### TECHNICAL SUPPORT FORENVIRONMENTAL 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 THISREPORT REPRESENT THEOFFICIALPOSITION OFTHEDEPARTMENT OFTHEARMY UNLESS EXPRESSLY MODIFIED BY A SUBSEQUENT DOCUMENT. THIS REPORT CONSTITUTES THE RELEVANT PORTION OF THE ADMINISTRATIVE RECORD FOR THIS CERCLA OPERABLE UNIT. THE USE OFTRADE 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.


# M9513475TABLE OF CONTENIS Section Page

EXECUTIVE SUMMARY ............................................ vi 1.0 INTRODUCTION ................................................ I 1.1 BACKGROUND ............................................ I 1.1.1 Decision Documents .................................... 2 2.0 LOGISTICS HISTORY ........................................... 3 2.1 UNDERGROUND STORAGE TANK INFORMATION ................ 3 2.2 USAGE ANALYSIS .......................................... 3 2.3 ARARs ................................ . ... ... ..... ...... 13 3.0 HAZARDOUS SUBSTANCEAVASTE STORAGE TANK REMOVAL PLAN .... 17 3.1 TANK SURVEY ............................................ 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 High Pressure Wash .................................... 19 3.7.2 ' Hydroblast .............................. ..... ........ 19 3.7.3 Chemical Wash ....................................... 19 3.8 TANK REMOVAL FOR DEMOLITION ........................... 20 3.9 SOIL SAMPLING ........................................... 20 4.0 PETROLEUM UNDERGROUND STORAGE TANK REMOVAL PLAN ....... . )I 4.1 TANK SURVEY ............................. .............. 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 SAMPLING ........................................... 24 4.9 REMOVED UNDERGROUND STORAGE TANKS ................... . 24

RMA\0760 Ii/10/94 10:18 am ap

### 5.0 WASTEMANAGEMENT ......................................... 26 5.1 SOLID WASTES ........................................... 27 5.2 LIQUID WASTES .......................................... 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 DOCUMENTATION ............................................. 31 

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

RNIA\0760 11/10/94 10:18 am apLIST OF TABLES Page Executive List ofPhase I Underground Storage Tanks to be Removed .............. ES Summary 2.1-1 Petroleum Underground Storage Tanks atRocky Mountain Arsenal ......... 4 2.1-2 Registered Underground Storage Tanks to be Removed . .................................. ....... ....... 9 2.1-3 Non-Registered Petroleum Underground Storage Tanks tobe Removed ........................................ 10 2.1-4 Nonregulated Compressed Propane Underground Storage Tanks to be Removed ............................................ 11 2.1-5 Hazardous Substance/Hazardous Waste Underground Storage Tanks to be Removed .................................. 12

RMA\0760 11/10/94 10:18 am apLIST OF FIGURES Page 2.1-1 North Plants Area Underground Storage Tanks at Rocky Mountain Arsenal ...................................... 5 2.1-2 South Plants Area Underground Storage Tanks at Rocky Mountain Arsenal ...................................... 6 2.1-3 Rail Yard Area Underground Storage Tanks at Rocky Mountain A rsenal ........................................... 7 2.1-4 Old Toxic Storage Yard Underground Storage Tank at Rocky Mountain Arsenal ..................................... 8

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### LIST OFACRONYMS AND ABBREVIATIONS API American Petroleum Institute ARAR Applicable or Relevant and Appropriate Requirement Army U.S. Department ofthe Army BTEX benzene, toluene, ethylene, and total xylenes CCR Colorado Code ofRegulations CDH Colorado Department ofHealth CERCLA ComprehensiveEnvironmental Response,Compensation, andLiabilityActof1980 CFR Code ofFederal 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 ofSignificant 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 ofDecision 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 ofthe Final Implementation letter (IL) for Underground Storage Tank (UST) Monitoring and Removal include the deletion oftwo tanks which were believed to be associated with operation in North Plants, one tank in South Plants, one tank in Section 09 which is undercontrol ofthe Federal Aviation Administration, one tankin Section 12 which is under control ofthe Fort Carson Director ofEngineering and Housing. Additionally, all tanks owned or leasedby Shell Oil Company (Shell) have beenremoved 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 lastknown contents ofall tanks listed in this IL have been identified and presented in theExecutive Summary table.
The attached table identifies the USTs to be removed upon approval ofthis IL.

