Superfund Record of Decision Alabama Army Ammunition Plant Operable Unit 6 (Area B) Study Areas 2 10 16 17 and 22 Childersburg AL


                                    EPA/ROD/R04-97/020
                                    1997
EPA Superfund
     Record of Decision:
     ALABAMA ARMY AMMUNITION PLANT
     EPA ID: AL6210020008
     OU06
     CHILDERSBURG, AL
     03/27/1997

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
100 ALABAMA STREET, S.W.
ATLANTA, GEORGIA 30303-3104

MAR 27 1997

4WD-FFB

Certified Mail
Return Receipt Requested

Mr. Randy Nida
U.S. Army Industrial Operations Command
Building 390, 4th Floor, NW Wing
AMSID-EQE
Rock Island, Illinois 61299-6000

SUBJ: Concurrence with Interim Record of Decision for Operable Unit 6 (Area B),
Study Areas 2, 10, 16, 17 and 22
Alabama Army Ammunition Plant, Childersburg, Alabama

Dear Mr. Nida:

The U.S. Environmental Protection Agency (EPA) Region IV has reviewed the above referenced
decision document and concurs with the Interim Record of Decision (IROD) for Operable Unit 6,
Study Areas 2, 10, 16, 17, and 22 of Area B, as supported by the Remedial Investigation and
Baseline Risk Assessment Reports.

The selected remedy is Alternative 1G in the IROD. EPA concurs with the selected remedy as
detailed in the IROD with the following stipulation:

It is understood that the selected remedy for Area A, Operable Unit 2 may not be the
final remedial action to address all media potentially affected by past disposal
practices at this unit.

This action is protective of human health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action
and is cost effective.

cc: Richard Isaac, U.S. Army Environmental Center
Kenneth Gray, U.S. Army Corps of Engineers
C.H. Cox, Alabama Department of Environmental Management

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INTERIM RECORD OF DECISION BRIEFING
OPERABLE UNIT 6: STUDY AREAS 2, 10, 16, 17, 19, and 22 SOILS, AREA B
ALABAMA ARMY AMMUNITION PLANT

Background

Alabama Army Ammunition Plant (AAAP) is located near Childersburg in Talladega County,
Alabama. The main installation was established on 13,233 acres in the Coosa Valley district of
the Valley and Ridge physiographic province of central Alabama. Area B comprises 2,700 acres
in the western portion of the original property.

AAAP was established in 1941 as a facility producing nitrocellulose, smokeless powder, and
nitroaromatic explosives [ie., trinitrotoluene (TNT), dinitrotoluene (DNT), and tetryl].
Operations were terminated and the base placed on standby status in August 1945. Beginning in
1973 several parcels of AAAP have been sold or returned to their original owners, including Area
A. Future land use for Area A is expected to be wildlife habitat, hunting grounds, and logging.
Area B was retained by the Army pending environmental restoration.

During the 1970s and 80s, the Army's Installation Restoration Program (IRP) conducted
studies revealing lead and explosives contamination of AAAP soils. In 1987, AAAP was placed
on the NPL. Area B includes the former explosives manufacturing areas. AAAP is presently on
the Base Realignment and Closure (BRAG) list slated for sale or lease for economic reuse.

Remedial Investigation and Operable Unit Description

The original Remedial Investigation (RI), completed in 1986 under the IRP, established
twenty-one study areas within Area B. As a result of these findings, cleanup activities,
consisting of building decontamination and demolition were conducted in 1986-87. 36,400 yd 3 of
explosive, asbestos, and lead contaminated soil was excavated and stockpiled for later
treatment. An IROD was signed in December, 1991, presenting the selected remedy for the
stockpiled soils (OU-1). This remedy consisted of thermal treatment and on-site disposal of
explosive contaminated soil, solidification/on-site disposal of lead contaminated soil, and
off-site disposal of asbestos-containing media.

The soils of Operable Unit 2, within Area B, were found to contain explosives and metals
lead, chromium, and nickel) compounds at levels of concern. Excavation and thermal treatment
of these soils were conducted in 1995-96 under an Interim ROD while investigation of the
explosives contaminated groundwater continued.

The continuing Remedial Investigation found evidence of explosives and metals contamination
in Study Areas 2 (Smokeless Powder Facility), 10 (Tetryl Manufacturing Area), 16 (Flashing
Ground), 17 (Propellant Shipping Area), 19 (Lead Remelt Facility), and 22 (Demolition Landfill).
These study areas were broken out as a separate Operable Unit (OU-6) for the purpose of
remediating the soils while the incinerator is still onsite and while the groundwater
investigation continues.

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INTERIM RECORD OF DECISION BRIEFING
OPERABLE UNIT 6: STUDY AREAS 2, 10, 16, 17, 19, and 22 SOILS, AREA B
ALABAMA ARMY AMMUNITION PLANT

Background

During the 1970s and 80s, the Army's Installation Restoration Program (IRP) conducted
studies revealing lead and explosives contamination of AAAP soils. In 1987, AAAP was placed
on the NPL. Area B includes the former explosives manufacturing areas. AAAP is presently on
the Base Realignment and Closure (BRAQ fist slated for sale or lease for economic reuse.

Remedial Investigation and Operable Unit Description

The soils of Operable Unit 2, within Area B, were found to contain explosives and metals
(lead, chromium, and nickel) compounds at levels of concern. Excavation and thermal treatment
of these soils were conducted in 1995-96 under an Interim ROD while investigation of the
explosives contaminated groundwater continued.

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                           U.S. ARMY INSTALLATION
                             RESTORATION PROGRAM

                          INTERIM RECORD OF DECISION

                                October 1996

                         ALABAMA ARMY AMMUNITION PLANT
                            CHILDERSBURG, ALABAMA
                       AREA B SOILS, OPERABLE UNIT IV
                     (STUDY AREAS 2, 10, 16, 17, 19 AND 22)
In accordance with Army Regulation 200-2, this document is intended by the Army to comply
with the National Environmental Policy Act  (NEPA) of 1969.

                            TABLE OF CONTENTS
DECLARATION OF THE INTERIM RECORD OF DECISION  	1

DECISION SUMMARY 	7

1.0   SITE NAME, LOCATION, AND DESCRIPTION  	8

      1.1     Physiography 	8
      1. 2     Climate 	8
      1.3     Surface Hydrology 	8
      1.4     Geologic Setting 	13
      1. 5     Land Use 	13
      1.6     Soils 	13
      1.7     Groundwater 	14
      1.8     Ecological System 	14

2.0   SITE HISTORY AND ENFORCENEENT ACTIVITIES  	14

3.0   HIGHLIGHTS OF COMMUNITY PARTICIPATION  	16

4 . 0   SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY  	17

5 . 0   NATURE AND EXTENT OF CONTAMINATION  	17

      5 .1   Description and Past Activities  	18
            5.1.1  Study Area 2 - Smokeless Powder Facility  	18
            5.1.2  Study Area 10 - Tetryl Manufacturing Area  	18
            5.1.3  Study Area 16 - Flashing Ground 	18
            5.1.4  Study Area 17 - Propellant  Shipping Area  	19
            5.1.5  Study Area 19 - Lead Remelt  Facility 	19
            5.1.6  Study Area 22 - Demolition  Landfill 	19

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      5 . 2   Analytical Data To Date 	20
            5.2.1  Study Area 2 - Smokeless Powder Facility 	20
            5.2.2  Study Area 10 - Tetryl Manufacturing Area 	20
            5.2.3  Study Area 16 - Flashing Ground 	23
            5.2.4  Study Area 17 - Propellant Shipping Area 	23
            5.2.5  Study Area 19 - Lead Remelt Facility 	25
            5.2.6  Study Area 22 - Demolition Landfill 	25

6. 0     SUMMARY OF SITE RISKS  	27

        6.1  Exposure Assessment 	27
        6.2  Intermediate Cleanup Levels (ICLs)  	28

7.0     DESCRIPTION OF ALTERNATIVES 	28

        7.1  Alternative 1A:  Stabilization of Metals- and PAH-Contaminated Soils ....  30
        7.2  Alternative 1C:  Off-Site Disposal of Metals- and PAH-Contaminated Soils  30
        7.3  Alternative ID:  Incineration of Explosives-Contaminated Soils 	30
        7.4  Alternative 1G:  Incineration/Stabilization of Metals-and
             Explosives-Contaminated Soils 	31
        7 . 5  Alternative II:  No Action 	31

8 . 0     SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 	31

        8.1  Threshold Criteria 	31
        8.2  Primary Balancing Criteria 	34
        8.3  Modifying Criteria 	35

9.0     SELECTED REMEDY AND REMEDIATION GOALS 	35

        9.1  Basis for Selection 	36
        9.2  Remediation Goals 	37

10.0    STATUTORY DETERMINATIONS 	40

        10.1 Protection of Human Health and the Environment 	40
        10.2 Compliance with Applicable or Relevant and Appropriate
             Reguirements 	41
        10.3 Cost-Effectiveness 	42
        10.4 Utilization of Permanent Solutions and Alternative Treatment
             Technologies or Resource Recovery Technologies to the
             Maximum Extent Practicable 	42
        10.5 Preference for Treatment as a Principal Element 	43

RESPONSIVENESS SUMMARY 	44

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                                LIST OF TABLES

1A  Concentrations of Contaminants of Potential Concern  (COPCs)
    in Shallow Soil and Sediment in Study Areas 10, 16,  17, 19
    and 22 at ALAA.P Area B  (ESE Sampling Programs, 1986  &  1990)  	  21

IB  Concentrations of Contaminants of Concern  (COCs) in  Soils and
    Sediments in Study Areas 2, 10, 17, 19 and 22 at
    ALAA.P Area B (SAIC, Draft Supplemental RI, February  1996)  	  22

2   Analytical Results of Ingots in Study Area 19 	  26

3   Intermediate Cleanup Levels (ICLs) for Area B Soils  Operable Unit  IV  ..  29

                                 LIST OF FIGURES

1   Location Map of ALAA.P 	  9

2   Study Areas at ALAA.P 	  10

3   Study Area 10 	  11

4   Study Areas 16 and 19 	  12

5   Suspected Contamination in Study Areas 16 and 19 	  24

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                   LIST OF ACRONYMS AND ABBREVIATIONS
Ig/g        micrograms per gram
1,3-DNB     1,3-dinitrobenzene
1,3,5-TNB   1,3,5-trinitrobenzene
2,4-DNT     2,4-dinitrotoluene
2,4,6-TNT   2,4,6-trinitrotoluene
2,6-DNT     2,6-dinitrotoluene
AAC         Alabama Administrative Code
ADEM        Alabama Department of Environmental Management
ALAAP       Alabama Army Ammunition Plant
ARAR        Applicable or Relevant and Appropriate Reguirement
CAA         Clean Air Act
CERCLA      Comprehensive Environmental Response, Compensation, and Liability Act
CFR         Code of Federal Regulations
COG         contaminant of concern
COPC        contaminant of potential concern
DOD         Department of Defense
DOT         Department of Transportation
EPA         U.S. Environmental Protection Agency
ESA         Endangered Species Act
ESE         Environmental Science & Engineering, Inc.
5F          degrees Fahrenheit
FS          Feasibility Study
gal         gallon
GOCO        government-owned/contractor-operated
HI          Hazard Index
ICL         Intermediate Cleanup Level
IRP         Installation Restoration Program
mg/kg       milligrams per kilogram
mg/L        milligrams per liter
NC          nitrocellulose
NCP         National Oil and Hazardous Substances Pollution Contingency Plan
NEPA        National Environmental Policy Act
NPL         National Priorities List
O&M         Operation and Maintenance
OSHA        Occupational Safety and Health Act
OU          Operable Unit
PAH         Polyaromatic hydrocarbon
ppm         parts per million
RA          Risk Assessment
RCRA        Resource Conservation and Recovery Act
RfD         reference dose values
RI          Remedial Investigation
RI/FS       Remedial Investigation/Feasibility Study
ROD         Record of Decision
SAIC        Science Applications International Corporation
SARA        Superfund Amendments and Reauthorization Act of 1986
TCLP        toxicity characteristic leaching procedures
Tetryl      2,4,6-trinitrophenylmethylnitramine
TMV         toxicity, mobility or volume
TNT         2,4,6-trinitrotoluene
USAGE       U.S. Army Corps of Engineers
USAEC       U.S. Army Environmental Center  (formerly USATHAMA)

