials Agency (USATHAMA)), managing the Army's Installation Restoration
Program (IRP), conducted a record search which concluded that specific areas of the facility
were potentially contaminated by explosives and lead compounds. Additional studies at ALAAP
confirmed that soils were contaminated with explosives compounds, asbestos, and lead. Several
investigations were conducted between 1981 and 1983 to define contamination further. In 1984,
ALAAP was proposed for inclusion on the CERCLA (Superfund) National Priorities List (NPL).
A Remedial Investigation/Feasibility Study (RI/FS) under the Department of Defense (DOD) IRP
was initiated in 1985 to determine the nature and extent of contamination at ALAAP and the
alternatives available to remediate the site. For the purposes of the RI/FS, the facility was
divided into two general areas. Area A consisted of the eastern portion of the facility and 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,
and included building decontamination and demolition, soil excavation, and stockpiling.
Initially, 21,400 yd3 of contaminated soils were excavated from Area A and stockpiled in Area
13
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B in two covered buildings and on a concrete slab that was subsequently covered with a
membrane liner. In July 1987, ALAAP was placed on the NPL. The subsequent sequence of
events related to Areas A and B are presented separately in the following paragraphs.
Area A
In 1990, 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 1991, a supplemental RI was conducted to verify the effectiveness of the completed remedial
actions in Area A. The supplemental RI determined that soils in Study Areas 12 and D
contained lead and explosives at unacceptable concentrations. The supplemental RI/FS,
completed in January 1993, concluded that approximately 3,800 yd3 of lead-contaminated soil
in Study Area 12 and approximately 5 yd3 of explosives-contaminated soil in Study Area D
required further remediation. An Interim Record of Decision for Area A Soil Operable Unit
(Study Areas 12 and D) was submitted in April 1994. Stabilization and incineration were
selected as the preferred remedial alternatives in the Interim Record of Decision for Area A
soils.
AreaB
In February 1991, a Characterization Study was conducted for the Stockpile Soils excavated
from Area A and stored in Area B. The study confirmed that explosives, lead, and asbestos
contamination was present above acceptable limits. In March 1991, a tornado demolished one
of the two buildings that contained Stockpiled Soils. Soils and debris from the demolished
building were relocated on the concrete slab and covered with a membrane liner. A Feasibility
Study was completed for the Stockpile Soils hi October 1991. A Record of Decision for the
Stockpile Soils Area Operable Unit was issued in December 1991 and recommended incineration
as the preferred alternative. The incineration of Stockpile Soils commenced in May 1994 and
ended in August 1994.
Numerous studies have been conducted for study areas within Area B which include: Sanitary
Landfill and Lead Facility (Study Area 3); Manhattan Project Area (Study Area 4); Red Water
Storage Basin (Study Area 5); Combined TNT Manufacturing Areas (Study Areas 6 and 7);
Acid/Organic Manufacturing Area (Study Area 8); Aniline Sludge Basin (Study Area 9); Tetryl
Manufacturing Area (Study Area 10); Flashing Ground (Study Area 16); the majority of the
Propellant Shipping Area (Study Area 17); Blending Tower Area (Study Area 18); Lead Remelt
Facility (Study Area 19); Rifle Powder Finishing Area (Study Area 20); Red Water Ditch (Study
Area 21); Demolition Landfill (Study Area 22); Storage Battery/Demolition Debris Area (Study
Area 25); Crossover Ditch (Study Area 26); and the Beaver Pond Drainage System (Study Area
27).
A supplemental RI/FS for Area B was submitted in March 1992.
14
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Reports describing studies conducted at ALAAP are contained in the Administrative Record at
the Holston Army Ammunition Plant (Kingsport, TN) and the Earle A. Rainwater Memorial
Library (Childersburg, AL).
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
A public meeting was held in December 1991 to discuss the issues related to the preferred
remedial alternative selected for the Stockpile Soils Area Operable Unit. The soils of the
Stockpile Soils Area Operable Unit have been successfully treated on-site by rotary kiln
incineration. This Interim ROD, for treating contaminated materials hi Study Areas 6, 7, 10,
and 21 in Area B with similar waste characteristics, is prepared as an extension of the existing
Stockpile Soils Area Operable Unit remediation project.
A public notification for the Area B Soils Operable Unit public meeting and public comment
period was advertised in four local newspapers, one of which was a major newspaper. The
public comment period began on 19 September 1994 and ended on 19 October 1994.
Approximately 20 people attended a public meeting which was held on 28 September 1994 at
the Central Alabama Community College. The major concern of the public involved recent
occasions of paniculate (dust) fallout from an unidentified source. The public was informed that
the transportable incinerator had completed remediation of the Area A Soils Operable Unit on
22'August 1994 and, therefore, had not been operational in the five-week period prior to the
meeting.
4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
The Area B Soils Operable Unit cleanup strategy is an interim remedial action for contaminated
materials in Study Areas 6, 7, 10, and 21 within Area B. This interim remedial action will
protect human health and the environment from unacceptable risks caused by contaminated soils
and sediments in Study Areas 6, 7, and 21, and the industrial sewer system in Study Areas 6,
7, and 10. To the extent practical, actions associated with this Interim ROD are consistent with
the Army's future planned activities at ALAAP.
The Remedial Investigations conducted in Area B have determined that significant and extensive
explosives contamination is present in Study Areas 6, 7, 10 and 21. The threats addressed hi
this Interim ROD are the contaminated soils and sediments in Study Areas 6, 7, and 21, and the
contaminated underground ISS in Study Areas 6, 7, and 10. These areas are contaminated with
explosives and lead. Actual or threatened release of hazardous substances from these
contaminated soils, sediments, and ISS, if not addressed by implementation of the selected
remedy, may present a current or potential threat to the public health and the environment.
A final Remedial Investigation/Feasibility Study (RI/FS), Risk Assessment (RA), and Record
of Decision will be conducted for all Area B, including soils, sediments, groundwater, and other
contaminated media. Ongoing and future investigations by the U.S. Army, as outlined in its Site
Management Plan for ALAAP, will determine a final course of action for the Alabama Army
Ammunition Plant.
15
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5.0 NATURE AND EXTENT OF CONTAMINATION
The present contamination in Study Areas 6, 7, 10, and 21 is a direct or indirect result of past
explosives production. TNT manufacturing operations were conducted in Study Areas 6 and 7.
Tetryl manufacturing operations were conducted in Study Area 10. Wastes from explosives
production were disposed to the ISS in their respective areas. As a result, soils and sediments,
and the industrial sewer lines became contaminated with explosives, primarily TNT and tetryl.
Lead is also found in soils and sediments to a lesser extent. TNT contamination in Study Area
21 (Red Water Ditch) is a result of upstream production.
The results of groundwater and surface water studies are not presented herein, as they are
beyond the scope of this Interim ROD. Groundwater at ALAAP will be addressed by the Army
as a separate operable unit.
The information presented in this section is based on the following documents:
1. Remedial Investigation and Feasibility Study of the Industrial Sewer System,
Alabama Army Ammunition Plant, September 1991.
2. Supplemental Remedial Investigation/Feasibility Study (RI/FS) for Area B,
Alabama Army Ammunition Plant (AAAP), Draft Feasibility Study, March 1992:
The extent of contamination of soils and sediments and the ISS are discussed in Subsections 5.1
and 5.2, respectively. A summary of the nature and extent of contaminants of potential concern
(COPCs) in Study Areas 6, 7, 10, and 21 is presented in Table 1.
5.1 Soils and Sediments
5.1.1 Combined TNT Manufacturing Areas (Study Area 6 - Southern TNT Manufacturing
Area and Study Area 7 - Northern TNT Manufacturing
The Combined TNT Manufacturing Areas were studied extensively during the exploratory and
confirmatory surveys (ESE, 1981; 1983). Groundwater samples were collected during the RI
survey (ESE, 1986) for historical comparison. Soil samples were also collected during the RI
survey and tested for teachable lead. Significant findings include:
1. As a result of DNT and TNT manufacturing activities at ALAAP, the soils of the
combined TNT Manufacturing Areas contain nitroaromatic residues. These residues are
distributed in a complex pattern within an area of approximately 78,000 square yards and
extend from the ground surface to depths ranging from 3 ft to 7 ft. Up to 15 percent of
the contaminated area may contain residues at concentrations of 1,030 ppm of TNT or
greater, while up to 2.5 percent may contain 1,280 ppm of 2,4-DNT or greater.
16
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Table 1
Exposure Concentrations of Contaminants of Potential Concern (COPCs) in
Shallow* Soil and Sediment at Study Areas 6, 7,10, and 21 at AAAP Area B
Study
Area Medium Analyte
6 Soil 135TNB
246TNT
24DNT
26DNT
Lead
7 Soil I35TNB
13DNB
246TNT
24DNT
26DNT
Chromium
Copper
Nickel
Lead
10 Soil Lead
Tetryl
21 Soil 13DNB
246TNT
24DNT
26DNT
Detected
Mean
(mg/kg)
9.27E-01
1.48E+03
6.13E+00
1.53E+00
3.55E+01
2.79E+00
3.18E-01
8.98E+02
1.93E+00
4.19E+00
1.05E+01
1.50E+01
9.76B-fOO
1.81E+02
9.01 E +02
4.27E+03
3.31E+00
7.16E+03
4.99E-01
3.01E+00
Concentration
Maximum
(mg/kg)
1.31E+00
7.90E+03
1.60E+01
3.30E+00
1.03E+02
2.79E+00
3.18E-01
4.39B+03
5.12E+00
1.61E+01
1.68E+01
1.63E+01
1.04E+01
3.15E+02
1.99B+03
1.37B+04
7.70B+00
2.20E+04
6.66E-01
5.87E+00
Frequency
of
Detection
4/13
14/20
4/16
5/17
6/6
2/9
1/8
8/ 15
11/19
4/15
2/2
4/4
3/3
3/3
3/3
4/8
3/5
4/5
2/5
2/5
Best Estimate
of the Mean
(mg/kg)
4.13E41
1.13E+05
8.82E-01
4.42E-01
3.55E+01
7.62E-01
1.14E-01
8.06E+04
1.26E+00
4.82E-01
1.05E+01
1.50E+01
9.76E+00
1.81E+02
9.01E+02
4.50E+05
5.59E+00
2.66E+07
4.99E-O1
4.40E+00
Upper 95%
Confidence
Limit (UCL,,)
(mg/kg)
6.00E-01
1.28E+09
5.28E+00
1.51E+00
6.36E+01
1.47E+00
1.69E-01
1.48E+10
4.39E+00
1.98E+00
5.05E+01
1.67E+01
1.40E+01
3.81E+02
2.58E+03
7.33E+15
2.78E+05
7.32E+28
1.56E+00
S.83E+16
Exposure
Concentration
(mg/kg)
6.00E-01
7.90E+03
5.28E+00
1.51E+00
6.36E+01
1.47E-rOO
1.69E-01
4.39E+03
4.39E+00
1.98E+00
1.68E+01
1.63E+01
1.04E+01
3.15E+02
1.99E+03
1.37E+04
7.70E+00
2.20E+04
6.66E-01
5.87E+00
17
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Table 1 (Continued)
Exposure Concentrations of Contaminants of Potential Concern (COPCs) in Shallow*
Soil and Sediment at Study Areas 6, 7,10, and 21 at AAAP Area B
Frequency
Study Detected Concentration of Best Estimate
Area Medium Analyte Mean
(mg/kg)
21, Sediment 13DNB 5.09E+01
cont. 246TNT 7.25E+00
24DNT 1.19E+00
26DNT 9.10E-01
ANTRC 2.40E-01
BAANTR 1.10E+00
CHRY 7.90E-01
Chromium 3.38E+01
Copper 1.93E4-01
FANT 1.60E+00
HG 4.01E-01
NB S.08E+01
Nickel 1.74E+01
NNDPA 5.00E-01
Lead S.80E+01
Tetryl 1.28E+00
'Soil and sediment data from samples collected 0 to 2 feet
Key: ANTRC - Anthracene
BAANTR - Benzo(a)anthracene
CHRY - Chrysene
24DNT - 2,4-Dinitrobenzene
26DNT - 2,6-Dinitrobenzene
Maximum
(mg/kg)
5.09E+01
1.65E+01
5.67E+00
1.85E+00
2.40E-01
1.10B+00
7.90E-01
5.03E+01
3.16E+01
1.60E+00
4.01 E-01
5.08B+01
2.07E+01
5.00E-01
2.23E+02
1.28B+00
below land surface.
