RECORD OF DECISION (RODS) - Records CollectionsEPA/ROD/R05-04/676 2004 EPA Superfund Record of...

EPA/ROD/R05-04/676 2004

EPA Superfund

Record of Decision:

JOLIET ARMY AMMUNITION PLANT (LOAD-ASSEMBLY-PACKING AREA) EPA ID: IL0210090049 OU 01 JOLIET, IL 08/20/2004

Joliet Army Ammunition Plant

Wilmington, Will County, Illinois

Record of Decision for the Soil Operable Unit Interim

Sites

June 2004

Final

TABLE OF CONTENTS

1 SITE NAME, LOCATION, AND DESCRIPTION .......................................................................................1

2 SITE HISTORY............................................................................................................................................ 2-1

3 HIGHLIGHTS OF COMMUNITY PARTICIPATION........................................................................... 3-1

4 SCOPE AND ROLE OF OPERABLE UNITS OR RESPONSE ACTIONS .......................................... 4-1

5 SITE CHARACTERISTICS ....................................................................................................................... 5-1 5.1 SRU1, EXPLOSIVES IN SOIL.................................................................................................................... 5-1

5.1.1 Site L1................................................................................................................................................ 5-1 5.1.2 Site L2................................................................................................................................................ 5-2 5.1.3 Site L7................................................................................................................................................ 5-2 5.1.4 Site L8................................................................................................................................................ 5-3 5.1.5 Site L9 (Group 3)............................................................................................................................... 5-3 5.1.6 Site L10.............................................................................................................................................. 5-4 5.1.7 Site L14.............................................................................................................................................. 5-4 5.1.8 Site M2............................................................................................................................................... 5-4

5.2 SRU2, METALS IN SOIL .......................................................................................................................... 5-5 5.2.1 Site L2................................................................................................................................................ 5-6 5.2.2 Site L3................................................................................................................................................ 5-6 5.2.3 Site L5................................................................................................................................................ 5-7 5.2.4 Site L23A............................................................................................................................................ 5-7 5.2.5 Site M4............................................................................................................................................... 5-8 5.2.6 Site M12............................................................................................................................................. 5-8

5.3 SRU3, EXPLOSIVES AND METALS IN SOIL .............................................................................................. 5-9 5.3.1 Site L3................................................................................................................................................ 5-9 5.3.2 Site M3............................................................................................................................................. 5-10

5.4 SRU5, ORGANICS IN SOIL..................................................................................................................... 5-11 5.4.1 Site L1.............................................................................................................................................. 5-11 5.4.2 Site L5 (Salvage Yard) ..................................................................................................................... 5-12

6 SUMMARY OF SITE RISKS ..................................................................................................................... 6-1 6.1 HUMAN HEALTH RISK ............................................................................................................................ 6-1

6.1.1 Human Health Risk Assessment......................................................................................................... 6-1 6.2 ECOLOGICAL RISK ASSESSMENT............................................................................................................. 6-2

6.2.1 Ecological Risk Assessments Conducted ........................................................................................... 6-2 6.2.2 Development of Preliminary Remediation Goals .............................................................................. 6-2

7 REMEDIAL ACTION OBJECTIVES (RAOS) ........................................................................................ 7-1 7.1 DEVELOPMENT OF REMEDIATION GOALS (RGS)..................................................................................... 7-1

8 DESCRIPTION OF ALTERNATIVES...................................................................................................... 8-1 8.1 SOIL OPERABLE UNIT ............................................................................................................................. 8-1

8.1.1 Common Soil Alternative Remedies................................................................................................... 8-1 8.1.2 Common Soil Actions......................................................................................................................... 8-2 8.1.3 SRU1: Explosives in Soil ................................................................................................................... 8-6 8.1.4 SRU2: Metals in Soil ......................................................................................................................... 8-7

JOAAP Record of Decision Interim Soil Operable Unit Final i

8.1.5 SRU3: Explosives and Metals in Soil ................................................................................................ 8-7 8.1.6 SRU5: Organics in Soil ..................................................................................................................... 8-7

9 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES................................................. 9-1 9.1 NINE EVALUATION CRITERIA.................................................................................................................. 9-1 9.2 SOIL OPERABLE UNIT ............................................................................................................................. 9-2

9.2.1 SRU1: Explosives in Soil ................................................................................................................... 9-2 9.2.2 SRU2: Metals in Soil ......................................................................................................................... 9-5 9.2.3 SRU3: Explosives and Metals in Soil ................................................................................................ 9-8 9.2.4 SRU5: Organics in Soil ................................................................................................................... 9-11 9.2.5 Summary of Selected Remedies for all SRUs................................................................................... 9-15

9.3 COST SUMMARY FOR SELECTED REMEDIES .......................................................................................... 9-16 10 SELECTED REMEDIES ...................................................................................................................... 10-1

10.1 SOIL OPERABLE UNIT ........................................................................................................................... 10-2 10.1.1 Common Soil Operable Unit Actions ......................................................................................... 10-2 10.1.2 SRU1: Explosives in Soil Excavation/Treatment.................................................................... 10-4 10.1.3 SRU2: Metals in Soil Excavation/Disposal ............................................................................ 10-6 10.1.4 SRU3: Explosives and Metals in Soil Excavation/Disposal ................................................... 10-6 10.1.5 SRU5: Organics in Soil Excavation/Treatment...................................................................... 10-7

11 STATUTORY DETERMINATIONS................................................................................................... 11-1 11.1 PROTECTION TO HUMAN HEALTH AND THE ENVIRONMENT.................................................................. 11-3 11.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS) AND TO-BE-CONSIDERED (TBC) GUIDANCE......................................................................................................................... 11-3

11.2.1 Action Specific ARARs................................................................................................................. 11-3 11.2.2 Location-specific ARARs and TBC Guidance ............................................................................. 11-8

11.3 COST EFFECTIVENESS ......................................................................................................................... 11-10 11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT TECHNOLOGIES (OR RESOURCE RECOVERY TECHNOLOGIES) TO THE MAXIMUM EXTENT PRACTICABLE.......................................................... 11-10

11.4.1 SRU1: Explosives in Soil........................................................................................................... 11-10 11.4.2 SRU2: Metals in Soil ................................................................................................................. 11-10 11.4.3 SRU3: Explosives and Metals in Soil ........................................................................................ 11-11 11.4.4 SRU5: Organics in Soil ............................................................................................................. 11-11

11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT .................................................................. 11-11 12 DOCUMENTATION OF SIGNIFICANT CHANGES ...................................................................... 12-1

12.1 DOCUMENTATION OF OTHER CHANGES ................................................................................................ 12-1 13 REFERENCES ....................................................................................................................................... 13-1

14 COMMUNITY PARTICIPATION RESPONSIVENESS SUMMARY..................................................1

JOAAP Record of Decision Interim Soil Operable Unit Final ii

APPENDICES

Appendix A: Joliet Army Ammunition Plant (JOAAP) Management Team Agreement on Cleanup Approach and Goals Appendix B: Summary of Estimated Costs of Remedial Alternatives for the four SRUs

JOAAP Record of Decision Soil & Groundwater OUs – October, 1998 pg. i

List of Figures (Section at Back of ROD)

Figure 1 Study Sites and Future Land Use Plan.................................Figure Section at back of ROD Figure 2 Soil Operable Unit, Summary of SRUs .........................................................Figure Section Figure 3 Site L1 Excavation and Pre-sampling Plan ...................................................Figure Section Figure 4 Site L2 Excavation and Pre-sampling Plan ...................................................Figure Section Figure 5 Site L7 Excavation and Pre-sampling Plan………………………………...Figure Section Figure 6 Site L8 Excavation and Pre-sampling Plan………………………………. .Figure Section Figure 7 Site L9 Excavation and Pre-sampling Plan………………………………...Figure Section Figure 8 Site L10 Excavation and Pre-sampling Plan……..………………………...Figure Section Figure 9 Site L14 Excavation and Pre-sampling Plan………..……………………...Figure Section Figure 10 Site M2 Excavation and Pre-sampling Plan………………………...……...Figure Section Figure 11 Site L3 Excavation and Pre-sampling Plan………………………………...Figure Section Figure 12 Site L5 Excavation and Pre-sampling Plan………………………………...Figure Section Figure 13 Site L23A Excavation and Pre-sampling Plan……………………………..Figure Section Figure 14 Site M4 Excavation and Pre-sampling Plan………...……………………...Figure Section Figure 15 Site M12 Excavation and Pre-sampling Plan……………….……………...Figure Section Figure 16 Site M3 Excavation and Pre-sampling Plan...................................................Figure Section

List of Tables Table 4-1 Soil Remediation Units..............................................................................................................4-2 Table 5-1 Site and Sub-areas of SRU1 (Explosives in Soil)......................................................................5-1 Table 5-2 Exceedances of Remediation Goals for SRU 1 .........................................................................5-5 Table 5-3 Sites and Sub-areas of SRU2 (Metals in Soil)..........................................................................5-6 Table 5-4 Exceedances of Remediation Goals in SRU2............................................................................5-9 Table 5-5 Sites and Sub-areas of SRU3 (Explosives and Metals in Soil) .................................................5-9 Table 5-6 Exceedances of Remediation Goals in SRU3..........................................................................5-11 Table 5-7 Sites and Sub-areas of SRU5 (Organics in Soil) .....................................................................5-11 Table 5-8 Exceedances of Remediation Goals in SRU5..........................................................................5-12 Table 6-1 Preliminary Remediation Goals Developed by the Management Team for the Interim ROD

Sites....................................................................................................................................................6-4 Table 6-2 Polynuclear Aromatic Hydrocarbons Preliminary Remediation Goals ...................................6-11 Table 9-1 Evaluation of Remedial Alternatives for SRU1 (Explosives in Soil).......................................9-4 Table 9-2 Evaluation of Remedial Alternatives for SRU2 (Metals in Soil) .............................................9-7 Table 9-3 Evaluation of Remedial Alternatives for SRU3 (Explosives and Metals in Soil) ..................9-11 Table 9-4 Evaluation of Remedial Alternatives for SRU5 (Organics in Soil).........................................9-15 Table 9-5 Summary of Recommended Remedial Alternatives for all SRUs (LAP and MFG Areas) ....9-16 Table 9-6 Summary of Total and Component Costs for the Selected Remedy for Each SRU................9-17 Table 10-1 Selected Remedies and Costs of Cleanup for each SRU.......................................................10-1

JOAAP Record of Decision Interim Soil Operable Unit March 2004 pg. ii

List of Acronyms AEHA Army Environmental Hygiene Agency ARAR Applicable or Relevant and Appropriate Requirement AST Above-Ground Storage Tank BNA Base-Neutral-Acid, also referred to as semivolatiles BTAG Biological Technical Assistance Group BTEX Benzene, Toluene, Ethylbenzene, and Xylenes CERCLA Comprehensive Environmental Response Compensation and Liability Act COC Chemical of Concern CY Cubic Yard CFR Code of Federal Regulations CHPPM Center for Health Promotion and Preventive Medicine DNB Dinitrobenzene DNT Dinitrotoluene DQO Data Quality Objective ERA Ecological Risk Assessment FFA Federal Facility Agreement FFS Focused Feasibility Study FOST Finding of Suitability to Transfer FS Feasibility Study GMZ Groundwater Management Zone GOU Groundwater Operable Unit GRU Groundwater Remedial Unit HMX High Melting Explosive or Octahydro-1,3,5,7-Tetranitro-1,3,5,7-Tetrazocine IAC Illinois Administrative Code IEPA Illinois Environmental Protection Agency IRP Installation Restoration Program JOAAP Joliet Army Ammunition Plant LAP Load-Assemble-Package Area LDR Land Disposal Restriction MFG Manufacturing Area mg/kg Milligram per kilogram µg/g Microgram per gram µg/L Microgram per Liter MNTP Midewin National Tallgrass Prairie NA Not Applicable NB Nitrobenzene NC Chemical is not a Contaminant of Concern NCP National Contingency Plan NEPA National Environmental Policy Act NFA No Further Action NPDES National Pollutant Discharge Elimination System NPL National Priority List NT Nitrotoluene

JOAAP Record of Decision Interim Soil Operable Unit Final iii

PAH Polynuclear Aromatic Hydrocarbons PCB Polychlorinated Biphenyl PH1 Phase 1 (of the Remedial Investigation) PH2 Phase 2 (of the Remedial Investigation) ppm Part Per Million PP Proposed Plan PRG Preliminary Remediation Goal RAB Restoration Advisory Board RAG Risk Assessment Guidance RAO Remedial Action Objective RBC Risk-based Concentration RCRA Resource Conservation and Recovery Act RDX Royal Demolition Explosive or Cyclotrimethylenetrinitramine RG Remediation Goal RI Remedial Investigation ROD Record of Decision SARA Superfund Amendments and Reauthorization Act SF Square foot SOU Soil Operable Unit SRU Soil Remedial Unit TBC To Be Considered TBE To be evaluated after the public review period TCLP Toxicity Characteristic Leaching Procedure TNB 1,3,5-Trinitrobenzene TNT 2,4,6-Trinitrotoluene TPH Total Petroleum Hydrocarbons TSCA Toxic Substances Control Act USACE U.S. Army Corps of Engineers USAEC U.S. Army Environmental Center USATHAMA U.S. Army Toxic and Hazardous Materials Agency USDA U.S. Department of Agriculture USDA/FS U.S. Department of Agriculture, Forestry Service USEPA U.S. Environmental Protection Agency USFS U.S. Forest Service USFWS U.S. Fish and Wildlife Service UST Underground Storage Tank UXO Unexploded Ordnance VOC Volatile Organic Compound WCLF Will County Landfill

JOAAP Record of Decision Interim Soil Operable Unit Final iv

GLOSSARY Biodegradation A molecular degradation, or chemical breakdown, of an organic substance

resulting from metabolic action of living organisms (principally bacteria, fungi, algae, or yeast).

