TECHNICAL SUPPORT FOR ENVIRONMENTAL

CLEANUP PROGRAMS AT

ROCKY MOUNTAIN ARSENAL

FINAL

IMPLEMENTATION LETTER

UNDERGROUND STORAGE TANK

MONITORING AND REMOVAL

Version 3.2

NOVEMBER 1994

CONTRACT NO. DAAA05-92-D-0002

DELIVERY ORDER 0001

TASK ORDER 92-07

Prepared by:

EBASCO SERVICES INCORPORATED

Prepared for:

PROGRAM MANAGER'S OFFICE

ROCKY MOUNTAIN ARSENAL

7 72-

THE INFORMATION AND CONCLUSIONS PRESENTED IN THIS REPORT REPRESENT

THE OFFICIAL POSITION OF THE DEPARTMENT OF THE ARMY UNLESS EXPRESSLY

MODIFIED BY A SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE

RELEVANT PORTION OF THE ADMINISTRATIVE RECORD FOR THIS CERCLA

OPERABLE UNIT.

THE USE OF TRADE NAMES IN THIS REPORT DOES NOT CONSTITUTE AN OFFICIAL

ENDORSEMENT OR APPROVAL OF THE USE OF SUCH COMMERCIAL PRODUCTS.

THIS REPORT MAY NOT BE CITED FOR PURPOSES OF ADVERTISEMENT.

M9513475
TABLE OF CONTENIS

Section Page

EXECUTIVE SUMMARY ............................................ vi

1.0 INTRODUCTION ................................................ I

1.1 BACKGROUND ............................................ I

1.1.1 Decision D ocum ents .................................... 2

2.0 LOGISTICS HISTORY ........................................... 3

2.1 UNDERGROUND STORAGE TANK INFORMATION ................ 3

2.2 USAGE ANALYSIS .......................................... 3

2.3 A R A R s ... .. .. .. .. .. .. .. .... .. .. .. .... .... ... ... .. ... ... . 13

3.0 HAZARDOUS SUBSTANCEAVASTE STORAGE TANK REMOVAL PLAN .... 17

3.1 TA N K SU RVEY ............................................ 17

3.2 SAMPLING AND CHARACTERIZATION OF TANK CONTENTS ....... 17

3.3 REMOVING TANK CONTENTS ................................ 17

3.4 PURGING TANKS .......................................... 18

3.5 DISCONNECTION OF PIPING AND ANCILLARY EQUIPMENT ........ 18

3.6 TANK EXTERIOR CLEANING ................................. 18

3.7 TANK INTERIOR CLEANING ................................. 19

3.7.1 H igh Pressure W ash .................................... 19

3.7.2 ' H ydroblast ... .. .. .. .. .. .. ... ... .. .. .. .. ... .. ... .. .. .. 19

3.7.3 C hem ical W ash ....................................... 19

3.8 TANK REMOVAL FOR DEMOLITION ........................... 20

3.9 SO IL SA M PLIN G ........................................... 20

4.0 PETROLEUM UNDERGROUND STORAGE TANK REMOVAL PLAN ....... .)I

4.1 TA N K SU RV EY ............................. .............. 21

4.2 SAMPLING AND CHARACTERIZATION OF TANK CONTENTS ....... 22

4.3 REMOVING TANK CONTENTS ................................ 23

4.4 PURGING TANKS .......................................... 23

4.5 DISCONNECTION OF PIPING AND ANCILLARY EQUIPMENT ........ 23

4.6 TANK INTERIOR CLEANING ................................. 23

4.7 TANK REMOVAL FOR DEMOLITION ........................... 23

4.8 SOIL SAM PLING ........................................... 24

4.9 REMOVED UNDERGROUND STORAGE TANKS ................... .24

RMA\0760 I i / 10/94 10: 18 am ap
5.0 W ASTE MANAGEMENT ......................................... 26

5.1 SOLID W ASTES ........................................... 27

5.2 LIQUID W ASTES .......................................... 27

5.3 SALVAGEABLE MATERIALS ................................. 27

5.4 PCB-CONTAMINATED MATERIALS ............................ 28

5.5 CONTAMINATED SOILS ..................................... 28

5.6 WASTE MATERIAL STORAGE ............................... 28

6.0 HEALTH AND SAFETY .......................................... 30

7.0 DOCUM ENTATION ............................................. 31

8.0 COST ESTIMATE -AND SCHEDULE ................... ............. 32

RNIA\0760 11/10/94 10:18 am ap
LIST OF TABLES

Page

Executive List of Phase I Underground Storage Tanks to be Removed .............. ES

Summary

2.1-1 Petroleum Underground Storage Tanks at Rocky Mountain Arsenal ......... 4

2.1-2 Registered Underground Storage Tanks to be

R em oved ... .. .. ... ... .. .. .... .. .. .. .. .. ... ... .. .. ... .. .. . 9

2.1-3 Non-Registered Petroleum Underground Storage

Tanks to be Rem oved ........................................ 10

2.1-4 Nonregulated Compressed Propane Underground Storage Tanks

to be R em oved ............................................ 11

2.1-5 Hazardous Substance/Hazardous Waste Underground

Storage Tanks to be Removed .................................. 12

RMA\0760 11/10/94 10:18 am ap
LIST OF FIGURES

Page

2.1-1 North Plants Area Underground Storage Tanks at

Rocky M ountain Arsenal ...................................... 5

2.1-2 South Plants Area Underground Storage Tanks at

Rocky M ountain Arsenal ...................................... 6

2.1-3 Rail Yard Area Underground Storage Tanks at Rocky

M ountain A rsenal ........................................... 7

2.1-4 Old Toxic Storage Yard Underground Storage Tank

at Rocky M ountain Arsenal ..................................... 8

iv

RMA\0760 11/10/94 10:18 am ap
LIST OF ACRONYMS AND ABBREVIATIONS

API American Petroleum Institute

ARAR Applicable or Relevant and Appropriate Requirement

Army U.S. Department of the Army

BTEX benzene, toluene, ethylene, and total xylenes

CCR Colorado Code of Regulations

CDH Colorado Department of Health

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980

CFR Code of Federal Regulations

CS1 Conservation Services Incorporated

CWHA Central Waste Handling Area

DCPD dicyclopentadiene

DLA Defense Logistics Agency

Logistics Defense Reutilization and Marketing Office

DRMS Defense Reutilization and Marketing Service

EPA U.S. Environmental Protection Agency

ESD Explanation of Significant Differences

FFA Federal Facility Agreement

GAC Granulated Activated Carbon

GAL gallon

GC gas chromatograph

IDLH Immediately dangerous to life or health

IL Implementation Letter

IRA Interim Response Action

LEL Lower explosive limit

ml milliliter

NA not available

PCB polychlorinated biphenyl

PMRMA Program Manager for the Rocky Mountain Arsenal

PPE Personal protective equipment

QA/QC quality assurance/quality control

RACT Reasonably Achievable Control Technology

RMA Rocky Mountain Arsenal

ROD Record of Decision

Shell Shell Oil Company

TEPH Total Extractable Petroleum Hydrocarbons

TSCA Toxic Substances Control Act

TVPH Total Volatile Petroleum Hydrocarbons

USED not defined

UST underground storage tank

WWTF Waste Water Treatment Facility

v

RMA\0760 11/10/94 10:18 am ap
EXECUTIVE SUMMARY

The revisions to Version 3.2 of the Final Implementation letter (IL) for Underground Storage

Tank (UST) Monitoring and Removal include the deletion of two tanks which were believed to

be associated with operation in North Plants, one tank in South Plants, one tank in Section 09

which is under control of the Federal Aviation Administration, one tank in Section 12 which is

under control of the Fort Carson Director of Engineering and Housing. Additionally, all tanks

owned or leased by Shell Oil Company (Shell) have been removed from this Interim Response

Action IL. Tank T0002 at Building 416 has been declassified from a petroleum UST to a

hazardous substance/waste UST based on sampling results which indicated remaining product to

be 85 percent benzene.

After reviewing analytical results and process history the last known contents of all tanks listed

in this IL have been identified and presented in the Executive Summary table.

