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APPENDICES

A RMA Site Location Map

B 1997 RMA Committee Agreement/April 1998 BAS Meeting Minutes

C 2003 RMA Committee Agreement

D Soil Tilling Plan for FWS TRER Sites

E Assessment Report for TRER Sites 35CC-6 and 1SE-4

El - TRER Site 35CC-6 Assessment

E2 - TRER Site I SE-4 Assessment

E3 - ARER Assessment for Upper Derby Lake

E4 - Remaining BAS Actions Memo

F TRER Figures:

Fl- TRER Sites Where Excavation Occurred

172- TRER Tilling Demonstration Sites

F3- Tilled and/or Sampled TRER Sites

G Changes to P 1 Soil Boundaries

H P I Soil Survey Data CD Index

TABLES

1.4-1 RER Soil Sample Risk Analysis

1.5-1 Contaminants of Concern

1.6-1 P1 Soil Tracking

2.0-1 Completion of RER Milestones

4.1.2-1 TRER Soil Tracking

5.3.2-1 PI Volumes

8.2-1 RER Soil Project Records and Documentation

13.0-1 Key Supporting Documents

FIGURES

1.0-1 P I Soil Areas Remediation Status

1.0-2 TRER Sites Remediation Status

4.1.6-1 MEC Recovered in RER Areas

5.3.1-1 Wells Located in P 1 Soils

5.3.1-2 Wells Located in TRER Areas

5.3.3-1 Rocky Mountain Arsenal RER Revegetation Status

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EXECUTIVE SUMMARY

This Construction Completion Report (CCR) for the Residual Ecological Risk (RER) Soil

Remediation - Part I of the Rocky Mountain Arsenal (RMA) Federal Facility Site was prepared

in accordance with the U.S. Environmental Protection Agency (EPA) OSWER Directive 9320.2-

09A-P (Close Out Procedures for National Priority. List Sites) (EPA 2000). It is understood that

the purpose of this CCR is to document completion of each remedial action based on the Record

of Decision (ROD) for the On-Post Operable Unit (OU) (FWENC 1996a), and provide a basis

for EPA acceptance and Colorado Department of Public Health and Environment (CDPHE)

concurrence therewith. The CCR will also be used as supporting documentation for

development of the Preliminary Closeout Report and Final Closeout Report.

The RMA OU is a Federally owned facility located in southern Adams County, Colorado,

approxi ' mately 10 miles northeast of downtown Denver, directly north of the fori-ner Stapleton

International Airport and west of Denver International Airport (Appendix A). The RMA OnPost OU currently encompasses 17.2 square miles and is on the EPA National Priority List for

environmental cleanup as a result of contamination released during previous operations. The

cleanup remedy selected in the ROD includes treatment of groundwater and 31 Implementation

Projects (IPs) for soil and structures. The RER Soil Remediation - Part I sites are located

throughout the On-Post OU of the RMA,

This CCR documents the iniplementation of remedial action through September 2005 for Priority

I (P I) and Terrestrial Residual Ecological Risk (TRER) soils, by either removal or 3-step tilling

and sampling, during the RER Soil Remediation - Part 1. P I and TRER soils are areas located

outside of IP boundaries that do not cause concern for human health but may pose a potentially

unacceptable risk to biota. All remaining PI and TRER site remedies completed after September

2005 will be documented in the RER Soil Remediation - Part 2 CCR.

Based on the results of risk characterization, RER soils are separated into two categories with

different remediation requirements:

" PI soil

" TRER soil

The Program Management Contract (PMC) Quality Assurance (QA)/Quality Control (QC)

Department assumed the construction QC responsibilities for removal of P I and TRER soil. The

Construction Quality Assurance Plans within the approved remedy IP design packages (FWENC

2003b, 2002e, 2001b, 2001c, 200le, 2001f, 2000a, 2000b, 2000d, 2000e, 1999a, 1999b, 1999f,

1998b, 1998c, MK 1998a) were implemented by the PMC and followed by the Subcontractor

during all construction activities. As presented in Table 1. 6- 1, 11 IPs removed P 1 soil within

project boundaries or from borrow areas (BAs) for use as gradefill or backfill in the Hazardous

Waste Landfill, Basin A, or within project sites. The TRER sites where soil has been removed

by IPs are provided in Table 4.1.2- 1. The use of P I or TRER soils is tracked by project sites in

the Annual Borrow Area Updates.

As of August 3, 2005, 1,502,574 bank cubic yards (bey) of P1 soil and 93,336 bey of TRER soil

have been excavated. The P I soil from BAs 4, 7b, and 9a (Parcel 2) remains to be excavated. Of

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the 42 TRER sites identified in the 2003 RMA Committee Agreement (Appendix C) for

remediation, portions of 6 sites remain to be remediated. The closure of these six remaining

TRER sites and three P I areas will be documented in the RER Soil Remediation - Part 2 CCR.

Those TRER sites not excavated by IPs were tilled in accordance with the 2003 RMA

Committee Agreement and/or sampled in accordance with the Biological Advisory

Subcommittee Sampling and Analysis Plan. A Remediation Venture Office (RVO) QC

representative inspected and verified completion of all TRER tilling sites, as documented in the

Annual Borrow Area Update project files. -

Personal health and safety sampling and analysis were perforrried during removal activities, in

accordance with the National Institute for Occupational Safety and Health Manual of Analytical

Methods. Sample analysis was perfornied by an analytical laboratory accredited by the

American Industrial Hygiene Association. The laboratory analysis included field blanks, as

required by the individual method or laboratory. Pflor to sampling, the specific sampling and

analytical method was discussed with the laboratory to detern-line any special requirements or

variations to established methods necessary to collect an acceptable Sample. There have been no

reported action level exceedances during removal activities for the RER Soil Remediation - Part

Prefinal and final inspections for IPs perfori-ning removal were conducted in accordance with

Comprehensive Environmentýl Response, Compensation and Liability Act guidance and contract

specifications to close out the subcontract of the remediation Subcontractor. The purpose of the

inspect ions was to detern-iine whether the construction was completed in accordance with the

subcontract and to determine whether all aspects of the plans and specifications were

implemented in accordance with the ROD and the approved design package. The prefinal and

final inspections were conducted in conjunction with representatives of the EPA, CDPHE, the

Tri-County Health Department, the PMC Project Team, and the RVO.

No caps, covers, or treatment facilities are required by the ROD for this remedial action,

therefore no long-tenii operations or maintenance is required. However, the property involved in

this remedial action is subject to restrictions on land and water use and will be included in the

RMA-wide 5-year reviews of remedial action.

