PB98-964310
EPA 541-R98-174
March 1999
EPA Superfund
Record of Decision:
Lake City Army Ammunition
Plant (NW Lagoon)
Independence, MO
9/29/1998
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Final
Record of Decision for
Interim Remedial Action at the Northeast
Corner Operable Unit
Lake City Army Ammunition Plant
Independence, Missouri
Prepared for
Lake City Army Amrnunitipn Plant
This ROD is for an interim action at the NECOU and is limited in scope. While it is
anticipated that the components of this ROD will become part of the final action, the final
ROD will provide for long-term protection of human and the environment, addressing of
principal threat posed by source areas, and fully address the statutory preference for
treatment. The reader should keep in mind that the ROD is a modification of the
"standard ROD" format since it is interim and limited in scope.
SEPTEMBER 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake Cit\ Army Ammunition Plant, Independence. Missouri
TABLE OF CONTENTS
Chapter Page
1.0 DECLARATION FOR THE RECORD OF DECISION 1-1
1.1 SITE NAME AND LOCATION 1-1
1.2 STATEMENT OF BASIS AND PURPOSE 1-1
1.3 ASSESSMENT OF THE SITE 1-1
1.4 SITE DESCRIPTION 1-1
1.5 DESCRIPTION OF SELECTED REMEDY 1-2
1.6 DECLARATION 1-2
1.7 SIGNATURE AND AGENCY CONCURRENCE ON THE REMEDY 1-4
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME AND LOCATION 2-1
2.2 NECOU DESCRIPTION/HISTORY AND REGULATORY OVERSIGHT
ACTIVITIES 2-1
2.2.1 LCAAP Description/History 2-1
2.2.2 NECOU Site Description/History 2-1
2.2.3 Regulatory Oversight Activities 2-2
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION ..2-2
2.4 SCOPE AND ROLE OF RESPONSE ACTION 2-4
2.5 SITE CHARACTERISTICS 2-5
2.6 SITE RISK SUMMARY 2-5
2.6.1 Risk Assessment Process 2-6
2.6.2 Human Health Risk 2-7
2.6.3 Ecological Risk 2-8
2.6.4 Interim Action Risk Reduction ;...... 2-8
2.7 DESCRIPTION OF ALTERNATIVES 2-8
2.7.1 Alternative 1: No Action 2-9
2.7.2 Alternative 2: Source Area Cover/Permeable Reactive Wall (PRW) 2-9
2.7.3 Alternative 3: Source Area Cover/Ground Water Extraction
Wells/Treatment at the Area 18 Ground Water Treatment
Plant 2-11
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 2-12
2.8.1 Overall Protection of Human Health and the Environment 2-13
2.8.2 Compliance with ARARs 2-13
2.8.3 Long-term Effectiveness and Permanence 2-14
2.8.4 Reduction of Toxicity, Mobility, or Volume Through Treatment 2-15
2.8.5 Short-term Effectiveness 2-15
2.8.6 Implementability 2-15
2.8.7 Cost 2-16
2.8.8 Regulatory Acceptance 2-17
2.8.9 Community Acceptance 2-17
2.9 SELECTED ALTERNATIVE 2-17
~~i September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Comer Operable Unit
Lake Cirv Armv Ammunition Plant. Independence. Missouri
2.10 STATUTORY DETERMINATIONS 2-18
2.10.1 Protection of Human Health and the Environment 2-19
2.10.2 Compliance with ARARs 2-19
2.10.3 Cost Effectiveness 2-19
2.10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies
to the Extent Possible 2-19
2.10.5 Preference for Treatment as a Principal Element 2-20
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES 2-20
3.0 LIST OF ACRONYMS AND ABBREVIATIONS 3-1
a September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake Cirv Armv Ammunition Plant, Independence, Missouri
APPENDICES
Appendix A Figures
Appendix B ARAR Table
Appendix C Ground Water Treatment Discharge Criteria
Appendix D Responsiveness Summary
LIST OF FIGURES
Figure 1 LCAAP Location Map
Figure 2 NECOU Location Map
Figure 3 Solid Waste Management Units at the NECOU
Figure 4 Alternatives 2 and 3
Figure 5 PRW Schematic
Figure 6 Ground Water Treatment System Schematic
iii September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Arm\ Ammunition Plant, Independence. Missouri
1.0 DECLARATION FOR THE RECORD OF DECISION
1.1 SITE NAME AND LOCATION
• Northeast Corner Operable Unit (NECOU), Lake City Army Ammunition Plant
(LCAAP), National Priorities List (NPL) Site, CERCLIS #M04213820489.
• Independence, Jackson County, Missouri.
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document describes the selected Interim Remedial Action (IRA) for the LCAAP
NECOU, in accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP).
This decision is based on the contents of the Administrative Record for the NECOU, LCAAP.
The U.S. Environmental Protection Agency (EPA) and the Missouri Department of Natural
Resources (MDNR) concur with the selected Interim Action alternative.
1.3 ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the NECOU, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
1.4 SITE DESCRIPTION
The Northeast Corner Operable Unit (the subject of this IRA ROD) is a 190-acre area
comprising solid waste disposal areas and burning areas. The NECOU is currently at the
feasibility study stage. This ROD is for an IRA at the NECOU and is the second ROD for
LCAAP.
The remedial action objectives (RAOs) for this IRA at the NECOU are:
• Reduce further migration of ground water containing COCs at concentrations above
cleanup goals from the NECOU to the Lake City Aquifer.
• Minimize further migration of chemicals from the soil in the Area 17 Oil and Solvent
Pits to ground water.
These RAOs are consistent with the overall NECOU management strategy which is:
• The use of EW-2 (or other containment components) to remediate contaminants
dissolved in the ground water in the Lake City Aquifer and minimize the potential for
1-1 September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Comer Operable Unit
Lake Cm Army Ammunition Plant, Independence, Missouri
offsite migration of contaminants in the ground water. Additional actions may be
needed to address potential off-Post contamination.
• IRA to minimize migration of contaminated ground water from the uplands to the
Lake City Aquifer. The selected alternative in this ROD includes installation of a soil
cover to minimize infiltration through contaminated soil at the Area 17B Oil and
Solvent Pits and installation of a PRW to intercept contaminated ground water as it
moves from the NECOU toward the Lake City Aquifer.
• Additional studies to assess the extent of contamination at the NECOU and possible
action to mitigate source areas.
1.5 DESCRIPTION OF SELECTED REMEDY
The major components of the selected IRA for the NECOU include the following:
• Installation of a subsurface permeable reactive wall (PRW) to treat contaminated ground
water in place (in-situ).
• A monitoring program to evaluate the effectiveness of the PRW in treating the
contaminated ground water and to determine the replacement period of the reactive
media.
• Installation of a soil cover over the Area 17 Oil and Solvent Pits (a principal threat
waste) located adjacent to the current sanitary landfill in the NECOU to minimize
infiltration of water through the pits and subsequently into ground water.
Together, these actions would reduce the potential for further migration of contaminated
ground water from the NECOU to the Lake City Aquifer.
1.6 DECLARATION
This IRA is protective of human health and the environment, complies with Federal and State
of Missouri applicable or relevant and appropriate requirements for this limited scope action,
and is cost-effective. Although this IRA is not intended to fully address the statutory mandate
for permanence and treatment to the maximum extent practicable, it does use treatment in
furtherance of that statutory mandate. Because this action does not constitute the final remedy
for the NECOU, the statutory preference for remedies that employ treatment to reduce
toxicity, mobility, or volume as a principal element, although partially addressed in this
remedy, will be addressed at the time of the final response action. Subsequent actions are
planned to fully address the remaining threats posed by the NECOU.
Because this remedy will result in hazardous substances remaining on site above health-based
levels, a review will be conducted within five years of the commencement of the remedial
action to ensure that the remedy continues to provide adequate protection of human health and
the environment. Because this is an Interim Action ROD, review of this site and of this
1-2 September 1998
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Final Record of Decision for Interim Remedial Action at the Nonheast Corner Operable Unit
Lake City Army Ammunition Plant. .Independence. Missouri
remedy will be ongoing as the Army continues to develop final remedial alternatives for the
NECOU.
September 1998
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Final Record of Decision for Interim Remedial Action at the Noriheasi Corner Operable Unit
Lake City Army Ammunition Plant, Independence. Missouri
1.7 SIGNATURE AND AGENCY CONCURRENCE ON THE REMEDY
/
(ichard R. Thibodeau
lieutenant Colonel, OD
Commander, Lake City AAP
Date
is Grams, P.E.
Regional Administrator
U.S. Environmental Protection Agency Region 7
Da/e /
September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Comer Operable Unit
Lake dry Army Ammunition Plant, Independence, Missouri
Reviewed and Concurred:
Installation Remedial Project Manager
Date
Major Subordinate Command DERP PM
Date
Installation/Major Subordinate Command
Legal Advisor
Date
September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Army Ammunition Plant. Independence, Missouri
2.0 DECISION SUMMARY
2.1 SITE NAME AND LOCATION
LCAAP is a 3,935 acre facility in Jackson County, Missouri (Figure 1). The Department of
Army is the lead agency of this CERCLA site (CERCLIS 0M04213820489). The NECOU is
approximately 190 acres and is in the northeast portion of the Installation (Figure12). Within
the NECOU are landfills and other waste disposal areas.
