United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/HOD/R05-89/118
August 1989
&EPA
Superfund
Record of Decision
New Brighton/Arden Hills
(TCAAP), MN
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R05-89/118
3. RecipienTs Accession No.
4. Tide and Subtftts
SUPERFUND RECORD OF DECISION
New Brighton/Arden Hills (TCAAP), MN
Seventh Remedial Action
5. Report Date
08/11/89
'.
7. Author(s)
8. Performing Organization Rept No.
9. Performing Organization Nairn and Address
10. ProjecVTask/Work Unit No.
11. ContracqC) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Umit: 200 words)
The New Brighton/Arden Hills site, also known as the Twin Cities Army Ammunition Plant
(TCAAP) site, is in New Brighton, Minnesota. Land use bordering the four square-mile
site is largely residential. Past disposal of ammunition manufacturing wastes onsite
resulted in contamination of ground water beneath and downgradient of the site. A total
of 14 waste disposal locations have been identified and assigned as Sites A through K.
During remedial investigations at Site D, soil was discovered to be contaminated with
PCBs and other organic and metal contaminants. A soil gas extraction system was
I implemented to remove the source of volatile organic contamination and reduce the
kpotential of migration to ground water. In implementing the soil gas extraction system,
PCB-contaminated soil was removed, stockpiled near Site D, and sealed with a plastic
liner material. This interim remedy addresses the treatment and disposal of
contaminated soil that is stockpiled near Site D. The primary contaminants of concern
affecting the soil are VOCs including TCE and PCE, other organics including PCBs, and
metals including arsenic and lead.
The selected remedial action for the site includes onsite treatment of approximately
1,400 cubic yards of stockpiled soil using mobile infrared thermal treatment technology;
analysis of treated soil to ensure PCB treatment goal is met (Continued on next page)
17. Document Analysis a. Descriptors
Record of Decision - New Brighton/Arden Hills (TCAAP), MN
Seventh Remedial Action
Contaminated Medium: soil
Key Contaminants: VOCs (TCE, PCE), organics (PCBs), metals (arsenic, lead)
b. kfentiflers/Opan-Ended Terms
c. COSATI Held/Group
18. Availability Statement
Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
32
22. Price
(See ANSI-Z39.18)
S«e Inttrvction* on Revere*
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R05-89/118
New Brighton/Arden Hills (TCAAP), MN
16. Abstract (Continued)
followed by placement of treated soil in an area near Site D; discharge of treated
scrubber wastewater to the TCAAP sanitary sewer system and ultimately to a POTW;
decontamination and removal of equipment used in the treatment process; and air
monitoring during soil treatment. The estimated total cost for the selected remedy is
$1,200,000.
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RECORD OF DECISION ON REMOVAL ACTION
FOR PCB-CONTAMINATED SOILS NEAR SITE D
TWIN CITIES ARMY AMMUNITION PLANT
NEW BRIGHTON. MINNESOTA
JUNE 1969
This Document ie Intended to Comply with the national Environmental Policy Act of 1969.
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INSTALLATION ENVIRONMENTAL RESTORATION PROGRAM
TWIN CITIES ABMY AMMUNITION PLANT
RECORD OF DECISION ON REMOVAL ACTION
Thermal Treatment of PCB-Contaminated Soils near Site D
SITE: Twin Cities Army Ammunition Plant (TCAAP),
New Brighton, Minnesota
STATEMENT OF BASIS AND PURPOSE:
This Record of Decision (ROD) document presents the selected
remedial action £or remediating soil contaminated with polychlor-
inated biphenyls (PCBs) near Site D of the TCAAP Superfund site
located in New Brighton, Minnesota. The decision document is
developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthoriration Act of
1986 (SARA), and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). This
decision is based on the administrative record for this site.
The following documents describe the basis for this decision.
INDEX
Post Action Report on PCS Removal
Site D
Twin Cities Army Ammunition Plant
Wenck & Associates, Inc. January 31, 1986
Final Report On-Site Incineration Testing
of Twin Cities Army Ammunition Site
New Brighton, MN
Shirco Infrared Systems Portable Test Unit
Report No. 833-87-01 September 24, 1967
Installation Restoration Program
Twin Cities Army Ammunition Plant
Site D - PCB-Contaminated Soil
Feasibility Study
Federal Cartridge Company
Final Report November 6, 1967
Interim Remedial Action Plan
Site D, PCB-Contaminated Soils
Twin Cities Army Ammunition Plant
Wenck Associates, Inc. March 1989
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Endangerment Assessment of PCB
Incineration at Site D,
Twin Cities Army Ammunition Plant
PRO Environmental Management
Chicago. IL March 1989
Risk Evaluation- of the Destruction of
PCBs by High-Temperature Treatment
of Affected Soils
Twin Cities Army Ammunition Plant, Site D
Carlos Stern Associates, Inc.
Arlington. VA March 1989
The final remedial action will be selected following comple-
tion of the TCAAP Remedial Investigation (RI) and New Brighton/
Arden Hills Feasibility Study (FS) . currently being conducted by
the Department of the Army (DA), and the New Brighton/Arden Hills
RI being conducted by the U.S. Environmental Protection Agency
(EPA) and the Minnesota Pollution Control Agency (MPCA).
The State of Minnesota has concurred in the selected remedy.
DESCRIPTION OF SELECTED REMEDY:
Approximately 1,400 cubic yards of PCB-contaminated soils
will be treated using a mobile thermal treatment system. The
mobile system will be transported to TCAAP and assembled for
operation. The thermal operation is expected to take approxi-
mately three weeks. This remedy is not intended to address the
groundwater contamination at TCAAP. Groundwater contamination
has been partially addressed by other Interim Remedial Actions.
Soil and water contamination will be addressed in the final
remedy.
DECLARATION:
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act oi 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and the NCP (40 CFR Part 300), we have determined that the ther-
mal treatment of PCB-contaminated soils near Site D is a cost-
effective interim removal action that will be consistent with
the final remedial action selected. The TCAAP Remedial Investi-
gation (RI) and New Brighton/Arden Hills Feasibility Study (FS)
currently being conducted by the Department of the Army (DA) and
the U.S. EPA/MPCA will determine the final remedial action. DA.
U.S. EPA, and MPCA have thoroughly discussed this removal action
and determined that the treated soil will meet all federal and
state requirements. The interim removal action will be
considered part of the approved final remedial action and eligi-
ble for Department of Defense Environmental Restoration Account
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monies. Actual or threatened releases of hazardous substances
from the PCB-contaminated soils near Site D. if not addressed by
implementing the response action selected in the ROD. may present
an imminent and substantial endangerment to public health, wel-
fare, or the environment.
The selected remedy is protective of human health and the
environment, attains federal and state requirements that are
applicable or relevant and appropriate for this remedial action,
and is cost-effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element and utilizes
a permanent solution to the maximum extent practicable.
DA is currently implementing the DA/EPA/MFCA Federal Facility
Agreement (effective 31 December 1987) in order to complete the
RI/FS process. A ROD will be prepared for approval of any future
remedial actions selected prior to or after completion of the
ongoing RI/FS.