The RVO has determined that this remedial action has been completed and has achieved the

intent of the ROD to be protective'of human health and the environment. No further action is

required on the RER Soil Remediation - Part I sites.

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1.2.3 2003 Committee Agreement

In 2003, the RMA Committee reached concurrence on an Agreement (Appendix Q regarding the

remediation of RER soils identified in the TRER report. The Agreement adopted the BAS

recommendations for removal or tilling of the 42 TRER sites. Twenty-four of the sites are

located primarily in or adjacent to BAs. For these sites, removal is the preferred remedial

approach. However, if the soil will not be removed, soil tilling can be substituted to reduce risk

to acceptable levels. The tilling method (Appendix D) approved by BAS consists of 3 steps, 1)

ripping to 18 inches, 2) plowing to 12 inches and 3) discing to 6 inches. The remaining 18 sites

are outside BAs and the Agreement states that the 3-step tilling process is the preferred approach

to reduce risk to acceptable levels. The original TRER boundaries defined by the BAS are

included in the 2003 Committee Agreement (Figure I of Appendix C).

The Agreement also stated that the following actions would be completed:

Provide interim documentation of the remediation of TRER sites in the Annual BA

Updates, to include the following:

- A summary of the soil tilling risk reduction demonstration (Section 5.2.1 Tilling

Demonstration Sampling and Analysis Plan [SAP] [TtFW 2004bl was completed in

2004. The TRER Soil Tilling Demonstration Study Report (RVO 2006) was issued in

March 2006.

- An evaluation to determine whether institutional controls are needed on P I or TRER

soil used as common gradefill outside Arn-iy-retained sites (Sections 5.1.2 and 5.1.3).

Only the Previously Excavated Lake Sediments sites from the Miscellaneous

Southern Tier Project require institutional controls. Institutional controls available are

described in the Interim Institutional Control Plan (PMRMA 2003). Results of the P I

Backfill SAP are provided in a Data Summary Report (DSR) (TtFW 2004a) and clear

all other backfill sites, outside Army-retained areas.

Track P I soil to ensure that P I soil with HQ > 10 is not used as common gradefill outside

of Anny-retained sites. (P I soil removal and placement operations began years prior to

the 2003 RMA Committee Agreement being signed. The RVO reviewed the placement of

the P I soil operations prior to 2004 and deten-nined that all Pl soil with an estimated HQ

>10 was placed inside an Am-ly-retained area. A review of the remaining Pl soil

indicated that only one area in BA 4 remains with a potential HQ >10. The BA 4 P1 soil

is planned to be placed in Basin F, an Arrny-retained area.)

Remedy for site I SE-4 is to include additional sampling at depth, evaluation of

biomonitoring data and an aquatic residual risk assessment by BAS (Appendices E2 and

E3).

1.3 RER Sites

The P I soil sites are shown on Figure 1.0-1. The Pl soil Contaminants of Concern (COCs) are

primarily OCPs and are limited to surficial soil (0 to I foot) as identified by the BAS and

documented in the 1997 RMA Committee Agreement and all subsequent Annual Borrow Area

Updates, including the years 1998 (FWENC 1998a), 1999 (FWENC 1999e), 2000 (FWENC

2000c), 2001 (FWENC 2001d), 2002 (FVvENC 2002d), 2003 (FWENC 2003c), 2004 (TtFW

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2004c and TtEC 2005a), 2005 (TtFW 2005a and TtEC 2006d), and future Annual Borrow Area

Updates, as necessary.

The 42 TRER sites (Figure 1.0-2) were identified in 2003 by the BAS after much of the soil

project remediation at RMA had been completed. The TRER soil COCs are primarily OCPs and

limited to surficial soil (0 to I foot) as identified by BAS and documented in the 2003 RMA

Committee Agreement and all subsequent Annual Borrow Area Updates, including the years

2004 (TtFW 2004c), 2005 (TtFW 2005a), and future Annual Borrow Area Updates, as

necessary.

Identification of these RER sites for remediation was completed in accordance with the process

described in the ROD (FWENC 1996a). Designation of these RER sites resulted in completion

of the ROD-identified requirements for the BAS (Appendix E3).

1A Scope of Project

RER Soil Remediation was provided for in the ROD and the 1997 and 2003 RMA Committee

Agreements.

Per 1997 Committee Agreement, and in accordance with approved IP design packages (FWENC

2003b, 2002e, 2001b, 2001c, 200le, 2001f, 2000a, 2000b, 2000d, 1999a, 1999b, 1999f, 1998b,

1998c, MK 1998), P1 soils have been predominantly used as borrow for gradefill/backfill or

taken to Basin A or HWL as waste (Table 1. 6- 1). Thus, removal has occurred under a multitude

of different RMA projects since 1998. All P1 areas were required, per RVO direction, to be

surveyed prior to and subsequent to excavation. These surveys were perfon-ned by the IPs and

placed electronically into the Geographic Information System (GIS). The documentation of

removal has been shown in the yearly Borrow Updates. In addition, Basin A Operations and

HWL Operations have used P I soils. Basin A Operations and HWL Operations project files

containing P1 survey data have been reviewed annually by the Regulatory Agencies prior to

archive. Project record reviews for implementing remedy projects are performed after project

implementation.

Per the 2003 RMA Committee Agreement, two acceptable remedies were identified for TRER

sites: removal or 3-step tilling. In addition, a Tilling Demonstration Study would confinn that

3-step tilling had sufficiently reduced risk. The Tilling Demonstration Study was performed in

2004 with an objective to confirm, through soil samples collected, that concentrations of OCPs

were at or below an HQ of 2 after the sites were tilled. Seven TRER sites, identified in

Appendix F2, were selected and sampled for this study. Sample results confirmed that

ecological risks for the small bird are acceptable in all but one subplot of the TRIER sites selected

for this study. Sample results for one area, 26NW-5 subplot A, had concentrations resulting in

an HQ >2. Based on the results of this study, all remaining unremediated TRER sites were

sampled to confirm that soil OCP levels were within the effective risk reduction range (2 < HQ

:510) of the tilling process (Appendix F3). Sites tilled prior to the Tilling Demonstration Study

were also sampled to confirm that HQs for these sites have been reduced to an HQ of 2 or less.

In addition, P 1 in BA 9C was sampled to determine actual risk. The results are documented in

Table 1.4-1 and the RER DSR.