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USATHAMA    U.S. Army Toxic and Hazardous Materials Agency
USC         United States Code
VCP         Vitreous Clay Pipe
WESTON      Roy F. Weston, Inc.
yd 3        cubic yard

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DECLARATION OF THE INTERIM RECORD OF DECISION

SITE NAME AND LOCATION

Alabama Army Ammunition Plant
Area B Soils Operable Unit IV - (Study Areas 2, 10, 16, 17, 19 and 22)
P.O. Box 368
Childersburg, AL 35044-0368

STATEMENT OF PURPOSE

This decision document presents the selected remedial action for the explosives- and metals-
contaminated soils and sediments in Study Areas 2, 10, 16, 17, 19 and 22 within Area B at the
Alabama Army Ammunition Plant (ALAAP), Childersburg, Alabama. This selected remedial action was
chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA) , and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP).

This interim remedial action is taken to protect human health and the environment from
unacceptable risks. This interim remedial action is limited to explosives- and metals-
contaminated soils and sediments in Study Areas 2, 10, 16, 17, 19 and 22, herein referred to
as the Area B Soils Operable Unit IV. This Interim Record of Decision (ROD) is based on the
Administrative Record for this site.

The U.S. Environmental Protection Agency (EPA) and the State of Alabama concur with the
selected remedy.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Interim Record of Decision (ROD), may present
an imminent and substantial endangerment to public health, welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

The Area B Soils Operable Unit IV addresses the principal threats from soils and sediments in
Study Areas 2, 10, 16, 17, 19, and 22. Each of the study areas is identified as follows:

• Study Area 2: Smokeless Powder Facility

• Study Area 10: Tetryl Manufacturing Area

• Study Area 16: Flashing Ground

• Study Area 17: Propellant Shipping Area

Study Area 19: Lead Remelt Facility

Study Area 22: Demolition Landfill

The scope of this Interim ROD is limited to these study areas. Based on the current property
use surrounding Area B (hunting, logging and industrial activities) and future potential land
use for Area B, the U.S. Army has selected an Industrial Scenario for remediation of Area B.

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Remedial investigations and remedial action efforts,  property transfers,  sales or leases will be
restricted to this Industrial Scenario.

The selected remedy for the Area B Soils Operable Unit IV consists of the following:

       •      Clear,  survey,  and grid areas;  perform  soil and sediment  sampling and chemical
              analysis  to delineate explosives  and metals contamination.

       •      Use Ground Penetrating Radar (GPR)  or test  pits to locate suspected burning trenches
              in Study  Areas  16 and 19.

       •      For contaminated areas (except  Study Area 22):   excavate  soils  until excavation
              criteria  are satisfied;  transport materials to  the TIS-20 site  in Area B;  treat
              materials by incineration and/or  stabilization  until treatment  and disposal criteria
              are satisfied;  dispose treated  material in  the  on-site  backfill area.   Study Area 22
              will be addressed using an engineered landfill  in accordance  with the remedial
              option  identified in the Draft  Final Feasibility Study  Report dated March  1996,
              prepared  by Science Applications  International  Corporation.

       •      If necessary,  expand the existing on-site disposal area for final placement of
              treated materials.

       •      Decontaminate oversize materials  by crushing or shredding and treatment in the
              TIS-20  or by high-pressure water  washing; dispose in the  backfill area.

       •      Treat contaminated process,  sampling, and decontamination wastewaters in the TIS-20
              agueous waste treatment system; reuse water for site dust control and process
              makeup.

       •      Conduct confirmatory soil and sediment  sampling and chemical  analysis to ensure
              that excavation criteria have been satisfied.

       •      Backfill  excavated areas in with  uncontaminated borrow  soils  and rough grade to
              pre-excavated contours.

       •      Close the on-site disposal area in accordance with the  existing approved permit
              applications for treated soils  ("Treated Soils  - Backfill Area  Permit Application
              for the Alabama Army Ammunition Plant",  March 1994 and  November 1994).

       •      Test portions of decontaminated concrete slabs  or structures  to ensure adeguate
              decontamination.   If Webster's  Reagent  is used,  there is  no numerical guantifiable
              decontamination criterion.  A change of color will indicate that TNT is present
              at concentrations above 15 Ig/cm  2.

Excavation criteria for contaminated soils and  sediments  are:
                                                 Excavation Criteria
  Explosives
    1,3-Dinitrobenzene (1,3-DNB)
    2,4-Dinitrotoluene (2,4-DNT)
    2,6-Dinitrotoluene (2,6-DNT)
    Tetryl
    1,3,5-Trinitrobenzene (1,3,5-TNB)
        1     ppm
      356     ppm
      356     ppm
>   5,000     ppm
>    36.7     ppm

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    2,4,6-Trinitrotoluene  (TNT)

  Metals  (total)

     Lead
      348
                                                          400
              ppm
                                                                  ppm
Excavation will proceed until excavation criteria are achieved or one of the following is
encountered:  groundwater, bedrock, foundations or other major subsurface obstructions.

For soils treated in the TIS-20, disposal criteria are as follows:

                                                 Disposal Criteria

  Explosives
    TNT
Metals -Toxicity Characteristic Leaching Procedure  (TCLP)

    Arsenic                                         <       5
    Barium                                          <     100
    Cadmium                                         <       1
    Chromium                                        <       5
    Lead                                            <       5
    Mercury                                         <     0.2
    Silver                                          <       5
    Selenium                                        <       1
                                                                  ppm
              mg/L
              mg/L
              mg/L
              mg/L
              mg/L
              mg/L (4 Ig/g using total
                    metals analytical
                    method)
              mg/L
              mg/L
For soils not treated in the TIS but stabilized, disposal criteria are as follows:
                                             Disposal Criteria for
                                             Stabilized Only Soils
  Explosives

    1,3-Dinitrobenzene  (1,3-DNB)
    2,4-Dinitrotoluene  (2,4-DNT)
    2,6-Dinitrotoluene  (2,6-DNT)
    Tetryl
    1,3,5-Trinitrobenzene  (1,3,5-TNB)
    2,4,6-Trinitrotoluene  (TNT)

  Metals  (TCLP)

    Arsenic
    Barium
    Cadmium
    Chromium
    Lead
    Mercury
    Silver
    1
  356
  356
5,000
 36.7
  348
              ppm
              ppm
              ppm
              ppm
              ppm
              ppm
<       5     mg/L
<     100     mg/L
<       1     mg/L
<       5     mg/L
<       5     mg/L
<     0.2     mg/L (4 Ig/g using total
                               metals analytical
                     method)
<       5     mg/L

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Selenium < 1 mg/L

Due to the nature of explosives contamination, sampling, excavation, and handling procedures
in the field will be dictated by safety considerations as determined by the U.S. Army or its
designated explosives expert(s). As such, general remedial actions will be performed in
accordance with plans developed by the explosives experts.

STATUTORY DETERMINATIONS

This interim action is protective of human health and the environment, complies with Federal
and State requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This interim action is intended to fully address the statutory
mandate for permanence and treatment to the maximum extent practicable. This action is interim
and may not be a permanent solution for contaminated soils in Study Areas 2, 10, 16, 17, 19 and
22 within Area B, and addresses the statutory preference for remedies that employ treatments
that reduce toxicity, mobility, or volume as a principal element. Subsequent actions are
planned to fully address the threats posed by the conditions in other areas within this operable
unit. Because this remedy will result in hazardous substances remaining on-site above
residential health-based levels, a review will be conducted by EPA within five years after
completion of the remedial action to ensure that the remedy continues to provide adequate
protection of human health and the environment.

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DECISION SUMMARY

1.0 SITE NAME, LOCATION, AND DESCRIPTION

Alabama Army Ammunition Plant (ALAAP) is located in Talladega County in east-central Alabama, 40
miles southeast of Birmingham and 70 miles north of Montgomery (Figure 1). The nearest town is
Childersburg, which is four miles south of ALAAP. This interim remedial action is limited to
explosives- and metals-contaminated soils and sediments in Study Areas 2, 10, 16, 17, 19 and 22,
herein referred to as the Area B Soils Operable Unit IV. The Area B boundary and individual
Study Areas within Area B are shown in Figure 2. Enlarged portions of Area B showing areas that
possess special surface features are provided in Figure 3 (Study Area 10) and Figure 4 (Study
Areas 16 and 19). Separate figures for Study Areas 2, 17 and 22 are not included since these
areas do not currently possess any special surface features.

1.1 Physiography

ALAAP is located in the Coosa Valley district of the Valley and Ridge physiographic province.
The border between the Valley and Ridge province and the Piedmont province is south of ALAAP
between Talladega and Tallaseehatchee Creeks.

1.2 Climate

Talladega County's climate is temperate. The weather during fall, winter, and spring is
controlled by frontal systems and contrasting air masses. Summer weather, which lasts from
May or June until September or October, is almost subtropical because maritime tropical air
prevails along the Bermuda high-pressure system.

Average daily temperatures in Talladega County are 75 degrees Fahrenheit (5F) for the high and
505F for the low. Summer high temperatures are commonly 905F or above; occasionally, maximum
temperatures exceed 1005F. Temperatures below 325F occur approximately 60 days per year,
primarily in December and January.

Mean annual rainfall is 52 inches. The lowest average monthly rainfall (2.2 inches) occurs in
October, and the highest average monthly rainfall (6.4 inches) occurs in March. Talladega
County has two rainy seasons per year. The winter rainy season is December to April, with the
majority of the rain associated with the passage of frontal systems. The summer rainy season
is May through September, with the highest rainfall occurring in June and July. Summer rains
are normally convective thunderstorms.

1.3 Surface Hydrology

The majority of the surface runoff from ALAAP drains either west or southwest into the Coosa
River. A small portion of the southern and eastern side of ALAAP drains toward Talladega
Creek, a tributary of the Coosa River. Prior to the construction of ALAAP, the area consisted
of farms, woodlands, and wetlands. Much of the eastern half of ALAAP was poorly drained.
Small natural drainways were enlarged and rerouted to provide drainage from the various
manufacturing operations.