The attached table identifies the USTs to be removed upon approval of this IL.

vi

RMA\0760 11/10/94 10:18 am ap
Executive Summary - Underground Storage Tanks at Rocky Mountain Arsenal Page I of I

Tank Count Tank No. Bldg. No. Northin,- Easting Approximate Size Status Last Known Contgnts

(Gal)

I 0242D* 242 180180 2183246 1,165 Fuel Oil

0256* 256 1 9W95 2192817 3,500 Diesel Fuel

3 NN0201 321 179617 2182970 12,M) Fuel Oil

4 T(W 1 329 179239 2182756 12,000 Gasoline

5 T(XX)2 329 179238 2182767 12,M) Gasoline

6 T0002t 461 179830 2174538 l,W0 Gasoline\Benzene

7 T(KX) I * 629 177537 2162900 12,M) Active Gasoline

8 TO(X)2* 629 177537 2172862 12,0W Active Gasoline

9 T(X)03* 629 177537 2172826 9,W0 Active Diesel Fuel

10 TW04* 629 177563 2172796 1,000 Kerosene

I I T(X)02 632 176258 2172835 40,(XX) Active Diesel Fuel

12 TOM 1 833 185567 2193405 1,(XX) Diesel Fuel

13 T0001 836 191312 2184074 1,000 Diesel Fuel

14 T0004 866 179426 2193821 250 Kerosene

15 NN2504 NN2504 196089 2197102 NA Gasoline

16 T0003** 632 176349 2172810 NA Diesel Fuel

17 T0002** 633 175935 2172913 NA Diesel Fuel

18 T0001** 732 1 9W30 2186293 NA Used Oil

19 TW0 I * * 627 177329 2172700 1, 100 Used Oil

20 T(M3t 329 179244 2192729 10,000 Benzene

21 T(W 1 633 175999 2172998 1,000 Propane

22 TOOO I f IQ2 190415 2186535 1,5W Fuel Oil

23 TWO I t 424C 1794W 2184444 1,(XX) Caustic\Aldrin

Tank registered with state as a petroleum tank

Tank is removed

t Hazardous substance/waste underground storage tanks

t Tank was discovered in July 1994

NA Not available

GAL Gallon

RMA/I 195 11/10/94 10:01 am ap
1.0 INTRODUCTION

This IL has been prepared as a requirement for the task to remove USTs at Rocky Mountain

Arsenal (RMA). This document was prepared in accordance with requirements set forth in the

Final Explanation of Significant Differences (ESD) for the Chemical Process-Related Activities

Interim Response Action (IRA). The purpose of this IL is to outline the basis and plan for

decontamination, removal, and disposal of USTs from RMA.

1.1 BACKGROUND

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 United

States government in 1942 and was used during World War Il as the site for the manufacture and

assembly of chemical warfare materials, such as mustard and lewisite, and incendiary munitions.

As part of the manufacturing process, USTs were installed at various locations to store raw

materials, act as catch and overflow basins, store fuel, and provide temporary storage while

process systems were being cleaned. Between 1946 through the 1980s, RMA was involved with

the destruction of chemical warfare materials. In addition to these military activities, between

1947 and 1982 major portions of the plant facilities were ]eased to private industries,

predominantly Shell, for the manufacture of various insecticides and herbicides. All military and

manufacturing operations at RMA ceased in 1982; since that time, RMA activities have been

focused on cleanup.

In February 1989, a Federal Facility Agreement (FFA) was entered into by Shell and the

following five federal agencies: the U.S. Environmental Protection Agency (EPA), the U.S.

Department of the Army (Army), the U.S. Department of Interior Fish and Wildlife Service, the

U.S. Department of Health and Human Services (Agency for Toxic Substances and Disease

Registry), and the U.S. Department of Justice. The FFA established a framework for

implementing the RMA cleanup program, and specified 13 IRAs determined to be necessary and

appropriate. The Chemical Process-Related Activities IRA was not one of the original IRAs, but

RNIA\0760 11/10/94 10:18 am ap
has been added to the program. The remediation of USTs is a discrete element of the Chemical

Process-Related Activities IRA.

1.1.1 Decision Documents

The IRA alternatives assessment and decision process for the USTs at RMA will be a discrete

element of the Chemical Process-Related Activities IRA. This element will be conducted as part

of the IRA process for RMA in accordance with the FFA and the Technical Program Plan. As

specified in the FFA, an IRA must be consistent with and contribute to the efficient performance

of the Final Remedy selected in the Record of Decision (ROD).

Alternatives for the USTs have been reviewed based on their overall protectiveness of human

health and the environment; compliance to the maximum extent practicable with Applicable or

Relevant and Appropriate Requirements (ARARs); reduction in contaminant toxicity, mobility,

or volume; short and long-term effectiveness; implementability; and cost-effectiveness. The

preferred alternative consists of cleaning and removing the USTs and disposing of them by

cutting them up for scrap.

2

RMA\0760 11/10/94 10:18 am ap
.. ........ ... ...... .... .... ........ ... ..........

2.0 LOGISTICS HISTORY

The remediation of USTs at RMA will consist of monitoring and removing 23 tanks located

throughout the facility. The field activities under this IRA will begin upon the approval of

this IL.

2.1 UNDERGROUND STORAGE TANK INFORMATION

Table 2.1-1 lists all the petroleum tanks at RMA. This table indicates that four tanks have

already been removed. For these tanks, investigations will be conducted and closure reports will

be written as part of this IRA.

Tables 2.1-2 through 2.1-5 list the registered petroleum tanks, non-registered petroleum tanks,

nonregulated compressed propane tank, and the hazardous substance/waste storage tanks to be

removed. Figures 2. 1 -1 through 2.1-4 show the location of the tanks in the north plants, south

plants, railyard, and old toxic storage yard areas.

Nonregistered tank T0001 at Building 1622 was discovered in July 1994. It is believed to be an

out of service heating fuel storage tank installed during the construction of North Plants. Since

this tank was only recently discovered, it was not listed in the Decision Document, but will be

removed as part of this IRA.

All tanks listed on Tables 2.1-2 through 2.1-5 will be removed in accordance with the ARARs

and procedures outlined below.

2.2 USAGE ANALYSIS

Tank classification was determined based on usage analysis. The usage analysis identified four

tank categories; USTs registered with the State as petroleum product storage tanks, USTs not

registered with the State as petroleum product storage tanks, hazardous substance/waste USTs,

and nonregulated USTs. The usage analysis also indicated all USTs have been taken out of

service except the four USTs in the Motor Pool, and the tank being used in support of activities

3

RMA\0760 11/10/94 10:18 am ap
Table 2. 1 -1 Petroleum Underground Storagc Tanks at Rocky Mountain Arsenal To Be Removed Page I of I

Tank Count Tank No. Bl(],,. No. Northing Fasting Approximate Size (Gal) Status

I 0242D* 242 190190 2183246 1,165

2 0256* 256 1 9W95 2192917 3,500

3 NN0201 *t 321 179617 2192970 12,000

4 T(W 1 329 179239 2182756 12,000

5 T(W2 329 179239 2192767 12,(X)O

6 T(M 1 629 177537 21629M 12,(M Active

7 T0002* 629 177537 2172962 12,(X)O Active

9 T(XX)3* 629 177537 2172926 9,000 Active

9 T(X)04* 629 177563 2172796 1,000

10 T0002 632 176258 2172835 40,000 Active

11 TOW 1 833 185567 2183405 1,000

12 TMO 1 936 191312 2194074 1,000

13 T0004 866 178426 2193921 250

14 NN2504 NN2504 196099 2187102 NA

15 TO(X)3** 632 176349 2172810 NA

16 T(M2** 633 175935 2172913 NA

17 TOOOI** 732 18W30 2196283 NA

18 TOOO 1 627 177329 2172700 1, 1 M

19 TOOO 1 1622 190415 2196535 1,500

Tank registered with state as a petroleum lank

Tank is removed

t Tank possibly contained hazardous substance during operation

f Tank wits discovered in July 1994

NA Not available

GAL Gallon

VkAA/I IRf, I 11MAM Q-SI qrn an
Tank T0001

I d ýg.8 3!