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A 3-step tilling procedure was written by RVO and reviewed by BAS. This procedure is used by

the tilling performer, in most cases USFWS. Prior to tilling a site, a survey is performed in order

to provide a visual boundary to the operator in the field. Quality Control inspection and

documentation were performed by RVO QC and placed in the BA project files, maintained by

the Program Management Contractor (PMC).

If a TRER site is removed rather than tilled, it is documented in the same manner as P I soil

removal. The site is surveyed prior to and following removal. The survey data are placed in the

implementing project file and the inforn-iation is transmitted to GIS. In most cases, TRER sites

have been removed by the Basin A Operations project.

Remediation tasks performed as part of the RER Soil Remediation - Part I are listed below for

PI and TRER soils. Remediation goals, standards and criteria are addressed in Section 3.0.

The scope of work for removal of PI and TRER soils by the implementing projects involved the

following common elements: construction of a temporary site access road, construction of

stormwater and sediment controls, removal of temporary site access road, final grading and

revegetation of disturbed sites. The scope of work for TRER soil tilling included a pretilling

survey, and inspection to document post-tilling completion and revegetation.

The scope of work for TRER soil sampling included use of the existing BAS RER SAP

(USFWS/FWENC 2000), preparation of sampling grid, surficial soil sample collection,

laboratory analysis and preparation of a RER DSR. Three types of soil sampling activities were

performed. Some TRER sites were identified as part of the BAS Tilling Demonstration effort

and were sampled after tilling was completed. All remaining TRER sites that had not been

removed were sampled either before or after tilling was performed.

The P I and TRER soil remediation elements are outlined below.

1.4.1 PI Soil

" Excavate and haul to HWL or Basin A.

" Excavate and place as backfill or subgrade at implementing project site and cover with a

minimum of 2 feet of clean soil. P I soil with HQ >10 will only be used as

backfill/gradefill at Army-retained areas.

" Sample P I sites not already removed to determine actual risk level (sampling results with

an HQ:!ý2 require no further action).

1.4.2 TRER Soil

" Excavate and haul to HWL or Basin A.

" Excavate and place as backfill or subgrade at implementing project site and cover with a

minimum of 2 feet of clean soil. TRER soil with HQ >10 will only be used as

backfill/gradefill at Army-retained areas.

" Perform 3-step tilling at BAS-identified areas.

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0 Sample TRER sites not excavated to demonstrate tilling effectiveness, or to determine

actual risk level (sampling results with an HQ :ý2 require no further action).

1.5 Contaminants of Concern

The COCs identified were determined in accordance with the BAS and pursuant to the ROD

(FWENC 1996a). Table 1.5-1 lists the COCs that were selected for the TRER and P 1 soils that

comprise RER Soil Remediation - Part 1. The Pl and TRER samples collected were analyzed

using the appropriate analytical suite for compounds associated with the identified COCs and at

the detection level sufficient to detect a todrin HQ <2. Biota risk exceedances were determined

by a risk-based calculation that accounted for aldrin/dieldrin levels only.

Table 1.5-1 Contaminants of Concern

Sites coc Corresponding Analytical Suite

P I and TRER Aldrin 0CPS

Dieldrin

1.6 Refinement of RER Site Boundaries

Modifications have been made to RER soil boundaries based on physical features, ROD

boundaries, and BAS recommendations. The RER soils are sites with potentially remaining

biota risk outside of the ROD-identified contamination sites. Although the BAS model was

designed to account for ROD remedy sites and physical features (e.g., roads, sewage lagoons,

etc.), delineation of P I and TRER boundaries were originally drawn without adjustment for these

features or boundaries.

The BAS provided the initial boundaries of PI soils to the RVO Borrow Team in 1997 and these

areas were adopted by RMA Committee Agreement in 1997 (Appendix B). It soon became

apparent that P I soil boundaries were extending onto roads, regularly maintained (graded)

ditches, adjacent ROD boundaries, facilities (e.g., the zero discharge wastewater treatment

lagoon), and other sites. In coordination with the BAS, the RVO began to adjust PI boundaries

to account for those sites that were not P I soil (BAS 1998) (Appendix B). In sites where P I

boundaries did not match adjacent ROD boundaries, the PI boundaries were modified to be

contiguous. This eliminated overlaps (double counting) and orphan islands of soil.

In consideration of the future National Wildlife Refuge, BAS has consistently recognized and

recommended the retention of valuable ecological habitat rather than excavation of modeled

RER risk sites. Three examples are: 1) BA 8 was moved from its original location to the West

in order to retain unique riparian soils and vegetation along the First Creek corridor; 2) BA 3 tree

grove was left undisturbed to retain existing nesting habitat for raptors; 3) Rattlesnake Hill was

left undisturbed to retain the unique soil/plant community associated with the Petrocalcic

Paleustoll soil classification that is rare at RMA.

The BAS meeting minutes from April 1998 provide documentation of recommendations from

BAS regarding habitat value in sites designated for P 1 removal. One global recommendation was

to avoid removing trees during P I removal operations (BAS 1998). Removal of RER soils was

stopped at tree driplines to avoid killing trees.

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The TRER sites were remediated either by removal (in the same manner as P 1) or by tilling and

sampling during USFWS revegetation efforts. If the TRER area was within an active BA or will

be disturbed, removal is the preferred remedial alternative. As identified in the BAS TRER

report (BAS 2002), removal of the highest soil concentration areas (identified as P2 soils) will

reduce the risk in the entire TRER site to an acceptable level, and the entire TRER site will be

remediated. This affected the excavation boundary for areas 26SW-1, 26WC-2, 31EC-1, 31EC-2

and36EC-1. Final excavation boundaries are shown in Appendix Fl. In cases where composite

sampling was performed and resulted in an area identified with HQ >2, the entire area, as

identified in the 2004 Borrow Update (I SE-4, 6NW-3, 26SE-7, 35SE- 1, and 36NE-3) was

excavated.

Equipment identified in the project-specific removal plans was used to stockpile and/or remove

contaminated soil. Haul trucks were used to transport contaminated soil to Basin A, HWL or

withina project site. If required, water was sprayed into the removal area for dust suppression.

Transport of PI and TRER soil to project sites for backfill or to on-site disposal facilities was

done in accordance with project plans and specifications (e.g., dust control, odor control).

Prior to removal, the boundary of each RER site was surveyed and staked. Upon completion, the

removal was surveyed to verify that proper depths were achieved. Appendix H contains the

survey data for removal of P I soil from all RER sites, excluding the CAMU. Survey data for the

CAMU is located in the project files, as identified in the CAMU CCR (RVO 1998, FVv`ENC

2000a). As of August 3, 2005, a total of 1,502,574 bey of PI soil had been removed and used as

backfill in implementing project sites or disposed of in the HWL or Basin A. The volume of PI

for each BA or IP is presented in Table 5.3.2-1 and in the Annual Borrow Area Updates. The

final disposition of P 1 soil is provided in Table 1.6- 1. Figure 1.0- 1 illustrates P I soil remedy

status.