Bioremediation or Treatment

Process where the biological microorganisms are used to biodegrade the contaminants in soil and groundwater.

Excavation Design Values

Values that were considered to be in the upper range of protective values for human health and the environment and are used to guide excavations.

Groundwater Water beneath the earth’s surface between saturated soil and rock that supplies wells and springs.

GOU Groundwater operable unit (GOU). GOUs consist of sites where contaminated groundwater plumes were identified.

JOAAP Management Team

A Multi-agency Team comprised of the Army, U.S. Environmental Protection Agency, Illinois Environmental Protection Agency, Illinois Department of Natural Resources, U.S. Department of Agriculture, U.S. Forest Service, U.S. Fish and Wildlife tasked with developing a plan for remediation of the contaminated lands of the future Midewin National Tallgrass Prairie.

mg/kg Unit of concentration equivalent to µg/kg and parts per million (ppm) PCBs Chemical compounds commonly used as heat exchange agents in

transformers. Remediation Goal (RG)

A value considered to be protective of the human health and/or the environment based on a selected threshold.

RCRA Hazardous Wastes

Regulations for RCRA hazardous wastes are provided in 40 CFR 260 through 272. Characteristic wastes (shown as Dxxx) exhibit the characteristics of ignitability, corrosivity, reactivity, or toxicity. Listed wastes (shown as Fxxx, Kxxx, Pxxx, or Uxxx) are process wastes that are regulated under 40 CFR. The following characteristic and listed wastes have been identified as potentially existing at JOAAP:

D003 Explosives category based on 40 CFR 261.23 (6), (7) or (8) D006 Wastes that exhibit or are expected to exhibit, the characteristic

of toxicity for cadmium based on extraction procedure (EP) in SW846 Method 1310.

D008 Wastes that exhibit or are expected to exhibit, the characteristic of toxicity for lead based on extraction procedure (EP) in SW846 Method 1310.

D030 Wastes that have toxic characteristics (TC) for 2,4-Dinitro-toluene based on the TCLP in SW846 Method 1311

K046 Wastewater treatment sludge from the manufacturing, formulation and loading of lead-based initiating compounds

K047 Pink/red water from TNT operations. K048 Dissolved air floatation (DAF) float from the petroleum

refining industry. K111 product washwaters from the production of dinitrotoluene via

the nitration of toluene U220 Toluene as a raw material or commercial chemical product

RCRA Subtitle C landfill

A hazardous waste landfill disposal facility

RCRA Subtitle D A non-hazardous solid waste landfill disposal facility

JOAAP Record of Decision Interim Soil Operable Unit Final v

landfill Semivolatiles Carbon-containing compound which does not evaporate readily at ordinary

temperatures. Semivolatiles are also known as BNAs (Base-Neutral-Acids) SOU Soil Operable Unit (SOU). SOU consists of sites where contaminated soils,

sediments, and debris were identified. Special Wastes Special wastes are defined under the Illinois Environmental Protection Act as,

“any industrial process waste, pollution control waste or hazardous waste except as determined pursuant to Section 22.9 of this Act. “Special Waste” also means potentially infection medical waste. [Section 3.45]

TCLP Toxicity Characteristic Leaching Procedure. The laboratory procedure used to determine whether the toxic contaminants of concern leach from the waste at unacceptable levels.

VOC Volatile Organic Compound. A carbon-containing compound which evaporates readily at ordinary temperatures.

WCLF Will County Landfill (WCLF) This landfill will be a permitted special waste landfill (as defined in Section 22.9 of the Illinois Environmental Protection Act) and will also be a permitted RCRA Subtitle D landfill.

JOAAP Record of Decision Interim Soil Operable Unit Final vi

DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION Joliet Army Ammunition Plant, Interim Soil Operable Unit Sites Record of Decision Manufacturing and Load-Assemble-Package Areas Wilmington, Will County, Illinois STATEMENT OF BASIS AND PURPOSE This decision document presents the selected final remedies for the interim portion of the Soil Operable Unit (SOU), for the Joliet Army Ammunition Plant (JOAAP). These remedies are chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 and the National Contingency Plan (NCP). This decision is based on the Administrative Record file for this site. The United States Environmental Protection Agency (USEPA) Region 5 and the Illinois Environmental Protection Agency (IEPA) concur with the selected remedies. This document complies with and satisfies the intent of the National Environmental Policy Act (NEPA) of 1969. JOAAP has been addressed under the CERCLA program as two National Priority List (NPL) sites, the Manufacturing (MFG) Area and the Load-Assemble-Package (LAP) Area. The MFG and LAP Areas were listed on the NPL on July 21, 1987 and March 31, 1989, respectively. This Record of Decision (ROD) addresses the remediation of soils in both the MFG and LAP Areas for which interim cleanup goals and remedies were selected in the 1998 Record of Decision (ROD). This is the second and final ROD for JOAAP. ASSESSMENT OF THE SITE Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the response actions selected in this ROD, may present an imminent and substantial endangerment to public health, welfare, or the environment. OVERALL SITE CLEANUP STRATEGY Originally, fifty-three (53) and three (3) subareas of these sites were identified in the CERCLA cleanup program at JOAAP. The 1998 ROD for JOAAP selected final remedies for the Groundwater Operable Unit and final remedies for the Soil Operable Unit contaminant groups of landfills (SRU4), PCBs (SRU6), and sulfur (SRU7). The 1998 ROD selected final remedies for portions of the Soil Operable Unit contaminant groups of explosives (SRU1), metals (SRU2), intermixed explosives and metals (SRU3), and organics (SRU5) for JOAAP lands intended for transfer to the State of Illinois for the development of industrial parks. The 1998 ROD also selected interim remedies for SRUs 1, 2, 3, and 5 for JOAAP lands intended for transfer to the U.S. Department of Agriculture (USDA) for the development of a tallgrass prairie. This document provides the final remedies for the 14 SOU sites for which interim remedies were selected in the 1998 ROD. The goal of the final cleanup of the SRUs is to protect human health and environment by eliminating, reducing, or controlling hazards posed by the site and to meet all applicable or relevant and appropriate requirements associated with the site.

JOAAP Record of Decision Interim Soil Operable Unit Final pg. D-1

DESCRIPTION OF THE SELECTED REMEDIES The SOU remedies described in this ROD are divided into four contaminant groups or Soil Remedial Units (SRUs). SRU1, Explosives in Soil, addresses the remediation of an estimated 19,535 cubic yards (CY) of explosives-contaminated soil and 480 CY of associated concrete debris. The selected remedy for SRU1 soils is Excavation/Treatment (see Section 10.1.2). The major components of this remedy include pre-sampling of specific areas within the sites, excavation of soils contaminated with explosives, confirmatory sampling, and treatment of the soil using a composting process. The pre-sampling, excavation, and confirmatory sampling will be performed as described in the JOAAP Management Team Agreement (Appendix A). The treated soil will be reused or properly disposed. Some of the soils in SRU1 were contaminated by Resource Conservation and Recovery Act (RCRA) listed hazardous wastes, and as such "contain" these wastes. The Army based its detailed analysis of alternatives and selection of remedial technologies for these SRU1 soils on two determinations. First, media, such as soils, at JOAAP that were contaminated with RCRA listed hazardous wastes, are not themselves hazardous wastes unless they exhibit the characteristic for which the waste was listed. Second, once media contaminated with RCRA listed hazardous wastes are treated to below Remediation Goals (RGs), are not Toxic Characteristic Leaching Procedure (TCLP) hazardous wastes under RCRA, and do not exceed RCRA Land Disposal Restriction (LDR) concentrations, the media are no longer a RCRA hazardous waste. SRU2, Metals in Soil, addresses an estimated 12,865 CY of soil and 15 CY of associated concrete debris contaminated with metals. The selected remedy for SRU2 is Excavation/Disposal (see Section 10.1.3). This remedial action will include pre-sampling as needed, the excavation of soil contaminated with metals, confirmatory sampling and final disposal. The soil will be reused or properly disposed based on characterization. SRU3, Explosives and Metals in Soil, addresses an estimated 2,300 CY of soil contaminated with metals and explosives. The selected remedy for SRU3 is Excavation/Disposal (see Section 10.1.4). The major components of the Excavation/Disposal remedy include pre-sampling as needed, excavation of soil contaminated with explosives and metals, confirmation sampling, and final disposal. The soil will be reused or properly disposed based on characterization. Some of the soils in SRU3 were contaminated by RCRA listed hazardous wastes, and as such "contain" these wastes. The Army based its detailed analysis of alternatives and selection of remedial technologies for these SRU3 soils on two determinations. First, media, such as soils, at JOAAP that were contaminated with RCRA listed hazardous wastes, are not themselves hazardous wastes unless they exhibit the characteristic for which the waste was listed. Second, once media contaminated with RCRA listed hazardous wastes are treated to below RGs, are not TCLP hazardous wastes under RCRA, and do not exceed RCRA LDR concentrations, the media are no longer a RCRA hazardous waste. SRU5, Organics in Soil, addresses an estimated 1,475 CY of soil and 30 CY of associated concrete debris contaminated with organic compounds. The selected remedy for SRU5 is Excavation/Treatment (see Section 10.1.5). This remedial action includes pre-sampling as needed, excavation of organics-contaminated soil, confirmatory sampling, and treatment of the soil using a compost process. The treated soil will be reused or properly disposed.


STATUTORY DETERMINATIONS The selected remedial actions for all SRUs will protect human health and the environment, comply with Federal and State requirements that are legally applicable or relevant and appropriate to the remedial actions, and are cost-effective. These remedies utilize permanent solutions and alternative treatment technologies to the maximum extent practicable. To the maximum extent practicable, they also treat the principal threats posed by the contamination identified at the sites. Because the remedies selected for the SRUs will result in hazardous substances remaining on-site above levels that allow for unlimited use and unrestricted access, a review will be conducted within five years after the commencement of remedial action to ensure that the remedies continue to provide adequate protection of human health and the environment. ROD DATA CERTIFICATION CHECKLIST The following information is included in the Decision Summary section of this Record of Decision. Additional Information can be found in the Administrative Record file for this site.

