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SUMMARY.   OF    SITE    HISTORY,
CONTAMINATION,   AND   SELECTED
REMEDY

Comhusker  Aimy .Ammunition  Plant  is
located near Grand-Island, Nebraska (Figure
1) on a 11,936  acre tract   The plant was
constructed in 1942 by  the Army for  the
production  of  artillery  rounds,  bombs,
booster  and supplementary charges.   The
plant was operated  intermittently for 30
years, with operations ending in 1973.

As a result of disposal practices, common at
threat~time  in  both  military  and civilian
sectors,  the groundwater at CHAAP was
found   to  contain  explosive   residue.
Subsequently, the CHAAP was listed on the
National Priorities  List (NPL)  on July 22,
1987.    At this  time  it  was   apparent
groundwater  containing explosive residue
had migrated beyond the CHAAP boundary,
about 2 miles into the Grand Island Gty
limits.

Investigations to date identified the explosive
residue  in groundwater migrated  from  the
cesspools and leach pits located in the center
of the  plant   The  affected  groundwater
encompasses a disjointed area 6 miles long
and one-half mile wide. While the explosive
residue  in the groundwater originated from
the CHAAP, the detected nitrates could have
come from several other sources, including
agricultural activities in the area.

As   an   interim  action  the  Army  has
constructed  a  permanent  water supply
system  to  the  affected  households  by
extending   the   city   water    system.
Approximately 800 residences were  provided
the opportunity to hook up to the Northwest
Grand Island Water Supply Extension.

During 1987 and 1988, the Army excavated
and incinerated explosive contaminated soils
from the cesspools and leachpits.  A second
removal action was conducted in the summer
of 1994 and focused on additional  source
areas.

On November 18, 1994, an Interim Record of
Decision was signed for remediation of  the
groundwater  plume  containing  explosive
residues, primarily  RDX.   This Record of
Decision requires the  Army  to  build a
groundwater  extraction,   treatment  and
discharge system that  will  capture   the
contaminated  groundwater  and  treat  the
groundwater to remove explosive residues to
levels  that   are  safe for  surface  water
discharge.   The   treated groundwater  will
then be pumped via underground pipeline to
a surface water discharge.

Compliance  monitoring will  be performed
with a groundwater monitoring system of the
plume  to verify protection of human health
and the environment   This  system  will
prevent   further   migration    of    the
contaminants   and    will   reduce    the
concentrations of explosive residues  in  the
'groundwater over time.

DESCRIPTION OF SIGNIFICANT
DIFFERENCES  AND THE  BASIS  FOR
THOSE DIFFERENCES

In June 1996, the VS. Army presented a plan
to discharge treated water from the proposed
groundwater treatment facility at CHAAP to
Silver Creek at a location near the northwest
comer of CHAAP. Previously, the discharge
point was to be the Platte River at a location
approximately 14 pipeline  miles  from  the""*
groundwater treatment  plant on CHAAP.
The proposed   discharge  location  was
changed because the design flow rate for  the"
discharge  was   reduced  during  design
evaluations from approximately 11 cubic feet
per second (5000 gallons per minute (gpm)) to
approximately  5  cfs  (2150  gallons  per
minute). An evaluation of the.potential  for
increased flooding problems associated with
the discharge to Silver Creek  was prepared.
The analysis determined if the discharge from
the treatment plant stopped during periods of

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high flow in Silver Creek,  there would be
insignificant increases to flooding problems
(RUST, 1996). Rust also estimated the impact
on groundwater elevation near the Creek and
found that during periods of the year.  The
discharge  to Silver Creek  could  result in
increased  pumping of sumps in basements
located directly adjacent to the creek.  The
analysis  was  presented  along with the
proposed  change at a June 5, 1996,  public
meeting.   Public concerns were raised over
discharging water to Silver Creek during the
meeting and during the 45 day comment
period.  There was a concern the discharge
would-be burdensome to some residents and
perhaps affect cropland.

