PB98-964304
EPA 541-R98-167
March 1999
EPA Superfund
Record of Decision:
Iowa Army Ammunition Plant
OU1
Middletown, IA
9/29/1998
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RECORD OF DECISION
IOWA ARMY AMMUNITION PLANT
SOILS OPERABLE UNIT #1
MIDDLETOWN, IOWA
DEPARTMENT OF THE ARMY
CORPS OF ENGINEERS
OMAHA DISTRICT
OMAHA, NEBRASKA
AUGUST, 1998
This document is intended to comply with the
National Environmental Policy Act of 1969
Iowa Army Ammunition Plant
Soils OU«M, Record of Decision (Revision No. 1)
August 14,1998
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TABLE OF CONTENTS
List of Tables 3
List of Figures 4
List of Acronyms 5
1.01 DECLARATION 7
Site Name And Location 7
Statement of Basis And Purpose 7
Assessment of The Site 7
Description of The Selected Remedy 8
Statutory Determinations 9
Concurrence 11
2.0 DECISION SUMMARY 12
2.1 Site Name, Location, and Description 12
2.2 Site History and Enforcement Activities 16
2.3 Highlights of Community Participation 17
2.4 Scope and Role of Operable Units 18
2.5 Summary of Site Characteristics 19
2.6 Summary of Site Risks 19
2.7 Description of Alternatives 22
2.7.1 Alternatives for Explosives-Contaminated Soils 22
2.7.2 Alternatives for Explosives plus Metals Contaminated Soils 31
2.7.3 Alternatives For SVOC-Contarainated Soils 33
2.8 Summary of the Comparative Analysis of Alternatives 34
2.8.1 Evaluation of Alternatives For Explosives - Contaminated Soils 35
2.8.2 Evaluation of Alternatives for Explosives Plus Metals Contaminated Soils ... 37
2.8.3 Evaluation of Alternatives for SVOC-Contaminated Soils 39
2.8.4 Environmental Consequences (NEP-A-EvUhlation) 40
2.9 Selected Remedy 41
2.9.1 Description 41
2.9.2 Remediation Goals 44
2.10 Statutory Determinations 47
2.10.1 Protection of Human Health and the Environment 47
2.10.2 Compliance with ARARs 47
2.10.3 Cost Effectiveness 59
2.10.4 Use of Permanent Solutions and Alternative Treatment Technologies 59
2.10.5 Preference for Treatment Which Reduces Toxicity, Mobility, or Volume .... 60
2.11 Documentation of Significant Changes 60
3.0 RESPONSIVENESS SUMMARY 61
3.1 Overview 61
3.2 Background on Community Involvement 61
3.3 Summary of Public Comments and Agency Responses 63
Iowa Army Ammunition Plant
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LIST OF TABLES
Table 1 Source and Disposition of Soils 20
Table 2 CAMU Contents 21
Table 3 Costs Alternative EIA: Incineration 24
Table 4 Costs Alternative EB Lttd 26
Table 5 Costs Alternative E2A: Composting 28
Table 6 Costs Alternative E2B: Bio-Slurry Treatment 30
Table 7 Alternative Cost Comparisons Explosives 37
Table 8 Alternative Cost Comparisons Explosives plus Metals 39
Table 9 Alternative Cost Comparisons SVOCS 40
Table 10 Selected Remedy Costs Explosives-contaminated Soils 42
Table 11 Selected Remedy Costs Explosives plus Metals Contaminated Soils 43
Table 12 Selected Remedy Costs SVOC-Contaminated Soils 44
Table 13 Soil Remediation Goals at 10"6 Risk Level Based on Ingestion/Dermal Contact . 45
Table 14 Soil Remediation Goals Based on Soil Leaching 46
Table 15a Compliance of Alternatives with Location-Specific ARARs 48
Table 15b Compliance of Alternatives with Chemical-Specific ARARs 50
Table 15c Compliance of Alternatives with Action-Specific ARARs 55
Iowa Army Ammunition Plant
Soils OU#1, Record o( Decision (Revision No. 1)
August 14,1998
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LIST OF FIGURES
Figure 1 Site Location Map 13
Figure 2 Drainage Basins and Site Features Map 14
Figure 3 CAMU Location 15
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
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ACRONYMS
ATL Alternate Treatment Level
ARAR Applicable or Relevant and Appropriate Requirement
BDAT Best Demonstrated Available Technology
BLRA Baseline Risk Assessment
CAA Clean Air Act
CAMU Corrective Action Management Unit
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
COC Contaminant of Concern
2,4-DNT 2,4-Dinitrotoluene
EPA U.S. Environmental Protection Agency
g Grams
g/dscm Grams Per Dry Cubic Meter at Standard Conditions
g/dlscf Grams Per Dry Cubic Feet at Standard Conditions
HAL Health Advisory Level
LAAAP Iowa Army Ammunition Plant
I.A.C. Iowa Administrative Code
IDNR Iowa Department of Natural Resources
IEQA Iowa Environmental Quality Act
kg Kilogram
LDR Land Disposal Restriction
LTTD Low Temperature Thermal Desorption
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
mg/kg Milligrams Per Kilogram
mg/L Milligrams Per Liter
Mg/yr Megagrams Per Year
"mrem Millirems "--'• ~~~
MSWLF Municipal Solid Waste Landfill
NAAQS National Ambient Air Quality Standard
NCP National Contingency Plan
NESHAP National Emission Standard for Hazardous Air Pollutant
NPDES National Pollutant Discharge Elimination System
NRL Negligible Risk Level
OU Operating Unit
PAH Polynuclear Aromatic Hydrocarbons
PCB Polychlorinated Biphenyl
pCi/L Pico Curies Per Liter
pH Unit of Measure for Hydrogen Ion Concentration
Iowa Army Ammunition Plant
Soils OUUM. Record of Decision (Revision No. 1)
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ACRONYMS (Continued)
PM10
ppm
RCRA
RDX
RI/FS
ROD
SDWA
SVOC
SWMU
TBC
TCLP
1,3,5-TNB
TNT
2,4,6-TNT
TSCA
T/S/D
u.s.c
UST
Particulate Matter (particles with an aerodynamic diameter less than or equal to a
nominal 10 micrometers)
Parts Per Million
Resource Conservation and Recovery Act
l,3,5-Trinitro-l,3,5-triazacyclohexane
Remedial Investigation/Feasibility Study
Record of Decision
Safe Drinking Water Act
SemiVolatile
Solid Waste Management Unit
To Be Considered
Toxicity Characteristic Leaching Procedure
1,3,5-Trinitrobenzene
Trinitrotoluene
2,4,6-Trinitrotoluene
Toxic Substances Control Act
Treatment/Storage/Disposal
United States Code
Underground Storage Tank
Micrograms Per Cubic Meter
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
August 14.1998
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1.0 DECLARATION
Site Name And Location
Iowa Array Ammunition Plant (LAAAP)
Soils Operable Unit #1 (OU#1)
Middletown, Iowa
Statement of Basis And Purpose
This decision document presents the selected remedial action for the Soils Operable Unit # 1 at the
Iowa Army Ammunition Plant (LAAAP) in Middletown, Iowa. The remedial action was chosen in
accordance with the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA), and to
the extent practicable, the National Contingency Plan (NCP). This decision is based on information
in the site Administrative Record file, which is located in the following information repositories:
Iowa Army Ammunition Plant Burlington Public Library
Visitor Reception Area 501 N. Fourth Street
Building 100-101 Burlington, Iowa 52601
Middletown, Iowa 52683-5000 (319)753-1647
(319)753-7710
Danville City Hall
105 W. Shepard
Danville, Iowa 52623
(319)392-4685
The U.S. Army (Army) has coordinated selection of this remedial action with the U.S.
Environmental Protection Agency (EPA). The Arrtiy'is IKeTead agency for implementing the
remedial action at the LAAAP. As the support agency, the EPA oversees the cleanup activities
conducted by the Army to ensure that requirements of CERCLA/SARA, the NCP, and the Federal
Facilities Agreement between the Army and the EPA have been met. EPA concurs with the selected
remedy. The State of Iowa has not participated in the review of CERCLA clean up activities at the
IAAAP and has declined to comment upon the selected remedy presented in this Record of Decision
(ROD).
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 Record of Decision, may present an imminent and
substantial endangerment to the public health, welfare, or the environment.
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
7 August 14,1998
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Description of The Selected Remedy
The IAAAP has been divided into a Soils OU (OU#1), a Groundwater OU (OU#3), and an
Installation-Wide OU (OU#4) to facilitate management of contamination at the site. The Soils OU#1
addresses contamination in the soils. The Groundwater OU#3 addresses contamination of
groundwater within the IAAAP boundaries and potentially off-site. The Installation-wide OU#4
addresses other unacceptable risks not addressed in either OU#1 or OU#3. The Remedial
Investigation for the Soils OU is complete and has been followed by a Feasibility Study (FS).
Additional data have been requested by the EPA to complete the investigation of the Groundwater OU
and the Installation-Wide OU.
An interim remedial action for the Soils OU#1 called for the temporary stockpiling, for future
treatment, of the most highly contaminated soils and the permanent disposal of the remaining
contaminated soils from various sites at the IAAAP. The Interim Action ROD specified that the most
highly contaminated soils will be stockpiled in the on-site Corrective Action Management Unit
(CAMU). which was constructed to specifications which meet Resource Conservation and Recovery
Act (RCRA) Subtitle C landfill requirements. The remaining contaminated soils will be permanently
disposed in either the on-site Soil Repository, which is also constructed to RCRA Subtitle C landfill
specifications, or the on-site Inert Landfill. A synthetic liner (HDPE) and GCL cover system will
cover contaminated soils placed in the Soil Repository. The cover for the Inert Landfill is of similar
design to the Soil Repository cover, absent the GCL. Soils in both the Soil Repository and Inert
Landfill will remain on-site for long-term management.
The remedial action presented in this Record of Decision is intended to provide for treatment and
ultimate disposal of soils, which are being temporarily stockpiled in the CAMU as a result of the
interim action. Soils stockpiled in the CAMU are managed based on the nature of contamination:
• Explosives-contaminated soils
• Explosives plus metals contaminated soils
• SVOC-contaminated soils
Any long-term monitoring needed to evaluate the performance of the remedy, land usage restrictions
as required, a closure plan to address the CAMU, and the identification and inclusion of any other
contaminated areas requiring remediation will be addressed in the Installation-Wide OU #4.
The major components of the selected remedy include:
Explosives-Contaminated Soils
• Excavate explosives-contaminated soil from the CAMU and transport it to a temporary treatment
facility on-site.
Iowa Army Ammunition Plant g
Soils OU#1, Record of Decision (Revision No. 1)
C \\MNOOWSMSMP\ROOAUC7 DOC AlKJUSt 14, 1998
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• Screen, shred and blend the soil to produce a uniform feed material.
• Process the blended soil through a mobile direct-fired low temperature thermal desorption (LTTD)
unit (Selected Remedy) or a temporary Biological Treatment unit (Contingent Remedy).
• Following confirmation sampling, dispose of treated soil according to the following criteria:
A. For soils with cumulative risks less than 10"6, in compliance with LDRs, and exceeding
Summers model remediation goals, dispose in the Soil Repository or under another synthetic
landfill cap on-site.
B. For soils with cumulative risks less than 10"*, in compliance with LDRs, and satisfying
Summers model remediation goals, dispose on IAAAP property in an appropriate manner
protective of human health and the environment. For Biotreated soils, treatment residuals
must also be shown to be non-toxic or not bioavailable at levels posing a threat to human
health or the environment.
Explosives Plus Metals Contaminated Soils
• Excavate explosives plus metals contaminated soil from the CAMU and transport it to a temporary
treatment facility on-site.
• Screen, shred and blend the soil to produce a uniform feed material.
• Process the blended soil through a temporary solidification/stabilization facility.
• Following sampling to confirm compliance with TCLP based remediation goals, dispose of treated
soil on-site in the Soil Repository or under another synthetic landfill cap.
--'—*_ '
SVOC-Contaminate d Soils
• Excavate SVOC-contaminated soil from the CAMU.
• Transport the soil to a commercial waste treatment and disposal facility off-site.
Statutory Determination
The selected remedy is protective of human health and the environment, complies with Federal
and State of Iowa requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This action utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable for this site and satisfies the statutory
preference for remedies that employ treatment to reduce toxicity, mobility, or volume as a
principle element.
Iowa Army Ammunition Plant Q,
Soils OU#1. Record of Decision (Revision No. 1)
c MWOOWSUEMPWOOAMO DOC August 14, 1998
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B ecause this remedy may result in hazardous substances remaining on-site above health based levels ,
depending upon the method of treatment selected, a review will be conducted within five years after
commencement of remedial action to ensure that the remedy continues to provide adequate
protection of human health and the environment. This review may be based on or incorporated into
a similar review which is required to be conducted within five years after commencement of the
Soils OU#1 interim remedial action that disposes contaminated soil in the on-site Soil Repository
and Inert Landfill.
P.E.
Regional Administrator / Eieuienant Colonel, OD
U.S. Environmental Protection Agency Commander, Iowa AAP
Region VII
Norman E. Williams
Major General, U.S. Army
Chief of Staff, U.S. Army Material Command
Date
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
10 August 14, 1998
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CONCURRENCE
ition Remedialrroject Manager
Major Subordinate Command Project Manager
Date /
Date
c
\
V
Installation/MSC Legal Advisor
Date
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
\\Hn-1\FKOJECTS-tttM4_tlttM4ffWOOMUil n*H.i»P
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2.0 DECISION SUMMARY
2.1 Site Name. Location, and Description
The Iowa Army Ammunition Plant (IAAAP) is a load, assemble, and pack (LAP) munitions facility
located in Middletown, a rural area of eastern Iowa, 10 miles west of Burlington in Des Moines
County, and approximately nine miles northwest of the Skunk and Mississippi Rivers (see Figure
1). Croplands comprise about 60 percent of the county; the remaining area is composed of 10
percent urban use, eight percent pasture use, and 22 percent woodland or idle land. The IAAAP is
located on about 19,000 acres. Approximately 8,000 acres are leased for agricultural use, about
7,500 acres are forested, and the remaining area is used for administrative and industrial operations.
Deer hunting is regulated at the IAAAP through the use of permits. Approximately 41 housing units
and 112 acres of land outside of the operating areas of the plant have been transferred to the City of
Middletown. Two housing units remain on-site and are currently occupied by military personnel and
their families.
The northern area of the IAAAP consists of gently undulating terrain. The central portion is
characterized by rolling terrain dissected by a shallow drainage system, while the southern area of
the site contains drainage ways with steep slopes down to the creek beds. Elevations within the
IAAAP range from 730 feet above mean sea level in the north to 530 feet in the south. There are
four principal aquifers in Des Moines county. These include a shallow or surficial aquifer (drift
aquifer) in unconsolidated Recent Pleistocene sediments, and bedrock aquifers occurring in the
Mississippian, Devonian, and Cambro-Ordovician units.
The IAAAP contains four watersheds. Brush Creek drains the central portion of the site, exits at the
southeastern boundary, and flows into the confluence of the Skunk and Mississippi Rivers. The
creek's flood plain at the southern boundary of the site is estimated to be 200 feet wide. Spring
Creek drains the eastern portion of the site, exits at the southeastern corner, and flows off site
directly into the Mississippi River. The creek's flood plain jitthe southeastern boundary of the site
is estimated to be 400 feet wide. Long Creek drains trleTwestem portion of the IAAAP, exits at the
southwestern boundary, and joins the Skunk River just south of the site. The Skunk River then flows
into the Mississippi River. The Long Creek drainage way has been dammed near the center of the
site to create the 85-acre George H. Mathes Lake. Use of this lake by the plant as a water source was
discontinued in January 1977. An open recreation area and a boat ramp used by fishermen are
present at the lake. North of Mathes Lake is the 7-acre Stump Lake, which was built to serve as a
sediment control for Mathes Lake. The flood plain of Long Creek is widest (500 feet) at the
southern plant boundary. The Skunk River is located south of the IAAAP, bordering the site's
perimeter on the southwest corner. The Skunk River provides year-round recreational use. Figure
2 provides a site plan of the IAAAP.