Of the 42 sites identified by the BAS in the 2003 Committee Agreement, a complete or partial

removal was performed at 10 TRER sites (I SE-4, 6NW-3 [south and west], 26SE-7, 26SW-1,

26WC-2, 3 1 EC- 1, 3 1 EC-2, 3 5 SE- 1, 36EC- 1, and 3 6NE-3 [north]). Portions of six TRER sites

(subplots) remain to be excavated (26NW-5-A, 26WC-3-A, 35WC-4-F, 36NE-3 [north of 8'h],

36NW-4-B, and 36NW-5-A). All subplots, except for the area in 36NE-3, were identified via

sampling (Table 4.1.2-1). The completion of these six sites will be documented in the RER Soil

Remediation - Part 2 CCR. Table 4.1.2-1 provides the status of all TRER sites, including

remedy method performed to date, removal volume (93,336 bey), and whether remedy action is

complete.

4.1.3 Backflll and Grading

The ITS have consistently required placement of a minimum of 2 feet of clean borrow soil over

RER used as backfill or designed for use in covers. RER soil with an HQ > 10 was only used as

backfill/gradefill in Army-retained areas. No backfill is required for excavated RER sites.

4.1.4 Monitoring Well Closures

Monitoring wells were closed by separate Subcontractor(s) responsible for monitoring well

abandonment on a RMA-wide basis in accordance with the Long-Term Monitoring Plan. All

well abandonment activities were supervised by the Well Abandonment team. All wells were

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abandoned in accordance with the Specifications and Drawings for the subcontract. Well

closures were coordinated to minimize impact on the remediation of the contaminated soil.

4.1.5 Revegetation

Final revegetation of borrow sites only occurs after the BA is closed. Revegetation of RER soils

removed as part of an implementing project was usually performed by USFWS. Support is

provided by a separate subcontractor as needed. Support services, if any, usually consisted of

the application and crimping of mulch after seeding. PMC personnel provided subcontract

management and technical/field oversight of subcontractor revegetation activities. Revegetation

technical oversight included the proper anchoring of hay mulch and ensuring the use of certified

weed-free seed and hay mulch. These sites will receive permanent revegetation by the USFWS

in accordance with the Habitat Restoration Plan (USFWS 1999). Figure 5.3.3-1 shows the status

of revegetation at RER sites.

.kfter completion of TRER tilling activities, the USFWS revegetated or managed the area for

weed control. Revegetation included seedbed preparation, seed placement, anchoring of hay

mulch, and use of certified weed-free seed and hay mulch.

4.1.6 Unexploded Ordnance (UXO) Tracking

Five Munitions and Explosives of Concern (MEQ were recovered during the removal of soils or

found within Magazines at RER sites, which is documented as follows:

0 M 16 igniter (UXO Emergency Response # 12 1) found in BA 3.

0 High Explosive-filled M14 burster (UXO Emergency Response #345) found in BA 9A,

Parcel 4.

0 4.2 inch burster found in TRER Site 36NE-3.

0 Magazine 1609 - one 75 min brass cartridge with primer (BA 6)

0 Magazine 1610 - an M74 10 lb. incendiary bomb (BA 6)

Following the recovery of a partial M14 burster during soil stockpiling, UXO oversight was

provided to support the project. Prior to allowing additional excavation, UXO personnel

conducted a surface sweep of the site. Once soil excavation resumed, UXO personnel began

visually screening the soil as it was loaded for transport. When UXO personnel determined the

amount of metal debris could no longer be effectively screened under the process in place,

excavation operations were altered to the following: the subcontractor distributed the soil in onefoot lifts, UXO personnel swept each lift with magnetometers, and all identified anomalies were

characterized and removed. PMC UXO personnel were present during stockpiling and loadout.

During the screening process, no additional MEC were recovered.

The MEC items were characterized, removed and tracked per RMA protocols. Figure 4.1.6-1

shows the locations of the recovered MEC.

4.2 Project Modifications

No contract modifications were issued as a result of RER remedy activities. All modifications to

RER boundaries or exemptions are documented in the Annual Borrow Area Updates.

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7.6 Natural Resources

The PMC consulted with the USFWS and BAS throughout field work in RER soil areas. The

USFWS and BAS removed some sensitive habitat sites from RER soil areas to avoid their being

disturbed by removal or tilling and adversely impacting native vegetation or wildlife. Examples

of sites removed from disturbance included limiting removal beneath the dripline of trees,

refraining from excavating prairie dog habitat, and excluding sites due to valuable habitat.

8.0 INSPECTION DOCUMENTATION

8.1 Prefinal Inspection Meeting

The PMC conducted a Prefinal Inspection Meeting and Site Inspection for IPs, which included

RER soil removal. These meetings were conducted in conjunction with representatives of the

PMC, RVO, EPA, and CDPHE. The Prefinal Inspection results are found in the implementing

project files.

8.2 Final Inspection Meeting

In accordance with the Remediation Design and Implementation Schedule (RDIS) (PMRMA

2005), a final inspection meeting was conducted for all implementing project sites. A list of

items remaining to be completed by the Subcontractor at that time was reviewed and any

outstanding actions identified in a punch list. The meeting representatives concluded that the

remediation had been performed in accordance with the approved contract documents, and that

the completion of the punch list items would constitute project completion. The project punch

list was updated through completion by the PMC Construction Engineer for the project. A

complete list of IPs implementing P I and TRER soil removal and their final inspection meetings

is presented in Table 8.2- 1.

No final inspection of TRER sites by the Agencies was required for sites that were not

excavated. An RVO QC representative inspected and documented each tilled TRER area at

completion, as documented in the PMC borrow project files.

8.3 Final Records Review

In accordance with the RDIS, a project final records review was performed by the EPA and

CDPHE on each IP that removed P1 and TRER soils. The records review included the volume

verification surveys, as-builts, Professional Engineer and Licensed Surveyor certification,

statements, survey logs, corrective action reports, design changes and modifications, and

supporting daily and weekly QA/QC summaries. The dates of the record review for each IP and

P I associated with those projects are provided in Table 8.2- 1.