FANT-
NB-
NNPDA -
135TNB -
246TNB-
Detection of the Mean
(mg/kg)
1 / 23 3.34E-01
7 / 26 1.46E+00
6/25 2.30E-01
5 / 14 4.95E-01
1/3 1.25E-01
1/3 6.02E-01
1 / 2 4.40E-01
4/5 2.84E+01
5/5 1.93E+01
1/3 1.19E+00
1/23 1.23 E-01
2 / 24 2.02E+00
8 / 8 1.74E+01
1 / 3 2.55E-01
26 / 26 5.80E+01
1 / 22 2.22E-01
Fluoranthene
Nitrobenzene
N-Nitrosodiphenylamine
1 ,3,5-Trinitrobenzene
2,4,6-Trinitrobenzene
Upper 95%
Confidence
Limit (UCL,5)
(mg/kg)
9.20E-01
7.07E+00
4.86E-01
1.53E+00
2.98E-01
1.83E+06
2.65E+00
4.62E+01
2.94E+01
7.76E+15
1.50E-01
7.23E+00
1.96E+01
6.22E-01
7.24E+01
3.17E-01
Exposure
Concentration
(mg/kg)
9.20E-01
7.07E+00
4.86E-01
1.53E+00
2.40E-01
1.10E+01
7.90E-01
4.62E+01
2.94E+01
1.60E+00
1.50 E-01
7.23E+00
1.96E+01
5.00E-01
7.24E+01
3.17E-01
Source: BSE.
18
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2. Soil samples collected during the RI survey (ESE, 1986) contained low concentrations
of leachable lead (20.7 to 94.4 /ig/L) that were below the then-applicable extraction
procedure (EP) toxicity criteria.
3. Friable and transite asbestos contamination is extensive and well mixed with soil due to
plant demolition activities.
4. Currently, no groundwater is used within 10,500 ft of the combined TNT Manufacturing
Areas. Based on a maximum horizontal migration rate in the unconsolidated materials,
contaminant migration to the point of withdrawal is not imminent.
5.1.2 Study Area 21 - Red Water Ditch
The Red Water Ditch was studied during the exploratory and RI surveys. Significant findings
include:
1. Sediments collected during the RI survey contained 0.880 ppm of TNT at the point where
the Red Water Ditch leaves the installation. TNT was also detected where the Red
Water Ditch leaves the Southern TNT Manufacturing Area (Study Area 6).
2. Low concentrations of nitroaromatic compounds (in three samples) and lead (in two
samples) were detected in the upstream surface waters during the exploratory survey.
The Red Water Ditch was not flowing during the RI survey. The 2,4-DNT concentrations
ranged from 3.0 to 3.7 jtg/L.
3. All soil samples collected along the spoil banks during the RI survey contained TNT,
with concentrations ranging from 0.665 to 22,200 ppm. The compounds 2,4-DNT (0.667
ppm in one sample); 1,3-DNB (0.221 and 7.70ppm); and 2,6-DNT (0.15 and 5.87 ppm)
were also detected. Individual pieces of TNT can still be found in the spoil banks.
Leachable lead (64.4 and 2,733 /*g/L) was detected in two of three soil samples tested.
Both values were below the then-applicable EP toxicity criteria.
4. Sediments in the Red Water Ditch are not a source for surface water contamination
migration. Contaminated sediments are generally associated with the surface of the WWH
grade of the Red Water Ditch. Bank erosion during the past 50 years has covered these
contaminated sediments with clay to a depth of 1 to 2 ft below the current surface of the
Red Water Ditch.
5. Runoff from the spoil piles and occasional discharges from contaminated industrial sewer
lines present potential pathways for contaminant migration.
6. TNT contamination in the surface sediments of the Red Water Ditch is a result of
upstream TNT production. The absence of tetryl in the surficial sediments of the Red
Water Ditch at the ISS outfall from the Tetryl Manufacturing Area indicates that, while
19
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the ISS is contaminated, it does not appear to be discharging the contamination to the
surface drainages.
5.2 Industrial Sewer System (ISS)
Layouts of the sewer lines in Study Areas 6, 7, and 10 are shown in Figures 4, 5, and 6,
respectively.
5.2.1 Study Area 6 - Southern TNT Manufacturing Area
Contamination (approximately 1 ppm of TNT) was detected in one sample collected from the
furthest upgradient manhole (MH 6-16) in the E-TNT production line where the Mono-Nitrating
House feeder Line meets the trunk line from the Fortifier House. Contamination was also
detected inside a manhole (MH 6-18) structure in one of the three samples collected where the
ditch from the Bi- and Tri-Nitrating House (E-TNT line) enters the system, and in a manhole
(MH 6-11) sample where the line from the H-TNT production line connects to the G-TNT line.
The highest nitroaromatic concentrations (15,800 ppm of 2,4-DNT and 12,500 ppm of TNT)
detected in the Southern TNT Manufacturing Area were in the shallow (6 ft) soil sample at
manhole MH 6-3, where the surface water ditch entered the vertical clay pipe. The sample
collected at 14 ft near the base of the manhole also contained nitroaromatic contamination (5
compounds) at lower concentrations. Discoloration generally diminished with depth and may
have been due to leaching by solvents in the wash runoff. High TNT concentrations (1,400 ppm)
were also detected in the sample (TP 6-4) collected from the ditch between the E-TNT
production line Washer House and the Red Water Ditch.
Three of the six sediment samples collected from the surface drainage ditches contained
detectable concentrations of TNT (0.47 to 2.87 ppm). No contamination was detected in the
sample collected from the Red Water Basin at the outfall of the ISS line. No other contaminants
were detected in the sediment samples.
Both water samples collected from the ISS outfalls contained detectable concentrations of TNT.
The sample from the outfall of the combined G- and H-TNT production lines contained 1.33
ppm of TNT, while the sample from the E-TNT production line contained 198 ppm of TNT.
This sample also contained 2,4-DNT; 2,6-DNT; and RDX.
Based on these results, the ISS within the Southern TNT Manufacturing Area is contaminated
with high concentrations of nitroaromatic compounds. These concentrations vary from production
line to production line and also within each production line. The manhole structures have
probably leaked to some degree, as evidenced by contamination in the soils surrounding the
structures. The greatest soil contamination appears to be in the area where the surface ditch from
the Bi- and Tri-Nitrating House enters the ISS.
TNT contamination in the surface sediments of the Red Water Ditch and multiple nitroaromatic
20
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KEY
MH - Manhole
TP-Test Pit
BJ- 4 TO.
NITftATma
HOUSE
MTftATMa
NOTE:
ALL PIPES ARE VITRIFIED CLAY.
ACID ANOFUMK
RECOVERY HOUSf
MH6-18|
, - TO RED WATER BASIN
RGURE4
LAYOUT OF INDUSTRIAL SEWER SYSTEM
IN STUDY AREA 6 - SOUTHERN TNT
MANUFACTURING AREA
SOURCE: ESC.
U.S. ARMY CORPS OF ENGINEEPS
HUNTSVILLE DIVISION
ALABAMA ARMY AMMUNITION PLANT
21
-------
JUMP ISPS V911B
KEY
MH - Manhole
IP - Test Pit
NOT TO SCALE
Uft OWT NRlUTMa
U2SWEATVM A
D- AOO
NCCOVCMY HOUH
•01 Wk
NOTE:
ALL PIPES ARE VITRIFIED CLAY.
JTP7-2 |
RGURE 5
LAYOUT OF INDUSTRIAL SEWER SYSTEM
IN STUDY AREA 7 - NORTHERN TNT
MANUFACTURING AREA
LLS. ARMY CORPS OF ENGMEERS
HUNTSVILLE DIVISION
ALABAMA ARMY AMMUNITION PUNT
22
-------
•_'S*Gt AAV ISFS V91 It
1 1
N \
NOT TO SCALE
0—
FLOW -
* PLOW
/ 24"
OUTPAU./
^ t ^~
«/
m FLOW
I/
a
M
:
DW
' 5
w
M
<
S
21"
IEIMV
MOUM
'',
MH1
, '
K -"J
J t,
FLOW
MH10-1 |
X
^
NOTE:
ALL PIPES ARE VITRIFIED CLAY.
i
UML
j.- r
UMK
< PLOW \.
LMi J \
(/•- r = \
I ^ ^. \
b y « /
/
UNI a
r~ »" f
UMP /
~ j. a
j- y I
. MTMAY1NO MOU3C 1QOM
1002-C LMi C
d r 3 ItlRVL HCATEM
J^X H0««,««
1 \
0-3 1 UNTB
1C J \
^ \
1 - '
1 *.. /
L J . /
UMA /f
UMK M x^
» ;
KEY
MH - Manhole
TP - Test Pit
v
FIGURE 6
LAYOUT OF INDUSTRIAL SEWER SYSTEM U.S. ARMY CORPS OF ENGINEERS
IN STUDY AREA 1 0 - TETRYL MANUFACTURING AREA HUNTSVILLE DIVISION
ALABAMA ARMY AMMUNITION PLANT
23
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compounds in the waters discharging from the ISS indicate that the ISS in the Southern TNT
Manufacturing Area is continuing to discharge contamination to its surface drainages.
5.2.2 Study Area 7 - Northern TNT Manufacturing Area
High concentrations (5,330 to 70,000 ppm of TNT) of contamination were detected in all four
samples collected inside the manhole structures. A large piece (approximately 1 ft by 2 ft) of
weathered TNT was observed in manhole MH 7-3. Contamination was detected in the two
samples collected from the upgradient manholes (MH 7-1 and MH 7-7) on the C-TNT and
D-TNT production lines where the Mono-Nitrating House feeder line meets the trunk line from
the Fortifier House. Contamination in these two manhole structures included: 5,300 ppm of TNT
and 19,300 ppm of nitrocellulose in MH 7-1; and 70,000 ppm of TNT and 8,600 ppm of
nitrocellulose in MH 7-7, along with 2,4-DNT. Contamination was detected in the three manhole
(MH 7-6, MH 7-9, and MH 7-15) samples collected where the ditch from the Bi- and
Tri-Nitrating House enters the ISS.
Soil contamination was detected in the five upper-reach soil samples (TP 7-10, TP 7-11, TP 7-7,
TP 7-4, and TP 7-2) from the four TNT production lines. The highest nitroaromatic
concentrations (79,700 ppm of TNT) detected in the Northern TNT Manufacturing Area were
in the deep soil sample (9.5 ft) at manhole MH 7-6 where the ditch from the Bi- and
Tri-Nitrating House enters the vertical clay pipe. The sample collected at 3.5 ft at this same
location also contained nitroaromatic contamination (46,100 ppm of TNT). Soils at the junction
of this ditch with the ISS line were discolored (bright purple) and had an odor, which did not
register on the photoionizing detector. This discoloration generally diminished with depth.
Four of the six sediment samples collected from the surface drainage ditches contained
concentrations of TNT (1.48 to 63.3 ppm). A detectable concentration of 2,4-DNT (1.41 ppm)
was also detected hi one sediment sample.
No water samples were collected from the Northern TNT Manufacturing Area due to dry
conditions during the field investigation.
Based on these results, the ISS within the Northern TNT Manufacturing Area is contaminated
with high concentrations of nitroaromatic compounds. These concentrations vary from production
line to production line and also within each production line. The manhole structures have
probably leaked to some degree as evidenced by high concentrations of contamination in the soils
surrounding the structures. The greatest soil contamination appears to be in the area where the
surface ditch from the Bi- and Tri-Nitrating House enters the ISS.
TNT contamination in the surface sediments of the Red Water Ditch indicates that the ISS in the
Northern TNT Manufacturing Area is continuing to discharge contamination to its surface
drainages.
24
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5.2.3 Study Area 10 - Tetryl Manufacturing Area
Soil contamination was detected where the wastes entered the ISS from surface ditches. The
highest tetryl concentrations (20,900 ppm and 18,900 ppm) detected in the Tetryl Manufacturing
Area were in the shallow (2 ft and 2.5 ft) soil samples at manholes MH 10-3 and MH 10-1,
where the surface ditches entered the vertical clay pipes leading to the base of the manhole
structures. The samples collected near the base of the manholes at these locations contained
tetryl contamination at lower concentrations. High nitrocellulose concentrations were detected
in the shallow soil samples at these two locations.
Low concentrations of TNT were detected in the two sediment samples collected from the
surface drainage and at the ISS outfall into the Red Water Ditch. No other contaminants were
detected in the sediment samples.
Based on these results, the ISS within the Tetryl Manufacturing Area is contaminated with high
concentrations of tetryl, nitrocellulose, and 1,3,5-TNB. The manhole structures have probably
leaked as evidenced by contamination in the soils surrounding the structures. The greatest soil
contamination appears to be in the area where the surface ditches enter the ISS.
6.0 SUMMARY OF SITE RISKS
The information presented in this section is based on the "Supplemental Remedial
Investigation/Feasibility Study for Area B, Alabama Army Ammunition Plant, Baseline Risk
Assessment", August 1992.
