### ROCKY MOUNTAIN ARSENAL

CONSTRUCTION COMPLETION REPORT CHEMICAL PROCESS RELATED ACTIVITIES FREE STANDING TANK REMOVAL OUTSIDE PIPELINEAND EQUIPMENT REMOVAL

SEPTEMBER 1998

Prepared by: Rocky Mountain Arsenal Remediation Venture Office Department oftheArmy Shell Oil Company U.S. Fish andWildlife Service

3900-1/1-A

00012070

### Construction Completion Report Chemical Process Related Activities Free Standing Tank Removal Outside Pipeline and Equipment Removal

Table ofContents

1.0 Introduction ............................................................ 1 2.0 Chronology ofevents ....................................................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 ofConstruction Activities ....................................... 6 6.0 Description ofProject Modifications ......................................... 6 7.0 Construction QA and H&S Documentation ................................... 7 8.0 Final Inspection ......................................................... 7 9.0 0 &M Requirements ..................................................... 7 10.0 Summary ofProject Costs ................................................. 7 11.0 Documentation .......................................................... 7 12.0 Certification thattheremedy is operational and fimctional ........................ 8 13.0 References ............................................................. 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 completionreport was apart ofthe workcarried out asInterim Response Actions prior to signing ofthe Record ofDecision (ROD).The workis in preparation forthe demolition ofSouth Plants structures. RMA occupies more than 17,000 acres (approximately 27 square miles) inAdams County, directly northeast ofmetropolitan 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 forWorld War 11. During the Korean Conflict, RNIA manufactured whitephosphorus filled munitions andincendiary cluster bombs. Starting in 1953, RMA produced the nerve agent GB (isopropyl methylphosphonofluoridate) until late 1957. After 1970, the primary mission ofRMA was the disposal ofchemical warfare material. The current mission ofRMA is contamination cleanup. There is no longer an operational mission. In addition tothese military activities, major portions ofthe plant facilities were leased to private industries, including Shell Oil Company, between 1947 and 1982, for themanufacture ofvarious insecticides andherbicides. The RMA site was proposed tobe added totheNational Priorities List (NPL) in 1984 and formally designated as aSuperfimd site inJuly 1987. Interim Response Actions were directed at mitigation ofcontamination sources and potential contamination sources associated with chemical production onRMA. A Record ofDecision was entered inJune 1996 that incorporated the continuation ofthese IRA's as Remedial Actions. Removal ofthe pipelines, associated tanks andprocess equipment addressed inthis construction completion report is called out inthe Record ofDecision as completion ofequipment removals. Previous activities ofthis nature were carried out underthe Chemical Process Related Activities, Free Standing Tank Removal, Interim Response Action. During shutdown activities in 1980 - 1982, the equipment used inoperating processes were drained, rinsed with decontaminating solutions and water, then drained again. Thepipelines, tanks and process equipment,were all inactive and their contents had beenpreviously removed. Experience has shownthatthe shutdown efforts were generally effective inremoving the process residues from equipment butthat small amounts ofproducts, precursors, constituents anddecon fluids werepresent.

12.0 Chronology ofEvents In February 1989, the U.S. Environmental Protection Agency (EPA), the Department ofthe Army, the Department ofthe Interior,the Agency for Toxic Substances and Disease Registry (ATSDR), Department ofJustice (DOJ), and Shell Oil Company entered into aFederal Facility Agreement (FFA) which established procedures for implementing theRocky Mountain Arsenal (RMA) cleanup program as specified in the Technical Program Plan. The FFA also incorporated many provisions ofthe modified proposed Consent Decree issued June 7, 1988. The Army and Shell Oil Company shared responsibility forthe various costs ofthe remediation tobe developed and performed under the oversight oftheEPA, with participation by the State ofColorado. The FFA specified 13 Interim Response Actions (IRAs) determined tobe necessary and appropriate while studies for selection ofthe final remedy were ongoing. In September 1991,the U.S. Department oftheArmy issued the Final Decision Document for the Chemical Process-Related Activities IRA. This document addressed the sampling, decontamination andremoval ofequipment 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 ofRMA, were used to produce munitions and chemicals. To address this change in scope, theArmy issued the Final Explanation ofSignificant Differences (Program Manager for Rocky Mountain Arsenal (PMRMA), 1992). The Explanation ofSignificant Differences document addressed the activities to be performed that would allow removal ofthe 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 fromexpansion ofthe Chemical Process-Related Activities Interim Response Action (CPRA IRA). The Final Implementation Letter for forthe 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 ofabove ground storage tanks in the South Plants area at RMA under the CPRA IRA. The document was prepared in accordance withrequirements set forth in the Final Explanation ofSignificant Difference (ESD) for the CPRA IRA. 3.0 Performance Standards and Cleanup Goals Met The scope ofthe work included the characterization and disposal ofAboveground Storage Tanks (AST) residuals, decontamination and salvage ofASTs andproject documentation. The goals addressed and accomplished were to remove potential sources ofhazardous contaminants andto prepare the South Plants area for demolition without exposing workers orthe public to hazardous