vi RMA\0760 11/10/94 10:18 am apExecutive Summary - Underground Storage Tanks at Rocky Mountain Arsenal Page Iof 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(W1 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 II T(X)02 632 176258 2172835 40,(XX) Active Diesel Fuel 12 TOM1 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 TW0I** 627 177329 2172700 1,100 Used Oil 20 T(M3t 329 179244 2192729 10,000 Benzene 21 T(W1 633 175999 2172998 1,000 Propane 22 TOOOIf IQ2 190415 2186535 1,5W Fuel Oil 23 TWOIt 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 ap1.0 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) forthe Chemical Process-Related Activities Interim Response Action (IRA). The purpose ofthis IL is to outline the basis and plan for decontamination, removal, and disposal ofUSTs from RMA.

1.1 BACKGROUND RMA occupies more than 17,000 acres (approximately 27 square miles) in Adams County, directly northeast ofmetropolitan Denver, Colorado. Theproperty waspurchased by the United States government in 1942 andwas used duringWorldWarIl asthe site forthe manufacture and assembly ofchemical 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, forthe manufacture ofvariousinsecticides andherbicides. 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 ofthe Army (Army), the U.S. Department ofInterior Fish andWildlife 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 tobe necessary and appropriate. The Chemical Process-Related Activities IRA was not oneofthe original IRAs, but

RNIA\0760 11/10/94 10:18 am ap

### hasbeen added totheprogram. Theremediation ofUSTs isadiscrete element ofthe Chemical Process-Related Activities IRA.
1.1.1 Decision Documents The IRA alternatives assessment and decision process forthe USTs atRMA will be a discrete elementofthe Chemical Process-Related Activities IRA. This elementwillbe conducted aspart ofthe IRAprocess for RMA in accordance with the FFA and the Technical Program Plan. As specified in theFFA, an IRA must beconsistent with andcontribute totheefficient performance ofthe Final Remedy selected in the Record ofDecision (ROD).
Alternatives for the USTs have been reviewed based on their overall protectiveness ofhuman 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 ofcleaning and removing the USTs and disposing of them by cutting them up for scrap.

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2.0 LOGISTICS HISTORY The remediation ofUSTs 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 thesetanks, investigations will be conducted and closure reports will be written aspart ofthis 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 ofthe 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 isbelieved to be an out ofservice heating fuel storage tank installed during the construction ofNorth Plants. Since this tank was only recently discovered, it was not listed in the Decision Document, but will be removed as part ofthis 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 ofactivities
3 RMA\0760 11/10/94 10:18 am apTable 2. 1 -1 Petroleum Underground Storagc Tanks at Rocky Mountain Arsenal To Be Removed Page Iof 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(W1 329 179239 2182756 12,000 5 T(W2 329 179239 2192767 12,(X)O 6 T(M1 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 TOW1 833 185567 2183405 1,000 12 TMO1 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 TOOO1 627 177329 2172700 1, 1 M 19 TOOO1 1622 190415 2196535 1,500

Tank registered with state asapetroleum lank Tank isremoved t Tank possibly contained hazardous substance during operation f Tank witsdiscovered inJuly 1994 NA Not available GAL Gallon

VkAA/I IRf, I11MAM Q-SI qrn anTank T0001 I d

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Legend

Petroleum Underground Storage Bldg. 1622 a Petroleum Tank Registered with Tank T00011-----,dý3 MD02 Hazardous Substance/Hazordou Underground Storage Tank

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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:::ZBldg. 833 Rocky Mountain Arsenal Prepared by: Ebosco Services Incorpc Tank T0001* 

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Tank 03 Tank T0002 Bldg. 461 0 SC 

### -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 3 63 + + 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 Prepored: Jonuory 1992 M 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 

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SCALE N FEET 1:087.0 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,ctedTable 2.1-2 Registered Petroleum Underground Storage Tanks To Be Removed Page Iof 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 RMA/1216 11/10/94 10:20am anTable 2.1-3 Non-Registered Petroleum Underground Storage Tanks Page Iof I Tank Count TankNo. Bld-,. No. Northing Easting Approximate Size (Gal) Status I TWO1 329 179239 2182756 12,000 2 T(XX)2 329 179239 2192767 12,000 3 T0002 632 176259 2172835 40,0M Active 4 TOOO1 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 inJuly 1994 NA Not Availahle GAL Gallon RMA/I 188 11110/94 10:23 am apI Table 2.1-4 Nonregulated Compressed Propane UndergrOUnd Storage Tanks To Be Removed Page Iof I TankCount TankNo. 131do. No. Northing Easting ApproximateSize (Gal) I TWO1 633 175999 2172998 1,000