• Chemicals of Concern and their respective concentrations (Table 4-1 and Section 5) • Baseline risk represented by the chemicals of concern (Section 6) • Cleanup levels established for chemicals of concern and the basis for these levels (Section

6 and Appendix A) • How source materials constituting principal threats are addressed (Section 8) • Current and reasonably anticipated future land use assumptions used in the baseline risk

assessment and ROD (Public Law 104-106) • Potential land use that will be available at the site as a result of the selected remedy

(Public Law 104-106) • Estimated capital, annual operation and maintenance (O&M), and total present worth

costs, discount rate, and the number of years over which the remedy cost estimates are projected (Section 9)

• Key factor(s) that led to selecting the remedy (Section 10)



___________________________________________________________ _____________ Renee Cipriano Date Director Illinois Environmental Protection Agency Reviewed and Concurred by: ___________________________________________________________ _____________ Arthur M. Holz Date Site Manager U.S. Army _______


1 SITE NAME, LOCATION, AND DESCRIPTION The Joliet Army Ammunition Plant (JOAAP) is a former U.S. Army munitions production facility located on approximately 36 square miles (23,542 acres) of land in Will County, Illinois. The JOAAP is located approximately 17 miles south of the city of Joliet and is divided into two main functional areas (Figure 1): the LAP Area (to the east of Route 53) and the MFG Area (to the west of Route 53). Each Area has been listed, by USEPA, on the NPL as a CERCLA site. The MFG Area, covering approximately 14 square miles (9,159 acres), is where the chemical constituents of munitions and explosives were manufactured. The production facilities are located in the northern part of the MFG Area. On the southern half of the MFG Area, there is an extensive explosives storage facility. The LAP Area, covering approximately 22 square miles (14,383 acres), is where munitions were loaded, assembled, and packaged for shipping. This area of JOAAP contains munitions filling and assembly lines, storage areas, and a demilitarization area. The JOAAP is located within the northern part of the extensive Central Lowlands physiographic province, which is characterized by relatively flat topography and low relief. The most prominent topographic feature at JOAAP is an approximately 50-foot-high escarpment that trends generally north-south through the installation. JOAAP lies within the fork of the confluence of the Des Plaines and Kankakee Rivers. Most of the LAP area drains to the Kankakee River. The Grant Creek and the Prairie Creek drainage basins cover approximately 70 percent of the installation, and the Jackson Creek drainage basin covers the remainder of the JOAAP. Jackson and Grant creeks are tributaries of the Des Plaines River, whereas Prairie Creek eventually discharges to the Kankakee River. Man-made ditches facilitate drainage to these creeks from the sites. The hydrogeology of the area is subdivided into four aquifer systems and major confining beds. From the uppermost downward, the aquifer systems are (1) the glacial drift (Pleistocene glacial deposits), (2) shallow bedrock (Silurian Dolomites), (3) Cambrian-Ordovician (sandstones and dolomites), and (4) Mount Simon (Cambrian sandstone). Groundwater flow at the MFG Area is generally westward but is locally influenced by streams that are incised into the glacial drift. Groundwater flow occurs in several aquifers beneath the site. The shallow overburden aquifer is composed of glacial drift and is underlain by the Silurian Dolomite water-bearing zone. Deeper bedrock aquifers are isolated from the shallow aquifer by low-permeability shale beds in the Maquoketa Group. Groundwater at the JOAAP has been determined to be both Class I and Class II. IEPA has classified the glacial drift aquifer as Class II because its low yield does not supply usable quantities of groundwater. The Silurian Dolomite is considered a Class I groundwater resource and it has a limited use in the vicinity of JOAAP as a water source despite elevated levels of sulfate and iron. In accordance with the Illinois Land Conservation Act of 1995, Public Law 104-106, Div. B, Title 2901-2932, Feb. 10, 1996, the Army will transfer 23,542 total acres of JOAAP land to various Federal, local and state jurisdictions. Approximately 19,100 acres are to be transferred to the USDA for establishing the MNTP; 982 acres to the Department of Veterans Affairs to establish a Veterans Cemetery; 455 acres to Will County, Illinois to establish the Will County Landfill (WCLF); and approximately 3,000 acres to the

JOAAP Record of Decision Interim Soil Operable Unit Final pg. 1-1

State of Illinois to establish two industrial parks. Figure 1 shows the current and future land use plan for JOAAP. Once potential hazards to human health and the environment are addressed and the property is found suitable for transfer under Public Law 104-106 and CERCLA, the Army prepares documentation for transfer. To date, the Army has transferred 15,080 acres to the USDA, 2,346 acres to the Joliet Army Development Association (JADA), 982 acres to the Department of Veterans Affairs, and 450 acres to Will County.

[END OF SECTION]


2 SITE HISTORY JOAAP was constructed during World War II for the purpose of manufacturing, loading, assembling, packing, and shipping bombs, projectiles, fuses, and supplementary charges. The production output at JOAAP varied with the demand for munitions. Although the plant was used extensively during World War II, in 1945 all production of explosives was halted, the sulfuric acid and ammonium nitrate plants were leased out, and the remaining production facilities were put in layaway status. The installation was reactivated during the Korean War, and again during the Vietnam War. Production at the plant gradually decreased until it was stopped completely in 1977. Since then, various defense contractors under facility-use contracts have utilized specific areas of the installation. Currently, no defense associated facility-use contracts remain active at the facility. Uniroyal Chemical Company, Inc operated the JOAAP as a government-owned, contract-operated (GOCO) facility until 1993. In April 1993, the property was declared as excess by the Army and is now being maintained by a small staff. The facility is not capable of explosives production and is undergoing transfer of use to other agencies and organizations in accordance with Public Law 104-106. In 1978, the U.S. Army Environmental Center (USAEC, formerly the U.S. Army Toxic and Hazardous Materials Agency or USATHAMA) conducted an Installation Assessment of JOAAP (USATHAMA, 1978), which consisted of records search and interviews with employees. This document reported that environmental impacts might be present at former industrial areas and locations where waste disposal activities occurred. During 1981 and 1982, an Installation Restoration Survey was conducted (Donohue and Associates, 1982). This study included sampling soils, groundwater, surface water, and sediment, and identified the presence of contamination at nine study areas at the MFG Area and nine study areas at the LAP Area. Subsequently, a Phase II study was conducted in 1983 (Donohue and Associates, 1983) to gather additional data on the previously sampled sites at the MFG and LAP Areas, and to evaluate the potential for off-site impacts. This investigation also included an assessment of several parcels of land near the edge of the MFG Area that JOAAP wanted to excess (sell). No off-site contamination was identified. From 1983 through 1985, a remedial action was conducted by Uniroyal (JOAAP’s operating contractor) at the Red Water lagoon located at site M7. The purpose of this remedial action was to remove contaminated surface water and sediment from the lagoon. Following the removal of contaminated materials, a clay cap was installed over the lagoon. Pre- and post-remediation sampling documented the conditions before and after the remediation (Donohue and Associates, 1983, 1985). Between 1983 and 1985, the U.S. Army Environmental Hygiene Agency (AEHA; now U.S. Army Center for Health Promotion and Preventive Medicine, CHPPM) performed groundwater sampling of selected existing monitoring wells. The sampling and monitoring were performed as part of JOAAP’s RCRA groundwater monitoring program around a closed sanitary landfill located at site M13, and the Red Water lagoon at site M7. In November 1984, because of the presence of contamination, the MFG Area of JOAAP was proposed for listing on the NPL by the USEPA based on the Hazard Ranking System (HRS) score 32.08. The LAP Area was proposed for listing in April 1985 based on the HRS score 35.23. Final listing on the NPL took place on July 21, 1987 for the MFG Area, and March 31, 1989 for the LAP Area.


During 1985 and 1986, additional groundwater and surface water samples were collected from previously sampled locations at the MFG and LAP Areas. This data was presented in an assessment report in which the feasibility and need for remediation of the study areas was discussed (Dames & Moore, 1986). In 1989, the Army, the USEPA and the IEPA entered into a Federal Facilities Agreement (FFA) under CERCLA Section 120 and RCRA Sections 6001, 3008(h), 3004(u), and 3004(v) (USEPA, 1989). The purpose of this FFA was to ensure that environmental impacts at the site would be investigated and that remedial actions would be taken to protect public health, welfare, and the environment. Also during 1989, the U.S. Army Corps of Engineers (USACE) made an investigation of underground storage tanks (USTs) throughout the JOAAP (USACE, 1989). One hundred seven USTs were identified, inventoried, and evaluated for possible leakage in accordance with USEPA regulations for existing USTs. All of the USTs were emptied and removed as of 1993. From 1988 through 1993, Phase 1 and Phase 2 Remedial Investigations (RIs) were conducted at the MFG Area (Dames & Moore, 1991, 1993). The RIs were performed to identify the type, concentration, and extent of contamination throughout the MFG Area at JOAAP. A total of 18 study areas were identified for investigation, including nine areas originally investigated during previous studies. These reports were amended by the Oleum Plant RI report (Dames & Moore, 1996) that was added as a potentially contaminated area following the completion of the RI reports. From 1991 through 1994, Phase 1 and Phase 2 RIs were conducted at the LAP Area for the same purposes as the MFG Area investigations (Dames & Moore, 1993; 1994). A total of 35 study areas were investigated, including nine sites investigated during the Installation Restoration Surveys at the LAP Area. The RI reports were supplemented by baseline risk assessments conducted to quantify the potential human health risks posed by contamination identified at the study sites present at the MFG and LAP Areas (Dames & Moore, 1994; 1995). The assessments included an environmental fate and transport assessment, a toxicity assessment, an exposure assessment, and a risk characterization. From 1993 through 1996, the U.S. Army CHPPM conducted an ecological risk assessment to evaluate the potential for site contamination to be impacting ecological receptors. The conclusions of those documents indicated limited impacts to terrestrial mammals, aquatic receptors, and avian species (birds). The results of these studies were presented in a Phase 1 Ecological Risk Assessment Report (USACHPPM, 1994) and a Phase 2 Aquatic Ecological Risk Assessment Report (USACHPPM, 1996). Potential risks posed to humans from consuming deer tissue from JOAAP were also investigated and determined to be negligible (USACHPPM, 1994). Following the risk assessments, Preliminary Remediation Goals (PRGs) were established to identify the specific cleanup to remediate the sites (OHM, 1996). The cleanup levels were developed to be protective of human health and the environment. In 1996 and 1997, the USACE conducted four removal actions to prevent the migration of contaminants from source areas. Wastes present in the oil pits located at study area L2 were excavated and disposed to prevent the contaminants present in these wastes from migrating into the groundwater. During the same time period, the Omaha District, Corps of Engineers, conducted a Removal Action along Prairie Creek at site L3. This action involved stabilizing the stream bank to prevent the erosion of the bank that contained buried debris and wastes. Also in 1996, the Louisville District Corps of Engineers conducted the removal of the PCB-Containing switch boxes from the MFG Area. Soils around the switch boxes were sampled


and subsequently removed if contamination was above RGs or if staining was noticeable. In 1997, an interim Removal Action was performed at the southern ash pile (M1). This project involved consolidating wastes that had migrated from the pile and covering the pile with a geosynthetic liner to prevent leaching of wastes from the pile. Also in 1997, the Louisville District, Corps of Engineers, conducted a Removal Action at site L6. This action involved the excavation and disposal of organics- and PCB-contaminated soil to protect human health and the environment. This action also was intended to facilitate the transfer of the land from the Army to Will County in accordance with Public Law 104-106 for establishing a landfill. Public Law 104-106 of the Fiscal Year 1996 Department of Defense Authorization Act legislated specific terms relating to the conveyance of JOAAP to various entities. This law is the governing document for the future land use at JOAAP. The majority of JOAAP is to be transferred to the U.S. Department of Agriculture (USDA), with the U.S. Department of Veterans Affairs, Will County, and the State of Illinois receiving the remainder of the property. Figure 1 identifies the planned future land use of JOAAP under this law. Since the volume of explosives-contaminated soil may have a direct bearing on the selected remediation method, field screening soil sampling programs were conducted in 1995 to provide data to more accurately estimate the volume of explosives-contaminated soils on the MFG and LAP Areas. These programs were supplemented by sampling to help characterize the types of wastes present, and the results of the sampling programs were used in the Feasibility Studies (FSs) for the MFG and LAP Areas. The purpose of the FSs was to identify and evaluate alternative remedies for mitigating the risks posed by contamination at JOAAP. Separate FSs were prepared for the Groundwater and Soil Operable Units for both the LAP (Dames & Moore, 1997) and MFG (OHM, 1997) Areas. Based on the information gathered and presented in the FSs, the Army recommended, with USEPA and IEPA concurrence, the preferred remedies for the contaminated soil and groundwater at JOAAP. The rationale behind the selection of the remedies was released to the general public in the Proposed Plan for the Soil Operable Unit and the Proposed Plan for the Groundwater Operable Unit (U.S. Army, 1997 a, b) and presented at a public meeting on January 8, 1998. A Record of Decision (ROD) was signed for JOAAP in November 1998. The 1998 ROD selected final remedies for the Groundwater Operable Unit and final remedies for the Soil Operable Unit contaminant groups of landfills (SRU4), PCBs (SRU6) and sulfur (SRU7). The 1998 ROD also selected final remedies for portions of the Soil Operable Unit contaminant groups of explosives (SRU1), metals (SRU2), intermixed explosives and metals (SRU3), and organics (SRU5) for JOAAP lands intended for transfer to the State of Illinois for the development of industrial parks. The 1998 ROD selected interim remedies for SRUs 1, 2, 3, and 5 for JOAAP lands intended for transfer to the U.S. Department of Agriculture (USDA) for the development of the Midewin National Tallgrass Prairie (MNTP) pending the development of soil cleanup goals that would protect prairie workers and the environment. A multi-agency management team was formed comprised of representatives from the Army, U.S. EPA, IEPA, USDA/FS, USFWS, and IDNR. This team tasked two sub-teams of human health and ecological risk assessment technical experts with developing preliminary remediation goals protective of the future MNTP lands. The technical work groups completed their assessment of available literature, databases, and site specific data and presented their findings in separate technical reports (Human Health Work Group, 2000; Ecological Work Group, 2000). The Management Team further refined the lists of chemicals of concern and developed an agreement document that defines the pre-sampling requirements for each site, the remediation goals that must be met by the average concentrations across the excavation areas, the excavation design values, confirmatory sampling, and the disposition of the sewer lines (Appendix A).