Legend

Petroleum Underground Storage

Bldg. 1622 a Petroleum Tank Registered with

Tank T00011-----,dý3 MD02

Hazardous Substance/Hazordou

Underground Storage Tank

lax-,

0 300 600

SCALE IN FEET

Prepared for:

U.S. Army Program Manager

for Rocky Mountain Arsenal

Prepcred: January 1992

Bldg, NN2504 L ýo MR\--Tank NN2504 Figure 2.1 -1

0 North Plants Area Undergi

Tanks at Rocky Mountain

mw2:::Z Bldg. 8 33 Rocky Mountain Arsenal

Tank Prepared by: Ebosco Services Incorpc T0001* IN
n 0 ý 0310 -F Li

Bldg. 242 

a am 000 0 0

Ee D 0 C= Bldg. 256 "a 4' 0 1 =I t) ES -1 . I . .TTank 0256* /ýýn 02-,42D4 ...... -4-

0

CO

000 ---------- - LA

ID a a CO El 321 E El 11 au

081.0 a ]JI 13 El 13 F1 0H

13

'-I f F F F F f

Bldg. 321 Bldg. 424c M

Tank NN020 C-3 Efl r

.... ... ... Ch go o! %F\T 'k T 110-

an 100 C3

TankIToqO2 

E6d 0

Tank 

03

Tank T0002

Bldg. 461 0

S C

-x- X- X- _U -X X1=1 X- X---7 Legend

x x T0002

0 LI = Petroleum Underground Storage Tank

x T0001

x Hazardous Substonce/Woste UndergrOL

0 

Petroleum Tank Registered with State

Tank is Removed

1711 X--X-.-,

x Prepared for:

U.S. Army Program Manager

for Rocky Mountain Arsenal

Prepared: January 1992

Figure 2.1 -2

South Plants Area UndergrOL

Tanks at Rocky Mountain Ari

Rocky Mountain Arsenal

Prepared by: Ebasco Services Incorporatc
+

F

ý Bl 629

T nK T0001*,' dg. 627 "---T nk T0002* LL nk T00034

-EW- . nk T0004*, Tonk 1 )0

+

Viý

Tank 11,0003- 1

T nk

"LJ

ý 63 3 + t +

Lj

t

4

7cr)k T0001

Bldg. 633

-NSCCE 11N FEE'

Prepared for:

Leaerd U.S. Army P,og-c- Manager

for Rocky Mountain A,senci

TOOD2 M Prepored: Jonuory 1992 Petro;eý-i Underground Storage 7onk

T0001 Figýýre 2.1 -3

Non,eguicfed Underground Storage Tcnk

Roi! Ycrd A-ec Urdergroind Sto-cge

Petroieurr, Tonk Registered with State Tcnks ot, Rocky Mountc;n A,sencl

Tank is Re-oved Rocky Vounto;n Asenol

Prepc ec by Eoosco Senices Inco,oo-ctec
\\v Ir,

0315

C07 70

M) w 3

-Bldg. 866

0

-Nmr2c

gro

0 300 e0o

SCALE N FEET

1:0 87.0 10 -20

Prepared for:

U.S. Army P,OqrCrrý Maýcger Legend for Rocky Moumtolr Arsec;

Drepcred: June 1994

T0002

Petroleum. Unde,grourd Storage Tank F;gLire 2.1 -4

T0001 Hczcrdous Sul-sIcnee/Wosle Underground Storage Tank Old Tox;c Storage lard U,-de-g,oLjn,_ Storage

Tank at Rocky VoLr)tc;r, A,senc:.

Petroleum Tcnk Registered w;tn Stcte RoCky Mountoir Arse,al

Tank is Re-oved Prepcrea by: Eocsco Services -Corpo,cted
Table 2.1-2 Registered Petroleum Underground Storage Tanks To Be Removed Page I of I

Tank Count Tank No. Bldg. No. Northin- Easting Approximate Size (Gal)

I 0242D 2421) 180190 2193246 1,165

2 0256 256 190095 2192817 3,5W

3 NN0201 321 179617 2192970 12,0M

4 TM) 1 629 177537 2172900 l2,WO

5 T0002 629 177537 2172962 12,000

6 TW03 629 177537 2172826 9,000

7 TOW4 629 177563 2172796 1,000

9 T(XX)l 833 195567 2193405 I'MO

Tank rx)%%ibly con(aincd hivardous substance during, operifion

NA Not Aviii1ble

GAL 6;dIon

R M A/ 1216 11/10/94 10:20 am an
Table 2.1-3 Non-Registered Petroleum Underground Storage Tanks Page I of I

Tank Count Tank No. Bld-,. No. Northing Easting Approximate Size (Gal) Status

I TWO 1 329 179239 2182756 12,000

2 T(XX)2 329 179239 2192767 12,000

3 T0002 632 176259 2172835 40,0M Active

4 TOOO 1 936 191312 2184074 LOW

5 T0004 966 178426 2193921 250

6 NN2504 NN2504 196099 2197102 NA

7 TOOOlt 1622 190415 2186535 1,500

Tank was discovered in July 1994

NA Not Availahle

GAL Gallon

RMA/I 188 11110/94 10:23 am ap
I

Table 2.1-4 Nonregulated Compressed Propane UndergrOUnd Storage Tanks To Be Removed Page I of I

Tank Count Tank No. 131do. No. Northing Easting Approximate Size (Gal)

I TWO 1 633 175999 2172998 1,000

N A Not Available

GAL Gallon

RMA/1237 11/10/94 10:22 am ap
Table 2.1-5 Hazardous Sbbstance/Hazardous Waste Underground Storage Tanks Page I of I

Tank Count Tank No. Bld,,. No. Northing Easting Approximate Size (Gal)

I T(M3 329 179244 2192729 1 0,(XX)

2 T0002 461 179930 2174538 1'(0)

3 T(XX) I 424C 1794M 2184444 1,000

GAL Gallon

RMA/I 189 11/10/94 10:21 ain ap
..... ..... .. ... ..... .....

at Stapleton International Airport. The Motor Pool is scheduled to close in late 1994 and at that

time those tanks will be taken out of service.

2.3 ARARs

The removal of USTs includes characterization, deactivation, decontamination, and disposal

activities. The known size of the tanks ranges from 250 gallons to 40,000 gallons. Tank

deactivation

activities will prepare the USTs for interior cleaning, removal, and demolition to scrap. These

activities will isolate the tanks from utilities and process piping, eliminate flammable or toxic

environments that are immediately dangerous to life or health (IDLH), and remove residual

wastes from the tanks. Tank cleaning and removal will provide for the complete demolition of

the tank interiors, ancillary piping, and equipment and for the systematic removal and demolition

of the tanks. Tank materials will be segregated for the recycling of all salvageable metal.

Polychlorinated biphenyl (PCB) contamination is a possibility for tanks containing residual fuels

or oils. In the event of PCB contamination, the following sections of the Toxic Substances

Control Act (TSCA) will be considered ARARs:

Marking of PCBs and PCB Items:

40 CFR 761.40 (a) (1)

40 CFR 761.40 (a) (10)

40 CFR 761.40 (b)

40 CFR 761.40 (h)

40 CFR 761.45 (a)

40 CFR 761.45 (b)

Storage and Disposal:

40 CFR 761.60 (a) (1)

40 CFR 761.60 (c) (1) (i)

40 CFR 761.60 (c) (2)

40 CFR 761.60 (d)

40 CFR 761.60 (g) (2)

40 CFR 761.65 (a)

13

RMA\0760 11/10/94 10:18 am ap
... ........... ......... ... ..... ... ....... 

 .......... ...... . 

 ... ..... ... ...... ........... ..... ... ... ..... ... ... ... ........ ... ...

....

.

40 CFR 761.65 (b) (1)

40 CFR 761-65 (c) (1) (iii)

PCB Waste Disposal Records and Reports:

40 CFR 761.202 (a)

40 CFR 761.202 (b)

40 CFR 761.202 (d)

40 CFR 761.207

40 CFR 761.208 (a)

40 CFR 761.209 (a)

40 CFR 761.215

40 CFR 761.218 (d) (1)

Potential ARARs for removal of hazardous substance/waste USTs are briefly detailed below.

Residues from tanks must be characterized in accordance with 6CCRIO07-3 Part 261

to determine if the residue is hazardous.

" All residues, piping and ancillary equipment and structures and equipment

contaminated with hazardous waste should be removed decontaminated. and

managed as hazardous waste unless excluded under 6CCRIO07-3 Part 261.3(d)

(6CCRIO07-3 Part 264.197)

" Ignitable, reactive, or incompatible wastes must be managed in accordance with

6CCRIO07-3 Part 264.198 to .199.

" The removal of hazardous substance/waste USTs will be done in accordance

with the Colorado Underground Storage Tanks Law (CRS S 25-18- 101 et seq.)

and the Colorado UST Regulations (6 CCR1007-5).

" Air emissions that result from purging tanks will be treated using RACT as

specified in Colorado Regulation Number 7 - Control of Emýissions of Volatile

Organic Compounds.