N

A NotAvailable GAL Gallon RMA/1237 11/10/94 10:22 am apTable 2.1-5 Hazardous Sbbstance/Hazardous Waste Underground Storage Tanks Page Iof 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 toclose 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 andforthe systematic removal anddemolition of the tanks. Tank materials will be segregated for the recycling of all salvageable metal. Polychlorinated biphenyl (PCB) contamination isa possibility for tankscontaining 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)

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### 40CFR 761.65 (b) (1) 40CFR 761-65 (c) (1)(iii) PCB Waste Disposal Records and Reports: 40CFR 761.202 (a) 40CFR 761.202 (b) 40 CFR761.202 (d) 40 CFR761.207 40 CFR761.208 (a) 40 CFR761.209 (a) 40 CFR761.215 40 CFR 761.218 (d) (1)
Potential ARARs for removal ofhazardous substance/waste USTs are briefly detailed below. Residues fromtanks mustbecharacterized in accordance with 6CCRIO07-3 Part 261 to determine ifthe residue is hazardous. " All residues, piping and ancillary equipment and structures and equipment contaminated with hazardous waste should be removed decontaminated. and managed ashazardous waste unless excluded under 6CCRIO07-3 Part 261.3(d) (6CCRIO07-3 Part 264.197) " Ignitable, reactive, orincompatible wastesmustbe managed inaccordance with 6CCRIO07-3 Part 264.198 to .199. " The removal of hazardous substance/waste USTs will be done in accordance withthe Colorado Underground Storage Tanks Law (CRS S25-18- 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 ofEmýissions ofVolatile 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 ofUSTs contaminated with ArmyAgents, will be consistent with the Department ofthe Armyregulationsthat areARARs. Armyregulations include AR385-131 (Safety Regulations forchemical 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 andAssociatedWeapon Systems), andAR420-420 (Solid and Hazardous Waste Management). Ifwastes from removal ofhazardous substance/waste USTs isdetermined to be hazardous and is sent off-site for treatment or disposal it will be done in accordance with the CERCLA Procedures forPlanning and Implementing offsite Response Actions (40CFR 300.440). Potential ARARs for removal ofpetroleum USTs are briefly summarized below. Residues from tanks should be characterized in accordance with UCCR 1007-3 Part 261 to determine ifthe residue is hazardous. Used oil should be managed in accordance with EPA standards for used oil to determine ifthe used oil is hazardous waste fuel, used oil fuel or specification used oil fuel (40 CFR 279). Ifresidual 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 StorageTanksLawCRS S25-18- 101 and theColorado UST Regulations (6CCR1007-5). Petro]eum-contaminated debris (CRS S25-18-101, et seq.) that fails the toxicity characteristic (et seq.) for hazardous waste codes DOI8-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 ofinert gas may cause air emissions that will be mana--ed in accordance with Colorado Regulation Number 7 - Control ofEmissions ofVolatile 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 ofChemical Agents and AssociatedWeapon Systems), andAR420-47 (Solid and Hazardous Waste Management).

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### Ifwastes from removal ofPetroleum USTs ishazardous and issent off-site itwillbe done soin accordance withthe CERCLA Procedures forplanning and Implementing off-site Response Actions (40 CFR.300.440).

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3.0 HAZARDOUS SUBSTANCE/WASTE STORAGE TANK REMOVAL PLAN 3.1 TANK SURVEY Priorto beginning any field work, a tank survey will be performed. The purpose ofthe survey will be to verify information regarding the tanks, including, but not limited to locations, dimensions, construction materials and ancillary equipment. Inaddition,the survey shallidentify which, ifany, ofthe tanks are onthe 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 ofthe sampling and characterization is to protect the safety and health ofworkers 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 ifthe 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 orotherresidues will be drained or pumped from the tank afterproper characterization. All pumps and hoses will be chemically compatible withthe liquid or sludge being pumped. Once asmuch liquid and sludge
aspossible ispumped fromthe tank, remaining contents willbe 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 ofthe Defense Logistics Agency at a certified offsite facility.