6.1 Exposure Assessment
The human risk assessment (RA) evaluated three primary exposure scenarios for quantitative
assessment of the risks associated with potential exposure of the local population within the
intended areas to site-related contaminants of concern. Based on the physical and chemical
properties of the contaminants identified in Area B, as well as the site-specific geological,
hydrogeological, and meteorological conditions, the most significant migration pathway has been
determined to be infiltration of soil contaminants to the underlying groundwater.
The following human exposure scenarios have been addressed in the risk assessment:
• Future residential scenario.
• Future industrial scenario.
• Current worker or caretaker scenario.
The primary human exposure routes evaluated for the residential and industrial scenarios in the
RA included:
• Exposure to contaminants as a result of ingestion of groundwater contaminated
by on-site soils and sediments.
25
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• Exposure to contaminants as a result of direct contact (dermal contact and
incidental ingestion) with surface soil, surface water, and sediments.
• Exposure to contaminants as a result of inhalation of contaminated dusts.
The main ecological exposure routes evaluated included:
• Exposure of aquatic and terrestrial animals to contaminants as a result of direct
contact (dermal contact and incidental ingestion) with surface soil, surface water,
sediments, and contaminated food.
• Exposure of terrestrial animals to contaminants as a result of inhalation of
contaminated dusts.
Results of the human and ecological RA indicated that the potential noncarcinogenic and
carcinogenic adverse impacts to human health and the environment, which are associated with
future exposure to several study areas within Area B, range from low to high. These impacts
depend on the exposure scenario and the study area being considered. The noncarcinogenic
impacts are indicated by a cumulative hazard index (HI) exceeding 1; a carcinogenic risk is
posed if the cumulative risk exceeds l.OE-04.
A summary of contaminants in soils and sediments that required remedial alternative screening
based on the ecological risk assessment is presented in Table 2.
6.2 Intermediate Cleanup Levels (ICT^s)
Intermediate Cleanup Levels (ICLs) developed in the Baseline Risk Assessment for future
residential and industrial scenarios for Study Areas 6, 7, 10 and 21 are presented in Table 3.
7.0 DESCRIPTION OF HFIMPTITAL ALTERNATIVES
In this section, remedial alternatives for soils and sediments and the ISS are discussed separately
as they were evaluated in various Area B feasibility studies. Soils and sediments remedial
alternatives are discussed in Subsection 7.1 and ISS remedial alternatives are discussed in
Subsection 7.2.
7.1 Soils and SAHiments Remedial Alternatives
Several remedial alternatives were considered during the initial screening stage in the Draft
Feasibility Study for Area B submitted in March 1992. The remedial alternatives were grouped
according to the type(s) of contaminants. The groups consisted of:
• Metals- and polyaromatic hydrocarbons (PAH)-contaminated soils and sediments.
• Explosives-contaminated soils and sediments.
• Metals- and explosives-contaminated soils and sediments.
26
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Table 2
Contaminants in Soils and Sediments that Required Remedial Alternative
Screening Based on the Ecological Risk Assessment
Study Area
6
7
10
21
Contaminant of Concern
TNT; 2,4-DNT; 2,6-DNT
TNT; 2,4-DNT; 2,6-DNT; Lead
Tetryl; Lead
TNT; Lead
Supplemental Remedial Investigation/Feasibility Study for Area B, Alabama Army
Ammunition Plant, Baseline Risk Assessment, August 1992.
27
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Table 3
Intermediate Cleanup Levels for Soils and Sediments
Considering Multiple Exposures
Contaminant
TNT
1,3-DNB
Tetryl
Lead
Intermediate Cleanup Levels1
(ppm)
Residential
34.3
l.O2
696
200
Industrial
647
l.O2
5,000
500
Key: 1 - For each contaminant in each category, the listed ICL is the lowest ICL
established for Study Areas 6, 7, 10 and 21. Although the lowest ICL
is listed, ICLs for each study area are quite similar (e.g., for TNT, the
ICLs for the Residential Scenario for Study Area 6, 7, and 21 are 34.8
ppm, 34.3 ppm and 34.7, respectively).
2 - Note that the Baseline Risk Assessment dated August 1992 included
excavation criterion for 1,3-DNB of 0.5 ppm. The Chemical Data
Acquisition Plan (CDAP) for the Stockpile Soils Area Operable Unit
outlines the quantitation limits for metals and explosives. Table 8-2 of
the CDAP indicates that the quantitation limit for 1,3-DNB is 1 ppm.
Review of Table 6.2-2 of the Baseline Risk Assessment of August 1992
indicates that the ICL for 1,3-DNB was based on the analytical detection
limit. There is a concern that due to potential analytical interferences,
the lower limits specified in the RI/FS may not be consistently
achievable. As such, the excavation criterion for 1,3-DNB is set at 1
ppm.
NE - Not Established.
Source: Supplemental Remedial Investigation/Feasibility Study for Area B, Alabama
Army Ammunition Plant, Baseline Risk Assessment, August 1992, Tables 6.2-1,
6.2-2, and 6.2-3.
28
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The aggressiveness of the remedial alternatives increased in ascending order. After the initial
screening, five final alternatives (Alternatives 1A, 1C, ID, 1G, and II) were assembled and
retained for detailed analysis. The final soils and sediments remedial alternatives were the
following:
1 A: Stabilization of Metals- and PAH-Contaminated Soils and Sediments.
1C: Off-Site Disposal of Metals- and PAH-Contaminated Soils and Sediments.
ID: Incineration of Explosives-Contaminated Soils and Sediments.
1G: Incineration/Stabilization of Metals- and Explosives-Contaminated Soils and
Sediments.
II: No Action.
Brief descriptions of the soils and sediments remedial alternatives are presented in Subsections
7.1.1 through 7.1.4.
7.1.1 Alternative 1A: Stabilisation of Metals- and PAH-r.nntaminated Soils and Sediments
Alternative 1A includes site preparation followed by excavation of all metals- and PAH-
contaminated soils and sediments. Excavated soils and sediments would be remediated using the
following operations:
1. Staging of soils and sediments prior to stabilization.
2. On-site stabilization until TCLP criteria are met.
3. Backfilling stabilized soils into the existing excavation.
4. Landfllling of remaining stabilized material in an off-site hazardous waste landfill.
7.1.2 Alternative 1C; Off-Site Disposal of Metals- and PAH-Ointfltninfltad Soils and
Alternative 1C includes site preparation followed by the excavation of all metals- and PAH-
contaminated soils and sediments. Excavated soils and sediments would be transported to the
Chemical Waste Management hazardous waste landfill facility for disposal.
7.1.3 Alternative 1T>; Incineration of Explosives-Cop^gm'nttted Soils and S*^*tn6Pts
Alternative ID includes site preparation followed by excavation of all explosives-contaminated
soils and sediments. Excavated soils and sediments would be remediated using the following
operations:
1. Staging of soils and sediments prior to incineration.
29
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2. On-site incineration via transportable rotary kiln incinerator for explosives-
contaminated material.
3. Disposal of incinerated ash in the original excavations.
4. Landfillihg of remaining stabilized material in an off-site hazardous waste landfill.
7.1.4 Alternative 1G; Incineration/Stabilisation of Metals- and Rxplosives-Copta"""3ted
Soils and Sediments
Alternative 1G includes site preparation followed by excavation of all explosives- and metals-
contaminated soils and sediments. Soils and sediments contaminated with metals and/or
explosives would be remediated using the following operations:
1. Staging of soils and sediments prior to incineration and/or stabilization.
2. On-site incineration via transportable rotary kiln incinerator.
3. Stabilization of soils and sediments and incinerator ash until TCLP criteria are
met.
4. On-site disposal of treated and stabilized material.
7.1.5 Alternative II - No Action
The no-action alternative is required to be included as stipulated by CERCLA/SARA as a
baseline against which other alternatives can be evaluated. Under this alternative, contaminated
soil and sediments would remain in place in the identified study areas. The risks from the
contaminants of concern (COCs) would remain. No cost is associated with this alternative.
7.2 Industrial Sewer System Alternatives
Three remedial alternatives were evaluated in the detailed analysis in the RI/FS for the ISS
submitted in September 1991. A fourth alternative was developed during the preparation of this
interim ROD based on site inspections and review of archive drawings. The new alternative is
identified as ISS3. The ISS remedial alternatives are as follows:
ISS1: Excavation, On-Site Flashing, and Off-Site Landfilling.
ISS2: Excavation, On-Site Mobile Rotary Kiln Incineration, and Off-Site Landfilling.
ISS3: Deactivation and Grouting of Concrete-Encased VCP; Excavation,
Decontamination or On-Site Incineration, and On-Site Disposal of VCP.
ISS7: No Action.
Approximately 20,000 linear feet of underground sewer lines (8 to 36 inches in diameter)
currently exist in Study Areas 6, 7, and 10. Some of the VCP is encased in concrete. Much
has been disturbed during plant demolition activities over the years. Subsections 7.2.1 through
30
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7.2.3 describe the three remedial alternatives.
7.2.1 Alternative ISS1: Excavation. On-Sfr» Flashing and Off-She Landfilling
Alternative ISS1 (identified as Alternative 1 in the RI/FS of September 1991) involves
excavation, on-site flashing, and off-site disposal of the contaminated sewer lines and manholes
in Study Areas 6, 7, and 10. Explosives-contaminated vitrified clay pipe sewer lines, concrete
encasement, and brick manholes would be flashed on-site. Flashing requires the use of a hand-
held flarner to thermally decompose surface contaminants. It is anticipated that complete
decomposition of all potentially energetic residues that are at, or near, the flame front can be
accomplished due to the intensity of the heat.
The explosives thermally decompose to volatile byproducts via a combination of ring-splitting
and fragmentation reactions. In all cases, the reactions are exothermic. No air emissions
controls are associated with on-site flashing. The primary byproducts of complete thermal
decomposition of explosives include nitrous oxides (NOJ, carbon monoxide (CO), carbon
dioxide (COj), water (H2O), and nitrogen gas (Nj). This technique has been used successfully
in the decontamination of structures at several sites including the West Virginia Ordnance Works
and the ALAAP Leaseback Area.
The decontaminated materials must then be crushed and transported off-site for disposal in a
hazardous waste landfill. The potentially energetic components of the hazardous waste will be
deactivated and residual materials disposed in a permitted hazardous waste landfill. The
estimated cost for implementation of this alternative is $4,165,000 (Feasibility Study of the
Industrial Sewer System, September 1991).
7.2.2 Alternative ISS2: Excavation. On-Site Mobile Rotary Kiln Incineration, and Off-
Site Landfillinp
Alternative ISS2 (identified as Alternative 2 in the RI/FS of September 1991) involves
excavation, on-site incineration, and off-site disposal of the contaminated sewer lines and
manholes in Study Areas 6, 7, and 10. Explosives-contaminated vitrified clay pipe sewer lines,
concrete encasement, and brick manholes would be incinerated on-site using a mobile
incinerator.
The mobile incinerator selected for this application would consist of a rotary kiln unit with a
secondary combustion chamber. The secondary combustion chamber would achieve a
destruction and removal efficiency (DRE) of 99.99% for organic contaminants in the off-gas.
The resulting ash and debris would then be transported off-site to a hazardous waste landfill.
This requires deactivation of the energetic components of the hazardous waste and disposal of
residual materials in a permitted hazardous waste landfill. The estimated cost for
implementation of this alternative is $6,190,000 (Feasibility Study of the Industrial Sewer
System, September 1991).
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7.2.3 Alternative TSS3; Deactivation and Grouting of Concrete-En
Decontamination or On-Site Incineration, and On-Site Disposal of VCP
Alternative ISS3 was developed during the process of writing this Interim ROD, based on site
inspections, discussions with U.S. Army Corps of Engineers personnel, and review of archive
drawings. In this alternative, concrete-encased pipes and non-encased pipes are addressed
separately. A detailed description of this alternative is presented in Section 9.0 (Selected
Remedy and Remediation Goals). A summary of remedial actions is presented in the following
paragraphs.
Concrete-encased pipes will be visually inspected for gross contamination. Contaminated
material will be removed and treated in the on-site incinerator, and the pipes will be grouted in
place. Where the pipes are crushed or broken, oversize material will be decontaminated and
disposed on-site in the backfill area. Undersized material (<2 inches) will be blended with
surrounding soil and will be treated on-site by incineration and/or stabilisation and disposed in
the on-site backfill area.
Nonencased sewer lines and manholes will be removed and transported to the incinerator site
for decontamination by high-pressure water washing or other approved methods. The
decontaminated material will be disposed in the on-site backfill area.
Contaminated soil exceeding the excavation criteria above and surrounding the VCP will be
treated on-site by incineration and/or stabilization and disposed in the on-site backfill area.
73.4 Alternative ISS7 - No Action
The no-action alternative is required to be included as stipulated by CERCLA/SARA as a
baseline against which other alternatives can be evaluated. Under this alternative, contaminated
VCP within the industrial sewer system would remain in place in the identified study areas. The
risks from the COCs would remain. No cost is associated with this alternative.