" Hazardous debris including ancillary equipment, piping and tanks that are

contaminated with hazardous waste will be treated in accordance with the

treatment standards for hazardous debris (6 CCR 1007-3, Part 268).

" Removal of USTs contaminated with Army Agents, will be consistent with the

Department of the Army regulations that are ARARs. Army regulations include

AR385-131 (Safety Regulations for chemical Agents), AR385-5 (Contamination,

Decontamination, and Disposal, AR385-61 (Safety Studies and Reviews of

14

RMA\0760 11/10/94 10:18 am ap
................... 

  ......................

Chemical Agents and Associated Weapon Systems), and AR 420-420 (Solid and

Hazardous Waste Management).

If wastes from removal of hazardous substance/waste USTs is determined to be

hazardous and is sent off-site for treatment or disposal it will be done in

accordance with the CERCLA Procedures for Planning and Implementing offsite Response Actions (40 CFR 300.440).

Potential ARARs for removal of petroleum USTs are briefly summarized below.

Residues from tanks should be characterized in accordance with UCCR 1007-3 Part

261 to determine if the residue is hazardous.

Used oil should be managed in accordance with EPA standards for used oil to

determine if the used oil is hazardous waste fuel, used oil fuel or specification used

oil fuel (40 CFR 279).

If residual fuel or oil is contaminated with Polychlorinated biphenyls (PCBs) the

waste will be regulated by the Toxic Substances Control Act (TSCA) regulations (40

CFR 761 Subpart B).

The removal of petroleum USTs will be done in accordance with the Colorado

Underground Storage Tanks Law CRS S25-18- 101 and the Colorado UST Regulations

(6CCR 1007-5).

Petro] eum-c ontamin ated debris (CRS S25-18-101, et seq.) that fails the toxicity

characteristic (et seq.) for hazardous waste codes DOI 8-D043 are not regulated as a

hazardous waste (6CCRIO07-3, Part 261). However, these wastes will be managed

in accordance with EPA technical UST Standards (40 CFR 280).

Purging of tanks by introduction of inert gas may cause air emissions that will be

mana--ed in accordance with Colorado Regulation Number 7 - Control of Emissions

of Volatile Organic Compounds.

Removal of petroleum USTs that are contaminated with Army agents will be

consistent with the Department of the Army regulations that are ARARs. Army

regulations include AR385-131 (Safety Regulations for Chemical Agents), AR 385

(Contamination, Decontamination and Disposal, AR 385-61) (Safety Studies and

Reviews of Chemical Agents and Associated Weapon Systems), and AR420-47 (Solid

and Hazardous Waste Management).

15

RMA\0760 11/10/94 10:18 am ap
........ ...... .. ........ .. .... .... .... .... 

   ........ .................. ... .... ........ ... ........ ........... ... .... ....... ....... 

, ....... ..... ..... .. .. .... ....... ... .... .... .... ........ ......... ... ... ................ ......... .. ...........

If wastes from removal of Petroleum USTs is hazardous and is sent off-site it will be

done so in accordance with the CERCLA Procedures for planning and Implementing

off-site Response Actions (40 CFR.300.440).

16

RMA\0760 11/10/94 10:18 am ap
.. ..........

3.0 HAZARDOUS SUBSTANCE/WASTE STORAGE TANK REMOVAL PLAN

3.1 TANK SURVEY

Prior to beginning any field work, a tank survey will be performed. The purpose of the survey

will be to verify information regarding the tanks, including, but not limited to locations,

dimensions, construction materials and ancillary equipment. In addition, the survey shall identify

which, if any, of the tanks are on the PMRMA Real Property List. Information obtained/verified

in the tank survey shall be included in the Completion Report.

3.2 SAMPLING AND CHARACTERIZATION OF TANK CONTENTS

The purpose of the sampling and characterization is to protect the safety and health of workers

and to characterize the wastes for treatment or disposal. Prior to removing any of the tank

contents the residues shall be sampled and characterized to determine if the contents must be

handled as a hazardous or special waste and to determine appropriate solutions for cleaning and

decontamination.

3.3 REMOVING TANK CONTENTS

The possibility exists that a small number of tanks will contain residues from production,

cleaning rinsates and/or groundwater accumulation. These liquids, sludges or other residues will

be drained or pumped from the tank after proper characterization. All pumps and hoses will be

chemically compatible with the liquid or sludge being pumped. Once as much liquid and sludge

as possible is pumped from the tank, remaining contents will be removed through a combination

of residual floating, manual scraping and shoveling and absorbent applications to the tank

interior. Residues removed from hazardous substance UST will be drummed, manifested, and

disposed of through the Defense Reutilization and Marketing Service of the Defense Logistics

Agency at a certified offsite facility.

17

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3.4 PURGING TANKS

Before intrusive activities, each tank's atmosphere will be monitored to determine the percent

oxygen and percent of the lower explosive limit (LEL). Purging shall be accomplished by the

introduction of an inert gas, either carbon dioxide or nitrogen. Purging methods utilizing liquids

as the purging medium shall not be allowed. All displaced vapors ventilated will be removed

from the surrounding work area using flexible ducting. Vapors of hazardous substances will be

treated using Reasonably Achievable Control Technology (RACT) before release into the

atmosphere.

3.5 DISCONNECTION OF PIPING AND ANCILLARY EQUIPMENT

Piping and process equipment will be removed as necessary to allow safe removal and demolition

of tanks. Piping shall be drained into the tank or an appropriate container and the piping

disconnected from the tank. Open pipes shall be blocked using blind flanges. Each and every

pipe disconnected shall be tagged with a uniquely coded, permanent tag. The removed piping

and equipment will be decontaminated and prepared for salvage.

3.6 TANK EXTERIOR CLEANING

The tanks will be visually examined to assure that they are not contaminated with hazardous

substances or hazardous wastes. If a residue is found, it will be characterized, removed,

packaged and disposed of separately. The exteriors will be cleaned using high-pressure water

washing to remove dirt, dust, loose scale and flakes. Rinsates will not be collected because of

the non-hazardous nature of these materials.

For those tanks in the south plants area, the rinse water and soil will be directed back into the

excavation. For tanks located elsewhere, the soil sill be placed back into the excavation and the

rinse water collected, filtered, and transported to the CERCLA Wastewater Treatment Facility

(WWTF).

18

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............ ...... ... .... ........

3.7 TANK INTERIOR CLEANING

Decontamination of tanks will require interior surface cleaning. The cleaning methods may

include one or a combination of the following: (1) By high pressure water wash; (2) hydroblast;

and (3) chemical wash by use of bleach, acid or caustic. The specific method will be selected

based on characterization of tank contents, if any. Decontamination rinse water will be collected

and treated at the RMA CERCLA Wastewater Treatment Facility (CVvWTF) or disposed of

through the Defense Reutilization and Marketing Service (DRMS) of the Defense Logistics

Agency (DLA).

3.7.1 High Pressure Wash

At a minimum every interior surface will undergo a high pressure wash with plain water. Tank

entry to clean by low volume high pressure will be used for interior cleaning where access,

atmosphere conditions, interior surfaces and contaminants allow. A remote high-pressure water

cleaning method will be used on large tanks, where access is limited, when interior atmosphere

conditions preclude tank entry, or when it is determined that this is the most effective procedure.

3.7.2 Hvdroblast

A hydroblast system is a high pressure unit that incorporates a rotating nozzle assembly that can

be lowered into a tank interior. The water generated from this method will be filtered and

recycled through the system to minimize rinsate volumes.

3.7.3 Chernical Wash

Chemical cleaning methods may be employed for cleaning interior surfaces and includes

bleaching, acid and caustic washing and peroxide wash. Specific cleaning solutions will be

determined based upon the nature of the residual contamination.

19

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......

3.8 TANK REMOVAL FOR DEMOLITION

At a minimum, every interior surface will undergo a high-pressure wash with potable water.

Rinse water will be removed either by vacuum truck or a pump lowered into the tank. The rinse

water will be drummed and hauled to CERCLA WWTF once it is removed from the tank. Rinse

water might have to be run through a granular carbon activated filter prior to transporting to

CERCLA WWTF.

The excavation will remain open while awaiting analytical confirmation about contamination

before backfilling. The open excavation will be surrounded with a portable fence to prevent

entrance by unauthorized personnel and wildlife. Upon confirmation that a site is

uncontaminated, the excavation will be backfilled to original grade and the site restored and

cleaned up.