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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 ofthe lowerexplosive limit (LEL). Purging shall be accomplished by the introduction ofan inert gas,eithercarbon dioxide ornitrogen. Purging methodsutilizing liquids as thepurging medium shall notbe allowed. All displaced vapors ventilated will be removed from the surrounding work areausing flexible ducting. Vapors ofhazardous substances willbe treated using Reasonably Achievable Control Technology (RACT) before release into the atmosphere.
3.5 DISCONNECTION OFPIPING AND ANCILLARY EQUIPMENT Pipingandprocessequipment willberemoved asnecessaryto allowsafe removal and demolition oftanks. 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 ofseparately. The exteriors willbe 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 ofthese 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 sillbeplaced backinto the excavation and the rinse water collected, filtered, and transported to the CERCLA Wastewater Treatment Facility (WWTF).

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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 ofthe following: (1) By high pressure water wash; (2) hydroblast; and (3) chemical wash by use ofbleach, acid or caustic. The specific method will be selected based on characterization oftank contents, ifany. 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 precludetank entry, orwhen it isdetermined thatthis isthe mosteffective procedure.
3.7.2 Hvdroblast A hydroblast system is ahigh 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 ofthe residual contamination.

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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 waterwill beremoved eitherbyvacuum truck orapump lowered intothetank. Therinse waterwillbedrummed andhauled toCERCLAWWTFonce itisremoved fromthetank. 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 EPAmethod 1311 (extraction) and EPA methods 8270, 8080, 8150, 6010, and 7000.

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### 4.0 PETROLEUM UNDERGROUND STORAGE TANK REMOVAL PLAN Petroleum USTtankremoval willbe conducted inaccordance withthe followingregulations 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 ofState Clean-Up Guidelines, Levels and Management ofContaminated Materials (CDH, December, 1992) " Ground Water Monitoring Guidance, CDH Solid Waste and Incident Management Section (CDH, January 1991) " Title 25 Article 18 ofthe Colorado Revised Statute, 1989 as amended " Petroleum Product or Waste Sampling and Analysis Project Plan (March 1, 1991) " Removal and Disposal ofUsed Underground Petroleum Storage Tanks (API 1604) Safe Entry and Cleaning ofPetroleum Storage Tanks (API 2015) " Guidelines for Confined Space Work in the Petroleum Industry API 2217 " Interior Lining ofUnderground Storage Tanks API 1631
In addition, the work to be performed will comply with all applicable sections of7Colorado Code ofRegulations (CCR) 1003 Part 290,and40 CodeofFederal 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 tobeginning,any field work, a tank survey willbe performed. The purpose ofthe 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, ofthe tanks are on the PMRMA Real Property List. Information obtained/verified in the tank survey will be included in the Completion Report.

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4.2 SAMPLING AND CHARACTERIZATION OF TANK CONTENTS The purpose ofsampling and characterization isto protect the safety and health ofworkers and to characterize the wastes for treatment ordisposal. Prior toremoving any ofthe tank contents, theresidues willbe sampled andcharacterized todetermine whetherthe contents mustbe handled as a hazardous or special waste and to determine appropriate solutions for cleaning and decontamination. Sampling during tank removal will consist oftwo distinct sets of samples. First, the residual liquids and sludges in the tank will be sampled and analyzed forbenzene, toluene, ethyene, and totalxylenes, BTEX, metals, PCBs,anddicyclopentadiene (DCPD) (where use history indicates). Afterthe tankhasbeen removed, conformational soil sampleswill be collected from the material below the tank. Uponremoval ofwaste oil tanks, soil samples willbe analyzed using EPA Method 413, andEPA 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, orotherresidues willbe drained orpumped from the tank afterproper characterization. All pumps andhoses will bechemically compatible withthe liquid or sludge being pumped. After as much sludge as possible is pumped from the tank, the remaining contents will be removed through acombination ofresidual floating, manual scraping and shoveling, and applications ofabsorbent 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).