Valdas V^ Adaml
Regional Admin:
Region V
Environmental
us ~y\ Da/te|
strator —
rotection Agency
Lewis D. Walker Date
Deputy Assistant Secretary of
the Army (Environment, Safety
and Occupational Health)
Office of the Assistant Secretary
of the Army (Installations and
Log is t i cs
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TABLE OF CONTENTS
Section Page
1.0 SITE MA1CE. LOCATION. AND DESCRIPTION 1
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
3.0 COMMUNITY RELATIONS HISTORY 4
4.0 SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY .. 4
5.0 SUMMARY OF SITE CHARACTERISTICS 5
6.0 SUMMARY OF SITE RISKS 5
7.0 DOCUMENTATION OF SIGNIFICANT CHANGES 6
8.0 DESCRIPTION OF REMEDIAL ACTION 6
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 9
9.1 EVALUATION CRITERIA 9
9.2 COMPARISON OF ALTERNATIVES 9
9.3 IDENTIFICATION OF LEGALLY APPLICABLE OR RELEVANT
AND APPROPRIATE REQUIREMENTS (ARARs) 12
10.0 THE SELECTED REMEDY -- ON-SITE THERMAL TREATMENT 14
.10.1 DESCRIPTION OF THE SELECTED REMEDY 14
10 . 2 RATIONALE FOR SELECTION 14
11.0 STATUTORY DETERMINATIONS 15
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LIST OF FIGURES
Figure Page
1 General Location Map of the Twin Cities Army Ammunition Plant 2
2 Areas of Contamination in the Twin Cities Army Ammunition Plant 3
Summary of June 15, 1989 Public Meeting 17
Questions/Comments of Public Meeting 25
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THE DECISION SUMMARY
This Decision Summary provides an overview of the site
location and description; site history and enforcement activi-
ties; community relations history; scope and role of the response
action within the site strategy; summary oi site characteristics;
summary oi site risks; documentation of significant changes;
description of remedial action alternatives; summary of compara-
tive analysis of alternatives, including the nine evaluation
criteria used to screen the alternatives; the selected remedy;
and the statutory determinations. The Decision Summary also
explains the rationale for selecting the remedy and how the
remedy meets the statutory requirements.
1.0 SITE NAME, LOCATION, AND DESCRIPTION
The Twin Cities Army Ammunition Plant (TCAAP) is a plant
owned by the U.S. Army that is located in New Brighton, Minnesota
(Figure 1). TCAAP occupies an area of approximately four square
miles north of the Saint Paul/Minneapolis area. A number of
communities surround TCAAP, including Arden Hills, New Brighton.
and Saint Anthony to the south and southwest, Shoreview to the
north and east, and Mounds View to the northwest. Residences
located near the southwest corner of TCAAP are approximately
one mile away from those areas within TCAAP that were identified
to be sources of contamination.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
TCAAF manufactured ammunition during major war conflicts.
Wastes generated during manufacturing of ammunition were disposed
of at several areas within TCAAP. Waste disposal, in turn,
resulted in contamination of groundwater beneath and downgradient
(southwest) of the TCAAP site. Earlier investigations on the
groundwater contamination have identified a total of 14 waste
disposal sites on the installation. Figure 2 depicts these
sites, which have been designated Sites A through K, 129-3, 123-5
and 129-15. One of these sites is Site D.
To plan and dictate the course of actions necessary to
remediate the contaminated areas of the TCAAP site, including
Site D, the U.S. Army, the U.S. EPA, and MPCA signed a Federal
Facility Agreement (FFA). The FFA was signed under the
authority of Section 120 of CERCLA and became effeetive on
December 31. 1987. All remedial investigation (RI) work and
interim response actions (IRA) at the site were and are being
undertaken in accordance with the stipulations of the FFA.
During the RI work at Site D, soil was found to be
contaminated with polychlorinated biphenyls (PCBs). In addition
to PCB contamination, other organic and inorganic contaminants
were detected. Based on the RI work at the site, a soil gas
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FIGURE 1
012346
General Location Map of the
Twin Cities Army Ammunition Plant
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FIGURE 2
Areas of Contamination in the
Twin Cities Army Ammunition Plant
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extraction System was implemented to remove the source of
volatile organic contamination and reduce the potential of
migration to the groundwater. In implementing the toil gas
extraction system. PCB-contaminated coil was removed, stockpiled,
and sealed within plastic liner material.
In November 1087, under the FFA, a feasibility study (FS)
was conducted to identify, evaluate, and select the remedial
action alternative that would: (1) be most protective of human
health and the environment by permanently destroying site
contamination; (2) meet all federal, state, and local regulatory
requirements; and (3) be cost-effective. Of the five
alternatives identified in the FS, on-site thermal treatment of
contaminated soil was selected as the most feasible alternative.
The FS was supplied to U.S. EPA and MPCA for review and approval.
The U.S. EPA and MPCA concurred that the on-site thermal
treatment alternative was the most feasible to implement at Site D,
consistent with the requirements under CERCLA, SARA, and the NCP.
3.O COMMUNITY RELATIONS BISTORT
Pursuant to CERCLA Section 113(k), 2 U.S.C.9613(k), and
Section 300.67 of the NCP, the public, local authorities, Region V
of the U.S. EPA, and the State of Minnesota were all requested
to comment on the Interim Response Decision Record and the pro-
posed ROD. Remediation was discussed at the community leaders
meeting. One special meeting was held specifically to discuss
the on-site thermal treatment. Since this ROD will be signed by
the U.S. Army and U.S. EPA. these agencies will respond to each
significant comment, criticism, and new data submitted.
Notification of comment period: 24 May 1989
Closing date of comment period: 22 June 1969
Public Meeting: Held at New Brighton, Minnesota
on June 15, 1989
4.0 SCOPE AMD BOLE OF RESPONSE ACTION WITHIN SITE STRATEGY
As described in Section 2.0 of this ROD, soils stockpiled
near Site D are contaminated with PCBs. organic, and inorganic
contaminants. These soils were excavated, stockpiled, and
covered with a liner at the site. If no action were to be taken.
the possibility of physical damage to the liner would potentially
cause release of the above contaminants to the environment. The
liner would have to be maintained and local groundwater monitored
for potential adverse impacts indefinitely. Furthermore, the
future access or land use of the site would have to be restricted
in perpetuity. Therefore, the remedial action sought for
alleviating contamination at the site should remove the source
of contamination and, using treatment response technology,
permanently reduce the mobility, toxicity, or volume of the
contaminant mass. This would prevent potential future release,
migration, or adverse impacts to human health and the environment,
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5.0 SUMMARY OF SITE CHARACTERISTICS
Based on the results of previous investigations at the site,
approximately 1,400 cubic yards of contaminated soil were exca-
vated from Site D in 1085 to allow implementation of the soil gas
extraction system at the site. The excavated contaminated soil
was then stored, pending final disposal, in secure containment
near Site D on a 40-mil high-density polyethylene (HDPE) liner,
with a 20-mil HPDE cover. Testing of the excavated soil revealed
the following average concentrations, in milligrams per kilogram
(mg/kg) of the following contaminants:
Average
Concentration
Constituent mg/kg
Organ ics
PCB 71.1
1,1,1-Trichloroethane 65.2
Tetrachloroethene 2.3
Trichloroethene 341.0
Inorganics
Arseni c 1.3
Barium 91.8
Lead 85.8
6.0 SUMMARY OF SITE RISKS
U.S. EPA conducted an Endangerment Assessment (EA) on PCB-
contaminated soil at Site D. The EA evaluated site risks under
two scenarios: (1) no-action, in which it is assumed that
contaminated soil is left in place and the public can easily
access the site (which is not possible under the present security
of the TCAAP). and (2) on-site thermal treatment of excavated soil
For conducting the EA, the following indicator chemicals
were selected: PCBs , organic contaminants (1,1,1-trichloroethane,
tetrachloroethene. trichloroethene, and dioxin). and inorganics
(arsenic, barium, and lead).