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
8.1 Threshold Criteria
Overall Protection of Human Health and the Environment
(A) Soils and Sedimem;
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(K) Industrial Sewer System: Alternative ISS7 (No Action alternative) would not provide
protection to human health or the environment. Alternatives ISS1, ISS2, and ISS3 would
provide adequate protection to human health and the environment by providing a permanent
solution which includes removal and irreversible destruction of contaminants.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
(A) Soils and Sediments: No federal or state chemical-specific ARARs regulate implementation
of any of the alternatives. Soils will be remediated according to health-based cleanup levels
determined to be protective to human health and the environment. In Alternatives 1A, ID and
1G, stabilized materials will meet the TCLP criteria for metals. In Alternatives ID and 1G,
incineration will meet <1 ppm for TNT in treated material. Alternative II (No Action
Alternative) would not achieve the remediation levels since the contamination would not be
removed or destroyed.
(B) Industrial Sewer System: No federal or state chemical-specific ARARs regulate
implementation of any of the alternatives. Alternatives ISS1, ISS2, and ISS3 would meet
excavation and decontamination criteria upon completion of remedial actions. Alternative ISS7
(No Action Alternative) would not achieve the remediation levels since the contamination would
not be removed or destroyed.
The following location-specific ARARs may be applicable within AAAP:
1. Within 100-year floodplain
• 40 CFR 264. 18(b) - Facility must be designed, constructed, operated, and
maintained to avoid washout by a 100-year flood.
2. Within floodplain
• Executive Order 11988; 40 CFR 6, App. A: Floodplain Management - Requires
actions to avoid adverse effects, minimize floodplain destruction, restore and
preserve natural and beneficial values, and minimize impact of floods on human
safety, health and welfare.
3. Wetland
• Executive Order 11990; 40 CFR 6, App. A: Protection of Wetlands - Requires
action to avoid adverse impact, minimize potential harm, and to preserve and
enhance wetlands to the extent possible.
4. Within an area affecting stream or river
• Fish and Wildlife Coordination Act [16 United States Code (USC) 661 et seq.] -
33
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Must take action to protect affected fish or wildlife resources, and prohibits
diversion, channeling, or other activity that modifies a stream or river and affects
fish or wildlife.
5. Critical habitat upon which endangered or threatened species depends
• Endangered Species Act of 1973 (16 USC 1531 et seq.): 50 CFR 402 - Requires
action to conserve endangered or threatened species. Must not destroy or adversely
modify critical habitat.
However, none of the location-specific ARARs are expected to apply to implementation of any
of the alternatives being evaluated since all activities associated with the Area B Soils Operable
Unit remediation would be conducted in areas located away from sensitive environment (i.e.,
the river, 100-year floodplain, or critical habitat).
The following action-specific ARARs may apply to implementation of these alternatives,
excluding Alternatives II and ISS7 (No Action):
1. Clean Air Act (CAA)
• 40 CFR Part 50: National Primary and Secondary Ambient Air Quality
Standards—Establishes standards for ambient air quality to protect public health and
welfare.
• 40 CFR Part 61: National Emission Standards for Hazardous Air Pollutants-Sets
emission standards for designated hazardous pollutants.
2. Resource Conservation and Recovery Act (RCRA)
• 40 CFR Part 261: Identification and Lasting of Hazardous Waste - Provides
guidelines for classifying wastes as hazardous waste.
• 40 CFR Part 262: Standards Applicable to Generators of Hazardous Waste -
• Establishes standards for generators of hazardous waste.
• 40 CFR Part 264: Standards for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities - Establishes minimum national standards
which define the acceptable management of hazardous waste for owners and
operators of facilities which treat, store, or dispose of hazardous waste.
• 40 CFR Part 266 Subpart H: Standards for Hazardous Waste Burned in Boilers and
Industrial Furnaces - Specifies standards for owners and operators of boilers and
industrial furnaces burning waste and not operating under interim status.
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3. Alabama Administrative Code (AAC)
• Chapters 13-1 through 13-7: Alabama Solid Waste Management Regulations -
Establishes minimum criteria for the processing, recycling and disposal of solid
wastes and the design, location, and operation of solid waste disposal facilities.
• Chapters 335-3-1 through 335-3-14: Alabama Air Pollution Control Rules and
Regulations - Sets emission standards and establishes permitting requirements for air
pollutants.
4. Code of Alabama
• Title 22, Chapter 27: Alabama Solid Waste Act - Establishes a statewide program
to provide for the safe management of non-hazardous wastes.
• Title 22, Chapter 28: Alabama Air Pollution Control Act of 1971 - Provides for a
coordinated statewide program of air pollution prevention, abatement, and control.
• Title 22, Chapter 30: Alabama Hazardous Waste Management and Minimization Act
- Establishes a statewide program to provide for the safe management of hazardous
wastes, including hazardous waste generation, transportation, and land disposal.
5. Alabama Department of Environmental Management (ADEM)
• Chapter 14-1: Alabama Hazardous Waste Management Regulations-Establishes
standards which define the acceptable management of hazardous waste for owners
and operators of facilities which treat, store, or dispose of hazardous waste.
8.2 Primary Balancing Criteria
Short-Term Effectiveness
(A1 Soils and Sediments: No significant risks to the community, workers, or the environment
are expected during the implementation of any of the soil and sediment remedial alternatives.
Workers will be provided with appropriate personal protection, and safety procedures will be
followed during all phases of the remedial actions. Alternative II would present unacceptable
risks to human health and the environment since no remediation of the contaminated soils and
sediments would occur. Therefore, this alternative would not be effective in the short term.
(B1 Industrial Sewer System: Provided that there are no adverse effects associated with
uncontrolled emissions resulting from flashing (Alternative ISS1), the risks to the community,
workers, and the environment associated with the implementation of each of the alternatives are
anticipated to be minimal The greatest safety hazards are expected to be associated with sewer
line excavation (in all alternatives), and deactivation of encased VCP (Alternative ISS3). The
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risks to the workers will be reduced by wearing appropriate personnel protection, and following
proper safety procedures. Alternatives ISS1, ISS2, and ISS3 present a risk to workers due to
the potential for explosion and exposure to contaminants during excavation. Alternative ISS7
would present unacceptable risks to human health and the environment since no remediation of
the contaminated VCP would occur. Therefore, this alternative would not be effective in the
short term.
Long-Term Effectiveness and Permanence
(A) Soils and Sediments! Alternatives 1A, 1C, ID, and 1G would reduce the risk associated with
contaminants Alternatives ID and 1G would provide a permanent remedy for explosives-
contaminated materials by irreversible destruction of organic contaminants via incineration.
Alternative 1G will provide additional long-term protection by immobilizing teachable metals,
primarily lead, by stabilization. Alternative II would not be effective in the long term since the
contamination soil and sediment would remain in place without treatment.
(F) Industrial Sewer System: Alternatives ISS1, ISS2, and ISS3 would remove and destroy the
source of contamination in the ISS. After remediation, no significant concentrations of
contamination would remain that require long-term management to ensure adequate levels of
protection. Alternative ISS7 would not be effective in the long term since the contamination
VCP would remain in place without treatment.
Reduction of Toxicity, Mobility, and Volume (TMV)
(A) Soil? t*"d Sediments: The TMV of contaminated materials will be reduced significantly in
each of the alternatives. Alternatives ID and 1G would provide more reduction in volume than
Alternatives 1A and 1C, since these alternatives provide permanent destruction of explosives-
contaminated materials. Alternative 1G would be the most effective since it addresses all types
of contaminants in soils and sediments. Although some smhiKMd materials will resuh in
Alternative 1G, the mobility of the contaminants will be significantly reduced. Because the
contaminants in soil an
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(F) Industrial Sewer System: The equipment, personnel and technology are readily available for
all three alternatives. No technical limitations are associated with the mobile incineration
(Alternatives ISS2 and ISS3). Implementation of the flashing alternative (ISS1), is dependent
upon obtaining a permit from EPA which allows uncontrolled emissions associated with open
burning (flashing). Deactivation procedures for encased VCP (Alternative ISS3) will be
evaluated by a firm specializing in management of energetic wastes. Procedures will be
approved by the U.S. Army. No remedial action would be conducted under Alternative ISS7.
Cost
(A) Soils and Sediments: Soil and sediment volumes and costs were estimated in the FS
submitted in March 1992. However, these volumes and costs are not representative of the
currently-proposed remedial actions due to changes in study areas and remediation goals. The
Baseline Risk Assessment was revised in August 1992. The ICLs established in the revised risk
assessment were higher than those established in March 1992. New volumes were not calculated
based on these revised ICLs.
The approximate cost for proposed remedial Alternative 1C is now estimated based on the
following assumptions:
(A) Volume of contaminated soils and sediments equals the volume of soil and
sediment computed for the industrial scenario, for Alternative 1G (from March
1992 FS).
. (B) Unit cost = $346/yd3 based on a remedial alternative with a similar remedial
approach and a comparable volume of contaminated soil (March 1992 FS:
Alternative ID, residential scenario, total cost = $12,039,913; total volume =
34,761 yd3; unit cost = $346/yd3).
The total cost of remediation of soils and sediments for the proposed alternative, based on a
volume of 39,800 yd3 and a unit cost of 5346/yd3, is $13,770,800 (volume calculations are
discussed in Subsection 9.1).
(E) Industrial Sewer System: The estimated costs for Alternatives ISS1 and ISS2 are $4,165,000
and $6,190,000, respectively. The exact costs for Alternative ISS3 are not available at this time.
However, the costs are expected to be approximately those of Alternative ISS2. Based on a total
pipe length of 20,000 ft in Study Areas 6, 7, and 10, and a unit cost of $300/linear ft, a total
cost of $6,000,000 is estimated at this time until detailed cost estimates are completed.
8.3 Mndifying Pi-fr*rfa
ADEM/EPA Acceptance
EPA and ADEM have concurred with the choice of Alternatives 1G and ISS3.
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Community Acceptance
A public notification for the Area B Soils Operable Unit public meeting and public comment
period was advertised in four local newspapers. The public comment period began on 19
September 1994 and ended on 19 October 1994. Approximately 20 people attended a public
meeting which was held on 28 September 1994 at the Central Alabama Community College.
The major concern of the public involved recent occasions of particulate (dust) fallout from an
unidentified source. The public was informed that the transportable incinerator had completed
remediation of the Area A Soils Operable Unit on 22 August 1994 and, therefore, had not been
operational in the five-week period prior to the meeting.
9.0 SELECTED BlEMlcnY AND REM1TATfON GOALS
The complete remedy for the Area B Soils Operable Unit consists of Alternatives 1G and ISS3.
A brief description of these alternatives follows:
Alternative 1G: Tncrineration/S^hiliTation of Metals- ?ni^ ^•xolosives-Corftflm inat^j Soils and
SatHmmte
• Clear, survey, and grid areas; perform soil and sediment sampling and analysis
to delineate contamination by explosives (TNT, 1,3-dinitrobenzene, and tetryl)
and lead.
• For contaminated areas: excavate soils and sediments until excavation criteria are
satisfied; screen materials- transport materials to the transportable incineration
system (TIS-20) site in Area B; treat materials .by incineration and/or stabilization
until treatment and disposal criteria are satisfied.
• Decontaminate, oversize materials by crushing or shredding and treatment in the
TIS-20, or by high-pressure water washing and disposal in the backfill area.
• Expand the existing tm-site disposal arpa for final pfapemqnt of treated materials,
• Backfill excavated areas in Study Areas 6 and 7 and rough grade to pre-excavated
contours; backfill Study Area 21 to the elevation of surrounding banks of the Red
Water Ditch.
• Close the' disposal area in accordance with the existing approved permit
application for treated soils ("Treated Soils - Backfill Area Permit Application for
the Alabama Army Ammunition Plant Stockpile Soils Area Operable Unit",
March 1993).
• Treat contaminated process, sampling, and decontamination wastewaters in the
TIS-20 aqueous waste treatment system; reuse water for site dust control and
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process makeup.
• Conduct confirmatory soil and sediment sampling and analysis to ensure that
excavation criteria have been satisfied.
• Excavated materials that contain asbestos (tiles, fragments, etc.) will be separated
during feed preparation activities at the TTS-20 site. Details of the materials
handling procedures may be found in the Work Plan.
Alternative ISS3: Deactivation and Grouting of Concrete-Encased VCP: Excavation. Qn-site
Incineration, and On-Site Disposal of VCP
• Locate and survey the existing vitreous clay pipe (VCP) sewer lines and
manholes.
• Sample overlying soils to determine compliance with excavation criteria; excavate
to depth of sewer, visually inspect interior and exterior of sewer; remove gross
contamination; treat materials in TIS-20 or other approved methods and
procedures.