9.0 LONG-TERM OPERATION AND MAINTENANCE/MANAGEM ENT

REQUIREMENTS

No caps, covers, or treatment facilities are required by the ROD for these remediated sites,

therefore no long-term operations or maintenance is required. Future revegetation of P I and

TRER soils is described in the 2005 Vegetation Management Plan (TtEC 2005) and all future

annual Vegetation Management Plans. However, the property involved in this project is subject

to restrictions on land and water use and will be included in the RMA-wide 5-year reviews of

remedial action.

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10.0 SUMMARY OF PROJECT COSTS

The costs associated with removal of P I and TRER sites are incorporated into the IP and are not

broken out. The costs for each IP are provided in the project CCRs and project files. Costs

associated with the 3-step tilling process are part of the USFWS habitat restoration program.

11.0 LESSONS LEARNED

The overarching lesson learned for the RER Soil Remediation - Part I effort was to identify and

realize the benefits of integrating remediation and restoration goals to more efficiently and

effectively achieve remedy closure of these sites. Examples of this integration approach include

the following:

0 Defining the BA boundaries to correspond with sites of RER soil contamination. This

approach enabled those sites requiring remediation to be excavated concurrently with

borrow soils needed by other remediation projects.

- ' Implementing a pretilling sampling program to further define the biota risk associated

with TRER sites. This approach resulted in a reduction in the size and number of RER

sites which require remediation.

0 Implementing a 3-step tilling process for TRER sites as an alternative to soil removal.

This approach resulted in retention of topsoil and using the tilling process as part of the

habitat restoration process at the RMA.

12.0 RER PROJECT CONTACT INFORMATION

Direct all questions related to the project to:

Mr. Bruce Huenefeld, Remedy Execution Manager

Department of the Ariny

Base Realignment and Closure

7200 Quebec Street, Building 111

Commerce City, CO 80022-1748

(303) 289-0520

EPA Project Manager:

Ms. Laura Williams, Project Manager

United States Environmental Protection Agency

Region 8

999 18 1h St., Suite 300

Denver, CO 80202-2466

(303) 312-6660

Primary Responsible Party (PRP) Contractor:

Mr. James Ruimerman, Deputy Program Manager

Tetra Tech EC, Inc.

72 nd and Quebec Street

24 0247013RER CCR-Rev 0

N TETRA TECH EC. INC,
Rocky Mountain Arsenal CCR

RER Soil Remediation - Part I Rev 0

WBS 2.07.35 March 13, 2006

2001 f (Jan) Buried M- I Pits Soil Remediation Project 100 Percent Design Package.

Revision 0.

2000a (Sept) CAMU Soils Remediation Completion and Support Project, Construction

Completion Report. Revision 0.

2000b (Aug) Secondary Basins Soil Remediation Project 100 Percent Design Package.

Revision 0.

2000c (Aug 9) Basin F Exterior Remediation Project 100 Percent Design Package. Final.

2000d (Apr 5) Borrow Areas and Priority I Soil Tracking Plan 2000 Update. Revision 0.

2000e (Jan) Miscellaneous RMA Structure Demolition and Removal Project, 100

Percent Design Package. Revision 0.

1999a (Dec) Burial Trenches and Munitions (Testing) Soil Remediation Project Phase, 1 1. Revision 0.

1999b (Oct) South Plants Structures Demolition and Removal - Phase IT 100 Percent

Design Package. Final.

1999c (Sept 30) Site- Wide Air Quality Monitoring Program Plan. Revision 0.

1999d (July 9) Site- Wide Odor Monitoring Program Plan. Revision 0.

1999e (Apr 9) Borrow Areas and Priority I Soil Tracking Plan 1999 Update, Final

Report, Revision 0.

1999f (Mar) Basin A Operations Plan. Revision C.

1998a (Oct 13) Borrow Areas Plan. Revision 1.

1998b (Oct) Miscellaneous Northern Tier, Miscellaneous Southern Tier, and Lake

Sediments Remediation Project 100 Percent Design Package. Revision 0.

1998c (Aug.24) Existing (Sanitary) Landfills Remediation Project 100 Percent Design

Package.

1996a(June) Record of Decisionfor the On-Post Operable Unit. Final. (Volume 1).

1996b (July) Supplemental Field Study - Phase I Program Results

1996c (Sept) Soil Quantity Calculation Summary Report

MK (Morrison Knudsen Corporation)

2000 (Jan) Interactive Comprehensive Air Pathway Analysis, Annual Screening

Analysisfor Year 2000 Projects.

1998a Final Design Specifications and Drawingsfor the CAMU Soil

Remediation Project.

1998b (Sept 30) Corrective Action Management Unit (CAMU) Soil Remediation,

Construction Completion Report. Final.

PMRMA (Program Manager Rocky Mountain Arsenal)

2005 (Nov) Remediation Design and Implementation Schedule

0247013RER CCR-Rev 0 29

TETRA TECH EC. INC,
N

Rocky Mountain Arsenal CCR

RER Soil Rernediation - Part I Rev 0

WBS 2.07.35 March 13, 2006

2003 (Feb) Interim Institutional Control Plan. Final.

RVO (Remediation Venture Office)

2006 (Mar) TRER Soil Tilling Demonstration Study Report. Revision 1.

2003 (Sept) Contingent Soil Volume Procedure Sampling and Analysis Plan. Revision

2.

2002 (Aug 22) Contingent Soil Volume Procedure. Revision 2.

1998 (Sept 30) Corrective Action Management Unit Soil Remediation Construction

Completion Report. Final.

Skipper, Sherry

2004 (June 30) Compact Disk containing the updated TRER boundary refinements. Hand

delivered with an electronic mail transmittalfrom Sherry Skipper to the

BAS members

TtEC (Tetra Tech EC, Inc.)

2006a (Feb 2) Borrow Areas Management Data Summary Reportfor Residual

Ecological Risk Sites. Revision 1.

2006b (Jan 3 1) Data Summary Reportfor Sand Creek lateral Soils Remediation Project.

Revision 0.

2006c (Jan 12) North Plants Soil Remediation Project Western Parcel PI Soil

Remediation Verification Data Summary Report. Revision 0.

2006d (Jan 9) Errata Pages - Final Borrow Areas and Residual Ecological Risk Soil

Tracking Plan, 2005 Update. Revision 0.

2005a (Nov. 29) Errata Pages - Appendix D of the Borrow Areas and Residual Areas and

Residual Ecological Risk Soil Tracking Plan, 2004 Update, Revision 1.

2005b (June 23) Soil Tilling Demonstration Data Summary Report. Revision 0.

2005c (Apr 26) Site- Wide Air and Odor Monitoring Planfor Year 2005 Projects with Air

Pathway Analysis. Revision 0.