As shown in Figure 2, two natural drainage systems conveyed surface runoff from ALAAP, west to

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the Coosa River. Liquid industrial wastes from the explosives manufacturing operations were
conveyed west to the Coosa River by a man-made channel (Red Water Ditch). No natural ponds
existed on ALAAP during its operation; however, two large storage lagoons were constructed to
retain industrial wastes. Extensive wooded swamp and pond areas have developed in the drainage
systems at ALAAP since the beginning of demolition activities in 1973, primarily as a result of
damming of drainways by beavers.

The properly is a nonwetland upland area based upon the 1987 Wetlands Delineation Manual.

1.4 Geologic Setting

The bedrock underlying ALAAP has been mapped on a regional scale and has been identified as the
undifferentiated Knox group of Upper Cambrian to Lower Ordovician age dolomite. The dolomite
underlying ALAAP is thick- to medium-bedded; cherty; and penetrated by numerous cavities,
joints, and fractures. The dolomite is overlain by residual soil derived from the weathering
process. This soil matrix consists primarily of clay, with some silt, sand, and occasional
chert boulders, and varies in thickness from less than 3 feet to more than 80 feet.

1.5 Land Use

ALAAP is currently in an inactive caretaker status with controlled access. The only activity
occurring on ALAAP is occasional Army-supervised logging. The land surrounding ALAAP is a
mixture of recreational and industrial. ALAAP is bordered on the west side by a country club;
on the south by a paper products company; on the east by wooded, private property; and on the
north by a water treatment plant. The current and future land use of the ALAAP property in Area
A is expected to consist of hunting grounds and occasional logging of wooded areas. Area A was
auctioned and conveyed to private buyers in 1990 and is currently used for hunting grounds and
occasional logging.

Based on the current property use surrounding Area B (hunting, logging and industrial
activities) and future potential land use for Area B, the U.S. Army has selected an Industrial
Scenario for remediation of Area B. All remedial investigations and remedial action efforts,
property transfers, sales or leases will be restricted to this Industrial Scenario.

1.6 Soils

The soils at ALAAP (Areas A and B) are generally divided into three associations. Soils of the
Bodine-Minvale Association are found on the high ground of the eastern portion of ALAAP. This
association is composed of deep, well-drained, steep, cherty, medium-textured soils derived from
limestone and dolomite. Most of ALAAP is covered by soils of the Decatur-Dewey-Fullerton
Association, which are also deep, well-drained, loam soils derived from limestone and dolomite.
The soils of the floodplains of Talladega Creek and the Coosa River have been classified as the
Chewacla-Chenneby-McQueen Association. These are deep, nearly level, alluvial loam soils that
grade from somewhat poorly drained to well drained and are subject to flooding.

These broad-based associations represent agricultural classifications rather than engineering
descriptions. Soil constitution at ALAAP may include three associations ranging from soils
consisting primarily of sand and silt (with little clay) to soils comprised almost entirely of
clay.

1.7 Groundwater

Potable groundwater from the dolomite aguifer of the Coosa Valley supplies the needs of the
communities, homes, farms, and industries around ALAAP. The majority of the successful wells

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draw water from the solution cracks and cavities in the dolomite. A few wells are completed in
the residual soil; however, these wells are less productive than those drilled into the
dolomite.

1.8 Ecological System

The environment at ALAAP has been disturbed three times in the past 50 years. Prior to the
construction of the facility, the area consisted primarily of cropland and woodland. The first
major change occurred during the operational years, when much of ALAAP consisted of maintained
industrial areas. In the second major change, the Army instituted a woodland management plan,
following closure of manufacturing operations, that extensively modified ALAAP by allowing 3,411
acres of controlled pine forest to be planted. More recently, the third major change occurred
as a result of selected remediation of soils on the site and demolition of various areas.

Currently, many of the formerly-maintained drainages, pine plantations, and cleared areas have
undergone considerable vegetative overgrowth. Much of the planted pine has been harvested,
and reforestation has occurred through natural revegetation. Damming of surface drainages by
beavers has modified the systems; drainage has become much slower, and extensive wooded swamp
and shallow pond areas have developed. As a result of these changes, the major ecological
systems currently consist of the following types: grassland/old field associations, upland pine
forests/pine plantations, oak forests, low moist pine woods, hardwood swamps, intermittent
streams, shallow ponds, and drainage ditches.

These systems support abundant populations of aguatic and terrestrial organisms. White-tailed
deer, introduced in the 1960s, have become particularly abundant, as have certain predators (the
red-tailed hawk, the marsh hawk, and the bobcat).

The extensive development of shallow beaver ponds has resulted in large populations of
amphibians and aguatic reptiles. The East Beaver Pond provides roosting for waterfowl.

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES

ALAAP was established on 13,233 acres of land near the junction of Talladega Creek and the Coosa
River. The plant was built in 1941 and operated during World War II (WWII) as a
government-owned/contractor-operated (GOCO) facility. ALAAP produced nitrocellulose (NC),
single-based smokeless powder, and nitroaromatic explosives (i.e., trinitrotoluene (TNT);
dinitrotoluene (DNT); and 2,4,6-trinitrophenylmethylnitramine (tetryl)). Activities at ALAAP
included the manufacture of explosives; DNT; and chemicals including sulfuric acid, aniline,
N,N-dimethylaniline, and diphenylamine. Spent acids were recycled and wastes resulting from
these operations were disposed. In August 1945, operations were terminated at ALAAP, and
the plant was converted to standby status.

The plant was maintained in various stages of standby status until the early 1970s. In 1973,
the Army declared ALAAP excess to its needs. Since that time, several parcels of the original
property were sold or returned to their previous owners. In 1977, a 1,354-acre parcel was sold
to Kimberly-Clark, Inc. for construction of a paper products plant. Area A, encompassing 2,714
acres, was auctioned in May 1990. Future land uses for these properties are expected to consist
of hunting grounds and wooded areas for occasional logging.

In 1978, the U.S. Army Environmental Center (USAEC) (formerly U.S. Army Toxic and Hazardous
Materials Agency (USATHAMA)), managing the Army's Installation Restoration Program (IRP),
conducted a records search which concluded that specific areas of the facility were potentially
contaminated by explosives and lead compounds. Additional studies at ALAAP confirmed that soils
were contaminated with explosives compounds, asbestos, and lead. Several investigations were

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conducted between 1981 and 1983 to further defirte contamination. In 1984, ALAAP was proposed
for inclusion on the CERCLA (Superfund) National Priorities List (NPL).

A Remedial Investigation/Feasibility Study (RI/FS) under the Department of Defense (DOD) IRP was
initiated in 1985 to determine the nature and extent of contamination at ALAAP and the
alternatives available to remediate the site. For the purposes of the RI/FS, the facility was
divided into two general areas. Area A consisted of the eastern portion of the facility and
Area B consisted of the western portion (Figure 2). The initial RI under the IRP confirmed the
existence of explosives, asbestos, and lead contamination in the soil in Area A and in the soil,
sediment and groundwater in Area B. The RI for Areas A and B was completed in 1986. As a
result of the findings of the RI, cleanup activities at Area A were conducted in 1986 and 1987,
and included building decontamination and demolition, soil excavation, and stockpiling.
Initially, 21,400 yd 3 of contaminated soils were excavated from Area A and stockpiled in Area
B in two covered buildings and on a concrete slab that was subseguently covered with a membrane
liner. In July 1987, ALAAP was placed on the NPL. The subseguent events related to Areas A and
B are presented separately in the following paragraphs.

Area A

In 1990, EPA indicated that additional investigations needed to be conducted at Area A to ensure
that no residual contamination remained. Area A was conveyed to private buyers in August 1990,
with the provision that additional investigations would be performed.

In 1991, a supplemental RI was conducted to verify the effectiveness of the completed remedial
actions in Area A. The supplemental RI determined that soils in Study Areas 12 and D contained
lead and explosives at unacceptable concentrations. The supplemental RI/FS, completed in
January 1993, concluded that approximately 3,800 yd 3 of lead-contaminated soil in Study Area 12
and approximately 5 yd 3 of explosives-contaminated soil in Study Area D reguired further
remediation. An Interim Record of Decision for the Area A Soil Operable Unit (Study Areas 12
and D) was submitted in April 1994, and was subseguently approved. During the latter half of
1994, Study Area 12 soils (2,179 yd 3) were excavated, stabilized and placed in the on-site
backfill area in Area B. TNT-contaminated soils from Study Area D (5 yd 3) were excavated,
incinerated in the TIS-20 and placed in the on-site backfill area in Area B.

Area B

In February 1991, a Characterization Study was conducted for the Stockpile Soils excavated from
Area A and stored in Area B. The study confirmed that explosives, lead, and asbestos
contamination was present above acceptable limits. In March 1991, a tornado demolished one of
the two buildings that contained Stockpile Soils. Soils and debris from the demolished building
were relocated on the concrete slab and covered with a membrane liner. A Feasibility Study was
completed for the Stockpile Soils in October 1991. A Record of Decision for the Stockpile Soils
Area Operable Unit was issued in December 1991 and recommended incineration as the preferred
alternative. The incineration of Stockpile Soils commenced in May 1994 and ended in August
1994.

Numerous studies have been conducted for study areas within Area B which include: the portion
of the Smokeless Powder Facility (Study Area 2) located within Area B; Sanitary Landfill and
Lead Facility (Study Area 3); Manhattan Project Area (Study Area 4); Red Water Storage Basin
(Study Area 5); Combined TNT Manufacturing Areas (Study Areas 6 and 7); Acid/Organic
Manufacturing Area (Study Area 8); Aniline Sludge Basin (Study Area 9); Tetryl Manufacturing
Area (Study Area 10); Flashing Ground (Study Area 16); the majority of the Propellant Shipping
Facility (Study Area 17); Blending Tower Area (Study Area 18); Lead Remelt Facility (Study Area
19); Rifle Powder Finishing Area (Study Area 20); Red Water Ditch (Study Area 21); Demolition

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Landfill  (Study Area 22); Storage Battery/Demolition Debris Area (Study Area 25); Crossover
Ditch  (Study Area 26); and the Beaver Pond Drainage System  (Study Area 27).

A supplemental RI/FS for Area B was submitted in March 1992.  Based on the FS and other
available documents and information, an Interim Record of Decision for the Area B Soils Operable
Unit was submitted and approved in November 1994.  This Interim ROD addressed contaminated soils
in Study Areas 6, 7, and 21, and the Industrial Sewer System (ISS)  in Study Areas 6, 7, and 10.
Remediation activities for the Area B Soils Operable Unit commenced in late 1994 and continue
today.

In 1995, the final Remedial Investigation and Feasibility Study was conducted by Science
Applications International Corporation (SAIC).   The findings were presented in draft reports in
February and March 1996, respectively.

Reports describing studies conducted at ALAAP are contained in the Administrative Record at the
Holston Army Ammunition Plant (Kingsport, TN)  and the Earle A.  Rainwater Memorial Library
(Childersburg, AL).

3.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION

A public meeting was held in December 1991 to discuss the issues related to the preferred
remedial alternative selected for the Stockpile Soils Area Operable Unit.  These soils were
subseguently remediated in 1994 using the selected method of on-site rotary kiln incineration.