• Remove nonencased sewer lines and manholes; transport materials to TIS-20 site
for decontamination by high-pressure water washing or other approved methods;
dispose decontaminated materials in the backfill area.
• Sample and analyze soils around sewer lines and manholes for contamination;
excavate as necessary to achieve excavation criteria.
• Screen and transport contaminated soils and sediments to the TIS-20 site for
treatment by incineration and/or stabilization.
• Where sewer lines are encased in concrete: visually inspect interior, remove
gross contamination; treat materials in TIS-20 or by other approved methods and
procedures; water wash; grout/cement in place after decontamination. .
• Where lines are crushed or broken: visually inspect and remove gross
contamination; excavate oversize (>2 inches) materials; transport oversize
materials to TIS-20 and decontaminate for disposal in on-site backfill; blend
undersize materials with surrounding soils using approved methods; transport
materials to the TIS-20 for treatment by incineration and/or stabilization.
• Portions (10 percent) of decontaminated VCP will be tested to ensure adequate
decontamination. Although not expected, if adequate decoptami™tinn ratmnt ht>
demonstrated using Webster's Reagent (due to porosity of pipe), a portion of the
decontaminated pipe will be crushed and analyzed for parameters outlined in the
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excavation criteria. If Webster's Reagent is used, there is no numerical
quantifiable decontamination criterion. A change of color will indicate that TNT
is present at concentrations above 15 jtg/cm2.
• If decontamination criteria are exceeded, the piping will be decontaminated again,
tested, and disposed in the backfill area if criteria are satisfied. Decontaminated
piping that fails to meet the decontamination criteria after two water-washings
will be crushed, blended with contaminated soils, treated in the TIS-20 and
disposed in the on-site backfill area.
• Conduct confirmatory soil sampling around and below removed pipe to ensure
that excavation criteria are satisfied.
9.1 Basis for Selection
Alternative 1G was selected as the most appropriate remedial alternative for soils and sediments
in Study Areas 6, 7, and 21 because it best addresses explosives and metals (primarily lead)
contamination and provides the most effective overall protection to human health and the
environment. Incineration is the primary treatment method in Alternative 1G. Numerous other
treatment methods (such as composting, biodegradation, etc.) were evaluated in the technology
screening stage in the FS. During the technology screening stage, these technologies were
eliminated based on their applicability to site-specific circumstances such as effectiveness of the
treatment technology to COCs, availability, implementability, etc. A complete discussion of
screening of technologies is contained in the Draft Feasibility Study of March 1992.
A cost comparison was performed in the Draft FS for three types of incinerators. They are
transportable rotary kiln incineration, slagging rotary kiln incineration, and infrared incineration.
The analysis indicated that the cost of incineration using a rotary kiln unit is considerably less
than the other two technologies. Currently, Stockpile Soils at ALAAP are being treated on-site
by a rotary kiln incinerator (TIS-20) with a permit capacity of 21.26 tons/hour. The TIS-20 has
already processed over 31,000 tons of soils contaminated with explosives, lead and other metals.
Extensive stack sampling during mini-burns and the Performance Test has demonstrated that the
TIS-20 is capable of meeting the reference air concentrations (RACs) for lead and other metals
as defined by the Boiler and Industrial Furnace (BIF) regulations. The remediation of Study
Areas 6, 7, 10 and 21 is not expected to produce soils with metals concentrations higher than
previously demonstrated in the Performance Test. Since the soils and sediments in Study Areas
6, 7, and 21 contain the same waste characteristics as the Stockpile Soils, it is appropriate to use
rotary kiln incineration as the primary treatment method. In addition to rotary kiln incineration,
Stockpile Soils treatment also includes a soils stabilization process, prior to on-site disposal of
treated materials.
All of the active industrial sewer system alternatives meet the evaluation criteria to reduce
toxicity, mobility, or volume. However, alternative ISS1 would result in some degree of
uncontrolled emissions which would potentially expose site workers. Alternatives ISS2 and ISS3
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are similar, since both alternatives require excavation and decontamination. Alternative ISS3
does not eliminate the possibility of on-site incineration, but it does allow the option of reducing
potential cleanup costs if high-pressure water washing meets the decontamination criteria.
The volumes of contaminated soils and sediments for Alternative 1G for Study Areas 6, 7, and
21 based on the Draft Feasibility Study of March 1992 are presented in Table 4. These volumes
are stated herein only as a guideline, and are expected to be less than originally-estimated for
the following reasons:
• The volumes of contaminated soils and sediments shown in Table 4 are health-
based risk cleanup goals derived in the Baseline Risk Assessment, conducted as
part of the Draft FS of March 1992. The Baseline Risk Assessment was revised
in August 1992 (after submission of the Draft FS) with higher cleanup goals, as
shown in Table 3. These higher goals will be used in the remediation of Area
B Soils Operable Unit. The revised volumes based on these later cleanup goals
are not available.
• When the volumes were calculated in the Draft FS of March 1992, the media
sampling upon which they were based was conducted only within a relatively
small portion of each study area of concern (Study Area 6, 7, 10, and 21), and
may not be representative of each entire area.
• The U.S. Army has elected to conduct an extensive sampling program to
delineate the extent of contamination in each study area prior to remediation.
Actual excavated volumes will be based on the results of the delineation sampling
and analysis program and may change significantly from those estimated from
earlier, more limited data.
Therefore, no effort will be made at this time to recalculate new volumes based on the August
1992 Baseline Risk Assessment.
9.2 Remediation Goats
The selected alternative will meet the following remediation goals:
Excavation Cleanup Goals
The excavation cleanup goals for explosives- and lead-contaminated soils and sediments are:
Criteria (m)
TNT 647
1,3-DNB* 1
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Table 4
Contaminated Soil and Sediment Volumes for Alternative 1G
Study
Area
6
7
21
Contammaiitfc)
TNT
Lead
TNT
1,3,5-TNB
Lead; 1,3-DNB; TNT
1,3-DNB; TNT
TNT
Scenario
Residential
(yd3)
16,600
16
18,148
13
10,225
Industrial
(yd3)
16,600
12
12,963
10,225
Caretaker
(yd3)
13,333
12
12,963
10,225
Source: Supplemental Remedial Investigation/Feasibility Study for Area B,
Alabama Army Ammunition Plant, Draft Feasibility Study, March 1992.
Note: The above volumes are based on the initial ICLs derived during the Baseline Risk
Assessment conducted in the March 1992 FS. The proposed remedial action will be
based on higher ICLs (Table 3) established hi the revised Baseline Risk Assessment of
August 1992. Because of the higher cleanup levels, die actual volume of contaminated
material is expected to be lower than shown hi Table 4. The ICLs for Industrial
Scenarios for both Baseline Risk Assessments are as follows:
ICLs based on March 1992 ICLs based on August 1992
Baseline Risk Assessment and Baseline Risk Assessment and
EPA Guidance for lead EPA Guidance for lead
(Table 3 volumes are based (Proposed Remedial Action
on these ICLs) is based on these ICLs)
Contaminant
TNT
1,3-DNB
Tetryl
Lead
64.1 ppm
0.5 ppm
1,290 ppm
500 ppm
647 ppm
0.5 ppm
5,000 ppm
500 ppm
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Parameter Excavation/Cleanup
Criteria (ppm)
Tetryl 5,000
Lead (total) 500
Source: Supplemental Remedial Investigation/Feasibility Study (RI/FS) for Area B, Alabama
Army Ammunition Plant (AAAP), Baseline Risk Assessment, August 1992.
* Note that the Baseline Risk Assessment dated August 1992 included excavation
criterion for 1,3-DNB of 0.5 ppm. The Chemical Data Acquisition Plan (CDAP) for
the Stockpile Soils Area Operable Unit outlines the quantitation limits for metals and
explosives. Table. 8-2 of the CDAP indicates that the quantitation limit for 1,3-DNB
is 1 ppm. Review of Table 6.2-2 of the Baseline Risk Assessment of August 1992
indicates that the ICL for 1,3-DNB was based on the analytical detection limit. There
is a concern that due to potential analytical interferences, the lower limits specified in
the RI/FS may not be consistently achievable. As such, the excavation criterion for
1,3-DNB is set at 1 ppm.
Water Treatment Criteria
The treatment criteria for wastewaters generated during remediation activities are:
Parameter Treatment Criteria
Flow < 50 gpm
Temperature < 90°F (April - November)
< 60°F (December - March)
Explosives
TNT < 6.9 /tg/L
1,3,5-TNB < 7.3 /*g/L
2,4-DNT < 5.7 /*g/L
Metals
Arsenic < 5 mg/L
Barium < 100 mg/L
Cadtttiuro < 1 mg/L
Chromium < 5 mg/L
Lead < 5 mg/L
Mercury < 0.2 mg/L
Selenium < 1 mg/L
Silver < 5 mg/L
Total Organic Carbon (TOC) < 50 mg/L
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Parameter Treatment Criteria
Total Suspended Solids (TSS) < 50 mg/L
Total Dissolved Solids (TDS) < 1000 mg/L
pH 6-10
Source: Chemical Data Acquisition Plan (CDAP) for a Transportable Incineration System
(US) at the Alabama Army Ammunition Plant (AAAP) Stockpile Soils Area
Operable Unit, Revision No. 5, 25 May 1994.
As in the case of the prior remediation of the Stockpile Soils Area Operable Unit, the rotary kiln
incineration system is a net water consumer. Treated water is only used for process makeup
water and site dust control. There is normally no surface water discharge.
Incineration/Backfill Criteria for Treated Soil from Incinerator
Treated soil from the incinerator will be stored until analytical results indicate that the ash
satisfies the following treatment criteria for backfill:
Parameter Incineration/Backfill
Criteria
TNT (Total) 1 ppm
Arsenic (TCLP) 5 mg/L
Barium (TCLP) 100 mg/L
Cadmium (TCLP) 1 mg/L
Chromium (TCLP) 5 mg/L
Lead (TCLP) 5 mg/L
Mercury (TCLP) 0.2 mg/L (4/xg/g using total metals analytical method)
Silver (TCLP) 5 mg/L
Selenium (TCLP) 1 mg/L
Source: Work Plan for a Transportable Incineration System (TIS) at the Alabama Army
Ammunition Plant (AAAP) Stockpile Soils Area Operable Unit, February 1994.
Treated material failing to meet the TCLP backfill criteria will be stabilized before disposal.
Treated material failing to meet TNT incineration criteria will be reprocessed.
Stabilisation/Backfill Criteria for Stabilized Material
The backfill criteria for stabilized material that is not incinerated will be the excavation cleanup
criteria for explosives and the TCLP criteria for metals, as follows:
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Parameter Stabilization/Backfill
Criteria
Explosives
TNT (Total) 647 ppm
1,3-DNB" (Total) 1 ppm
Tetryl (Total) 5,000 ppm
Metals
Arsenic (TCLP) 5 mg/L
Barium (TCLP) 100 mg/L
Cadmium (TCLP) 1 mg/L
Chromium (TCLP) 5 mg/L
Lead (TCLP) 5 mg/L
Mercury (TCLP) 0.2 mg/L (4 /xg/g using total metals analytical
method)
Silver (TCLP) 5 mg/L
Selenium (TCLP) 1 mg/L
Sources: (/1J Backfill criteria for explosives: Supplemental Remedial Investigation/Feasibility
Study (RI/FS) for Area B, Alabama Army Ammunition Plant (AAAP), Baseline Risk
Assessment, August 1992.
(B) Backfill criteria for metals: Work Plan for a Transportable Incineration System
(TTS) at the Alabama Army Ammunition Plant (AAAP) Stockpile Soils Area Operable
Unit, February 1994.
* Note that the Baseline Risk Assessment dated August 1992 included excavation
criterion for 1,3-DNB of 0.5 ppm. The Chemical Data Acquisition Plan (CDAP) for
the Stockpile Soils Area Operable Unit outlines the quantitation limits for metals and
explosives. Table 8-2 of the CDAP indicates that the quantitation limit for 1,3-DNB
is 1 ppm. Review of Table 6.2-2 of the Baseline Risk Assessment of August 1992
indicates that the ICL for 1,3-DNB was based on the analytical detection limit. There
is a concern that due to potential analytical interferences, the lower limits specified in
the RI/FS may not be consistently achievable. As such, the excavation criterion for
1,3-DNB is set at 1 ppm.
Decontamination Criteria
Portions (10 percent) of decontaminated VCP will be tested to ensure adequate decontamination.
Although not expected, if adequate decontamination cannot be demonstrated using Webster's
Reagent (due to porosity of pipe), a portion of the decontaminated pipe will be crushed and
analyzed for parameters outlined in the excavation criteria. If Webster's Reagent is used, there
is no numerical quantifiable decontamination criterion. A change of color will indicate that TNT
is present at concentrations above 15 /ig/cm2.