2005d (Apr 15) 2005 Vegetation Management Plan. Revision 0.

TtFW (Tetra Tech FW, Inc.)

2005a (Apr 12) Borrow Areas and Residual Ecological Risk Soil Tracking Plan 2005 -

Update. Revision 0.

2005b (Mar. 30) Well Abandonment Summary Report 2004, Final, Revision 0.

2004a (Dee 7) Borrow Sites Management Residual Risk Soil Concentration Verification

for PI Borrow used in North Plants (NP) Chemical Sewer and Section 36

Existing (Sanitary) Landfill Projects (ESL36) Data Summary Report

(DISR), Revision 0.

2004b (Oct 11) Final Residual Risk Soil Concentration Verification Sampling and

Analysis Plan Soil Tilling Demonstration Study. Rev 1.

30 0247013RER CCR-Rev 0

N TIETRATECH EC, INC.
Table 5.3.2-1 P1 Volumes

1998 Remainino, Survev Index Estimated n I Exempt Desiv Desig volume n., Number (s) Volume Volume (2) Volume -H) Removed Volume' (AppendLx BorroNv Area (bcv) - (bcv (bcý (bcy) (bcv- (bcý,)

3 329,051 296,331 1,400 340,832 0 1-23

4 321,840 304,500 0 304,500 NA

5 62,754 59,100 1,000 67,989 0 24

6 100,595 100,768 121,137 -0 25-27

7A 100,382 100,647 116,379 0 28-41

7B 50,369 48,028 54,542 2,581 42-44

8 46,843 36,010 44,081 0 47

9A 81,665 79,148 104 56,950 21,583 48-51

9C (1) 80,020 29,568 41,094 0 53-55

11 142,740 144,232 176,346 0 56-57

12 38,333 38,333 44,271 0 Note (3)

P I Soil Stockpiles NA NA 6,031 NA NA

Subtotal 1,354,592 1,236,665 2,504 1,069,652 328,664

Project P1 SoilRemediation

CAMU Soil Remediation Project 207,442 254,584 0 Note (3)

CAMU Soil Remediation Project

(RCRA-Equivalent Test Plots) 3,411 3,931 0 Note (3)

CAMU Soil Remediation Project

(North Access Control Area) 13,744 16,795 0 Note (3)

Existing (Sanitary) Landfills

Remediation - Section 1 10,308 11,930 0 58-59

Misc. Southem Tier Soils (SSA2a) 5,268 5,919 0 56-57

Misc. Southern Tier Soils

(Fisherman's Parking Lot) 4,015 4,367 0 60

Secondary Basins Soil

Remediation Project 19,758 23,558 0 1-23

Section 35 Soil Remediation 29,222 36,781 0 1-23

Existing (Sanitary) Landfills

Remediation - Section 36 2,637 3,125 0 46

North Plants Structures Demolition

and Removal (Chemical Sewer) NA 4,316 0 Note (4)

South Plants Soil Remediation

(Phase II) (Outside BA 11

Boundary) 6,271 6,473 0 56-57

Section 36 BOA 41,299 57,921 0 62-68

CAMU Soil Remediation Project

(ELF Construction Project -

Section 25) 2,995 3,222 0 61

Subtotal NA 34 X0 NA 432,922 0

Total 1,354,592 1,583,035 T- 2,504 1,502,574 328,664

Notes:

(1) Approximately 68,192 bcy of soil from BA 9C was redesignated as 'clean' based on sample results.

(2) Refer to Section 1.6 for Boundary Refinements

(3) Survey documented in the CAMU soil removal CCR (MK 1998b) (Ref. Table 8.2- 1)

(4) Survey documented in the North Plants Structures Demolition CCR (TtFW 2004h)
Table 8.2-1: RER Soil Project Records and Documentation

Fli%iorityl Scmrces and Subcontractor inspection Date Rerords Review DaTteSurvey PrDýect Fi[e Lcc;ation

lmpýementation Pro)ect

Borrow Area 3

Buried M-1 Pits Soil Rernediation Geo-Con I-Nov-01 22-Jan-02 Basin A - 20.4.3.1

Basin A and HWL Operations Envirocon Jan-02 9-Apr-03 Basin A - 20.4.3.1

Secondary Basins (Part 2) Soil Rernediation (north) Weston 26-Feb-03 29-Jul-03 SBSRP-1 1.11.7

Secton 35 Soil Rernediation (haul road) Weston 26-Feb-03 29-Jul-03 S35-11.11.7

Section 35 Soil Rernediation (sewer in Causbc Basin) Weston 26-Feb-03 29-Jul-03 S35-11.11.7

Basin A and HWL Operations Envirocon Nov-03 22-Jun-04 Basin A - 20.4.3.5

Borrow Area 4

Basin F Gradefill TBO TBD TBID TBD

Basin F Rernediation (RCRA-Equivalent Cover) TBD TBD TBID TBD

Borrow Area 5

CAMU Soil Remediation Nielson's 16-Dec-99 20-Jan-00 CAMU -10.2.1.2.19 - 28

Miscellaneous RMA Structures Dernolibon (Phase 11)' Envirocon, ECC 2-Mar-05 1 MS - 11.11.7

Borrow Area 6

CAMU Soil Rernediation Nielson' s 16-Dec-99 20-Jan-00 CAMU -10.2.1.2.19 - 28

North Plants Structures &rnolition Envirocon, ECC 4-Jun-03 12-Nov-03 NPD-1 1.11.8

Basin A and HWL Operations Envirocon Sep-03 22-Jun-D4 Basin A - 20.4.4.1

Borrow Area 7A

CAMU Soil Remediation Nielson's 16-Dec-99 20-Jan-00 CAMU .10.2.1.2.19 - 28

North Plants Structures Dernollbon Envirocon, IT 4-Jun-03 12-Nov-03 NPD-1 1.11.8

Basin A and HWL Operations Envirocon Jan-04 3-Mar-05 Basin A - 20.4.1.2

Borrow Area 7B

Existing (Sanitary) Landfills Rernediation - Section 36 ECC 26-Aug-03 18-N.v-03 ESL36-11.11.7

Basin A and HWL Operations Envirocon IT TBD TBE TBD

Borrow Area 8

Basin A and HWL Operations Envirocon Jun-04 3-Mar-05 Basin A - 20.4.5.1

Borrow Area SA

Basin A Operations (Parcel 1) Weston, West Hazmat Jun-03 3-Mar-05 Basin A - 20.4.9.1

