ROCKY MOUNTAIN ARSENAL

CONSTRUCTION COMPLETION REPORT

CHEMICAL PROCESS RELATED ACTIVITIES

FREE STANDING TANK REMOVAL

OUTSIDE PIPELINE AND EQUIPMENT REMOVAL

SEPTEMBER 1998

Prepared by:

Rocky Mountain Arsenal Remediation Venture Office

Department of the Army

Shell Oil Company

U.S. Fish and Wildlife Service

3900-1/1-A

00012070
Construction Completion Report

Chemical Process Related Activities

Free Standing Tank Removal

Outside Pipeline and Equipment Removal

Table of Contents

1.0 Introduction ............................................................ 1

2.0 Chronology of events .................................................... 4

3.0 Perfon-nance standards and cleanup goals met ................................. 5

4.0 Quality assurance/quality control (QA/QC) & Health and Safety (H&S) procedures ... 5

5.0 Description of Construction Activities ....................................... 6

6.0 Description of Project Modifications ......................................... 6

7.0 Construction QA and H&S Documentation ................................... 7

8.0 Final Inspection ......................................................... 7

9.0 0 & M Requirem ents ..................................................... 7

10.0 Summ ary of Project Costs ................................................. 7

11.0 D ocum entation .......................................................... 7

12.0 Certification that the remedy is operational and fimctional ........................ 8

13.0 R eferences ............................................................. 8
Construction Completion Report

Chemical Process Related Activities

Free Standing Tank Removal

Outside Pipeline and Equipment Removal

1.0 Introduction

The activity covered by this completion report was a part of the work carried out as Interim

Response Actions prior to signing of the Record of Decision (ROD). The work is in preparation

for the demolition of South Plants structures.

RMA occupies more than 17,000 acres (approximately 27 square miles) in Adams County,

directly northeast of metropolitan Denver, Colorado. The property was purchased by the US

government in 1942. The RMA was established in 1942 to manufacture and assemble chemical

and incendiary munitions for World War 11. During the Korean Conflict, RNIA manufactured

white phosphorus filled munitions and incendiary cluster bombs. Starting in 1953, RMA

produced the nerve agent GB (isopropyl methylphosphonofluoridate) until late 1957. After 1970,

the primary mission of RMA was the disposal of chemical warfare material. The current mission

of RMA is contamination cleanup. There is no longer an operational mission.

In addition to these military activities, major portions of the plant facilities were leased to private

industries, including Shell Oil Company, between 1947 and 1982, for the manufacture of various

insecticides and herbicides.

The RMA site was proposed to be added to the National Priorities List (NPL) in 1984 and

formally designated as a Superfimd site in July 1987. Interim Response Actions were directed at

mitigation of contamination sources and potential contamination sources associated with

chemical production on RMA. A Record of Decision was entered in June 1996 that incorporated

the continuation of these IRA's as Remedial Actions.

Removal of the pipelines, associated tanks and process equipment addressed in this construction

completion report is called out in the Record of Decision as completion of equipment removals.

Previous activities of this nature were carried out under the Chemical Process Related Activities,

Free Standing Tank Removal, Interim Response Action.

During shutdown activities in 1980 - 1982, the equipment used in operating processes were

drained, rinsed with decontaminating solutions and water, then drained again. The pipelines,

tanks and process equipment, were all inactive and their contents had been previously removed.

Experience has shown that the shutdown efforts were generally effective in removing the process

residues from equipment but that small amounts of products, precursors, constituents and decon

fluids were present.

