INTERIM RESPONSE ACTION (IRA) SUMMARY REPORT

Asbestos Remediation

Final

September 2000

Jointly developed and written by the

U.S. Environmental Protection Agency, Region 8, 6888-1/1-B

and the U.S. Army, Rocky Mountain Arsenal 1111111111111111111111111111

00021475
Interim Response Action Summary Report

Asbestos Remediation

Table of Contents

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

2.0 Background ................................................ ............................................................................... 1

2.1 Investigative Studies .......................... ................................................................. 2

2.2 Nature and Extent of Contamination .................................................................... 3

2.3 Decision Process ............ .................................. ............................................ 3

3.0 W ork Performed ......................................................................................................................... 3

4.0 Operations/M onitoring Results ................................................................................................... 4

5 .0 S tatu s ........ ............................................................................................................................... 4

6.0 References .................................................................. - ............... ............................................. 5

Attachments:

Figure I - Location of Rocky Mountain Arsenal

Table I - Asbestos Removal by Building and Contract

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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, the Department of the

Interior, the Department of Health and Human Services, and the Department of Justice,

which established procedures for implementing the Arsenal cleanup program as specified

in the Technical Plan, and incorporated many provisions of the 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 of the U. S,

Environmental Protection Agency, with opportunities for participation by the 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 of the thirteen IRAs.

The objectives of the Asbestos Removal IPLA are to conduct inspection surveys, sample

suspected asbestos-containing materials and asbestos-containing building materials

(collectively herein referred to as ACM) and removal of ACM 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 of metropolitan Denver, Colorado

(Figure 1). The property was purchased by the US government in 1942 for use in World

War II to 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 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 the

National Priorities List (NPL) in 1984 and formerly designated as a Superfund site in July

1987.

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The RMA contains a large variety of facilities ranging from a few square feet in area to

several thousand square feet. Many of the facilities have been abandoned for several years

and are in a state of deterioration. 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 of the 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 of the facilities in the 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 of the early constructed buildings contain

appreciable amounts of ACK such as pipe lagging, floor and ceiling tiles, siding and

roofing.

Since construction of the RMA, federal and state statutes have been promulgated that

require the inspection, sampling, and removal of ACM prior to demolition of a building,

structure, or pipe run/rack. The purpose of this IRA is to document ACM in and on the

various facilities at the RMA, in order to ensure its complete removal prior to demolition

of the facilities (Weston 1991).

2.1 Investigative Studies

Several investigations were conducted to locate, identify the type, percentage and quantity

of ACM present in and on the various facilities at RMA.

During the weeks of September 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 of suspected ACM and sent to

Analytics Laboratory in Richmond, VA for analysis. This survey showed six building to

be free of ACM.

In 1990, the Army was interested in demolishing several structures at the Rocky Mountain

Arsenal (RMA). The structures were in various states of disrepair. 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 of ACM and percentage of

asbestos, and also estimate the quantity of ACM. Ebasco performed an asbestos

assessment to determine the extent of ACM in the previously inspected 32 structures that

had ACM. During this assessment, a total of 137 bulk samples were taken in and

around 17 of those 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 of 486 structures, 19 miles of pipe runs and

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more than 15,000 pipe fittings, gaskets, etc., were surveyed. More than 5,000 samples of

suspect ACM were collected of which approximately 4,300 were analyzed for asbestos.

2.2 Nature and Extent of Contamination

During the OHM asbestos sampling and survey program, 38 buildings were sampled for

the presence of ACM. Of the 48 ambient air samples, all were below the 0,02 fibers/cc

Personnel Exposure Limit (PEL) for asbestos. Of the 170 bulk samples taken, 90 samples

were confirmed to contain asbestos of I percent or greater. Recommendations were made

for the removal of ACM of 1 percent or greater, based on lab analysis.

In 1990, Ebasco investigated 32 structures at RMA for ACM. ACM was 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 of pipe

lagging and approximately 12,500 pipe fittings and gaskets.

2.3 Decision Process

Asbestos removal was identified in the FFA (EPA et al. 1989) as a contaminant source

requiring an IRA. Asbestos removal did not follow the typical 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 for this 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 of the 3 8 buildings (I 11, 213, 3 2 1 D,

342, 344, 345, 624, 728, 732, and 741) identified as containing ACM during the sampling

and survey program. A total of approximately 4,900 linear feet of ACM pipe lagging and

5 cubic yards of hot water tank insulation were removed, double bagged and drummed for

disposal. Approximately 6,500 square feet of transite sheet were removed, double

wrapped and pallatized for disposal.

Clearance samples were taken and walk-through inspections were conducted before final

releases of the buildings were approved. Clearance air sampling was conducted in each

building and the clearance standard of 0.01 fibers per cubic centimeter (F/CQ was either

met or surpassed.

All work was conducted according to OHM's Technical Plan with the exception of the

disposal of the ACM. The originally planned disposal site (Lowry Landfill) was not used

because of uncertainties concerning the integrity of some of the waste cells at that site.

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The USPCI disposal facility at Grassy Mountain, Utah, which had been used previously

for RMA waste, was chosen as the disposal site for the ACM from this 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 and RMA

employees. A total of approximately 3215 tons of ACK personal protection equipment,

containment plastic sheet material and other materials contaminated during the ACM

removal process have been removed from RMA. A list of projects by building and

contract number and the amount of ACM removed under each project is at Table 1. The

actual cost of carrying 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 of the structures abated.

5.0 Status

The Asbestos Removal RMA was considered completed at the signing of the On-Post

ROD on June 11, 1996.

Other ACM removal work still ongoing as part of the demolition of structures 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.

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6.0 References

Foster Wheeler Envirom-nental Corporation. 1996 (June). Record ofDecisionfor the OnPost Operable Unit.

Ebasco, Services Incorporated. 1991 (March). Final Asbestos Survey of 32 Structures

(Version 3. 1).

O.H. Materials Corp. 1989 (January 17). Asbestos Sampling Reportfor the Rocky

Mountain Arsenal in Commerce City, CO.

Roy F. Weston, Inc. 1991 (September). Final Technical Plan Task 005 Survey of

Asbestos Containing Materials Version 3. 1.

Roy F. Weston, Inc. 1992 (April ). Summary andMethodologies Final Report Task 005

Survey of Asbestos Containing Materials at the Rocky Mountain Arsenal Version

3.0.

U. S. EPA et al. 1989 (February 17). Federal Facility Agreement in the Matter of Rocky

Mountain Arsenal, U.S. Dept. of the Army and Shell Oil Company.

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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