3.9 SOIL SAMPLING

Once the tank is removed, the soil in the excavation will be sampled to determine if

contamination exists. Samples will be analyzed specifically for the substance that was held in

the tank. The soil samples will also be analyzed using EPA method 1311 (extraction) and EPA

methods 8270, 8080, 8150, 6010, and 7000.

20

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4.0 PETROLEUM UNDERGROUND STORAGE TANK REMOVAL PLAN

Petroleum UST tank removal will be conducted in accordance with the following regulations and

guidance documents provided by CDH and the American Petroleum Institute (API):

" The Storage Tank Facility Owner/Operator Guidance Documents for Initial Site

Characterization, Second-level Site Assessment, Use of State Clean-Up Guidelines,

Levels and Management of Contaminated Materials (CDH, December, 1992)

" Ground Water Monitoring Guidance, CDH Solid Waste and Incident Management

Section (CDH, January 1991)

" Title 25 Article 18 of the Colorado Revised Statute, 1989 as amended

" Petroleum Product or Waste Sampling and Analysis Project Plan (March 1, 1991)

" Removal and Disposal of Used Underground Petroleum Storage Tanks (API 1604)

Safe Entry and Cleaning of Petroleum Storage Tanks (API 2015)

" Guidelines for Confined Space Work in the Petroleum Industry API 2217

" Interior Lining of Underground Storage Tanks API 1631

In addition, the work to be performed will comply with all applicable sections of 7 Colorado

Code of Regulations (CCR) 1003 Part 290, and 40 Code of Federal Regulations (CFR) Part 280.

The Colorado Inspector of Oils will be notified in writing a minimum of 10 days prior to

removal of the USTs.

4.1 TANK SURVEY

Prior to beginning, any field work, a tank survey will be performed. The purpose of the survey

will be to verify information about the tanks including, but not limited to locations, dimensions,

construction materials, and ancillary equipment. In addition, the survey will identify which, if

any, of the tanks are on the PMRMA Real Property List. Information obtained/verified in the

tank survey will be included in the Completion Report.

21

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4.2 SAMPLING AND CHARACTERIZATION OF TANK CONTENTS

The purpose of sampling and characterization is to protect the safety and health of workers and

to characterize the wastes for treatment or disposal. Prior to removing any of the tank contents,

the residues will be sampled and characterized to determine whether the contents must be handled

as a hazardous or special waste and to determine appropriate solutions for cleaning and

decontamination.

Sampling during tank removal will consist of two distinct sets of samples. First, the residual

liquids and sludges in the tank will be sampled and analyzed for benzene, toluene, ethyene, and

total xylenes, BTEX, metals, PCBs, and dicyclopentadiene (DCPD) (where use history indicates).

After the tank has been removed, conformational soil samples will be collected from the material

below the tank.

Upon removal of waste oil tanks, soil samples will be analyzed using EPA Method 413, and EPA

Method 413, oil and grease, and EPA Method 8240 volatile organics, EPA Method 6010 ICP

metals. This will provide information as to the presence of solvents, degreasers, PCB's and

metals.

4.3 REMOVING TANK CONTENTS

It is possible that some tanks will contain residues, cleaning reinstates, and/or groundwater

accumulation. These liquids, sludges, or other residues will be drained or pumped from the tank

after proper characterization. All pumps and hoses will be chemically compatible with the liquid

or sludge being pumped. After as much sludge as possible is pumped from the tank, the

remaining contents will be removed through a combination of residual floating, manual scraping

and shoveling, and applications of absorbent materials to the tank interior. All uncontaminated

liquids and residues as determined by sampling results will be drummed, manifested, and

disposed at an offsite certified disposal facility. All contaminated sludge will be drummed,

manifested, and transported to Conservation Services Incorporated (CSI).

22

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.. .... ...... .................... ........ .................... ......

4.4 PURGING TANKS

Before intrusive activities, each tank's atmosphere will be monitored to determine the percent

oxygen and percent of the LEL. Purging will be accomplished by the introduction of an inert

gas, either carbon dioxide or nitrogen. Purging methods using liquids as the purging medium

will not be allowed. All displaced vapors will be removed from the surrounding work area using

the existing vent line. For the tank where use history indicates DCPD was added, if the air

sample results indicate DCPD is present, then the displaced vapors will be treated using RACT.

The proposed RACT is to pass the displaced vapors through a Granular Activated Carbon (GAC)

column.

4.5 DISCONNECTION OF PIPING AND ANCILLARY EQUIPMENT

Piping and process equipment will be removed as necessary to allow safe removal and demolition

of tanks. Piping will be drained into the tank or an appropriate container and the piping

disconnected from the tank. Open pipes will be blocked using blind flanges. Each pipe

disconnected will be tagged with a uniquely coded permanent tag. The removed piping and

equipment will be decontaminated and prepared for salvage.

4.6 TANK INTERIOR CLEANING

Decontamination of tanks will require interior-surface cleaning by high-pressure water wash.

Decontamination rinse water will be collected and treated at the CERCLA WWTF or disposed

at CSI. Rinse water will be removed either by vacuum truck or a pump lowered into the tank.

The rinse water will be drummed and hauled to CERCLA WWTF once it is removed from the

tank. At a minimum, every interior surface will undergo a high-pressure wash with potable

water.

4.7 TANK REMOVAL FOR DEMOLITION

Tanks will be removed in their entirety to increase safety and efficiency in demolition and

remediation efforts. Removal methods and requirements will be dictated by the interior condition

of the tank, surrounding obstructions or interferences, and the capabilities or limitations of the

23

RMA\0760 )1/10/94 10:18 am ap
..... ....... 

  ... ........... .....

demolition equipment. The methods may include the independent or combined use of a crane,

excavator, or manual handling of the tank. Once the tanks are removed from the excavation, any

remaining soil is scraped off and the outside of the tank rinsed. For those tanks in South Plants

area, the rinse water and soil will be directed back into the excavation. For tanks located

elsewhere, the soil will be placed back into the excavation and the rinse water collected, filtered,

and transported to CERCLA WWTF.

The excavation will remain open while awaiting analytical confirmation about contamination

before backfilling. The open excavation will be surrounded with a portable fence to prevent

entrance by unauthorized personnel and wildlife. Upon confirmation that a site is

uncontaminated, the excavation will be backfilled to original grade and the site restored and

cleaned up. If petroleum contamination is found, the contaminated soil will be excavated and

disposed off site at a permitted facility. The excavation will then be backfilled with clean

material to original grade.

4.8 SOIL SAMPLING

All soil samples will be analyzed for BTEX utilizing EPA Method 8020 and for tanks containing

gasoline products samples will also be analyzed for Total Volatile Petroleum Hydrocarbons

(TVPH) using modified EPA Method 8015. For tanks containing diesel fuel, the soil samples

will be analyzed for Total Extractable Petroleum Hydrocarbons (TEPH) using Colorado 8015

modified method. If the tank residue analytical results indicate that PCBs or other contaminants

exist, the soil samples at those specific tank locations will be analyzed for PCBs and other

identified contaminants.

4.9 REMOVED UNDERGROUND STORAGE TANKS

For USTs removed prior to the approval of this Implementation Letter the following procedure

will be followed to check for contamination. Based on the coordinates of the tank, a geophysical

survey will be performed to determine the boundary of the excavation. Based on the size of the

24

RMA\0760 11/10/94 10:18 am ap
 .......... ......... .. .. ...... ... .. .. ..........

excavation, one to three holes will be drilled through the backfilled material to undisturbed

ground and the soil sample will be collected from the undisturbed ground. The soil samples will

be analyzed per Section 4.8.

25

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...... .. 

, ...... ........ .... ...... .. ..... .

5.0 WASTE MANAGEMENT

Wastes generated during the performance of Phase I may include fuel, sludge, rinse water, scrap

metal, and possibly petroleum-contaminated soil. Any contaminated fuel will be drummed for

off-site disposal at an authorized disposal facility. DRMS through PMRMA Defense

Reutilization and Marketing Office (Logistics) will arrange for transportation and disposal of

uncontaminated fuel at an appropriately licensed facility.

Rinse waters generated during tank cleaning will be containerized and considered to be liquid

waste. Rinse water from the initial tank washing will be drummed and transported to CSI for

disposal. Rinse water from any subsequent tank washing will be drummed and disposed of

through the CERCLA WWTF provided that no petroleum product is observed floating on the

surface of the water. If petroleum product is observed to be floating on the rinse water, it will

be disposed of by DRMS through PMRMA Logistics.