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2.0 Chronology of Events

In February 1989, the U.S. Environmental Protection Agency (EPA), the Department of the

Army, the Department of the Interior, the Agency for Toxic Substances and Disease Registry

(ATSDR), Department of Justice (DOJ), and Shell Oil Company entered into a Federal Facility

Agreement (FFA) which established procedures for implementing the Rocky Mountain Arsenal

(RMA) cleanup program as specified in the Technical Program Plan. The FFA also incorporated

many provisions of the modified proposed Consent Decree issued June 7, 1988. The Army and

Shell Oil Company shared responsibility for the various costs of the remediation to be developed

and performed under the oversight of the EPA, with participation by the State of Colorado. The

FFA specified 13 Interim Response Actions (IRAs) determined to be necessary and appropriate

while studies for selection of the final remedy were ongoing.

In September 199 1, the U.S. Department of the Army issued the Final Decision Document for the

Chemical Process-Related Activities IRA. This document addressed the sampling,

decontamination and removal of equipment and piping and ancillary equipment in several

buildings used to produce chemical agents. Storage yards and one-ton containers used to store

chemical agents were also addressed.

In 1992, the Army determined that extending the IRA activities to non-chemical agent related

buildings and salvage yards would support and expedite final remediation. These facilities,

located primarily in the South Plants Area of RMA, were used to produce munitions and

chemicals. To address this change in scope, the Army issued the Final Explanation of Significant

Differences (Program Manager for Rocky Mountain Arsenal (PMRMA), 1992). The

Explanation of Significant Differences document addressed the activities to be performed that

would allow removal of the non-agent chemical process piping and equipment in the South

Plants Area. It described the background and information leading to differences in the applicable

or relevant and appropriate requirements (ARARs), health risk assessment considerations, and

scope arising from expansion of the Chemical Process-Related Activities Interim Response

Action (CPRA IRA).

The Final Implementation Letter for for the Chemical Process Related Activities, Interim

Response Action (IRA), Free Standing Tank Removal (DOA, 1993), was issued in October 1993

and covers the work effort for demolition of above ground storage tanks in the South Plants area

at RMA under the CPRA IRA. The document was prepared in accordance with requirements set

forth in the Final Explanation of Significant Difference (ESD) for the CPRA IRA.

3.0 Performance Standards and Cleanup Goals Met

The scope of the work included the characterization and disposal of Aboveground Storage Tanks

(AST) residuals, decontamination and salvage of ASTs and project documentation. The goals

addressed and accomplished were to remove potential sources of hazardous contaminants and to

prepare the South Plants area for demolition without exposing workers or the public to hazardous

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releases. The project objectives included:

0 Tank Survey.

0 Sampling and characterization of tank contents.

0 Removing tank contents.

0 Purging tank contents.

0 Disconnection of piping and ancillary equipment.

0 Tank exterior cleaning.

0 Tank interior cleaning.

0 Tank removal for demolition.

0 Waste management.

a Documentation.

Pipelines and tanks designated for demolition were monitored for hazardous atmospheres and

for any residues. Residual sludges were removed from the pipelines and tanks before any

cleaning or demolition. Residues were transfered to drums.

Tank condition was determined by a final visual inspection prior to release for recycle. All metal

was sent for recycle. Non-recyclable material was rinsed and stored in a bermed area of Tank

Farm TF0105 for eventual disposal in the on-post Hazardous Waste Landfill.

4.0 Quality Assurance /Quality Control (QA/QC) & Health and Safety (H&S)

Procedures

The QA/QC and H&S Procedures were implemented to assure compliance with the goal of

preventing exposures to hazardous releases.

Quality Assurance was required in the area of documenting that the tanks had been destroyed

and the metal had been recycled by melting. The Morrison Knudsen Quality Assurance Project

Plan (QAPjP), Rocky Mountain Arsenal, September 5, 1997 was followed as a procedure.

Verification was completed to assure the appropriate certifications and letters were produced.

The following design specifications cover the removal and recycling/disposal of Shell only

tanks, ancillary equipment, and piping for South Plants at the RMA:

Spec.# 02051, Tank Clearance and Demolition / South Plants

(Rev. 1, Oct-95), (Rev.4, Dec-95)

Spec.# 02051, Equipment Clearance and Demolition / South Plants

(Rev. 6, Aug.-96)

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According to each of the above specifications, Section 1.9 "QUALITY ASSURANCE" requires

the following documentation for Tanks which have been destroyed:

A Certificate of Destruction for any tanks which have been demolished.