A separate public comment period (19 September to 19 October 1994)  and public meeting  (28
September 1994) were held to discuss issues regarding remediation of the Area B Soils Operable
Unit  (soils in Study Areas 6, 7 and 21, and the Industrial Sewer System in Study Areas 6, 7 and
10).   The Interim ROD, including the responsiveness summary, was approved by the U.S. Army and
the regulatory agencies in November 1994.  The selected remediation method was on-site rotary
kiln incineration.  Remedial activities for the Area B Soils Operable Unit began in November
1994 and are projected to be completed before the end of 1996.

A public notification for the Area B Soils Operable Unit IV public meeting and public comment
period was advertised in four local newspapers, one of which was a major newspaper.  The public
comment period began on 15 September 1996 and ended on 15 October 1996.  Two people attended the
public meeting which was held on 8 October 1996 at the Central Alabama Community College.  The
public appears to have no concerns regarding implementation of Area B Soils Operable Unit IV.

4.0  SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY

The Area B Soils Operable Unit IV remediation strategy is an interim remedial action for
contaminated materials in Study Areas 2,  10, 16, 17, 19 and 22.  This interim remedial action
will protect human health and the environment from unacceptable risks caused by contaminated
soils in Study Areas 2, 10, 16,  17, 19 and 22.   To the extent practical, actions associated with
this Interim ROD are consistent with the Army's future planned activities at ALAAP.

Remedial investigations, historical records, and recent sampling activities conducted at the
site indicate that significant contamination is present in varying degrees in Study Areas 2, 10,
16,  17, 19 and 22.  (For example, Study Area 10 is primarily contaminated with tetryl and lead.
Study Area 16 is primarily contaminated with explosives.  Study Area 19 is contaminated with
high concentrations of lead, among other metals, and explosives).   Actual or threatened release
of hazardous substances from contaminated soils in Study Areas 2,  10, 16, 17, 19 and 22, if not
addressed by implementation of the selected remedy, may present a current or potential threat
to public health and the environment.

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A final Remedial Investigation/Feasibility Study (RI/FS), Risk Assessment (RA) , and Record of
Decision will be conducted for all of Area B, including soils, sediments, groundwater, and other
contaminated media. Ongoing and future investigations by the U.S. Army, as outlined in its Site
Management Plan for ALAAP, will determine a final course of action for the Alabama Army
Ammunition Plant.

5.0 NATURE AND EXTENT OF CONTAMINATION

The nature and extent of contamination can be better understood by reviewing the history of the
activities previously conducted in Study Areas 2, 10, 16, 17, 19 and 22. The results of
groundwater and surface water studies are not presented herein, as they are beyond the scope
of this Interim ROD. Groundwater at ALAAP will be addressed by the Army as a separate operable
unit.

5.1 Description and Past Activities

5.1.1 Study Area 2 - Smokeless Powder Facility

Most of the Smokeless Powder Facility, which covers approximately 3,230,000 sg. ft. (74.2 acres)
is located in the GSA Leaseback Area. The Installation Assessment reported that packages of
smokeless powder pellets were loaded into fiber boxes for transport and that pellets often were
spilled during these operations. The buildings were decontaminated and burned, the eguipment
was decontaminated and salvaged, and the area has been transferred to Kimberly Clark
(Supplemental RI, Environmental Science & Engineering, Inc. (ESE), 1986). Portions of Study
Area 2, located within Area B, have not been remediated. During the environmental survey
conducted by ESE, zinc and mercury were detected above background levels in groundwater, and
2,4-DNT was detected in sediment and soil samples.

Results of sampling program conducted by SAIC in 1995, indicated high concentrations of 2,4
DNT were present in soil in Study Area 2 located within Area B.

5.1.2 Study Area 10 - Tetryl Manufacturing Area

The Tetryl Manufacturing Area consists of twelve manufacturing lines where tetryl was produced
in a two-step process by first sulfonating N-N-dimethylanitine and then nitrating the resulting
intermediate.

Extensive amounts of lead were used in the piping, floors, and fittings of the nitrating houses.
Lead scrap and melted chunks of lead were abundant in the soil adjacent to most of the nitrating
houses in the area. During the Installation Assessment, team members recovered explosive
material from the soil surface. The buildings have been razed and rubble spread on both sides
of the manufacturing lines. Currently, the concrete foundations of the buildings and the
wheeling walk remain. Extensive bulldozing has scattered both friable and Transite asbestos
over the area. The underground sewers that transported wastewater during the process operations
are still buried at the site. (These vitreous clay pipes (VCPs) are part of the Industrial
Sewer System (ISS) and are addressed in the Area B Soils Operable Unit Interim Record of
Decision remediation activities.) The wastewater generated from tetryl manufacturing processes
was discharged to the Red Water Ditch through a tributary. The current study area covers
approximately 4,720,000 sg. ft (108.4 acres).

5.1.3 Study Area 16 - Flashing Ground

The Flashing Ground was used for disposal of smokeless/black powder by open burning. Today, the
remaining features include an explosives burning area and two burning pits or trenches. A flume

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is located at the end of one burning trench to capture solids generated during washout
operations. The burning area trenches and flume are contaminated with explosives and heavy
metals, based on past analytical results. Substantial logging of timber has recently occurred
in Study Area 16. The current study area covers approximately 719,000 sg. ft (16.5 acres).

5.1.4 Study Area 17 - Propellant Shipping Area

The Propellent Shipping Area is located in the eastern region of Area B extending to the
southern border of ALAAP. About one-third of Study Area 17 extends into Area A. There are
48 buildings (Series 229 Buildings), which were used to store smokeless propellant prior to
shipment. Thirteen of the 48 shipping buildings are located on the land that was previously
sold (Area A). Contamination may have resulted from sweeping debris from the buildings onto the
ground and by spills and breaks during the storage and shipping processes.

All 35 shipping buildings located within Area B were spot-tested for the presence of
nitrocellulose and nitroaromatic residues. Low levels of nitrocellulose were detected in 84
percent of the samples. All buildings were covered with Transite shingles, but no friable
asbestos was found. The current study area covers approximately 5,485,000 sg. ft (125.9
acres).

5.1.5 Study Area 19 - Lead Remelt Facility

Study Area 19 (Lead Remelt Facility) was originally used for flashing explosives. Later, it was
used for remelting and recovering lead as part of the demolition activities conducted in former
TNT and tetryl production areas. As in Study Area 16, there are two burning pits or trenches.
A thick concrete flashing rack barricade and a concrete slab for flashing explosives remain in
the area. Stressed vegetation is visible in the area where large lead ingots or slag are found.
Study Area 19 is contaminated with heavy metals, primarily lead. Elevated concentrations of
explosives are also suspected. The current study area covers approximately 116,000 sg. ft (2.7
acres).

5.1.6 Study Area 22 - Demolition Landfill

The Demolition Landfill is located near the Flashing Ground (Study Area 16), and consists of
a semicircular landfill in a swale extending approximately 500 ft along Patrol Road. At this
site, rubble from demolition activities was dumped in a 50-ft wide semicircle around the edge of
the swale to an average depth of approximately 7 ft. Several hundred pounds of lead were found
on the surface at this site in the form of sheets, wire, and pipe. Large amounts of cast iron,
stainless steel fittings, aluminum, Transite, and other rubble were partially buried by concrete
and earth. Friable asbestos also was distributed in the soil of this area.

Drainage from the Demolition Landfill joins the drainages from Study Areas 16 and 19 and
eventually enters Talladega Creek. No surface water bodies are present in Study Area 22. The
current study area consists of approximately 77,000 sg. ft (1.8 acres).

5.2 Analytical Data to Date

Over the years, numerous studies have been conducted at ALAAP to delineate the extent of
contamination. Among these studies, investigations conducted by ESE and SAIC are considered
as the most comprehensive in Area B.

Table 1A presents a summary of analytical data based on site investigations conducted by ESE
in 1986 and 1990, and presented in the Supplemental RI/FS of March 1992. Table IB presents
a summary of analytical data based on site investigations conducted by SAIC in 1995, and

-------
presented in the Draft Supplemental RI of February 1996. Data in these tables are separated by
study area and medium. Both tables contain frequencies of detection, and mean and maximum
concentrations for each contaminant of concern. In addition, a separate sampling program was
conducted by WESTON in 1996 to delineate explosives and metals contamination in Study Areas
16 and 19.

The following subsections present important findings of these previous investigations.

5.2.1 Study Area 2 - Smokeless Powder Facility

During an environmental survey conducted by ESE in 1986, zinc and mercury were detected above
background levels in groundwater, and 2,4-DNT was detected in sediment and soil samples.

The presence of 2,4-DNT in Study Area 2 was confirmed during the sampling program conducted by
SAIC as part of the Supplemental RI. According to the Draft Final RI Report of February 1996,
one of the surface samples contained 26,100 ppm of 2,4-DNT.

5.2.2 Study Area 10 - Tetryl Manufacturing Area

The Tetryl Manufacturing Area was studied during the exploratory and confirmatory surveys (ESE,
1981; 1983; 1991). Soil and sediment samples were analyzed for explosives, metals, and
leachable lead. During the RI survey (ESE, 1986), groundwater and surface water samples were
collected for historical comparison. Soil samples were collected and tested for leachable lead.

Soil contamination was detected where the wastes entered the ISS from surface ditches. The
highest tetryl concentrations (20,900 ppm and 18,900 ppm) detected in the Tetryl Manufacturing
Area were in the shallow (2 ft and 2.5 ft) soil samples at manholes MH 10-3 and MH 10-1, where
the surface ditches entered the vertical clay pipes leading to the base of the manhole
structures. The samples collected near the base of the manholes at these locations contained
tetryl contamination at lower concentrations.

Low concentrations of TNT were detected in the two sediment samples collected from the surface
drainage and at the ISS outfall into the Red Water Ditch. No other contaminants were detected
in the sediment samples.

Based on these results, the ISS within the Tetryl Manufacturing Area is contaminated with high
concentrations of tetryl. The manhole structures have probably leaked as evidenced by
contamination in the soils surrounding the structures. The greatest soil contamination appears
to be in the area where the surface ditches enter the ISS.

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                                          Table 1A
               Concentrations of Contaminants of Potential Concern (COPCs)  in
       Shallow Soil and Sediment in Study Areas 10, 16, 17, 19 and 22 at ALAAP Area B
                           (ESE Sampling Programs, 1986 & 1990)
  Study
  Area
   10
   16
            Medium
             Soil
             Soil
   17
   19
   22
             Soil
 Analyte
Tetryl
Lead

1,3,5-Trinitrobenzene
2,4,6-Trinitrotoluene
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Chromium
Copper
Nickel
Lead
Frequency
of
Detection

4/8
3/3
2/8
6/11
4/8
1/8
2/2
3/3
1/1
6/6
Concentration
Detected

Mean
4,270
901
2.30
0.874
0.919
0.767
3.25
954
13.3
462
(ppm)

Maximum
13,700
1,990
3.92
2.35
1.87
0.767
6.13
1,430
13.3
1,890
           Sediment   Lead
             Soil
             Soil
                            2/2
                                                             10.i
2, 4-Dinitrotoluene
Lead
Chromium
Copper
Nickel
Lead
Anthracene
Benzo (a) anthracene
Benzo (a) pyrene
Chromium
Chrysene
Copper
Fluor anthene
Lead
Nickel
Pyrene
Tetryl
Zinc
2/20
18/19
3/3
3/3
2/2
5/5
1/1
1/1
1/1
1/1
1/1
1/1
1/1
2/2
1/1
1/1
1/2
1/1
0.371
18.9
5.13
16.4
7.08
5,320
0.18
1.70
0.79
38.9
1.10
45.8
1.60
1,260
34.5
1.10
55.3
393
0.371
29.5
5.40
29.0
12.0
14,700
0.18
1.70
0.79
38.9
1.10
45.8
1.60
2,160
34.5
1.10
55.3

  *  Soil and sediment data from samples collected 0 to 2 feet below land surface.