2releases. Theproject objectives included: 0 Tank Survey. 0 Sampling and characterization oftank contents. 0 Removing tank contents. 0 Purging tank contents. 0 Disconnection ofpiping and ancillary equipment. 0 Tank exterior cleaning. 0 Tank interior cleaning. 0 Tank removal for demolition. 0 Wastemanagement. 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 wasdetermined by afinal visual inspection priorto release forrecycle. All metal was sent forrecycle. Non-recyclable material was rinsed and stored in abermed area ofTank Farm TF0105 for eventual disposal inthe on-postHazardous 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 areaofdocumenting thatthe tanks had been destroyed andthe metal hadbeen recycled by melting. The Morrison Knudsen Quality Assurance Project Plan (QAPjP), Rocky Mountain Arsenal, September 5, 1997 was followed as aprocedure. Verification was completed to assure the appropriate certifications andletters were produced. The following design specifications coverthe removal andrecycling/disposal ofShell only tanks, ancillary equipment, andpiping for SouthPlants atthe RMA: Spec.# 02051, Tank Clearance andDemolition / South Plants (Rev. 1,Oct-95), (Rev.4, Dec-95) Spec.# 02051, Equipment Clearance and Demolition / South Plants (Rev. 6, Aug.-96)

3According to each ofthe above specifications, Section 1.9 "QUALITY ASSURANCE" requires the following documentation for Tanks which have been destroyed: A Certificate ofDestruction for any tanks which have been demolished. A Certificate ofRecycle/Reclarnation to show thatthe tank debris or salvaged materials were not reused priorto melting. Additional requirements regarding worker protection and theprotection ofthe environment were addressed in the Task Specific Health and Safety Plan and theN4KWaste Management Plan respectively. A Task Specific Health and Safety Plan (TSHSP) wasprepared for the work to be perforined. The TSHSP addressed site-specific considerations fortank characterization and demolition activities and augmented the Site Health and Safety Plan (SHSP). The TSHSP used wasthe Task Specific Health and Safety Plan for South Plants Above-Ground Tank Removal andAssociated 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 ofConstruction 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 workrequired the characterization ofpipelines and tank interiors, cleaning ofthe tank interiors, transportation of liquid wastes to an on-site treatment system, transportation ofdrummed 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 4Pipelines 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 torecycle receptacles. Associated piping penetrating a structure was removed up to the structure and capped or screened atthat point. Any material considered to be non-recyclable but notconsidered 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 priorto treatment at the CERCLA treatment plant. During internal cleaning ofthe tanks, no deleterious material was allowed to leach, run-off,percolate or in any way be harmful to the environment. Residuals and solvent rinsate thatcould notbe recycled was contained in specified tanks or drums for eventual transfer to the CERCLA Treatment Plant ifparameters werewithin acceptance criteria. Materials that were not within acceptance criteria for the CERCLA Plant were moved to the long term storage warehouse as defined inthe 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 ofdestruction was created and filed in the project file to document each tank's demolition/destruction. Salvageable materials were collected intransportation containers provided by the salvage subcontractor and temporarily stored at the work site. 5.2.5 Salvage ofRecyclable Metals All metals from the demolition ofthe 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 thatmonth and stated the type and quantity ofmaterials, source origination, method ofdisposition, and date of disposition. 5.2.6 Transportation ofWaste Materials Waste materials were not allowed to accumulate at the tank demolition sites. 5Liquid wastes to be treated at the on-site facility were transported to the temporary storage facility at the end ofeach working day. Wastes collected in 55 gallon drums or other containers intended for long term storage were temporarily stored at adesignated area ofthe work site until transported to the long term storage warehouse as defined inthe 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 indrums 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 ofrinse 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 orplastic 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 notunreasonably interfere with the work. All existing monitoring wells, improvements and utilities at or near the work site were protected.