A Certificate of Recycle/Reclarnation to show that the tank debris or salvaged

materials were not reused prior to melting.

Additional requirements regarding worker protection and the protection of the environment were

addressed in the Task Specific Health and Safety Plan and the N4K Waste Management Plan

respectively.

A Task Specific Health and Safety Plan (TSHSP) was prepared for the work to be perforined.

The TSHSP addressed site-specific considerations for tank characterization and demolition

activities and augmented the Site Health and Safety Plan (SHSP). The TSHSP used was the Task

Specific Health and Safety Plan for South Plants Above-Ground Tank Removal and Associated

Activities May 6, 1996. The SHSP used was the Site Health and Safety Plan, Morrison Knudsen

environmental Srevices, Rocky Mountain Arsenal Project Site Health and Safety Plan. July 1996

5.0 Description of Construction Activities

5.1 Technical Approach

The most important consideration throughout all aspects of the activities performed was

the safety and health of all on-site personnel and the surrounding community. Each

removal site involved unique health and safety considerations. Therefore, a Task

Specific Health and Safety Plan (TSHSP) was prepared for the work to be performed.

The TSHSP addressed site-specific considerations for tank characterization and

demolition activities and augmented the Site Health and Safety Plan (SHSP).

5.2 General Work Tasks

This work required the characterization of pipelines and tank interiors, cleaning of the

tank interiors, transportation of liquid wastes to an on-site treatment system,

transportation of drummed wastes to a on-site storage area, and demolition of pipelines

and tanks. Recyclable materials were transported to the salvage container location.

5.2.1 Pipeline and Tank Clearance

Pipelines and tanks designated for demolition were monitored for hazardous

atmospheres and for any residues. Residual sludges were removed from the

pipelines and tanks before any cleaning or demolition. Residues were transferred

to drums.

5.2.2 Pipe and Equipment Removal

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Pipelines and tanks were rinsed and then removed by a combination hot and cold

cutting methods. Pipe supports and equipment (pumps, valves, etc.) were rinsed

and moved to recycle receptacles. Associated piping penetrating a structure was

removed up to the structure and capped or screened at that point.

Any material considered to be non-recyclable but not considered construction

debris or clean trash was cleaned by rinsing with hot water and consolidated in

Tank Farm TF0105 as designated in the revised implementation document.

5.2.3 Final Rinse Tanks

Tank exteriors were rinsed using high pressure wash. Tank interiors were triple

rinsed and rinse water was collected for transfer to the CERCLA treatment

plant. Samples were retrieved for characterization analysis prior to treatment at

the CERCLA treatment plant.

During internal cleaning of the tanks, no deleterious material was allowed to

leach, run-off, percolate or in any way be harmful to the environment.

Residuals and solvent rinsate that could not be recycled was contained in

specified tanks or drums for eventual transfer to the CERCLA Treatment Plant

if parameters were within acceptance criteria. Materials that were not within

acceptance criteria for the CERCLA Plant were moved to the long term storage

warehouse as defined in the Waste Management Plan.

5.2.4 Demolish Tanks

Tanks and ancillary pipelines were cut to a maximum size that was most

efficient based on transport container restraints. Smaller tanks were cut into at

least two pieces. A certificate of destruction was created and filed in the project

file to document each tank's demolition/destruction.

Salvageable materials were collected in transportation containers provided by

the salvage subcontractor and temporarily stored at the work site.

5.2.5 Salvage of Recyclable Metals

All metals from the demolition of the pipelines and tanks was removed for

recycle. The salvage subcontractor issued a letter that documented the melting of

recyclable metals (e.g, tanks and pipeline metals). The letter included a list of

all load numbers that were processed that month and stated the type and

quantity of materials, source origination, method of disposition, and date of

disposition.