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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, ifthe air sample results indicate DCPD ispresent, thenthe displaced vapors will be treated using RACT. Theproposed RACT istopass the displaced vapors through a Granular Activated Carbon (GAC) column.
4.5 DISCONNECTION OF PIPING AND ANCILLARY EQUIPMENT Piping and processequipment willbe removed as necessary to allow safe removal anddemolition 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 methodsand requirementswill bedictated bythe interiorcondition ofthe tank, surrounding obstructions or interferences, and the capabilities or limitations ofthe
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### demolition equipment. The methods may include the independent or combined use ofacrane, excavator, ormanual handling ofthetank. Oncethetanks are removed fromtheexcavation, any remaining soil is scraped offand the outside ofthe tankrinsed. Forthose tanks in South Plants area, the rinse water and soil will be directed back into the excavation. For tanks located elsewhere, the soil willbeplaced backintotheexcavation andthe rinse watercollected, 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. Ifpetroleum 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 willbe analyzed forBTEX utilizingEPAMethod 8020and fortanks 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. Ifthe tank residue analytical resultsindicate that PCBs orothercontaminants exist, the soil samples at those specific tank locations will be analyzed for PCBs and other identified contaminants.

4.9 REMOVED UNDERGROUND STORAGE TANKS ForUSTs removed prior tothe approval ofthis Implementation Letter the following procedure willbe followed tocheck forcontamination. Based onthe coordinates ofthetank, a geophysical survey willbeperformed to determine the boundary ofthe excavation. Based onthe size ofthe
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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.

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### 5.0 WASTE MANAGEMENT Wastes generated during theperformance ofPhase Imay include fuel, sludge,rinse water, scrap metal, andpossibly 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 toCSI 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 ofthe water. Ifpetroleum product is observed tobe floating on therinse water, it will be disposed ofby DRMS through PMRMA Logistics. Disposal ofpetroleum-contaminated soil will be at CSI. A facility-specific batch number and manifest will be required for each load ofcontaminated soil removed from Rocky Mountain Arsenal (RMA).
Concrete or asphalt encountered during tank removal processes willbe consolidated at alocation 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 ofthis IL.
All tanks willbe transported to acentral location tobe cut upand putintoaroll-offfor 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.. . ........

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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 atruck 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 ofgeneration. 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-offreceptacles 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 offreceptacles-not segregated. Metals such as copper, aluminum, and brass, as well as other miscellaneous items that have a resale value will also be segregated.

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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 isencountered, groundwater samples will be collected along with the soil samples. The number ofsamples required is afunction ofthe tank size. Small USTs may require lessthan the three-sample minimum (per 7 CCR 1003 Part 280), whereas large USTs (greater than 8,000 gallons) may require more than three samples. Soilsthathave beencontaminated withpetroleum hydrocarbons will be excavated and disposed ofonly at acertified facility. Ifproduct is visible in the soil afterremoval ofhazardous substance tanks,the soilwill be containerized in 55 -allon drums. The drums will subsequently be sampled and the soil characterized forproper disposal.
5.6 WASTE MATERIAL STORAGE Each step ofthe wastemanagement procedure has uniqueregulatory controlsthat facilitate waste management options and ensure that all waste materials generated during UST removal are handled in a safe and responsible manner.
Waste rinsewater 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 thatthe waste volume does not exceed 55 gallons ofhazardous waste or one quart ofacutely 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 ofat CSI.

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### 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).

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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 ofsupervisor and employees " Hazard assessment and site safety " Description ofPPE to be used " Site personnel safety training " Medical surveillance " Air monitoring and safety training " Decontamination procedures " Site control " Emergency procedures

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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 ofmaterial removed and treated " Tank destruction certificates Sample locations and corresponding identification codes " Chain ofcustody forms " Analytical laboratory results Copies ofmanifests and certifications Identification ofsampler, analyticallaboratory, transporter, andacceptor forallwastes encountered

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8.0 COSTESTIMATE 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 hasundergone majorrevision to accommodate responses tocornments,from theEPA and the CDH. Each comment and response has been keyed to this edition ofthe IL. Each comment on the previous edition (old format) has been referenced in this edition (new format).