6.0 Description ofProject Modifications The portion ofthe work completed since the ROD is defined further by a series ofletters (enclosed) that werewritten tomodify the details ofthe original Implementation Letter: May 4, 1995 Army letter transmitting Shell intenttoremove 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 lettertransmitting Shell intentto continue activities. July 10, 1996 CDPHErequest for information on continuation. July 18, 1996 EPA requests meeting priorto continuation. August23, 1996 Army letterdefining continuation. September 11, 1996 Army letter transmitting Shell responses to CDPHE comments. September 17, 1996 CDPHE agreeswith continuation.

67.0 Construction QA and H&S Documentation Specifications forthis work required the following documentation for Tanks which hadbeen destroyed: A Certificate ofDestruction for anytanks whichhave been demolished. A Certificate ofRecycle/Reclamation to show that the tankdebris or salvaged materials were not reused priorto melting. Verification was completed to assure the appropriate certifications and letters were produced. A log sheet fortracking purposes was established for each scope of work. The logsheets summarize the dates and associated load numbers (i.e., fortransporting and recycling) of salvageable metal. Uponproject closeout, the logsheet was reviewed toverify that logsheet entries matched up withthe documentation received fromthe salvage/recycling companies. No other QA/QC requirements were associated with this task. Construction H&S documentation is recorded inthe Health and Safety log books and filed inthe Morrison Knudsen health and safety files.Monitoring readings PPE requirements and general safety notations are included. 8.0 FinalInspection The final inspection was conducted on March 12, 1998. This inspection consisted ofadrive through tour ofthe SouthPlants area including all areas ofthe tankand 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 showbefore and afterconditions in some ofthe areas ofthe South Plants. 9.0 0 &MRequirements Due tothe nature ofthe project, there is no operation and only minimal maintenance associated with this activity. The storage area inTFO105 fornon-recyclable materials as defined inthe modifications letter dated June 28, 1995 will bemonitored untilplacement inthe on-site Hazardous Waste Landfill. 10.0 Summary ofProject Costs The original scope and additional work outlined inthe June 19, 1996 letter from theArmy was completed including 120tanks and 240,000 feet ofpipelines. During the demolitionofthese tanks and pipelines 3000 tons ofmetal were recycled. The project cost through completion was approximately $2,100,000.

711.0 Documentation Morrison Knudsen project specific files are maintained in Rocky Mountain Arsenal Building 132 Associated records generated under this scope ofwork include, butare notlimited to the following: Weigh Scale Tickets for Truckloads/Roll-offs. Drawings or Maps Associated withThe Scope ofWork. Tank Clearance Checklist. (Where applicable) Pipe Clearance Checklist. (Where applicable) FieldLogbooks. (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., fortransporting 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 thatthis remedial action has been completed in accordance with the ROD, has met the intent oftheROD to be protective ofhuman 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 ofJustice, 1989. Federal Facility Agreement and Settlement Agreement to Ensure the Continued Cleanup ofRocky Mountain Arsenal. February 17, 1989. Document Control Number: TES Department ofthe Army, 1992. Final Explanation of Significant Differences, Chemical Process Related Activities, Interim Response Action. November 6, 1992. Document Number: 7760-- 028-IN-CLLX. Department ofthe Army, 1993. Final Implementation Letter for the Chemical Process Related Activities, Interim Response Action (IRA), Free Standing TankRemoval. October 15, 1993. Document Control Number: 7760-040-RT-CXCJ

8Department ofthe 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 oftheArmy, 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 ofthe Army, 1996. Record ofDecision forthe On-Post Operable Unit. June 1996. Document Control Number: 3102-036-RT-BJFM Task Specific Health and Safety Plan for SouthPlants 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 MountainArsenal Waste Management Plan. July 1997, Revision 10. Morrison Knudsen Quality Assurance Project Plan (QAPjP), Rocky Mountain Arsenal, September 5, 1997.

9LIST OF ATTACHMENTS Army lettertransmitting 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 letterforwarding responses to comments, June 28, 1995 Army lettertransmitting Shell intentto continue activities, June 19, 1996 CDPHE request for information on continuation, July 10, 1996 EPArequests 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 afterphotos ofareas ofthe South Plants

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