The C AMU is located along the western edge of the Inert Landfill at IAAAP as illustrated in Figure
3. The area is part of the Long Creek watershed.
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
viNn.iu>RCuecTs-<\M44.intwd«ooew4i>/odO}.iiM 12 August 14, 1998
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Figure 1
SITE LOCATION MAP
SOILS OU No.1 RECORD OF DECISION
IOWA ARMY AMMUNITION PLANT
MkJdletown, Iowa
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SOILS OU No 1 RECORD OF DECISION
IOWA ARMY AMMUNITION PI ANT
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Figure 3
CAMU LOCATION
SOILS OU No.1 RECORD OF DECISION
IOWA ARMY AMMUNITION PLANT
Middletown Iowa
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2.2 Site History and Enforcement Activities
The IAAAP produced munitions for World War n from the plant's inception in September 1941 until
August 1945, and munitions for military activities in southeast Asia in the 1960s and early 1970s.
Activities at the IAAAP continued at a reduced level during peacetime. The plant was operated from
1941 -1946 by Day & Zimmerman Corporation. The former Atomic Energy Commission operated
at Line 1 from 1948 through mid-1975, at which time operation reverted to U.S. Army (Army)
control. The Army continues to own the IAAAP, which has been operated by the private contractor
Mason & Hanger Corporation since 1951. The IAAAP currently is operating to load, assemble, and
pack (LAP) munitions, including projectiles, mortar rounds, warheads, demolition charges, anti-tank
mines, anti-personnel mines, and the components of these munitions, including primers, detonators,
fuses, and boosters. Since the installation is an active production plant, inactive lines are maintained
on a standby status or leased to other contractors.
The primary source of contamination at the site is attributable to past operating practices in which
explosives-contaminated wastewaters and sludges were discharged to uncontrolled, on-site lagoons
and impoundments. Additional sources of contamination include open burning of explosives
materials and munitions, and landfilling of waste material. Process wastewaters currently are treated
and recycled, while only a small portion of the treated wastewater, containing residual explosives
and other contaminants regulated under the plant's NPDES permit, is discharged to surface.
Pink/red wastewaters from trinitrotoluene (TNT) operations are a listed hazardous waste (K047)
according to the Resource Conservation and Recovery Act (RCRA).
The U.S. Environmental Protection Agency (EPA) added the IAAAP to the National Priorities List
(NPL) in 1990. The NPL is the EP As list of sites that appear to pose the greatest threat to human
health and the environment, based on the site assessment process. The Department of Defense
(DOD) has established the Defense Environmental Restoration Account to address sites under the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended
by the Superfund Amendments and Reauthorization Act (SARA), that are within the responsibility
~<5f the DOD. The Army, "as an agency within the DODris'ffieTe'ad agency for implementing the
interim remedial action at the IAAAP. As the support agency, the EPA oversees cleanup activities
conducted by the Army to ensure that the requirements of CERCLA/SARA and the National
Contingency Plan (NCP) have been met. The EPA and the Army signed a Federal Facilities
Agreement (FFA) for site cleanup, which became effective December 10, 1990, following public
comment. The FFA provides a framework for CERCLA response actions to be performed at the
IAAAP, including the investigation and cleanup of contamination. The State of Iowa has declined
to participate as a signatory party to this FFA.
Numerous investigations have been conducted at the site by the Army from 1975 to the present to
investigate soil and groundwater contamination. Based on data collected at the site, the Army has
initiated response actions at the IAAAP to address soil contamination at several areas across the
IAAAP. These actions are documented in several Action Memoranda from 1995 through 1997 and
an Interim Action Record of Decision (ROD) signed by EPA in March 1998. During removal
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
16 August 14, 1998
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actions completed at the former Line 1 impoundment and the Line 800 pinkwater lagoon, cumulative
risk levels were determined for soils at each source based on sampling and analysis for contaminants
of concern. Soils with the highest contaminant concentrations were excavated and stockpiled in a
lined storage facility known as a Corrective Action Management Unit (CAMU) for subsequent
treatment. Moderately contaminated soils were excavated and disposed in an on-site Soil
Repository. Lightly contaminated soils were disposed under the synthetic cap of the Inert Landfill
on-site. Excavation of materials from the Line 1 Impoundment and the Line 800 Lagoon was
completed in August, 1997. The remaining areas of soil contamination will be excavated and placed
in the CAMU or in the Soil Repository according to the March 1998 Interim Action ROD.
2.3 Highlights of Community Participation
The RJ/FS and Interim Action Proposed Plan for the Soils OU were released to the public in
November 1996 and May 1997, respectively. These documents were made available to the public
in both the administrative record and the site information repositories. The notice of availability
for the Interim Action Proposed Plan was published in the Burlington Hawk Eye on May 28,1997.
A public comment period was held from May 28, 1997 to June 30, 1997. In addition, a public
meeting was held on June 5, 1997 at the Danville Community Center. At this meeting
representatives from the Army and EPA were available to the public to discuss concerns, accept
comments, and answer questions regarding the preferred alternative presented in the Interim Action
Proposed Plan. There were no written or verbal comments regarding the Interim Action Proposed
Plan submitted to the Army at this meeting or during the comment period, thus a Responsiveness
Summary was not included in the Interim Action ROD.
The Proposed Plan for final action for the Soils OU #1 was released to the public on June 20, 1998.
This document was made available to the public in both the administrative record and the site
• information repositories. The notice of availability for the Proposed Plan was published in the
Burlington Hawk Eye on June 20, 1998 and later in the Ft. Madison Daily Democrat. A public
comment period was held from June 20,1998 to July 19,1998. In addition, a public meeting was
"Held on July 9, 1998 at the Pzazz Best Western Motorttn lifBurlington, Iowa. At this meeting
representatives from the Army and EPA were available to the public to discuss concerns, accept
comments, and answer questions regarding the preferred alternative presented in the Proposed Plan.
All comments received by the Army and the USEPA during the public comment period, including
those expressed at the public meeting, are addressed in the Responsiveness Summary which is
attached to this document.
An LAAAP Restoration Advisory Board (RAB) has been established to enable the community and
representatives of government agencies to meet and exchange information about the lAAAP's environmental
cleanup program and to provide the community an opportunity to review progress and participate in dialogue
with decision makers. The RAB was organized in mid-1997 and has held public meetings generally monthly.
This decision document presents the selected remedial action for the Soils OU#1 at the IAAAP in
Middletown, Iowa, chosen in accordance with CERCLA, as amended by SARA and, the extent
practicable, the National Contingency Plan. The decision for this site is based on the administrative
Iowa Army Ammunition Plant
Soils OIMM. Record of Decision (Revision No. 1)
UH«*1\PROJECTS-l\MM_lM«U|i«ODIM44jindraxM 17 AlKJUSt 14, 1998
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record.
2.4 Scope and Role of Operable Units
Due to the complexity of the problems associated with the IAAAP, the site has been divided into
three OUs to facilitate project management. These are the:
• Soils OU (#1), to address contamination in the soils.
• Groundwater OU (#3), to address contamination of groundwater within the IAAAP
boundaries and potentially off-site.
• Installation-Wide OU (#4), to address closure of the CAMU, institutional controls,
previously unaddressed areas of soil contamination, VOC-contaminated media, ecological
risks, long-term monitoring requirements, and any other unacceptable risks which may be
identified and not addressed in either OU #1 or OU #3.
OU #2 was originally established for the soils interim action, but was subsequently merged into OU
#1 for simplicity and completeness.
The Removal Actions and the Interim Action for the Soils OU #1 addressed the contaminated soils
in a number of areas at the IAAAP. These areas posed an .unacceptable threat to human health and
the environment due to risks from possible ingestion or dermal contact with soils, and due to
potential contaminant leaching from soil to groundwater. Under these actions, soils contaminated
at levels posing a potential health threat, or acting as a potential source of continuing groundwater
contamination, were contained in on-site landfill facilities. Highly contaminated soils were
stockpiled in the CAMU for subsequent treatment, while moderately and lightly contaminated.soils
were disposed permanently in a Soil Repository or beneath an Inert Landfill cap on-site. Potential
groundwater impacts as measured by Summer's model and Land Disposal Restrictions (LDRs) were
"also considered in identifying principal threats and loW-leveTThreats. This ROD provides for
treatment and ultimate disposal of the soils representing the principal threat at the IAAAP which
have been stockpiled in the CAMU under the Soils OU #1. Substantial on-site activities associated
with treatment will commence within 15 months of the physical completion of the interim remedial
action for the Soils OU#1. The action specified in this ROD is intended to be the final action under
the Soils OU (OU # 1) at IAAAP. Separate RODs will be issued for the Groundwater OU #3 and
the Installation-Wide OU #4 to provide an opportunity for the public to comment on cleanup plans
under consideration for those areas.
Iowa Army Ammunition Plant
Soils OU01, Record of Decision (Revision No. 1)
\wi»np*aoECTs-i\M*on»uiiwoD«eui»ndB2.
-------
2.5 Summary of Site Characteristics
Table I summarizes the sources and quantities of soils removed under Removal Actions or Interim
Action. Only the soils stockpiled in the C AMU are intended to receive additional treatment under
this ROD prior to final disposal. Table 2 identifies the individual sources, quantities, and
characteristics of soils stockpiled in the CAMU. Soils identified in this table are characterized as
follows:
Approximately 9,000 cubic yards of soil contaminated with explosives.
• Approximately 600 cubic yards of soil contaminated with explosives plus metals.
• Approximately 200 cubic yards of soil contaminated with semi-volatile organic compounds
(SVOCs).
The Interim Action ROD identified approximately 300 cubic yards of soil to be excavated and
stabilized because of the presence of radionuclides. However, there is currently uncertainty whether
these soils are contaminated above naturally occurring levels. If excavation and treatment ultimately
is required, these soils will be addressed later under a separate OU or response action
Excavation of materials from the Line 1 Impoundment and the Line 800 Lagoon was completed in
August, 1997. The remaining sources will be excavated and placed in the CAMU or in the Soil
Repository according to the March 1998 Interim Action ROD. Volumes and concentrations of
contaminated soil to be removed from these remaining sources are estimated based on limited site
sampling. The actual volumes and characteristics will be determined based on additional
confirmation sampling during the Interim Action. Actual volumes and characteristics may vary from
those shown in Table 2. However, since the greatest volume of soil to be treated originated from the
Line 1 Impoundment and the Line 800 Lagoon excavation, which has already been completed, the
total volumes and characteristics presented in Table 2 are considered representative for the purposes
"of this ROD. ~ "•••-•-" '~~
2.6 Summary of Site Risks
During the RI/FS, an analysis was conducted to estimate the health or environmental problems that
could result if the soil contamination at LAAAP was not cleaned up. This analysis is referred to as
a Baseline Risk Assessment (BLRA). In conducting the BLRA, the focus was on the health effects
that could result from direct exposure to contaminants as a result of the soil coming into contact with
the skin, or from direct ingestion of the soil. The analysis identified explosives as the major
contaminants of concern. Metals and semi-volatile organic compounds (SVOCs) were also
identified as contaminants of concern at certain sites. The BLRA for the IAAAP identified
unacceptable risk based on a future commercial/industrial land use setting due to possible incidental
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
WM-1\PROJECT$-1\S«44_«l'M44|lWOO\M44|in«>2.Bpll 19 AUQUSl 14, 1998
-------
TABLE 1
SOURCES AND DISPOSITIONS OF SOILS
SOURCE
DISPOSITION
INERT
LANDFILL
CAMU SOIL REPOSITORY CAP TOTAL
Criteria:
Removed Under Removal
Line 1 Impoundment
Line 800 Lagoon
Subtotal (cubic yards)
A ; B
Action (Currently stockpiled)!
618 1,2341
6.803 12,133!
7,421 13,3671
Removed Under Interim Action (To be removed) |
Line 1 (R01)
Line 2 (R02)
Line 3 (R03)
Line 3A (R04) ,
Lines 4A&B (R05)
Lines 5A&B (R06)
Line 6 (R07)
Line 8 (R09) ]
Lin09(R10) '
Linr800(R11)
East Bum Pas (R1 2)
Demolition Area (R15)
West Bum Pads (R24)
North Bum Pad (R25) '
Roundhouse (R28)
402
86 i 452
1,395 1751
327 442
0| 0|
187i 244!
0, 401
0! 0
0 Oi
0 1,095!
140! 293I
0' 0
0 0
0! 41
0 599
3,742
Subtotal (cubic yards)
C : D
:
I 6,418 8,270
55.800. 74,736
i 62.218 83,006
I ' '
3,960 1,874. ' 6,236
1,117 293 1.948
1.0861 837! 3.493
0! 1,267( 2.036
1531 01 > 153
Oi 300! I 731
44| 0 445
476J OI 476
469 1 Oi 469
117 113| 1,325
Oi 20,978) 21.411
753 1 Oi : 753
1,112 339! 1.451
00 41
00 599
9.207; 26.001\ i
2,537! 39,030 * « 41.567
i
Total (cubic yards)
I !
9,958 52,397 i 62,2181 124,573
! I
: : I ;
Criteria:
1
A(rfsfc>10-5): Place in CAMU ~ - • "-•-». r- I :
B (risk between. 10-6 & 10-5): Place in Soil Repository
C (risk <10-6, w/ metals): Place in Cap
D (risk <10-6, w/o metals):
Place in Cap
! i
i i
! i
i I I
* Inert Landfill not available for additional fill
i
Data taken from: Focused
Feasibility Study, Appendix E (5-8-98)
1
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-------
ingestion and dermal contact with contaminated soils. The BLRA also identified unacceptable risk
associated with potential consumption of contaminated groundwater on-site. Site soils have been
determined to be acting as a continuing source of groundwater contamination at unacceptable levels.
The BLRA provided the basis for the response actions that determined what soils were to be
excavated and either disposed in the Soil Repository of the Inert Landfill or stockpiled in the CAMU
for subsequent treatment. Under the CERCLA, containment of low level threats is acceptable while
treatment of principal threats to permanently reduce contaminant toxicity, mobility and volume is
preferred. Principal threats are defined as the most highly contaminated, most toxic, and most
mobile source materials. Under the Interim Action ROD, highly contaminated soils (cumulative risk
greater than 10'5) were considered to represent the principal threat and therefore were stockpiled in
the CAMU for treatment at a later date. Moderately contaminated soils (cumulative risk between
10'5 and 10"6) and lightly contaminated soils (cumulative risk less than 10"*) were considered to
present low-level threats and therefore were permanently disposed in the Soil Repository or the Inert
Landfill cap. Potential groundwater impacts as measured by Summer's model and LDRs were also
considered in identifying principal threats and low-level threats.
The BLRA presents risks associated with the "baseline" condition at the site prior to execution of
any response actions. For the purposes of this ROD the "baseline" conditions as defined in the
BLRA no longer exist because response actions been taken or are planned to abate certain site risks.
2.7 Description of Alternatives
Separate alternatives were developed forsoils contaminated with explosives, soils contaminated with
explosives and metals, and soils contaminated with SVOCs. The Superfund program requires that
the "no-action" alternative be considered as a baseline for comparison of other alternatives. The "no-
action" alternative was evaluated as part of the OU # 1 Interim Action, which is the precursor to this
Final Action for OU # 1. Since the Final Action is intended to address treatment of the principal
threat, the "no-action" alternative was not considered further.
2.7.1 Alternatives for Explosives-contaminated Soils
Approximately 9,000 cubic yards of soil are identified as being contaminated solely with
explosives, without metals contamination exceeding LDRs. Alternatives for treating soils
contaminated solely with explosives are as follows.
Alternative E1 A: Incineration
This alternative consists of on-site incineration, with disposal of incinerator ash in an on-site
landfill; because metals concentrations in the soils are low, it is assumed that additional
treatment of incinerator ash (i.e., solidification/stabilization) will not be required. The
principal elements of this alternative are as follows:
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
wm.i\p«QjicTs.i\M44_«i»»44(iwoo»«urtA>d02«i»i 22 August 14, 1998
-------
Excavate explosives-contaminated soil from the CAMU and transport it to a
temporary treatment facility on-site.
Screen, shred and blend the soil to produce a uniform feed material.
Process the blended soil through a mobile rotary-kiln incinerator to achieve disposal
criteria outlined below.