2.2 NECOU DESCRIPTION/HISTORY AND REGULATORY OVERSIGHT
ACTIVITIES
2.2.1 LCAAP Description/History
LCAAP was established in the early 1940s and was the first government-owned facility
constructed to expand small arms ammunition production. Construction at the facility began
on December 26, 1940 and was completed on October 11, 1941. The Plant has operated
continuously since 1941, except for a 5-year period between World War II and the Korean
Conflict. The operating contractor from 1941 to 1985 was Remington Arms. Olin
Corporation became the operating contractor in November 1985 and continues to operate the
plant on behalf of the Army.
2.2.2 NECOU Site Description/History
The NECOU is approximately 190 acres in-size and is located in the northeast portion of the
Installation. The majority of the NECOU source areas are situated in an upland area composed
of clay and claystone. However, the western boundary of the OU is situated on an area of
transition between the uplands and a lower-lying afea-6ndeTwhich the Lake City Aquifer is
found. Within the NECOU, the Lake City Aquifer is located northwest of Buckner Road. This
aquifer is an old stream channel beneath the ground surface consisting primarily of sand and
gravel. The sand and gravel that make up this aquifer carry significant quantities of potable
ground water.
Ground water is found at depths below five feet in the uplands where most of the contaminant
source areas are located. Ground water in the Lake City Aquifer is generally encountered below
depths of approximately two to ten feet in the NECOU.
Land use in the NECOU is primarily waste disposal areas with surrounding areas of undeveloped
woodlands and fields. Land bordering the installation in the vicinity of the NECOU is comprised
of farmland and several residential dwellings.
The NECOU is comprised of three areas: Area 11, Area 16, and Area 17 (Figure 3). There are
ten solid waste management units (SWMUs) within these three areas. These SWMUs have been
used for a variety of waste disposal activities including open burning of explosives and other
waste; and landfilling of solid waste, industrial sludge, spent solvents, and paints and oils. The
ZH September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Army Ammunition Plant, Independence. Missouri
SWMUs consist of lagoons, disposal pits, and burn pits. Their locations were identified from
aerial photographs spanning the period 1940 - 1990. The Area 11 Burning Grounds was a site
for open burning of explosive compounds and has been closed under the Stale of Missouri
hazardous waste regulations.
The SWMUs within the NECOU and their status are identified as follows (Figure 3):
1. Area 11 - Burning Grounds (Closed but can be used for limited safety and training
procedures)
2. Area 16D - Burning Grounds (inact'ive)
3. Area 17C - Burning Pad (inactive)
4. Area 17D - Waste, Glass, Paint, and Solvents Area (inactive)
5. Area 17B - Oil and Solvents Pits (inactive)
6. Area 16A - Abandoned Landfill (inactive)
7. Area 16C - Firing Range (inactive)
8. Area 17E - Current Pistol Range (used for security force weapons training)
9. Area 16B-Solvent Pits (inactive)
10. Area 17A - Current Landfill (permitted sanitary landfill but not currently being used)
Analyses of soil and ground water samples collected during the RI at the NECOU indicate that
Volatile Organic Compounds (VOCs), Base Neutral/Acid Extractable compounds (BNAs),
explosives, and metals are present above detection limits in these media.
2.2.3 Regulatory Oversight Activities
LCAAP was proposed for listing on EPA's National Priorities List (NPL) in October 1984
with final listing in July 1987, effective August 1987. The site is jointly regulated by the
EPA and the MDNR: ~ The Army, EPA, and MDNR signed a Federal Facility Agreement
(FFA) that became effective November 28, 1989, which defines the procedural framework
under which LCAAP sites will be investigated and remediated, and the roles and
responsibilities of the Army, EPA, and the State of Missouri regarding CERCLA response
activities at the site.
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
Community relations activities that have taken place at LCAAP to date include:
• FFA process - After preparation of the FFA by the U. S. Army, EPA, and MDNR,
the document was published for public review and comment. The FFA became
effective November 1989.
• Administrative Record - Consistent with requirements of CERCLA section 113(k), an
Administrative Record for information associated with CERCLA cleanup activities at
LCAAP was established at LCAAP. The Administrative Record contains information
2-2 September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Army Ammunition Plant, Independence, Missouri
used to support LCAAP decision-making associated with CERCLA issues. All
documents in the Administrative Record are available to the public.
• Information repositories - The Administrative Record is located at the Mid-Continent
Public Library, Blue Springs South Branch (public repository), and the West Gate
(Building 6) at LCAAP.
• Community Relations Plan (CRP) - The CRP was prepared pursuant to requirements
in the LCAAP FFA and is being actively implemented. This plan was updated in
1996.
• Restoration Advisory Board (RAB) - The RAB has been formed to facilitate public
input in the CERCLA cleanup at LCAAP, and meets on alternating months. In
addition to U.S. Army, EPA, and State of Missouri personnel, the RAB includes
community leaders and representatives from the surrounding area.
• Mailing list - A mailing list of all interested panics in the community is maintained by
LCAAP and updated regularly.
- Fact sheet - A fact sheet describing the status of the Installation Restoration Program
(IRP) was last distributed to the mailing list addressees in November 1996.
• Proposed Plan - The Proposed Plan on this Interim Action was made available to the
public for their comments.
The Remedial Investigation/Feasibility Study (RI/FS) and Proposed Plan for the LCAAP
NECOU were released _to the public on April 13_4998i_jrhese documents were made
available to the public in both the Administrative RTcbrd at the LCAAP and in the site
Information Repository noted above. The notice of availability for these documents was
published in the Independence and Blue Springs Examiner on April 11, 12, 18, and 19, 1998.
A public comment period was held from April 13 to May 22, 1998, to allow the public the
opportunity to make comments on the proposed Interim Action at the NECOU. In addition, a
public meeting was held on May 12, 1998, where representatives of LCAAP, EPA, and
MDNR were available to answer questions and accept comments regarding the remedial action
under consideration. A response to the comments related to the action received during this
period is included in the Responsiveness Summary, which is part of this ROD.
This ROD is based on the contents of the Administrative Record for the NECOU, in
accordance with CERCLA, as amended by SARA, and the NCP. The RI/FS reports and the
Proposed Plan for the NECOU provide information about the OU and the selected remedy.
These documents are available at the Information Repositories at LCAAP (West Gate,
Building 6) and the Mid-Continent Public Library, Blue Springs, South Branch.
September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Armv Ammunition Plant. Independence, Missouri
2.4 SCOPE AND ROLE OF RESPONSE ACTION
As wiih many Superfund sites, the environmental problems at LCAAP are complex. This IRA
will begin cleaning up ground water contamination at the NECOU while additional
investigations to support the final action at the NECOU proceed. This Interim Action
addresses part of the risk associated with exposure to contaminated ground water by containing
and treating a known plume of contaminated ground water. In addition, principal threat waste
sources, the Oil and Solvents pits, are being covered and contoured to address exposure to
surface soil containing VOCs and reduce infiltration of precipitation. This action primarily
addresses the migration of contaminated ground water into the Lake City Aquifer. The Final
ROD for the NECOU will address unacceptable risks in the NECOU RI/FS.
In addition to actions related to the other OUs, LCAAP has installed an extraction well, EW-
2, as a separate Response Action. EW-2 is located within the NECOU near the northern
Installation boundary (Figure 4) and was installed to intercept contaminated ground water at
the Installation boundary, prior to its movement off the Installation. Although not a specific
component of this Interim Action remedy, EW-2 will minimize the potential for contaminated
ground water from the NECOU, already downgradient of the proposed location of the PRW,
to move off-Post. The Final Action for the NECOU may incorporate the use of EW-2 as a
containment component of the final remedy for the NECOU.
The RAOs for this Interim Action at the NECOU are:
• Reduce further migration of ground water containing COCs at concentrations above
cleanup goals from the NECOU to the Lake City Aquifer.
• Minimize further migration of chemicals from the soil in the Area 17 Oil and Solvent
Pits to ground water.
These RAOs are consistent with the overall NECOU management strategy which is:
• The use of EW-2 (or other containment components) to contain and remediate
contaminants dissolved in the ground water in the Lake City Aquifer and minimize the
potential for offsite migration of contaminants in the ground water. Additional actions
may be needed to address potential off-Post contamination.
• An Interim Action to minimize migration of contaminated ground water from the
uplands to the Lake City Aquifer. The alternative selected in this ROD includes
installation of a soil cover to minimize infiltration through contaminated soil at the
Area 17B Oil and Solvent Pits and installation of a PRW to intercept contaminated
ground water as it moves from the NECOU toward the Lake City Aquifer.
• Additional studies to assess the extent of contamination at the NECOU and possible
action to mitigate principal threat waste sources.