It is believed that organic contaminants may migrate from
the site primarily through volatilization and release of
fugitive dusts. Because a portion of the area surrounding Site D
is contaminated with organic (except PCBs) and inorganic
contaminants, fate and transport data were ineffective in
determining migration routes for indicator chemicals other than
PCBs.
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Under the no-action alternative, three exposure scenarios
were identified: (1) ingestion of soils, (2) direct contact with
soils, and (3) inhalation of volatile organic compounds (VOCs)
and particulate air contaminants. Under the probable-case
scenario, 6 lifetime excess cancer risks in a population of
10,000 might be induced due to contamination. Under the worse-
case scenario, the lifetime excess cancer risk increases to 2 in
1,000. The no-action alternative poses potential risks to human
health. These risks exceed the Superfund acceptable risk range
of 1 in 10,000 to 1 in 10 million.
One exposure scenario was identified for the on-site thermal
treatment alternative: inhalation of stack emissions. The
worst-case lifetime excess cancer risk would be 4 in 10 million
(equivalent to 1 in 2.5 million). Relative to the no-action
alternative, thermal treatment does not present significant human
health risks. The potential health risks that may be posed from
implementing the remaining four alternatives considered in the FS
were not quantified. However, the relative performance of these
alternatives with respect to the nine evaluation criteria (pre-
sented in Section 9) is discussed in Section 9 of this ROD.
7.0 DOCUMENTATION OF SIGNIFICANT CHANGES
This ROD does not differ significantly from the public
comment draft ROD of May 1989. There are no significant changes
in the joint decision (by U.S. Army, U.S. EPA, and MPCA) to
implement the selected remedy at Site D. This ROD has only
been changed from the May 1989 public comment draft ROD to
clarify the criteria and basis used in this decision.
8.0 DESCRIPTION OF REMEDIAL ACTION
The FS for remediating PCB soil contamination near Site D
identified and evaluated five response action alternatives: (1)
no action; (2) transfer of contaminated soils to Honeywell's
Retrievable Monitored Containment Structure (RMCS) located near
Building No. 502 of TCAAP; (3) off-site disposal; (4) on-site
thermal treatment; and (5) off-site thermal treatment.
Alternative A: No Action
Under the no-action alternative, the contaminated soil would
remain in the secured soil storage area near Site D. Specific
components of the no-action remedial alternative include:
Continue maintenance of the HDPE liner, site
fence, and access gate.
Leave the contaminated soil in its present
location for an undetermined period of time.
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Monitor the storage area for possible infiltration
to or leakage from the HDPE liner.
Monitor the local groundwater to determine whether
soil storage is impacting the aquifer.
Implementation Time: Maintenance of the site and monitoring
of groundwater contamination would
continue indefinitely.
Total Cost: Approximately *500 per month.
Alternative B: Transfer to Honeywell's RMCS
This alternative consists of transporting the contaminated
soil and liner to the Honeywell Retrievable Monitored Containment
Structure (RMCS), a specially designed storage vault, located
near Building No. 502 on the TCAAP installation. The following
measures comprise the RMCS alternative:
General site preparation
Loading transport vehicles
Relocating contaminated soil and liner to RMCS
Site closure
Implementation Time: Approximately 1-2 months
Total Cost: *100,000 with additional monthly fees.
Alternative C: Off-Site Disposal
Another alternative is to relocate the contaminated soil and
liner to an off-site Secure Chemical Management Facility (SCMF).
Placing the material in a SCMF would eliminate environmental
threats posed by leaving the contaminated soil on-site. The
Off-Site Disposal alternative consists of the following remedial
action measures:
General site preparation
Loading transport vehicles
Decontaminating loading equipment and transport
vehicles
Off-site transportation/disposal
Site closure
Implementation Time: Approximately 1-2 months
Total Cost: *500,000 - *1.000.000
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Alternative D: On-Site Thermal Treatment
Soil remediation by the on-site thermal treatment method
involves the use of a leased portable thermal processing unit at
the soil storage area. The thermal treatment technology would
eliminate environmental threats posed by leaving the contaminated
soil on-site as well as avoid any liability incurred by placing
the material in a SCMF. The thermal treatment process involves:
General site preparation
Mobilizing thermal processing unit
Thermal processing of soil
Disposing of treated soil (ash)
Demobilization
Site closure
Implementation Time: Approximately 3 weeks of thermal
processing .
Total Cost: SI.2 million
Alternative E: Off-Site Thermal Treatment
This alternative is to transport the contaminated soil and
liner to an off-site thermal treatment facility for destruction;
it involves the following measures:
General site preparation
Load transport vehicles
Decontaminating loading equipment and transport
vehicles
Off-site transportation/disposal
Site closure
Implementation Time: 3-7 months
Total Cost: «<5.7 - 85.0 million
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0.0 SUMMARY OF COMPARATIVE AHALTSIS OF ALTERNATIVES
This section describes the criteria used for evaluating the
remedial action alternatives and identifies the strengths and
weaknesses of each alternative in satisfying these criteria. It
also identifies the legally applicable, relevant, or appropriate
requirements (ARARs) with which the remedial actions have to
comply.
O.I EVALUATION CRITERIA
The alternatives are weighed against nine evaluation criteria:
Overall protection of human health and the environment
Compliance with applicable or relevant and appropriate
requirements (ARARs);
Long-term effectiveness and permanence;
Reduction of mobility, toxicity, or volume (M/T/V);
Short-term effectiveness;
Implementabi1ity;
Cost ;
State acceptance; and
Community acceptance.
In addition, the selected remedy must satisfy the statutory
requirements of Section 121 of CERCLA as amended by SARA.
9.2 COMPARISON OF ALTERNATIVES
The five remedial action alternatives are compared below in
terms of their ability to satisfy the above nine evaluation
cri teria:
Overall Protection of Human Health and the Environment
Under the no-action alternative (Alternative A), the
contaminated soil would be left intact and the potential for
releasing contaminants to the environment would still exist
because of possible physical damage to the HDPE liner material.
On-site storage in Honeywell's RMCS (Alternative B) and
off-site disposal (Alternative C) would alleviate the potential
for adverse environmental impacts by storing and monitoring the
contaminated soil in approved storage facilities. However,
Alternatives B and C do not provide a permanent solution to the
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contamination problem but transfer the contaminated soil from its
existing location to other disposal areas. Under Alternatives B
and C, on-«ite workers may be exposed to contaminated coils by
ingestion or inhalation during removal of the soil from Site D.