Miscellaneous RMA Structures Demolition (Phase 11) (Parcel 3) Envirocon 2-Mar-05 19-Apr-05 MS - 11.11.7

Section 36 BOA (Parcel 3) Envirocon Dec-134 16-Aug-05 S36BOAS 11.5.2.17

Basin A Subgrade (Parcels 2) TBD TBID TBD TBD

Basin A Subgrade (Parcels 4) Envirocon TBD TBD BASG - 11. 13.3

Borrow Area 9C

Basin A Subgrade Envirocon Jul-05 18-J:n-06 BASG -11.13.3

Section 36 BOA Enviroc Jul-( 18-J n-06 S36BOA - 11.13.3

Borrow Area 11

Sou th Plants Soil Remed-iation (Phase 11) URS 4-Jun-03 11 -Sep-03 SPSP2-24.0

Borrow Area 12

CAMU Soil Rernediation Nielson's 164)ec-99 20-Jan-00 CAMU -10.2.1.2.19 - 28

Tables-8(1).2_1_Projecý_Records-and-Document4on-Revised I of 2
Table 8.2-1: RER Soil Project Records and Documentation

Priority 1 SDUrces and Subcontraclor Inspection Date Records Review Date Survey Project File Lcaaýon

nrplernen.ýation Pnzteýt

PI Soil Stockpiles

1 stockpile west of North Plants Haul Road Envirocon 4-Jun-03 12-Nov-03 NPD-1 1.11.8

3 stockpiles in BA 9C Envirocon Jan-03 18-Jan-D6 S36BOAS 11.5.2.17

1 stockpile in BA 9A east of North Plants Haul Road TBD TBD TBD TBD

Project P1 Soil Remedlation

CAMU Soil Remediation Project Nielson's 16-Dec-99 20-Jan-00 CAMU -10.2.1.2.19 - 28

CAMU Soil Remediation Project (RCRA-Equivalent Test Plots) Nielson's 16-Dec-99 20-Jan-00 CAMU -10.2.1.2.19 - 28

CAMU Soil Remediation Project (North Access Control Area) Nielson's 116-Dec-99 20-Jan-00 CAMU -10.2.1.2.19 - 28

Existing (Sanitary) Landfills Remediation - Section 1 ECC 20-Sep-99 14-Jan-00 ESI-011-11 1.01

Misc. Southern Tier Soils (SSA-2a) Nielson's 7-Oct-99 29-Sep-99 MSTSR-1 1.5.1 and 8.10

Misc. Southern Tier Soils (Fisherman's Parking Lot) Nielson's 7-Oct-99 29-Sep-99 MSTSR-11 1.5.2.6

CAMU Soils Remediation Nielson's 16-Dec-99 20-Jan-00 CAMU -10.2.1.2.19 - 28

Secondary Basins Soil Remediation Project Weston, ECC 12-Sep-01 9-Jan-02 SBSRP-1 1.11.7

Section 35 Soil'Remediation Weston 26-Feb-03 29-Jul-03 S35-11.11.7

Existing (Sanitary) Landfills Remediation - Section 36 ECC 26-Aug-03 18-Nov-03 ESL36-11.11.7

North Plants Sýuctures Demolition (Chemical Sewer) Envirocon, ECC 4-Jun-03 12-Nov-03 NPD-11 1. 11.8

South Plants Soil Remediation (Phase 11) (Outside BA 11 Boundary) URS 4-Jun-03 11 -Sep-03 SPSP2-24.0

CAMU Soil Remediation Project (ELF Construction Project - Section 25) Nielson's 3-Aug-03 25-Jan-05 Basin A - 20.4.8.2

Section 36 BOA Envirocon 12-Apr-05 18-Jan-06 S36BOA - 11. 13.3

TRER Soil Remedlation

1 SE-4 (MISTS Deep Acute) Envirocon 12-Nov-04 18-Jan-06 MISTS - 11.13.3

6NW-3 (South Plants [Phase 111) URS Jun-03 1 1-Sep-03 SPSP2-24.0

26SE-7 (Basin F Exterior) Envirocon Jan-03 13-May-03 BFE-11.5.2.14

26SW-1 (Basin A) Envirocon NA 3-Mar-05 Basin A .20.4.3.5

26WC-2 (Basin A) Envirocon NA 3-Mar-05 Basin A - 20.4.3.5

31EC-1 (Basin A) Envirocon NA 3-Mar-05 Basin A - 20.4.2.2

31EC-2 (Basin A) Envirocon NA 3-Mar-05 Basin A - 20.4.2.2

35SE-1 (Section 35) Weston 26-Feb-03 29-Jul-03 S35-11.11.7

36EC-1 (Basin A) Envirocon NA 3-Mar-05 Basin A - 20.4.1.2

36NE-3 (Basin A) Envirocon NA 3-Mar-05 Basin A - 20.4.1.2

P1 = Priority 1, CAT = Complex Army Trenches, CAMU Corrective Action Management Unit, BOA Balance of Areas

Note: Refer to Appendix H for Complete Survey Data

Tables-8(l).2_1 _Project_Records-and-Docuinentadon_Revised 2 of 2
APPENDIX H - Pl SOIL SURVEY DATA COMPACT DISC INDEX

(RESIDUAL ECOLOGICAL RISK SOIL REMEDIATION PART 1 (FINAL)

CONSTRUCTION COMPLETION REPORT (CCR), REVISION 0)

Author(s): TETRA TECH EC, INC

Date: 03/27/2006

THIS DOCUMENT IS A CD-ROM.

DATA HAS BEEN COPIED TO IMGSRV. TO VIEW THIS DATA PLEASE SEE THE

IMAGING ADMINISTRATOR OR IMAGING MANAGER.