Using the data from the 1997 FS documents, an updated Focused Feasibility Study (FFS) was developed (2004, USACE) to present final cleanup values and evaluate alternatives for the interim ROD sites. A Proposed Plan document for the interim ROD sites was provided for public comment from February 20, 2004 to March 20, 2004 and was publicly presented on 3 March 2004. One comment of support was received from the Restoration Advisory Board (RAB) members (Section 14).

[END OF SECTION]


3 HIGHLIGHTS OF COMMUNITY PARTICIPATION The Army has made major documents concerning the CERCLA activities at JOAAP available to the public at two information repositories in the vicinity of the installation. These two repositories are located at the JOAAP office and the Joliet Public Library in Joliet. The Proposed Plan for the Soil Operable Unit Interim ROD sites was released to the public on February 20, 2004. The notice of availability of this document was published in the Joliet Herald News newspaper on February 20, 2004. A 30-day public comment period on the Proposed Plan extended from February 20, 2004 through March 20, 2004. In addition, a public meeting was held during the public comment period on Wednesday, March 3, 2004. At that meeting, representatives from the Army, USEPA, and IEPA presented a summary of the project and answered questions relating to the Proposed Plan. Written and oral comments received at this meeting, as well as written comments received during the public comment period, which are relevant to the Proposed Plan, were responded to in the Responsiveness Summary section of this document. The JOAAP RAB was established in December 1995 to facilitate communication and coordination between community and governmental agencies related to the restoration of the JOAAP. The RAB is intended to bring together members who reflect the diverse interests within the local community. The RAB held its regular monthly meetings at the Wilmington City Council Chambers from January 1996 to July 1999 when bimonthly meetings were instituted and are ongoing. In 1996 and 1997, the JOAAP RAB held open forums, discussed upcoming studies, took field trips to visit other RABs, provided input on the Proposed Plans and 1998 ROD, and participated in deciding removal action projects conducted at JOAAP. In 1997 and in 2000 the RAB hosted a press tour of the JOAAP facility in order to promote information exchange among the community and the installation. Since 1997, several additional tours of the facility and ongoing remedial operations have been provided for the RAB. The RAB has been briefed on remedial activities ongoing for the SRUs determined to be final in the 1998 ROD and has been active in discussions concerning the development of this ROD. Three interdisciplinary, multi-agency teams were formed to develop the preliminary remediation goals leading to this ROD. One member of the RAB participated in the Ecological Work Group and two RAB members participated in the Human Health Work Group. Two members of the RAB actively participate in the Installation Action Plan meetings each year since 2000. Prior to the formation of the RAB, Technical Review Committee meetings were held regularly to inform the public about the ongoing environmental studies in accordance with JOAAP's Public Involvement Response Plan (Dames & Moore, 1990).

[END OF SECTION]


4 SCOPE AND ROLE OF OPERABLE UNITS OR RESPONSE ACTIONS

Past releases and disposal practices at JOAAP have resulted in soil and groundwater contamination with explosives compounds, metals, organics, PCBs, sulfur, and hazardous and non-hazardous debris. The goal of the overall cleanup activities at JOAAP is to eliminate or reduce the levels of contaminants to concentrations that are protective to human health and the environment, such that no adverse health effects or adverse ecological impacts will result from future uses of the JOAAP property. The 1997 FS documents and 1998 ROD divided contaminated media identified at JOAAP into two operable units (OUs) to aid in the development, evaluation, and selection of remedies. The soil operable unit (SOU) consists of sites where contaminated soils, sediments, and debris were identified. The groundwater operable unit (GOU) consists of sites where contaminated groundwater plumes were identified. The SOU was further divided into seven soil remedial units (SRUs) according to the type of contamination discovered. Based on the original risk assessments, surface waters studied at JOAAP have been determined to pose no risk to human health and the environment and, therefore, have not been addressed further. The 1998 ROD selected natural attenuation for contaminated groundwater for all sites in the GOU. A groundwater monitoring system has been established, and groundwater monitoring has been conducted biannually since 1999. The 1998 ROD selected final remedies for all sites in the SOU contaminant groups of landfills (SRU4), PCBs (SRU6), and sulfur (SRU7), and for the sites contaminated with explosives (SRU1), metals (SRU2), intermixed explosives and metals (SRU3) and organics (SRU5) for JOAAP lands intended for transfer to the State of Illinois for the development of industrial parks. Bioremediation was selected for cleanup for SRUs 1 and 3. A windrow composting facility was built by the Army and became operational in early 2000. More than 130,000 tons of SRU1 and SRU3 contaminated soils have been treated at this facility to date. All (7,730 tons) but a small volume of PCB-contaminated soil (SRU4) was excavated and sent off-site for proper disposal in the summer of 1999. The surficial sulfur that was present at Site M8 was removed and disposed off-site as part of the other installation disposal activities in 1999. Implementation of the final SOU remedies selected in the 1998 ROD is expected to continue through 2008. The 1998 ROD also selected interim remedial goals and remedies for SRUs 1, 2, 3 and 5 for the JOAAP lands intended for transfer to the USDA for the development of the Midewin National Tallgrass Prairie (MNTP). No remedial actions have taken place at the interim ROD sites. This ROD presents the final remedial goals and final remedies for the interim portion of the 1998 ROD. Final response actions are presented for the fourteen SOU sites within the SRUs. These four SRUs are summarized in Table 4-1 and are describe in more detail in Section 5. .


Table 4-1: Soil Remedial Units

SRUs

Description

Primary Contaminants of Concern

Remedial Action Sites

SRU1 Explosives DNT, TNB, TNT, HMX, RDX

L1, L2, L7, L8, L9, L10, L14, M2

SRU2 Metals Arsenic, Lead, Cadmium, and Copper

L2, L3, L5, L23A, M4, M12

SRU3 Explosives and Metals

DNT, TNT, RDX, Arsenic, Lead

L3, M3

SRU5 Organics Total Petroleum Hydrocarbons/ PAHs

L1, L5

Note: Sites beginning with letter “L” are in the LAP Area; with the letter “M” are in the Manufacturing

Area

[END OF SECTION]


5 SITE CHARACTERISTICS During the Remedial Investigations (RIs), numerous samples were taken to delineate the nature and extent of contamination of the soils and sediments. Surface and subsurface soil samples were taken using hand augers, drilling rigs, and backhoes. The horizontal and vertical extent of contamination was evaluated at each site. The specific interim ROD sites intended for the USDA considered in this ROD include: Sites L1, L2, L3, L5, L7, L8, L9, L10, L23A, M2, M3, M4, and M12, which are grouped into four SRUs. These four SRUs are described below. In some instances, different types of contamination were present in a single study site; therefore, the same study site may appear in more than one SRU.

5.1 SRU1, Explosives in Soil SRU1, Explosives in Soil, contains the majority of the contaminated soils remaining at JOAAP and poses a principal threat to human health and the environment if not remediated. Most of this contamination is found at sites L1 and L2 where demilitarization and reclamation and burning of various munitions occurred. The contamination is generally confined to the surface soils in the immediate vicinity of the operations. A brief description for each site follows in Sections 5.1.1 to 5.1.8. A total of 8 sites are grouped under this SRU, as shown in Table 5-1. One of these sites is within the MFG Area and seven are within the LAP Area, as shown in Figure 2. It should be noted that only certain sub-areas under each site are included in this SRU and not the entire site. Table 5-1 lists the sub-areas and the estimated volume of soil/sediment that needs to be remediated. Table 5-2 lists exceedances of Remedial Goals for sites included in SRU1.

Table 5-1 Site and Sub-areas of SRU1 (Explosives in Soil)

Sites Sub-areas VOLUMES IN CUBIC YARDS (CY) SOIL [CONCRETE]

Ridge and furrow system L1 Near Building 61-4 and Building 61-35 sump 4240 [15]

L2 Burning Pads and Popping Furnace Area 10,000 [15]L7 Around and beneath buildings and sumps 925 [120]L8 Around and beneath buildings and sumps 400 [90]L9 Around and beneath buildings and sumps 750 [135]

Around and beneath buildings and sumps L10 Sediment in drainage ditch south of Building 3A-10 1200 [75]

L14 Soil near sump at Building 4-5 420 [30]M2 The northern portion of the explosive burning ground and the

wetland separating M2 and M11 1,600 [0]

Total 19,535 [480]

5.1.1 Site L1 Site L1 was constructed in 1941 as part of the initial operations of the installation to support World War II efforts. This 80-acre site is centrally located in the northern portion of the LAP Area. Site L1 was the location of demilitarization and reclamation of various munitions. It was originally used for crystallizing ammonium nitrates, but then extensively modified to function as a shell renovation and 1,3,5-


trinitrobenzene (TNB) recovery plant until 1945. In April 1946, the facility was reactivated to reclaim TNT. Washout operations involving the larger munitions were performed outside Building 61-35, which is located southeast of Building 61-4. The solids that settled in the sump were sent to Site L2 (Explosive Burning Grounds), while the overflow from the sump (pink water) was discharged to an adjacent 4.3-acre ridge-and-furrow system (or evaporating bed). The contaminant drivers for explosives remediation are 2,4,6-Trinitrotoluene (TNT), Trinitrobenzene (TNB), and 2,4-Dinitrotoluene (2,4-DNT). Figure 3 shows the excavation areas planned. Explosives contamination at site L1 appears to be limited to the ridge-and-furrow system, south of the washout building and around the sump. It has been estimated that a portion of the 4.3-acre ridge and furrow area is contaminated with explosives above excavation design values to a one foot depth. Pre-excavation sampling will confirm the areas with contamination above the excavation design values. The area requiring remedial action at the washout building and sump is limited to the stained area and includes an estimated volume of 800 CY of contaminated surface soil, assuming the depth of contamination above excavation design values extends to 1 foot. Subsurface soils were determined to be contaminated an additional 2 feet in depth to the west side of the sump. Other contaminated materials include: subsurface soil beside the sump building, sump sediment and concrete (15 CY). The total volume of explosives-contaminated soil from Site L1 areas requiring remedial action is approximately 4240 CY. Potential waste characterization of L1 soils is described in detail in the Appendix A of 1997 Dames and Moore FS for the LAP area. Based on this documentation, the soils are not considered to be hazardous.

5.1.2 Site L2 Site L2, Explosives Burning Grounds (Figure 4), is located in the west central portion of the LAP Area, adjacent to Prairie Creek and Kemery Lake. The operational area for SRU 1 soils covers approximately 5 acres and consists of six east-west burning pads, on which explosives and associated waste from other LAP Areas sites were burned. In addition to the east –west burning pads the south –north burning pads located east of the east-west burning pads will be investigated by screening and sampling. Three popping furnaces, where small ammunition was detonated, were located at the southwest corner of the site. UXO, including fuses and other items have been identified to be present on the burning pads. A majority of the burning pad area is contaminated with TNT, 2,4-DNT, 2,6-DNT, TNB and Cyclotrimethylenetrinitramine (RDX). When excavation/treatment is conducted, the entire burning pad will be mechanically screened for potential UXO prior to soil treatment. It is estimated that 16,000 CY of soil will be screened and approximately 10,000 CY of screened soil will be treated. Associated concrete debris is expected to total 15 CY. The screening of the potential UXO will consist of mechanical excavation of the soils and a screening operation. The screening operation will consist of UXO technicians collecting potential UXO that is screened out. The UXO material will either be transported off base for disposal or the contractor could use a properly obtained burn permit to dispose of intact UXO on-site. Once the UXO material is screened out, the stockpile soil will be sampled. The sampling strategy will be worked out during the RD. Waste characterization of L2 soils from the burning pads indicated the soils are not hazardous waste because they don’t fail the characteristic test of toxicity. If intact UXO is encountered in the excavation or screening, proper disposal regulations will be followed.

