### INTERIM RESPONSE ACTION (IRA) SUMMARY REPORT

Asbestos Remediation

Final

September 2000

Jointlydevelopedandwrittenby the U.S. Environmental Protection Agency, Region 8, 6888-1/1-B andthe U.S.Army, Rocky MountainArsenal 1111111111111111111111111111 00021475

## Interim Response Action Summary Report Asbestos Remediation

Table ofContents
1.0 Introduction ................................................................................................................................ 1 2.0 Background ................................................ ............................................................................... 1 2.1 Investigative Studies.......................... .................................................................2 2.2 Nature andExtent ofContamination .................................................................... 3 2.3 Decision Process ............ .................................. ............................................3 3.0 Work Performed .........................................................................................................................3 4.0 Operations/Monitoring Results ................................................................................................... 4 5.0 S tatus ........ ...............................................................................................................................4 6.0 References ..................................................................- ............... ............................................. 5

Attachments: Figure I - Location ofRocky Mountain Arsenal Table I - Asbestos Removal by Building and Contract

U:\1RA.SUMMARY REPORTS\ASBESTOS.WPD

## Interim Response Action Summary Report Asbestos Remediation September 18, 2000
1.0 Introduction In February 1989, a Federal Facility Agreement (FFA) was entered into between five federal agencies: the Environmental Protection Agency, the Army, theDepartment ofthe Interior, the Department ofHealth and Human Services, and the Department ofJustice, which established procedures for implementing the Arsenal cleanup program as specified in the Technical Plan, and incorporated many provisions ofthe modified proposed consent decree (June 7, 1988). The Army and Shell Oil Company agreed to share certain costs of the remediation to be developed and performed under the oversight ofthe U.S, Environmental Protection Agency, with opportunities forparticipation bythe State of Colorado, The Federal Facility Agreement (EPA et al. 1989) specifies 13 Interim Response Actions (IRA) determined to be necessary and appropriate. Asbestos removal (Section XXII paragraph 22.1 (k)) is one ofthethirteen IRAs. The objectives ofthe Asbestos Removal IPLA are to conduct inspection surveys, sample suspected asbestos-containing materials and asbestos-containing building materials (collectively herein referred to as ACM) andremoval ofACM to protect onsite workers. The Asbestos Removal IRA is regulated under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) in accordance with 40 CFR 61.145. 2.0 Background Rocky Mountain Arsenal OUAA) occupies more than 17,000 acres (approximately 27 square miles) in Adams County, directly northeast ofmetropolitan Denver, Colorado (Figure 1). The property was purchased by the US government in 1942 for use inWorld War IIto manufacture and assemble chemical warfare materials, such as mustard and lewisite, and incendiary munitions. Starting in the 1950's, RMA produced the nerve agent GB (isopropyl methylphosphonofluoridate) until late 1969. A significant amount of chemical warfare materials destruction took place during the 1950s and 1960s. In addition to these military activities, major portions ofthe plant facilities were leased to private industries, including Shell Oil Company, between 1947 and 1982, for the manufacture ofvarious insecticides and herbicides. The RMA site was proposed to the National Priorities List (NPL) in 1984 and formerly designated as a Superfund sitein July 1987.