Following confirmation sampling, dispose of treated soil (ash) on-site either:
a. For soils with cumulative risk less than 10"*, in compliance with LDRs, and
exceeding Summers model remediation goals, dispose in the Soil Repository
or under another synthetic landfill cap on-site.
b. For soils with cumulative risk less than 10*, in compliance with LDRs, and
satisfying Summers model remediation goals, dispose on 1AAAP property in
an appropriate manner protective of human health and the environment.
Incineration is the primary treatment technology used under this alternative. Incineration is
a thermal treatment method in which organic compounds are oxidized at elevated
temperatures (combusted) and decomposed into basic products of combustion such as carbon
dioxide (C02), water vapor, and (in some cases) inorganic gases. In most incinerator
applications, an auxiliary heat source such as fossil fuel-fired burners is used to achieve the
temperature necessary to evaporate water from the feed material and combust the organic
compounds. Emissions from the incinerator will be controlled with proper emission control
devices such as a baghouse, and by routing off-gases through an afterburner for complete
combustion of gases prior to release to the atmosphere. Results from a trial burn will be used
to define operating parameters for the incinerator. During a trial burn, the incinerator will
be operated for-a specified regulatory durajiop ^wwiet assumed operating conditions to
monitor performance, emissions, and operational safety.
Capital costs for incineration include mobilization and project planning; site preparation;
erection of a temporary shelter for stockpiled soil; conduct of a trial bum; and demobilization
and site restoration. Operating costs include excavation of soils from the CAMU; incinerator
operation; labor; utilities; confirmation sampling; and disposal of treated soil in the Soil
Repository. Corps of Engineers program management costs are additional. For cost
estimating purposes, the treatment unit is assumed to be located adjacent to the CAMU and
disposal is assumed to be in the Soil Repository. Treatment capacity is assumed to be
approximately 250 tons/day based on commercially available equipment, experience at other
sites, and consideration of the clay soil at LAAAP. Costs for treatment of 9,000 cubic yards
of explosives-contaminated soil are estimated as follows:
Iowa Army Ammunition Plant
Soils OLWM, Record of Decision (Revision No. 1)
uHM.i<> 23 August 14, 1998
-------
TABLE 3
Costs
Alternative EIA: Incineration
Capital Cost
Operating Cost
Subtotal
Project Contingency
Total Project Budget
Unit Rate
$ 370/cy
30% '
Cost
$ 4,600,000
$ 3,330,000
$ 7,930,000
$ 2,380,000
$10,310,000
This represents a present worth value of $10,310,000. Details of these cost estimates are
presented in the Feasibility Study report.
Remediation could be completed in less than two months of incineration. Additional time
would be required for planning, design, mobilization, conducting a trial bum and obtaining
approvals, and for demobilization. These activities are expected to require approximately
two additional years.
Significant applicable or relevant and appropriate requirements (ARARs) for this alternative
include requirements relating to ambient air quality and air emissions specified under IAC
28.1 (455 B), IAC 22.3 (3), IAC 23.3 (2) (a) and Table 1, and IAC 23.3 (a) (c) (1),
CERCLA's preference for treatment specified under Section 121 (b); Land Disposal
Restrictions specified under 40 CFR 268 Subparts A and D; and requirements for
incineration of hazardous waste specified under 40 CFR 264, Subpart 0.
' ~" • "..'*-*. ~^-^*^ •
Alternative E1B: Low Temperature Thermal Desorption (LTTD)
This alternative consists of on-site LTTD, with disposal of residuals in an on-site landfill;
it is assumed that additional treatment (i.e., solidification/stabilization for metals) will not
be required. The principal elements of this alternative are as follows:
• Excavate explosives-contaminated soil from the CAMU and transport it to a
temporary treatment facility on-site.
• Screen, shred and blend the soil to produce a uniform feed material.
• Process the blended soil through a mobile direct-fired LTTD unit to achieve disposal
criteria outlined below.
Iowa Army Ammunition Plant
Soils OUffl, Record or Decision (Revision No. 1)
24
August 14, 1998
-------
• Following confirmation sampling, dispose of treated soil on-site either:
a. For soils with cumulative risk less than 10"6, in compliance with LDRs, and
exceeding Summers model remediation goals, dispose in the Soil Repository
or under another synthetic landfill cap on-site.
b. For soils with cumulative risk less than 1O"6, in compliance with LDRs, and
satisfying Summers model remediation goals, dispose on IAAAP property in
an appropriate manner protective of human health and the environment.
LTTD is the primary treatment technology used under this alternative. LTTD treatment is
similar to rotary kiln incineration except that the process operates at a lower temperature
(typically 200 to 600 °F in the primary chamber, depending on the contaminants of concern).
At this lower temperature, volatilization is the primary mechanism at work in the primary
chamber. Organic contaminants are driven off as gases which are then destroyed at higher
temperatures in the secondary chamber or afterburner. Emissions from the LTTD unit will
be controlled with proper emission control devices such as a baghouse, and by routing off-
gases through an afterburner for complete combustion of gases prior to release to the
atmosphere. Results from treatability tests will be used to define operating parameters for
the LTTD unit.
Capital costs for LTTD treatment include mobilization and proj ect planning, site preparation,
erection of a temporary shelter for stockpiled soil, conduct of treatability tests, and
demobilization and site restoration. Operating costs include excavation of soils from the
C AMU, LTTD operation, labor, utilities, confirmation sampling, and disposal of treated soil
in the Soil Repository. Corps of Engineers program management costs are additional. For
cost estimating purposes, the treatment unit is assumed to be located adjacent to the CAMU
and disposal is assumed to be in the Soil RepositoryTTreatment capacity is assumed to be
approximately 5 tons/hour based on commercially available equipment, experience with
other applications, and consideration of the clay soil at IAAAP. Costs for treatment of 9,000
cubic yards of explosives-contaminated soil are estimated as follows:
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
m«fr1U>*OJECT$-1\S«44_lM«U»ltR001M44>n
-------
TABLE 4
Costs
Alternative EIB: LTTD
Capital Cost
Operating Cost
Subtotal
Project Contingency
Total Project Budget
Unit Rate
$ 300/cy
30%
Cost
$ 830,000
$ 2,700,000
$ 3,530,000
$ 1,060,000
$ 4,590,000
This represents a present worth value of $4,590,000. Details of these cost estimates are
presented in the Feasibility Study report.
It is expected that remediation could be completed in approximately six months of LTTD
operation. Additional time would be required for planning, design, mobilization, conducting
treatability tests and a trial burn and obtaining approvals, and for demobilization. These
activities are expected to require approximately two additional years. Treatability test results
will provide a clearer indication of actual time required for LTTD treatment.
Significant ARARs for this alternative include requirements relating to ambient air quality
and air emissions specified and IAC 28.1 (455 B), IAC 22.3 (3), 1AC 23.3 (2) (a) and Table
1, and IAC 23.3 (a) (c) (1); CERCLA' s preference fortreatment specified under Section 121
(b); Land Disposal Restrictions specified uricfer 40 CFR 268 Subparts A and D; and
requirements for incineration at hazardous waste specified under 40 CFR 264, Subpart 0.
Alternative E2A: Composting
In this alternative, composting will be used to treat contaminated soils. The principal
elements of this alternative are as follows:
• Excavate explosives-contaminated soil from the CAMU and transport it to a
temporary treatment facility on-site.
• Screen, shred and blend the soil to produce a uniform feed material.
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
26
August 14, 1998
-------
• Process the blended soil in a temporary compost shelter by mixing with amendments
such as manure, corn stalks, and food processing wastes; spreading the mixture in
windrows; and turning periodically to help aerate the material and regulate
temperature. Soils will be treated to achieve disposal criteria outlined below.
• Following confirmation sampling, dispose of treated soil on-site either:
a. For soils with cumulative risk less than 10"*, in compliance with LDRs, and
exceeding Summers model remediation goals, dispose in the Soil Repository
or under another synthetic landfill cap on-site.
b. For soils with cumulative risk less than 10"*, in compliance with LDRs, and
satisfying Summers model remediation goals, dispose on 1AAAP property in
an appropriate manner protective of human health and the environment.
Treatment residuals must also be shown to be non-toxic or not bioavailable
at levels posing a threat to human health or the environment.
Composting is the primary treatment technology used under this alternative. Composting
is a biological process in which naturally occurring micro-organisms degrade contaminants
into intermediates, some of which bind to soil organic components in such a way as to reduce
the mobile or extractable fraction of the contaminants. In windrow composting,
contaminated soils are mixed with locally available amendments (manure, wood chips, food
processing wastes, molasses, etc.) and water, then spread out in long rows. Facilities
required for window composting include an asphalt pad and a temporary structure to protect
the windrows from precipitation and temperature fluctuations. Conventional earth moving
equipment (front end loader, dump trucks) is used to place contaminated soil and remove
finished compost, while a commercially available windrow turning machine is used in the
composting process. Alternatives to windro.w,composting include use of a mechanical
agitated vessel to help aerate the material and regulate temperature, while in a static pile the
soil/amendment mix is left undisturbed.
It is assumed that treated soils will be disposed of in an on-site landfill (disposal option "a"
above). If composting can reliably achieve risk levels less than 10"* and comply with
Summers' model treatment requirements and LDRs, on-site land application of the finished
compost (disposal option "b" above) may be feasible. However, additional studies of long-
term stability and toxicity of compost treatment residues will be required to verify the
acceptability of unrestricted land application. Because of available landfill capacity, the
Army does not expect land application to provide significant cost advantages.
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
27 August 14, 1998
-------
Capital costs for composting include mobilization and project planning; site preparation;
construction of a compost shelter, and demobilization and site restoration. Operating costs
include excavation of soils from the CAMU; compost facility operation; labor; compost
amendments; utilities; confirmation sampling; and disposal of treated soil in the Soil
Repository. For cost estimating purposes, the treatment unit is assumed to be located
adjacent to the CAMU and disposal is assumed to be in the Soil Repository. Corps of
Engineers program management costs are additional. A treatment cycle of approximately
30 days per batch is assumed as a year-round average, allowing 5 days for loading, 20 days
for composting, and 5 days for unloading. Costs for treatment of 9,000 cubic yards of
explosives-contaminated soil are estimated as follows:
TABLE 5
Costs
Alternative E2A: Composting
Capital Cost
Operating Cost
Subtotal
Project Contingency
Total
Unit Rate
$260 - $360/cy
30%
Cost
$ 1,050,000
$2,340,000-53,240,000
$ 3,390,000 - $ 4,290,000
$1,020,000-$ 1,290,000-
$4,410,000-55,580,000
This represents a present worth value of $ 4,410,000 - $ 5,580,000. The variation in
estimated operating costs indicates the potential range of amendment requirements and costs.
Details of these cost estimates are presented in the Feasibility Study report.
It is expected that remediation could be completed-nr-approximately one year of compost
facility operation. Additional time would be required for planning, design, mobilization,
process optimization testing, and demobilization.
Significant ARARs for this alternative include CERCLA's preference fortreatment specified
under Section 121 (b); Land Disposal Restrictions specified under 40 CFR 268 Subparts A
and D; and requirements for composting of hazardous waste in buildings specified under 40
CFR Part 264, Subpart DD.
Alternative E2B: Bio-Slurry Treatment
In this alternative, either aerobic/anoxic or anaerobic bio-slurry treatment will be used to
treat contaminated soils. The principal elements of this alternative are as follows:
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
28
August 14.1998
-------
Excavate explosives-contaminated soil from the CAMU and transport it to a
temporary treatment facility on-site.
Screen, shred and blend the soil to produce a uniform feed material.
Process the blended soil in a bio-slurry treatment facility. Soil will be treated to
achieve disposed criteria outlined below.
Following confirmation sampling, dispose of treated soil on-site either.
a. For soils with cumulative risk less than 10"*, in compliance with LDRs, and
exceeding Summers model remediation goals, dispose in the Soil Repository
or under another synthetic landfill cap on-site.
b. For soils with cumulative risk less than 10"6, in compliance with LDRs, and
satisfying Summers model remediation goals, dispose on IAAAP property in
an appropriate manner protective of human health and the environment.
Treatment residuals must also be shown to be non-toxic or not bioavailable
at levels posing a threat to human health or the environment.
If disposal option "a" is selected, an additional treatment process will be
required for treatment of slurry water following solids dewatering and prior
to disposal.
Bio-slurry treatment is the primary treatment technology used under this alternative. Bio-
slurry treatment uses naturally occurring micro-organisms to degrade contaminants. The
process involves blending contaminated soils with water to produce a slurry of between 15
and 40 % solids, adding nutrients and co-substtates-(such as molasses), and mixing.
Processes may use either aerobic/anoxic regimes and anaerobic regimes. In aerobic/anoxic
processes, blowers cycle on and off to alternate between aerobic (oxygenated) and anoxic
(oxygen-starved) conditions, while mechanical mixers maintain solids in suspension. In
anaerobic processes, no aeration is provided and anaerobic conditions are maintained;
mechanical mixers again maintain solids in suspension.
It is assumed that thickening and dewatering will be required prior to disposal in an on-site
landfill (disposal option "a" above). If bio-slurry treatment can reliably achieve risk levels
less than 10"6 and comply with Summers' model treatment requirements and LDRs, on-site
land application of the liquid slurry (disposal option "b" above) may be feasible. However,
additional studies of long-term stability and toxicity of treatment residues will be required
to verify the acceptability of unrestricted land application. Because of available landfill
capacity, the Army does not expect land application to provide significant cost advantages.
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
29 August 14, 1998
-------
Capital costs for bio-slurry treatment include mobilization and project planning; site
preparation; construction of a treatment facility including three 250,000 gallon treatment
tanks, solids dewatering facilities (assumed to be precoat rotary drum vacuum filters), an
equipment building, and associated equipment; and demobilization and site restoration.
Operating costs include excavation of soils from the CAMU; treatment facility operation;
labor; chemicals; utilities; confirmation sampling; and disposal of treated soil in the Soil
Repository. Corps of Engineers program management costs are additional. For cost
estimating purposes, the treatment unit is assumed to be located adjacent to the CAMU and
disposal is assumed to be in the Soil Repository. A treatment cycle of approximately 10
weeks per batch is assumed as a year-round average. With two tanks processing at all times,
this allows an additional one week for loading and three weeks for unloading and dewatering.
Land application of the treated liquid slurry would require a longer treatment cycle (assumed
to be approximately 18 weeks). Costs for treatment of 9,000 cubic yards of explosives-
contaminated soil are estimated as follows:
TABLE 6
Costs
Alternative E2B: Bio-Slurry Treatment
Capital Cost
Operating Cost
Subtotal
Project Contingency
Total
Unit Rate
$300 - $440/cy
30%
Cost
$ 1,950,000
$2,700,000 - $ 3,960,000
$4,650,000 - $ 5,910,000
$ 1,400,000 - $ 1,770,000
$6,050,000 - $ 7,680,000
This represents a present worth value of $5,740,000 to $7,070,000 based on a 5% annual
discount rate. The variation in estimated operating costs indicates the potential range of
slurry concentrations in the treatment tanks. Details of these cost estimates are presented in
the Feasibility Study report.
It is expected that remediation to concentrations suitable for landfilling could be completed
in 3 to 5 years. Additional time would be required for planning, facility design and
construction, mobilization, process optimization testing, and demobilization. These activities
are expected to require approximately two additional years.
Iowa Army Ammunition Plant
Soils OIMM, Record of Decision (Revision No. 1)
30
August 14,1998
-------
Significant ARARsforthis alternative include CERCLA's preferencefortreatment specified
under Section 121 (b); Land Disposal Restrictions specified under 40 CFR 268 Subparts A
and D; and surface water quality criteria and limitations on discharges to surface waters
specified under IAC 61.3 (455B) and 33 USC Section 402.
2.7.2 Alternatives for Explosives plus Metals Contaminated Soils
Approximately 600 cubic yards of soil are identified as being contaminated with both
explosives and metals, out of an estimated total of 10,000 cubic yards of contaminated soil.
Alternatives for treating soil contaminated with both explosives and metals in excess of LDR
criteria are presented in the following paragraphs. The volume of soil contaminated with
both explosives and metals is small enough that it is not expected to affect the overall time
required for soils remediation under any of these alternatives.