2-4 September 1998
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Final Record of Decision for Interim Remedial Aciion at the Northeast Comer Operable Unit
Lake City Army Ammunition Plant, Independence, Missouri
2.5 SITE CHARACTERISTICS
VOC contamination at the NECOU originates from SWMUs (principal threat waste sources) in
the uplands and migrates in ground water to the northwest and may have migrated off the
Installation. A conceptual site model (CSM) for the NECOU is as follows:
• Upland VOC source areas include VOCs potentially as dense non-aqueous phase liquid
(DNAPL). These source areas are considered the principal threat for the NECOU. The
upland sources are in areas with low permeability (less than 10~6 cm/sec).
• VOCs from these sources have migrated through low yielding water bearing units to the
Lake City Aquifer. Dissolved phase contaminants have been detected in the Lake City
Aquifer.
• Hydraulics of the Lake City Aquifer are influenced by LCAAP water supply wells and
CERCLA remediation wells (EW-1, EW-2, and 17-FF).
• VOCs have been detected above MCLs in ground water samples collected from
monitoring wells 16-17,16-18, and 16-19 located at the northern LCAAP boundary. In
areas where contaminated ground water may have migrated off-post, no ground water
users have been identified.
At the Area 17 Oil and Solvents Pits, polycyclic aromatic hydrocarbons (PAHs) and VOCs
including trichloroethene (TCE), toluene, tetrachloroethene (PCE), 1, 2-dichloroethene (1,2-
DCE) were detected. These VOCs were detected in two of three (central and western) former
disposal pits. Soil boring data indicates that the central pit contains the highest concentration and
largest mass of VOCs. VOCs were detected in samples to a depth of approximately 43 feet
beneath the central pit, which was the maximum depth of the borings due to auger refusal.
Shallow ground water in the vicinity of the Area 17 Oil and Solvents Pits was also determined to
contain VOCs. Chemicals in ground water at the NECOU were detected at concentrations as
high as 300,000 ^g/L of specific VOCs in the immediate vicinity of the pits to approximately
1,000 Mg/L within 400 feet downgradient of the pits. VOCs from source areas in the uplands
have migrated into the Lake City Aquifer and subsequently appear to be moving off the
Installation. TCE and PCE were the only VOCs detected above cleanup goals (Maximum
Contaminant Levels or MCLs) in the Lake City Aquifer within the NECOU. The maximum
concentration of TCE detected in the Lake City Aquifer was 87^g/L (MCL = 5 ^g/L) and PCE
was detected at a maximum concentration of 8.1 ^g/L (MCL = 5 /^g/L). Figure 4 shows an
approximate representation of concentrations of chemicals detected in ground water at the
NECOU.
2.6 SITE RISK SUMMARY
Based on available data, the greatest potential threat to human health and the environment is
from the migration of source area contaminants to potential receptors using the Lake City
Aquifer. This IRA addresses these risks but is only a partial solution to the overall
environmental concerns at the NECOU. Implementing an Interim Action addresses risk from
September 1998
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Final Record of Decision for Interim Remedial Action at ihe Northeast Comer Operable Unit
Lake City Army Ammunition Plant, Independence. Missouri
migration of contaminated ground water from a portion of the NECOU and allows cleanup of
ground water to begin while a strategy to cleanup the entire NECOU is developed. This Interim
Action may become part of the Final Action for the NECOU.
2.6.1 Risk Assessment Process
A baseline risk assessment (BLRA) was conducted during the RI to identify receptors of
concern, exposure pathways, and contaminants of concern that drive unacceptable risk to
humans. A BLRA evaluates risks under current and anticipated future land uses assuming no
remedial action is conducted. It should be noted that the BLRA data did not indicate the
presence of contaminants off-post. Therefore, the BLRA did not consider current off-post
residents potentially drinking contaminated ground water.
The assessment of human health risks for this OU considered the following topics:
• COCs in soil and ground water samples.
• Current and future land-use conditions.
• Potential environmental pathways by which populations might be exposed.
• Estimated exposure point concentrations of COCs.
• Estimated intake levels of the COCs.
• Toxicity of the COCs.
• Uncertainties in the assessments of exposure, toxicity, and general risks.
Both current site uses and potential future site uses were considered. In conducting this
assessment, the focus was on the health effects that could result from direct exposure to
contaminants by:
• Current workers and mowers at the Plant and workers at the permitted landfill.
• Exposure to contaminants in surface water by current workers and mowers, workers at
the permitted landfill, and offsite children who could potentially play in streams that
drain surface water from the NECOU.
• Exposure to contaminants by hunters who eat deer meat from animals that were exposed
to contaminants at the NECOU.
• Exposure to contaminants in the ground water by future industrial workers and off-Post
residents.
At the NECOU, soil (surface and subsurface) and ground water samples were collected and
analyzed to complete the BLRA for human and ecological receptors. COCs were identified
and a determination was made as to which COCs would be retained for development of RAOs.
The COCs at the NECOU include VOCs (primarily solvents and solvent-related compounds
[TCE, toluene, PCE, and DCE], in surface and subsurface soil, VOCs and their degradation
products (TCE, PCE, DCE, and vinyl chloride) in ground water, and metals in surface soil.
2-6 September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Armv Ammunition Plant. Independence, Missouri
2.6.2 Human Health Risk
The human health risk assessment identified two exposure groups (both under future land-use
scenarios) that could potentially be exposed to contaminants at levels that result in unacceptable
risk. The first group is off-Post residents who could potentially be exposed to solvents (TCE and
its breakdown components) in the ground water by drinking the water, inhaling VOCs that
volatilize out of the ground water, or through skin contact (e.g., during showering). The second
group is onsite industrial workers who could potentially be exposed to solvents in the ground
water by drinking untreated ground water. Data available at the time of the BLRA did not
indicate off-post ground water contamination. Therefore, no unacceptable risk was identified in
the BLRA for current off-post residents.
TCE is the primary solvent detected in the Lake City Aquifer contributing to unacceptable risk.
TCE is a highly mobile contaminant that typically migrates through the soil into the ground
water. In the environment, TCE (and other solvents found in the NECOU) gradually breaks
down into various components, one of which is vinyl chloride. TCE and vinyl chloride are
known to cause cancer in laboratory animals and are considered carcinogens. The BLRA
conducted during the RI conservatively assumed that all TCE in ground water would break down
into vinyl chloride which is more toxic than TCE and the most toxic of the TCE breakdown
components. The risk calculations also conservatively assumed there would be no remediation
of any LCAAP areas.
Potential cancer risks are classified by the increased probability of a person getting cancer in his
or her lifetime (assuming a 70-year lifetime) from being exposed to known or suspected cancer-
causing chemicals at the site. According to the NCP and EPA's Risk Assessment Guidance for
Superfund (EPA/540/1-89/002), the acceptable carcinogenic risk range is between 1 x 10"4 and 1
x 10"6. This means there is a probability of one additional case in 10,000 to one case in
1,000,000 that an in'divfdual will develop cancer ab'ovfe thTexpected normal rate of 250,000 per
1,000,000 (or one in four). Generally, the IxlO"6 risk level is considered the level below which
the number of increased cancer occurrences from exposure to specific contaminants cannot be
differentiated from other causes. Depending upon site-specific information, remediation may or
may not be warranted if the total site risk lies within the acceptable risk range. The concentration
of TCE found in the ground water at NECOU is associated with an excess lifetime cancer risk of
4 x 10"3 for future industrial workers. This means that if no cleanup action is taken, 4 additional
persons per 1,000 have a probability of developing cancer as a result of exposure to TCE-
contaminated ground water. Similarly, the excess lifetime cancer risk to future off-Post residents
exposed to ground water from the NECOU is 7 x 10"*, meaning that if no cleanup action is taken,
7 additional persons per 10,000 have a probability of developing cancer as a result of exposure to
TCE-contaminated ground water. These estimates were developed by taking into account
various conservative assumptions about the likelihood of a person being exposed to the untreated
ground water and the toxicity of TCE. As discussed above, all TCE in ground water at the
NECOU was assumed to degrade to vinyl chloride. Expressing TCE as vinyl chloride provides a
more conservative risk assessment since vinyl chloride is more hazardous than TCE.
September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Anny Ammunition Plant. Independence, Missouri
The Environmental Protection Agency and the State of Missouri have established MCLs for
drinking water for many chemicals including the VOCs detected in the ground water at the
NECOU. Since MCLs have been established for these chemicals (in particular. TCE and
vinyl chloride), the cleanup goals for these chemicals are their respective MCLs (5 ug/L for
TCE and 2 ug/L for vinyl chloride).
2,6.3 Ecological Risk
As part of the overall BLRA, ecological risks were also evaluated. However, it is beyond the
scope of the alternatives evaluated for this IRA to address any unacceptable ecological risks
which may be present in the NECOU. Any such unacceptable ecological risks will be addressed
as part of the comprehensive final action for the NECOU.
2.6.4 Interim Action Risk Reduction
VOCs in ground water pose a potential risk to future commercial/industrial workers at the
NECOU. Breathing vapors from untreated ground water that contains the VOCs TCE and
vinyl chloride would result in unacceptable cancer risk. These same VOCs in ground water
also pose a potential unacceptable risk to nearby off-Post residents under future land-use
scenarios if the VOC contaminated ground water were to be used.