In addition, Alternative C would pose a potential threat to the
surrounding population because contaminated soil would need to be
transported off-site.
On-site thermal treatment (Alternative D) and off-site
thermal treatment (Alternative E) would provide the greatest
degree of protection possible to human health and the environment
by permanently destroying contaminants present in the soil. Under
Alternatives D and E, on-site workers may also be exposed to
contaminants during removal of soil from Site D. Only Alterna-
tive D would minimize handling and avoid transportation of the
contaminated soil. On the other hand. Alternative E would pose a
potential threat to the surrounding population because of the
need to transport contaminated soil off-site.
Compliance with Applicable or Relevant and Appropriate
Requirements (ABABs)
All alternatives except no-action would achieve ARARs and
the requirements of the Federal Facility Agreement (FFA). However
on-site storage and off-site disposal alternatives (Alterna-
tives B and C) do not satisfy the spirit of the land disposal
restrictions under the Resource Conservation and Recovery Act
(RCRA). as amended by the Hazardous and Solid Waste Act (HSWA) of
1984; nor do these alternatives satisfy the preference of SARA
Section 121 for solutions that permanently reduce the mobility,
toxicity. or volume (M/T/V) of contamination by implementing a
response treatment technology. Under Alternatives B and C,
transferring the contaminated soil to the RMCS or off-site (SCMF)
would require RCRA manifesting in accordance with Minnesota
Rules. Part 7045.0261. Transportation of the contaminated soil
would also have to comply with Minnesota Rules, Part 7045.0371.
Any applicable RCRA or Toxic Substances Control Act (TSCA) per-
mit (s) would need to be maintained by Honeywell (for the RMCS) or
the SCMF for the duration of the storage period.
On-site and off-site thermal treatment alternatives
(Alternatives D and E) would be consistent with the preference of
SARA for solutions that permanently reduce the M/T/V of the
contaminated soil. In addition, Alternative E would have to
comply with the manifesting and transportation requirements
described above. Both Alternatives D and E would have to comply
with the TSCA requirements presented in the Code of Federal
Regulations (CFR §761.70). A permit from the Metropolitan Waste
Control Commission (MWCC) would be required under Alternative D
for discharging scrubber blow-down water to the TCAAP sanitary
sewers. Following thermal treatment of the contaminated soil,
Site D closure requirements set forth in the FFA would also have
to be met.
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Long-Term Effectiveness and Permanence
Alternatives A. B. and C would do nothing to remove perma-
nently and effectively the contaminants of concern. Only on-site
and off-site thermal treatment (Alternatives D and E) would
destroy permanently the contaminants by treating thermally the
contaminated soil. According to the TSCS requirements, Alterna-
tives D and E would have to meet a Destruction Removal Efficiency
(DRE) performance standard of 99.9999 percent, or greater, to
ensure that contaminants are effectively removed from the Site D
soil .
Seduction of Mobility, Toxicity, or Volume (M/T/V)
The no-action alternative would not reduce the M/T/V of
contamination because, under this alternative, no treatment or
containment measures would be implemented. On-site storage and
off-site disposal (Alternatives B and C) would reduce the mobility
of the contaminants in the short-term by reducing the potential
for migration due to infiltration or precipitation. Only on-site
and off-site thermal treatment (Alternatives D and E) would
permanently reduce the M/T/V of contaminants from the contaminated
soil.
Short-Term Effectiveness
Except for the no-action alternative, the remaining alterna-
tives would effectively alleviate the contamination problem at
Site D on the short-term basis. The primary short-term concern
during implementation of any alternative other that no-action
would be with volatilization of VOCs and PCB-contaminated fugi-
tive dust that may be generated during handling of soil. The
on-site storage, off-site disposal, and off-site thermal treat-
ment would require more handling of the contaminated soil than
on-site thermal treatment. Therefore, the on-site thermal treat-
ment alternative would involve minimal soil handling and would be
more effective than the other alternatives on the short-term
bas is.
Implementabi1ity
All considered remedial action alternatives are implement-
able. The no-action alternative (Alternative A) would only
require maintenance of the fence, the HDPE liner, and monitoring
of the contaminated soil and ground beneath the site. On-site
storage and off-site disposal (Alternatives B and C) would uti-
lize conventional construction equipment such as front-end load-
ers, bulldozers, and trucks to remove the contaminated soil and
transport it to its final destination (on-site to the RMCS or
off-site to a SMCF) . The FS estimated that it -would take
approximately 30-60 days to implement Alternative B and 30-60 days
to implement Alternative C. On-site and off-site thermal treat-
ment (Alternatives D and E) would implement proven technologies
for treating and removing PCBs and VOCs from the contaminated
soil. The estimated time for implementing Alternative D is
approximately 3 weeks while implementing Alternative E would take
3-7 months.
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Co»t
The total costs for the remedial action alternatives were
presented in the FS for PCB-contaminated soil remediation at the
site. These costs are presented below:
Total Cost
Alternative Description (1989 Dollars)
A No-Action «500/month
B On-Site Storage *100,000 + Monthly Fee
C Off-Site Disposal «500.000 - «1,000,000
D On-Site Thermal Treatment »1,200,000
E Off-Site Thermal Treatment «4,700.000 - *5,000.000
The costs shown above represent 1989 dollar estimates. The
on-site thermal treatment alternative (Alternative D) is the
second most expensive alternative after off-site thermal treat-
ment.
State Acceptance
The State of Minnesota fully agrees and supports the on-site
thermal treatment alternative. The other alternatives are less
acceptable to the State because either they do not provide a
permanent remedy for the contamination problem or they do not
reduce the M/T/V of the contaminants.
Community Acceptance
From the public meeting held in New Brighton, Minnesota on
June 15, 1989, and from no public comments received during the
comment period, it appears that the public has no distinct pref-
erence as to which alternative is acceptable for remediation of
contaminated soil. A total of 41 people attended the June 15th
public meeting, of which about 10 were private citizens and not
from federal, state, or local agencies.
9.3 IDENTIFICATION OF LEGALLY APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs)
The purpose of this section is to identify the federal and
state ARAEs that should be applied to the effluent from the
thermal treatment Eys^em, pursuant to Section 121 of SARA.
The following factors were applied in selecting ARARs:
1. Any standard, requirement, criteria or limitation under
federal environmental law may be an ARAB [SARA 121
(d)(2)(A)(1)]. Non-binding advisories, goals, and
guidelines are not ARARs.
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2. Any promulgated standard, requirement, criteria or
limitation under a state environmental law that is more
stringent than any federal standard is of general
applicability, enforceable by the state, and identified
by the state to the U.S. Army in a timely manner, may
be an ARAB.
3. Only substantive requirements may be ARARs. Permits,
notices, and reporting requirements in federal and
state laws do not apply to CERCLA response actions.