Source:   Environmental Science & Engineering,  Inc.
                                                                                     393

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                                          Table IB
                    Concentrations of Contaminants of Concern (COCs)  in
                  Soils in Study Areas 2, 10, 17, 19 and 22 at ALAAP Area B
                         (SAIC, Draft Supplemental RI, February 1996)
  Study
  Area
            Medium
Analyte
     Frequency       Concentration
    of          Detected (ppm)
Detection
               Mean        Maximum
         Surface Soil   2,4-Dinitrotoluene
            0-1 ft.
                             2/8
                       3,260
26,100
  10
  17
  19
  22
Surface Soil
0-1 ft.
Surface Soil
0-1 ft.

Surface Soil
0-1 ft.
Surface Soil
0-1 ft.
Manganese
2, 4-Dinitrotoluene
Manganese
Lead
Lead
Manganese
3/3 2,090 4
5/7 718 4
3/3 1,460 2,400
19/20 2,410 24,000
9/9 1,530 5,020
3/3 891 1,570
                                                                                  4,100
                                                                                  4,000
Source:     Draft Final RI Report,  Alabama Army Ammunition Plant Area B Supplemental Remedial
           Investigation, February 1996,  prepared by Science Applications International
           Corporation (SAIC).   Contaminants of Concern from Table 6-55,  and Freguencies of
           Detection and Concentrations from tables in Section 4.

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Leachable lead was detected in two of five soil samples taken during the RI survey. The
concentrations were 0.02 and 2.3 mg/L, which were below the then-applicable extraction
procedure (EP) toxicity criterion of 5 mg/L for lead.

The SAIC Draft Final RI Report (February 1996) indicate that manganese was detected in all 3
samples collected between 0-1 ft depth with a maximum concentration of 4,100 ppm.

5.2.3 Study Area 16 - Flashing Ground

The Flashing Ground was studied during the exploratory and confirmatory surveys (ESE, 1981;
1983; 1991). Soil and sediment samples were analyzed for explosives, metals, and leachable
lead. During the RI survey (ESE, 1986), groundwater and surface water samples were also
collected for historical comparison. Significant findings include:

1. No contamination was detected in the surface water or sediment samples.

2. As a result of depositing explosives on the ground for flashing and burning, Study Area
16 is contaminated with nitroaromatic residues. Elevated concentrations of lead were
also found in the soils in the area.

Based on available analytical results and past activities at the site, the suspected locations
of contamination in Study Area 16 are shown in Figure 5.

High levels of 2,4-DNT and TNT were detected during WESTON's sampling program in February-March
1996 with maximum concentrations of 16,000 and 14,000 ppm, respectively. Other detected
compounds were 1,3-DNB (2.1 ppm), 1,3,5-TNB (23 ppm), and lead (628 ppm).

5.2.4 Study Area 17 - Propellant Shipping Area

The Propellant Shipping Area was studied during the exploratory and 1986 and 1990 supplemental
RI surveys (ESE, 1986, 1990). Soil and groundwater were analyzed for a range of contaminants.
Significant findings include:

1. Soil samples contained 2,4-DNT (0.371 ppm), lead (29.5 ppm), and nitrocellulose (131
ppm) .

2. The only detectable contaminant found in groundwater was lead (0.002 to 0.012 mg/L).
Concentrations were below the then-applicable extraction procedure (EP) toxicity
criterion of 5 mg/L for lead.

The SAIC Draft Final RI Report (February 1996) indicates that 2,4-DNT was detected in 5 of 7
samples collected between 0-1 ft depth with a maximum concentration of 4,000 ppm. Manganese was
detected in all 3 samples Collected at the same depth with a maximum concentration of 2,400 ppm.

5.2.5 Study Area 19 - Lead Remelt Facility

The Lead Remelt Facility was studied during the exploratory and confirmatory surveys (ESE, 1981;
1983; 1991). Soil and sediment samples were analyzed for explosives, metals, and leachable
lead. During the RI survey (ESE, 1986), groundwater and surface water samples were collected
for historical comparison. Significant findings include:

1. No contamination was detected in the surface water or sediment samples.

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2. The soils of the Lead Remelt Facility contained high concentrations of lead residues.
Numerous large pieces (ingots) of lead remain on the soil surface in this area. A slag
pile outside the ALAAP fence contained a lead concentration of 14,700 ppm
(approximately 1.5 %). This pile was relocated inside the fence during remedial
investigation activities.

3. Leachable lead was detected in all soil samples collected during the RI survey.
Concentrations of leachable lead ranged from 0.016 to 7.6 mg/L. The upper limit of the
range was higher than the then-applicable extraction procedure (EP) toxicity criterion of
5 mg/L for lead.

Lead ingots in Study Area 19 were sampled on 22 February 1995 during a site tour conducted by
the USAGE. Samples were obtained from the surface of ingots/slag currently stored to the north
of the concrete wall in the old Lead Remelt Facility (Figure 5). The analytical results of this
sampling event are presented in Table 2.

As shown in Table 2, Sample #1 contained high concentrations of iron and copper and moderate
concentrations of arsenic, chromium, lead, and tin. Sample #2 contained high concentrations
of iron and moderate concentrations of arsenic, lead, and copper. Both samples are
representative of waste material (i.e., slag or dross on molten metal) produced by lead recovery
or remelting operations. The surface of these materials was guite friable, probably due to
oxidation of iron. The surrounding soils are discolored and there is a stressed vegetation area
within a radius of approximately 100 ft. Based on available analytical results and past
activities at the site, the suspected locations of contamination in Study Area 19 are shown in
Figure 5.

The SAIC Draft Final RI Report (February 1996) indicates that lead was detected in 19 of 20
samples collected between 0-1 ft depth with a maximum concentration of 24,000 ppm.

Results of the sampling program conducted by WESTON in February-March 1996 indicated the
presence of lead at 566 ppm.

5.2.6 Study Area 22 - Demolition Landfill

The Demolition Landfill was examined during the exploratory and 1986 RI studies (ESE).
Significant findings include:

1. Soil samples contained total lead with concentrations up to 2,160 ppm. Low
concentrations of tetryl, chromium, copper, iron, and nickel were also detected.

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                          Table 2





       Analytical Results of Ingots in Study Area 19





Contaminant           Units             Concentration





                                  Sample #1                Sample  #2
Antimony
Arsenic
Cadmium
Calcium
Chromium
Lead
Sodium
Tin
Copper
Iron
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
CL
%
4.9
221
8.24
112
159
355
<50
196
1.18
24.9
<0.5
137
6.78
1,489
69.6
295
69.8
<100

19.5
                                                          0.23
Source:  WESTON,  February 1995.

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2. Some polyaromatic hydrocarbons (PAHs) were detected in soil. Mean concentrations
ranged from 0.18 ppm for anthracene to 1.7 ppm for benzo(a)anthracene.

The SAIC Draft Final RI Report (February 1996) indicates that lead was detected in all 9 samples
collected between 0-1 ft depth with a maximum concentration of 5,020 ppm. Manganese was detected
in all 3 samples collected at the same depth with a maximum concentration of 1,570 ppm.

6.0 SUMMARY OF SITE RISKS

The information presented in Section 6.1 (Exposure Assessment) and Section 6.2 (Intermediate
Cleanup Levels (ICLs)) is based on the "Supplemental Remedial Investigation/Feasibility Study
for Area B, Alabama Army Ammunition Plant, Baseline Risk Assessment", August 1992.

6.1 Exposure Assessment

The human risk assessment (RA) evaluated three primary exposure scenarios for guantitative
assessment of the risks associated with potential exposure of the local population within the
intended areas to site-related contaminants of concern. Based on the physical and chemical
properties of the contaminants identified in Area B, as well as the site-specific geological,
hydrogeological, and meteorological conditions, the most significant migration pathway has been
determined to be infiltration of soil contaminants to the underlying groundwater.

The following human exposure scenarios have been addressed in the risk assessment:

• Future residential scenario.
• Future industrial scenario.
• Current worker or caretaker scenario.

The primary human exposure routes evaluated for the residential and industrial scenarios in the
RA included:

• Exposure to contaminants as a result of ingestion of groundwater contaminated by on-site
soils.

• Exposure to contaminants as a result of direct contact (dermal contact and incidental
ingestion) with surface soil, surface water, and sediments.

• Exposure to contaminants as a result of inhalation of contaminated dusts.

The main ecological exposure routes evaluated included:

• Exposure of aguatic and terrestrial animals to contaminants as a result of direct contact
(dermal contact and incidental ingestion) with surface soil, surface water, sediments, and
contaminated food.

• Exposure of terrestrial animals to contaminants as a result of inhalation of contaminated
dusts.

Results of the human and ecological RA indicated that the potential noncarcinogenic and
carcinogenic adverse impacts to human health and the environment, which are associated with
future exposure to several study areas within Area B, range from low to high. These impacts
depend on the exposure scenario and the study area being considered. The noncarcinogenic
impacts are indicated by a cumulative hazard index (HI) exceeding 1; a carcinogenic risk is
posed if the cumulative risk exceeds l.OE-04.

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Although the baseline risk assessment only indicates lead and copper as contaminants of concern
based on past site activities, soil characteristics (e.g., Table 1) and recent analyses of
ingots in Study Area 19 (Table 2) suggest that there is explosives and metal contamination that
must be addressed in Study Areas 2, 10, 16, 17, 19 and 22.

6.2 Intermediate Cleanup Levels (ICLs)

Intermediate Cleanup Levels identified for Area B Soils Operable Unit IV are presented in Table
3. During the ICL selection process, the following soil cleanup levels were considered:

Category (a) ICLs established in the Area B Soils Operable Unit and the Stockpile Soils Area
Operable Unit.

Category (b) Preliminary Remediation Goals (PRGs) developed in the Supplemental RI/FS of
March 1992 prepared by ESE.

Category (c) Industrial Risk-Based Concentrations developed by the Technical Support Section
of EPA Region III, October 1995.

Category (d) Remedial Option Goals (ROGs) developed by SAIC in the Draft Supplemental
RI of February 1996. Separate ROGs have been developed in the RI based on
noncarcinogenic and carcinogenic health effects.

The ICLs for the contaminants of concern were selected from the above categories based on
engineering and scientific judgement using available information.

7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES

Several remedial alternatives were considered during the initial screening stage in the Draft
Feasibility Study for Area B submitted in March 1992. The remedial alternatives were grouped
according to the type(s) of contaminants. The groups consisted of:

• Metals- and polyaromatic hydrocarbons (PAH)-contaminated soils.
• Explosives-contaminated soils.
• Metals- and explosives-contaminated soils.