This Interim Action remedy will minimize the risk to future exposure groups discussed above
where the baseline risk assessment showed a potential for unacceptable risks. This action will
reduce overall site risk by treating the ground water in situ prior to entering the Lake City
Aquifer. A soil cover over the Area 17B Oil and Solvents pits will reduce exposure to soil
contaminated with VOCs and minimizes further migration of VOCs to the ground water by
controlling runon and runoff of precipitation.
Actual or threatened releases of hazardous substances from this site, if not addressed by the
preferred alternative or one of the other active measures considered, may present a current or
potential threat to public health, welfare, or the environment.
2.7 DESCRIPTION OF ALTERNATIVES
Superfund requires that each site remedy selected be protective of human health and the
environment, be cost-effective, and comply with Applicable or Relevant and Appropriate
Requirements (ARARs). The Superfund process also requires that permanent solutions to
contamination problems be developed whenever possible. These solutions should reduce the
volume, toxicity, or mobility of the contaminants. Emphasis is also placed on treating the wastes
at the site whenever possible, and on applying innovative technologies to clean up the
contaminants. Given the scope of this Interim Action, a small universe of alternatives
appropriate to achieve the RAOs of this ROD were selected from the Interim FS.
Development of the FS included the identification an.d evaluation of technologies to see if they
were applicable to the overall waste management strategy for the NECOU. The technologies
September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake dry Army Ammunition Plant. Independence, Missouri
were combined into alternatives for remedial action. The site is complex, and during the
development of the FS additional data collected and evaluated by the Army indicated that is \vas
appropriate to implement an interim remedial action at a portion of the NECOU. The decision to
pursue an interim remedial action allows the Army to respond more quickly to reducing site risk.
Some of the remedial technologies identified in the Draft FS are applicable to the Interim
Remedial Action. Therefore, the Draft FS has been entered into the Administrative Record to
support the interim action described in this ROD. A Final FS is being developed that will take
into account this Interim Action and any additional data collected at the NECOU subsequent to
the RJ. Final remedial action for all of the NECOU will be addressed by the Final FS, Proposed
Plan, and Record of Decision.
The Interim Action at the NECOU partially addresses the Area 17B Oil and Solvents Pits and a
known contaminated ground water plume moving from the NECOU toward the Lake City
Aquifer. It does not specifically address source areas or areas of contaminated ground water that
may be downgradient of the proposed location of the Interim Action ground water remedy, nor
does this ROD address other source areas within the NECOU. As discussed above, these other
areas will be addressed in the Final Remedial Action for the NECOU. The Interim Action
alternatives meet the RAOs for the Interim Action and are consistent with the overall NECOU
management strategy stated above.
Three alternatives were evaluated as part of the Interim Action for soil and ground water
contamination and are discussed below.
2.7.1 Alternative 1: No Action
The no action alternative represents the baseline condition at the NECOU to which other
alternatives are compared. Under this alternative, no action would be taken to reduce the
amount of contamination present in the ground"-wate~f~SnU"source area and no reduction of
risk would be realized. Because this alternative does not reduce the risks identified in the
BLRA, this alternative was not selected as the preferred Interim Remedial Action. Under
this alternative, no accelerated action would be taken at the NECOU, site risk would not be
reduced, and the formal process to address the entire OU would continue. The cost for No
action is $0.
2.7,2 Alternative 2: Source Area Cover/Permeable Reactive Wall (PRW)
Description
Alternative 2 is the selected alternative for Interim Action at the NECOU. Figure 4 shows the
approximate location of the soil cover and PRW, while Figure 5 is a schematic of the PRW.
The major components of this alternative include:
• Installation of a soil cover over the Area 17B Oil and Solvent Pits (source area) to
minimize the amount of infiltration into source area soils and subsequent movement of
contaminants into the underlying ground water. The cover would consist of 18 inches
23 September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake C//>' Army Ammunition Plant. Independence, Missouri
of compacted earth beneath a 6-ineh vegetated layer. The cover would be constructed
to promote drainage off the covered area, minimize erosion of the cover, and provide
long-term minimization of water infiltrating through the underlying contaminated soils.
This component is similar to the cover component described in the Alternative
SA/GW-2 in the Interim NECOU FS except for the composition of the cover.
• Installation of a PRW to contain and treat a defined contaminated .ground water plume
within the NECOU. The wall would be keyed to bedrock to intercept and treat
contaminated ground water that may migrate from upgradient sources of VOC
contamination before it enters the Lake City Aquifer. PRWs degrade contaminants
through chemical reactions. A design study would be required to determine the final
design parameters of the wall and to determine its exact location. Soil excavated
during construction of the PRW will be tested to determine whether potential
contaminants in the soil exceed remediation goals. Soil that has contaminants above
remediation goals will be addressed in accordance with the remedial action workplan.
All other soil will be managed on-Plant. It. is assumed that the reactive media, which
is typically iron, may have to be replaced periodically.
• A monitoring program will be used to evaluate the effectiveness of the PRW for
treating contaminated ground water. The actual time frame for replacement of iron in
the wall would also be determined from monitoring data. This component is similar
to the barrier wall described in the Alternative SA/GW-3 in the Interim NECOU FS.
Maior ARARs
The selected alternative will comply with ARARs with respect to its limited scope relative to
final remedy for the NECOU. The oil and solvents pits area ceased use (1979) prior to the
effective data of RCRA~(November 1980). Thereferc/whtte not applicable the standards are
relevant and appropriate. Action-specific ARARs for installation of the cover would include
RCRA requirements stated in CFR 264 for designing the cover to be less permeable than the
natural subsurface soils. The interim action waiver (40 CFR 300.400 (0(c)(l)) is being
invoked for the part 264 requirements for covers. The final action for the NECOU may
require intrusive activity within the oil and solvents pits, therefore a low permeability cover
may be inconsistent with the final remedy.
Due to the limited scope of this interim action, which does not address soil cleanup, potential
chemical-specific ARARs were not considered.
The PRW will treat contaminated ground water to meet the chemical-specific ARARs for
ground water, specifically the MCLs established under the Safe Drinking Water Act and State
of Missouri ground water quality standards. The wall will treat contaminated ground water to
meet MCLs immediately downgradient of the wall. Therefore ARARs will be attained within
the scope of this interim action.
September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake Citv Armv Ammunition Plant. Independence. Missouri
Implementation Time and Cost
The estimated lime to implement this remedy and begin meeting cleanup goals is 24 months.
Ground water will be treated within the wall as it passes through and will meet clean up goals
on the downgradient side of the wall. Time associated for the treatment process is
insignificant, although the continued need for the wall is anticipated to be in excess of 30
years. The estimated capital cost of this remedy $1,740,000. Annual Operation and
Maintenance (O&M) cost is estimated to be $88,000. An additional outlay of $832,000 for
replacement of the iron media is estimated for year 16 of the remedy. Total 30 year present
worth is $3,493,000.
2.7.3 Alternative 3:Source Area Cover/Ground Water Extraction Wells/Treatment at
the Area 18 Ground Water Treatment Plant
Description
Alternative 3 is the contingent Interim Action remedy and would be implemented if Alternative
2 cannot be readily installed. This alternative is similar to Alternative 2 except that extraction
wells or ground water recovery trenches would be used to intercept contaminated ground water
instead of a PRW. Intercepted ground water would be treated at the Area 18 air stripper.
Figure 4 shows the approximate location of the soil cover and extraction wells and Figure 6 is
a schematic of the air stripping process. The major components are:
• A reduced permeability cover as described under Alternative 2.
• Ground water extraction wells or trenches south of Buckner Road. This component is
similar to the ground water extraction component described in the Alternative SA/GW-
2 in the Interim "NECOU FS. Approximafely^Crwetts would be arrayed for extracting
contaminated ground water. Use of extraction wells or trenches would be determined
during the design phase.
• Treatment of contaminated ground water removed from the wells or trenches at the
Area 18 ground water treatment plant (air stripper with catalytic oxidation offgas
treatment). The Area 18 treatment plant was designed and built with excess capacity to
accept additional waste streams. Discharge from the Area 18 treatment plant will be
consistent with the requirements of LCAAP's Little Blue Valley Sewer District User
Discharge Permit. Pre-design data would be required to determine the need, if any, to
modify the treatment plant to effectively treat the additional waste stream from the
NECOU. Costs for any additional treatment components have not been included in this
ROD since the need is not known at this time.
Major ARARs
The contingent alternative will comply with ARARs with respect to its limited scope relative
to final remedy for the NECOU.
ZH! September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Arm\ Ammunition Plant, Independence, Missouri
The ground water extracted under this alternative would be treated at the Area 18 OU
treatment plant. The discharge would meet the criteria established by the Little B|ue Valley
Sewer District (Appendix C). The requirements under the Safe Drinking Water Act and State
of Missouri ground water quality standards would be met at the location of the wells/trenches.
since the ground water would be extracted prior to entering the Lake City Aquifer. While
MCLs would be attained at the location of the wells, this alternative does not address the
NECOU in its entirety and will not meet ARARs as applied to the entire NECOU.