5.1.3 Site L7 Site L7 (Figure 5) is located in the southern portion of the LAP area. The basic processes and procedures involved in LAP operations are similar for all ammunition items. Explosives were melted and loaded into


a projectile; process water containing explosives residue was discharged to sumps. The loaded projectiles were then transferred to another building for final assembly. Solids collected in the sump were reportedly sent to the Explosive Burning Grounds (Site L2) for disposal. According to JOAAP personnel, carbon treatment units were installed in each melt-load building around 1976. Spent carbon units were disposed of at the Explosive Burning Grounds. Site L7, unlike L1, has much less defined areas of contamination and removal will be more selective. Figure 5 identifies the areas of explosives contaminated soil at Site L7 that are to be pre-sampled to determine the extent of the remedial action. Existing data and pre-excavation sampling will determine which soil will be considered for excavation, as fringe areas and/or as anomalies as documented in the JOAAP Management Team Agreement (Appendix A). TNT is the remedial driver in soil at Site L7. The total volume of affected soil for Site L7 is estimated to be approximately 925 CY however this number will be refined with pre-sampling data. 120 CY of associated concrete debris is expected to require excavation. Based on the waste characterization report no RCRA hazardous wastes were identified at Site L7. There is the possibility that traces of raw TNT might be found that would be considered a D003 hazardous waste.

5.1.4 Site L8 Site L8 (Figure 6) is centrally located in the LAP Area, east of the intersection of Chicago and Central Roads. LAP operations performed at the site included: melting and loading of Composition B into projectiles, subsequent cleaning and wash-down operations that produced pink-water, and discharge of this waste water to external sumps and surface areas. The explosive contaminant that is the remedial driver in soil at Site L8 is 2,4,6-TNT. Explosives were identified in soil adjacent to buildings scattered throughout the site much like site L7. Figure 6 identifies the areas of explosives contaminated soil at Site L8 that are to be pre-sampled to determine the extent of the remedial action. Existing data and pre-sampling will determine which soil will be considered for excavation, as fringe areas and/or as anomalies as documented in the JOAAP Management Team Agreement (Appendix A). The total volume of affected soil is estimated to be approximately 400 CY. The volume of raw TNT is estimated to be 1 CY. Additionally, a total of 90 CY of structural concrete in the sump areas is estimated for disposal. Based on the waste characterization report, the only RCRA hazardous waste identified at Site L8 is trace raw TNT which is hazardous based on its reactivity (waste code D003).

5.1.5 Site L9 (Group 3) Site L9 (Figure 7) is located in the central part of the LAP Area, 1 mile east of the intersection of Chicago and Central Roads. Operations were similar to those described for Sites L7 and L8. Explosives contaminants of concern for soil at Site L9 include 1,3,5-TNB, 2,4,6-TNT and RDX. Explosives have been identified in soil adjacent to buildings throughout the site. High levels of RDX contamination occur in a few locations beyond stained areas and are not as apparent as surrounding TNT contamination. Figure 7 identifies the areas of explosives contaminated soil at Site L9 that are to be pre-sampled to determine the extent of the remedial action. Existing data and pre-excavation sampling will determine which soil will be considered for excavation, as fringe areas and/or as anomalies as documented in the JOAAP Management Team Agreement (Appendix A). The total volume of affected soil, including areas beneath building foundations, is estimated to be approximately 750 CY. The volume


of raw TNT is estimated to be 1 CY. Additionally, a total of 135 CY of structural concrete in the sumps area is estimated for disposal. Based on the waste characterization report, the only RCRA hazardous waste identified at Site L9 is trace raw TNT which is hazardous based on its reactivity (waste code D003).

5.1.6 Site L10 Site L10 (Figure 8) is located in the central part of the LAP Area, between Sites L7 and L8. LAP operations performed at Site L10 were similar to those described for Site L7. Explosive contaminants of concern for soil at Site L10 are 2,4,6-TNT, 2,4-DNT, Octahydro-1,3,5,7-Tetranitro-1,3,5,7-Tetrazocine (HMX), and RDX. High levels of explosives have been identified in surface soil adjacent to buildings and sumps throughout the site. High concentrations of RDX occur in some locations where staining is absent and vegetation is present. Explosives were detected in heavily contaminated surface areas, beneath the foundation of one sump building, 3A-53, and next to the manhole near Building 3A-12. Figure 8 identifies the areas of explosives contaminated soil at Site L10 that are to be pre-sampled to determine the extent of the remedial action. Existing data and pre-excavation sampling will determine which soil will be considered for excavation, as fringe areas and/or as anomalies as documented in the JOAAP Management Team Agreement (Appendix A). The total volume of affected soil at Site L10 is estimated to be 1200 CY. The volume of raw TNT is estimated to be 1 CY. Additionally, a total of 75 CY of structural concrete in the sumps area is estimated for disposal. The only RCRA hazardous waste identified at Site L10 is trace raw TNT which is hazardous based on its reactivity (waste code D003).

5.1.7 Site L14 Site L14 (Figure 9) is a 33-acre site located in the southwestern corner of the LAP Area, near Sites L15 through L19. It was initially constructed to produce various types of fuses. After 1945, Building 4-14 was used for repackaging smokeless powder. According to JOAAP personnel, a sump north of Building 4-5 periodically overflowed resulting in soil contamination in this area. Explosives contaminants of concern include 2,4,6-TNT, RDX and HMX. The highest concentrations of explosives were detected in surface soil near the large sump north of Building 4-5. Explosive concentrations decreased with depth, but were detectable in the samples collected at 5 feet. Figure 9 identifies the areas of explosives contaminated soil at Site L14 that are to be excavated and confirmatory sampling performed as documented in the JOAAP Management Team Agreement (Appendix A). Explosives concentrations in soil samples from all other areas at Site L14 were below the remediation goals. The total volume of affected soil and sediment at Site L14 is estimated to be 420 CY. Additionally, a total of 30 CY of structural concrete in the sump area is estimated for disposal. Based on the waste characterization report no RCRA hazardous wastes were identified at Site L14. There is the possibility that traces of raw TNT might be found that would be considered a D003 hazardous waste.

5.1.8 Site M2 Site M2 (Explosive Burning Ground, Figure 10) covers approximately 25 acres in the south central part of the MFG Area. Open burning of explosive wastes was performed on a 4-acre burning pad until 1965. The burning pad consists of gravel placed over the topsoil. Berms surround much of the burning pad area. A wetland area is present to the north of the burning pad area and along the eastern boundary of M2.


More than 400 tons of suspected red water ash were encapsulated in an impermeable membrane (“ash pillow”) and buried at a shallow depth in the northern section of the explosives burning pad. The color, odor, texture, and apparent solubility of the buried waste are indicative of potentially untreated explosives sludge. Explosives contaminants of concern for soil at Site M2 include 1,3,5-TNB, 2,4,6-TNT, 2,4-DNT, and 2,6-DNT. The volume of explosives-stained soil in M2 exceeding the RGs is estimated to be 1330 CY. The area of stressed vegetation in M2, without observable explosive residue is estimated to represent part of the soil estimate. Additionally, there is an estimated 270 CY of material in the "ash pillow", which will be characterized for appropriate disposal or treatment. Soils at M2 may include the following RCRA characteristic waste: soil contaminated with TCLP extractable 2,4-DNT (RCRA waste code D030).

Table 5-2 Exceedances of Remediation Goals for SRU 1

MIDEWIN TALLGRASS PRAIRIE AREAS (USDA) Site L1 L2 L7 L8 L9 L10 L14

M2

Explosives

RG (mg/kg)

Maximum Concentration Exceeding RGs (mg/kg)

1,3,5-TNB 17 235 220 25 53 3,900 2,610 2,4,6-TNT 200 22,000 7,800 150,000 16,000 44,000 13,000 72,300 2,4-DNT 20 61 110 522 2,6-DNT 20 HMX 2,860 17,000 3,900 RDX 107 1,800 12,000 77,000 42,000

CONTAMINATED SOIL VOLUME (CY) TOTAL 19,535

4,240

10,000

925

400

750

1,200

420

1,600

5.2 SRU2, Metals in Soil SRU2, Metals in Soil, contains sites where production, testing and waste disposal activities resulted in metals contamination. Most of the metals found are confined to surface soils, and because they are not readily leachable, have not caused groundwater contamination. A total of six sites are grouped under this SRU. Two of these sites are within the MFG Area and four are within the LAP Area, as shown in Table 4-1 and Figure 2. It should be noted that only certain sub-areas under each site are included in this SRU and not the entire site. Table 5-3 lists these sub-areas and the estimated volume of soil/sediment that needs to be remediated. Table 5-4 lists exceedances of the Remedial Goals (RGs) for sites included in SRU2.


Table 5-3 Sites and Sub-areas of SRU2 (Metals in Soil)

Sites Subareas Volume in cubic yards (CY)

Soil [Concrete] L2 Soils near popping furnaces 700 [15]

Soils east of demolition pits L3 Fire Training Area 300

L5 Open storage area 2,165 L23A Soils in pit 3,300 M4 Lead contaminated soil around the former lead azide lagoon 3,200 M12 Metal contaminated soil throughout the site 3,200 Total 12,865 [15]

5.2.1 Site L2 Site L2 (Explosives Burning Grounds, Figure 4) is located in the west-central portion of the LAP Area, adjacent to Prairie Creek and Kemery Lake. The operational area covers approximately 5 acres and consists of burning pads for demolition of explosives and associated explosive waste. These areas have been described in more detail in Section 5.1.2. Three popping furnaces, where small ammunition was detonated, were located at the southwest corner of the site. During operations, metal waste from the furnaces was removed and sent to the Salvage Yard (Site L5). The Explosive Burning Grounds also contained three solvent and oil disposal pits (each less than 0.25 acre) located adjacent to the burning pads, which (according to JOAAP personnel) were occasionally used to burn waste oil. These pits were remediated in 1996 as part of a removal action conducted by the U.S. Army, and UXO were discovered to be buried in an area north of the burning pads. The UXO were disposed of properly as part of the removal action, although a complete UXO sweep was not performed and it is possible that additional UXO remain at the site in the vicinity of the removal action. It is estimated that an area approximately 140 feet square surrounding and including the popping furnaces would require the remedial actions for arsenic, cadmium and lead. Surface soil contaminated with arsenic, cadmium, and lead has been estimated to extend to a depth of 1 foot representing a volume of 700 CY. The removal, and potential decontamination, of the popping furnaces will be necessary to adequately remove the contaminated soil. This represents approximately 15 CY of concrete and steel debris. Soils in the vicinity of the popping furnaces at Site L2 may be contaminated with RCRA characteristic hazardous wastes for cadmium (RCRA waste code D006) and lead (RCRA waste code D008). As part of the remedial action, UXO personnel will be consulted and UXO screening will be performed as required for safety compliance. If intact UXO is encountered in the excavation or screening, proper disposal regulations will be followed.

5.2.2 Site L3 Site L3 (Demolition Area, Figure 11) is located directly southwest of the Explosive Burning Grounds, Site L2. Covering approximately 50 acres, Site L3 is bounded to the west by Prairie Creek, to the south by an unnamed tributary to Prairie Creek, and to the east by Star Grove Cemetery. The principal operation conducted in this area was the open burning of combustible refuse and munitions crates. An air curtain destructor, which facilitates combustion while reducing particulate emissions, was constructed at the site but never used. In addition, uncontaminated solid waste and some potentially low-level


explosives-contaminated solid waste from JOAAP operations were burned in this area. A 1-acre fire training area is also located at the site. The burning area is designated an SRU3 site as it contains levels of both explosives and metals above RGs. The burning area is further described in Section 5.1.3. The fire training area consisted of a small depression enclosed by an earthen berm, which contained burning and fire training areas. The metal drivers include arsenic, copper and lead in areas of the fire training area and a small area around an old incinerator east of the demolition pits. Figure 11 shows these areas to be excavated and confirmatory sampling performed as documented in the JOAAP Managements Team Agreement (Appendix A). As part of the remedial action, UXO personnel will be consulted and UXO screening will be performed as required for safety compliance. The volume of soil requiring a remedial action at the fire training pit is an estimated 200 CY. Soil in the area east of the demolition pits requiring a remedial action is estimated to total 100 CY. A total of 300 CY of soil is estimated to require a remedial action for lead and arsenic. Based on the waste classification document, no RCRA hazardous wastes are present at Site L3. While no UXO has been encountered in the fire training area or the area near the old incinerator, UXO has been detected elsewhere at L3 and should be considered during the implementation of the remedial action. If intact UXO is encountered in the excavation or screening, proper disposal regulations will be followed.