Alternative M1: Explosives Treatment Followed by Solidification
In this alternative, soils contaminated with both explosives and metals exceeding LDR
criteria will be managed separately from soils contaminated solely with explosives, using the
same technology selected for management of explosives-contaminated soil, followed by
solidification/stabilization treatment for metals. Residuals will be disposed in an on-site
landfill. It is assumed that costs for treatment of the explosives portion of the contamination
in these soils will be determined by the technology selected for management of explosives-
contaminated soils. Capital costs are assumed to be covered under alternatives El A, E1B,
E2A, and E2B, and operating costs for treatment of the explosives portion of the
contamination vary from $260 to $440 per cubic yard. Operating costs for
solidification/stabilization of metals are estimated at approximately $150 per cubic yard.
Therefore, the total incremental cost for treatment of 600 cubic yards of contaminated soil
is estimated at between $250,000 and $350,000, -—,_-
ARAR's requirements will be determined by the alternative selected for treatment of the
explosives - contaminated soil.
Alternative M2: Solidification/Stabilization With Activated Carbon
This alternative consists of stabilization using activated carbon along with solidification
materials such as cement and flyash, with disposal of residuals in an on-site landfill.
A temporary solidification/stabilization facility will be erected on-site (assumed to be
adjacent to the CAMU or the final disposal site). Soil stockpiled in the CAMU will be
excavated, transported to the solidification/stabilization facility, screened, shredded and
blended to produce a uniform feed material; and processed through the
solidification/stabilization facility. Following confirmation sampling, treated soil will be
Iowa Army Ammunition Plant
Soils OIWM, Record of Decision (Revision No. 1)
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transported to the disposal site (assumed to be the Soil Repository) where it will be spread,
compacted, and covered.
Since solidification/stabilization immobilizes contaminants rather than destroying them,
compliance with remedial action objectives will be determined based on analysis of leachate
as a measure of groundwater protectiveness. For metals and explosives with Toxicity
Characteristic Leaching Procedure (TCLP) limits established under RCRA, treatment will
be considered protective of human health and the environment if TCLP results are below
RCRA regulatory limits. For other COCs, TCLP remediation goals for groundwater
protection are established based on the following hierarchy:
1. 100 times EPA Drinking Water Maximum Contaminant Level.
2. 100 times EPA Lifetime Health Advisory.
3. For carcinogens, 100 times the groundwater concentration corresponding to EPA 10"6
risk levels based on residential water usage.
4. For non-carcinogens, 100 times the groundwater concentration corresponding to a
Hazard Index of 1.0 based on residential water usage.
It is assumed that this material will be processed at the same time as other materials in the
CAMU. Capital costs for planning, site preparation, mobilization and demobilization are,
therefore, assumed to be covered under alternatives El A, E1B, E2A, and E2B. Operating
costs for solidification/stabilization using activated carbon are estimated at $220 to $3 80 per
cubic yard, depending upon the amount of activated carbon, cement, and flyash required.
Therefore, the total incremental cost for treatmeat-of-60G cubic yards of contaminated soil
is estimated at between $130,000 and $230,000.
Significant ARARs for this alternative include CERCLA's preferencefortreatmentspecified
under Section 121 (b), and Land Disposal restrictions specified under 40 CFR 268 Subparts
AandD.
Alternative M3: Off-Site Disposal
Under this alternative, soil contaminated with both explosives and metals would be
excavated from the CAMU and transported to a commercial waste treatment and disposal
facility off-site. Capital costs for planning, site preparation, mobilization and demobilization
are assumed to be covered under alternatives El A, El B, E2A, and E2B. Operating costs are
estimated at $600,000 to $ 1,000,000 depending on unit prices charged by commercial waste
Iowa Army Ammunition Plant
Soils OLWM, Record of Decision (Revision No. 1)
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disposal operators for transportation and disposal. These costs assume disposal as a
hazardous waste based on exceeding TCLP regulatory limits under RCRA. Off-site disposal
facilities must be permitted under RCRA and operate in compliance with permit conditions,
based on CERCLA Off-site Policy (NCP 300.440).
2.7.3 Alternatives For SVOC-Contaminated Soils
Approximately 200 cubic yards of soil are identified as being contaminated with SVOCs.
Alternatives for treating these soils are the same as presented above for soil contaminated
solely with explosives:
Alternative S1A: Incineration
This alternative consists of on-site incineration, with disposal of incinerator ash in an on-site
landfill. Capital costs for incineration are assumed to be covered under alternative El A for
explosives-contaminated soils. Operating costs are estimated at $370 per cubic yard.
Therefore, the incremental cost for treatment of approximately 200 cubic yards of SVOC-
contaminated soil is estimated at approximately $74,000. Incineration of SVOC-
COntaminated soils is expected to add only a couple of days to the remediation time. ARARs
requirements are equivalent to those for treatment of explosives contaminated soils under
Alternative El A.
Alternative S1B: Low Temperature Thermal Desorption (LTTD)
This alternative consists of on-site low temperature ' tnal desorption (LTTD), with
disposal of residuals in an on-site landfill. Capital cost- .or LTTD treatment are assumed
to be covered under alternative EIB for explosives-contaminated soils. Operating costs are
estimated at $300 per cubic yard. Therefore,,-the-rincremental cost for treatment of
approximately 200 cubic yards of SVOC-contaminated soil is estimated at approximately
$60,000. LTTD treatment of SVOC-contaminated soils would add less than a week to the
remediation time. ARARs requirements are equivalent to those for treatment of explosives -
contaminated soils under Alternative E1B.
Alternative S2A: Composting
This alternative consists of on-site composting, with disposal of residuals in an on-site
landfill. Capital costs for compost treatment are assumed to be covered under alternative
E2A for explosives-contaminated soils. Operating costs are estimated at $260 to $360 per
cubic yard. Therefore, the incremental cost for treatment of approximately 200 cubic yards
of SVOC-contaminated soil is estimated at approximately $52,000 to $72,000. Composting
of SVOC-contaminated soils would add roughly two weeks to the overall remediation
requirement. ARARs requirements are equivalent to those for treatment of explosives-
lowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
33 August 14, 1998
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contaminated soils under Alternative E2A.
Alternative S2B: Bio-slurry Treatment
This alternative consists of on-site bio-slurry treatment, with disposal of residuals in an on-
site landfill. Capital costs for bio-slurry treatment are assumed to be covered under
alternative E2B for explosives-contaminated soils. Operating costs are estimated at $300 to
$440 per cubic yard. Therefore, the incremental cost for treatment of approximately 200
cubic yards of SVOC-contaminated soil is estimated at approximately $60,000 to $88,000.
Bio-slurry treatment of SVOC-contaminated soils would add roughly one batch to the
overall remediation requirement. This is not expected to have a significant impact on the
overall remediation schedule. ARARs requirements are equivalent to those for treatment of
explosives-contaminated soils under Alternative E2B.
Alternative S3: Off-Site Disposal
Under this alternative, soil contaminated with S VOCs will be excavated from the CAMU and
transported to a commercial waste treatment and disposal facility off-site. Since sampling
data does not exceed hazardous waste criteria, it is assumed that these soils can be disposed
of as non-hazardous waste. Capital costs are assumed to be covered under alternatives El A,
El B, E2A, and E2B. Operating costs are estimated at $30,000 to $70,000 depending on unit
prices charged by commercial waste disposal operators for transportation and disposal. Off-
site disposal facilities must be permitted under RCRA and operate in compliance with permit
conditions, based on CERCLA Off-site Policy (NCP 300.440).
2.8 Summary of the Comparative Analysis of Alternatives
.JUSEPA has established nine criteria that balance healuXjechnical, and cost considerations to
determine the most appropriate remedial action alternative. These criteria are used to select a
remedial action that is protective of human health, and the environment, attains ARARs, is cost
effective, and utilizes permanent solutions and treatment technologies to the maximum extent
practicable. In accordance with Superfund guidance, each alternative is assessed against the
following evaluation criteria:
• Overall Protection of Human Health and the Environment: Describes how the alternative,
as a whole, achieves and maintains protection of human health and the environment.
• Compliance with Applicable or Relevant and Appropriate Requirements (ARARs):
Describes how the alternative complies with ARARs or, if a waiver is required, how it is
justified; also addresses other information from advisories, criteria, and guidance "to be
considered".
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• Lone-Tenn Effectiveness and Permanence: Evaluates the long-term effectiveness of
alternatives in maintaining protection of human health and the environment after response
objectives have been met.
• Reduction of Toxicitv. Mobility, and Volume Through Treatment: Evaluates the anticipated
performance of the specific treatment technologies an alternative may employ.
• Short-Term Effectiveness: Examines the effectiveness of alternatives in protecting human
health and the environment during the construction and implementation of a remedy until
response objectives have been met.
• Implementabilitv: Evaluates the technical and administrative feasibility of alternatives arid
the availability of required goods and services.
• Cost: Evaluates the capital and operation and maintenance (O&M) costs of each alternative.
• State Acceptance: Reflects the state's apparent preferences among or concerns about the
alternatives.
• Community Acceptance: Reflects the community's apparent preferences among or concerns
about alternatives.
The analysis of alternatives is arranged by type of contaminant: explosives, explosives plus metals,
SVOCs.
2.8.1 Evaluation of Alternatives For Explosives - Contaminated Soils
Overall Protection of Human Health and the Environment: Since both Thermal Treatment
(incineration and LTTD) and Biological Treatment (composting and bio-slurry treatment)
provide for destruction/degradation of contaminants to acceptable risk levels and the
management of residuals (either through landfilling or treatment to lower levels protective
of groundwater), both categories of alternatives are considered equally protective of human
health and the environment.
Compliance with ARARs. Most ARARs issues will be comparable for both Thermal
Treatment and Biological Treatment, although Thermal Treatment will involve more
concerns related to air emissions (i.e., ambient air quality standards, visible emission
standards, emission standards for particulate matter) and compliance with £P A's requirement
for a combustion facility risk assessment. Significant ARARs are identified in Tables 15a,
15b, and 15c.
Iowa Army Ammunition Plant
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Long-Term Effectiveness and Permanence: Thermal Treatment will permanently destroy
explosives contaminants that are present above remediation goals (RGs), while Biological
Treatment will degrade and stabilize them. Both of these processes are considered
irreversible. While composting has been conducted on a scale similar to that required at
IAAAP, long-term effectiveness of Biological Treatment is difficult to assess because of
uncertainties about the degree of treatment that can be achieved and the bio-availability of
treatment residuals. Thermal Treatment may be considered more effective since destruction
of contaminants is more complete. However, long-term landfill operation and maintenance
is required under either alternative unless Biological Treatment is determined to be
acceptable for unrestricted land application.
Reduction of Toxicitv. Mobility, and VolumeThrough Treatment: Both Thermal Treatment
and Biological Treatment will reduce contaminant levels to below RGs, although Thermal
Treatment will provide a greater degree of reduction in contaminant toxicity and mobility.
Incineration will result in some volume reduction, while composting will result in a volume
increase. LTTD and bio-slurry treatment are not expected to change soil volumes
significantly as a result of treatment.
Short-Term Effectiveness: While explosives hazard assessments and control measures will
be required under both Thermal and Biological Treatment, the requirements for Thermal
Treatment are expected to be more rigorous than-for Biological Treatment. A combustion
risk assessment will demonstrate that risks associated with Thermal Treatment can be
managed effectively. Other short-term effectiveness issues are considered to be equivalent.
Implementabilitv: Both Thermal Treatment and Biological Treatment involve a number of
implementability issues. Both use commercially available equipment. Testing will be
required for each alternative prior to implementation: incineration and LTTD will require
a trial bum; LTTD has not been utilized for remediation of explosives-contaminated soils
in this country and testing will, therefore, be required to demonstrate its effectiveness;
although testing has been done to demonstrate the effectiveness of composting and bioslurry
treatment, additional testing will be required to define process and operating parameters.
Once approvals are received and equipment is mobilized, Thermal Treatment can be
accomplished in a few months while Biological Treatment will require several years.
Cost: The costs of Thermal and Biological Treatment may be compared as follows.
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
36 August 14, 1998
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TABLE 7
Alternative Cost Comparisons
Explosives
Alternative
El A: Incineration
E1B: LTTD
E2A:Composting
E2B: Bio-slurry
Capital Cost
$ 4,600,000
$ 830,000
$ 1,050,000
$ 1,950,000
Operating Cost
$ 3,330,000
$ 2,700,000
$ 3,390,000- $ 4,290,000
$ 2,700,000- $ 3,960,000
Present Worth
(incl. contingency)
$10,310,000
$ 4,590,000
$4,410,000-5,580,000
$ 5,740,000- $7,070,000
Corps of Engineers program management costs are not included in the above costs.
Operating costs of each alternative may be influenced significantly by variables that are
difficult to predict at this time. Operating efficiencies (including cycle times, labor costs,
energy costs, and amendment mixes and costs) may vary considerably for any of these
processes, depending on the physical characteristics of the soil, weather, treatability of the
contaminants, and individual contractor capabilities. Previous studies at LAAAP included
an evaluation of Thermal and Biological Treatment alternatives considering the impact of
varying volumes of contaminated soil. Although total costs were significantly influenced
by soil volumes, the relative positioning of the alternatives were not affected. If further
investigations demonstrate that LTTD can achieve PRGs, it appears to be the least costly
alternative. However, with favorable amendment requirements and costs, composting and
bio-slurry treatment may be competitive with LTTD. Incineration is considerably more
costly. - . ....^•--—_
State and Community Acceptance: State and community acceptance issues are summarized
in Section 3 of this ROD.
Summary: In summary, Biological Treatment (i.e., composting) may be cost competitive
with Thermal Treatment (i.e., LTTD) or may cost up to a million dollars (roughly 20%)
more. In other criteria one alternative or the other may offer specific advantages, but both
comply with RAOs and on balance are considered equivalent.
2.8.2 Evaluation of Alternatives for Explosives Plus Metals
Contaminated Soils
Overall Protection of Human Health and the Environment: Since Alternative Ml (Explosives
Iowa Army Ammunition Plant
Soils OIW1, Record of Decision (Revision No. 1)
37
August 14, 1998
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Treatment Followed by Stabilization), Alternative M2 (Solidification/Stabilization With
Activated Carbon), and Alternative M3 (Off-site Disposal) all provide for
destruction/degradation, immobilization, and/or containment of contaminants, all three
alternatives are considered equally protective of human health and the environment.
Compliance with ARARs: Thermal Treatment under Alternative M1 would involve more
concerns related to air emissions and compliance with EPA's requirement for a combustion
facility risk assessment. ARARs are not a part of off-site alternatives. Off-site alternatives
must meet conditions specified in the off-site facility's permit. Significant ARARs are
identified in Tables 15a, 15b, and 15c.
Lone-Term Effectiveness and Permanence: The long-term effectiveness of Alternative Ml
will depend on the process selected for explosives treatment as discussed above for Explosives-
Contaminated Soils. Both Alternatives M2 and M3 stabilize contaminants rather than
degrading them, and both require long-term landfill operation and maintenance to ensure
continued effectiveness.
Reduction of Toxicity. Mobility, and Volume Through Treatment: Alternative M1 would
provide reduction in both contaminant toxicity and mobility through destruction or degradation
of explosives and solidification/stabilization of metals. Alternatives M2 and M3 would
provide reduction in contaminant mobility only. Contaminant volume is not expected to be
reduced significantly under any of the alternatives.
Short-Term Effectiveness: Short-term effectiveness would be comparable for all three
alternatives, although Thermal Treatment under Alternative Ml would involve more rigorous
explosives, hazard assessments, and control measures.
Implementabilitv-: Off^Site Disposal (Alternati,ve-M3)- would be the easiest alternative to
implement. Process development testing would be required for Explosives Treatment
Followed by Stabilization (Alternative M1) and for Solidification/Stabilization With Activated
Carbon (Alternative M2). In addition, the presence of metals may interfere with the
implementability of Biological Treatment under Alternative M1.
Costs: Costs may be compared as follows:
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
wn-itpfiajECTS.i\MM_iM«44ittoo««44i.ra<«>2«p
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TABLE 8
Alternative Cost Comparisons
Explosives Plus Metals
Alternative
Ml:
M2:
M3:
Explosives Treatment Followed by Stabilization
Solidification/Stabilization With Activated Carbon
Off-Site Disposal
Incremental Cost
$250,000 to $350,000
$130,000 to $230,000
$600,000 to $1,000,000
State and Community Acceptance: State and community acceptance issues are summarized in
Section 3 of this ROD.