Implementation Time and Cost
The estimated time to implement this remedy and begin meeting cleanup goals is 24 months.
The estimated capital cost of this remedy $2,417,000. Annual Operation and Maintenance
(O&M) cost is estimated to be $126,000. Total 30 year present worth is $4,354,000.
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The RAOs for this Interim Action at the NECOU are:
• Reduce further migration of ground water containing COCs at concentrations above
cleanup goals from the NECOU to the Lake City Aquifer.
• Minimize further migration of chemicals from the soil in the Area 17B Oil and Solvent
Pits to ground water.
These RAOs are consistent with the overall NECOU management strategy which is:
• The use of EW-2 (or other containment components) to remediate contaminants dissolved
in the ground water in'the Lake City AquifeV^nd"rninTrnize the potential for offsite
migration of contaminants in the ground water. Additional actions may be needed to
address potential off-Post contamination.
• Interim Action to minimize migration of contaminated ground water from the uplands to
the Lake City Aquifer. The selected alternative in this ROD includes installation of a soil
cover to minimize infiltration of precipitation through contaminated soil at the Area 17B
Oil and Solvent Pits and installation of a PRW to intercept contaminated ground water as
it moves from the NECOU toward the Lake City Aquifer.
• Additional studies to assess the extent of contamination at the NECOU and possible
action to mitigate source areas.
Pursuant to Section 300.430(e)(9)(iii) of the NCP, the remedial action to be implemented
should be selected based upon consideration of nine evaluation criteria. These criteria are as
follows:
Threshold Criteria
1. Overall protection of human health and environment.
£12 September 1998
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Final Record of Decision for Interim Remedial Action at the Nonheast Corner Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
2. Compliance with ARARs.
Primary Balancing Criteria
3. Long-term effectiveness and permanence.
4. Reduction of toxicity, mobility, or volume of contamination.
, 5. Short-term effectiveness.
6. Implementability.
7. Cost.
Modifying Criteria
8. State acceptance.
9. Community acceptance.
The following sections provide a brief review and comparison of the remedial alternatives
based on the limited scope of the Interim Action.
2.8.1 Overall Protection of Human Health and the Environment
This criterion considers whether a remedy provides adequate protection and describes how
risks are mitigated through treatment, engineering, or institutional controls.
Alternatives 2 and 3 would provide adequate protection of human health and the environment by
eliminating, reducing, or controlling risk through treatment and engineering controls. The
selected alternative would treat contaminated ground water from the NECOU, provide a reduced
permeability cover over the Oil and Solvents Pits to minimize the potential for further migration
"of contaminants from tfie soil'to the ground water vte'mfTItration of precipitation, and reduce the
migration of contaminated ground water from the NECOU.
Because the no action alternative is not protective of human health and the environment, it is not
considered further in this analysis as an option for this site.
2.8.2 Compliance with ARARs
Alternatives are evaluated under this criterion to assess compliance with ARARs. Applicable
requirements include cleanup standards, standards of control and other substantive
environmental protection requirements, and criteria or limitations promulgated under Federal
or State laws that specifically address a hazardous substance, pollutant, contaminant, remedial
action, location or other circumstances at a CERCLA site.
Relevant and appropriate requirements address problems or situations sufficiently similar to
those encountered at a CERCLA site that their use is well suited to the environmental and
technical factors at a particular site. The determination of "relevant and appropriate"
2-13 September 1998
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Final Record of Decision for Interim Remedial Action at the Nonheast Corner Operable Unit
Lake City Armv Ammunition Plant. Independence. Missouri
emphasizes the similarity and appropriateness of the requirement to a site. ARARs are
grouped into these three categories:
• Chemical-Specific ARARs are health or risk-based numerical values or methodologies
which, when applied to site-specific conditions, result in establishment of the amount
or concentration that may be found in, or safely discharged to, the environment.
• Location-Specific ARARs restrict the concentration of hazardous substances or the
conduct of activities solely because they are in specific locations such as flood plains,
wetlands, historic places, and sensitive ecosystems or habitats.
• Action-Specific ARARs are usually technology or activity-based requirements or
limitations on actions taken with respect to hazardous wastes.
Action and location-specific ARARs are similar for most of the alternatives. Major action-
specific ARARs would include storm water management and Clean Air Act Amendments.
Major location-specific ARARs would include consideration of wetlands and floodplain
management requirements.
Alternatives 2 and 3 would meet their respective ARARs of Federal and State environmental
laws. Under Alternative 2, ground water would be treated to meet MCLs. Under Alternative 3,
extracted ground water treated at the Area 18 treatment plant would meet discharge criteria
established by the Little Blue Valley Sewer District. Emissions from the catalytic oxidation
offgas treatment unit would meet air discharge criteria. The Interim FS discusses ARARs in
more detail.
2.8.3 Long-term Effectiveness and Permanence
This criterion considers the long-term effectiveness of alternatives in maintaining protection of
human health and the environment after response action objectives have been met.
The selected alternative would reduce the hazards posed by the contaminants by intercepting and
treating the contaminated ground water in situ as it migrates from the NECOU toward the Lake
City Aquifer. Installation of a compacted earth cover at the Oil and Solvents Pits would
minimize the migration of contaminants from the soil to the ground water by promoting drainage
of surface water away from the pit area.
Alternative 3 provides similar long-term effectiveness and permanence but uses ground water
extraction (ex situ) and treatment of ground water to achieve this. Alternative 3 also includes a
compacted earth cover at the Oil and Solvents Pits. The treatment for both Alternatives 2 and 3
would be permanent and irreversible.
2-14 September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake dry Army Ammunition Plant. Independence, Missouri
2.8.4 Reduction of Toxicity, Mobility, or Volume Through Treatment
This criterion considers the anticipated performance of specific treatment technologies an
alternative may employ.
Alternatives 2 and 3 treat and contain VOC-comaminated ground water but do not address
principal threat sources. Reduction of toxicity. mobility, and volume of principal threat sources
will be addressed in the final action for the NECOU. Alternative 2 uses in situ treatment that
destroys the contaminants using a PRW. Alternative 3 uses extraction and ex situ treatment
using air stripping. Catalytic oxidation will be used to destroy VOCs in the offgas.
2.8.5 Short-term Effectiveness
This criterion considers the effectiveness of alternatives in maintaining protection of human
health and the environment during the construction of a remedy until remedial response
objectives have been met.
The selected alternative uses in situ treatment to destroy VOCs in the ground water. Therefore,
there are no risks of exposure to contaminants during treatment. There are slight risks of
exposure to contaminated ground water under Alternative 3 since water would be extracted and
piped to the Area 18 treatment plant. There is a slight risk under both alternatives for potential
exposure to contaminated soil or ground water during construction, although this would be
mitigated using personal protective equipment as appropriate. This risk would be minimized
through the use of personal protective equipment. There may be some minor short-term risk of
exposure to waste (soil and ground water) generated during construction, prior to its ultimate
disposal. Water generated during construction activities would be treated to MCLs prior to
discharge or discharged to the Area 18 treatment plant. VOC-contaminated soil (>10 ppm, total
"chlorinated VOCs) would be containerized and disptssfed"oTafan appropriate repository.
2.8.6 Implementability
This criterion considers the administrative and technical feasibility of implementing the
alternatives and the availability of necessary goods and services for implementation of the
response action.
Neither of the alternatives have significant administrative difficulties that would delay
implementation. Both remedies are being used to successfully address similar contaminants at
other Superfund sites, and the skilled workers needed to construct the remedies are available.
However, the use of reactive walls (the selected alternative) does not have the history of use that
extraction wells do and installation of reactive walls is more of a specialty area. Alternative 2 is
an innovative technology and will require extensive monitoring to determine its effectiveness.
Since Alternative 2 is innovative it is preferred under Superfund. The need to conduct bench
studies to determine final design parameters of the reactive wall could result in a longer time to
implement than Alternative 3. Alternative 3 would make use of the existing treatment plant
located at Area 18. This plant is anticipated to be operational for a number of years.
£13 September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Comer Operable Unit
Lake City Army Ammunition Plant, Independence, Missouri
Alternative 3 will require an evaluation of potential plant modifications to address the additional
waste stream from the NECOU. While implementation concerns are not completely defined, the
Army has collected preliminary design information indicating favorable constructability of
Alternative 2.
2.8.7 Cost
This criterion considers the capital and O&M costs associated with each of the alternatives.
Costs were developed using Means Building Cost Index, vendor estimates, and contractor
experience. Alternatives are evaluated for cost in terms of both capital costs and long-term
O&M costs necessary to insure continued effectiveness of the alternatives. Capital costs
include the sum of the direct capital costs (materials and labor) and indirect capital costs
(engineering, licenses, permits). Long-term O&M costs include labor, materials, energy,
equipment replacement, disposal, and sampling necessary to ensure the future effectiveness of
the alternative.