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### 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 acomplete review. Response: The ILpresents a general overview ofthe program. Details ofhow the work will be accomplished have been addedto version 3.1 ofthe IL. Comment 2: The document provides no indication ofhow contamination around the USTs willbe identified orwhat response actions will be taken. Response: Identification ofcontamination 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 TankFacility Owner/Operator GuidanceDocument forInitial SiteCharacterization Second-Level Site Assessment, Use ofStateCleanup Guidelines, and Management ofContaminated 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 alsoaddresshowcontamination ofthe surrounding soils will be identified and what remedial actions will be taken to clean up contaminated soils. Response: Identification and removal ofpetroleum contaminated soil are included in Section 5.5 ofthe IL. Contaminated soil willbe disposed ofin accordance with Section 5.0 ofthe IL. While the excavation ofcontaminated soil is proceeding, soil gas sampling will continue tobe conducted to provide immediate results as to the extent of contamination. The removal of contaminated soil will cease whenthe soil gas survey indicates thepetroleum contamination no longer exists and no contamination in excess of action levels is detected in the confirmation samples. Ifat any time contaminants otherthanpetroleum hydrocarbons are encountered during the removal ofpetroleum-contaminated soil, the excavation will cease immediately.

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### Comment 2: Old Format New Fon-nat Page 10, Section 1.2 Section 2.4 Backfilling andregrading once buried tanks are removed should alsobe discussed orreferenced as appropriate. Response: Backfilling andregrading activities havebeen added totheIL. Theexcavation will remain openwhile awaiting analytical confirmation about contamination beforebackfilling. The open excavation willbe surrounded with a portable fence toprevent entrance by unauthorized personnel and wildlife. Upon confirmation that a siteisuncontaminated, theexcavation will be backfilled to original grade and the siterestored and cleaned up. Ifpetroleum contamination is found,the contaminated soil willbeexcavated and disposed offsite at apermitted facility. The excavation will thenbe backfilled with clean material tooriginal grade. Comment 3: Old Format New Format Page 11, Section 3.0 Sections 3.0 and4.0 Please refer to previous comments concerning site/soil remediation and restoration. There shouldbe a discussion ofthese items in this section. Response: Seethe responses to specific comments I and 2. Detail hasbeen 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 thecontents ofthese USTs? There should alsobe a discussion as towhere Sampling andAnalysis for adjacent soilswillbe addressed. Response: The executive summary table liststhepast contents ofthe USTs. Sampling during tank removal willconsist ofthree distinct sets ofsamples. First,the residualliquids and sludges in the tank will be sampled and analyzed for BTEX, metals, PCBs, and dicyclopentadiene
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(DCPD) (whereuse history indicates). Next, the area aroundthe 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 tankremoval. Comment 5: Old Format New Format Page 13, Section 3.4 Sections 3.4, 4.4 There should be a discussion ofhow 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 ofvapors during UST removal operations. Given the size ofthe USTs to be removed during Phase I, preliminary calculations indicate the volume ofvapors liberated during Petroleum USTtank removal does notreach the threshold for preparation ofan 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 ofliquid from the bottom ofthe 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

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Response: Section 5.0 addresses waste management forthis 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-offfor disposal as scrap metal. Petroleum-contarninated soil will be excavated andplaced in a truck tobe transported to apermitted facility. Drummed wastes willbe sampled, manifested, and disposed ofaccordingly. 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.

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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 ofContaminated Materials (Dec. 1992). Response: The Reference to the Guidance Document will be updated. Comment 2: Page 10. The list ofapplicable statutes should include Title 25, Article 18 ofthe Colorado Revised Statute, 1989 as amended. Response: The reference will be added to the list ofapplicable 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 ofpetroleum products (volatile, sernivolatile, etc.) Response: The Executive Summary Table ofthe Implementation Letter (IL) lists the past or present contents ofthe underground storage tanks (USTs). As specified in Sections 3.9 and4.8, 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 EPAMethod 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). Ifthe tank residue analytical results indicate that polychlorinated biphenyls (PCBs) or other contaminants exist, the soil samples at those specific tanklocations will befurther analyzed for PCBsand other identified contaminants. For tanks containing hazardous substances the soil samples will be analyzed using EPA Method 1311 (extraction), andEPA Methods: 8270, 8080, 8150, 6010, and 7000 for analysis.