Disposal of petroleum-contaminated soil will be at CSI. A facility-specific batch number and

manifest will be required for each load of contaminated soil removed from Rocky Mountain

Arsenal (RMA).

Concrete or asphalt encountered during tank removal processes will be consolidated at a location

identified by the Contracting Officer Representative (COR) on RMA along with any

nonhazardous and nonpetroleum wastes.

The potential exists for PCB-contaminated petroleum products; such waste will be destroyed in

accordance with TSCA regulations. Waste management procedures will comply with ARARs

identified in the ESD to the Chemical -Process Related Activities IRA Decision Document and

those identified in Section 2.3 of this IL.

All tanks will be transported to a central location to be cut up and put into a roll-off for disposal

as scrap metal. The central location will be the concrete pad on the northeast corner of

26

RMA\0760 11/10/94 10:18 am ap
.. ......... ...... ._ _ .... .............................. ...... ..... ... ....... ... .. ... ..... .. .... ... .. .... ....... ...

Building 256. A lined decontamination area will be constructed using 8 X 8 lumber and a 60

mil liner. Petroleum -contaminated soil will be excavated and placed in a truck to be transported

to a permitted facility. Drummed wastes will be sampled, manifested, and disposed of

accordingly. Rinse water that is captured will be filtered and sent to the CERCLA W`WTF.

5.1 SOLID WASTES

To minimize final hazardous waste volumes, wastes will be segregated to make certain that

nonhazardous waste is not mixed with hazardous waste. Discarded Personal Protective

Equipment (PPE) will be decontaminated, contained in drums and stored in the Central Waste

Handling Area (CWHA) for future disposal. Hazardous wastes will be characterized, labeled,

and packaged for off-site treatment and disposal through DRMS through PMRMA Logistics.

5.2 LIQUID WASTES

Rain water and decontamination rinse water will be treated at the CERCLA WWTF. Liquid

wastes that are not acceptable for treatment at this facility will be disposed at CSI.

5.3 SALVAGEABLE MATERIALS

All scrap metal will be collected at the point of generation. Paint and external coatings will be

left on the scrap metals. Salvageable materials may include light steel, short heavy steel, heavy

steel, aluminum, cast iron, stainless steel, high-temperature alloy, electric motors, copper wire,

and brass.

Prior to disposal, this material will be decontaminated and tested for contaminants. The steel

(generally structural and piping) will be placed in roll-off receptacles provided by the DRMS

contractor. Lead-based paint coated steel and cast iron will be cut into appropriate sizes and

placed in the steel roll off receptacles-not segregated. Metals such as copper, aluminum, and

brass, as well as other miscellaneous items that have a resale value will also be segregated.

27

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5.4 PCB-CONTAMINATED MATERIALS

PCB -contaminated materials will be treated and stored at the TSCA cell in Building 345.

5.5 CONTAMINATED SOILS

Soil samples will be collected from "undisturbed ground" after the UST has been removed. If

groundwater is encountered, groundwater samples will be collected along with the soil samples.

The number of samples required is a function of the tank size. Small USTs may require less than

the three-sample minimum (per 7 CCR 1003 Part 280), whereas large USTs (greater than 8,000

gallons) may require more than three samples. Soils that have been contaminated with petroleum

hydrocarbons will be excavated and disposed of only at a certified facility. If product is visible

in the soil after removal of hazardous substance tanks, the soil will be containerized in 55 -allon

drums. The drums will subsequently be sampled and the soil characterized for proper disposal.

5.6 WASTE MATERIAL STORAGE

Each step of the waste management procedure has unique regulatory controls that facilitate waste

management options and ensure that all waste materials generated during UST removal are

handled in a safe and responsible manner.

Waste rinse water or PPE generated during UST removal will be contained at each tank location.

Once waste material is contained, the tank location must be considered a satellite accumulation

point. Waste material can remain at a satellite accumulation point indefinitely provided that the

waste volume does not exceed 55 gallons of hazardous waste or one quart of acutely hazardous

waste. Containers of waste material exceeding these volumes may be collected from several

satellite accumulation points and stored at a collective 90-day accumulation point for 90-days or

less. After 90 days at a collective accumulation point, waste materials must be delivered to the

CWHA for storage, moved to the CERCLA WWTF for treatment or disposed of at CSI.

28

R,MA\0760 11/10/94 10:18 am ap
Satellite accumulation points will meet six requirements:

1) Containers must not leak and must be in good condition

2) Containers must be labeled or marked

3) Containers must remain closed except when being filled or emptied

4) Incompatible wastes must not be mixed in the same container

5) The waste and the container must be compatible

6. The total quantity of waste must not exceed 55 gallons (or I quart if acutely

hazardous)

Proper waste management will be achieved by complying with specified minimum requirements

from 40 CFR 262 and the Rocky Mountain Arsenal CWHA standard operating procedures 260

(Drum Checkout for DRMS through PMRMA Generated Operational and Demolition Wastes,

August 1993) and 261 (DRMS through PMRMA Generators Drum Return Procedures for

Operational and Demolition Wastes, August 1993).

29

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.... ......

6.0 HEALTH AND SAFETY

An Accident Prevention Safety Task Plan will be prepared and approved by the Army prior to

beginning field work. The Plan will address the following:

" Safety responsibilities of supervisor and employees

" Hazard assessment and site safety

" Description of PPE to be used

" Site personnel safety training

" Medical surveillance

" Air monitoring and safety training

" Decontamination procedures

" Site control

" Emergency procedures

30

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7.0 POCUMENTATION

A Completion Report will be prepared for each tank removed. Each Completion Report will

include the following:

" Tank number, location, size, content type and amount, and related information

obtained during removal

" Tank monitoring data

" Log documenting all pipe disconnects, pipe-blocking method employed, associated

tanks and corresponding tag identification code

" Actions taken, including quantities and types of material removed and treated

" Tank destruction certificates

Sample locations and corresponding identification codes

" Chain of custody forms

" Analytical laboratory results

Copies of manifests and certifications

Identification of sampler, analytical laboratory, transporter, and acceptor for all wastes

encountered

31

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............... .......... I ....... ...........

8.0 COST ESTIMATE AND SCHEDULE

The cost estimate for this project is $1,200,000. The project was initiated in October 1992 and

will be completed by March 31, 1996.

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...... ............ .... .......... ...........

Responses to Comments

This IL has undergone major revision to accommodate responses to cornments, from the EPA and

the CDH. Each comment and response has been keyed to this edition of the IL. Each comment

on the previous edition (old format) has been referenced in this edition (new format).

RMA/I 129 11/10/94 1:39 pm ap
.. ..................

RESPONSES TO EPA COMMENTS

GENERAL COMMENTS

Comment 1: The document presents a "conceptual" approach to the projected work.

The document lacks sufficient detail necessary for a complete review.

Response: The IL presents a general overview of the program. Details of how the work will

be accomplished have been added to version 3.1 of the IL.

Comment 2: The document provides no indication of how contamination around the

USTs will be identified or what response actions will be taken.

Response: Identification of contamination around the USTs and a sampling plan have been

added to the IL (Sections 3.4, 4.8, and 5.5). All UST removals will comply with the Storage

Tank Facility Owner/Operator Guidance Document for Initial Site Characterization Second-Level

Site Assessment, Use of State Cleanup Guidelines, and Management of Contaminated Materials

(CDH, December 1992).

SPECIFIC COMMENTS

Comment 1:

Old Format New Format

Page 2, Section I Sections 3.9, 4.8, and 5.5

Recognizing that this IL is only for the monitoring and removal, this

document should also address how contamination of the surrounding soils

will be identified and what remedial actions will be taken to clean up

contaminated soils.

Response: Identification and removal of petroleum contaminated soil are included in Section

5.5 of the IL. Contaminated soil will be disposed of in accordance with Section 5.0 of the IL.

While the excavation of contaminated soil is proceeding, soil gas sampling will continue to be

conducted to provide immediate results as to the extent of contamination. The removal of

contaminated soil will cease when the soil gas survey indicates the petroleum contamination no

longer exists and no contamination in excess of action levels is detected in the confirmation

samples. If at any time contaminants other than petroleum hydrocarbons are encountered during

the removal of petroleum-contaminated soil, the excavation will cease immediately.

RMA/0855 11/10/94 1:39 pm ap
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.......... ...