Based upon these factors, th'e intent of the following
standards and regulations are applicable federal and
Minnesota ARARs:
1. Resource Conservation and Recovery Act (Federal)
2. The Toxic Substances Control Act Regulations (Federal)
3. Standards issued pursuant to the Clean Air Act by
the Minnesota Pollution Control Agency (Federal
and State)
4. Discharge limitations as related to the Clean
Water Act from the scrubber water discharge
5. Occupational Safety and Health Act
At this time there are no known toxic substances, pollu-
tants, or any contaminants, as defined by SARA, migrating from
the stockpiled PCB-contaminated soil. The U.S. Army, in conjunc-
tion with the U.S. EPA and MPCA, will continue to monitor any
toxic substances, pollutants, or contaminants that may migrate
from this PCB-contaminated soil pile, and will take appropriate
action to avoid imminent and substantial danger to public health
or the environment.
Establishing water quality criteria to determine the neces-
sary extent and degree of remediation for groundwater migrating
from the TCAAP site is not part of this interim ROD. Such
determinations will be based on ARARs or on a risk-based number
and will be included in the final RI/FS and ROD. However, a
thermal treatment level for the soils will be based upon a PCB
concentration of 2 parts per million (ppro) or less to meet the
TSCA requirements. Processed soil found to have PCB concentra-
tions of greater than 2 ppm will be returned for retreatment. In
the past, the thermal treatment chosen has consistently reduced
the PCB concentrations to below detection levels.
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10.0 THE SELECTED REMEDY -- OH-SITE THERMAL TREATMENT
This section describes the selected remedy and the rationale
for its selection.
10.1 DESCRIPTION OF THE SELECTED REMEDY
A mobile infrared thermal treatment unit owned by the OH
Materials (OHM) Corporation will be used on this site to thermally
destroy the polychlorinated biphenyls (PCBs) in the soils. The
OHM treatment unit has been contracted through the Ecova Company.
This unit has a National Toxic Substances Control Act (TSCA)
permit to dispose of PCBs.
The mobile thermal treatment process consists of a high-
temperature-powered primary chamber with a high-temperature alloy
belt conveying system. The secondary chamber is fossil-fuel
fired, operated at a temperature of approximately 2,000° Fahren-
heit. Combustion off-gases from the secondary chamber will be
run through pollution control equipment consisting of a quench
'section, a scrubber chevron mist eliminator, and a packed column
chemical scrubber.
The thermal treatment operation will be performed in accord-
ance with conditions of the TSCA permit and other applicable
requirements [40 CFR §76 1 . 70 (b) (2) ] . Comprehensive monitoring of
the process streams and complete system checks will be conducted
to ensure safe and efficient operating conditions.
Thermally treated soil will be analyzed to ensure a PCS
concentration of less than 2 ppm before it is placed at an area
near Site D.
Treated wastewater, meeting the regulatory guidelines, will
be discharged to the TCAAP sanitary sewer system and ultimately
to the MWCC system.
After completing the soil thermal treatment, the equipment
used in the process will be decontaminated before being removed
of f-site.
10.2 RATIONALE FOR SELECTION
The selected alternative is chosen based on the assessment
of each criterion listed in Section 9.2. Section 121 of CERCLA
stipulates that to be considered for selection in the ROD, an
alternative must be protective of human health and the environ-
ment and able to attain ARARs, unless a waiver is granted. For
those alternatives that met these statutory requirements, the
U.S. Army, U.S. EPA, and MPCA focused on the other evaluation
criteria, including short-term effectiveness, long-term effec-
tiveness, implementabi1ity, permanently reduced M/T/V of
contamination, and cost.
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Thermal treatment technology satisfies all of these crite-
ria, particularly permanence. On-site thermal treatment was
found to be more cost-effective than off-site thermal treatment.
Additionally, the short-term impacts associated with off-site
treatment, such as increased truck traffic and the transportation
of contaminated materials untreated over long distances through
public access areas, are considered to be less acceptable than
the construction impacts associated with on-site thermal treat-
Bent .
The U.S. Army, U.S. EPA, and MPCA also considered nontechni-
cal factors that affect the implementabi1ity of a remedy, such as
state and community acceptance. Based upon this assessment,
taking into account the statutory preferences of CERCLA and SARA,
the thermal treatment approach was selected for the site.
11.0 STATUTORY DETERMINATIONS
The interim remedial action selected for implementation at
the site is consistent with CERCLA, SARA, and, to the extent
practicable, the NCP. The thermal treatment alternative addresses
the five statutory criteria in the following manner:
(1) Protects Human Health and the Environment
Thermal treatment will permanently reduce the risks presently
posed to human health and the environment by preventing
exposure to contaminated soils.
(2) Attains ARARs
This remedy will meet all applicable federal, state, and
local ARARf that apply to the site. Federal environmental
laws t'r.ax. apply to the selected remedial action at the site
include:
Resource Conservation and Recovery Act (RCRA)
Clean Water Act (CWA)
Toxic Substances Control Act (TSCA)
Clean Air Act (CAA)
Occupational Safety and Health Act (OSHA)
During removal and thermal treatment of PCB-contaminated
soil, air emissions will be monitored and all relevant
federal and state standards will be attained. Specifically,
the National Ambient Air Quality Standards (NAAQS) will be
met through specified techniques for activities, as well as
required air monitoring during removal, to ensure that
site-specific ambient levels are not exceeded.
OSHA regulations include 29 CFR 1910.120, which specify
standards for handling hazardous wastes, and 29 CFR
1910.1000, which sets allowable ambient air concentrations
for VOCs in the workplace. Suppressant foams and air-puri-
fying and filtering devices will be used to comply not only
with OSHA regulations but with any federal and state air
quality standards.
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(3) la Cost-Effective
The estimated cost of on-site thermal treatment may be
somewhat higher than several of the other remedial alterna-
tives. However, the U.S. Army. U.S. EPA, and MFCA believe
that the selected remedy is cost-effective because it will
permanently destroy the PC'B contamination at the site.
(4) Employs Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable
Thermal treatment technology provides a permanent solution
to the PCB problem at the site. Removing and treating the
PCB-contaminated soil will reduce the risks posed to human
health by virtual complete destruction of PCBs, as well as
by eliminating the potential risk of release of PCBs from
the soils into groundwater.
(5) Satisfies the Preference for Treatment as a Principal
Element to Reduce Mobility. Toxicity. or Volume
Thermal treatment of PCB-contaminated soils will reduce the
M/T/V of the contaminated soils and will minimize the threat
posed by these soils to human health and the environment.
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PUBLIC MEETING
PCB-CONTAMINATED SOILS
INTERIM REMEDIAL ACTION PLAN
JUNE 15, 1969 - 7:00 P.M.
NEW BRIGHTON CITY HALL
Opened at 7:00 P.M.
Clarence Oster: Please, all of you that have not signed up out
at the entrance way, please sign up so we can get your name and
address and then when we have future such gatherings as this we
can make sure that we can get you on the mailing list. This
podium over here will be set up for those of you that want to
make individual statements following this public meeting. We
ask that you use the mike and ask that you state your name so
that we can get that all down on tape.
My name is Clarence Oster and I am the Project Manager for the
Army out at the TCAAP site. With us in our introduction
comments here are Art Kleinrath, who is the Project Manager for
EPA, and Mark Schmitt, Project Manager for the MPCA.