The objective of the cost analysis is to evaluate each of the alternatives based on their ability to
protect human health and the environment for additional costs that may be incurred. Costs
vary between the alternatives as a result of differences in the amount of materials and the level
of effort required for each alternative.
The following cost tables provide a summary of probable costs for the Interim Action
alternatives. A detailed cost basis is provided in the Interim FS and Administrative Record.
Alternative 1: No Action
Total Capital Costs
30- Year Present Value for Annual Costs
Annual Cost = SO
Years = 30
Discount Rate = 5 %
TOTAL 30- Year Present Value
$0
$0
$0
Capital Cost Year 1
Capital Cost Year 16
30- Year Present Value for Annual Costs
Annual Cost = $88,000
Years = 30
Discount Rate = 5%
TOTAL 30-Year Present Value
$1,740,000
$832.000
$1,353,000
$3,493,000
2-16
September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake dry Army Ammunition Plant. Independence, Missouri
Alternative 3: Source Area Cover/Ground Water Extraction Wells/Treatment at Area 18 OU Treatment
Plant
Total Capital Costs
30- Year Present Value for Annual Costs
Annual Cost = S 105 .000
Years = 30
Discount Rate = 5%
TOTAL 30-Year Present Value
52,417,000
$1,937,000
$4,354,000
2.8.8 Regulatory Acceptance
This criterion considers the support agencies preferences or concerns about the alternatives.
EPA and the State of Missouri support the selected Interim Action remedy, Alternative 2.
2.8.9 Community Acceptance
Comments offered by the public were used to assess whether the proposed alternative was
acceptable to the community. The Army received no written comments during the public
comment period of April 13, 1998 through May 22, 1998. Questions were posed to the Army
regarding the selected remedy during the public meeting held on May 12, 1998. There were
no objections to the selected remedial alternative expressed at the meeting. Questions about
the remedy posed during the public meeting appeared to be satisfactorily addressed during the
meeting. The questions and concerns of the community are discussed in the Responsiveness
Summary, which is Appendix C of this ROD. Based on the nature of the public response, the
remedy described in" the Proposed Plan is acceptabteTo thlTcommunity.
2.9 SELECTED ALTERNATIVE
Based on the requirements of CERCLA, comparative analysis using the nine criteria, public
comments, and in consultation with EPA and the State, the Army has determined that the
selected Interim Action alternative for the NECOU is Alternative 2 (Source Area Cover and
Permeable Reactive Wall). Alternatives 2 and 3 (the selected remedy and the contingent
remedy, respectively) meet the RAOs for the Interim Action and the overall NECOU waste
management strategy. Alternative 3 would be implemented as a contingent remedy should
Alternative 2 not be readily implementable.
The selected remedy meets these objectives through a combination of containment of
contaminated ground water (PRW treating contaminated ground water) and partial containment
of a principal threat waste (cover over the Area 17B Oil and Solvents Pits). The final remedy
for the NECOU will address other source areas within the NECOU, long-term implementation
of institutional controls, monitoring, and CERCLA 121(b) preference for treatment of
principal threat waste.
Z-TJ September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Arrm Ammunition Plant, Independence, Missouri
Major components of Alternative 2 are:
• Installation of PRW to treat contaminated ground water to MCLs in place.
Construction methods will be determined during the remedial design.
• Installation of a 24-inch thick vegetated soil cover over the Area 17B Oil and Solvents
Pits to provide positive drainage and minimize infiltration of water through the
contaminated soil.
• Restore disturbed areas to promote positive drainage.
• Monitoring of the effectiveness of the PRW for treating ground water contaminated
with VOCs and for determining reactive media replacement time and operation &
maintenance considerations.
• Cost to implement Alternative 2: Capital Cost of $1,740,000 for year 1 and $832,000
in year 16 for the replacement of reactive media. Estimated O&M cost of $88,000 per
year for 30 years with a total 30-year present worth cost is $3,493,000.
Institutional Controls and Monitoring
Institutional controls will be implemented as specified in the Final ROD for the NECOU.
Institutional controls would include: (1) issuing a continuing order to restrict onsite worker
access to contaminated soil; (2) filing a notice to the deed detailing the restrictions of the
continuing order; and (3) a covenant to the deed in the event of property transfer.
Monitoring of the PRW will be conducted to ensure that treatment goals are being met and to
determine the replacement time for the reactive media in the PRW. A long-term monitoring
program will be developed as part of the remedial design for the final action at the NECOU.
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 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 NECOU IRA satisfies the above requirements is discussed in the
following sections. The discussion of section 121 CERCLA statutory determinations is
presented in accordance with the limited scope and purpose of the Interim Action.
The Interim Action has been designed to be part of the final remedy for the NECOU. The
selected remedy represents the best balance of tradeoffs among the alternatives considered with
2^5 . September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Army Ammunition Plant, Independence, Missouri
respect to pertinent criteria and the limited scope of the Interim Action. The selected remedy
will be reviewed prior to implementation of a Final ROD for the NECOU to ensure that it
meets the RAOs for the operable unit.
2.10.1 Protection of Human Health and the Environment
The selected remedy addresses health and environmental issues that were identified in the
NECOU RI and BLRA. Specifically, the PRW:
• Reduces potential exposures to off-Post receptors by treating contaminated ground
water at levels exceeding MCLs within LCAAP boundaries.
• Reduces risk by reducing the concentration of contaminants in the ground water to
levels below MCLs.
• Provides for long-term monitoring of ground water to identify potential future risks
associated with the NECOU and to monitor the effectiveness of the remedial action.
Specifically, the source area soil cover:
• Eliminates exposure to VOCs in the surface soil by constructing a cover over these
soils.
• Reduces migration of VOCs in the subsurface soil which may migrate to ground water.
2.10.2 Compliance with ARARs
There are no chemical-specific ARARs for soil. Alternative 2 will meet Safe Drinking Water
Act. MCLs and State Ground Water Quality Standards at the location of the PRW. Action and
location-specific ARARs will be met, including Clean Air Act and State air quality
requirements. " •.'-=•-••
2.10.3 Cost Effectiveness
The selected remedy has been determined to provide overall effectiveness in reducing human
health risks relative to their costs. The 30-year net present worth of Alternative 2 is
$3,493,000. The estimated cost of the selected remedy is similar to Alternative 3, but
achieves the best balance of risk reduction and contaminant mass removal.
2.10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Extent Possible
The selected remedy meets the statutory requirement to use permanent solutions and treatment
technologies to the maximum extent practical for the NECOU. EPA considers a PRW an
innovative technology for the in place treatment of contaminated ground water. The selected
remedy provides the best balance of tradeoffs among alternatives which are both protective and
ARAR-compliant relative to the five primary balancing criteria: long-term effectiveness and
permanence; reduction of toxicity, mobility, or volume of contamination; short-term
2^19September 1998
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Final Record of Decision for Interim Remedial Aaion at the Northeast Comer Operable Unit
Lake On- Army Ammunition Plant. Independence, Missouri
effectiveness: Implementability; and cost. Section 2.8 provides a comparative analysis of these
criteria relative to each alternative.
A review of the selected remedy will be performed since the selected remedy will need to be
incorporated into the Final ROD for the NECOU. The review will be conducted at a time
frame to insure that the remedy continues to provide adequate protection of human health and
the environment. During this review, RGs and the selected alternative will be reevaluated to
ensure that they remain protective, provide a significant reduction in contamination, are cost
effective, and are achievable in a reasonable time frame.
2.10.5 Preference for Treatment as a Principal Element
The selected remedy will contain ground water contaminated with VOCs and provides
treatment as its principal element and is an innovative technology. The scope of the interim
action remedy is limited, and does not address principal threat waste sources within the
NECOU, which will be addressed in the final remedy.
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES
The selected action is the same as the preferred alternative presented in the Early Remedial
Action Proposed Plan for the NECOU. The remedy is considered an interim action.
Therefore, "Interim" has replaced "Early" in the description of the action in this ROD.