Comment 2:

Old Format New Fon-nat

Page 10, Section 1.2 Section 2.4

Backfilling and regrading once buried tanks are removed should also be

discussed or referenced as appropriate.

Response: Backfilling and regrading activities have been added to the IL. The excavation will

remain open while awaiting analytical confirmation about contamination before backfilling. The

open excavation will be surrounded with a portable fence to prevent entrance by unauthorized

personnel and wildlife. Upon confirmation that a site is uncontaminated, the excavation will be

backfilled to original grade and the site restored and cleaned up. If petroleum contamination is

found, the contaminated soil will be excavated and disposed off site at a permitted facility. The

excavation will then be backfilled with clean material to original grade.

Comment 3:

Old Format New Format

Page 11, Section 3.0 Sections 3.0 and 4.0

Please refer to previous comments concerning site/soil remediation and

restoration. There should be a discussion of these items in this section.

Response: See the responses to specific comments I and 2. Detail has been added to Sections

3.0 and 4.0 concerning site/soil remediation and restoration.

Comment 4:

Old Format New Format

Page 12, Section 3.2 Section 3.2, 3.9, 4.8

The document states that chemical analyses will be performed only if

existing information is insufficient to allow characterization. What

information exists on the contents of these USTs? There should also be

a discussion as to where Sampling and Analysis for adjacent soils will be

addressed.

Response: The executive summary table lists the past contents of the USTs. Sampling during

tank removal will consist of three distinct sets of samples. First, the residual liquids and sludges

in the tank will be sampled and analyzed for BTEX, metals, PCBs, and dicyclopentadiene

2

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.. ........... .... ............ ... .... .......... ..... 

11... ...1 1.111.11 .......... .. ..... ... .......... ....... .............

(DCPD) (where use history indicates). Next, the area around the tank and any feed lines will be

sampled with a soil gas survey to identify potential areas of contamination. Finally, after the

tank has been removed, confirmational soil samples will be collected from the material below

the tank. Sections 3.9 and 4.8 outline soil sampling after tank removal.

Comment 5:

Old Format New Format

Page 13, Section 3.4 Sections 3.4, 4.4

There should be a discussion of how vapors will be monitored (and

collected and treated where required) to ensure safety for field personnel

and how air pollution regulations will be observed.

Response: Sections 3.4 and 4.4 discuss monitoring of vapors during UST removal operations.

Given the size of the USTs to be removed during Phase I, preliminary calculations indicate the

volume of vapors liberated during Petroleum UST tank removal does not reach the threshold for

preparation of an Air Pollution Emissions Notice (APEN).

Comment 6:

Old Format New Format

Page 13, Section 3.6 Sections 3.3, 4.3

Please clarify how the Army proposes, to remove rinse water from the

tanks.

Response: Sections 3.3 and 4.3 discuss the removal of residual liquids and rinse water from

USTs. All liquids and residues will be removed from the tank using explosion-proof or airdriven pumps, or a vacuum truck. It may be necessary to remove the last few inches of liquid

from the bottom of the tank with a hand pump.

Comment 7:

Old Format

Page 15, Section 3.8, Section 3.8.1, New Format

Section 3.8.2, Section 3.8.3, Section 3.8.4 Section 5.0

There should be a discussion and reference to where these items will be

segregated, transported, stored, and ultimately disposed of

3

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.. ......... .......... ... ...... ... ................

Response: Section 5.0 addresses waste management for this IL. All tanks will be transported

to a central location (asphalt pad near the northeast comer of Building 256) to be cut up and

placed in a roll-off for disposal as scrap metal. Petroleum-contarninated soil will be excavated

and placed in a truck to be transported to a permitted facility. Drummed wastes will be sampled,

manifested, and disposed of accordingly. Rinse water that is captured will be filtered and sent

to CERCLA Wastewater Treatment Facility. Petroleum contaminated soil will be disposed of

at CSI.

Comment 8:

Old Format New Format

Page 17, Section 3.11 Section 8.0

The document states that the project is scheduled to begin in October

1992 and to be completed by March 31, 1994.

Response: The task order to prepare the Decision Document and Implementation Letter began

in October 1992, the UST Removals will begin once the IL is finalized. The completion date

has been changed to March 31, 1996.

4

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..

. .

RESPONSES TO STATE OF COLORADO COMMENTS

GENERAL COMMENTS

Comment 1: Page 10, First Bullet. The guidance document listed has been replaced

by Storage Tank Owner/Operator Guidance Document for Initial Site

Characterization, Second-Level Site Assessment, Use of State Cleanup

Guidelines, and Management of Contaminated Materials (Dec. 1992).

Response: The Reference to the Guidance Document will be updated.

Comment 2: Page 10. The list of applicable statutes should include Title 25, Article

18 of the Colorado Revised Statute, 1989 as amended.

Response: The reference will be added to the list of applicable statutes.

Comment 3: Please clarify the past or present contents of the USTs scheduled for

removal. The TPH analyses are not the same for all types of petroleum

products (volatile, sernivolatile, etc.)

Response: The Executive Summary Table of the Implementation Letter (IL) lists the past or

present contents of the underground storage tanks (USTs). As specified in Sections 3.9 and 4.8,

all soil samples will be analyzed for benzene, toluene, ethylene, and total xylenes (BTEX)

utilizing EPA Method 8020, and for tanks containing gasoline product the samples will also be

analyzed for Total volatile petroleum hydrocarbons (TVPH) using EPA Method modified 8015

(unedited). For tanks containing diesel fuel, the soil samples will be analyzed for total

extractable petroleum hydrocarbons (TEPH) using Colorado 8015 Method (unedited). If the tank

residue analytical results indicate that polychlorinated biphenyls (PCBs) or other contaminants

exist, the soil samples at those specific tank locations will be further analyzed for PCBs and other

identified contaminants. For tanks containing hazardous substances the soil samples will be

analyzed using EPA Method 1311 (extraction), and EPA Methods: 8270, 8080, 8150, 6010, and

7000 for analysis.

RMA/0854 11/10/94 1:38 pm ap
Comment 4:

Old Format New Format

Page 12, Section 3.2 Section 3.2

The first two sentences discuss sampling of the tanks for waste

characterization. The last sentence then states that chemical analyses will

only be performed if insufficient information is available to characterize

the waste. Please clarify.

Response: The wording of this section has been modified to reflect that chemical sampling will

be performed to determine tank contents and characterize them for disposal. Sampling during

tank removal will consist of 3 distinct sets of samples. First, residual liquids and sludges will

be sampled and analyzed to confirm tank usage. Next, the area around the tank and feed lines

will be sampled with a soil gas survey to identify potential areas of contamination, and finally

confirmation soil samples will be collected from the material under the tank after tank removal.

Sections 3.9 and 4.8 outline soil sampling after tank removal.

Comment 5:

Old Format New Format

Page 14, Section 3.6.1 Section 3.6

When discussing decontamination of these tanks, reference is made only

to interior cleaning. Please include a discussion of handling of exterior

cleaning and any associated wastes produced.

Response: Section 3.6 of the IL covers tank exterior cleaning. The tanks will be removed from

the excavation, scraped on the outside for remaining soil and rinsed. For those tanks in the South

Plants area, the rinse water and soil will be directed back into the excavation. For tanks located

elsewhere, the soil will be placed back into the excavation and the rinse water collected, filtered,

and transported to the CERCLA Wastewater Treatment Facility.

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Comments on

Final Implementation Letter

Underground Storage Tank

Monitoring and Removal

February 1994

EPA Comments

General Comments:

The responses to EPA's previous comments have not been adequately addressed. Most of

the responses to comments refer to the workplan, which is not furnished to the parties. These

responses are inadequate and not at all helpful. Such issues as how liberated vapors will be

handled is deferred to the workplan. EPA has no assurance that the workplan's method of

treating vapors is adequate. Similarly, EPA has no knowledge of how the Army intends to

insure that all contaminated soils are removed. Also, changes were made to the document

that were not based on the paries comments and were not explained.

EPA was informally given Sections 3.3.1 through 3.3.5 of the Draft Final Workplan and

Sections 4.0 through 4.1 and Sections 4.3 through 4.3.2 of the Field Sampling Plan, but this

was also not an adequate response to the comments that EPA has made. EPA request that

the Army address our previous comments on the Draft Final version and the comments being

made at this time on the final document.