5.2.3 Site L5 Site L5 (Salvage Yard, Figure 12) was used for salvage and open storage of miscellaneous materials from the installation. It is located in the northwestern corner of the LAP Area along Hoff Road. Metal waste from the popping furnaces at the Explosive Burning Grounds (Site L2) was reportedly sent to Site L5 when JOAAP was in operation. Three areas of concern within L5 were identified in aerial photographs: the junk pile located in the southeast portion of the site, the ditch located along side the railroad tracks and a storage yard for railroad ties. Metal contamination in the former junk pile area is primarily limited to lead and copper in exceedence of RGs in the surface soil with deeper hot spots located in the same area. An estimated total of 2,165 CY of soil is considered for a remedial action. Lead contamination in the ditch and open storage area is primary limited to surface soil. Soils (estimated 100 CY) from the ditch and open strorage will be excavated and confirmatory sampling will be performed as documented in the JOAAP Management Team Agreement (Appendix A). Anomalous sites of lead contamination have been located at this site and will be excavated as documented in the JOAAP Management Team Agreement for anomalies. It is expected that 100 CY of soil may result from the anomaly excavations. In the waste characterization of the soils, one sample exceeded TCLP limits for lead. Also a portion of the soils might be regulated under TSCA for PCB results. Soils will be classified for disposal during response actions.

5.2.4 Site L23A Historic aerial photo-interpretation from 1946 identified a small (less than 0.5 acre) disposal pit located in the southwestern corner of Sites L23/L23A that is identified as Site L23A (Disposal Pit, Figure 13). It is not known what materials were placed in this pit; however, aerial photos from 1952 indicated that disposal activities had ceased.


Lead was detected in soil samples from the pit at concentrations exceeding its RG. The volume of lead-contaminated soil is assumed to extend across the center of the disposal pit and the area north of the pit (approximately 100 feet north-south by 150 feet east-west) to a depth of 6 feet. The total affected volume of soil is estimated to be approximately 3,300 CY. Metal debris is associated with the area requiring remedy and will thus be removed as associated metal waste (165 CY). No RCRA hazardous wastes were identified at Site L23A. The soils, however, may be considered special (non-hazardous) waste as defined under 35 IAC 808.100. This definition only applies once these soils are excavated for storage or disposal.

5.2.5 Site M4 Site M4 (Lead Azide Area, Figure 14) is located in the west central part of the MFG Area and covers approximately 136 acres. Lead azide, a primary initiating explosive, was produced in M4 from the early 1940s through the Korean War and again during the Vietnam War from 1966 into early 1968. The principal feature located in the western part of M4 was the Lead Azide Lagoon. The Lead Azide Lagoon was used as a settling basin to store wastewater treatment sludge from the manufacturing and formulation of lead-based initiating compound prior to neutralization and subsequent discharge to Grant Creek. Any remaining lagoon sludge is classified as K046 hazardous waste. The Lead Azide Lagoon covered an area of approximately 2,000 SF. In 1982, the production facility in the central portion of M4 was demolished with the wreckage being burned within the Lead Azide Lagoon. At present, the only visible evidence of the lagoon is brick and concrete rubble in the surface soil. A ditch leading away from the lagoon toward Grant Creek also shows elevated lead levels. Concentrations of lead greater than the clean up level were present in 14 of 20 soil samples analyzed from M4; lead was detected in an area covering approximately 47,500 SF, and extending to a depth of 3 feet. Figure 14 shows the areas planned for pre-sampling, excavation, and the fringe areas associated with the lead contamination. The volume of lead-contaminated soil in M4 exceeding the RG for lead is estimated to be 3,200 CY. Soils at Site M4 may contain RCRA characteristic hazardous wastes for TCLP extractable lead (RCRA waste code D008) and RCRA listed hazardous wastes for lead wastewater treatment sludges (RCRA waste code K046).

5.2.6 Site M12 M12 (Sellite Manufacturing Area, Figure 15) is located to the west of the TNT Ditch Complex in the northwestern portion of the MFG Area. Sellite was manufactured for use in the purification of crude TNT. Sellite consists of a solution of sodium sulfite and sodium sulfate. M12 includes two sellite production units, a wastewater lagoon, and associated drainage ditches. No data was collected that directly identifies the vertical extent of lead contamination in M12. Based on patterns of lead concentrations in samples collected in other areas within the MFG Area, the lead contamination in soils and sediments at the Sellite Manufacturing Area is estimated to be limited to a depth of 12 inches. The depth of contamination is based on high concentrations of sulfate throughout M12 and the insolubility of lead sulfate and other lead salts. The volume of lead-contaminated soil and sediment in M12 exceeding the RGs is estimated to be 3,200 CY and includes both sediment in the lagoon and soils in the ditches. Figure 15 shows the area planned for excavation and the associated fringe area.


Soils at Site M12 may contain RCRA characteristic hazardous wastes for TCLP extractable lead (RCRA waste code D008).

Table 5-4 Exceedances of Remediation Goals in SRU2

MIDEWIN TALLGRASS PRAIRIE AREAS (USDA) Site L2 L3 L5 L23A M4 M12 Metals

RG (mg/kg)


Arsenic 21 86 110 26 Cadmium 63 5,800 Copper 190 4,390 Lead* 500 12,000 2,250 2,300 4,340 49,000 2,510 Contaminated Soil Volume (CY) ,Total 12,865

700

300

2,165

3,300

3,200

3,200

* Lead samples must meet the 500 mg/kg limit instead of a site average (See Joliet Management Team Agreement (Appendix A)).

5.3 SRU3, Explosives and Metals in Soil SRU3, Explosives and Metals in Soil, contains sites where production and disposal activities released both types of contaminants. SRU3 is comprised of two sites, L3 and M3. One is on the LAP side and one is on the MFG area as shown in Figure 2. Site M3, where equipment and demolition materials were flash burned, contains most of the identified contaminated soils. It should be noted that only certain sub-areas under each site are included in this SRU and not the entire site. Table 5-5 lists the sub-areas and the volume of soil that needs to be remediated. Table 5-6 lists exceedances of the Remedial Goals (RGs) for sites included in SRU3.

Table 5-5 Sites and Sub-areas of SRU3 (Explosives and Metals in Soil)

Sites Sub-areas Volumes in cubic yards (CY)

Soil [Concrete] L3 Bermed area 300 M3 Flashing Area 2,000 Total 2,300

5.3.1 Site L3 Site L3 (Demolition Area, Figure 11) was described in Section 5.1.3. Results of sampling of site L3 indicated contamination of RDX and lead that exceed RGs in the western portion of the bermed area with an approximate surface area of 170 square feet (SF) from the western edge. Since samples from 2.5 feet in depth did not exceed RGs for explosives or metals, soil contamination over the 170-foot square area has been assumed to be limited to 1 foot below grade. The


volume of explosives and metals-contaminated soil within the bermed area of site L3 is estimated to be 300 CY. In addition, UXO were identified in this area as a potential safety concern. The explosives and metals contaminated soil from the bermed area at Site L3 is not classified as potentially hazardous waste; however, they may be classified as special (non-hazardous) wastes if they are excavated as part of the remedial action. Since UXO was found in other areas of L3, any remedial actions that occur will include UXO screening and removal prior to disposal of soils. Intact UXO will be treated and /or disposed appropriately based on regulations. Although it is not expected, any raw TNT in the area would be classified as D003 hazardous waste based on reactivity.

5.3.2 Site M3 Site M3, the Flashing Grounds (Figure 16), covers an area of approximately 66 acres located in the west central portion of the MFG Area adjacent to Grant Creek. From 1942 until 1988, the principal activity in the M3 was the flash burning of equipment and demolition materials to remove explosives residues inside the fenced area. The flash burning was performed at two primary locations within a 6-acre fenced area. An area of explosives stained soil, where trucks were washed after dumping explosives materials, is located between the primary burning pads and a dumping area/pad. Four additional burning pads, located to the south of the fenced area of M3, were identified in aerial photographs. These areas will be screened to determine if any areas need to be removed based on previous data and on screening results and confirmation samples. If areas exceed the excavation design value then those areas would be excavated and confirmed. Figure 16 shows the planned excavation area. The vertical extent of lead contamination is assumed to be limited to a maximum depth of 1 foot based upon the non-intrusive nature of flashing operations. Explosive contamination is commingled with the lead contamination. Metal contamination is the driving force for clean-up of M3. The volume of contaminated soil in M3 exceeding the RGs is estimated to be 2,000 CY. Soils at M3 may include soils contaminated with TCLP extractable lead (RCRA waste code D008). The results from the waste classification study indicate that the soils from the within the fenced would not be considered a D030 waste. However a portion is considered D008 waste based on lead results. Confirmation sampling will include TCLP analyses to ensure that no RCRA hazardous waste is left in place.



MIDEWIN TALLGRASS PRAIRIE AREAS (USDA)

Sites


RG (mg/kg) USDA L3

M3

Explosives 1,3,5-TNB 17 86 300 2,4,6-TNT 200 4,810 4,100 RDX 107 2,400 Metals Arsenic 21 110 Lead * 500 2,740 35,000

CONTAMINATED SOIL VOLUME (CY),TOTAL 2,300

300

2,000

* Lead samples must meet the 500 mg/kg limit instead of a site average

(See Joliet Management Team Agreement (Appendix A)).

5.4 SRU5, Organics in Soil SRU5 consists of sites L1 (Group 61) and L5 (Salvage Yard) where petroleum products were spilled. Both of these sites are within the LAP Area, as shown in Figure 2. It should be noted that only certain sub-areas under each site are included in this SRU and not the entire site. Table 5-7 lists the sub-areas and the volume of soil/sediment that needs to be remediated. Table 5-8 lists exceedances of RGs for sites included in SRU5.

Table 5-7 Sites and Sub-areas of SRU5 (Organics in Soil)

Sites Subareas VOLUMES IN CUBIC YARDS (CY)

SOIL [CONCRETE] L1 Soil near above-ground storage tanks (ASTs) at

Building 61-1 and 61-2 1275 [15]

Oil stain area 200 [15] Total 1,475 [30]

5.4.1 Site L1 Site L1 (Figure 3) was described in Section 5.1.1. Field reconnaissance identified petroleum-stained soils near aboveground storage tank (AST) locations west of Building 61-1 and north of Building 61-2. In the vicinity of the AST location at Building 61-1, samples were collected at the surface and at depths of 2.5 and 5 feet. Total Petroleum Hydrocarbons (TPH) were detected in all samples. The surface area contaminated by TPH is estimated to be 2,500 SF and contamination is assumed to extend to a depth of 10 feet. This volume of soil is estimated to be 925 CY. In the vicinity of the ASTs located at Building 61-2, soils below the ASTs within the surrounding earthen berm are heavily saturated with petroleum products and presumably are contaminated with TPH.


The hydrocarbon-stained soils are limited to the area within the earthen berm surrounding the tanks, which is approximately 900 SF based on field measurements. Therefore, the volume of soil north of Building 61-2 is estimated to be 350 CY assuming contamination extends to a depth of approximately 10 feet below grade. In summary, a total volume of 1,275 CY of soil is contaminated with TPH at the two AST locations of site L1. The confirmation sampling will include TCLP of semi-volatiles to verify that hazardous waste is not left behind.

5.4.2 Site L5 (Salvage Yard) Site L5 (Figure 12) was described in Section 5.2.3. The former oil spill area adjacent to Building 26-3 contains surface soils that contaminated with TPH. The volume of TPH-contaminated soil in the oil spill area of site L5 is estimated to be 200 CY and is limited to soils 1 foot in depth between Buildings 26-3 and 26-4. The confirmation sampling will include TCLP of semi-volatiles to verify that hazardous waste is not left behind .