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                                                                  Table 3
                                    Intermediate Cleanup Levels  (ICLs) for Area B Soils Operable Unit IV
    Contaminat
Benzo(a)anthracene
Benzo(a)pyrene
Chrysene
1,3-Dinitrobenzene
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Tetryl
1,3,5-Trinitrobenzene
2,4,6-Trinitrotoluene
Maximum Concentration in Soil

2,

ESE (a)
Supplemental
RI/FS (1992)
1.7
0.79
1.1

1.87
0.77
13,700
3.92
2.35
Detected in Study
10, 16, 17, 19 &

WESTON (b)
Areas 16 & 19
(1996)



2.1
16,000


23
14,000
Areas
22 (ppm)

SAIC (c)
Supplemental
RI (1996)
91.9
131


26,100
0.154

3.23
49
ICLs Used
in
Area B
Soils OU
(d) (ppm)





1


5,000

647
PRGs
From 1992
RA (e)
(ppm)



37.1
17.2
24.0



5,000

647
EPA Reg. Ill
Industrial
Risk-Based
Cone.
Oct. 1995 (f)
(ppm)

7.8
0.78
780
200
8.4 (4,100) (h)
8.4 (2,000) (h)
20,000
100
190
Remedial Option
Goals for

Industrial Scenario, Draft
Supplemental RI,

Noncarcinogenic
Effects
(ppm)
12,900
12,900


1,730
864

36.7
348
SAIC, 1996 (c)

Carcinogenic
Effects
(ppm)
165
16.5


356 (i)
356 (i)

6,500

Selected
ICLs
(ppm)


165 (g)
16.5(g)
24 (g)
1
356 (i)
356 (i)
5,000
36.7
348
Lead
                        14,700
                                           628
24,000
                                                                         500
                                                                                  250
2,860
400 (j)

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Key: (a) Supplemental RI/FS for Study Area B, March 1992, prepared by Environmental Science and Engineering, Inc.
(b) Sampling program conducted by Roy F. Weston, Inc. in Study Areas 16 and 19, February-March 1996.
(c) Draft Final RI Report, Alabama Army Ammunition Plant Area B Supplemental Remedial Investigation, Februay 1996, prepared by Science Applications
International Corporation (SAIC) .
(d) "Final Interim Record of Decision, Area B Soils Operable Unit (Study Areas 6, 7, 10 and 21) , Alabama Army Ammunition Plant, Childersburg, Alabama",
November 1994, prepared by Roy F. Weston, Inc.
(e) Preliminary Remediation Goals (PRGs) developed for the Industrial Scenario in the "Supplemental Remedial Investigation/Feasibility Study for Area B,
Alabama Army Ammunition Plant, Final Baseline Risk Assessment", August 1992, prepared by Environmental Science and Engineering, Inc.
(f) Risk-Based Concentration Table (Industrial), July-December 1995, prepared by R. L. Smith, Technical Support Section, EPA Region III, Philadelphia, PA,
October 20. 1995.
(g) PAHs were only identified in Study Area 22 and will be addressed using an engineered landfill in accordance with the remedial option identified in the
Draft Final Feasibility Study Report dated March 1996, prepared by Science Applications International Corporation.
(h) The values within brackets indicate concentrations only if one isomer is present. If both isomers are present, the combined concentration is 8.4 ppm.
In most cases, both isomers exist together.
(i) The Human Health Remedial Goal Options for cancer effects is calculated using a cancer slope factor for a mixture of 2,4- and 2,6-Dinitrotoluene. An
EPA-approved slope factor is not available for either compound individually.
(j) "Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities", OSWER Directive #9355.4-12, Office of Solid Waste and
Emergency Response, U.S. Environmental Protection Agency, Washington DC, July 14, 1994.

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After the initial screening, five alternatives (Alternatives 1A, 1C, ID, 1G, and II) were
assembled and retained for detailed analysis. The alternatives developed in the FS were for all
the Study Areas at ALAAP including Study Areas 2, 10, 16, 17, 19 and 22. The final soil
remedial alternatives developed in the FS were as follows:

1A: Stabilization of Metals- and PAH-Contaminated Soils.

1C: Off-Site Disposal of Metals- and PAH-Contaminated Soils.

ID: Incineration of Explosives-Contaminated Soils.

1G: Incineration/Stabilization of Metals- and Explosives-Contaminated Soils.

II: No Action.

Brief descriptions of the remedial alternatives are presented in Subsections 7.1 through 7.5.
Since these general alternatives were developed in the FS for all of the study areas in Area B,
some of the components listed in the remedial alternatives are not specifically applicable to
this operable unit, nevertheless, they have been included for completeness.

7.1 Alternative 1A: Stabilization of Metals- and Polyaromatic Hydrocarbon (PAH)-
Contaminated Soils

Alternative 1A includes site preparation followed by excavation of all metals- and PAH-
contaminated soils. Excavated soils would be remediated using the following operations:

1. Staging of soils prior to stabilization.
2. On-site stabilization until TCLP criteria are met.
3. Backfilling stabilized soils into the existing excavation.
4. Landfilling of remaining stabilized material in an off-site hazardous waste landfill.

7.2 Alternative 1C: Off-Site Disposal of Metals- and PAH-Contaminated Soils

Alternative 1C includes site preparation followed by the excavation of metals- and PAH-
contaminated soils. Excavated soils would be transported to the Chemical Waste Management
hazardous waste landfill facility for disposal.

7.3 Alternative ID: Incineration of Explosives-Contaminated Soils

Alternative ID includes site preparation followed by excavation of explosives-contaminated
soils. Excavated soils would be remediated using the following operations:

1. Staging of soils prior to incineration.
2. On-site incineration via transportable rotary kiln incinerator.
3. Disposal of incinerated ash in the original excavations.
4. Landfilling of remaining stabilized material in an off-site hazardous waste landfill.

7.4 Alternative 1G: Incineration/Stabilization of Metals- and Explosives-Contaminated Soils

Alternative 1G includes site preparation followed by excavation of explosives- and metals-
contaminated soils. Soils contaminated with metals and/or explosives would be remediated using
the following operations:

1. Staging of soils prior to incineration and/or stabilization.

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2. On-site incineration via transportable rotary kiln incinerator.
3. Stabilization of soil, treated soil and/or flyash until TCLP criteria are met.
4. On-site placement of treated and stabilized material in on-site disposal area.

7.5 Alternative II - No Action

The no-action alternative is required to be included as stipulated by CERCLA/SARA as a baseline
against which other alternatives can be evaluated. Under this alternative, contaminated soil
and sediments would remain in place in the identified study areas. The risks from the
contaminants of concern (COCs) would remain. No cost is associated with this alternative.

8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

8.1 Threshold Criteria

Overall Protection of Human Health and the Environment

Alternative II (No Action) would not provide protection to human health or the environment.
Alternatives 1A and 1C address only metals- and PAH-contaminated soils. Alternative ID
addresses only explosives-contaminated soils, therefore, the potential risk from leaching lead
into groundwater will remain. Alternative 1G provides the most protection to human health and
the environment by permanent destruction of all organic contaminants through incineration and
through immobilizing metals by stabilization.

Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

No federal or state chemical-specific ARARs regulate implementation of any of the alternatives.
Soils will be remediated according to health-based cleanup levels determined to be protective of
human health and the environment. In Alternatives 1A, ID and 1G, stabilized materials will meet
the TCLP criteria for metals. In Alternatives ID and 1G, incineration win meet <1 ppm for TNT
in treated material. Alternative II (No Action) would not achieve the remediation levels since
contamination would not be removed or destroyed.

The following location-specific ARARs are examined for applicability at ALAAP:

1. Within 100-year floodplain

• 40 CFR 264. 18(b) - Facility must be designed, constructed, operated, and
maintained to avoid washout by a 100-year flood.

2. Within floodplain

• Executive Order 11988; 40 CFR 6, App. A: Floodplain Management - Requires actions
to avoid adverse effects, minimize floodplain destruction, restore and preserve
natural and beneficial values, and minimize impact of floods on human safety, health
and welfare.

3. Wetlands

Executive Order 11990; 40 CFR 6, App. A: Protection of Wetlands - Requires action
to avoid adverse impact, minimize potential harm, and preserve and enhance wetlands
to the extent possible.

4. Within an area affecting stream or river

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Fish and Wildlife Coordination Act [16 United States Code (USC) 661 et seq.] -
Must take action to protect affected fish or wildlife resources, and prohibits
diversion, channeling, or other activity that modifies a stream or river and affects
fish or wildlife.

5. Critical habitat upon which endangered or threatened species depend

Endangered Species Act of 1973 (16 USC 1531 et seq.); 50 CFR 402 - Requires action
to conserve endangered or threatened species. Must not destroy or adversely modify
critical habitat.

However, none of the location-specific ARARs are expected to apply to implementation of any
of the alternatives being evaluated since all activities associated with the Area B Soils
Operable Unit IV remediation would be conducted in areas located away from sensitive
environments (i.e., the river, 100-year floodplain, or critical habitat).

The following action-specific ARARs may apply to implementation of these alternatives,
excluding Alternatives II (No Action):

1. Clean Air Act (CAA)

• 40 CFR Part 50: National Primary and Secondary Ambient Air Quality Standards
- Establishes standards for ambient air quality to protect public health and
welfare.

40 CFR Part 61: National Emission Standards for Hazardous Air Pollutants - Sets
emission standards for designated hazardous pollutants.

2. Resource Conservation and Recovery Act (RCRA)

• 40 CFR Part 261: Identification and Listing of Hazardous Waste - Provides
guidelines for classifying wastes as hazardous waste.

40 CFR Part 262: Standards Applicable to Generators of Hazardous Waste -
Establishes standards for generators of hazardous waste.

40 CFR Pail 264: Standards for Owners and Operators of Hazardous Waste Treatment,
Storage, and Disposal Facilities - Establishes minimum national standards which
define the acceptable management of hazardous waste for owners and operators of
facilities which treat, store, or dispose of hazardous waste.

40 CFR Part 266 Subpart H: Standards for Hazardous Waste Burned in Boilers and
Industrial Furnaces - Specifies standards for owners and operators of boilers and
industrial furnaces burning waste and not operating under interim status.

3. Alabama Administrative Code (AAC)

• Chapters 13-1 through 13-7: Alabama Solid Waste Management Regulations -
Establishes minimum criteria for the processing, recycling and disposal of solid
wastes and the design, location, and operation of solid waste disposal facilities.

Chapters 335-3-1 through 335-3-14: Alabama Air Pollution Control Rules and
Regulations - Sets emission standards and establishes permitting requirements for
air pollutants.

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4 . Code of Alabama

• Title 22, Chapter 27: Alabama Solid Waste Act - Establishes a statewide program
to provide for the safe management of non-hazardous wastes.

Title 22, Chapter 28: Alabama Air Pollution Control Act of 1971 - Provides for a
coordinated statewide program of air pollution prevention, abatement, and control.

• Title 22, Chapter 30: Alabama Hazardous Waste Management and Minimization Act -
Establishes a statewide program to provide for the safe management of hazardous
wastes, including hazardous waste generation, transportation, and land disposal.