IIIIIIIIIIIIIIIIIII III 00042586 15207 4
Borrow Area / or Section

Survey 

File No. Associated Pre/Post Excavation Files Design Boundary Files Soil Type

Borrow Area 3 and Section 35 1 2a_HH3.xls SECT 35 P1 BOUNDARY.xls P1

2 0203 BA 3 So Far in support of CCRs.CSV

3 Addl P1 Sec 35.xls

4 BA-3 Post ex.xls

5 CADD 012403 Borrow 3 Central P1 Removal Sub 075.xls

6 CADD 031125 BA-3 North P1 soil removal Sub 080.xls

7 CADD 031203 Borrow Area 3 Central P1 Removal Sub 075.xls

8 CADD 040303 Borrow 3 Central P1 Removal Sub 075.xls

9 CADD 050503 Borrow 3 Central P1 Removal Sub 075.xls

10 CADD 052703 Borrow 3 Central P1 Removal Sub 075.xls

11 CADD 083002 Borrow 3 South P1 Removal Sub 072.xls

12 CADD 111202 Borrow 3 South P1 Removal Sub 073.xls

13 NCSA-2a #3 11-18-02 (REV. 1).xls

14 North Central P1.xls

15 P1 Offsets.xls

16 Sec 35 NE P1.xls

17 SEC 35 P1 East.xls

18 SEC 35 P1 South East.xls

19 Sec 35 Surf Biota #1.xls

20 Sec 35 Surf Biota #2.xls

21 Sec 35 Surf Biota #4a.xls

22 m1-pits-pre and post.xls

23 Sec Bas P1 Rev 1.xls

Borrow Area 5 24 836.xls BA5-P1 DESIGN BOUNDARY.xls P1

Borrow Area 6 25 BA-6 Post-HSI.xls P1-BA6-BOUNDARY.xls P1

26 P1BA-6.xls

27 BA6-SUPPLEMENT-EXCAV-DATA.xls

Borrow Area 7A 28 020201 Borrow 7A Interim P1 Removal Sub 046.xls P1-BA7A-BOUNDARY.xls P1

29 031501 Borrow 7A Interim P1 Removal Sub 047.xls

30 040302 Borrow 7A Interim P1 Removal Sub 066.xls

31 092501 Borrow 7A Interim P1 Removal Sub 054.xls

32 102201 Borrow 7A Interim P1 Removal Sub 060.xls

33 CADD 033103 Borrow 7A Interim P1 Removal Sub 062.xls

34 CADD 041001 Borrow 7A Interim Post Excavation Sub 050.xls

35 CADD BA-7 Post P1 Survey Report Sub.87A.xls

36 CADD 050902 Borrow 7A Post Excavation Sub 070.xls

37 CADD 071900 Borrow 7A Interim Post Excavation Sub 040.xls

38 0206 BA 7a & b in support of CCRs.CSV

39 0209 BA 7a &b Adds in support of CCRs.CSV

40 CADD BA-7Apost Sub 093.xls
Borrow Area / or Section

Survey 

File No. Associated Pre/Post Excavation Files Design Boundary Files Soil Type

41 suppl-pre-ba7a.xls

Borrow Area 7B EAST 42 7BEAST Pre and Post Excavation Reports.xls P1-BA7Be-BOUNDARY.xls P1

43 0206 BA 7a & b in support of CCRs.CSV

44 0209 BA 7a &b Adds in support of CCRs.CSV

Borrow Area 7B WEST 45 7BWEST Pre and Post Excavation Reports.xls P1-BA7Bw-BOUNDARY.xls P1

P1-STRIP-7B-E&W 46 ESL SECT 36 B1& P1-1.xls P1-BA7B-E-W-STRIP-BOUNDARY.xls P1

Borrow Area 8 47 BA-8_post Sub091.xls P1-BA8-BOUNDARY.xls P1

Borrow Area 9A 48 9A P4 POST.XLS P1-BA9A-BOUNDARY.xls P1

49 080403 Complete Post.xls

50 BA 9A P3 (Pre and Post Ex Report).xls

51 CADD030804 BA9A P1 Soil Removal.xls

Borrow Area 9C 52 BA_9C_Post2.XLS P1-BA9C-BOUNDARY.xls P1

Borrow Area 9C Misc. 53 793.xls BA9CMISC-DESIGN BOUNDARY.xls P1

54 794.xls

55 795.xls

Borrow Area 11 56 Borrow11 Report.xls P1-BA11-BOUNDARY.xls P1

57 0207 BA 11 in support of CCRs.CSV

Borrow Area 12 (HWL) P1

ESL-SECT 1 58 ESL1-Calc_Data.xls ESL-SECT1-BOUNDARY.xls P1

59 SSA2AP11.xls SSA2A P1-1.xls P1

FISHERMAN's Parking Lot 60 FISHERPOST.xls FISHERMAN-BOUNDARY.xls P1

P1-ALONG ELF FENCE 61 SECTION 25 P1-REMOVAL-ELF-FENCELINE.xls P1 ALONG ELF FENCE-BOUNDARY.xls P1

P1 in Section 36 East 62 Zone C3 report.xls SECT36-EAST-BOUNDARY.xls P1

63 Zone C4 report.xls

64 Zone E Report.xls

P1 In Section 36 North 65 Zone C2 report.xls SECT36-NORTH-BOUNDARY.xls P1

66 Zone C6 report.xls P1

P1 in Section 36 West 67 Zone A1.xls SECT36-WEST-BOUNDARY.xls P1

Excavation documented in the CAMU soil removal CCR by MK 1998b (REF. TABLE 8.2-1)
Borrow Area / or Section

Survey 

File No. Associated Pre/Post Excavation Files Design Boundary Files Soil Type

68 Zone C-1(North) report.xls P1

P1 in RCRA EQ. Test Plots P1

P1 in North Access Control Area P1

North Plants Structure Demolition (Chem 

Sewer Removal) P1

P1 within the CAMU boundary P1

1SE-4 69 1SE-4TRER-post-101204.xls 1SE-4-BOUNDARY.xls TRER

70 1SE-4TRER-post and backfill-111004.xls

6NW-3 71 TRER

24SW-1 72 Borrow-5 P2 and Topsoil Removal Verification.xls 24SW-1-DESIGN BOUNDARY.xls TRER

26SW-1 73 CADD BA-3_26SWpost Sub 094.xls 26SW-1-DESIGN BOUNDARY.xls TRER

26WC-2 74 CADD BA-3_26SWpost Sub 094.xls 26wc-2-design boundary.xls TRER

26SE-7 Excavation documented in Basin F Exterior Soil Remediation part 1 CCR TRER

31EC-1&2 75 BA-10_post 060704 Sub092.xls 31EC-1-2-BOUNDARY.xls TRER

35SE-1 76 TRER

36EC-1 77 BA-9B_36EC-1post Sub 095.xls 36EC-1-DESIGN BOUNDARY.xls TRER

36NE-3 TRER

Excavation documented in P1 Section 35 

Excavation documented in the CAMU soil removal CCR by MK 1998b (REF. TABLE 8.2-1)

Western area Excavation documented in Borrow area 7a 

Excavation documented in Borrow Area 11

Excavation documented in the CAMU soil removal CCR by MK 1998b (REF. TABLE 8.2-1)

Excavation documented in the CAMU soil removal CCR by MK 1998b (REF. TABLE 8.2-1)

Excavation documented in the North Plants Structure Demolition CCR