5.2.6 Transportation of Waste Materials

Waste materials were not allowed to accumulate at the tank demolition sites.

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Liquid wastes to be treated at the on-site facility were transported to the

temporary storage facility at the end of each working day. Wastes collected in

55 gallon drums or other containers intended for long term storage were

temporarily stored at a designated area of the work site until transported to the

long term storage warehouse as defined in the Waste Management Plan.

Non-hazardous wastes, such as construction debris and other non-hazardous

waste were deposited in a waste dumpster or other suitable disposal containers.

Potentially hazardous waste, such as disposable Personal Protective Equipment

(PPE) was deposited in drums for transport to the long term storage warehouse.

5.3 General Requirements

Laboratory testing was performed as necessary for characterization, during the removal

work. Samples of rinse water and any sludges were taken as required by the Waste

Management Plan.

Temporary storage tanks were protected with a secondary containment which was either

an existing concrete berm or plastic lined berm

Efforts were made to preserve and protect all structures, equipment and vegetation

(such as trees, shrubs and grass) on or adjacent to the work site, which was not to be

removed and which did not unreasonably interfere with the work. All existing

monitoring wells, improvements and utilities at or near the work site were protected.

6.0 Description of Project Modifications

The portion of the work completed since the ROD is defined further by a series of letters

(enclosed) that were written to modify the details of the original Implementation Letter:

May 4, 1995 Army letter transmitting Shell intent to remove tanks.

May 31, 1995 CDPHE comments on Shell proposal.

June 1, 1995 EPA Comments On Shell proposal.

June 28, 1995 Army letter forwarding responses to comments.

June 19, 1996 Army letter transmitting Shell intent to continue activities.

July 10, 1996 CDPHE request for information on continuation.

July 18, 1996 EPA requests meeting prior to continuation.

August 23, 1996 Army letter defining continuation.

September 11, 1996 Army letter transmitting Shell responses to CDPHE comments.

September 17, 1996 CDPHE agrees with continuation.

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7.0 Construction QA and H&S Documentation

Specifications for this work required the following documentation for Tanks which had been

destroyed:

A Certificate of Destruction for any tanks which have been demolished.

A Certificate of Recycle/Reclamation to show that the tank debris or salvaged

materials were not reused prior to melting.

Verification was completed to assure the appropriate certifications and letters were produced.

A log sheet for tracking purposes was established for each scope of work. The logsheets

summarize the dates and associated load numbers (i.e., for transporting and recycling) of

salvageable metal. Upon project closeout, the logsheet was reviewed to verify that logsheet

entries matched up with the documentation received from the salvage/recycling companies. No

other QA/QC requirements were associated with this task.

Construction H&S documentation is recorded in the Health and Safety log books and filed in the

Morrison Knudsen health and safety files. Monitoring readings PPE requirements and general

safety notations are included.

8.0 Final Inspection

The final inspection was conducted on March 12, 1998. This inspection consisted of a drive

through tour of the South Plants area including all areas of the tank and pipeline removals. The

tour was attended by: Kerry Guy (EPA), Mark Kadnuck (CDPHE), Anthony LaChance (RVO),

Dave Vincelette (RVO) and Joe Smith (Shell/MK). There were no outstanding items required for

completion. The attached photos show before and after conditions in some of the areas of the

South Plants.

9.0 0 & M Requirements

Due to the nature of the project, there is no operation and only minimal maintenance associated

with this activity. The storage area in TFO 105 for non-recyclable materials as defined in the

modifications letter dated June 28, 1995 will be monitored until placement in the on-site

Hazardous Waste Landfill.

10.0 Summary of Project Costs

The original scope and additional work outlined in the June 19, 1996 letter from the Army was

completed including 120 tanks and 240,000 feet of pipelines. During the demolition of these

tanks and pipelines 3000 tons of metal were recycled. The project cost through completion was

approximately $2,100,000.