Specific Comments:

Comment 1:

New Format

Old Format Section 2.0, 2.2 and 2.3

P.2 first full paragraph p 2-4

The document states that 19 tanks will be removed, but when compared to the

tables, there are 17 petroleum tanks, one of which may have contained a

hazardous substance, and 2 hazardous substance/hazardous waste tanks. This

document only addresses the removal of petroleum tanks. Please clarify.

Response: Sections 2.0, 2.2 and 2.3 of the IL have been rewritten and Tables 2.1-2 through

2.2-1 have been revised to account for all the tanks that will be removed in

Phase 1. The consolidated South Plants IL will address the remaining tanks

identified in the Decision Document.

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Comment 2:

Old Format New Format

Table 1-4 Table 2.1-4

Figure 2.1-3

Please explain why Tank No. T0001 at Building 633 has been removed from the

final report. Table 1-4, Nonregulated Underground Storage Tanks has been

deleted from the report and Tank No. TOOO I does not show up in any of the other

tables. However, it is still shown in Figure 1-3 as a nonregulated tank. Please

clarify.

Response: Nonregulated compressed natural gas tank No. T0001 at Building 633 was

mistakenly removed from the report. It has been returned as a tank to be removed

during Phase I activities.

Comment 3:

Old Format New Format

page 10 first paragraph Section 2.3 first paragraph

Table 2.1-1

The text indicates that there are 4 tanks remaining in service, which contradicts

the data in Table 1-1 which shows 6 tanks as still being active. Please clarify this

discrepancy.

Response: The text and tables have been changed to indicate four active tanks at the motor

pool and two others elsewhere on RMA.

Comment 4:

New Format

Old Format

Page 14, second full paragraph

Reference is made to the workplan, but the OAS has not, and typically does not

get to see this document. In order for EPA to accept this Implementation Letter,

our comments need to be addressed prior to commencing field activities.

Response: Sections 2.3, 3.9, and 4.8 have been added to this IL which address sampling and

analysis requirements for removal of USTs.

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Comment 5:

New Format

Old Format

Page 15, first full paragraph Sec. 5.0

How long does the Army Plan to store the wastes prior to disposal? What

arrangements have been made with DRMO to procure offpost disposal? Where

will the central staging area be located?

Response: The Army intends to dispose of waste as soon as proper characterization has been

completed. Offpost disposal will be at Conservation Services Incorporated (CSI).

The central staging area is located on the northeast comer of Building 256.

Comment 6:

New Format

Old Format

Page 16, first paragraph Section 4.3

What certified facility(s) does the Army intend to use for the disposal of the

contaminated soils?

Response: Conservation Services, Inc., is the intended facility for petroleum contaminated

soil.

CDH Comments

General Comments:

Comment: Reference is made to two stages of this project; however, it is unclear whether this

implementation letter addresses both phases, or just the first. The maps are

confusing, and the state would like to know when the non-petroleum USTs will

be removed, and when information on this phase of the project will be received.

Response: The IL has been rewritten to specifically address Phase I and Phase Il activities

in Sections 2.0, 2.1, and 2.2. Phase II activities will be addressed in the

Consolidated Implementation letter.

Comment: There appears to be a discrepancy between this document and the previous

versions of the implementation letter. In the previous versions the Army

referenced 21 petroleum tanks; this version references 19. Please explain this

discrepancy. If any tanks are to be left in service, they must be registered with

the state.

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Response: Sections 2.0, 2. 1, and 2.2 have been rewritten to address this discrepancy.

Twenty-two petroleum tanks are referenced in the IL. The 21 originally

referenced and the addition of a recently discovered UST north of North Plants.

Specific Comments

Comment 1:

New Format

Old Format Sections 2 and 3

Page 2, second paragraph

The third sentence states that phase two will include the removal of petroleum

storage tanks not registered with the state. The fourth sentence states that all

tanks to be removed during this project are listed in Tables 1- 1, 1-2, and 1-3. The

tanks listed in 1-2, and tank NN0201 are hazardous material or hazardous waste

storage tanks. This information is contradictory, please clarify. The guidance

documents listed in this document apply to petroleum storage tanks. The removal

of tanks which contained hazardous materials or waste is not discussed in this

document. Please supply a plan for the removal of these tanks. This plan must

list ARARs including 40 CFR 268, Colorado Hazardous Waste Management,

Colorado Revised Statues, Sections 25-15-301 et seq. (1989 & Supp. 1993), and

6 CCR 1007-3, Part 268.

Response: Section 2 has been rewritten to describe the tanks included in Phase I and Phase 11

activities and list hazardous substance and petroleum storage tank ARARs.

Section 3 has been added to address removal of hazardous substance USTs,

associated with Phase I activities.

Comment 2:

Old Format New Format

Page 2, third paragraph Sections 2 and 3

The tanks scheduled to be removed during the first phase of this project are listed.

Where is the list for the tanks which will be removed during the second phase.

Will all remaining ranks listed in Table 1-1, 1-2, and 1-3 be removed during the

second phase? Again, the protocols listed in this document are for removal of

petroleum storage tanks and are not directly applicable to hazardous material and

wastetanks.

Response: See response to Comment I above.

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Comment 3:

Old Format New Format

Page 9 Section 2.4, Section 3

The documents listed on this page refer to petroleum storage tanks only. Please

describe how non-petroleum tanks will be handled.

Response: ARARs for hazardous substance tanks will been added to Section 2.4. Section 3

has been added to describe hazardous substance tank removal.

Comment 4:

Old Format New Format

Page 12, last paragraph Section 3.3, Section 4.3

Page 13, second paragraph

The discussion on removing tank contents and piping residuals does not describe

the handling and disposal of the residuals. A decision tree on the handling of

these wastes would be helpful.

Response: The handling and disposal of hazardous residuals is addressed in Section 3.3. The

handling and disposal of petroleum residue is discussed in Section 4.3.

Comment 5:

Old Format New Format

Page 14, third paragraph Section 4, Section 5

The document states that the identification of contamination around USTs and a

sampling plan are presented in the work plan. The work plan is also referenced

in many of the responses to comments. The regulatory agencies do not receive

and review work plans. The requested information needs to be supplied to the

agencies either by responses to comments, or by supplying he agencies with the

work plan. The state is not able to determine whether this project is protective of

public health and the environment, or whether it meets the substantive

requirements of sate laws without the additional information. Missing information

includes waste handling and disposal information, sampling plans and the levels

the Army proposes as clean levels for the soils.

Response: Sampling and waste handling has been addressed in Section 4 and Section 5 of

the IL. Soils will be cleaned to Remedial Action Category I (RACI) standard.

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Comment 6:

Old Format New Format

Page 16, second paragraph

Soil found with contamination other than petroleum hydrocarbons will be

addressed in the Feasibility study. This is acceptable as long as the contents of

the tanks were petroleum hydrocarbons. If other contamination is found that is

related to the removed tank, this soil contamination should be addressed at the

time of tank removal in accordance with 40 CFR 268, Colorado Hazardous Waste

Managements Act, Colorado Revised Statues, Sections 25-15-301, et seq. (1989

& Supplemental 1993), and 6 CCR 1007-3, Part 268.

Response: ARARs for hazardous materials are addressed in Section 2.4. For the tanks to be

removed in Phase 1, soil contaminated only with the removed tank products will

be addressed in this IL.

Comment 7:

Old Format New Format

Page 17, section 3.11. Section 8.0

The schedule only states when the project will be completed. Please outline a

general proposed time frame for these phases of this project, and when phase one

is scheduled to begin.

Response: The early start date listed corresponds to the start of the Decision Document.

Phase I field activities will begin upon approval of this IL. Scheduling for

Phase Il is discussed in Section 2.2, and in the Consolidated Implementation letter

for South Plants.

Comment 8: Responses to EPA and state comments. The work plan is referenced extensively

in these comments. Again the state and EPA have not been supplied a copy of

the work plan. Supplying a copy of the work plan is not necessary, but the

requested additional information must be supplied for the state to evaluate the

protection of public health and the environment, and to assure appropriate

procedures are being followed.

Response: Additional information and detail of how the work is to be completed has been

added to this IL. Sections 3.0, 4.0, and 5.0 detail the UST removal and waste

disposal operations to be conducted under this IL.

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Comment 9: Response to state Comment 3. The state still requests additional information on

the past and present contents of the USTs. The response reference to Table 3-1

is confusing because the document contains no such table. Please supply this

information.

Response: The past contents and suspected past contents are listed in the executive summary.

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