The purpose of this meeting - you will hear more of this from Art
and Mark - is one of many meetings that we hold for many of the
different remedial action programs that we have ongoing out at
the Twin Cities Army Ammunition Plant. Some of you have probably
attended past public meetings, maybe you have seen public notices
on it; but this particular project is one of many of those that
we have ongoing and we will have more of these meetings and there
will be lots more projects that are going to continue.
So with those introductory remarks, I will turn this over to Art
Kleinrath.
Art Kleinrath: I am Art Kleinrath and I work for U.S. EPA out of
their Chicago office, Region V. I am assigned by the Superfund
Division there to be the Remedial Project Manager at the Twin
Cities Army Ammunition Plant. What we are here to talk to about
tonight is the proposed thermal treatment of contaminated soils
that rests on the TCAAP site. What we are going to be discussing
has been considered and studied for quite a long time by the
Army, the MPCA, and the U.S. EPA, all in coordination and cooper-
ation with each other. The U.S. EPA believes that this proposed
remedy for destruction of the contaminants is the best alterna-
tive that we have to do with the soil.
As Clarence mentioned, tonight is-part of the decision-making
methods that we use in Superfund projects. What we have done is
we have collected a set of alternatives - remedies that we can use
for the contaminated soils - and we have chosen one and we propose
to go forward with it. What we are asking for tonight is public
input into that decision-making process, and that can be done
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•ither in written form mailed to the address on the News Sheets
that are out front at the door, and taken as oral comments
tonight. We will be having a taped transcript of this meeting
and each and every comment will be considered before any final
decision is made. The responses to those comments would be put
in writing in a document called the Responsiveness Summary that
would be issued at the same time as the final decision. The
procedure that we are following is the procedure that is followed
for Superfund and we are desiring your input into this process,
but the thing to understand is this is also your right under the
law. In order to help separate the questions from the comments.
I think it might be a good idea if we took the questions after
the presentation separately and will ask for comments to ensure
that everybody's comment can get included in the decision-making
process. This effort that is culminating this proposal that we
are putting forth tonight has been jointly worked on by the Army
and the U.S. EPA and the Minnesota Pollution Control Agency. Now
what I would like to do is turn over the microphone to Mark
Schmitt of the Minnesota Pollution Control Agency.
Mark Schmitt: Thanks, Art. My name is Mark Schmitt and 1 am
Project Manager for the TCAAP site for the Minnesota Pollution
Control Agency, and I am here to represent the interest of the
State as regards to the proposed remedial action at TCAAP on the
thermal treatment of the contaminated soil. I am here to express
support and reiterate some of the opinions you have heard already
from Mr. Oster and Mr. Kleinrath, that MPCA has for some time now
been working rather closely with the Army and with EPA in evalu-
ating the potential remedial action that we are discussing to-
night. I am here now and I want to go on the record as saying
that the MPCA enthusiastically supports the proposed remedial
action. As we will hear later in the program this evening, there
are many alternatives that were considered and it's our opinion
that the one that is being proposed as the final remedy is far
and away the best option. It would have been very easy for the
Army to pursue other options that would have been less expensive,
but of particular satisfaction to the MPCA is the fact that the
Army is choosing an option which will not transplant the contami-
nated soil but will actually destroy the contaminants in the
soil. As a state representative here, I am very interested in
hearing your opinion on the proposed remedial action and I want
to also assure you that irregardless of the remedial action that
ultimately is implemented here, that MPCA staff will be on sate
to monitor the activities that's going to go on, and with that,
I'll turn it over back to Clarence.
Clarence Oster: Thanks, Mark. My remarks are going to be very
brief and they are going to involve the Record of Decision, which
has been out on public notice for approximately three weeks.
Will stay out there so that written comments can still come in
until June the 22nd.
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The Record of Decision basically uses the analysis of the
alternatives and this is what those are based upon, as you can
see on this slide. The Technical Feasibility, the Implementation
Timeframe, the Regulatory Compliance, Cost, and the Environmental
Effectiveness. The five alternatives that were looked at and are
listed in the Record of Decision are the ones that you see on the
•lide. No. 1 of course is no action, which means that you
leave the stuff there and you don't do anything with it, which I
don't believe anybody feels is a very good idea. The monitoring
would continue, etc. The next one talks about transferring it
to another storage facility within the TCAAP. The third one is
off-site disposal which involves hauling the materials to a
hazardous waste landfill out of the state - there are none in
Minnesota, so we are dealing with something in Ohio, Illinois,
Oklahoma, or some place like that. The fourth alternative is
on-site thermal treatment which is the preferred method and
that's the one that we are going to discuss more in detail this
evening for your information and for your comments and
suggestions. Lastly, we looked at off-site thermal treatment
which means that you haul the material to a hazardous waste
incinerator which might be in Arkansas, Oklahoma, or wherever.
These are the alternatives that were looked at. Again, like I
said, the on-site thermal treatment was looked at because of the
following reasons: no transportation of hazardous waste is
required; it's a permanent solution which everybody likes - it
eliminates the future liability; and then, it is the EPA/MPCA/
Army preferred alternative. Now, to cover more of what this
remedial action plan is, we have consultant Norm Wenck who will
show you slides also and he will talk to you in detail about what
that remedial action plan is.
Norm Wenck: Thank you, Clarence. Wenck Associates is a consult-
ing engineering firm and we are located out in Wayzata. We have
been involved with this project since 1985. The purpose of the
overall project was to clean up a contaminated area here called
Site D, which is in the center of the Twin Cities Army Ammunition
Plant. It is approximately a mile from any direction from the
fence line. I am going to show a few slides about taking out
this soil, what we did with it, and something else that we are
doing with this site that was the reason that we found it. The
soils were discovered there contained PCBs. This is a view of
the site before they were removed. They were discovered through
some drilling, soil samples that were taken. It was decided to
remove these soils before another action was taken. They were
taken froa the site and moved approximately 100 feet to an area
that was prepared. We laid down a 40-mil liner, the seams were
all heat sealed, the contaminated soil was placed on this liner.
it was then sampled and tested, and then we ended up covering the
liner and sealing it all around, and it's sort of like a ravioli
sitting out there today. It has been monitored over the years.
Like I said, it has been there since November-December of '85.
It's in a secure area at this time and will continue to be until
the action is taken. What we did with that site is built a
vacuum system to clean the soils from other organic contaminants
that were there. That has been successfully been operating, and
it's operating today.
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The particular subject tonight that I want to talk about is the
remedial action plan which is this document that I am just going
to briefly highlight some of the things in the plan. This plan
was developed after the selected alternative of on-site thermal
treatment was, and only deals basically with the on-site thermal
treatment.
As I said, the soil is presently stored there with a security
fence. .In 1967, a series of demonstration test burns were
performed using the technology that's proposed here, and achieved
what's called six nines (99.9999X) removal of the PCB contami-
nants. Tests were performed on the ash and it was found to be
not hazardous according to the RCRA requirements. The PCB soils
will be treated to below two parts per million, or two milligrams
per kilogram. The purpose of the plan is to thermally treat the
soils in conforsiance with what's called TSCA - the Toxic Sub-
stances Control Act - and the thermal treatment unit that will be
used is presently permitted and has gone through rigorous moni-
toring and testing to make sure that it will meet the EPA re-
quirements. The work plan, of which I have been talking here,
describes the remedial actions and presents the detailed informa-
tion on that thermal treatment. I am going to be covering mostly
in a general manner and then we are going to have Greg McCartney
talk about specifically the thermal treatment method and technol-
ogy.
