2005-01 - Radford Army Ammunition Plant

477 Pages·2006·19.43 MB·English

RADFORD ARMY AMMUNITION PLANT, VIRGINIA
SWMU 39
RCRA Facility Investigation1
Corrective Measures Study Report
Prepared for: Prepared by:
USACE Baltimore District Shaw Environmental, Inc.
10 S. Howard St. Shaw- 21 13 Emmorton Park Rd.
Baltimore, MD 21201 ~dgewoodM, D 21040
Contract No. DACA31-01- F-0085
Final Document June 2005
DEPARTMENT OF THE ARMY
RADFORD ARMY AMMUNITION PLANT
P.O. Box 2
RADFORD VA 24143-0002
SJMRF-OP 17 August 2005
MEMORANDUM FOR Cmdr, US Army Environmental Center, Attn: SFIM-AEC-CDN
(Tony Perry), 51 79 Hoadley Road, Aberdeen Proving Ground, MD 21 010 -5401
SUBJECT: Notification of Radford Army Ammunition Plant Decision Document SWMU
39- Excavation of Soil for Clean Close Out, Off Site Disposal
I.R eference Memorandum from Assistant Chief of Staff For Installation Management,
9 Sep 03, Subj: Policies for Staffing and Approving Decision Documents.
2. A copy of the subject decision document (enclosed) is submitted IAW reference. As
the cost of the action in the subject decision document is under $2 million, approval
authority is with the Installation Commander.
3. Point of contact is Mr. James J. McKenna, 540 639 8641 COM, 931 8641 DSN.
Encl
VBERT N. DAVlE
Chief Operafions Team
RADFORD ARMY AMMUNITION PLANT, VIRGINIA
Decision Document
-
SWMU 39 Excavation of Soil for Clean Close Out and Off-Site
Disposal
Final August 2005
TABLE OF CONTENTS
Section Page
. ........................................................................................................................................
1 0 PURPOSE 1
........................................................................................................................................
2.0 SITE RISK 2
...........................................................................................................
3.0 REMEDIAL ALTERNATIVES 2
..........................................................................................
4.0 PUBLlClCOMMUNlTY INVOLVEMENT 3
................................................................................................................................
5.0 DECLARATION 3
.......................................................................................................
6.0 APPROVAL AND SIGNATURE 4
.................................................................................................................................
7.0 REFERENCES 4
I Radford Army Ammunition Plant
SWMU 39 Decision Document
1.0 PURPOSE
This Decision Document (DD) is prepared in accordance with the Assistant Chief of Staff for
Installation Management (ACSIM) memorandum (ACSIM, 2003) detailing policies for staffing
and approving DDs and Defense Environmental Restoration Program (DERP) management
guidance (DERP, 2001). This document describes the selected action (Excavation of Soil for
Clean Close Out and Off-site Disposal) for soil contaminated with metals and dioxinslfurans at
Solid Waste Management Unit (SWMU) 39 - the Wastewater Ponds from the Propellant
Incinerators at Radford Army Ammunition Plant (RFAAP). This alternative was selected in
accordance with the Resource Conservation and Recovery Act of 1976 (RCRA), the Hazardous
and Solid Waste Amendments of 1984 (HSWA), the RFAAP Resource Conservation and
Recovery Act (RCRA) Permit requirements (USEPA, 2000) (EPA ID No. VA1210020730), and
the Final RCRA Corrective Action Plan (USEPA, 1994), as applicable as well as the SWMU 39
RCRA Facility InvestigatiodCorrective Measures Study Report, Final Document, June 2005.
SWMU 39 consists of two unlined and bermed earthen ponds. The ponds received scrubber and
pre-cooler quench water from incinerator exhaust. The ponds were excavated approximately 6 to
8 feet into the natural grade. The excavated material was used to create a berm that surrounds
each pond. A fence surrounds the ponds, and the enclosed area is approximately 450-ft. by 300-
ft. at the widest points.