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11.0 Documentation

Morrison Knudsen project specific files are maintained in Rocky Mountain Arsenal Building 132

Associated records generated under this scope of work include, but are not limited to the

following:

Weigh Scale Tickets for Truckloads/Roll-offs.

Drawings or Maps Associated with The Scope of Work.

Tank Clearance Checklist. (Where applicable)

Pipe Clearance Checklist. (Where applicable)

Field Logbooks. (Both Health and Safety, and Waste Management)

Training Records. (Health and Safety, Task Specific, and Waste Management)

Daily Field Reports/Construction Reports

Photographs (Before and After - Not required as a QA Item)

A log sheet for tracking purposes was established for each scope of work. The logsheets

summarize the dates and associated load numbers (i.e., for transporting and recycling) of

salvageable metal. Upon project closeout, the logsheet was reviewed to verify that logsheet

entries matched up with the documentation received from the salvage/recycling company.

12.0 Certification That the Remedy is Operational and Functional

The Remediation Venture Office (RVO) has determined that this remedial action has been

completed in accordance with the ROD, has met the intent of the ROD to be protective of human

health and the environment, and complies with the final design package, as modified. No further

action is required.

'o.ft Signed: 1)ykf4:feý Date: 7,8 4r

y -fx-eFc4,h-#;% 0#44jeo13.0 References

US Department of Justice, 1989. Federal Facility Agreement and Settlement Agreement to

Ensure the Continued Cleanup of Rocky Mountain Arsenal. February 17, 1989. Document

Control Number: TES

Department of the Army, 1992. Final Explanation of Significant Differences, Chemical Process

Related Activities, Interim Response Action. November 6, 1992. Document Number: 7760--

028-IN-CLLX.

Department of the Army, 1993. Final Implementation Letter for the Chemical Process Related

Activities, Interim Response Action (IRA), Free Standing Tank Removal. October 15, 1993.

Document Control Number: 7760-040-RT-CXCJ

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Department of the Army, 1995. Final Implementation Letter, Chemical Process Related

Activities, Interim Response Action, Free Standing Tank Removal (Shell-Only). May 4, 1995.

Document Control Number: (Used 3102-036-EP-BGRB)

Department of the Army, 1995. Final Implementation Letter (IL) for the Chemical Process

Related Activities, Free Standing Tank Removal Task - Notification Letter. October 10, 1995.

Document Control Number: 3102-036-IN-BHLZ

Department of the Army, 1996. Record of Decision for the On-Post Operable Unit. June 1996.

Document Control Number: 3102-036-RT-BJFM

Task Specific Health and Safety Plan for South Plants Above-Ground Tank Removal and

Associated Activities. May 6, 1996.

Site Health and Safety Plan, Morrison Knudsen environmental Srevices, Rocky Mountain

Arsenal Project Site Health and Safety Plan. July 1996

Waste Management Plan, Rocky Mountain Arsenal Waste Management Plan. July 1997,

Revision 10.

Morrison Knudsen Quality Assurance Project Plan (QAPjP), Rocky Mountain Arsenal,

September 5, 1997.

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LIST OF ATTACHMENTS

Army letter transmitting Shell intent to remove tanks, May 4, 1995

CDPHE comments on Shell proposal, May 31, 1995

EPA Comments On Shell proposal, June 1, 1995

AiTny letter forwarding responses to comments, June 28, 1995

Army letter transmitting Shell intent to continue activities, June 19, 1996

CDPHE request for information on continuation, July 10, 1996

EPA requests meeting prior to continuation, July 18, 1996

Army letter defting continuation, August 23, 1996

Army letter transmitting Shell responses to CDPHE comments, September 11, 1996

CDPHE agrees with continuation, September 17, 1996

Locations and before and after photos of areas of the South Plants

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