2.8.3 Evaluation of Alternatives for SVOC-Contaminated Soils
Overall Protection of Human Health and the Environment: The overall protection provided
by Biological Treatment is difficult to assess because of uncertainties about its effectiveness
for the specific SVOCs of concern. The remaining alternatives (Thermal Treatment and Off-
site Disposal) are considered equally protective of human health and the environment.
Compliance with ARARs: Thermal Treatment would involve more concerns related to air
emissions and compliance with EPA's requirement for a combustion facility risk assessment.
ARARs are not a part of off-site alternatives. Off-site alternatives must meet conditions
specified in the off-site facilities'permit. Significant ARARs are identified in Tables 15a, 15b,
and 15c.
- - - -..•_-»"—~—
Long-Term Effectiveness and Permanence. Thermal Treatment will permanently destroy
contaminants that are present above RGs. The effectiveness of Biological Treatment is
difficult to assess because of uncertainties about ability to treat the specific SVOCs of concern.
Off-Site Disposal contains contaminants rather than degrading them, and requires long-term
landfill operation and maintenance to ensure continued effectiveness.
Reduction of Toxicitv. Mobility, and Volume Through Treatment: Thermal Treatment
provides reduction in both contaminant toxicity and mobility through destruction of
contaminants. The reduction provided by Biological Treatment is difficult to assess because
of uncertainties about ability to treat the specific SVOCs of concern. Off-Site Disposal
provides reduction in contaminant mobility only. Incineration will result in some volume
reduction, while composting will result in a volume increase. LTTD, bio-slurry treatment, and
off-site disposal are not expected to change soil volumes significantly.
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
39 August 14, 1998
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Short-Term Effectiveness: Short-term effectiveness will be comparable for all three
alternatives, although Thermal Treatment will involve more rigorous explosives, hazard
assessments, and control measures.
Implementability: Off-Site Disposal will be the easiest alternative to implement. Process
development testing will be required for Biological Treatment, and trial burns will be required
for Thermal Treatment.
Costs: Costs may be compared as follows:
TABLE 9
Alternative Cost Comparisons
SVOCs
Alternative
SI A: Incineration
SIB: LTTD
S2A: Composting
S2B: Bio-slurry
S3: Off-Site Disposal
Incremental Cost
$74,000
$60,000
$52,000 to $72,000
$50,000 to $72,000
$30,000 to $70,000
State and Community Acceptance: State and community acceptance issues are summarized
in Section 3 of this ROD.
2.8.4 Environmental Consequences (NEP/T£valuation)
The feasibility study reviewed the environmental and socioeconomic effects of remediating
contamination at the IAAAP, in compliance with the National Environmental Policy Act of
1969 (NEPA). Thermal treatment, biological treatment and "No Action" alternatives were
reviewed for effects on numerous aspects of hydrology, soils, ecology, socioeconomics, and
public health. No significant adverse effects were identified in the review. Further, none were
identified by reviewing agencies or the general public during the public comment period of the
Proposed Plan. It was the finding of the NEPA review that neither biological nor thermal
treatment would adversely affect environmental resources at the IAAAP. A combustion
facility risk assessment will be performed prior to implementation of the remedial action to
address potential minor risks of adverse effects of air pollution and construction worker safety
from thermal treatment technologies.
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
40
August 14,1998
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2.9 Selected Remedy
Based on an evaluation of the various alternatives, the Army and EPA conclude that Biological
Treatment (Alternatives E2A and E2B) and LTTD Thermal Treatment (Alternative EIB) are capable
of providing treatment to reduce the toxicity, mobility, and volume of principal threat contaminants
in the CAMU in response to CERCLA's expressed preference for treatment, complying with land
disposal restrictions (LDRs) for disposal of treated soil, and providing long-term protection of human
health and the environment.
LTTD Thermal Treatment is the remedy selected for explosives-contaminated soils, with Biological
Treatment as the contingency remedy pending results of the LTTD Thermal Treatment feasibility
testing field demonstrations, and risk assessment. The feasibility testing and field demonstrations will
include additional process development and economic evaluations to farther define the performance
and cost OF the LTTD Thermal Treatment alternative. In addition, a combustion facility risk
assessment will be conducted consistent with EPA policies and guidance prior to implementation of
LTTD Thermal Treatment. The results of this risk assessment will be presented to the public with an
opportunity to comment prior to commencing the site work. If the feasibility testing, field
demonstrations, or risk assessment shows that LTTD Thermal Treatment cannot be conducted in a
protective manner, appropriate documentation will be prepared for review and submitted to the
Administrative Record, and the contingency remedy will be implemented. Implementation of specific
biological treatment processes (composting, bio-slurry, or other) will be determined based on
demonstrated effectiveness following treatability testing using IAAAP soils, and on solicitation of
competitive cost proposals from remediation technology vendors.
Solidification/Stabilization With Activated Carbon (Alternative M2) is the remedy selected for soils
contaminated with explosives plus metals exceeding LDRs, and Off-Site Disposal (Alternative S#)
is the remedy selected for soils contaminated with SVOCs. These alternatives comply with remedial
action objectives at a lower cost than other alternatives and are equivalent to or better than other
"alternatives in most of the remaining criteria. - -» " —r—
2.9.1 Description
The major components of the selected remedy include:
Explosives-Contaminated Soils
• Excavated explosives-contaminated soils from the CAMU and transport it to a temporary
treatment facility on-site.
• Screen, Shred and blend the soil to produce a uniform feed material.
• Process the blended soils through a mobile direct-fired low-temperature thermal desorption
unit (LTTD) (Selected Remedy) or a temporary Biological Treatment Unit (Contingent
Remedy).
Iowa Atmy Ammunition Plant 4 \
Soils OU*M, Record of Decision (Revision No. 1) August 14. 1998
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Following confirmation sampling, dispose of treated soil according to the following
criteria:
a. For soils with cumulative risks less than 10"6, in compliance with LDRs, and exceeding
Summers model remediation goals, dispose in the Soil Repository or under another
synthetic landfill cap on-site.
a. For soils with cumulative risks less than 10*, in compliance with LDRs, and satisfying
Summers model remediation goals, dispose on 1AAAP property in an appropriate
manner protective of human health and the environment. For Biotreated soils,
treatment residuals must also be shown to be non-toxic or not bioavailable at levels
posing a threat to human health or the environment.
Costs for treatment of 9,000 cubic yards of explosives-contaminated soil are estimated as
follows:
TABLE 10
Selected Remedy Costs
Explosives-Contaminated Soils
Capital Cost
Operating Cost
Project Contingency
Total
Estimated Time Required
for Treatment Facility
Operation
Present Worth
Based on 5%
Annual Discount Rate
LTTD Treatment
Unit
Rate
$300/cy
30%
Cost
$830,000
$2,700,000
$1,060,000
$4,590,000
Six Months
$4,590,000
Composting
Unit Rate
$260
to
$360/cy
"-. ~-*_ -*-*—^— -
30%
Cost
$1,050,000
$2,340,000
to
$3,240,000
$1,020,000
to
$1,290,000
$4,410,000 to 5,580,000
One Year
$4,410,000 to 5,580,000
Bio-Slurry Treatment
Unit Rate
$300
to
$440/cy
30%
Cost
$ 1,950,000
$ 2.700,000
to
$ 3,960,000
$ 1,400,000
to
$ 1,770,000
$6,050,00 to 7,680,000
Three to Five Years
$5,740,000 to $7,070,000
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Soils OU#1, Record of Decision (Revision No. 1)
42
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Explosives Plus Metals Contaminated Soils
• Excavate explosives plus metals contaminated soil from the CAMU and transport it to a
temporary treatment facility on-site.
• Screen, shred and blend the soil to produce a uniform feed material.
• Process the blended soil through a temporary solidification/stabilization facility.
• Following confirmation sampling, dispose of treated soil on-site in the Soil Repository or
under another synthetic landfill cap.
Costs for treatment of 600 cubic yards of explosives plus metals contaminated soils are
estimated as follows:
TABLE 11
Selected Remedy Costs
Explosives plus Metals Contaminated Soils
Capital Cost
Operating Cost (unit rate)
Incremental Cost (total)
Cost
Covered under management of Explosives-Contaminated Soils
$220 to $380 per cubic yard
$130,000 to $230,000
SVOC-Contaminated Soils
• Excavate SVOC-contaminated soil from the CAMU.
• Transport the soil to a commercial waste treatment and disposal facility off-site.
Costs for treatment of 200 cubic yards of SVOC-contaminated soils are estimated as follows:
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
43 August 14, 1998
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TABLE 12
Selected Remedy Costs
SVOC-Contaminated Soils
Capital Cost
Operating Cost (unit
rate)
Incremental Cost (total)
Cost
Covered under management of Explosives-Contaminated Soil
$150 to $350 per cubic yard
$30,000 to $70,000
Capital costs for the selected remedy may vary as a result of changes made to the remedy
during the remedial design and construction processes. Operating costs may be influenced
significantly by variables that are difficult to predict at this time. Operating efficiencies
(including cycle times, labor costs, energy costs, and amendment mixes and costs) may vary
considerably for any of these processes, depending on the physical characteristics of the soil,
weather, treatability of the contaminants, and individual contractor capabilities.
2.9.2 Remediation Goals
Chemical-specific remediation goals have been established for treatment of soils stockpiled
in the IAAP CAMU. These treatment goals are based on risk considerations and are
considered to be protective of individuals who may be exposed at the site. Remediation goals
have been established at 1 E(-6) risk, level to the reasonably maximum exposed individual
considering an industrial land use setting. Exposure assumptions have been adopted from
those specified in EPA guidance (see OSWER Directive 9285.6-03) Remediation goals based
on these criteria are outlined in Table 13, with-exceptTohs noted.
Iowa Army Ammunition Plant
Soils OIMM, Record of Decision (Revision No. 1)
44
August 14.1998
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TABLE 13
Soil Remediation Goals
at 10-* Risk Level
Based on Ingestion/Dermal Contact
Chemical
Antimony
Arsenic
Beryllium
Cadmium
Chromium VI
Lead'
Thallium
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenz(a,b)anthracene
Total PCBs-*
1,3,5- Trinitrobenzene
2,4-Dinitrotoluene (2,4-DNT)
2,4,6-TNT
RDX
HMX
PRGfa/g)
816
30.0
5
1,000
10,000
1000
143
8.1
0.81
8.1
0.81
10
102
8.7
196*
533
51,000
1 . Remediation goal for lead is determined based on the
"PRO Screen Model," rather than a carcinogenic risk.
2. Remediation goal for PCB is based on EPA OSWER
Directive 9355.4-01, "Guidance on Remedial Actions for
Superfund Sites with PCB Contamination"
3. See Table 14
Remediation goals for other constituents which may be detected at the site and which are not specified
in this table will be established using similar criteria;- -» "—~-*
In addition to risk-based soil remediation goals for protection of human health, impact to groundwater
from residual soil contamination has been evaluated. The Summers' model was utilized to estimate
the point at which contaminant concentrations in the soils will produce groundwater contamination
at concentrations above acceptable levels. The resultant soil concentrations can then be used as a
guidelines in estimating boundaries or extent of soil contamination and specifying soil cleanup goals
for remediation. The Summers' model was used to determine acceptable levels for explosives COCs
in soils (RDX and 2,4,6-TNT), which are found in on-and off-site groundwater. The model was based
on not exceeding groundwater concentrations of 2 ppb RDX and 2 ppb 2,4,6-TNT. The model was
not used for metals as metals are relatively immobile in the clay soils found at the IAAAP. There are
also no Summers' model limits for SVOCs. The site-specific remediation goals for the major
contributing explosives are:
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
45
August 14, 1998
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TABLE 14
Soil Remediation Goals
Based on Soil Leaching
Chemical
RDX
2,4,6-TNT
PRGfrg/g)
1.3
47.6
These concentrations of RDX and 2,4,6-TNT were used as remediation goals in order to satisfy the
remedial action objectives for the protection of human health and the protection of groundwater.
These values supersede those presented in Table 13 for RDX and TNT for unrestricted land application
of treated soil.
Compliance with the stated objectives for this ROD may be achieved in one of two ways:
a. Treatment to a cumulative risk level of 10"6 and compliance with LDRs, followed by
management of residuals in a landfill. This would result in 95% to 99+% removal of
contaminants, which is consistent with CERCLA's requirement for "significant"
treatment, and would be protective of groundwater.
b. Treatment to lower levels protective of groundwater (as defined by the Summers'
model) followed by on-site management of treatment residuals. Unrestricted land
application of residuals would require a demonstration of contaminant destruction or
a demonstration that residuals are not toxic or not bioavailable at levels that would
pose a threat to human health and the environment.
"Since solidification/stabilization immobilizes contaminsntsTatfierthan destroys them, compliance with
remedial action objectives for treatment of explosives plus metals contaminated soil will be
determined based on analysis of leachate as a measure of groundwater protectiveness. For metals and
explosives with Toxicity Characteristic Leaching Procedure (TCLP) limits established under RCRA,
treatment will be considered protective of human health and the environment if TCLP results are
below RCRA regulatory limits. For other chemicals of concern, TCLP remediation goals for
groundwater protection are be established based on the following hierarchy:
1. 100 times EPA Drinking Water Maximum Contaminant Level.
2. 100 times EPA Lifetime Health Advisory.
3. For carcinogens, 100 times the groundwater concentration corresponding to EPA 10"6 risk
levels based on residential water usage.
lowii Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
46
August 14, 1998
-------
4. For non-carcinogens, 100 times the groundwater concentration corresponding to a Hazard
Index of 1.0 based on residential water usage.
2.10 Statutory Determinations
In accordance with the statutory requirements of Section 121 of CERCLA, remedial actions that are
selected are required to:
• Protect human health and the environment.
• Comply with applicable or relevant and appropriate requirements (ARARs).
• Be cost effective.
• Use permanent solutions and alternative treatment technologies to the maximum extent
practicable.
• Satisfy the preference for treatment that reduces contaminant toxicity, mobility, or volume as
a principal element.
The manner in which the IAAAP Soils OU #1 remedial action satisfies the above requirements is
discussed in the following sections.
2.10.1 Protection of Human Health and the Environment
The selected remedy will provide for protection of human health and the environment through
destruction/degradation of explosives contamination.!!? acceptable risk levels and through
management of residual explosives, metals, and SVOC contaminants through landfilling.
2.10.2 Compliance with ARARs
The selected remedy will comply with applicable or relevant and appropriate requirements
(ARARs). ARARs are presented in Table 15a, 15b, and 15c according to location-specific,
chemical-specific, and action-specific requirements. Activities conducted entirely on-site do
not require Federal, State, or local permits, but on-site actions must comply with the
substantive requirements of any Federal or State environmental laws that are ARARs. Off-site
activities must meet conditions specified in the off-site facility's permits.
Significant ARARs associated with the selected remedy include:
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
47 August 14, 1998
-------
TABI.F I5a
COMPLIANCE OF ALTERNATIVES WITH I.O( ATION-SPEC IFIC ARARS
IOWA ARMY AMMUNITION PI.ANT. MIDDI.FTOWN. IOWA
ARAR
Citation
Endangered Species Act. I61I.S.C. 15M rt stq.. and
Fish and Wildlife Coordination Act. I6II.SC.66I n
stq.
50 CFR Part 200. 50 CTK Part 402. and 13 C\-"H Parts
.120 - 330
Bald Eagle Protection Act. 16 IJ.S.C. 668 el seq
Migratory Bird Treaty Act of 1972. 16 IJ.S.C. Section
703
National Archeological and Historical Preservation
Act, 16 US.C. Section 469
36 CFR Part 65
Native American CJraves and Repatriation Act. 25
IJ.S.C. Section 3(X)I
Fish and Wildlife Coordination Act. I6U.S.C.<>6I rt
"1
40 CFR 6. 1(12
Explosive* Contaminated Soil*
Thermal Treatment
Excavation and construction activities may
afl'ecl habitat upon which the federally listed
bald eagle or Indiana hat may depend.
Measures will be taken to avoid affecting
critical habitat.
Excavation and construction activities may
affect habitat upon which the bald eagle may
depend Measures will be taken to avoid
affecting the bald eagle's habitat.
Excavation and construction activities may
adversely impact migratory bird species
present on or in the vicinity of the 1AAAP.