The RFAAP RCRA Corrective Action Permit, signed in September 2000, identified SWMU 39
as having the potential to pose a threat, or potential threat, to human health and the environment.
The Permit required that a sampling strategy be developed to complete the delineation and
characterization of the site. RCRA Facility Investigation (RFI) field efforts were conducted in
1999 and 2002. Data indicated that metals and dioxidfurans had contaminated soil at SWMU
39. The contamination was mostly confined to the top two feet of soil. Human Health and
Screening Level Ecological risk assessments (Section 2.0) indicated there was elevated risk at the
site and remedial measures were necessary to ensure the protection of human health and the
environment.
Based on the findings of the SWMU 39 RFI, a Corrective Measures Study (CMS) was
conducted. The CMS evaluated remedial alternatives (Section 8.0) to address the cadmium
contamination at the site. The selected remedy was Excavation of Soil for Clean Close Out and
Off-site Disposal. This alternative was selected as the final alternative for SWMU 39 because it
is implementable and provides protection to human health and the environment. In addition, this
alternative facilitates clean close out and is cost effective. By achieving clean close out, these
corrective measures accomplish the Army's Installation Restoration Program (IW) goal by
cleaning up the site, mitigating risks, and restoring it for beneficial use. Therefore, the
alternative - Excavation of Soil for Clean Close Out and Off-site Disposal - has been selected by
the U.S. Army with concurrence from the U.S. Environmental Protection Agency (USEPA)
Region III, Virginia Department of Environmental Quality (VDEQ) and the US Army Center for
Health Promotion and Preventive Medicine (USACHPPM). Documents supporting this decision
are located in the RFAAP information repository.
Radford Army Ammunition Plant
SWMU 39 Decision Document
2.0 SITE RISK
A human health risk assessment (HHRA) and screening level ecological risk assessment
(SLERA) was conducted as part of the SWMU 39 RFVCMS.
The risks associated with five exposure scenarios were calculated the HHRA: current
maintenance workers, future maintenance workers, future excavation workers, future adult
residents, and future child residents. The potential cumulative risk for the current maintenance
worker, the future maintenance worker, and the excavation worker were less than the USEPAts
target risk range. The potential cumulative risks for the adult and child residents were within the
USEPAts target risk range. The potential cumulative hazard index (HI) for the current and future
maintenance worker and adult resident scenarios were less than 1. The potential cumulative HI
for the future excavation worker scenario was slightly above 1; no individual chemical was equal
to or greater than 1. The potential cumulative HI for the future child resident scenario was above
1, primarily due to vanadium and iron. The margin-of-exposure evaluation indicated that the
intake from iron was within the allowable range. Lead was also evaluated as a chemical of
potential concern (COPC) in the HHRA using the Adult Lead Model for the worker scenarios
and the Integrated Exposure Uptake Biokinetic (IEUBK) model for the resident scenarios. For
each scenario, site concentrations of lead in surface soil and total soil were above the health
protective criterion.
A Screening Level Ecological Risk Assessment (SLERA) was conducted to identify potential
hazards to ecological receptors. The assessment suggests potential adverse impacts to terrestrial
wildlife, especially shrews, robins, and voles, from food-chain exposure, as well as a potential
reduction in food supply from elevated concentrations of lead, copper, and chromium. For food-
chain exposure, the primary hazard drivers were lead and dioxinslfurans in surface soil.
Thallium, chromium, and copper were secondary hazard dnvers in surface soil for this exposure
pathway. Regardless, based on uncertainties of toxicity, no wildlife RTE species confirmation in
the SWMU 39 study area, the engineered treatment unit nature of the site, and the small size of
the SWMU (2.6 acres), remedial measures solely to address ecological concerns are not
warranted at this time. It should be noted, however, that the proposed remedial action will
provide a significant reduction in ecological risk to potential receptors.