MIDEWIN TALLGRASS PRAIRIE AREAS (USDA) Site L1 L5

RG (mg/kg) USDA


Polynuclear Aromatic Hydrocarbons (PAH)

Naphthalene 32,793 Acenaphthene 98,386 Anthracene 491,930 Benzo(a)anthracene 17 Benzo(a)pyrene 2 Benzo(b)fluoranthene 17 Benzo(k)fluoranthene 171 Chrysene 1708 Dibenz(a,h)anthracene 1.7 Fluoranthene 65,591 Fluorene 65,591 Indo(1,2,3)pyrene 17 Pyrene 49,193 Excavation Design Parameters TPHs 2,500 111,000 10,000 Contaminated Soil Volume (CY) ,Total 1,475

1,275

200

[END OF SECTION]


6 SUMMARY OF SITE RISKS Risk assessment consists of evaluating the types and levels of contaminants present, the pathways by which receptors could potentially be exposed to these contaminants, and the toxicity and/or carcinogenicity of the contaminants. Human health risk models and other appropriate USEPA and Illinois EPA criteria were used during the development of the 1998 ROD to establish soil cleanup values for each of the 79 contaminants of concern identified in the soils. The 1998 ROD established the final facility-wide groundwater RGs, final RGs for soil for industrial land use scenarios, and final RGs for three contaminant groups under the prairie use scenario. The 1998 ROD also presented interim soil RGs for the contaminant groups of explosives (SRU1), metals (SRU2), inter-mixed explosives with metals (SRU3), and organics (SRU5) on USDA lands [lands currently managed by or intended for the USDA for establishment of the MNTP]. The 1998 ROD specified that a multi-agency team develop final cleanup levels that are protective of human health and the environment for USDA lands. Two different multi-agency teams, made up of representatives from the USEPA, Illinois EPA, Army, US Department of Agriculture/Forest Service, US Fish and Wildlife Service, Illinois Department of Natural History, Illinois Department of Public Health, and the Restoration Advisory Board (representing the community), were established to complete this task and were called the Ecological Work Group and the Human Health Work Group.

6.1 Human Health Risk

6.1.1 Human Health Risk Assessment Two groups of receptors are expected to be present on JOAAP lands that will be developed into the MNTP - prairie workers and visitors. Prairie workers are further divided into employed and volunteer workers. The types of activities engaged in by employed and volunteer workers are expected to be similar; however, the duration of exposure and exposure frequency differs between employed and volunteer workers. The following activities were evaluated for the employed and volunteer prairie worker: tilling, planting, weeding, constructing and maintaining trails, prairie burns, plant and seed sample collection, field trips, and camping. The exposure routes for contaminated soils that were evaluated for workers and volunteers were ingestion, inhalation, and dermal. Since young children may accompany adult volunteer workers, childhood exposures were also included in the quantitative evaluation for volunteer prairie workers. Activities of visitors to the MNTP may include picnicking, hiking, and camping. The expected frequency and levels of exposure to surface soils would be lower than the frequency and exposure to soil for prairie workers; therefore, visitors were not evaluated quantitatively. The preliminary remediation goals developed for the prairie workers are protective of all persons expected to be present at the MNTP, and represent a 1 x 10-6 excess risk for carcinogens or a hazard index of 1 for noncarcinogens. Additional details regarding the exposure routes and risk equations used to calculate cleanup levels can be found in the “Joliet Army Ammunition Plant Human Health Preliminary Goals Midewin National Tallgrass Prairie,” dated September 2000.


6.2 Ecological Risk Assessment

6.2.1 Ecological Risk Assessments Conducted The overall process for developing a range of cleanup values for ecological receptors started with selection of assessment endpoints and the definition of the conceptual site model. Six different groups of ecological receptors were evaluated based on the assessment endpoints developed for the project. These included the following: plants; invertebrates in soil; mammals, birds, and herpetofauna that consume plants (herbivores); mammals, birds, and herpetofauna that consume invertebrates; mammals, birds, and herpetofauna that consume other animals (carnivores); and Federal and State threatened and endangered species. Toxicity reference values (TRVs) were then developed. A TRV is either a soil concentration or an ingested dose of a given contaminant that represents a specific level of toxicity for a given ecological receptor. TRVs were developed using site-specific toxicity tests, published benchmarks, or literature surveys. The work group developed two TRVs for each receptor that represent different degrees of protection from contaminant toxicity: a no observed adverse effects level (NOAEL), which is the highest concentration at which no adverse effects are observed; and a lowest observed adverse effects level (LOAEL), which is the lowest concentration at which effects are observed. Information was then collected on habitat and receptors attributes, including soil type, dietary preferences, ingestion rates, body weights, etc. Next, exposure models were developed for mammal, bird, and herptile receptors considering biouptake models for wildlife and biochemical properties of the chemicals of concern. Finally, TRVs were combined with the exposure assessment to derive the range of cleanup values for each chemical of concern. Details of the process used to develop cleanup values that are protective of the ecological resources at the MTNP can be found in the “Ecological Preliminary Remediation Goals, Joliet Army Ammunition Plant, and Midewin National Tallgrass Prairie,” dated August 2000.

6.2.2 Development of Preliminary Remediation Goals Using the 79 contaminants of concern identified in soil in the 1998 ROD, a range of cleanup values for the USDA lands were developed by the Ecological Work Group and the Human Health Work Group and were presented in their reports. In addition to the 79 contaminants of concern, the Human Health Work Group calculated cleanup values for some volatile organic compounds. Both teams did not present cleanup values for some contaminants because they did not contribute to unacceptable health risks for the evaluated receptors (e.g., aluminum). Additionally, cleanup values could not be calculated for a few chemicals of concern because no toxicity data were available (e.g., phosphate, sulfate). The multi-agency Management Team, created to provide direction to the work groups and resolve the cleanup values to be used at USDA lands, evaluated the range of cleanup values developed by the work groups. Taking into account the nature and extent of the contamination, the conservative nature of the cleanup values and the uncertainties associated with developing these values, the Management Team applied risk management principles and developed a set of soil RGs to be applied to the USDA lands. Table 6-1 and Table 6-2 present the RGs developed by the Management Team. The RGs are considered to be protective of human health and the environment and are compatible with development of the tallgrass prairie. The rationale for the RGs and an agreement on how they will be applied can be found in Appendix A. Additional rationale is provided below. The Management Team agreed certain chemicals, or groups of chemicals (i.e., volatile organic compounds and pesticides), could be eliminated as chemicals of concern. Several compounds were


eliminated as a chemicals of concern since they were not detected above background levels (beryllium) or were not detected at all (tetryl, 2,4,6-trinitrophenol) on the USDA lands. Volatile organic compounds were eliminated as contaminants of concern since they are not expected to be present in soils due to the likelihood the compounds have migrated or degraded so that they are not longer present. Soil data support this assumption since only low levels of a few volatile organic compounds at a few sites were present when sampled in 1993. Pesticides were also eliminated as contaminants of concern since some pesticides are present at a few sites but are co-located with other chemicals at levels that require remedial actions. Therefore, RGs are not presented for those compounds that were eliminated as contaminants of concern. The Management Team reviewed the cleanup values for polynuclear aromatic hydrocarbons (PAHs) proposed by the work groups. Due to the suspected sources of the PAH contamination (heating fuel or oil), the compounds are localized and are not expected to migrate. In some cases, the PAH contamination is co-located with other compounds that are found at concentrations requiring remedial action. Because of the uncertainties of the work groups’ cleanup values, and because the PAH contamination is considered to not contribute significantly to unacceptable risk to the environment, the Management Team proposed using the human health based PAH cleanup values as the PAH RGs. Any residual PAH contamination remaining at sites after cleanup will continue to degrade through natural processes.


Table 6-1 Remediation Goals Developed by the Management Team for the Interim ROD Sites

Contaminant of Concern (COC)

RG (average concentration should be no higher than this) Basis for RG

Excavation Design Value Basis for Excavation Design Value

Aluminum N/A Eliminated as a COC because it is generally not toxic. N/A

Eliminated as a COC because it is generally not toxic.

Antimony 50

The RG was developed after examining the most sensitive receptors (plants, soil invertebrates and wetlands invertebrates). Selected 50 as a reasonable number based in part on conservative assumptions in Ecological Work Group report. Average of 50 will result in majority of areas being below LOELs values indicated in Ecological Work Group report. 757

Antimony is not extensively present in high levels. For excavation design purposes, extensive plant data are not available; excavation design value is 757 mg/kg for humans. The excavation design value is protective of human health from the Human Health Work Group report.

Arsenic 21

The RG was developed after examining the most sensitive receptors (insectivores). 21 was the value set at both the industrial site and in the interim ROD for USDA lands. At the industrial site, confirmation sampling revealed that actual background was significantly lower than 21. 84

The excavation will be designed based on 2x the upper tolerance limit (UTL) of the data as determined in the Remedial Investigation.

Barium 625

The RG was developed after examining the most sensitive receptors (insectivores and carnivores). Selected 625 as a reasonable number based in part on conservative assumptions in Ecological Work Group report. Average of 625 will result in majority of areas being below LOELs values indicated in Ecological Work Group report. 1950

Excavation design value is a calculated EPC (Exposure Point Concentration) based on applying a factor of 10 to the adjusted background estimate (195, as calculated using statistical transformation of the original background data to account for non-normal distribution).

Beryllium N/A

Eliminated as a COC because it is not found at any interim ROD site at levels significantly above background N/A

Eliminated as a COC because it is not found at any interim ROD site at levels significantly above background.


Cadmium 63

The RG was developed based on “no adverse effects level” for plants from a study by Levy et al (1999) 220

Excavation design value is a calculated EPC based on applying a factor of 10 to upper end value for insectivores provided in the Ecological Work Group report (Table 35, Appendix B).

Chromium 213

The RG is a calculated EPC using 10 times the LOEL for insectivores based on the Ecological Work Group’s calculated threshold of 21.3. The factor of 10 was used in this instance because of the lack of data in the literature and on the site distinguishing between the various oxidation states of Chromium (+3 and +6) 213

The RG and design value represent a calculated EPC for insectivores based on the Ecological Work Group’s calculated threshold of 21.3.

Cobalt 240

The RG is representative of a low adverse effects level for plants and soil invertebrates from the Ecological Work Group report. 2400

The literature available for adverse effects developed Dutch Ecotoxicological Intervention Values (EIV) concentrations, which typically represent NOELs. The design value is a calculated LOEL value (NOEL X 10=LOEL).

Copper 190

The RG was developed after examining the most sensitive receptors (plants, soil invertebrates and wetlands invertebrates). Average of 190 will result in majority of areas being below LOELs values indicated in Ecological Work Group report. 925

The literature used by the Ecological Work Group for adverse effects developed EIV concentrations, which typically represent NOELs. The design value represents a low adverse effects level for plants from a recent study in the literature (Gartside and McNeilly 1999)

Iron N/A

Removed from the list of COCs because it is not toxic at levels found on JOAAP and site specific conditions (soils not sufficiently acidic) N/A

Removed from the list of COCs because it is not toxic at levels found on JOAAP and site specific conditions (soils not sufficiently acidic)

Lead 500

This RG, unlike all others, is a “not to exceed number” based on the low adverse effects level for plants and from Khan and Frankland (1984), and similar to the LOEL for plants from Ecological Work Group report (530). 500

This RG, unlike all others, is a “not to exceed number” and therefore excavation design is developed at the same value as the RG (no averaging).

Manganese N/A


N/A



Mercury 10

The RG was developed after examining the most sensitive receptors (insectivore). Average of 10 will result in majority of areas being below LOELs values indicated in Ecological Work Group report. 13

The excavation design value was developed by using the PRG for the most sensitive receptor (insectivores) in Table 35, Appendix B of the Ecological Work Group report. The literature available for adverse effects developed EIV concentrations, which typically represent NOELs. The design value is a calculated LOEL value (NOEL X 10=LOEL)

Nickel 210

The RG was developed after examining the most sensitive receptors (wetlands invertebrates). Average of 210 will result in almost all areas being below LOELs values indicated in Ecological Work Group report. 2090

The excavation design value was developed by using the value for the most sensitive receptor (insectivores) in Table 35, Appendix B of the Ecological Work Group report (Used 209 instead of 210). The literature available for adverse effects developed EIV concentrations, which typically represent NOELs. The design value is a calculated LOEL value (NOEL X 10=LOEL)

Selenium N/A

Eliminated as a COC because it is not found at any interim ROD site at levels significantly above background. N/A


Silver 16

The RG is developed at 2x background UTL as calculated using statistical transformation of the original background data to account for non-normal distribution. In addition, the LOEL for plants from study by Hirsch (1998) showed adverse effects to Chinese Cabbage at concentrations of 14 ppm. 9467

The excavation design value is developed using the value calculated by the Human Health Work Group to protect human health. Functionally, silver is only a concern at a couple of sites, and values significantly above background are co-located with other contaminants. Excavation design value combined with the application of the average RG will ensure no dangerous levels remain.


Thallium 2 X UTL

The analytical results from past sampling efforts are probably high because of analytical interference from Magnesium. Army will establish background levels using modern analytical techniques that will adjust for the interference. USEPA and IEPA will review and approve method and sampling approach prior to sampling and establishment of the UTL. 86

The excavation design values is developed by removing a factor of 10 safety factor from the carnivore upper value as listed by the ecological risk workgroup Table 35, Appendix B.