Measures will he taken to avoid such adverse
impacts
Excavation and construction activities are not
expected to unearth significant scientific,
prehistoric, 01 archacologic data. 11 such
artifacts are discovered during excavation
activities, measures will he taken to avoid
mepanible harm, loss or destruction ol the
artifacts
Excavauon and construction activities are not
expected Native American graves or Native
American cultural objects If such graves or
objects are discovered during excavation
activities, measures will be taken to avoid
their irreparable harm, loss or destruction
Surface water removed fnmi excavated areas
or decontamination water mav be discharged
In Hrusli. l.onp. m Spring Creeks It so. the
water v. ill be treated as neccssiirv In avoid
modifying Hie creeks and .illcilini; lish or
\Vllilllti*
Biological Treatment
I'xcavauon and construction activities may
affect habitat upon which the federally listed
bald eagle or Indiana bat may depend.
Measures will be taken to avoid affecting
critical habitat.
Excavation and construction activities may
allect habitat upon which the bald eagle may
depemt. Measures will be taken to avoid
atlccting the bald eagle's habitat.
Kxcavalion and construction activities may
adversely impact migratory bird species
present on or in the vicinity of the 1AAAP.
Measures will be taken to avoid such adverse
impacts.
Excavaliop and construction activities are not
expected to unearth significant scientific.
prehistoric, or archaeologic data. If such
artifacts are discovered during excavation
activities, measures will be taken to avoid
irreparable harm, loss or destruction of Ihe
artifacts.
Excavation and constructiop activities are not
expected Native American graves or Native
American cultural objects. If such graves or
objects arc discovered during excavation
activities, measures will be taken l<> avoid
Ihcir irreparable harm, loss or destruction
Surface water removed from excavated areas
i»r deioni.'umnation waier may be discharged
lo Hrush. l.oiij.1. in Sptmg Creeks II so. the
uatcr will be liea'cd as ncccssar\ tn avoid
inmhlvmg the crei-ks and aflcctinp tish or
_u.ililliliL
Eiplmivn Plus Metalt Contaminated Smlv
Solidification/Stabilization with
Activated Carhnn
lixcavation and construction activities mav
alTecl habitat upon which the federally listed
bald eagle or Indiana bat may depend.
Measures will be taken to avoid affecting
critical habitat.
Excavation and construction activities may
affect habitat upon which the bald eagle mav
depend. Measures will be taken to avoid
affecting the bald eagle's habitat.
Excavation and construction activities may
adversely impact migratory bird species
present on or in the vicinity of the 1AAAP.
Measures will be taken to avoid such adverse
impacts
Excavation and construction activities arc not
expected to unearth significant scientific.
prehistoric, or archaeologic data If such
artifacts are discovered during excavation
activities, measures will be taken lo avoid
irreparable harm, loss or destruction of the
artifacts.
lixcavation and construction activities are not
expected Native American graves or Native
American cultural objects If such graves or
objects are discovered during excavation
activities, measures will he taken lo avoid
their irreparable harm, loss or destruction.
Surface water removed from excavated areas
or decontamination water mav be discharged
to Hrush. Long, or Spring Creeks 11 so. the
water will be treated as necessary to avoid
inodifving the creeks and aflccling fish or
uil.lliiv
SVOC - Contaminated S»il<
Off-tile Disposal
lixcavation and construction activities may
affect habitat upon which the federally listed
bald eagle or Indiana bat may depend.
Measures will be taken to avoid affecting
critical habitat
Excavation and construction activities may
affect habitat upon which the bald eagle may
depend. Measures will he taken lo avoid
alVecbng (he bald eagle's habitat.
Excavation and construction activities may
adversely impact migratory bird species
present on or in the vicinity of the IAAAP
Measures will he taken to avoid such adverse
impacts.
Excavation and construction activities are nol
expected to unearth significant scientific.
prehistoric, or archaeologic data If such
artifacts arc discovered during excavation
activities, measures will be taken to avoid
irreparable harm, loss 01 destruction ot the
artifacts
Excavation and construction activities are not
expected Native American graves or Nauve
American cultural objects It such graves or
objects are discovered during excavation
activities, measures will be taken lo avoid
their irreparable harm, loss or destruction
Surface water removed from excavated ;treas
or decontamination water may he discharged
to Hnish. Long, or Spring Creeks If so. the
water will be treated as iiecessarv In avoid
modifying Ibe creeks and affecting lisli or
wilrllili- 1 ill ?
tows Army Ammunition Plant
Sals OU»1. Record ol Decision (Revision No I)
August M 1998
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TABLE I5a
COMPI.IANC E OF ALTERNATIVES WITH LOCATION-SPECIFIC ARARS
IOWA ARMY AMMUNITION PLANT, MIDDLETOWN. IOWA
ARAR
Citation
Farmland Protection Policy Art, 7 1) S.C. 4201 rf.tr?
7 CFR Part 65R.4 and hS8 .5
Iowa Environmental Quality Art. I A C., Division
567. Title XI. Chapter 151. Iowa Hazardous Waste
Facilities Siting Regulations
IAC 15 1.3(2) and Table I
Iowa Environmental Quality Act. IAC, IWtsio'n
567. Title XI. Chapter 151. Iowa 1 lazardous Waste
Facilities Siting Regulations
{AC I5I..1(I)
Iowa Code Annotated. Title XI. Natural Resources;
Subtitle 6. Wildlife; Chapter 481A. Wildlife
Conservation
IAC 48IA 38
F.iplmive* Contaminated Soils
Thermal Treatment
Prime and unique farmland may he present at
the IAAAI'. 1 lowcvct. excavation and
construction activities are not expected to
occur near such farmland.
Thermal treatment facilities will not be sited
in critical wildlife habitat or prime farmland
Inermal treatment facilities will not be sited
within 1 mile of wetlands.
Excavation and construction activities may
affect habitat upon which the federally listed
bald eagle or Indiana bat may depend, or
upon which the stale-listed orangethroal
darter or yellow trout lily may depend
Measures w-ill be taken to avoid the "nking"
ol wildlife
Biological Treatment
Prime and unique farmland may be present at
the 1AAAP However, excavation and
construction activities are not expected to
occur near such farmland.
I fiologicul treatment facilities will not be
sited in critical wildlife habitat or prime
farmland
[Jiolopical treatment facilities will not be
sited within 1 mile ol wetlands.
Excavation and construction activities may
allect habitat upon which the federally listed
bald eagle or Indiana bat may depend, or
upon which the state-listed orangethroat
darter or yellow trout lily may depend
Measures will he taken to avoid the "taking"
of wildlife.
Etplniivrt Plui MeUU Contaminated SoiU
Solidification/Stabilization witli
Activated Carbon
Prime and unique farmland may he present at
the IAAAP. However, excavation and
construction activities are not expected to
occur near such farmland.
Treatment facilities will not be sited in
critical wildlife habitat or prime farmland.
Treatment facilities will not he sited within 1
mile of wetlands.
Excavation and construction activities nay
affect habitat upon which the fcdenlly -istcd
bald eagle or Indiana bat may depend, <• r
upon which the state-lisle*! orangcthroai
darter or yellow trout lily may depcml
Measures will be taken to avoid the "taking"
of wildlife.
SVCK - Contaminated Soils
Off-site Diipos a)
Prime and unique farmland may be present at
the IAAAP. However, excavation and
construction activities are not expected to
occur near such farmland
Materials handling facilities will not be sited
in critical wildlife habitat or prime farmland
Materials handling facilities will not be sited
within 1 mile of wetlands
Excavation and construction activities may
affect habitat upon which the federally listed
bald eagle or Indiana bat may depend, or
upon which the stale-listed onm^ethroat
darter or yellow trout lilv may depend.
Measures will be taken to avonl the "lakinp"
of wildlife.
2 of 2
tows Anny Ammunition Plant
Soils OLttH. Record at Decision (Revision A/o It
Page -I')
August 14. r998
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COMPLIANCE OF A'..TEHNAT!YESW!TH CHEMICAL-STECIF.C ARAUS
IOWA ARMY AMMUNITION PI.ANT. MIDDLETOWN, IOWA
ARAR
Citation
Iowa Underground Storage Tanks Acts. 1 A.C..
Division 567. Tille X. Chapter 1 35. Iowa
Underground Storage Tanks Regulations
I.AC 1.157(4550X9)
1 Petroleum Contamination Corrective Action Levels]
Einlnsives Contaminated Soils
Thermal Treatment
Binlngiral Tmtment
Elplniivrs Plus Metili Contaminated Soils
Saliditicalion/Stahilizaiinn with
Activated Carbon
SV()( Contaminated S»il>
Off-Silt Disposal
SOILS
Compliance with the petroleum corrective
action level of UK) rng/kg will be achieved by
off-site disposal orSVOC-contaminaled soils
Compliance with the petroleum corrective
action level of 10(1 ing/kg will be achieved by
off-site disposal of SVOC-contaminated soils.
Compliance with the petroleum corrective
action level of 100 mg/kg will be achieved by
off-site disposal of SVOC-contaminated soils.
Compliance with the petroleum corrective
action level of 100 mg/kg will he achieved by
off-site disposal of SVOC-contaminated soils.
AIR
Iowa Environmental Quality Act (IKQA). Division
567. Title U. Chapter 28. Ambient Air Quality
Standards
I.A.C. 28.1(4551))
[Ambient Air Quality Standards)
IEQA, Division 567, Title II. Chapter 22, Controlling
Pollution
\AC 22.3(3)
(Visible Emission Standard Set in Permit]
1F.QA. Division 567. Title 11. Chapter 23. Emission
Standards for Contaminants
IA.C.2.VJ(2Xa)aiul Table 1
(Emission Standard I'nr Paniculate- Mailer)
This alternative involves excavation and
construction activities that may release lead
and paniculate matter into the air, and
thermal treatment ol metals/explosives-
contaminated soils that may release lead and
paniculate matter into the air. Control
equipment will be used to ensure compliance
with the ambient air quality standards.
This alternative involves the thermal
treatment of contaminated soils in a mobile
unit, which is subject lu new source review.
Although the IAAAP is not required In obtain
a permit, it will need to meet Uic visible air
emission standard that is IDNR's policv.
This alternative involves the thermul
treatment ol contaminated .soils, which is a
process that may emit smoke, paniculate
matter, gaseous mailer or other contaminants
Control equipment will he used to ensure
compliance with the emission standard lor
paniculate matter
This alternative involves excavation and
construction activities that may release lead
and ^articulate matter into the air.
bngineering measures will be used to ensure
compliance with the ambient air quality
standards.
•
This alternative does not involve new source
review.
This alternative dues not involve emission of
paniculate matter from any process.
This alternative involves excavation and
construction activities that may release lead
and paniculate matter into the air.
Engineering measures will be used to ensure
compliance with the ambient air quality
standards.
This alternative does not involve new source
review
This alternative does not involve emission of
paniculate matter from any process.
This alternative involves excavation and
construction activities that may release lead
and particular matter into the air.
Engineering measures will be used to ensure
compliance with the ambient air quality
standards
This alternative does not involve new source
review.
This alternative docs not involve emission of
paniculate matter from any process.
1 of 5
Iowa Army Ammunition Plant
Soils OUni. Record of Decision tRevtvon No
August 14. 1998
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TABLE I SI.
COMPLIANCE OF ALTERNATIVES WITH rHEMiCAIx-SPECIFlCARARS
IOWA ARMY AMMUNITION PI.ANT. MIDDLETOWN, IOWA
AKAR
Citation
Kipl»iivf» Contaminated Soil*
Thermal Treatment
Biological Treatment
Elplniivei Plui Mrfah Contaminated Soils
Solidification/Stabilization with
Activated Carbon
SVOC Cunt.miruli-cl Snili
Off-Site Disposal
AIR
IEQA, Division 5
-------
I Mil I IM,
I OMI'I I\N( r01 Al.lt HNA ll\ \ S Will I ( IIFMII AI-SI'H IH< *H \HS
IOWA AICW AMMI'NIIIIlM'I.ANI. MIIIDI.M OWN. |O\\A
ARAR
Citation
FiplnHtr\ Contaminated Suilv
Thermal Irralmrnt
l Treatment
* Ptu\ Mrlatt Contaminati-d
Nnlidifkatinn/Stahiltzatinn *'ith
Artivafrd Carhnn
SV(H' ( imiaminilrd SniK
Off-Silr Dllpoial
SURFACE WATER
IKQA. I A C.. Division V.7. litle III. Chapter tS2.
Effluent and I'rrtrealmrnl Standards Other I IHiienl
Limitations or Prohibitions
[HFDES permit conditions
I Ins alternative may involve Ihe discharge ol
surface water removed trom excavated ureas.
ol decontamination water, into llmsh. 1 nng.
or Spring Creels Appropriate treatment will
ensure discharges comply with standards in
the NI'DI-S permit issued to the IAAAI'
'Ihis alternative may involve the discharge ol
surtace water removed from excavated areas.
or decontamination water, into Brush. Long,
or Spring Creeks Appropriate treatment will
ensure discharges comply with standards in
the NPDI-'S permit issued to the IAAAP.
I "his ajtrmative may involve the discharge oi
surface water removed tmm excavated areas.
or decontamination water, into Hrush, Long.
nr Spring Creeks Appropriate treatment will
ensure discharges comply with standards in
the NPD1-S permit issued to the IAAAP
This alternative may involve the discharge o('
surface water removed Vmm excavated areas.
or decontamination water, into Brush. I [
1 his alternative may involve the discharge of
surtace water removed Irom excavated areas.
or decontamination water, into Hnish. Long.
or Spring Creeks Appropriate treatment will
ensure discharges comply with (he stale
anlidegradalion policy
1 his alternative may involve the discharge of
surface water removed from excavated areas.
or decontamination water, into Brush. Long,
or Spring Creeks. Appropriate treatment will
ensure discharge] comply with the state
antidcgradation policy.
This alternative may involve the discharge nf
surface water removed from excavated areas.
or decontamination water, into llnislt. Long.
or Spring Creeks. Appropriate treatment will
ensure discharges comply with the state
antidegradauon policy
I his alternative may involve the discharge of
surface water removed fmm excavated areas,
or decontamination water, into tlmsh. Long.
or Spring Creeks Appropriate treatment will
ensure discharges comply with the- stale
anlidegradation policy
IEQA. I A.C . Division V.7. Title IV, Chapter hi.
Surface Water Quality Cntena
IAC 61 1(455H)
(Water Quality Criteria Im pciictal use segment*, ami
for designated use uatn segments)
'Mm alternative may involve the discharge ol
Mirlai c water removed trom evcavatcd areas,
nr decontamination walci. into Hnjsh. Long.
ot Spring Creeks Trie discharge will he
Healed a|ipri>pnalelv In ensure compliance
wild the stale water qualify inlcna lor Class
Hll It) waters
'Ihis alternative may involve the discharge of
surlacc water removed Irom excavated areas,
or decontamination water, into Brush. Long.
or Spring Creeks 'Ihe discharge will be
treated appropriately to ensure compliance
ui(Ji the slate water quality criteria for Class
11(1 K) waters
This alternative may involve the discharge of
surface water removed from excavated areas.
or decontamination water, into llnish. Long.
or Spring Creeks The discharge will be
treated appropriately to ensure compliance
with the state water quality criteria foi Class
H(I.R) waters
This alternative may involve the discharge ol
surface water removed from excavated areas,
or decontamination water, into Unisli. Long.
or Spring Creeks. The discharge will he
treated appropnatcly to ensure compliance
with Ihe slate water quahu critcna Inr CI.-LSS
waters
nl
lowi Army Ammunition Plant
Sals Ol>* 1. Record ol Decision {Revision Nn II
August 14 1998
-------
TABLE 15b
COMPLIANCE OF ALTERNATIVES WITH CHEMICAL-SPECIFIC ARARS
IOWA ARMY AMMUNITION PI.40CFR Ml M-t V-l. ami Table I
jGroumlwatcr Protection Standards for permitted
haftirdous waste facilities!
This alternative includes the nnsite disposal
of treatment residuals into an nn-sile landlill
'Ihis may present a potential lor kaclmif of
contaminants into the groundwater. which is ;
potential source ol drinking water
tffoundwatcr monitoring will ensure
compliance with the groundwater protection
standards
This alternative may include the onsite
disposal ol treatment residuals into an on-site
laiidtill 'Mils may present a potential for
leaching ol contaminants into the
proimdwaler. which is a potential source of
drinking water (.iroiindwattr monitoring will
ensure compliance with the proundwatcr
protection standards
This alternative includes the onsite disposal
of treatment residuals into an on-sitc landlill.