3.0 REMEDIAL ALTERNATIVES
Four corrective measures alternatives were evaluated to address metals and dioxinslfurans in soil
at SWMU 39:
1. No Further Action;
2. Institutional Controls (Land Use Controls, Groundwater Monitoring);
3. Excavation of Soil with Waste in Place, Off-site Disposal, and Institutional Controls (Land
Use Controls, Groundwater Monitoring); and,
4. Excavation of Soil for Clean Close Out and Off-site Disposal.
These four alternatives were evaluated using the selection criteria: effectiveness,
implementability, and cost. The corrective measures objective (CMO) for the RFVCMS was to
reduce contaminant concentrations in soil to mitigate the human health risk and to allow clean
2 Radford Army Ammunition Plant
SWMU 39 Decision Document
close out of the site. To fully address this objective, a remedy that addressed the potential for
future groundwater impact received preferential consideration. RFAAP is underlain by karst
geology. The preferential remedial alternative in this type of geological setting is source
removal. Allowing waste to remain in place above actionable regulatory levels represents a risk
to RFAAP personnel and the environment.
Alternative Four was selected as the final alternative because it is implementable and provides a
greater level of protection to human health and the environment not provided by Alternatives
Two and Three. Alternative Four facilitates clean close out, is cost effective, and is protective of
groundwater. By achieving clean close out, these corrective measures accomplish the Army's
IRP goal by cleaning up the site, mitigating risks, and restoring it for beneficial use. This
corrective measure can be implemented in approximately one year, however, this should be
considered an estimate. The actual time to complete the corrective measures could be impacted
by site-specific conditions, funding delays, andlor regulatory review. The total estimated cost for
this alternative is $1,130,000.
This alternative includes the following:
Delineation of soil containing arsenic, lead, vanadium, and dioxinslfurans above the
Residential RG;
Excavation of the delineated area such that the remaining soil is below the Residential
RG;
Transportation and off-site disposal of soil; and,
Site restoration activities.
Implementation of this alternative will reduce the concentrations of metals and dioxin/furans to
below the Residential RGs and facilitate clean close out. In addition, the proposed human health
RG for residential land use is expected to result in reduction of ecological risks associated with
analytes in soil to levels that are protective of the environment. Therefore, implementation of
this alternative meets the corrective action objective and is protective of human health and the
environment.
4.0 PUBLICICOMMUNITY INVOLVEMENT
RFAAP has a Restoration Advisory Board (RAB) which has been actively involved throughout
the environmental investigation activities conducted during the RFVCMS. The RAB includes
representatives from USEPA and VDEQ, as well as members of the local community.
Comments on the RFVCMS were solicited from the USEPA and VDEQ. Comments were
received and considered by the U.S. Army prior to selection of the Excavation of Soil for Clean
Close Out and Off-site Disposal alternative.
5.0 DECLARATION
The selected remedy is protective of human health and the environment, attains Federal and State
requirements that are applicable or relevant and appropriate to this corrective measures action,
Radford Army Ammunition Plant
SWMU 39 Decision Document
and is cost effective. This remedy utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable for this site. However,
because onsite treatment of the principal threats of the site was not found to be practicable, this
remedy does not satisfy the statutory preference for onsite treatment as a principal element of the
remedy. Onsite treatment of metals and dioxinlfuran-contaminated soil was determined to not be
implementable and cost effective for the volume of contaminated soil at SWMU 39. The
selected remedy will result in no hazardous substances remaining on-site above levels that would
restrict future use, therefore, the five-year review process will not apply to this action.
6.0 APPROVAL AND SIGNATURE
In summary, the Army will implement the Excavation of Soil for Clean Close Out and Off-site
Disposal alternative for SWMU 39 at RFAAP. The total cost for this action is below $2 million;
therefore, the appropriate approval authority is the Installation Commander for RFAAP.
Approved By:
Ronald F. Fizer Date
LTC, CM, Commanding
Radford AAP
7.0 REFERENCES
Assistant Chief of Staff for Installation Management (ACSIM), 2003. Memorandum from Major
General Larry J. Lust: Policies for StafJing and Approving Decision Documents (DDs),
dated 09 September 2003. I
Defense Environmental Restoration Program (DEW), 200 1. Memorandum for Assistant
Secretary of the Army: Management Guidancef or the Defense Environmental
Restoration Program, dated 28 September 2001.