5. Alabama Department of Environmental Management (ADEM)

• Chapter 14-1: Alabama Hazardous Waste Management Regulations-Establishes
standards which define the acceptable management of hazardous waste for owners
and operators of facilities which treat, store, or dispose of hazardous waste.

8.2 Primary Balancing Criteria

Short-Term Effectiveness

No significant risks to the community, workers, or the environment are expected during the
implementation of any of the remedial alternatives. Workers will be provided with appropriate
personal protection, and safety procedures will be followed during all phases of the remedial
actions. Alternative II would present unacceptable risks to human health and the environment
since no remediation of the contaminated soils would occur. Therefore, this alternative would
not be effective in the short term.

Long-Term Effectiveness and Permanence

Alternatives 1A, 1C, ID, and 1G would reduce the risk associated with contaminants. Alternatives
ID and 1G would provide a permanent remedy for explosives-contaminated materials by irreversible
destruction of organic contaminants via incineration. Alternative 1G will provide additional
long-term protection by immobilizing leachable metals, primarily lead, by stabilization.
Alternative II would not be effective in the long term since the contamination in soil and
sediment would remain in place without treatment.

Reduction of Toxicity, Mobility, and Volume (TMV)

The TMV of contaminated materials will be reduced significantly in each of the alternatives,
except in Alternative II (No Action). Alternatives ID and 1G would provide more reduction in
volume than Alternatives 1A and 1C, since these alternatives provide permanent destruction of
explosives-contaminated materials. Alternative 1G would be the most effective since it
addresses all types of contaminants in soils. Although some stabilized materials will result in
Alternative 1G, the mobility of the contaminants will be significantly reduced. Because the
contaminants in soil and sediment would not be destroyed or treated under Alternative II, TMV of
the contaminants would remain unchanged.

Implementability

All alternatives are easily implementable. The eguipment, personnel and technologies associated
with each alternative are readily available. No remedial action would be conducted under

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Alternative II.

Cost

Soil volumes and costs estimated in the FS submitted in March 1992 are not representative of
the currently-proposed remedial actions due to changes in the contaminants of concern and ICLs.
For example, the costs in the FS are based on remediation of only lead- and copper-contaminated
soils in Study Area 2, 10, 16, 17, 19 and 22.  However, it is known that elevated concentrations
of explosives are present in the soils  (especially Study Area 10) which also require
remediation.

A sampling program will be conducted prior to the commencement of remediation activities to
further delineate the nature and extent of contamination.  A remediation estimate will be
developed from the volumes of contaminated material greater than ICLs, based on the results
of the sampling program.  At this time, however, it is possible to compute a unit cost based on
the actual expenditures incurred to date associated with the Area B Soils Operable Unit  (Study
Areas 6, 7 and 21),  since the same remediation technologies (excavation, incineration and/or
stabilization, on-site backfilling) are used in both operable units.  Accordingly, the estimated
unit costs for incineration and stabilization are:

Incineration  (including project plans, sampling, excavation,  backfill of excavated
              area,  feed preparation, incineration, and on-site disposal of treated
              material) 	$300 to $330 per yd 3

Stabilization (including project plans, sampling, excavation,  backfill of excavated
              area,  stabilization, and on-site disposal of treated
              material)	$100 to $130 per yd 3

Above costs include transportation of contaminated soil from Study Areas 2, 10, 16, 17, 19 and
22 to the incineration/stabilization/disposal process area in Area B currently in use for Area B
Soils Operable Unit remediation.

8.3  Modifying Criteria

ADEM/EPA Acceptance

EPA and ADEM have concurred with the choice of Alternative 1G.

Community Acceptance

A public notification for the Area B Soils Operable Unit IV public meeting and public comment
period was advertised in four local newspapers, one of which was a major newspaper.  The public
comment period began on 15 September 1996 and ended on 15 October 1996.  Two people attended the
public meeting which was held on 8 October 1996 at the Central Alabama Community College.  The
public appears to have no concerns regarding implementation of Area B Soils Operable Unit IV.

9.0  SEIiECTED REMEDY AND REMEDIATION GOALS

The complete remedy for the Area B Soils Operable Unit IV consists of Alternative 1G.  A brief
description of this alternative is as follows:

       •      Clear,  survey,  and grid areas;  perform soil and  sediment sampling and chemical
              analysis to delineate explosives and metals contamination.

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• Use Ground Penetrating Radar (GPR) or test pits to locate suspected burning
trenches in Study Areas 16 and 19.

• For contaminated areas (except Study Area 22): excavate soils until excavation
criteria are satisfied; transport materials to the TIS-20 site in Area B; treat
materials by incineration and/or stabilization until treatment and disposal criteria
are satisfied; dispose treated material in the on-site backfill area. Study Area 22
will be addressed using an engineered landfill in accordance with the remedial
option identified in the Draft Final Feasibility Study Report dated March 1996,
prepared by Science Applications International Corporation.

• If necessary, expand the existing on-site disposal area for final placement of
treated materials.

• Decontaminate oversize materials by crushing or shredding and treatment in the
TIS-20 or by high-pressure water washing; dispose in the backfill area.

• Treat contaminated process, sampling, and decontamination wastewaters in the TIS-20
agueous waste treatment system; reuse water for site dust control and process
makeup.

• Conduct confirmatory soil and sediment sampling and chemical analysis to ensure
that excavation criteria have been satisfied.

• Backfill excavated areas with uncontaminated borrow soils and rough grade to
pre-excavated contours.

• Close the on-site disposal area in accordance with the existing approved permit
applications for treated soils ("Treated Soils - Backfill Area Permit Application
for the Alabama Army Ammunition Plant", March 1994 and November 1994).
• Test portions of decontaminated concrete slabs or structures to ensure adeguate
decontamination. If Webster's Reagent is used, there is no numerical guantifiable
decontamination criterion. A change of color will indicate that TNT is present at
concentrations above 15 Ig/cm 2.

9.1 Basis for Selection

Alternative 1G was selected as the most appropriate remedial alternative for soils in Study
Areas 2, 10, 16, 17, 19 and 22, because it best addresses explosives and metals (primarily lead)
contamination and provides the most effective overall protection to human health and the
environment. Incineration is the primary treatment method in Alternative 1G. Numerous other
treatment methods (such as composting, biodegradation, etc.) were evaluated in the technology
screening stage in the FS. During the technology screening stage, these technologies were
eliminated based on their applicability to site-specific circumstances such as effectiveness of
the treatment technology to COCs, availability, implementability, etc. A complete discussion of
screening of technologies is contained in the Draft Feasibility Study of March 1992.

A cost comparison was performed in the Draft FS for three types of incinerators. They are
transportable rotary kiln incineration, slagging rotary kiln incineration, and infrared
incineration. The analysis indicated that the cost of incineration using a rotary kiln unit is
considerably less than the other two technologies. The TIS-20 incinerator is currently in
operation at ALAAP treating explosives- and lead-contaminated soils from Study Areas 6, 7 and
21, and the Industrial Sewer System in Study Areas 6, 7 and 10, as approved in the Area B Soils
Operable Unit Interim ROD. The TIS-20 has already processed over 120,000 tons of soils

-------
contaminated with explosives, lead, and other metals at ALAAP.  Extensive stack sampling during
three mini-burns and the Performance Test demonstrated that the TIS-20 is meeting the reference
air concentrations  (RACs) for lead and other metals as defined by the Boiler and Industrial
Furnace  (BIF) regulations.  In addition, over 35,000 tons of soils have been stabilized and
disposed on-site.

The remediation of Study Areas 2, 10, 16, 17, 19 and 22 is not expected to produce soils with
metals concentrations higher than previously demonstrated in the Performance Test.  Since the
soils in Study Areas 2, 10, 16, 17, 19 and 22 contain the same waste characteristics as the
Stockpile Soils Operable Unit and the Area B Soils Operable Unit, and will be sampled prior
to treatment, it is appropriate to use rotary kiln incineration as the primary treatment method.
In addition to rotary kiln incineration, a soils stabilization process will be conducted, as
necessary, prior to on-site disposal of treated materials.

9.2  Remediation Goals

The selected alternative will meet the following remediation goals:

                                                   Excavation Cleanup Goals
    Explosives

      1,3-Dinitrobenzene                           >      1   ppm
      2,4-Dinitrotoluene  (2,4-DNT)                 >    356   ppm
      2,6-Dinitrotoluene  (2,6-DNT)                 >    356   ppm
      Tetryl                                       >  5,000            ppm
      1,3,5-Trinitrobenzene  (1,3,5-TNB)             >   36.7   ppm
      2,4,6-Trinitrotoluene  (TNT)                  >    348   ppm

    Metals  (total)

      Lead                                         >    400   ppm

Source:  Table 3 of this document  (Selected ICLs).

Excavation will proceed until excavation criteria are achieved or one of the following is
encountered:  groundwater, bedrock, foundations or other major subsurface obstructions.

Water Treatment Criteria

The treatment criteria for wastewaters generated during remediation activities are:

                                              Wastewater
       Parameter                          Treatment Criteria

         Flow                             < 50 gpm

         Temperature                      < 905F (April - November)
                                          < 605F (December - March)
       Explosives

         TNT                              < 6.9  Ig/L
         1,3,5-TNB                        < 7.3  Ig/L
         2,4-DNT                          < 5.7  Ig/L

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       Metals

         Arsenic                          < 5    mg/L
         Barium                           < 100  mg/L
         Cadmium                          < 1    mg/L
         Chromium                         < 5    mg/L
         Lead                             < 5    mg/L
         Mercury                          < 0.2  mg/L
         Selenium                         < 1    mg/L
         Silver                           < 5    mg/L

       Total Organic Carbon  (TOG)         < 50   mg/L
       Total Suspended Solids  (TSS) 1           < 50   mg/L
       Total Dissolved Solids  (TDS) 1           < 1000 mg/L
       pH                                 6-10

    Source:    Work Plan for a Transportable Incineration System (TIS)  at the Alabama Army
             Ammunition Plant  (AAAP) Stockpile Soils Area Operable Unit, February 1994.

As in the case of the prior remediation of the Stockpile Soils Area Operable Unit and the Area
B Soils Operable Unit, the rotary kiln incineration system is a net water consumer.  Treated
water is only used for process makeup water and site dust control.  There is normally no surface
water discharge.

    1  As directed by USAGE, if all limits but TSS and TDS are satisfied, treated water may be
       used for dust control and treated soil moistening.
Incineration/Backfill Criteria for Treated Soil from Incinerator

Treated soil from the incinerator will be stored until analytical results indicate that the ash
satisfies the following treatment criteria for backfill:

                                       Disposal Criteria
       Explosives (total)

         TNT                              <     1     ppm

       Metals (TCLP)

         Arsenic                          <     5     mg/L
         Barium                           <   100     mg/L
         Cadmium                          <            1      mg/L
         Chromium                         <     5     mg/L
         Lead                                   <      5      mg/L
         Mercury                             <   0.2           mg/L (4 Ig/g using total metals
                                                                   analytical method)
         Silver                                 <      5      mg/L
         Selenium                               <      1      mg/L

Source:    Work Plan for a Transportable Incineration System  (TIS) at the Alabama Army
           Ammunition Plant  (AAAP) Stockpile Soils Area Operable Unit, February 1994.

Treated material failing to meet the TCLP backfill criteria will be stabilized before disposal.