2-20 September 1998
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Final Record of Decision for Interim Remedial Action at the Nonheast Corner Operable Unit
Lake City Army Ammunition Plan:, Independence. Missouri
3.0 LIST OF ACRONYMS AND ABBREVIATIONS
ARARs: Applicable or Relevant and Appropriate Requirements
BLRA: Baseline Risk Assessment
BNA: Base Nuetral/Acid Extractable compounds
CERCLA: Comprehensive Environmental Response, Compensation and Liability Act
COC: Chemical of Concern
CRP: Community Relations Plan
CSM: Conceptual Site Model
DCE: Dichloroethene
DNAPL: Dense Non-Aqueous Phase Liquid
EPA: Environmental Protection Agency
FFA: Federal Facility Agreement
IRA: Interim Remedial Action
IRP: Installation Restoration Program
LBVSD: Little Blue Valley Sewer District
LCAAP: Lake City Army Ammunition Plant
MCL: Maximum Contaminant Level
MDNR: Missouri Department of Natural Resources
^g/L: Micrograms per liter
mg/L: Milligrams per liter
NCP: National Oil and Hazardous Substances. Contingency Plan
NECOU: Northeast Corner Operable Unit "*"*"
NPL: National Priorities List
O&M: Operation and Maintenance
OU: Operable Unit
PCE: PerchJoroethylene; liquids used in degreasing or paint removal.
ppm: Parts per million by weight
PRW: Permeable Reactive Wall
RAB: Restoration Advisory Board
RAO: Remedial Action Objective
RCRA: Resource Conservation and Recovery Act
RfD: Reference Dose
RG: Remediation Goal
RI/FS: Remedial Investigation/Feasibility Study
ROD: Record of Decision
3-1
September 1998
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Final Record of Decision for Interim Remedial Action at the Nonheast Corner Operable Unit
Lake City Army Ammunition Plant. Independence. Missouri
SARA:
SWMU
Superfund Amendments and Reauthorization Act
Solid Waste Management Unit
1,1. l.-tetrachloroethane
TCE: Trichloroethylene
VOC: Volatile Organic Compound
September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Army Ammunition Plant, Independence. Missouri
APPENDIX A
FIGURES
September 1998
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9 o
d -o
a. S
loflD
1 1
°S
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IOWA
MISSOURI
NEBRASKA
KANSAS
KANSAS CITY, KS
TO DES MOINES, IA
197 Ml.
TO OMAHA, NE
198 Ml.
KANSAS CITY, MO
INDEPENDENCE
N
TO TOPEKA. KS
51 Ml.
TO ST. LOUIS. MO
257 Ml.
LAKE CITY
ARMY
AMMUNITION
PLANT
TO SPRINGFIELD, MO
170 Ml.
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CA CNCINEEMINC.
SCIENCE. AND
TECHNOLOGY. INC.
DEPARTMENT OF THE ARMY
LCAAP
LAKE CITY. MISSOURI
REGIONAL LOCATION MAP
LCAAP - NECOU
PROJECT MCR
GAT
DESIGNED BY
JDK
DRAWN BY
PMS
CHECKED BY
JOK
SCALE
NONE
DATE
DEC 97
PROJECT NO
60984.01
FIGURE NO.
1
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NORTHEAST CORNER OPERAAE UNII
LOCATION MAP
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APRIL 98
SOU
AS SHOWN
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AREA
WASTE. G
PAINT AN0 WASTE SOLVENT
<~-*~^ FACILITY
AREA ?16D
8URNIN
CERCLA/SARA
SITE
AREA
BOUNDARY
BUNK&
ZOMPLB.
PROJCCI NO.
60783.01
RTA ENGINEERING.
SCIENCE. AND
TECHNOLOGY
DEPARTMENT OF THE ARMY
LCAAP
art. MISSOURI
SOLID WASTE MANAGEMENT UNITS
LCAAP-NECOU
SCALE
AS SHOWN
-------
APPROXIMATE LOCA
REACTIVE WALL (ALT- *)
AND EXTRACTION WELLS (ALT
SOURCE: BURNS & McDONNELL. 1996
400'
400'
LEGEND:
O PRELIMINARY SCREENING IOCAHON
x CORPS OF ENGINEERS SCAPS LOCATION
O SHALLOW WELL
$ INTERMEDIATE WEIL
S DEEP WELL
&- BEDROCK WELL
4 EXTRACTION WELL
EA ENGINEERING.
SCIENCE:. AND
TECHNOLOGY
DEPARTMENT OF THE ARMY
LCAAP
LAKC CITY. MISSOURI
ALTERNATIVES 2 AND 3
OCSlCNtO BY
TER
BY
SMO
cutotco or
TER
PROJKI
TER
APRIL 98
SCAH
AS SHOWN
wo
12422.09
-------
VOC-BEARING
CROUNDWATER
TREATED
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or
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PERMEABLE TREATMENT SECTION
c O
O
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rA FT NGINEIERING.
SCIENCE. AND
TECHNOLOGY
DEPARTMENT OF THE ARMY
LCAAP
IAKE an. MISSOURI
PERMEABLE
REACTIVE WALL (PRW)
DESIGNED BY
RK
CHECKED BY
PK
DRAWN BY
SMD
PROJECT MGR.
WWW
DATE
APR 98
SCAIE
NONE
PROJECT NO
17422.09
FIGURE
-------
DemUter
Tow*r Pump
High Level
Sensor
Water InM Una
^
1
1
I
— 0
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X"
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Air
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Tower
T Sump
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Clean Out
1 Packing
Clean Out
Air Valve
Blower
4-44 94P-33I2 W13W4
SOURCE: RECOVERY EQUIPMENT SUPPLY. INC.
t"A
KCIf.VNGl". AND
TECMMOI.OGV
DEPARTMENT OF THE ARMY
LCAAP
UKC an. ussoun
AIR STRIPPER
SCHEMATIC
OtSICNCD ITT
RK
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RK
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APR 96
SCAU
NONE
fROJ(CI NO
12422.09
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Final Record of Decision for Interim Remedial Action at the Northeast Comer Operable Unit
Lake City Army Ammunition Plant, Independence. Missouri
APPENDIX B
ARAR TABLE
September 1998
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SUMMARY OF ACTION SPECIFIC ARARS FOR NECOU, LCAAP (CONTINUED)
SUMMARY OF ACTION SPECIFIC ARARS FOR NECOU, LCAAP
Statutory/Regulatory Citation
Safe Drinking Water Act, 42 USC
300(0
National Primary Drinking Water
Standards, 40 CFR Part 141
General Description
Specific Requirements
SUilus
,
Establishes health based standards for
public water systems (MCLs).
40 CFR 14 1.61 lists MCLs for
organic COCs, including those
detected at the NECOU. 40 CFR
141.62 lists MCLs for inorganic
COCs, including those detected at the
NECOU.
Relevant and appropriate. Ground
water in aquifer is used lor drinking
water supply for LCAAP.
Clean Air Act. 42 USC 7401-7642
National Primary and Secondary
Ambient Air Quality Standards, 40
CFR Part 50
National Emission Standards for
Hazardous Air Pollutants, 40 CFR
Part 61 (Missouri 10CSR 10-6.080)
Establishes standards for ambient air
quality to protect public health and
welfare.
Establishes emissions standards for
specific air pollutants.
National Ambient Air Quality
Standards (NAAQSs) have been
established for the following
chemicals: carbon monoxide (40
CFR 50.8), lead (40 CFR 50. 12),
nitrogen dioxide (40 CFR 50. 1 1 ),
paniculate matter (40 CFR 50.6),
ozone (40 CFR 50.9), and sulfur
dioxide (40 CFR 50.4 and 40 CFR
50.5).
Sets emission standards for benzene
(40 CFR 6 1 .342), beryllium (40 CFR
61.32, mercury (40 CFR 61.52), and
vinyl chloride (40 CFR 6 1.63). 10
CSR 10-6.080 adopts the
requirements of 40 CFR 61 for these
constituents.
Applicable to contingency remedy.
Applies to air emissions from the .
Area 18 treatment plant.
Relevant and appropriate to
contingency remedy. Relevant and
appropriate to air emissions from (he
Area 18 treatment plant.
Resource Conservation and Recovery Act
Identification and Listing of
Hazardous Waste, 40 CFR Part 261,
Subpart C
Lists contaminants and establishes
concentrations that are considered
characteristic hazardous waste based
on the toxicity characteristic.
40 CFR 26 1.24 lists maximum
concentrations for the toxicity
characteristic for the COCs detected
at the NECOU.
Applicable. Determines if excavated
soil generated during remedial action
is hazardous (toxic) based on its
characteristics.
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SUMMARY OF ACTION SPECIFIC ARARS FOR NECOU, LCAAP (CONTINUED)
Land Disposal Restrictions, 40 CFR
Part 268.38 and 40 CFR Part 268
Subpart D
Standards Applicable to RCRA-
permitted Air Strippers, 40 CFR Part
264. 1032 (Subpart A A)
Missouri Air Pollution Control
Regulations
Fugitive Dust, IOCSR 10-6.170
Ambient Air Quality Standards, 10
CSR 10-6.010
IOCSR 10-6.060
Identifies hazardous wastes that are
restricted from land disposal and
defines limited circumstances when a
prohibited waste may continue to be
land disposed.
Limits total organic emissions from
process vents.
40 CFR 268.38 lists specific organic
toxicity characteristic wastes that are
prohibited from land disposal
including wastes listed as DO 18,
D022, D029, D030, D036, D039,
D040, and D043. Subpart D lists
treatment standards for specific
wastes that if met, allow these wastes
to be land disposed.
Requires that the total organic
emissions from all process vents be
reduced to below 3. 1 tons per year or
be reduced by 95 percent by weight.
Applicable. If excavated soil
generated during implementation of
the remedial action is determined be
hazardous based on its characteristics
and will be disposed of onsite, l.DRs
will be applicable. Also applicable to
the contingency remedy for treatment
residuals (sediment/sludge from the
air stripper unit and spent catalyst
from the catalytic oxidation unit)
from the Area 18 treatment plant if
the residuals arc determined to be
hazardous and will be disposed of
onsite.