U;\1RA SUMMARY REPORTS\ASBESTOS.WPD IThe RMA contains a large variety offacilities ranging from a few square feet in area to several thousand square feet. Many ofthe facilities have been abandoned for several years and are in a state ofdeterioration. Facilities such as warehouses are currently being used but are infrequently occupied. Other facilities such as the administration building and the fire station are both currently used and occupied. The majority ofthe facilities are located in the North Plant and South Plant areas. These two areas were used for chemical and munitions manufacturing and processing. Therefore, many ofthe facilities inthe North Plant and South Plant areas are contaminated with hazardous chemicals. In addition to the facilities that were used for chen-dcal and munitions purposes, there are facilities that were used for residence, recreation, utilities, warehousing, and other purposes. Most ofthe early constructed buildings contain appreciable amounts ofACK such as pipe lagging, floor and ceiling tiles, siding and roofing. Since construction ofthe RMA, federal and state statutes have been promulgated that require the inspection, sampling, and removal ofACM prior to demolition ofa building, structure, or pipe run/rack. The purpose ofthis IRA is to document ACM in and on the various facilities at the RMA,in order to ensure its complete removal prior to demolition ofthe facilities (Weston 1991). 2.1 Investigative Studies Several investigations were conducted to locate, identify the type, percentage and quantity ofACM present in and on the various facilities at RMA. During the weeks ofSeptember 14, 1988, through October 6, 1988, personnel from OHM initiated an extensive asbestos sampling and survey program in and around 3 8 buildings on the Rocky Mountain Arsenal in Commerce City, Colorado. During this time, a total of 170 bulk samples and 48 ambient air samples were taken ofsuspected ACM and sent to Analytics Laboratory inRichmond, VA for analysis. This survey showed six building to be free ofACM. In 1990, the Army was interested in demolishing several structures at the Rocky Mountain Arsenal (RMA). The structures were in various states ofdisrepair. Some structures were in very poor condition and constituted a safety hazard to personnel who work in or near the area. Ebasco was requested to locate and identify the type ofACM and percentage of asbestos, and also estimate the quantity ofACM. Ebasco performed an asbestos assessment to determine the extent ofACM in the previously inspected 32 structures that had ACM. During this assessment, a total of137 bulk samples were taken in and around 17 ofthose 32 structures (Ebasco 1991). In 1991, under Task Order 0005 (Task 5) (Contract No. DAAA 15-88-D-0023), Roy F. Weston, Inc., (WESTON) surveyed, sampled, and quantified ACK at the Rocky Mountain Arsenal (Weston 1996). A total of486 structures, 19 miles ofpipe runs and
U:\1RA SUMMARY REPORTS\ASBESTOS.WPD 2more than 15,000 pipe fittings, gaskets, etc., were surveyed. More than 5,000 samples of suspect ACM were collected ofwhich approximately 4,300 were analyzed for asbestos. 2.2 Nature and Extent ofContamination During the OHM asbestos sampling and survey program, 38 buildings were sampled for the presence ofACM. Ofthe 48 ambient air samples, all were below the 0,02 fibers/cc Personnel Exposure Limit (PEL) for asbestos. Ofthe 170 bulk samples taken, 90 samples were confirmed to contain asbestos ofI percent or greater. Recommendations were made forthe removal ofACM of 1percent orgreater, based onlab analysis. In 1990, Ebasco investigated 32 structures atRMA for ACM. ACMwas found in all of the 32 structures investigated in this survey (Ebasco 1991). Under Task 005 Roy F. Weston Inc. found ACM in 304 buildings, 17 miles ofpipe lagging and approximately 12,500 pipe fittings and gaskets. 2.3 Decision Process Asbestos removal was identified inthe FFA (EPA et al. 1989) as a contaminant source requiring an IRA. Asbestos removal did not follow thetypical alternatives assessment, decision document, implementation document process since its removal is federally regulated under 40 CFR 61.145. Their was no Final Implementation Document and no total estimated cost developed forthis IRA. 3.0 Work Performed OHM conducted asbestos abatement activities between April 17, and June 30, 1989. During this time, abatement was conducted on 10 ofthe 38buildings (I11, 213, 321 D, 342, 344, 345, 624, 728, 732, and 741) identified as containing ACM during the sampling and survey program. A total ofapproximately 4,900 linear feet ofACM pipe lagging and 5 cubic yards ofhot water tank insulation were removed, double bagged and drummed for disposal. Approximately 6,500 square feet oftransite sheet were removed, double wrapped and pallatized for disposal. Clearance samples were taken and walk-through inspections were conducted before final releases ofthe buildings were approved. Clearance air sampling was conducted in each building and the clearance standard of0.01 fibers per cubic centimeter (F/CQ was either met or surpassed. All work was conducted according to OHM's Technical Planwith the exception ofthe disposal ofthe ACM. The originally planned disposal site (Lowry Landfill) was not used because ofuncertainties concerning the integrity ofsome ofthewaste cells at that site.

U:\1RA SUMMARY REPORTS\ASBESTOS.WPD 3The USPCI disposal facility at Grassy Mountain, Utah, which had been used previously for RMA waste, was chosen as the disposal site forthe ACM fromthis project (OHM 1989). From 1990 until June 11, 1996, approximately 150 buildings/structures have undergone asbestos removal abatement and encapsulation work. These buildings were identified as containing ACM during the asbestos surveys conducted by Ebasco, Weston andRMA employees. Atotal ofapproximately 3215 tons of ACK personal protection equipment, containment plastic sheet material and othermaterials contaminated during the ACM removal process have been removed from RMA. A list ofprojects bybuilding and contract number and the amount ofACM removed under each project is at Table 1. The actual cost ofcarrying out the asbestos removal was approximately $30 million. 4.0 Operations/Monitoring Results Ongoing operations and subsequent monitoring were not required after the completion of asbestos abatement at any ofthe structures abated. 5.0 Status The Asbestos Removal RMA was considered completed at the signing ofthe On-Post ROD on June 11, 1996. Other ACM removal work still ongoing as part ofthe demolition ofstructures under ROD Implementation Projects are not covered by this report and will be covered by separate Construction Completion Reports. Transite siding, which is non-friable until broken, is being removed from South Plants and Logistics Area structures prior to and concurrent with their demolition.

U:\IRA SUMMARY REPORTS\ASBESTOS.WPD 46.0 References Foster Wheeler Envirom-nental Corporation. 1996 (June). RecordofDecisionforthe OnPostOperableUnit. Ebasco,Services Incorporated. 1991(March). Final Asbestos Survey of 32 Structures (Version 3.1). O.H. Materials Corp. 1989 (January 17). AsbestosSamplingReportfortheRocky Mountain Arsenalin Commerce City,CO. Roy F.Weston, Inc. 1991 (September). FinalTechnical PlanTask005 Surveyof Asbestos Containing MaterialsVersion3.1. Roy F. Weston, Inc. 1992 (April ). Summary andMethodologies Final ReportTask005 Survey of Asbestos Containing Materials attheRocky Mountain Arsenal Version 3.0. U.S. EPA et al. 1989 (February 17). Federal Facility Agreementin theMatterofRocky Mountain Arsenal, U.S. Dept.oftheArmy andShell Oil Company.

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WELD CO. 76
BOULDER GO. 85 BARR LAKE 25

JEFFERSON CO. ROCKY MOUNTAIN ARSENAL 270 L-jif

STAPLETON _j ADAMS 00. AIRPORT 70 DENVER CO. ARAPAHOE CO. C9 225 _j rN ri CHERRY CREEK RESERVOIR

DOUGLAS CO,

3 4 5 Scale in miles Figure Prepared for: LOCATION MAP OF U.S. Army Program Manager's Office ROCKY MOUNTAIN ARSENAL For Rocky Mountain Arsenal Aberdeen Proving Ground, Maryland