U.S. Environmental Protection Agency (USEPA), 1994. Final RCRA Corrective Action Plan,
Office of Solid Waste and Emergency Response. EPA/520/Rl94/004.
U.S. Environmental Protection Agency (USEPA), 2000. Radford Army Ammunition Plant Pem't
for Corrective Action and Waste Minimization. Permit No. VA1210020730. 3 1 October
2000.
U.S. Army Radford Army Ammunition Plant (RFAAP), 2005. SWMU 39 RCRA Facility
Investigation/Corrective Measures Study Report, Final Document June 2005.
Radford Anny Ammunition Plant
SWMU 39 Decision Document
,?
McKenna, Jim
From: McKenna, Jim
Sent: Friday, August 05, 2005 9:41 AM
To: Tony Perry (E-mail)
Cc: Karen Colmie Heckelman (E-mail); Katie Watson (E-mail); Stephen. C. Wood (E-mail); Davie,
Robert; Redder, Jerome
Subject: SWMU 39 Decision Document, Final Aug 2005
Importance: High
All:
In the attached file is the subject document that I will present to the LTC Fizer for his signature. Note a draft document has
been reviewed and approved by USACHPPM, JMC and NERO. The draft and final document are based on the final
SWMU 39 RFllCMS that was approved by the EPA Region Ill on June 6, 2005. The terminology used in this document is
consistent with the approved RFIICMS. In future reports RFAAP will consider alternate language.
If you have'any questions or concerns please contact me at 540 639 8641.
Final SWMU 39 DD
Aug 2005.d0~
Jim McKenna
IMPORTANT NOTE: When replying to this message please cut and paste [email protected] into the address line.
Please do not hit the reply button. THIS A NEW ADDRESS. Thanks.
RE: SWMU 39 Decision Document, staffing for review and approval Page 1 of 2
\
\
McKenna, Jim
From: Jennings, David M Mr NERO [[email protected]]
Sent: Tuesday, November 16,2004 7:48 AM
To: McKenna, Jim
Subject: RE: SWMU 39 Decision Document, staffing for review and approval
Sorry Jim, been out of the office for too much. I concur, too.
Dave
David M. Jennings
Installation Management Agency, Nortteast Reg~un
Environmental & Natural Resources Branch
SFIM-NE-PW-ER
5 North Gate Road
Fort Monroe, VA 23651-1048
[phone]
DSN: 680-7638
From: McKenna, Jim [mailto:[email protected]]
Sent: Monday, November 15, 2004 11:32 AM
To: 'David Jennings, NERO IR'
Subject: RE: SWMU 39 Decision Document, staffing for review and approval
1m portance: High
David, everyone else has concurred. Need your response. Thanks. Jim
Jim McKenna
IMPORTANT NOTE: When replying to this message please cut and paste [email protected] into the
address line. Please do not hit the reply button. Thanks.
-----Original Message-----
From: McKenna, Jim
Sent: Tuesday, November 09,2004 10:34 AM
To: 'Jackson, Thomas'; 'Wyatt, William'; 'Williams, Keith J Mr USACHPPM'; 'David Jennings, NERO IR'
Subject: RE: SWMU 39 Decision Document, staffing for review and approval
If you got this message then I have not received your reply. Please respond with your concurrence. If
you have questions or concerns please call me at 540 639 8641so we can discuss them. Thanks.
Jim McKenna
IMPORTANT NOTE: When replying to this message please cut and paste [email protected] into
the address line. Please do not hit the reply button. Thanks.
-----Original Message-----
Fmm: McKenna, Jim
Sent: Tuesday, October 26, 2004 12:49 PM
To: Case, Joy; 'Jackson, Thomas'; 'Wyatt, William'; 'Williams, Keith J Mr USACHPPM'; 'David Jennings, NERO IR'
Cc: 'john e tesner'; Redder, Jerome; Davie, Robert