Applicable to contingency remedy.
Applicable to emissions from the
Area 18 air stripper if used to treat
extracted ground water.
Restricts persons fibm causing or
allowing fugitive oust to go beyond
the premises where.such dust
originates. \
Establishes standards for ambient air
quality to protect public health and
welfare.
Requires that emission limits be
established for sources emitting
specific pollutants above dc minimus
levels specified.
Requires dust suppression measures
(e.g., applying water) be
implemented to control dust at the
point of origin.
10 CSR 10-6.010 has the same
requirements as 40 CFR 'JO and also
adds emission standards for hydrogen
sulfide and sulfuric acid.
Under the NECOU remedy, air
emissions will be below de minimus
levels for ozone emissions (measured
as VOC) - 40 tons per year, and vinyl
chloride emissions - 1 top per year.
Applicable. Dust may be generated
during construction of the remedy.
Applicable to contingency remedy.
Applies to air emissions from the
Area 18 treatment plant.
Applicable to contingency remedy.
Applicable to emissions from the
Area 18 air stripper if used to treat
extracted ground water.
Missouri Storm Water Regulations
10 CSR 20-6.200
Regulates storm water discharges
during construction activities.
Requires the use of best management
practices (BMPs) for controlling
storm water runoff, erosion, and
sediment transport.
Applicable for regulation of storm
water discharge during construction
activities.
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SUIflTflARY OF ACTION SPECIFIC ARARS FOR NECOI i. LCAAP (CONTINUED)
Missouri Ground Water Well
Installation Regulations
Specifies material requirements,
borehole preparation, well
completion, decontamination
requirements, general installation
requirements, and other requirements
that must be followed when
constructing monitoring wells.
IOCSR 23-4.060
Establishes minimum construction
standards for monitoring wells and
extraction wells. Although
requirements for extraction wells are
not specifically listed, requirements
for monitoring wells listed in 10 CSR
23-4 are considered applicable to
extraction wells.
Applicable for the installation of
monitoring wells as part of the
remedy.
10 CSR 23-4.030
Establishes criteria for monitoring
well be placed.
Specific requirements include
locating so that surrounding area can
be kept sanitary and provide ready
access for maintenance and repairs, to
provide proper drainage, in areas that
do riot flood, and farther than 15'
from cavities used for underground
utilities.
Applicable for the installation of
monitoring wells as part of the
remedy.
Applicable for the installation of
monitoring wells as part of the
remedy.
I OCSR 23-4.070
Establishes criteria that must be met
in developing a monitoring well.
Specifies methods of developing
wells to prevent contamination and
properly develop a well.
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Final Record of Decision for Interim Remedial Action at the Northeast Comer Operable Unit
Lake dry Army Ammunition Plant, Independence. Missouri
APPENDIX C
GROUND WATER TREATMENT DISCHARGE CRITERIA
September 1998
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Permit No. LB-0200-LC504
PART 1 - Effluent Limitations Continued:
J. During the period of February 21, 1997 to February 20, 2000 wastes containing
any of the following substances in solution or in suspension in concentrations
exceeding the maximum permissible concentration shall not be discharged through
Outfall 003 to the District's system. Repeated or willful violation of these maximum
limits shall be deemed sufficient to warrant enforcement action.
Parameter
.PH
1.1-Dichlcroethane
1.1-Dichloroethene
1,2-Dichlorcethene
1.1,1-Trichlcroethane
Benzene
Carbon Tetrachloride
Chloroform
Ethyl Benzene
Methylene Chloride
Methylisobutyl Ketone
Toluene
Trichloroethene
Vinyl Chloride
Bis(2-Ethylhexyl)Phthalate
Chrysene
Di-N-Octyl Phthalate
2,4-Dinitrotoluene
HMX
Nitrobenzene
RDX
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Nickel
Selenium
Silver
Zinc
Daily
Maximum
mg/l
5 to 10.5 SI
0.026
0.035
0.400
0.900 '
0.043
0.044
0.009
0.007
0.030
0.002
0.110
0.680-
0.250
0.360
0.066
0.013
O.CC6
0.002
0.013
0.005
0.078
0.030
0.856
0.010
0.200
1.000
3.000
1.500
1.000
0.034
0.100
5.000
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Final Record of Decision for Interim Remedial Action at the Northeast Comer Operable Unit
Lake dry Army Ammunition Plant. Independence. Missouri
APPENDIX D
RESPONSIVENESS SUMMARY
September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Army Ammunition Plant, Independence, Missouri
Responsiveness Summary
Interim Remedial Action at the Northeast Corner Operable Unit
Lake City Army Ammunition Plant, Independence, Missouri
1. Overview
The United States Army established a public comment period from April 13 to May 22, 1998
for interested panics to review and comment on remedial alternatives considered and described
in the Interim Action Proposed Plan for the Northeast Corner Operable Unit (NECOU). The
Proposed Plan was prepared by the Army in cooperation with the U. S. Environmental
Protection Agency (EPA) and the Missouri Department of Natural Resources (MDNR).
The Army also held a public meeting at 7:00 p.m. on May 12, 1998 at the Building 6
Conference Room at the Lake City Army Ammunition Plant (LCAAP) to outline the proposed
remedy to reduce risk and control potential hazards at the NECOU.
The Responsiveness Summary provides a summary of comments and questions received from
the community at the public meeting and during the public comment period as well as the
Army's responses to public comments.
The Responsiveness Summary is organized into the following sections:
• Background on Community Involvement
• Summary of Comments and Questions Received During the Public Comment Period
and Army Responses
• Remaining Concerns .
The major components of the selected Interim Remedial Action for the NECOU include the
following:
• Installation of a subsurface permeable reactive wall (PRW) to treat contaminated ground
water in place (in-situ).
• Monitoring to evaluate the effectiveness of the PRW in treating the contaminated ground
water and to determine the replacement period of the reactive media.
• Installation of a soil cover over the Area 17 Oil and Solvent Pits located adjacent to the
current sanitary landfill in the NECOU.
Together, these actions would reduce the potential for further migration of contaminated ground
water from the NECOU to the Lake City Aquifer.
D-l September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Corner Operable Unit
Lake dry Army Ammunition Plant, Independence. Missouri
2. Background on Community Involvement
In August 1987, LCAAP was listed on the EPA's National Priorities List (NPL). A Federal
Facilities Agreement (FFA) was signed by the Army, EPA, and the State and went into effect
on November 28, 1989. The FFA establishes a procedural framework and schedule for
developing, implementing, and monitoring appropriate response actions for LCAAP.
Community relations activities that have taken place at LCAAP to date include:
• FFA process - After preparation of the FFA by the U. S. Army, EPA, and MDNR, the
document was published for comment. The FFA became effective November 1989.
• Administrative Record - An Administrative Record for information was established in
Building 3 at LCAAP. The Administrative Record contains information used to
support Army decision-making. All the documents in the Administrative Record are
available to the public.
• Information repositories - An Administrative Record outline is located at the Mid-
Continent Public Library, Blue Springs South Branch (public repository) and at the
west entrance to the Plant (Building 6).
• Community Relations Plan (CRP) - The CRP was prepared and has been accepted by
EPA and the State of Missouri and is being implemented. This plan was updated in
1996.
• Restoration Advisory Board (RAB) - The RAB has been formed to facilitate public
input in the cleanup and meets on alternating months. In addition to Army, EPA, and
Missouri oversight personnel, the RAB includes -community leaders and local
representatives from the surrounding area!
• Mailing list - A mailing list of all interested parties hi the community is maintained by
LCAAP and updated regularly.
• Fact sheet - A fact sheet describing the status of the IRP at LCAAP was last distributed
to the mailing list addressees in November 1996.
• Proposed Plan - The Proposed Plan on this Interim Action was made available to the
public for their comments.
The Proposed Plan for this remedial action was made available for public review and copies of
the Proposed Plan were available at the May 12, 1998 public meeting. A transcript of
comments, questions and responses provided during the public meeting was prepared.
D-2 September 1998
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Final Record of Decision for Interim Remedial Action at the Northeast Comer Operable Unit
Lake City Army Ammunition Plant, Independence, Missouri
3. Summary of Comments and Questions Received During the Public Comment Period
and Army Responses
Part I - Summary and Response to Local Community Concerns
In review of the written transcript of the public meeting, there were no community objections
to the proposed remedial action indicated. No written comments were received during the
public comment period.
The majority of the comments received during the public meeting were in the form of
questions about the remedial investigation findings and the remedial action (i.e., what would be
done, how it would be done, and what effects the action might have). Representatives of the
Army were available to provide answers to the questions and also provided an overview
presentation during the meeting to describe the proposed actions.
Part II - Comprehensive Response to Specific Technical, Legal and
Miscellaneous Questions
There were no community objections to the proposed remedial action and there were no
comments or questions from the public as a result of the May 12, 1998 public meeting.
4. Remaining Concerns
Based on review of the transcript of the oral comments received during the public meeting,
there are no outstanding issues or remaining concerns associated with implementation of the
proposed remedial action.
D-3 September 1998
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