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### Comment4: 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 sentencethen statesthatchemical analyses will only be performed ifinsufficient information is available to characterize the waste. Please clarify. Response: The wording ofthis section hasbeen modified to reflect that chemical sampling will be performed to determine tank contents and characterize them for disposal. Sampling during tank removal will consist of3 distinct sets ofsamples. 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 toidentify potential areas ofcontamination, and finally confirmation soil samples will be collected fromthe material under the tank aftertank 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 ofthese tanks, reference is made only to interior cleaning. Please include a discussion ofhandling of exterior cleaning and any associated wastes produced. Response: Section 3.6 ofthe IL covers tank exterior cleaning. The tanks will beremoved from theexcavation, scraped ontheoutside forremaining soil and rinsed. Forthose tanksin the South Plants area, the rinse water and soil will be directed backinto the excavation. For tanks located elsewhere, the soil will be placed backinto the excavation and therinse water collected, filtered, and transported to the CERCLA Wastewater Treatment Facility.

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### Comments on FinalImplementationLetter

Underground Storage Tank MonitoringandRemoval February1994 EPA Comments General Comments: The responses to EPA's previous comments have not been adequately addressed. Most of theresponses to commentsreferto the workplan,which isnot furnished tothe 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 ofhow 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 ofthe Draft Final Workplan and Sections 4.0 through 4.1 and Sections 4.3 through 4.3.2 ofthe 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 previouscomments on the DraftFinal 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 ofpetroleum tanks. Please clarify. Response: Sections 2.0, 2.2 and 2.3 ofthe 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 andTankNo.TOOOI does not show upin any ofthe 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 fromthereport. Ithasbeen returned asa tanktobe 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 datain Table 1-1 which shows 6tanks 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 4.8have been added to this IL which address sampling and analysis requirements for removal ofUSTs.

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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 areabe located? Response: The Army intends todispose ofwaste as soon asproper characterization has been completed. Offpost disposal will be atConservation Services Incorporated (CSI). The central staging area is located on thenortheast comer ofBuilding 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 ismadeto two stages ofthisproject; however, itisunclear whether this implementation letter addresses both phases, orjust the first. The maps are confusing, and the state would like to know when the non-petroleum USTs will be removed, and when information onthis 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. Ifany 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 ofarecently discovered UST north ofNorth 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 ofpetroleum storage tanks not registered with the state. The fourth sentence states that all tanks toberemoved during thisproject are listedinTables 1-1,1-2, and 1-3. The tanks listed in 1-2, and tank NN0201 are hazardous material orhazardous waste storage tanks. This information is contradictory, please clarify. The guidance documents listedin thisdocument apply topetroleum storage tanks. The removal of tanks which contained hazardous materials or waste is not discussed in this document. Please supply aplan forthe removal ofthesetanks. This plan must list ARARs including 40 CFR 268, Colorado Hazardous Waste Management, Colorado Revised Statues, Sections 25-15-301 etseq. (1989 &Supp. 1993), and 6 CCR 1007-3, Part 268. Response: Section 2hasbeenrewritten todescribe thetanksincluded inPhase IandPhase 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 Thetanks scheduled toberemoved duringthe firstphase ofthisproject are listed. Where is the list forthe tanks which will be removed during the second phase. Will all remaining ranks listed in Table 1-1, 1-2, and 1-3 beremoved during the second phase? Again, the protocols listed in this document are for removal of petroleum storage tanks and are not directly applicable tohazardous material and wastetanks. Response: See response to Comment I above. 5 RMA/1128 11/10/94 1:39 pm ap.......... . .. . ......

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### Comment3: Old Format New Format Page 9 Section 2.4, Section 3 The documents listed on this page referto 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, lastparagraph 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 ofthe residuals. A decision tree on the handling of these wastes would be helpful. Response: Thehandling anddisposal ofhazardous residuals is addressedin Section 3.3. The handling and disposal ofpetroleum 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 ofcontamination around USTs and a sampling plan are presented in the work plan. The work plan is also referenced in many ofthe 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 workplan. The state is notable to determine whether this project isprotective of public health and the environment, or whether it meets the substantive requirements ofsate laws without theadditional information. Missinginformation 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. Ifother contamination is found that is related to the removed tank, this soil contamination should be addressed at the time oftankremoval in accordance with 40CFR 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. Forthe 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 ofthis 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 isdiscussed in Section 2.2, andin theConsolidated Implementation letter for South Plants. Comment 8: Responses to EPA and state comments. The work plan isreferenced 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 ofhow 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 andpresent contents ofthe USTs. The response reference toTable 3-1 is confusing because the document contains no such table. Please supply this information. Response: Thepast contents and suspectedpastcontents arelistedin theexecutive summary.

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