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If decontamination criteria are exceeded, the piping will be decontaminated again, tested, and
disposed in the backfill area if criteria are satisfied. Decontaminated piping that fails to meet
the decontamination criteria after two water-washings will be crushed, blended with
contaminated soils, treated in the HS-20 and disposed in the on-site backfill area.
10.0 STATUTORY DETERMINATIONS
The selected remedy (Alternatives 1G and ISS3) satisfies the requirements under Section 121 of
CERCLA to:
• Protect human health and the environment.
• 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 permanent treatment
and disposal of treated material.
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 dust,
lead, TNT, tetryl and asbestos fibers potentially generated during material handling activities.
In addition, workers will be provided with personal protection equipment during all phases of
remediation activities. Both area and personnel air sampling programs will be established to
monitor ambient and worker exposures and ensure adequate protection. Deactivation of encased
VCP (or removal of potentially energetic materials for incineration) will be performed by
qualified personnel with proper safety precautions. Although not expected, if necessary for
reasons of safety, personnel will be evacuated from the immediate vicinity prior to deactivation
activities.
Long-term protection to human health and the environment will be provided by minimising
residual risk from the contaminants and by reducing or eliminating impacts on the environment.
Controls employed in this alternative are adequate and reliable. The air pollution control system
of the incinerator (currently operating on-site) successfully passed its Performance Test in June
1994 and yielded stack emissions in accordance with regulatory limits, protecting workers and
the community from risks associated with inhalation. There are no unacceptable short-term or
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long-term impacts on human health or the environment in this alternative.
The selected alternatives (1G and ISS7) comply with all ARARs. All the COCs in soils of Study
Areas 6, 7, 10 and 21 within the Area B Soil OU (i.e., explosives and lead) are expected to
meet required regulatory treatment/disposal standards prior to disposal.
No federal or state chemical-specific ARARs prevent implementation of the selected alternatives.
Soils will be remediated based on health-based cleanup levels determined to be protective to
human health and the environment. Lead-contaminated soils will be remediated to achieve the
health-based soil lead concentration of <500 mg/kg (based on blood-lead uptake levels in
children). Soils contaminated with TNT will be remediated to achieve the health-based soil TNT
concentration of < 647 mg/kg (based on the resultant risk for adult residents and the contributing
hazard index (HI) due to exposure concentration for child residents).
No location-specific ARARs prevent the use of the selected alternative. All activities associated
with implementation of this alternative will be conducted away from sensitive environments (i.e.,
river or 100-year floodplain).
The following action-specific ARARs will be met with implementation of this alternative:
• Incinerator ash will be routinely tested for destruction of explosives, as required by
RCRA (40 CFR Part 264; Standards for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities) and the State of Alabama (Alabama
Administrative Code Chapter 335-14-5.15(4)(a)l: Performance Standards for
Incinerators).
• TCLP extract analysis on incinerator ash will be performed to ensure that metals
concentrations meet RCRA guidelines for arsenic, barium, cadmium, chromium, lead,
mercury, selenium, and silver (40 CFR Part 264; Standards for Owners and Operators
of Hazardous Waste Treatment, Storage, and Disposal Facilities). Incinerator ash that
does not pass TCLP will be solidified/stabilized prior to disposal.
• Incinerator ash and solidified/stabilized material (if required) will be disposed on-site in
Area B in accordance with RCRA (40 CFR Part 264; Standards for Owners and
Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities) and the State
of Alabama (Code of Alabama, Title 22, Chapter 27; Alabama Solid Waste Act and
Alabama Administrative Code Chapters 13-1 through 13-7; Alabama Solid Waste
Management Regulations).
• Workers will be provided with personal protection equipment during all phases of the
selected remedy, hi compliance with the Occupational Safety and Health Act (OSHA) (29
USC ss. 651-678). Adequate protection will be provided to the community by reducing
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risks posed by air emissions from the thermal treatment unit and reducing dust potentially
generated during material excavation and handling activities.
• Portions (10 percent) of decontaminated VCP will be tested to ensure adequate
decontamination (< 15 /ig/cm3). Decontaminated debris will be disposed of on-site in
Area B in accordance with State of Alabama regulation (Code of Alabama, Title 22,
Chapter 27: Alabama Solid Waste Act and Alabama Administrative Code Chapters 13-1
through 13-7: Alabama Solid Waste Management Regulations).
103 Cost-Effectiveness
Based on a cost comparison study conducted during the Draft FS of March 1992, transportable
rotary kiln incineration was determined to provide overall effectiveness proportionate to its costs,
compared to other types of incinerators. This alternative takes advantage of the special
equipment, operators, site preparation, thermal treatment system, and regulatory approvals
already in place for the treatment of the Area B soils.
10.4 Tftilraartjon of Permanent So)"tfons and Alternative Treatment TWhtmiogjes or
Resource Recovery Technologies to the Maximum Ffoteut Practicable
The selected remedy (Alternatives 1G and ISS3) 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 ^ffectivenejfs and Permanence: The selected remedy employs
destruction of explosives-contaminated materials and stabilization of lead-
contaminated materials. All treated materials will be disposed on-site by
expanding the existing disposal area.
• Short-Term Effectiveness: The selected remedy does not involve off-site
transportation of contaminated soils, thereby eliminating the risks due to Spillage
and fugitive emissions. The community, workers, and the environment will be
protected during remedial actions by implementing appropriate protective
measures.
• Tmp|emfentabnity: No waiting period is involved for implementation of the
selected remedy. An incinerator and a stabilization plant are currently approved
by the regulatory agencies and are operating on-site treating soils of the Stockpile
Soils Area Operable Unit which have similar characteristics as the contaminated
soils and sediments in the Area B Soils Operable Unit.
• Cost: Transportable rotary kiln incineration is considerably less costly than other
types of incineration. . Since an incinerator is currently on-site, treating soils with
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10.5
similar characteristics, costs for activities such as regulatory approvals,
mobilization/demobilization, etc. will be minimal for incineration of soils and
sediments.
>s a Principal Element
The selected interim action utilizes treatment for the contaminated soils and sediments in Study
Areas 6, 7, and 21, and the Industrial Sewer System (ISS) in Study Areas 6, 7, and 10 within
the Area B Soils Operable Unit. Any additional required actions for Study Areas 6, 7, 10, and
21 will be addressed in the final Decision Document for the Soils of the Area B Soils Operable
Unit.
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RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
1.0 OVERVIEW
The public reaction to the selected remedy is mainly acceptance. The major concern of the
public involved recent occasions of paniculate (dust) fallout from an unidentified source. All
of the public comments have been addressed, and the public appears to have no substantive
concerns regarding implementation of the selected remedy. Continued community relations
activities will be held to maintain public awareness of the status of remedial activities at
ALAAP.
2.0 BACKGROUND ON COMMUNITY INVOLVEMENT
General community interest in the ALAAP site has historically not been great. Since the site
was declared excess to Army needs in 1973, interest has generally come from private groups or
industry interested in developing portions of the site. The southern part of the site (i.e., the
former nitrocellulose manufacturing area) was sold to the Kimberly Clark Corporation in the late
1970s, and a paper products plant was constructed. In the mid-1980s, in response to interest
in purchasing the eastern part of ALAAP (Area A), this section was remediated by the Army
and the contaminated soil was stockpiled in the western part of ALAAP (Area B), creating the
Stockpile Soils Area Operable Unit (OU). A ROD for treatment (i.e., incineration followed by
solidification/stabilization, if required) of the Stockpile Soils Area OU has been signed and
implemented.
Post-excavation sampling was performed to verify the remediation efforts within Area A and two
sites (Study Areas 12 and D) were subsequently identified as containing contamination above
acceptable levels. A final ROD for treatment (i.e., excavation followed by stabilization) of the
Area A OU was issued in April 1994, and has been subsequently implemented.
A supplemental RI/FS for Area B, prepared in March 1992, identified tetryl, lead and TNT
contamination in the old m^nnfartiiring areas. A draft final ROD for treatment of the Area B
Soils OU (for Study Areas 6, 7, 10 and 21) was issued in August 1994. Notice of the public
comment period and meeting for the Area B Soil OU was placed in four local newspapers on
September 19, 1994. A 30-day public comment period extended until October 19, 1994. A
public meeting was held on September 28, 1994 at the Central Alabama Community College,
located about 5 miles from the ALAAP site. Two written public comments were received, and
are attached at the end of mis Responsiveness Summary
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3.0 SUMMARY OF PUBLIC COMMENT AND AGENCY HF.SPONST1
3.1 Continents from Public Meeting
At the public meeting held September 28, 1994, the public was given the opportunity to
comment and ask questions about the selected remedy (Alternatives 1G and ISS3). The
following is a summary of the questions/comments raised by the public and
Army/regulator/contractor responses given at the meeting, including supplemental answers
(where applicable):
Ql. Aren't they already burning the soil out here? Aren't they already in the process of
decontaminating?
Answer at meeting; (USAEC) Yes.
Supplemental: WESTON has successfully treated approximately 21,000 yd3 of
explosives- and metals-contaminated soils from Area A. Soils which failed to meet the
TCLP criteria for metals are currently being stahiiirarf before being placed in the backfill
area. All equipment and those areas not necessary to support the stabilization activities
have been decontaminated.
Q2. Is this the first public meeting?
Answer at meeting; (Army) We had a public meeting over a year ago. And we're
getting better at notifying the community on mail-outs and similar kinds of things to give
them more of a chance to know what's going on.
Answer at meeting: (USAGE) It's going to be an on-going process. This is just one
phase of the cleanup out there. So you would get input into a continuing process in the
cleanup of the site.
Q3. Exactly what kind of material are you going to be burning?
Answer at meeting: (WESTON) The Alabama Army Ammunition Plant, during the
second World War and shortly thereafter, manufactured tetryl and TNT, along with other
chemicals on this particular site. The chemicals of concern (COCs) in terms of their
exposure to the human environment and to wildlife, are TNT and tetryl (which are
explosive compounds) and lead (which is a heavy metal).
Areas 6 and 7 are the TNT manufacturing areas, and Area 10 is the tetryl manufacturing
area. The Red Water Ditch (Study Area 21) was the major drainage for wastewaters to
go off of the site. The industrial sewer system (ISS) from the various production areas
emptied into the Red Water Ditch.
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Where there is a hit or a compound that's detected at or above the excavation level, the
cleanup level, the soil will be excavated and transported to the incinerator for thermal
treatment.
Q4. Could you explain, without a lot of detail, maybe a little bit about a Restoration Advisory
Board (RAB) - what their function would be and what the end result is going to wind
up being?
Answer at meeting: (USAEC) Well, among other things, they review the technical
documents with respect to cleanup; they look at things lite the Interim Record of
Decision that's on the table in the back of the room; keep up with the progress of
cleanup actions. You have an opportunity to make comments here in a public forum, but
members of the Board will have the opportunity to make their comments early on to the
decision makers. They will also be able to report back on what they have learned to
members of the community.
Q5. Aren't we getting into this late?
Answer at meeting: (USAEC) It's something that the Army has issued a policy on, and
its starting now. It's a little bit late, but better late than never. . . .If we get enough people
saying yes, we want to have a Restoration Advisory Board, then we move in that
direction at that time.
Q6. Would one of thekfcKmses also be to assure the completeness of the remediaticra project?
Answer at meeting: (Army) Absolutely. You would get to see the evolution of the
project as it progresses.
Q7. Are you monitoring what comes out of the smoke stack?
Answer at meeting: (USAEC) Yes.
Answer at meeting: (Army) Absolutely.
Answer at meeting: (ADEM) Before the State of Aiahania permitted the start-up of this
incinerator, we put on very, very tough restrictions. And there has been no
malfunctions, or intermittent emissions from the plant.
Q8. Is there any kind of fallout?
Answer at meeting: (Army) No.
Q9. Is it in transparent form or other forms? What's happening when you burn it?
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Answer at meeting: (Army) We destroy its properties. We destroy its ability to hurt the
environment. We're making it sterile. We're making it harmless.
Q10. Are there any particulates being emitted from the burning process?
Answer at meeting: (USAGE) There are some. It'swell within the established EPA and
ADEM criteria. In fact, it's about tenfold less.
Answer at meeting: (USEPA) EPA standards on paniculate emissions are very strict.
We ran the incinerator through an exhaustive series of trial tests without hazardous waste
hi it to measure what paniculate output would be.
Qll. What would be the makeup of the particulates that are emitted?
Answer at meeting: (USAGE) Carbon dioxide (CO^, ...
Supplemental: Water vapor, oxygen, acceptable levels of trace metals.
Q12. I live in the northeastern pan of Childersburg, and there appears to be fallout that seems
like coagulated mud. It's happened within the last two or three months. I've tried, as
have some of my neighbors, to get someone to come and take a look at what might be
tailing. The State of Alabama came out three weeks ago, but I've gotten no report. It
may be nothing harmful, I don't know. I have some samples that I have taken, and I
would like someone to look at them and see what they might be.