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Treated material failing to meet the TNT incineration criterion will be reprocessed.

Stabilization/Backfill Criteria for Stabilized Material

The backfill criteria for stabilized material that is not incinerated will be the excavation
cleanup criteria for Explosives and TCLP criteria for RCRA metals, as follows:
          Parameter

       Explosives

         1,3-Dinitrobenzene
         2,4-Dinitrotoluene (2,4-DNT)
         2,6-Dinitrotoluene (2,6-DNT)
         Tetryl
         1,3,5-Trinitrobenzene (1,3,5-TNB)
         2,4,6-Trinitrotoluene (TNT)

       Metals  (TCLP)

         Arsenic
         Barium
         Cadmium
         Chromium
         Lead

         Parameter
         Mercury

         Silver
         Selenium
 Disposal Criteria for
Stabilized Only Soils
        1    ppm
      356    ppm
       <      356     ppm
       <   5,000    ppm
       <    36.7    ppm
       <      348     ppm
        5    mg/L
              100
       <        1
        5
           5
   mg/L
   mg/L
   mg/L
   mg/L
     Disposal Criteria for
  Stabilized Only Soils
                                                           0.2
             mg/L
                1
   mg/L (4  Ig/g using total
metals analytical method)

  mg/L
Source:     (A)  Metals (TCLP):   Work Plan for a Transportable Incineration System (TIS)  at the
            Alabama Army Ammunition Plant (AAAP)  Stockpile Soils Area Operable Unit,
            February 1994.

Decontamination Criteria

Portions (approximately 10 percent)  of decontaminated debris and building foundations will be
tested to ensure adequate decontamination.  If Webster's Reagent is used, there is no numerical
quantifiable decontamination criterion.  A change of color will indicate that TNT is present at
concentrations above 15 Ig/cm 2.

10.0   STATUTORY DETERMINATIONS

The selected remedy (Alternative 1G) satisfies the requirements under Section 121 of CERCLA
to:
              Protect human health and the environment.

              Comply with ARARs.

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• Be cost-effective.

• Utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable.

• Satisfy the preference for treatment as a principal element.

10.1 Protection of Human Health and the Environment

The selected remedy protects human health and the environment through permanent treatment and
disposal of treated material.

During the remediation activities, adeguate protection will be provided to the community by
reducing the short-term risks posed by air emissions from the thermal treatment unit and dust,
metals, explosives, and asbestos fibers (if any) potentially generated during material handling
activities. In addition, workers will be provided with personal protection eguipment during all
phases of remediation activities. Area air monitoring programs will be established to monitor
ambient and worker exposures and ensure adeguate protection.

Long-term protection to human health and the environment will be provided by minimizing
residual risk from the contaminants and by reducing or eliminating impacts on the environment.

Controls employed in this alternative are adeguate and reliable. The air pollution control
system of the incinerator (currently operating on-site) successfully passed its Performance Test
in June 1994 and yielded stack emissions in accordance with regulatory limits, protecting
workers and the community from risks associated with inhalation. There are no unacceptable
short-term or long-term impacts on human health or the environment in this alternative.

10.2 Compliance with Applicable or Relevant and Appropriate Reguirements

The selected alternative (Alternative 1G) complies with all ARARs. All the COCs in explosives-
and metals-contaminated soils of Study Areas 2, 10, 16, 17, 19 and 22 within the Area B Soil
Operable Unit IV are expected to meet reguired regulatory treatment and disposal standards.

No Federal or state chemical-specific ARARs prevent implementation of the selected alternative.
Soils will be remediated based on health-based cleanup levels determined to be protective to
human health and the environment. Lead-contaminated soils will be remediated to achieve the
health-based total lead concentration of < 400 mg/kg (Selected ICL for lead from Table 3).
Soils contaminated with TNT will be remediated to achieve the health-based soil TNT
concentration of < 348 mg/kg (based on the resultant risk for adult residents and the
contributing hazard index (HI) due to exposure concentration for child residents). Similarly,
soils contaminated with tetryl will be remediated to achieve the health-based soil tetryl
concentration of < 5,000 mg/kg.

No location-specific ARARs prevent the use of the selected alternative. All activities
associated with implementation of this alternative will be conducted away from sensitive
environments (i.e., river or 100-year floodplain).

The following action-specific ARARs will be met with implementation of this alternative:

• Incinerator ash will be routinely tested for destruction of explosives, as reguired
by RCRA (40 CFR Part 264; Standards for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities) and the State of Alabama (Alabama
Administrative Code Chapter 335-14-5.15(4) (a)l: Performance Standards for

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              Incinerators) .

       •       TCLP extract analysis on incinerator ash will be performed to ensure that metals
              concentrations  meet RCRA guidelines for arsenic,  barium,  cadmium,  chromium,  lead,
              mercury,  selenium,  and silver (40 CFR Part 264;  Standards for Owners and Operators
              of Hazardous Waste  Treatment,  Storage,  and Disposal Facilities).  Incinerator ash
              that does not pass  TCLP will be  stabilized prior to disposal.

       •       Incinerator ash and stabilized material (if reguired)  will be disposed on-site in
              Area B in accordance with RCRA (40 CFR Part 264;  Standards for Owners and Operators
              of Hazardous Waste  Treatment,  Storage,  and Disposal Facilities)  and the State of
              Alabama (Code of Alabama,  Title  22,  Chapter 27;  Alabama Solid Waste Act and Alabama
              Administrative  Code Chapters 13-1 through 13-7;  Alabama Solid Waste Management
              Regulations).

       •       Workers will be provided with personal protection eguipment during all phases of  the
              selected remedy,  in compliance with the Occupational Safety and Health Act (OSHA)
              (29 USC ss.  651-678).  Adeguate  protection will  be provided to the community by
              reducing risks  posed by air emissions from the thermal treatment unit and reducing
              dust potentially generated during material excavation and handling activities.

       •       Portions of the decontaminated concrete slabs and structures in Study Areas 2,  10,
              16,  17,  19 and  22 will be tested to ensure adeguate decontamination. Decontaminated
              debris will be  disposed on-site  in Area B in accordance with State of Alabama
              regulations (Code of Alabama,  Title 22,  Chapter  27:  Alabama Solid Waste Act and
              Alabama Administrative Code Chapters 13-1 through 13-7:  Alabama Solid Waste
              Management Regulations).

10.3  Cost-Effectiveness

Based on a cost comparison study conducted during the Draft FS of March 1992, transportable
rotary kiln incineration was  determined to provide overall effectiveness proportionate to its
costs, compared to other types of incinerators.  This alternative takes advantage of the special
eguipment, operators, site preparation, thermal treatment system, and regulatory approvals
already in place for the treatment of soils and debris from the Stockpile Soils Area Operable
Unit and the Area B Soils Operable Unit.

10.4  Utilization of Permanent Solutions and Alternative Treatment Technologies or
      Resource Recovery Technologies to the Maximum Extent Practicable

The selected remedy  (Alternative  1G) meets the statutory reguirements to utilize permanent
solutions and treatment technologies to the maximum extent practicable to achieve remediation
goals.  The rationale for selecting this remedy is based on the comparative analysis of the
evaluation criteria. The criteria used in selecting the remedy include:

       •       Long-Term Effectiveness and Permanence:   The selected remedy employs destruction  of
              explosives-contaminated materials and stabilization of metals-contaminated
              materials.  All treated materials will be disposed on-site by expanding the existing
              disposal area.

       •       Short-Term Effectiveness:   The selected remedy does not involve off-site
              transportation  of contaminated soils,  thereby eliminating the risks due to spillage
              and fugitive emissions.   The community,  workers,  and the environment will be
              protected during remedial actions by implementing appropriate protective measures.

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       •       Implementability:   No waiting period is  involved for  implementation of  the  selected
              remedy.   An incinerator and a stabilization plant are currently approved  by the
              regulatory agencies and are operating on-site  treating soils  of the Area  B  Soils
              Operable  Unit which have similar characteristics as the contaminated soils  in the
              Area B Soils Operable Unit  IV.

       •       Cost:   Transportable rotary kiln incineration  is considerably less  costly than other
              types of  incineration.   Since an incinerator is  currently on-site,  treating soils
              with similar characteristics,  costs  for  activities such as regulatory approvals,
              mobilization/demobilization,  etc.  will be  minimal for incineration  of soils.

10.5  Preference for Treatment as a Principal Element

The selected interim action utilizes treatment for the explosives-  and metals-contaminated soils
in Study Areas 2,  10, 16, 17,  19 and 22 within the Area B Soils Operable Unit IV. Any additional
reguired actions for Study Areas 2, 10, 16, 17,  19 and 22 will be addressed in the final
Decision Document for the soils of Area B.

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                                        RESPONSIVENESS SUMMARY

1.0   OVERVIEW

The public reaction to the selected remedy is mainly acceptance.  No concerns were received
from the public during the public meeting.  The public appears to have no substantive concerns
regarding implementation of the selected remedy.  Continued community relations activities will
be held to maintain public awareness of the status of remedial activities at ALAAP.

2.0   BACKGROUND ON COMMUNITY INVOLVEMENT

General community interest in the ALAAP site has historically not been great.  Since the site
was declared excess to the Army needs in 1973, interest has generally come from private groups
or industry interested in developing portions of the site.  The southern part of the site (i.e.,
the former nitrocellulose manufacturing area) was sold to the Kimberly Clark Corporation in the
late 1970's, and a paper products plant was constructed.  In the mid-1980's, in response to
interest in purchasing the eastern part of ALAAP (Area A), this section was remediated by the
Army and the contaminated soil was stockpiled in the western part of ALAAP  (Area B),  creating
the Stockpile Soils Area Operable Unit (OU).   A ROD for treatment (i.e., incineration followed
by solidification/stabilization, if reguired) of the Stockpile Soils Area OU has been signed and
implemented.

Post-excavation sampling was performed to verify the remediation efforts within Area A and two
sites  (Study Area 12 and D)  were subseguently identified as containing contamination above
acceptable levels.  A final ROD for treatment (i.e., excavation followed by stabilization) of
the Area A OU was issued in April 1994, and has been subseguently implemented.

A supplemental RI/FS for Area B, prepared in March 1992, identified tetryl, lead and TNT
contamination in the old manufacturing areas.  An interim final ROD for the treatment of the
Area B Soils OU (for Study Areas 6, 7, 10 and 21) was issued in August 1994 and is being
implemented.  A separate interim ROD was issued in October 1996 for the Area B Soils Operable
Unit IV, which includes the treatment of contaminated soils and sediments in Study Areas 2,  10,
16, 17, 19 and 22.  Notice for the public comment period and public meeting for the Area B Soils
Operable Unit IV was placed in three local newspapers on 15 September 1996, and in one local
newspaper on 17 September 1996.  The public comment period extended until 15 October 1996.  A
public meeting was held on 8 October 1996 at the Central Alabama College.  No public comments
were received.

3.0   SUMMARY OF PUBLIC COMMENT AND AGENCY RESPONSES

Comments from Public Meeting

At the public meeting held on 8 October 1996, the public was given the opportunity to comment
and ask guestions about the selected remedy  (Alternative 1G).   No guestions/comments were
raised by the public.

4.0   REMAINING CONCERNS

The public appears to have no substantive concerns about the implementation of the selected
remedy.

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