This may present a potential for leaching of
contaminants inlo the groundwater. which is a
potential source of drinking water
t iroundwater monitoring will ensure
compliance with the groundwater protection
standards
This alternative does not involve on-sitc
disposal oi SVOC" containinalt-tl soil.
•1 of 5
/otv* Arniy Ammunition Plant
Soils OUt 1. Record of Decision (Revision No 1)
August 1-1. 1998
-------
TA
GMFLiANrE Or ALTERNATIVES WiTii CHEMiCAix-SPfcCiFiC AKAkS
IOWA ARMY AMMUNITION PI.ANT, MII>DLETO\VN. IOWA
ARAR
Citation
Eiploiivtt Contaminated Soils
Thermal Treatment
Biologic:! Treatment
KiploMvct Plui Medls Contaminated Soil*
Soiidifiiralion/.Siabiliziiifln wiih
Activated Carbon
SVOC Contaminated Soils
Off-Silt Diiposal
GROl'NDWATER
FEQA, I.A.C., Division 567. Title III. Chapter 41,
Iowa Drinking Water Regulations
I.A.C 41 .3(455BX 1 XU 4 1 .3(455BX5Xa) anil (by.
and 41 3<455BX6Xa)
[state MCLs|
IEQA, I.A.C.. Division 567. Title X. Chapter 1 33,
Iowa Responsible Parties Cleanup Regulations
I.A.C. l33.4(455B.455KX2>and(3XnXI>
(Action Levels foi groumlwatcr cleanup actions)
This alternative includes the onsile disposal
of treatment residuals into on-site landfill
Ihis may present a potential lor leaching of
contaminants into the groundwaicr, which is a
potential source of drinking water
Groundwater monitoring will ensure
compliance with the stale MCLs
Ihis alternative includes the onsile disposal
of treatment residuals into an on-site landfill
Ihis may result in point source contamination
presenting a significant risk to groundwater,
through leaching of contaminants.
Groundwaler monitoring will ensure
compliance with the stale action levels.
This alternative may include the onsile
disposal of treatment residuals into an on-site
landfill. 'Ihis may present a potential for
leaching of contaminants into the
groundwater, which is a potential source of
drinking water Grnundwater monitoring will
ensure compliance with the state MCLs
This alternative may include the onsile
disposal of treatment residuals into an on-site
landfill. This may result in point source
contamination presenting a significant risk to
groundwaler, through leaching of
contaminants. Gronndwaier monitoring will
ensure compliance with the stale action
levels.
This alternative includes the onsite disposal
of treatment residuals into on-site landfill
'Ihis may present a potential for leaching of
contaminants into the groundwater. which is a
potential source ol drinking water.
Groundwater monitoring will ensure
compliance with the state MCLs.
This alternative includes the onsile disposal
of treatment residualrinto an on-sitc landfill
This may result in point source contamination
presenting a significant risk to groundwater.
through leaching of contaminants
CiroundwatCT monitoring will ensure
compliance with the state action levels.
This alternative does not involve on-site
disposal of SVOC contaminated soil
This alternative does not involve on-siie
disposal of SVOC contaminated soil
5 of 5
Iowa Army Ammunition Plant
Soils OU91, Record of Dectston (Revision No 1)
ll/*l- 1\PROJEC TS-1\&4
August 14. 1998
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1 Alll.f IS
COMIM IA NO' OK AI TFRNAIIVFS WITH ACTION-SPFfTFH AKAKS
IOWA ARMY AMMI'NIIION PLANT. MIIXH.F I O\VN. |O\VA
ARAR
Citation
Kiphmvr*. Cunt am in a fed Soils
Thermal Treatment
Biologic il Treatment
F,ip|o*ivc* I'lut MrfaU Contaminatrri Suili
SoJidificmtinnf Stabilization wit
Activated ( •rhon
NVOC Contaminated SmK
Off-Site Di
CI-RCl.A Section I2MM
(Preference lor treatment)
Ihis alternative involves Ihennal treatment of
contaminated soils I his alternative ensures
compliance with CI-.KCl.A's preference |nr
tieatmrnt. anil compliance with the
cs1;tblished M) percent treatment goal.
Ihix alternative involves biological treatment
ol contaminated soils This alternative
ensures compliant e wiih CTRC'LA's
prelerenfe lot treatment, and compliance with
the established 50 percrnt treatment poaJ
This alternative involves
sulidifk;itinn/stahili?£tjon ol contaminated
suits This alternative ensures compliance
with CI-'RCI;A's preference COT treatment, ami
compliance with the established 50 percent
trealmcnl goal
Ihis alternative involves diiqwsal to a lamlfill
of contaminated soils If these contaminated
soils a/e rcslncicd Irom land disposal.
alternative treatment levels will be met before
disposal in;i landfill
Solid Waste Disposal Act. as amended by the
Resource Conservation ;uid Recovery At I (RCRA). -12
U.SC' ftWI ttxeq
40 CFR 26R Siihf arl« A and I»
[ljuitl Dispcisal Rcstnctions]
This alternative may involve disposal to n
landfill ot metals - conlaniinatcd soils that
have hern solidified and stabili/eil If these
contaminated soils arc restnrted Irom land
ili^os.il. allrmative trcatnirnl levels will he
mrl bclon: dt^iosal in a land Ml I
7nis alternative mav involve disposal to a
landfill of ntetnls - contaminated soils that
have hern snlulifici) »nil stanilizetl It the.se
cimt.irtiinatcd soiU are restncted Irom land
di^ntsal. ahemativc tfcilmcnt levels will he
mcl before dispos:il in » hindt'ill
1 nis alternative mav involve disposal to a
landfill of metals - c on lain mated soih lhat
have been solidified ami stflbili7«l It thes«-
innlamin.itrd .coils juc rrTlncIrd linm huid
cli-^iosal. altcmaUve trcalmenl leveK viill bt-
met before disposal in a landfill
This alternative involves disposal In a landfill
ol contaminated soils It these (.onl.-umn.itrd
soils arc restnctwl Irom land disposal,
alternative I real mm I lt-\i:N will be* mrt before
tli^tos^il in ii l:uidfi||
Iowa 1-nvironmenUi) Unaliiv Act (II IJA). I A (' .
Division 5n7. Title X. Chapter 1-11. lla/aidou* Waste
40CKR26I 21 -2M 2-t. ;oijftam
l:\ravjted soils will be identified as either
RCRA nr non-RCRA h;t7.aidous wastes This
allemalivr wil| comply with the relevant and
appropriate action f^iecific requireincnb;
\\ ithm the state's hazardous waste propiam
l:\eavalcd) soils wiH be idenUfinl as nthcr
RCRA or non-RCRA hayardous waste*. Ihis
allrrnative will eomph w-ith the rrlevunt and
appropriate action-specific requirements
within the state's ha*;inlmis waste pmptam
I xcavated soils wi)t br identified as either
RC'RA or nun RCRA h;i/ajdoiis \\;islfs T\»\
alternative, will comply with the relevant and
appropriate action ^>eciftc retjiiireiiiL'nts
within the state's ha/afdnus waslc
JFOA.I AC .l>ivismn ^,7. Title X. Chapter 141.
Waste
40CKK2n| 12(MlnpiLi)al I AC l-*12|l)» .
(Criteria for l.ixlmg RCUA lla/anlons WaslesJ
I'lloi In placrment m the CAM! I. exeavatcd
soils will be tested lo determine if the lisled
K( RA li:i/:ir«lnus waste KIM 7 is present
(biisrd on ipnilabtlilv) '111is aMcmaUve will
tcMUplv with (he. relevant and appmpriaU1
attmn-spcufii tt-qtiircincnlN within I he state's
11,t/,ifiInu>. \\ aslt: propram
Tnor to placement «n thr CAM11, excavated
soils w-ill he icslcrl to determine if the listed
KCRA ha7nidtiu5 waste K(M7 is present
(based on ipmtahilily) Inis alternative will
cumplv with the relevant mul appropriate
;u tioir^>ecilic rcijuirctnents willnn the slate's
ha/ardons viaste piofraiti
Prior to placement in \he CAM1). e^cavated
soils will he (rsted lo drtermine if Uic listed
RCRA hazardous waste K<*47 is present
(based on ipnitability) Hus aJtcmalive will
tomplv with the relevant and appropriate
aclion-.^iei ific requirements within the slate's
hazardous waste pn»pram
Prior to placement in the CAMU. excavated
soils will he testa! lo determine it Uic listed
RCRA ha/aidous wa>slf KH-17 is present
(based on ignilabilily) ITiis altemalive will
comply with the relevant and appiopttatc.
nction-spet ilir re(|Hiremenls«iUnn tin- stale's
lia/urdons wa
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I ABU* IV
COMI'lltM KOK4I UKNAHVJSUITN A< rinNAPF* IFI< ARAKS
lOU-t AKMN ,\MMrMHf »N|'| AN I MlhlH.l 'I OWN. IO\V,\
AKAR
< tlatitm
Kipl«»nr» 4 nntitminalrd
thermal Trratmrnt
rvBtmmi
Pin* MrtjU Omiaminafrd
SdlulifualiWStabtlitatinn with
Activated Carbon
SV'OC Cnnlaminafrd S«il%
Off-Sitv I
IFQA. I A C . Division V.7. l,(Jr X. Cfoqitrr Ml.
IU?anlous Waste
40 CMl 2M 14 (adopted :il I A C Ml
(Rccurilv Renum'iiuiiK|
1 uiaiithnn/ed persons and livestock will he
re-slri*. led (mm all active portions ol Ihe
IAAAI* during soil remediation actions, nsin
Inume and site control measures
I'nauUiori/ed persons end livestock will he
restricted Irom all active portions of (he
lAAAPdunnp SIM! remediation actions, using
lenuup and sttc control measures
Iliuuthorvrd persons and livestock will he
restricted (mm all active portions of the
IAAAI1 durinp soil remediation actions, using
Icncinp nnd sitcmntrol measures
I mauUion/ed persons ami livestock u ill he
restncled from .ill active portions ol the
IAAAP diinng soil remediation actions, usinp
lencmp and site control measures
H-:OA. I AC., division V.7. lulc X. Chapter |
tis Wnsle
|\ or hit/ardons based on the
char;rcteristics of ipnilahitily or reactivity
rrecaiilions will he taken to prevent
accidental ipmtjnn or rejclion ol ipnit;ih|e or
Contaminates I soils may he incompatible w i»h
each other or with harwdous waste* in the
soil tqtosiiorv, orha/afflous based »»llie
charattenstics ot ipnilabilitv or rciclivilv
!vrec.iiilioiis will be t;0ten to prevent
iUcidenLil ignition or r cat. t ion o| if? m table or
re.iilive wastes
Contaminated soils m;iv he mcompatihlc with
each oilier or with hiuardous waste-* in vhr
sod Ttptisilor*. or hn/nnlotis based i>n thr
th:ujctensites of iprtitjibiliiv or rcaciivii\
Tre* aiition-j u ill be taken to prrvcnt
;K ci'lent;tl i^nihnn cr rc.ution nl i^tiM;il>|f m
n-jii »IVL- \ia--1e':
IFQA, I A C , Division Sf,7. litlc X. Chapter Ml.
40 CFF I'art 264. Siibparl I- (adoplcd at I A (
141 S|45
I nis alternative involves (he disposal of
certain treated conUinimited soils niln a
landfill which is a land di5posa) unit
Measures will ensure ihis alternative will
nice! Ihe prnundu-iilcr protection
I his ajlcniative m»v involve ihe disposal ol
treated and untreated (ontarnmaled soils into
a landfill which is a land di^>osaj unit
Measures will ensure the alternative will meet
(he pioumlwatcr protection requirements
This alternative invokes Ihe disp"s;il o|
cerum treated contaminated soils into a
landfill which is .1 land di.^Misa) tintl
Measures will ensure Uus alternative will
meet the pmuiidwater pmtccUon
iis allcm-ilive dors not involve on-si
pos.-il n( SVOC (OiiUimmalcd Soil
IFOA.I AC .Division 5(-7. bile X. Chapter Ml.
lla?jwtous Waste
40CrRrart2M. Stib|);iiiii|adnpirtla»| A t
141
Ifcis alli*m:itive involves the dtspnsil nl
cerlam treated containmatrr) soil.s into a
landfill Die atlrnialivc url) comply uiih the
closure anil pixt-ilos-rirc rr<)iiimiienK uhrn
the soil rf|M)Mtor\ is ilosfil
Hits iiitrntative mav involve the dij^wsiil oj
(rcatetl and untreated conl.'immated soils into
;i I:uidl"i11 Hie alternative will comply with
the fliiMirc ami post-closure m|uiremmls
« hen l(u* soil repository is closed
l^iis allcmative involves Ihe disposal of
certain treated contaminated soils into a
landfill I>ie alternative will cornplv with the
closure and post-closure rei|tiironcnls whrn
tin* soil repository is closed
Tins alternative does not involve on
J Closure and I'osl-ClosMri- KcijmrnTi
low* Army Ammunition Plant
Sols OU*l. Record of OeciMnn (Revision No It
1998
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TABLE IV
rrx OF AMTRNATIVF.S WITH ACTION-SPEC inr ARARS
IOWA ARMY AMMUNITION PLANT, MIDIM > I OWN. IOWA
ARAR
Ciutittn
Contaminated Sml*
Thermal Treatment
Biological Treatment
ntivfi Plot Mr tali Contaminated NmU
KolidifitaCinn/StabiNzatiun with
Activated Carhnn
SVOC Ctmtaminafrd SniK
OIT-Sifr Dit
IF.QA.l All .l>ivitiniiSii7. litlcX.Criaptn 141.
I Inzjirdous W«5tr
40 CJH Pafl 2M. Snhpart I (adopted at I A T
| Requirement 5 for I Kr and Man;ip cment of
Containers) __
Suil;it:r water Irom excavated areas, and
decontamination water may result tmm this
alternative Storape ol these waters in
containers would be necessary until treatment
ajidMr disposal could occur I he alternative
will comply with the requirements tnr the use
and management ol containers.
Suifacc water from excavated areas, anil
deviontnmination water may result tmm this
alternative Storape of these water* in
container; would he necessary until treatment
and/or disposal could occur Hie alternative
will complv with the requirements tor the use
and management «l containers
Surface water fmm excavated areas, and
decontamination watey may result Imrn thii
alternative Storape of these waters in
containers would he netesxarv until treatment
and/or disposal could occur. I he alternative
will comply with the requirements fur the use
and management of containers
Surface water from excavated areas, and
decontamination water may result I mm this
alternative Storage of these waters in
containers would he necessary until treatment
and/or disposal could occur "Pic alternative
will comply with the requirements lor the use
and management of containers
1EQA, 1 A C , Division M.7. Title X. Chapter 141,
Ha?jwk>us Waste
40 CFR Part 2M. Siihp.irt I. fiidopted at I A C
141 1
soils may he temporanly slored in
piles pnor to treatment ami/or disposal l>us
alternative will complv with the requirements
tor storage of ha/ardons waste in piles
F.xcavated soils may l>e temporarily stored in
piles phor to treatinent and/or disposal This
alternative will cnmply with the requirements
for stonipe of ha/ardoiis waste in piles
I'.xcavated soils may be temporanlv stored m
piles prior to treatment artd/nr disposal Ihis
alternative will comply with the rctpnremenlt
for sinrape of ha?aidous waste in piles
r.xcnvated soils may he temporanlv stored in
piles pnor to treatment and/or disposal 'Ihis
ahcniative will comply with the requirements
lor storage of hazardous waste m piles
fRequircmenls for Sinwpenf ll.v.irdous Wastr in
Piles)
ffiOA, I.AC . Division 5*7. I itieX, fritter 141,
Ha7A/xlnus Waste
40 CFH Part 2M. Suhp.irt N (iidnpted ul I A C
Ihis alternaltve involves the di^osal of
certain treated conlammaled soils into a
laiidliH llic allernaUve will comply with the
di.-^osal reqiiircrucnls
This alternative may involve the di.^tosal of
treated and untreated contaminated soils into
a landfill The alternative wilt complv with
Ihe disposal requirements
This alternative invo|ve5 the di.^>opcr;ilnip and
nionilorinp ru
This alternative does not involve Ihe
immeralion
This alternative does nol involve Ihe
incineration of contaminated stnN
[ Requirement'; for hit ini-r;flmti <>| M;i/;u*l
-------
I AH1> IS
COMIM.tANO: 01- Al.TKKNAl IVKS WITH AC TION-Sl'tl IKIC ARAKS
IOWA AKMY AMMUNITION 1'l.ANT. MIDlH.tlTOWN. IOWA
AKAR
Citation
KipluiivM CtinfftRiinaled Soil*
Thermal Treatment
Biological Treatment
Fipln»ivrs Plus Mt'Ul* Contaminated Soils
Sutultficatinn/Slahilizattnn with
Activated Carbon
SVCK' Contaminated Soil*
Off-Site Diipnsa
IEQA. LA C. . Division 567, Tide X. Chapter Ml.