Answer at meeting: (USAGE) The incinerator hasn't been on for over six weeks. It's
been in a cold status for six weeks. And when it ran, we continuously monitored the
stack, phis there were monitoring stations put around the perimeter of operations to
ensure no particulates were emitted.
Answer at meeting' (ADEM) Who was the gentleman that came out to look? Response:
Carl Ferraro. Answer. I have to apologize for the Department of Environmental
Management. I assure you that I will get something started tomorrow, and I'll have a
report back to you at the end of the week to let you know what we're doing.
Supplemental: (ADEM) The sample supplied to ADEM was analyzed and determined
to be mostly quartz (45-97%) and organic matter (2-54%) from an unknown source. A
letter addressed to the concerned citizen was issued October 6, 1994 reporting the test
results, which has been attached at the end of the Responsiveness Summary.
Q13. Couldn't that stuff be ion particles in the atmosphere, gather enough moisture to
coagulate, then form larger panicles?
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Answer at meeting: (ADEM) It is possible. But because of the requirements and the
regulations that we put on this incinerator since it was classified as a hazardous waste,
I would just about guarantee that it's not coming from our incinerator, simply because
of the multiple devices that the emission goes through before it goes to the atmosphere.
^t's very stringent.
Q14. When was the last date your incinerator operated?
Answer at meeting: (USAGE) 22 August 1994.
Q1S. I wonder if you can tell us if five years from now that the incinerator wasn't hazardous
to our health?
Answer at meeting: (ADEM) From a toxicological point of view, we've had a health
assessment run on this plant. We've done health and ecological risk assessments. And,
to our knowledge, our restoration will eliminate any risk at that site. That's all we can
say today.
Q16. In the last days of World War n, I heard there was a project at ALAAP called Heavy
Water which was the atom bomb. Are there any of those contaminants that are
radioactive or anything from those experiments?
Answer at meeting: (Army) He's talking about the Manhattan project area.
Answer at meeting: (USAEC) We've done numerous studies on where the Manhattan
project took place and where the Heavy Water was produced. We have not found
anything that would lead us to believe that there's anything of a radioactive nature or
contaminating matter on the installation.
Answer at meeting: (Army) There was very limited Heavy Water at this facility. I think
they produced about 1,300 gallons of water. DOE (Department of Energy), which
operated that portion of the project, does not have a lot of information about what went
on at that time. And most of the structures have been taken away. In future studies, we
will be putting more monitoring wells around that area to see if there is any impact.
Answer at meeting: (USAGE) That area has been evaluated since 1973. People have
been out, trees have been dug up, samples have been taken, monitoring has been done.
Nothing's ever been found.
Q17. In the history of the plant, can you tell me how many fish, foul, animal, or humans have
been harmed by this contamination?
Answer at meeting: (USAEC) I can't
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Answer at meeting: (WESTON) I cannot answer that question.
Q18. Do you have a record of anybody or anything?
Answer at meeting! (USAEC) No, sir. Unless it's been in an explosive manner where
some igloo blew up, I don't think so.
Q19. If not, why are we cleaning up this contamination after 45 or SO years?
Answer at meeting; (Army) That's been man^t^ by the political leadership. Their
direction to us - it's certainly not an Army decision. It's mandated from a political
structure that says to restore this property to the public domain for the use of the
community. I mean, we couldn't say we want to put a fence around it and leave it for
100 years. That's not even our decision - that's political leadership.
Q20. Do you have an estimate of the total cost of the decontamination of Study Areas 6, 7,
10 and 21?
Answer qt meeting* (USAEC) We do have a rough estimate. . . But we really haven't got
a firm estimate yet on it.
Answer at meeting: (Army) Believe me, we would like to spend as little as possible,
because the mandated money we have to spend comes from outside our control. We
would love to spend less, but we have a standard we have to meet for cleanup.
Answer at meeting: (USAGE) Give you a ball park, three to ten million.
Q21. How many acres are involved?
Answer at meeting: (WESTON) Approximately 160 acres for areas 6, 7, 10 and 21.
Q22. Is this similar like Gadsden is doing right now?
Answer at meeting: (WESTON) No. There are no chemical agents at this particular
site.
Q23. Are there any trucks coming in and out of that plant?
Answer af meeting- (WESTON) No, sir. Everything is contained within the plant
When we shut down, let's say at the end of a normal eight or a ten-hour day, those
trucks stay in that particular area. They do not go over the road until they've been
decontaminated, and that won't happen unless the truck breaks down and we've got to
take it off-site or if we're demobilizing. All of our equipment is contained within the
ALAAP boundary limits.
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Q24. Do you know how long it's going to take to clean it up?
Answer at meeting: (WESTON) If we go with the estimates that we have right now,
we're probably talking hi the area of about a year to a year and a half,
Q24. What's done with the material after it's burned?
Answer at meeting: (WESTON) It's disposed in the backfill areas on-site. It is basically
clean soil. Again the contaminants of concern are either tetryl or TNT. Both of these
are in relatively low concentrations, but they are combustible materials. So when the soil
goes through an incinerator that has a temperature of 1800°F, phis or minus, those things
are completely combusted. And what comes out at the tail end is basically a sanitized
disinfected soil.
Q2S. Does that destroy the lead too?
Answer at meeting: (WESTON) The lead stays with the soil. And if it passes the tests
as far as the treatment criteria goes, it goes into the backfill. If it does not pass that
treatment criteria, it gets stabilized. And that basically means it gets mixed with a
cement or a lime-kiln type of material to make it into a solidified mass.
Q26. I was wondering that if you have to send this soil to another lab to be sure that it's clear
of everything and that it's okay, how can we be sure mat your equipment and incinerator
is doing its job as it's supposed to? And how can we be sure our air is not contaminated
if you've got to send this soil to another lab to really be sure that it's clean?
Answer at meeting: (USAGE) The first test is at the site; the second test is by an
independent off-site laboratory. But there's a third test, which is 10% of all samples I
send to the Missouri River Division, my laboratory, to run tests. And they correlate data
against his data here from his laboratory and his data out in the field.
Q27. But we just have one check on the stuff that comes out of the smokestack?
Answer at meeting: (WESTON) No. We do periodic tests on that incinerator. There
is an on-line instrument that is calibrated every single day. And those calibration records
are a part of what I must submit on a weekly basis to the Corps of Engineers.
In addition to that, I didn't mention there are two independent combustion emission
monitoring systems (CEMS). They are totally independent. One backs up the other.
They both operate 24-hours a day, so if there is a malfunction in one, the other one picks
up the slack until the first one is brought back on-line.
Also, there are about 24 automatic waste feed cut-offs. If our temperature in the
incinerator gets too low, if our residence time gets too low, ... the incinerator shuts off.
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Q28. Don't you also have ambient air monitoring equipment?
Answer at meeting: (WESTON) We have ambient air monitoring, that is correct, around
the perimeter of the site, in addition to the meteorological station.
Q29. Could you add one more piece of paper to that stack of paperwork you produce, that is
to visit a person who has a complaint, who thinks that you may be at fault?
Answer at meeting: (WESTON) You are welcome to come out to the incinerator at any
time, with advance notice to our site manager Mr. Barry Wright... If you call up and just
tell us you want to be out there a half hour from now or whatever to have a tour of the
site — now, there's certain areas that we can show you, but certain areas we can't
because they are handling contaminated material. But from the outside of the fence, it's
visually very easy to see what's going on. We're not biding anything. The number at
the plant is (205)378-3924.
Q30. Have y'all already got buyers for the property?
Answer at meeting: (USAGE) The property has not yet been put up for sale. It won't
until we get it cleaned up.
3.2 Responses to Written Comments
LI. Letter No. 1: Dated September 29, 1994 from Ms. Laura Payne.
• Comment -1 would Tike information on groundwater contamination at ALAAP.
Response - The current Area B Interim ROD does not address groundwater
mnta.Tnina.tion which may be present at this facility. Any information which has
been published regarding site investigations (including groundwater
contamination) at the ALAAP may be found at:
Earle A. Rainwater Memorial Library
12 9th Avenue, SW
Childersburg, AL 35044
or at the Holston Army Ammunition Plant located in Kingsport, TN. Ongoing
and future investigations by the U.S. Army, as outlined in its Site Management
Plan for ALAAP, will determine a final course of action for groundwater
contamination at the facility.
• Comment - Is there any way that the public could be supplied with someone who
could interpret the information provided?
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Response - The Army has designated Ms. Catherine Stalcup as the public affairs
official for ALAAP. She can be reached at the following address:
U.S. Army Environmental Center
Attention: SHM-AEC-PA (Ms. Catherine Stalcup)
Building E4461-T
Aberdeen Proving Ground, Maryland 21010-5401
(410) 671-1268
L2. A letter dated 22 September 1994 was received from Ms. Laura Olah, President of
Citizens for Safe Water Around Badger (CSWAB). Major issues and responses are as
follows:
• Comment - Alternative 1G (on-site incineration) does not reduce the toxicity,
mobility or volume of inorganics (such as lead).
Response - Alternative 1G includes incineration and stabilization of metals- and
explosives-contaminated soils and sediments.
Treated materials will be tested to ensure compliance with the treatment criteria
for TNT and the toxicity characteristic leachate procedure (TCLP) for metals.
If required, stabilization will be conducted prior to backfill to "encapsulate" or
"contain" the inorganics (specifically metals). As stated in the Feasibility Study,
the mobility and toxicity of metals in soils and sediments would be reduced by
solidification/stabilization; however, the volume of contaminated soils/sediments
would not be reduced. Solidification would increase the volume by approximately
20 to 30 percent since reagents are added to the soils/sediments. Stabilization is
expected to reduce the mobility and toxicity of metals-contaminated soils and
sediments by preventing the leaching of metals from the final product and by
effectively bonding the contaminants to the reagents in a staMi*T^ material.
• Comment - Incineration disperses inorganic contaminants to air, water, soil and
incinerator ash. Incinerators are not safe. The direct risks of incinerator
pollutants on human health are based on the probability of exposure to levels of
toxic compounds sufficient to cause disease. Incinerators produce air, water and
soil toxics through stack emissions or fugitive emissions. The uptake of these
toxins into plants and animals and their biomagnification through the food web
present the greatest risk to people—either through absorption, inhalation or
ingestion.
• Response - Stringent stack testing was conducted on the incineration system
during previous remediation activities at ALAAP. Three "mini-bums" were
conducted to ensure proper operation of me air pollution equipment. Emissions
testing was conducted while the incineration system processed uncontaminated and
59
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contaminated materials. Following demonstration of proper operation, a
Performance Test was conducted on contaminated soils spiked with maximum
metals content. Emission testing was conducted to determine the concentrations
of metals and chlorine in discharge gases and to determine the removal
efficiencies of the air pollution control equipment. Metals and chlorine stack
emissions were compared to values provided in the EPA's document entitled
"Technical Implementation Document for EPA's Boiler and Industrial Furnace
Regulations" dated March 1992. Emissions of all metals (antimony, barium,
lead, mercury, silver, thallium, nickel, selenium, arsenic, cadmium, chromium,
and beryllium) and chlorine satisfied the limits imposed by a Tier in risk-based
analysis. Operation of the incineration system requires that maximum metals
loading does not exceed the values demonstrated during the Performance Test.
To verify that the metals loading does not exceed the demonstrated maximum
metals loading, samples are taken daily from each feed soil stockpile and analyzed
prior to processing.
An ambient air monitoring program will be conducted during excavation,
screening, blending, and feed preparation activities to ensure that ambient
concentrations of respiiable dust, TNT, tetryl and lead are below site-specific
action levels. Ambient air monitoring results conducted during previous activities
at the ALAAP site indicated that no harmful concentrations of dust, TNT,
asbestos or lead were present in the on-site work areas or have migrated from the
site.
The remediation program is proposed to remove the high concentrations of
contaminants currently in the food web and significantly reduce then* mobility and
toxicity.
Comment - The major pollutants associated with incineration include acids,
metals, nitrogen oxides, carbon monoxide, ozone, dioxin, volatile organic
compounds (VOCs) and partially incinerated compounds (PICs). The production
of nitric acid cannot be prevented. Most toxic metals that axe present in the
waste stream are likely to remain in the combustion ash, but some likely (mercury
and chromium) axe known to exit stacks despite air pollution control equipment.
Response - The compounds potentially present in trace amounts in stack gases are
directly dependent on the contaminants in the feed material. The major
contaminants of concern for the subject Operable Unit include nitroaromatic
compounds (specifically, TNT, tetryl and 1,3-DNB) and lead.
During the Performance Test previously conducted at ALAAP for metals- and
explosives-contaminated soils, stack testing was conducted for carbon dioxide,
oxygen, particulate, hydrochloric acid, chlorine, explosives, metals, and
hexavalent chromium. Carbon monoxide, total hydrocarbons and nitrogen oxides
were also monitored by the' continuous emissions monitoring (CEM) system.