The soils, as I showed you, are contained in the liner. They are
about 1400 cubic yards of soil. The average PCB contamination
level is 70 parts per million, or .007% - a very low level. When
we removed it, the level, if the soil would have been below 50, it
could have basically stayed where it was. It was over the 50
limit at that time and so that's why we had to remove it.
There are seven parts of the remedial action. First will be the
site preparation which will be to grade the site, install con-
crete pads, (you will see some slides of the equipment that
will be brought in), and put in the connections for the water,
the electricity, the gas, and the sewer discharge. Soil samples
will be taken from below the pads to insure that there is nothing
there before we start because we will be checking after we finish
to see that we did not leave any contamination there. Concrete
pads will be surrounded by 10-inch high curbs to prevent any
water or rain that happens from running off and also from rain
running onto the site. Any run-off or water that's collected
during the process will be treated. The concrete will be sealed
so that when we are through we will be able to clean it properly.
Then equipment will come in. It's contained in about 15 trucks.
After this mobilization it will be set up, installed, and you
will see some more details on that. There is a start-up and
check-out protocol to make sure that everything is working
mechanically and electrically, there is computer control and
lots of checks that will be performed.
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Then we go to the soil handling. If there are over-sized objects
to be crushed, there will be a crusher on site to make sure the
materials are all one inch or smaller in size. Fuel oil will be
mixed to increase the BTU content of the soils, and then will be
fed to the incinerator which has a primary chamber, a secondary
chamber, and air pollution control devices, gas scrubber. The
process is computer controlled and all the time there are opera-
tors on-site controlling it, constant monitoring of emissions,
constant monitoring of the oxygen, carbon dioxide, and carbon
monoxide - which are the parameters to control the process - in
addition to temperature. The clean soils come out; they are
tested for PCS, and they are held until we get one-day turnaround
soil sample analysis so that we know that soils in the cleanup
are below 2 mg/1, and then they are stored near the site where
they will remain. If they do not meet the level of two parts per
million, they will be recycled. There will be other residuals
that will result. From scrubber, solid st«p media, filter media;
these again will also be sampled and if th*y have PCBs they will
be incinerated. There are other tests called EP Toxic tests that
will be performed. If there are any problems there, these mate-
rials might have to be handled as hazardous wastes and they would
be drummed and properly handled.
So we have the clean soils, the other residuals, we have permis-
sion from the MWCC to discharge any clean water that doesn't
contain PCBs that we are using in our process. It is held until
the test results come back and then we get permission from the
MWCC to discharge that water.
Then the final thing is decontamination of the equipment and of
the pad and the work area. We check that, seu 1 sampling, wipe
samples on the pad, etc. If there is any ctmtamination, it is
taken care of and possibly some of it may be incinerated and
then, of course, decontaminated again to make sure we have
removed all the soil.
We have a number of things that we are monitoring. I have sort
of listed them as I have gone along but we will be monitoring the
ambient air, the air on the site and at the property boundary of
TCAAP, to take background measurements before we start, and every
day will be taking measurements. People from our firm will be
doing that because as we get finished with the job we will be
certifying that it was done in accordance with the plan. We will
be sort of overview of the project as it continues.
The stack emissions, as I have mentioned, will be continuously
monitored. The oxygen, CO and CC>2 will be monitored on a contin-
uous basis, continuous records. As mentioned, the soil will be
monitored before each batch is classified as clean, and also then
as we finish there will be monitoring decontamination of the
water that's used, the equipment, the pad, and the area.
There are some other considerations we might just touch on. That
is site control - no one will be in the area that isn't required
to be there. The area will be surrounded by the same kind of
fence that we show around the storage area right now. We have a
health and safety plan that prescribes how people dress when they
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Are working Around this and what kind of gloves they wear,
overalls and boots, and that level of safety that they need to
have while they are working.
Then documentation as I mentioned - we will be on site during the
work and wall be accumulating all the operational records, the
process records, the monitoring records, and the daily logs, and
putting them into a documentation report which will be prepared
as part of the certification that it was completed in accordance
with the plan.
The proposed schedule for the work is broken down into five
activities - site preparation from the day of approval to proceed
will take three and a half weeks, mobilization just a few days or
a half week, putting all the equipment together is two weeks, the
actual thermal treatment of the soil will take three weeks. It
will be a 24-hour day operation. To decontaminate and demobilize
will be another two weeks. It's about a twelve and a half week
time period from the time to go ahead to hopefully we will be out
of here and gone.
That's the end of my presentation. I would like to introduce
Greg McCartney with OH Materials, who is the firm who has been
contracted to actually do the thermal treatment.
Greg McCartney: Hello, I'm a project engineer with OH Materials.
OH is an environmental services company that has over 20 years of
experience in remediating environmental problems. What I want to
talk to you about today is the OHM thermal treatment process,
which has been chosen as the alternative to be used out at the
TCAAP site.
This is a schematic of the process. This type of technology has
been used for over 60 years in the metal annealing industries.
This is a perfect temperature control type of furnace that can
deliver the needed heat for annealing metal parts for the heavy
equipment. I want to point out some of the aspects of this unit.
The soil is fed to the unit at this point where it is leveled out
and it drops down onto a metal conveyor belt which pulls the
waste through the thermal treatment unit. There are electric
heating outlets mounted above on this unit which heat the soil up
to approximately 1200° Fahrenheit, at which temperature all the
organics will leave the soil, thus leaving the soil free of
contamination by the time that it exits the unit. The organics
are then taken over to a secondary combustion chamber. This is
the place where the organics that are contained in the waste are
actually destroyed. This chamber is operated at over 2000°
Fahrenheit. After this, the organics are combusted in this unit.
This is the primary chamber (slide) being brought onto our first
project which was a Superfund project down in Florida. That
project consisted of over 18,000 tons of materials that were
contaminated to a level that was approximately three times more
concentrated than at the TCAAP site.
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This 18 th« chamber (slide) being backed onto the site. You can
•ee it's a big piece of equipment.
This is a slide of the conveyor belt which is inside the chamber.
This conveyor belt can reach temperatures of 1600° Fahrenheit.
These are the secondary chamber modules (slides) before they were
mounted on the trailer; you can see the 13 inches of insulation
which assures that the 2000° Fahrenheit chamber on the inside
does not come to the outside. The outside skin of this unit is
designed to remain less than 150° Fahrenheit.
This is the scrubber trailer (slide) being brought onto the site.
This is where the gases are cooled, quenched, and scrubbed of
particulars.
This is an overall shot (slide) of the unit as it was set up at
the site in Florida. There was a vacant building at this site so
we decided to utilize it since in southern Florida you do get
quite a bit of rain.
You can see the (slides) primary chamber here, secondary chamber,
air pollution control devices, and then the exhaust fan.