The Army, EPA, and the NDEQ identified the
need to eliminate  the further  migration of
contaminants in the groundwater off-site. In
order to accomplish this the Agencies want to
proceed with a phased approach.
The  Army therefore proposes installing the
treatment facility and  the  extraction  wells
planned   for   the  areas   of  remaining
groundwater  contamination  on  CHAAP.
This  action  would  provide  important
environmental improvement and could be
completed at the same time that, an interlocal
agreement   which  would  formalize   the
evaluation   process  of the  discharge as
identified in the  phased approach.   The
agreement will include representatives from
local governments, the EPA, the NDEQ and
the Army.    Along  with this  agreement,
discussions  will  continue for off-site piping
and  further  evaluation   of  contingency
alternatives  (for example, the  Prairie Bend
Project).   The  phased approach will  also
provide  an avenue to evaluate the most
recent off-site data (Dec. 1996 and Feb. 1997)
and the effect  of natural  attenuation on
improving groundwater quality.

Under  the  p*hased  approach,  the Army
proposes  to begin on-site  extraction  and
treatment as soon as  possible.  The treated
water would be discharged to an  existing
drainage canal  located on CHAAP.   The
water in the canal would discharge to Silver
Creek  after traveling  through CHAAP for
about  two  miles.   This  proposal differs
significantly from the earlier Silver Creek
discharge proposal in two ways:
1.  The discharge flow is lower-only 1.7 cfs/|
     allons per minute ^The initial period of
lower flow  would allow an opportunity to
evaluated the modeled versus actual impacts
from the discharge.  This information would
be  used  to  evaluate  the  need  to change
discharge locations in the future. It will allow
real time data to determine the capabilities of
the Creek for any future off-post actions.

2.   The  revised  model  demonstrates the
effects of 1.7 cfs discharge into  the Eastern
Drainage  Canal   Under  the most likely
conditions, the model anticipates much of the
water would infiltrate through the on-post
canal  bottom  during  transport  to  Silver
Creek.    Therefore  the  amount  of  water
•reaching Silver Creek would be even less than
the amount of treated water discharged to the
canal.

The design capacity  of the system will allow
for  capture and  treatment of  the  entire
plume, as identified in the Cornhusker AAP
OU1 Interim Record of Decision, Nov  1994.
The treatment system will be constructed to
treat up to 2150 gpm or 4.8 cu. ft/s.

Under  the   OU1  Record  of Decision  the
discharge location is the Platte River.  This
would  require  the effluent to be  piped
thirteen   and  a  half  mile  underground.
Changing the  discharge  location  to the
Drainage Canal would require a maximum of
a quarter mile  of effluent pipeline.  This
change  would  save  over  13   miles  of
underground pipeline, approximately four
months of construction time and five to six
million dollars.  This figure does not include
reduction    in   real   estate    acquisition
procedures or maintenance costs, which will

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 be realized through the change in discharge
 location.

 Several different scenarios were modeled to
 evaluate the potential impact to surrounding
 areas under  a variety of conditions.  The
 model  estimated  during periods  of  high
 groundwater (e.g., groundwater less  than'5
 feet below the ground surface and a flowing
 stream)   the   discharge   would    take
 approximately  8  to 10  miles to infiltrate.
 Model  predictions  were also  made  under
 drier conditions or when irrigation wells are
 pumping.    Under   these  conditions  the
 groundwater will  be 5-  10  feet below the
 surface.  In this case,  the model simulations
 show  the effluent  infiltrating mostly on
 Comhusker property (traveling al distance of
 2 miles). This scenario assumes the Drainage
 Canal will be cleaned and maintained.  The
 results from the modeling show the effect to
 Creek   and  surrounding   area  is   very
 dependent on;  1)   the water  levels  in the
 Creek, 2)  the groundwater level, 3)   the
 infiltration rate of the Creek/Canal bed and
 4) the area of the Creek/Canal bed.

 Studies have been conducted using the flood
 insurance modeling, 10,50 and 100 year flood
 flows and information from past  flooding
 occurrences. These reports demonstrate there
 will be no additional risk of flooding of Silver
 Creek  by discharging 1.7 cfs or 4.8  cfs  of
 treated  water.  To virtually eliminate  the
 possibility the discharge from CHAAP could
 increase  flooding  problems along  .Silver
 Creek, the Army will stop discharging the
 treated water during times when the flow in
Silver Creek  is more than  250 cfs.    This
limitation  has  been  included in   other
 discharge permits for Silver Creek.