60
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Stack testing results indicated that emissions are well within acceptable Federal
and state criteria.
The CEM system continuously monitors stack gases for carbon monoxide,
oxygen, carbon dioxide, nitrous oxides and total hydrocarbons to ensure the
incineration system is operating properly at all times.
Additionally, EPA and ADEM require that the incinerator operate within stringent
criteria. The control system is provided with an automatic waste feed cutoff
(AWFCO) system which will shut down feed to the incinerator should operating
conditions exceed allowable conditions.
Regarding formation of dioxin and furan, the Federal Register dated 21 February
1991 indicated that the Agency believes that the operating temperatures of the
paniculate control device (baghouse) and hydrocarbon concentrations in the flue
gas play a significant role in dioxin/furan emissions. For a given hydrocarbon
concentration in the flue gas, the available data suggest that the potential for
elevated dioxin/furan emissions is low if the paniculate matter control device
operates at temperatures of less than 450°F or above 750°F. The Federal
Register indicates that units with particulate matter control devices operating at
temperatures outside of the 450-750 °F window are not required to determine
dioxin/furan emission rates unless hydrocarbon levels are greater than 20 ppm by
volume (page 7163). The temperature of inlet gases to the baghouse on the
incineration system operates below 449 °F. The AWFCO system is activated if
the temperature exceeds 449° F. The CEM system continuously monitors stack
gases for total hydrocarbons. Furthermore, during the Performance Test, the
concentration of total hydrocarbons ranged from 0.05 to 0.07 ppm by volume,
well below the upper limit of 20 ppm.
The Federal Register also indicates that an upper limit for carbon monoxide
emissions of 100 ppm by volume (on an hourly rolling average) in the flue gas
represents steady-state high efficiency combustion conditions resulting in PIC
emissions that would not pose a significant risk (page 7150). The CEM system
continuously monitors stack gases for carbon monoxide. During operations, if
the carbon monoxide concentration exceeds 100 ppm (on an hourly rolling
average), the AWFCO system is activated. During the Performance Test, caibon
monoxide concentrations ranged from 0.37 to 0.44 ppm by volume (corrected to
7 percent oxygen), well below the limit of 100 ppm.
Comment - Alternative technologies implemented at other federal facilities have,
according to the U.S. Army, successfully remediated explosives-contaminated
soils (e.g., bioremediation, composting). Soil washing has been utilized for the
treatment of metals-contaminated soils. Alternative, applicable technologies have
not been sufficiently researched nor characterized.
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Response - Alternative technologies have been researched and characterized. The
Feasibility Study for Area B evaluated a number of technologies to determine
their applicability as a source control measure for contaminants of concern.
Technologies included: physical, chemical, biological, thermal, irradiation,
diversion, containment, removal and disposal. During the screening process,
technologies were retained or eliminated based on waste characteristics, site
characteristics, the degree of technology development, performance record, and
inherent construction, operation, and maintenance problems. Technologies that
survived the screening were further evaluated for threshold criteria (overall
protection of human health and the environment and compliance with ARARs)
Technologies that met threshold criteria were further screened for effectiveness,
implementability, and cost to reduce the number of alternatives for further
analysis while preserving a range of options. Detailed analyses were conducted
on the remaining alternatives. The selected alternatives (1G and 1SS3) represent
the optimum remedial activities for the Study Areas.
Comment - Precautions should be taken during excavation procedures to reduce
and monitor fugitive dust which may pose significant health and environmental
risk (e.g. , application of lime, covering of transport trucks, wetting of roads and
disturbed soils). Air monitoring should be conducted during the excavation and
remediation process to ensure the adequate protection of workers and
consequently nearby residents, surface water and soils.
Response - An ambient air monitoring program win be conducted during
excavation, screening, blending, and feed preparation activities to ensure that
ambient concentrations of respirable dust, TNT, tetryl and lead are below site-
specific action levels. Ambient air monitoring results conducted during previous
activities at the ALAAP site indicated that no harmful concentrations of dust,
TNT, asbestos or lead were present in the on-site work areas or migrated from
the site.
Additionally, precautions will be taken to minimize, dust emissions during site
activities (e.g. , transport trucks will be covered, transport roads will be moistened
with water, etc.).
4.0 PFMATVTNG CONCERNS
All of the public comments have been adequately addressed. The public appears to have no
substantive concerns about the implementation of the selected remedy.
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ALABAMA
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
October 6,1994
Mr. Bill Hicks
207 Poplar Drive
Childemburg, AL 35044
Dear Mr. Hicks,
On August 26,1994 I vfeHed your residence In response to the compburit you filed
concerning a clay-like fallout During that visit i collected two samples for
analysis. Tins purpose of this letter is to inform you of the results of this anaJyals
and other investigations we have conducted concerning your complaint.
The results of our analysis Indicated that the samples were composed of smafl
dumps of quartz (45-97%), organic matter sudi w plant material and Insect
droppings (2-54%) and an unidentified brown/amber colored binder (1%). The
alze and density of the clumps Indicates that even at extreme conditions
speeds of 20 mph and a source stack height of 150 feet or higher) these
eouM only stay airborne for approximately 1/4 to 1/2 mile. Our ii
no euoh source within that distenoe of <
fallout b unknown at this time.
finds
your residence end the eouroe of tWa
If you observe euoh fallout In the future, please feet free to contact our office. In
order to help locate the source tt would be very helpful If you could collect another
sample and record the date and time of the mHout as well as the wind direction
and speed. You may also wish to attempt to trace the fallout upwind and try to
determine the source.
Thank you for your cooperation in this matter. If you have any questions please
feel free to contact me at 271-7860 in Montgomery.
Sincerely.
CarlFerraro
Special Services Section
Air Division
CF/ct
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Sept. 29, 1994
Commander
U. S. Army Environmental Center
ATTN: SFIM-AEC-BCP (Mr. Rich Isaac)
Building E4480
Aberdeen Proving Ground, MD 21010-5401
Dear Sir.
I was unable to attend the public hearing held Sept. 28,
1994, but I have read the DECLARATION OF THE DRAFT FINAL
INTERIM RECORD OF DECISION.
I would like any information on GROUNDWATER CONTAMINATION at
the Alabama Army Ammunition Plant. located in Childersbur;
Alabama.
It is obvious after reading the article in the local paper,
(The Daily Home) that people do not understand what is going
on. Is there any way that the public could be supplied with
someone who could interpret the information provided the
public?
I would also like to be put on any mailing list that you have
on information about this issue.
Laura Payne
P. O. Box 257
Childersburg, Al 35044
205-378-5718
6"d
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CITIZENS FOR
51ft
E12629 Weigand's Bay South
____^_ Mammae, Wisconsin 53561
Si f e Water Around Badger Phone (608) 643-3124
Commander
U.S. Army Environmental Center
ATTN: SFIM-AEC-BCP (Mr. Rich Isaac)
Building E4480
Aberdeen Proving Ground, MD 21010-5402
%
September 22,1994
RE: Draft Final Interim Record of Decision Alabama Army Ammunition Plant
Otildersburg, AL August 1994
Dear Mr. Isaac:
The following is public comment on the draft final Interim Record of Decision,
Area B Soils operable unit. Alabama Army Ammunition Plant, Childersburg, Alabama
dated August 1994.
I am President and co-fbvmder of Citizens for Safe Water Around Badger
(CSWAB), a grassroots citizens group working to involve and empower local
community members in advocacy of human health, environmental restoration and
economic conversion issues related to military toxics. As a community leader and
activist, I am familiar with many of the issues associated with military toxins, particularly
regarding the treatment and remediation of explosives comarninated soils.
According to the Draft Final Record of Decision (DFROD) the prevalent
contaminants at all Study Areas (6,7,10 and 21) act metals (lead), and explosives and
their degradation products (TNT, tetryl and 1.3-DB). In addition to metals and
explosives contamination: friable and transite asbestos and nitrocellulose contamination
are extensive in soils at Area 7; the industrial sewer system (ISS) within Area 6 is
contaminated with nitrocellulose, and the explosive RDX was detected at one site within
this area.
The DFROD reports vast areas of the Alabama AAP facility consist of surface
waters and wetlands, including creeks, swamps and pond areas. Further, beaver dams
have significantly slowed the drainage and have TihpTrH the success of local aquatic and
terrestrial organisms including waterfowl, white-tailed deer and larger predatory species.
These resources and biological receptors will be extremely sensitive to both the positive
and negative consequences of remedial processes.
As stated in the DFORD, the purpose of remediation is reduce foxicity, mobility
and to a lesser degree, volume. Alternative 1O (on-site incineration) does not reduce the
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toxidty, mobility or the volume of inorganics such as lead — a pervasive contaminant in
the soils at Alabama AAP. Incineration of lead only results in the dispersal of these
contaminants to the air, water, soil and resultant incinerator ash; incineration is
completely ineffective in reducing the toxicity of lead or other metals.
Further, our opposition to incineration is based on increasing evidence that
incinerators are not safe. The direct risks of incinerator pollutants on human health are
based on the probability of exposure to levels of toxic compounds sufficient to cause
disease.
Incinerators produce air. water and soil toxics through stack emission or fugitive
emissions. More importantly, the uptake of these toxins into plants and animals and their
biomagniflcation through the food web present the greatest risk to people — either
through absorption, inhalation or ingestion.
The major pollutants associated with incineration include acids, metals, nitrogen
oxides, carbon monoxide, ozone, dioxin, volatile organic compounds (VOC's) and
partially incinerated compounds (PIC). Sulfuric acid production can be controlled in
stacks with air pollution control equipment, but the production of nitric acid cannot be
prevented. Most toxic metals that arc present in the waste stream are likely to remain in
the combustion ash, but some likely (mercury and chromium) are known to exit stacks
despite air pollution control equipment
Volatile organic compounds are a large group of compounds, many of which have
known or suspected human disease capability. These compounds may or may not be
completely destroyed in incinerators, depending upon conditions of temperature,
pressure, and oxygen levels in the incinerator flame zone. Finally, partially incinerated
compounds (PIC) are produced in the incineration process and could have innumerable
chemical formulations and health effects.
Without doubt the most studied of these compounds is dioxin, of which the most
toxic variation known is tetrachlordibenzodioxui (TCDD). This compound is regarded as
possibly the most toxic substance known. The recently-released EPA report on dioxin
establishes that dioxin causes cancer, confirming the unacceptable risks to human health
caused by hazardous waste incineration.
Further, alternative technologies implemented at other federal facilities have,
according to the US Army, successfully remediated cxploaves-contaminated soils. For
example, field-scale demonstration projects prili7«"g bioremediation (composting) have
been conducted at Louisiana Army Ammunition Plant, Badger Army Ammunition Plant
hi Wisconsin and Umatilla Depot in Oregon for the treatment of explosives-contaminated
soils. Soil washing has been utilized at Twin Cities Army Ammunition Plant for the
treatment of metals-contaminated soils, and chaiacterired as a success by the Army
officials.
These examples illustrate that alternative, applicable technologies have not been
sufficiently researched nor characterized in the DFROD. Given the absence of
significant levels of solvents in contaminated soils, it would appear that bioremedial and
other alternative technologies could be considered and parenthetically could be
considerably cheaper man the proposed incineration processes.
Regardless of the final treatment technology chosen, steps should be taken during
excavation procedures to reduce and monitor fugitive dust which may pose a significant
'Aid lanscm -VZHH UMA^^T *« TT
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health and environmental risk. Safeguards such as the application of lime, covering of
transport trucks, wetting of roads and disturbed soils are imperative. Air monitoring
should be conducting during the excavation and remediation process to ensure the
adequate protection of workers and consequently nearby residents, surface water and
soils.
Based on the information given, I believe die DFROD is insufficient and
incomplete in its assessment of alternative, safer technologies and therefore potentially
places workers, community, biological receptors and the environment at excessive and
unnecessary risk.
Thank you for the opportunity to submit comment and I hope that the Army and
appropriate regulators will reassess the conclusions of this report and pursue alternatives
to hazardous waste incineration at Alabama AAP.
Sincerely,
LAURA OLAH
Presk
CC: Mr. Lewis D. Walker, Secretary of Army for Environment, Safety and Occupational
Health, Room ZES77,110 Army Pentagon, Washington, DC 20310-0110
Mr. Dan Speriosa, USEPA- Region IV, 345 Courtland St., NE. Atlanta, GA 30365
Mr. C.H. Cox, Alabama Department of Environmental Management, Attention:
Special Projects, 1890 AA W.L. Dixonson Drive, Montgomery, AL 36109
Ms. Cathy Hinds, Executive Director, Military Toxics Project, PO Box 845,
Sabattus, ME 04280
B'd 'Aid 3SnSCTO 3SHH Ue&t>:?T tnR, TT
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