You can also see another exhaust fan here (slide). This is an
emergency backup exhaust fan. The way this system was designed,
it is fail-safe. If we have a power outage, this emergency
backup blower will start automatically on an emergency generator
and the scrubber pumps will also be operated off this unit in
order to include any emissions being discharged during a power
outage. The unit is also equipped with many interlocking devices
in order to make sure that the permit conditions are maintained.
An aerial shot (slide) of the unit as it was set up at one point.
Control trailer, all the control equipment, computer equipment,
monitoring equipment will be in this trailer (slide).
The electrical equipment is located in this trailer - the pri-
mary, secondary, and pollution control devices (slide).
The advantages of the infrared process - there are a couple of
them - is that the waste has a precise time in the chamber. When
it is set for 20 minutes, you know your waste is in there for
exactly 30 minutes. There is very accurate temperature control
since the heat is put into the unit through the electrical heating
elements; you can control the furnace atmosphere: there is a low
combustion gas flow since you are indirectly heating the primary
chamber; there is a high throughput on this trailer so we can get
quite a bit of tonnage through the trailer and thus make the
project shorter. There is also minimal mechanical agitation
inside this unit.
This is a slide of the computer console; there are two completely
redundant systems here so if one fails the other one can be used
to control the incinerator. The operator can monitor the site
with the video screens. He has two-way communication with the
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field and he also has outside communication. On the screen he
has all the motors, pumps, and all the electrical monitoring
devices shown. If anything was to go out of specifications, the
waste feed system automatically shuts down and the operator can
know immediately what the problem is and he can resolve it there.
This is the emissions monitoring equipment (slide) that Norm
talked about - carbon monoxide, carbon dioxide, and oxygen. They
are recorded and monitored on a .continuous basis. This informa-
tion is continuously fed to the computer console and it assures
that the proper permit conditions are maintained inside the
incinerator during the process.
This is the crushing plant (slide) to assure that the waste is
all sized less than one inch before it's placed into the inciner-
ator .
This is the feed hopper (slide) for the incinerator. At that
point is the last time the material is exposed to the outside
atmosphere; from thereon it is totally enclosed into the primary
chamber where it is leveled out and thermally treated. The
thermal treatment unit also has negative draft on the entire
system. Therefore, if there is a leak from the unit, it is
leaked into and not out of the unit.
Picture inside the primary.
The shot inside the secondary where the 2000° temperature and
four-second retention time for gasses to release.
This is the air pollution control device and the exhaust stack
(slide).
Here is the point (slide) where the soil enters the unit at this
far end, you can see the controls here. It comes out this end
after it has been decontaminated and is loaded into a truck and
transported to an analytical storage area where the verification
of the cleanup criteria is established.
This unit has been through a very comprehensive demonstration
program with the U.S. EPA out of Washington, DC, the Office of
Toxic Substances. We have completed over eight demonstration
runs with this unit, during which all of the guidelines and
requirements were exceeded for the destruction of PCBs. With
that, we have been authorized by the U.S. EPA in order to use this
on other sites.
Clarence Oster: That's the conclusion of what this project is
and our presentation to you. I guess at this point is when we
open it up, and Art indicated we should try to keep it for ques-
tions first. So, are there any questions'5 Again, if you would
please, if you would step up to the mike and state your name and
I guess it doesn't have to necessarily be to your affiliation,
but at least so that we know or we can trace you back to the regis-
tration slip.
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If there aren't any questions, are there any comments'?
My name if Mar*- Murlowski mad I live in Mew Brighton. I WAS Just
curious - if there going to be required to have a performance
bond tor this particular work through the company that la going
to be doing the remedial action? Did bonding ever enter into it?
Clarence - Maybe I can take a shot at that. Performance bond
normally does not enter into these that I am aware of, but what
has been used in this case is the past testing and, as you heard
from OH and from the regulatory agencies, that they have a
hazardous waste permit for this unit. So based upon that, is
the go ahead to do the work.
Mark Murlowski: Where doee the ultimate liability rest then, if
there was a problem?
Clarence - I guess the ultimate liability would rest with the
Army, who is funding all the remedial action projects.
Greg McCartney: Clarence. I think I might be able to clarify
something here. In obtaining our National TSCA permit, we
needed to supply financial assurance for the closure of the unit,
which is provided to the EPA in Washington. If there was a
problem, the EPA in Washington has the funds to demobilize,
decontaminate, and remove the incinerator from the site. That is
a part of the requirements to obtaining the permit; that way the
liabilities are covered.
Mark: So liabilities are covered through the government again,
rather than through a private firm such as yourself.
Greg: No, we provide the assurances.
Mark: The government holds the assurances?
Greg: As a private contractor, we have to provide those and they
are supplied to the government and they are given the authoriza-
tion to use it.
Carlos Stern: As I understand it, the payment is based on
achieving the performance level, and if they don't achieve the
performance level they have to keep doing the job until they do
or they don't get paid. The goal that Clarence described is the
necessary point for receiving payment.
Mark: My quest ion more was with regard to, rather than them being
paid for the job done adequately, is in case there was a problem,
is there an insurance company that backs up the problem or is
there ultimately a performance bond to kick in, that type of
thing? I mean, a liability could be tens of millions of dollars
where possibly this action is significantly less than that.
Clarence: I'm not aware of anything like this, unless some of
the consultants are. I know the consultants have a real concern
about liabilities, etc., and Congress has been fighting with this.
If there are some lawyers in the audience, perhaps they may have
some idea. Carlos?
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Carlos: I'm not a lawyer, but in similar situations my experi-
ence has been that unless there is negligence on the part of the
contractor, the responsibility basically is with the party that
generated the waste. They have the liability now. This is the
way to terminate the liability that's there already. If a prob-
lem emerges of a type, I don't know what you have in mind, there
would be an argument I imagine between the Army and the contrac-
tor as to whether they behaved and acted in a professional man-
ner .
Clarence: I could visualize, let's say that we haul this
material off site to a landfill in Oklahoma and along the way,
either by train or trucks or whatever, there were accidents or
something happened and the materials ended up on the roadside and
whatever, those materials will still be the responsibility of
whoever, in this case the Army, so we would have to go out there
and clean it up. We would probably go after that firm that did
the work, like Carlos says, to see if they acted in a responsible
manner. If it was a complete accident, if a tornado went through
or something, well then you know that's something by itself.
Clarence: Are there any other comments from Art or from Mark7
Art: Just in terms of the performance, I think the one thing to
really truly remember here is that assurances were performed - in
terms of the system that's been set up, in terms of the trace of
that system, and in terms of the fact that the contaminated
material won't be put to rest permanently until it has already been
checked and the operating conditions will be continuously moni-
tored to know that fact in order to ensure that things don't go
wrong.
Clarence: Art, what do you do in other Superfund sites where
this cleanup goes on and whatever may happen?
Art: Well, there is an indemnification for things that are
done under Superfund. In case of situations as the Army, we look
at the Army or whatever the party would be.
Clarence: Or if the industry did it, you would look at them to
carry it through all the way.
Art: Correct.
Clarence: Are there any other comments, questions. OK, like I
said before, if something else comes up. the record will stay
open, as the Record of Decision is being advertised, until June
22nd. Thank you very much for attending. We hope that we'll see
you at the next one.
Adjourned at 7:45 P.M.
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