 In  addition   to  the  modeling  effort  a
 monitoring program has been proposed  to
monitor the ^urface water flow in the creek,
 take   visual   observations  and   monitor
groundwater   levels  along  Silver   Creek.
Surface  water flow measurements will be
made twice per month for two years.  Visual
observations  will  be  recorded  to include
documenting distance of observable flow in
the canal and Creek.  These observations will
be  made during  periods of little  or  no
precipitation (when there is no flow upstream
at the point where the Canal discharges into
the  Creek).   This  will  provide  data  on
infiltration rates through the drainage canal
and Creek bed that can be used to refine the -
model  predictions.    •' Any  ice buildup
conditions in  the  winter will  also  be
documented.   If ice buildup is excessive the
system will be temporarily shut-down.

According to CERCLA Section 121(e)(l) the
discharge will  occur on-site and  will not
require   a National  Pollutant  Discharge
Elimination System  (NPDES) permit.   The
Army will submit a letter request to allow
discharge to Silver Creek. This letter will set
effluent standards equivalent to those set in
the   NPDES   permit,   NE0131725   for
Comhusker   Army    Ammunition   Plant
Groundwater  Remediation  Project,   dated
October 18,1995 (Table 1).
Effluent Parameters
PH
MtretB as Mtrogen
Total Sulfate
Total HMX(1A5>7>
TetraDBodne
Total RDX
2,4,6-Trirftrotoluene
Combined Explosive
Trlcrdoraettylene

incitiorouinuoroetnane
UMts
S.U.
mg/l
mo/I
mo/1
mo/I
mo/1
mo/1
mo/I
mo/I
Doily
Mrirrun
as
Report
Report
02
0.05
0.01
0.1
0.005
as
   Table 1 Effluent Concentration Limits as
        Proposed in NPDES NE0131725

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The  extraction  treatment  systems  will  be
constructed  and  operated  as  originally
designed.    Therefore,  the  entire   phased
remedy will offer the same level of protection
to human health and the environment as was
originally envisioned in the OU1 Record of
Decision. An amendment to the final design,
incorporating the changes to the effluent line
location will be issued for review  by the
regulatory agencies.

REGULATORY AGENCY SUPPORT
COMMENTS

EPA and NDEQ support the changes to the
Record-of Decision described in this ESD.

AFFIRMATION OF THE STATUTORY
DETERMINATIONS

Considering the changes that have been made
to the selected remedy' the Army, EPA and
NDEQ believe that  the  remedy  remains
protective  of  human health  and   the
environment   The  selected  remedy  also
complies with Federal and State requirements
that   are  applicable   or  relevant  and
appropriate to  this remedial action, and is a
cost-effective application of public funds.  In
addition,  the  remedy  utilizes permanent
solutions    and    alternative   treatment
technologies to the maximum extent possible
for this site.

Public Participation Activities

A public comment period will be held  from
Feb.7,1997 to March 9, T997.  The comment
period  includes  a   public   availability/
information session during which the Army,
EPA and NDEQ will be available to discuss
new information that supports the change in
discharge  locations.   This meeting will  be
held on Feb. 19,1997 from 10 a.m.-2 p.m. and
5-8 p.m.  at the Grand Island City Hall.  A
copy of the Response to Comments from the
45 day public comment period and public
meeting  discussing  the initial  ESD  that
proposed to discharge 4.8 cfs of treated water
directly into Silver Creek.  The responses to
these  comments  will be  available  at the
information session and will be placed in the
information repository.

The Army will accept both oral and  written
additional comments during the availability
session and through the  public  comment
period. These comments will be summarized
and responses will be provided.  A copy of
these  responses  will  be  kept  with  the
Administrative  Record  for  OU1,   which
includes this ESD.  It is available for review
and comment at the locations  and times
provided on Page 1  of this  ESD.  To send
written  comments   or  to   obtain  further
information, please contact:

     Tom Jamieson
     Comhusker Army Ammunition Plant
     102 North 60th Road
     Grand Island, NE 68803
     (308) 381-0313

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                       CORNHUSKER 'ARMY AMMUNITION PLANT
                            GRAND ISLAND, NEBRASKA
                                PUBLIC MEETING
                            GRAND ISLAND CITY HALL
                               19 February 1997

                 EXPLANATION OF SIGNIFICANT DIFFERENCES  (ESD)
                       OU #1 Groundwater Treatment Plant
                         Change of Discharge Location
                                      of
                            Treated Effluent Water
NAME:

ADDRESS:
TELEPHONE:
QUESTION/COMMENTS:
Please turn-in your question/comment or mail to the following:
       Cornhusker Army Ammunition Plant
       ATTN:  Mr. Tom Jamieson
       102 North 60th Road
       Grand Island, NE  68803
       (3
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