Hazardous Waste
40 CFU t'art 2fc4, Subpart S <8doplcd at I A C
141 5|455H|)
(Corrective Action (01 Solid Waste Management
UniLs)
Contaminated soils will be stockpiled in a
C A Ml' pnor lo treatment This alternative
will comply with the substantive
requirements 1m CAMUs.
Contaminated soils will he stockpiled in a
CAMD pnor to treatment Ihts alternative
will comply with ihc s
requirements tin CAM Us
Contaminated soils wtll he stockpiled in a
CAM1) pnor to treatment ThisaJtcmdtive
will comply with ihe substantive
requirements tor C AMI Is
(.'ontan)milled soils will he stockpile*! in ;i
CAMIt pnof to IrcaUncnl MIIS alternative
will comply with the siibstajiUvc
rcquiienietits toi i'AMI Is
. I AC. Division Sii7/hilcX. Chapia I-IJ. - •
Hazardous Waste
4(1 LTK I'art ?M. Suhpait DDfadnpletl at I A<
141 5|4S5»|)
(Kequimiicnt.s Ini ( tiin|<>stinf
(if imilariiiri.ticd soiK ui i oiitaifiiitent
IF.QA, I A C . Division M*7. I ille II. Chapter 2^.
(•mission Standards tni
I AC 233(2KcXD
(Fugitive I>usi Con(ro)>)
'this alternative involves the excavation n|
contaminated suits and the transport o( these
.soils to citiicr treatment or disposal areas
ITitr allcTiuttvc also involves coiisinjction
ailivitics Control measures will be
nnplenienicd In limit fugitive dust emisMoits
ih.it niiiv result Irom renicdul actions
llus alternative involves the excavation ol
contammulei.1 soils and Uie Iran sport ol these
soils lo either treatment or disposal areas
llic alternative also involves construction
aclivjues. C!oiiuj-il uieitsuresuill be
unpletnenicd lo limit fugitive dust emissions
th.il may result Irnm remedial actions
This allemaUve involves ihe exeavahon ol
contamiiittted soils and the Iranian <>( Uiev-
soils to either treatment or disposal ;ireas
Hie alternative also involves lonstrmlion
activities Control measures wit) he
implemented to limit fugitive du.-.i entissions
that may result Irum rvmcdial actions
This alternative involves llie excavatton ol
contamuuited sotls ;uid Uie u:ui^iort ol UIC-M-
soils to either U*c;iUiienl or disjios^l uie:iN
{lie altcni;iiivc a I NO involves mn^iniLltoit
acttviUes ('out/I*! nicitstircs u itl he
implemented to hunt htjiilivc dtist einissiiin.
thut may rcsull trom rciueitiiil ;n.tiitn.s
4 ol 4
fowd Aftny AfT»muotinMi Cf
Soi/s QU91 HetottJ of liftm
ivon A/<> 1)
>998
-------
• Chemical - specific ARARs relating to ambient air quality standards specified under
IAC 28.1 (455B), visible emission standards specified under IAC 22.3 (3), paniculate
emission standards specified under IAC 23.3 (2) (a) and Table 1, and fugitive dust
emissions standards specified under I AC 23.3 (2) (c) (1).
• CERCLA's preference for treatment specified under Section 121 (b).
• Land Disposal Restrictions for treated soils and residues specified under 40 CFR 268
Subparts A and D.
• Requirements for incineration of hazardous waste specified under 40 CFR 264, Subpart
0, for the selected remedy.
• Requirements for composting of hazardous waste in buildings specified under 40 CFR
Part 264, Subpart DD, for the contingent remedy.
• Requirements for surface water quality criteria and discharge limitations specified under
IAC 61.3 (455B) and 33 USC Section 402.
2.10.3 Cost Effectiveness
The selected remedy is cost-effective because it provides overall effectiveness proportional to its costs.
LTTD Thermal Treatment, the preferred technology for treatment of explosives-contaminated soils,
appears to be the least costly technology based on information currently available. If a combustion
facility risk assessment and additional process development and economic evaluations show that LTTD
Thermal Treatment cannot be conducted in a protective manner, appropriate documentation will be
prepared for review and submitted to the administrative record, and the contingency remedy of Biological
Treatment will be implemented. Solidification/stabilization of explosives plus metals contaminated soils
ancfoff-site disposal of SVOC-contaminated soils provide«-eveTalt-protectiveness equivalent to other
alternatives, at lower costs.
2.10.4 Use of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
Superfund specifies a preference for utilization of permanent solutions and innovative treatment
technologies or resource recovery technologies to the maximum extent practicable. The selected remedial
action permanently destroys or degrades and stabilizes contaminants in explosives-contaminated soils, and
permanently stabilizes contaminants in explosives plus metals contaminated soils. Off-site disposal of
SVOC-contaminated soil contains contaminants rather than degrading them, and requires long-term
landfill operation and maintenance to ensure continued effectiveness. On-site treatment for this small
volume of SVOC-contaminated soil was determined to be not cost effective. The Army and EPA believe
Iowa Army Ammunition Plant 59
Soils OU#1, Record of Decision (Revision No. 1) August 14, 1998
-------
the preferred alternative provides the best balance of trade-offs among the alternatives with
respect to the evaluating criteria.
2.10.5 Preference for Treatment Which Reduces Toxicity, Mobility, or
Volume
Both LTTD Thermal Treatment and Biological Treatment will reduce explosives contaminant
levels below remediation goals, although Thermal Treatment will provide a greater degree of
reduction in contaminant toxicity and mobility. LTTD and bio-slurry treatment are not
expected to change soil volumes significantly as a result of treatment; composting will result
in a volume increase of 150 to 200%. Solidification/stabilization of explosives plus metals
contaminated soils and off-site disposal of SVOC-contaminated soils will provide for reduction
of contaminant mobility only.
2.11 Documentation of Significant Changes
The Proposed Plan specified management of thermal treatment residuals in the Soil
Repository. This ROD provides for the potential management of these residuals outside of the
Soil Repository in an appropriate manner protective of human health and the environment.
Thermal treatment will destroy contaminants and, therefore, disposal of thermal treatment
residuals outside the Soil Repository will not comprise protection under this alternative. This
disposal method will save landfill space which may be better used for more highly
contaminated materials from other sources and, therefore, is considered cost effective.
owa Army Ammunition Plant
ils OU#1, Record of Decision (Revision No. 1)
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3.0 RESPONSIVENESS SUMMARY
The Proposed Plan for final action for the Soils OU #1 was released to the public on June 20, 1998.
A public comment period was held from June 20, 1998 to July 20, 1998. During this period, no
comment letters were received. In addition, a public meeting was held on July 9, 1998. At this
meeting representatives from the Army and EPA were available to the public to discuss concerns,
accept comments, and answer questions regarding the preferred alternative presented in the Proposed
Plan. -
This Responsiveness Summary serves two functions First, it summarizes the comments of the public.
Second, it provides responses to the comments on the Proposed Plan that were made at the public
meeting.
3.1 Overview
The preferred alternative selected jointly by the Army and EPA and presented in the Proposed Plan
involved on-site LTTD Thermal Treatment of explosives-contaminated soils as the preferred remedy,
with Biological Treatment as the contingency remedy pending results of feasibility testing and field
demonstrations. The preferred alternative also included on-site solidification/stabilization of
explosives plus metals contaminated soils and off-site disposal of SVOC-contaminated soil.
Verbal public comments on the preferred alternative were documented at the public meeting on July
9, 1998. No written comment letters were received .during the public comment period.
Commentors expressed interest in the following issues:
• Alternative equipment for LTTD (use of existing on-site incinerators; use of mobile
equipment). - . .._>'—-—
• Usability of soil after treatment.
• Health risks of LTTD treatment
• Transportation and off-site disposal locations for SVOC - contaminated soil.
3.2 Background on Community Involvement
Overall, the opportunities for participation of local stakeholders in CERCLA actions have been
provided through two principal mechanisms. First, documents prepared that lead to decisions have
undergone public comment periods, with document availability announced in the local media. Second,
an 1AAAP Restoration Advisory Board (RAB) has been established to enable the community and
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
61 August 14, 1998
-------
representatives of government agencies to meet and exchange information about the lAAAP's
environmental cleanup program and to provide the community an opportunity to review progress and
participate in dialogue with decision makers.
The RJ/FS and Proposed Plan for the Interim Soils OU were released to the public in November 1996
and May 1997, respectively. A public comment period was held from May 28,1997 to June 30,1997.
In addition, a public meeting was held on June 5,1997 at the Danville Community Center. There were
no written or verbal comments regarding the Proposed Plan submitted to the Army at this meeting or
during the comment period.
This Final FS and Proposed Plan for Soils OU#1 went through a similar public review and comment,
in compliance with NEPA. The Proposed Plan for final action for the Soils OU #1 was released to the
public on June 20, 1998. This document was made available to the public in both the administrative
record and the site information repositories. The notice of availability for the Proposed Plan was
published in the Burlington Hawk Eye on June 20, 1998 and later published in the Ft. Madison Daily
Democrat. A public comment period was held from June 20, 1998 to July 20, 1998. In addition, a
public meeting was held on July 9, 1998 at the Pzazz Best Western Motor Inn in Burlington, Iowa.
At this meeting representatives from the Army and EPA were available to the public to discuss
concerns, accept comments, and answer questions regarding the preferred alternative presented in the
Proposed Plan. Comments submitted to the Army were considered in final selection of the remedial
action.
The RAB was organized in mid-1997 and has held public meetings generally monthly. Typically these
meetings include environmental cleanup progress reports, explanations of the regulatory process, and
informational handouts and exhibits. Tapes, minutes, and attendance at the meetings is available from
the IAAAP Environmental Affairs Office.
Documents prepared as part of removal or remedial actions, aUAAAP have be placed in the site
Administrative Record file, which is located in the following public information repositories:
Iowa Army Ammunition Plant Burlington Public Library
Visitor Reception Area 501 N. Fourth Street
Building 100-101 Burlington, Iowa 52601
Middletown, Iowa 52683-5000 (319) 753-1647
(319)753-7710
Iowa Army Ammunition Plant
Soils OIMM, Record of Decision (Revision No. 1)
wm-iv>iioiECTs-i\sM«_ii««UKWoo««44«/M02xpd 62 August 14, 1998
-------
Danville City Hall
105W. Shepard
Danville, Iowa 52623
(319)392-4685
The Army has coordinated selection of this remedial action with the U.S. Environmental Protection
Agency (EPA). The Army is the lead agency for implementing the remedial action at the 1AAAP.
As the support agency, the EPA oversees the cleanup activities conducted by the Army to ensure that
requirements of CERCLA/SARA, the NCP, and the Federal Facilities Agreement between the Army
and the EPA have been met. The State of Iowa has declined to participate in the review of CERCLA
clean up activities at the IAAAP.
3.3 Summary of Public Comments and Agency Responses
This responsiveness summary includes statements made at the July 9, 1998 public meeting (no
additional comments were submitted in writing during the comment period). It also includes Army
and EPA responses to those comments and questions. Comments and questions have been
paraphrased or quoted in italic text. Every attempt has been made to accurately preserve the intent of
the comment and to include all issues raised. Individual comments are grouped into common issues
to avoid repetitiveness in responses.
ISSUE 1: Can existing on-site incinerators be used for treatment of contaminated soil?
Due to differences in materials handling requirements, volumes, and operating conditions, existing on-
site incinerators are not suitable for treatment of contaminated soils. Permitting issues and air
emission control requirements would also be significantly different. The selected remedy uses
equipment specifically designed for treating contaminated soils.
ISSUE2: Will the selected remedy destroy organisms present in the soil, making it difficult to use
it for anything?
LTTD will degrade other organic compounds in the soil in addition to degrading explosives. The
degree of degradation will depend on the characteristics of particular compound (i.e., boiling point,
vapor pressure) and the operating conditions used for the LTTD unit. LTTD exposes contaminated
soil to a much lower temperature than incineration (typically 200 to 600 °F in the primary chamber for
LTTD vs. 1400 to 1800 °F for incineration). While these LTTD operating conditions are known to
be effective for destroying explosives contamination, information is not necessarily available to predict
the degree of destruction for other, desirable, organic compounds. However, LTTD typically does not
produce as much of a volume reduction as incineration and therefore can be presumed to be less
destructive than incineration. Contaminated soil requiring treatment is primarily clay, so loss of
productivity will be less significant than if it were primarily topsoil.
Iowa Army Ammunition Plant
Soils OLDH1, Record of Decision (Revision No. 1)
63 August 14, 1998
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ISSUE 3: To minimize capital costs, will treatment equipment be reusable at other facilities?
The LTTD treatment equipment will be modular, trailer-mounted, mobile equipment brought to the
site and operated by a contractor specializing in providing soil remediation services. While the
equipment may require special modifications to adapt to site-specific conditions, it likely will have
been used previously at other sites and will be intended for use again elsewhere in the future. The
Army will be purchasing a service rather than purchasing a piece of equipment.
ISSUE4: Have sites been identifiedfor off-site disposal ofSVOC-contaminated soil? How would
the soil be transported? How can we visualize a volume of 200 cubic yards?
Cost estimates presented in the Proposed Plan and ROD were based on conversations with
representatives from three commercial waste disposal companies: American Waste Group, Laidlaw
Environmental Services of Illinois, Inc., and Waste Management, Inc. Disposal could be at any of
several licensed waste disposal facilities operated by these or other companies. Competitive bids will
be solicited prior to actual implementation, and a specific contractor and disposal facility will be
identified at that time. Transportation would most likely be by truck. The largest roll-offbox typically
used for over-the-highway transportation of wastes has a volume of approximately 20 cubic yards.
Assuming they are typically loaded half-full (10 cubic yards each), 200 cubic yards represents about
20 truckloads. Viewed another way, 200 cubic yards represents a block 15' by 15' by 24' in
dimensions.
ISSUE 5: Will the proposed cleanup process produce additional carcinogens that the public
should be aware of? Will the LTTD unit have continuous monitoring of air emissions?
LTTD operates by volatilizing contaminants in the soil (heating them until they are converted to a
gaseous state) and burning them under controlled conditions in a secondary combustion chamber.
Comhustion results in essentially complete destruction of contaminants to carbon dioxide and water.
However, no process in 100% efficient, and trace amounts of byproducts (products of partial
combustion) may be expected to remain. The LTTD unit will be equipped with appropriate air
emission control facilities, such as filters and wet scrubbers, to clean the off-gases prior to release to
the atmosphere. The specific operating conditions of the LTTD unit (i.e., temperature, residence time,
oxygen requirements) will be determined based on a trial burn, with the purpose of maximizing
contaminant destruction as required to protect human health and the environment. In addition, a
combustion risk assessment will be completed prior to implementation of the selected remedy. The
combustion risk assessment is intended to identify potential byproducts and, through an evaluation of
site-specific conditions such as prevailing winds, evaluate the potential impacts on receptors. The
results of the risk assessment will be used to establish requirements for safe operation to control
unacceptable risks. The combustion risk assessment will be reviewed by experts within both the Army
and EPA who are experienced in thermal treatment of explosives-contaminated soils at other
installations. Emissions monitoring during operation will ensure that the unit is operated in
compliance with the requirements established by the risk assessment. Army and EPA representatives
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
64 August 14, 1998
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indicated that results of a combustion risk assessment would be shared with the public prior to
implementing any thermal treatment operations associated with this ROD.
Iowa Army Ammunition Plant
Soils OU#1, Record of Decision (Revision No. 1)
63 August 14, 1998
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