Vanadium N/A

Eliminated as a COC because it is not found at any interim ROD site at levels significantly above background. In addition, records do not indicate that Army activities were likely to have produced this specific contaminant, which is associated with combustion of specific fossil fuels. N/A

Eliminated as a COC because it is not found at any interim ROD site at levels significantly above background. In addition, records do not indicate that Army activities were likely to have produced this specific contaminant, which is associated with combustion of specific fossil fuels.

Zinc 720

The RG was developed after examining the most sensitive receptors (insectivore). Average of 720 will result in vast majority of areas being below LOEL values indicated in Ecological Work Group report for all other receptors. 2500

The excavation design value was developed by using the value for the most sensitive receptor (insectivores) in Table 35, Appendix B of the Ecological Work Group report. The literature available for adverse effects developed EIV concentrations, which typically represent NOELs. The design value is a calculated LOEL value (NOEL X 10=LOEL)

DNAP N/A Removed from the list of COCs because it does not occur on any interim ROD site. N/A

Removed from the list of COCs because it does not occur on any interim ROD site.

1,3-DNB N/A Removed from the list of COCs because it does not occur on any interim ROD site. N/A


2,4- DNT 20

Both the RG and design value are protective of human health. On average this concentration will be protective of other receptors. Ecological Work Group report value of 4.87 to protect insectivores was based on many conservative assumptions. 20

Both the RG and design value are protective of human health. On average this concentration will be protective of other receptors. Ecological Work Group report value of 4.87 to protect insectivores was based on many conservative assumptions.


2,6-DNT 20

Both the RG and design value are protective of human health. On average this concentration will be protective of other receptors. Ecological Work Group report value of 4.87 to protect insectivores was based on many conservative assumptions. 20

Both the RG and design value are protective of human health. On average this concentration will be protective of other receptors. Ecological Work Group report value of 4.87 to protect insectivores was based on many conservative assumptions.

HMX 2860

Based on a calculated EPC for herbivores using the Ecological Work Group value of 286 (Table 35, Appendix B). 2860

Based on a calculated EPC for herbivores using the Ecological Work Group value of 286 (Table 35, Appendix B).

Nitrobenzene N/A Removed from the list of COCs because it does not occur on any interim ROD site N/A

Removed from the list of COCs because it does not occur on any interim ROD site

2-Nitrotoluene N/A Removed from the list of COCs because it does not occur on any interim ROD site N/A


RDX 107

The RG is a low effects level for carnivores from the Ecological Work Group report and is not significantly different from the LOEL for plants. 125

The design value is protective of human health from the Human Health Work Group report. Excavation design value combined with the application of the average RG will ensure no dangerous levels remain.

Tetryl N/A Removed from the list of COCs because it does not occur on any interim ROD site N/A


1,3,5- TNB 17 The RG is based on evaluation of the results of a site specific study on plants and earthworms. 386

The excavation design value is a calculated EPC for insectivores using the value in Table 35, Appendix B of the Ecological Work Group report. The literature available for adverse effects developed EIV concentrations, which typically represent NOELs. The design value is a calculated LOEL value (NOEL X 10=LOEL). Excavation design value combined with the application of the average RG will ensure no dangerous levels remain.

2,4,6- Trinitrophenol N/A

Removed from the list of COCs because it does not occur on any interim ROD site N/A



2,4,6- TNT 200

The RG is based on a study conducted on site, and a study from the literature (Krishnan et al 2000). The literature study showed low adverse effects for plants at 270. However, that study and the site specific study suggested that some plants are more sensitive. The level 200 was a compromise position based on risk management considerations. 459

Because of the limited data available for plants and because of confounding effects which made the interpretation of the Army’s site specific study difficult, the design value is developed to be protective of human health from the Human Health Work Group report. The excavation design value combined with the application of the average RG will ensure no dangerous levels remain.

**** Points of Rationale for Excavation Design Value and RG Selection 1) The levels selected should be protective of ecological receptors. 2) The levels selected should be protective of human health, especially for workers and volunteers engaged in restoration activities. 3) The Management Team concluded that the assumptions (e.g., using the smallest body weight and largest ingestion rate to calculate exposure) used by the Ecological Work Group were very conservative; therefore, the Management Team started with the low end of the higher values contained in the Ecological Work Group report. 4) Values protective of ecological receptors are generally lower than values protective of human health. 5) Some, albeit minor, adverse effects to the environment are acceptable. 6) The levels selected should, for the most part, not represent absolute not to exceed numbers, but that on average contaminants in the soils should not exceed the selected RG. 7) The excavation should be designed to achieve these average values, and therefore, the design value generally exceeds the RG. 8) Some COCs should be dropped from the list because they are not toxic. 9) Some COCs should be dropped from the list because they do not occur on interim ROD sites. 10) Over the past several years analytical methods available at laboratories have greatly improved. Therefore, for some contaminants, past reported levels for the site are highly suspect, and likely exceed actual concentrations. For these contaminants selection of the RG was based on statistical analyses of past data. Confirmation will be based on current analytical methods.


11) Newly discovered or conducted studies were used to validate or refute the recommended cleanup values contained within the Ecological Work Group's report. 12) Further analyses of the Ecological Work Group's report led to a modification of some of their numbers. In some cases, the Work Group believed that the original authors were reporting LOEL's, when they were actually reporting NOEL's. 13) In some cases a more or less conservative value was selected because after taking RGs for more prevalent contaminants into consideration, the cleanup value of the COC under discussion did not affect removal plans.


Table 1-2 Polynuclear Aromatic Hydrocarbons Remediation Goals

Constituents RG (mg/kg)

Naphthalene 32,793 Acenaphthene 98,386

Acenaphthylene No Data Available Anthracene 491,930

Benzo(a)anthracene 17 Benzo(a)pyrene 2

Benzo(g,h,i)perylene No Data Available Benzo(b)fluoranthene 17 Benzo(k)fluoranthene 171

Chrysene 1708 Dibenz(a,h)anthracene 1.7

Fluoranthene 65,591 Fluorene 65,591

Indeno(1,2,3)pyrene 17 Phenanthrene No Data Available

Pyrene 49,193

[End of Section]

JOAAP Record of Decision Interim Soil Operable Unit Final 6-11

7 Remedial Action Objectives (RAOs) The primary objective of the cleanup at JOAAP is to effectively mitigate, minimize threats to, and provide adequate protection of human health and the environment. To meet this objective, the Army developed remedial action objectives for the interim ROD sites. The objectives of the final remedial actions are summarized as: 1. Clean up contaminants to the site-specific and chemical-specific remediation goals (RGs); 2. Prevent human and environmental exposure to contamination at concentrations above the RGs; 3. Eliminate soil contamination as a continuing source of groundwater contamination; 4. Prevent migration of contaminants; and 5. Actions will not leave behind any characteristically hazardous RCRA wastes.

7.1 Development of Remediation Goals (RGs) The RGs (Tables 6-1 and 6-2) developed by the JOAAP Management Team provide an acceptable level of risk for human health (i.e. less than 1x10-6 for carcinogens and Hazard Index less than 1 for noncarcinogens) and do not pose a risk to populations of plants or animals or individual endangered or threatened species. The remediation goals are to be applied as specified in the JOAAP Management Team Agreement (Appendix A). As such they will be goals for the excavation site average instead of a point by point chemical comparison. The RGs will be used for both surface and subsurface soil. Lead is the exception to this remedial action plan. Lead will be compared on a sample by sample basis against the remedial goal of 500 ppm. This is outlined in the JOAAP Management Team Agreement (Appendix A). The Excavation Design Values (also presented in Table 6-1) are values that are used to trigger and design the excavation bounds from the available data. The Army reserves the right to work with the USEPA and IEPA with input from the MNTP stakeholders to address unknown conditions or chemicals encountered during remedial actions.

[END OF SECTION]

JOAAP Record of Decision Interim Soil Operable Unit Final 7-1

8 DESCRIPTION OF ALTERNATIVES The alternatives evaluated for the interim ROD sites are described in this Section. The SOU contains four SRUs for which a total of four remedial alternatives were analyzed in detail in a focused feasibility study. Some of these alternatives are common among the SRUs. In addition, some alternatives have several common remedial actions (e.g., soil excavation). These common alternatives or actions are described once and referred to, when appropriate, under each SRU's description. Exceptions from the general description are noted under each alternative's description.

8.1 Soil Operable Unit

8.1.1 Common Soil Alternative Remedies The No Action and the Limited Action alternatives are common to all SRUs.

8.1.1.1 Alternative 1: No Action Alternative Under this alternative, the U.S. Army would take no action to prevent exposure to contaminated soil. The NCP and CERCLA as amended by SARA require that the No Action alternative be evaluated to establish a baseline for comparison of other alternatives, especially, in terms of cost and protection of human health and the environment. This alternative would neither eliminate nor reduce the exposure of humans or the environment to the contaminants of concern, and the existing risk to humans and the environment would remain. There is no implementation time or cost associated with the No Action alternative because no additional remedial activities are implemented.

8.1.1.2 Alternative 2: Limited Action Alternative The Limited Action alternative was developed to provide actions that may be taken to limit human exposure to the contaminated soil. This alternative is usually not effective at reducing the toxicity, mobility, or volume of contaminants, but it would reduce the probability of physical contact with the contaminated soil, thereby reducing risk to human health. This alternative would not reduce the risk posed by the soil to ecological receptors such as Federal and State Endangered or Threatened species. The Limited Action alternative involves the following:

• Excavation resulting in unacceptable human health risk would be prohibited. These restrictions would be included in property transfer documentation.

• Fences and signs would be placed around all currently unfenced sites and an inspection and maintenance program of these fences and signs would be implemented.

• Risks associated with future land use would be specified in the property transfer documentation. • Five-year review plan would be implemented. Five-year reviews are required by the NCP at all

sites where hazardous chemicals remain at sites above levels that allow for unlimited use and unrestricted exposure. The review would present the analytical data and would include a determination of whether additional remedial actions are required at the sites under this SRU.

Although this alternative would not result in the treatment of soil or the significant reduction of contaminant concentration, the Institutional Controls alternative would limit potential human exposure to the contaminants of concern, but would not mitigate environmental impacts and would not prevent migration of contaminants via erosion or other mechanisms.


8.1.2 Common Soil Actions As previously mentioned, the alternatives have some common operations. These actions are described below and then referenced later under the description of each alternative. Any deviation from the general description is noted under the description of each alternative.

8.1.2.1 Soil Excavation for Treatment or Disposal Contaminated soil will be excavated from the various sub-areas within each site, loaded into trucks, and transported to a central stockpiling area for treatment or transported to a landfill for disposal. Conventional earthmoving equipment would be used for excavation. Two approaches to excavation design will be used: one for excavation of release areas where data indicate a release of a site contaminant has occurred and is above the average site RGs or exceeds the excavation design value and one for points that have concentrations exceeding the excavation design value but surrounding points do not indicate a release (anomalies). Release Areas. The Army will design excavations at the sites to encompass areas of contaminant releases above the excavation design value based on existing data and any data collected from pre-excavation sampling. Depths of excavations will be based on available data and any pre-excavation sampling data. Based on data currently available, excavations are generally not expected to exceed four feet in depth. However, it may be necessary for some individual excavations to exceed four feet in depth where sampling indicates source areas exist that could result in significant ecological or groundwater impacts. As the lead agency, the Army will make a recommendation as to when the excavation for a specific site is completed in terms of depth and aerial extent. The final excavation will be approved by the USEPA and Illinois EPA in consultation with the US Forest Service, Illinois Department of Natural Resources and US Fish and Wildlife Service. Anomalies. Where existing data indicate isolated points where excavation design values are exceeded, but no reasonable explanation for the exceedence exists, excavation will be limited to a 5 foot by 5 foot area surrounding the point to a depth of 1 foot below the sample point showing the high concentrations. If available, concentration gradients down the soil column will be used to tailor the excavation depth or possibly eliminate the site from consideration (e.g., high concentrations of naturally occurring metals are found only at depth, indicating no surficial release has occurred). Anomalies will be identified on a site-specific basis considering site history, comparison to constituents of adjacent sampling points, and proximity to adjacent points. The Remedial Design will highlight such sites. Confirmation sampling will not be conducted at these sites. Soil excavation would continue until sampling confirms that average excavation site concentration levels in the soil are below RG levels. If necessary, excavated areas would be backfilled for safety reasons and to avoid ponding of surface runoff with soil from an on-site borrow location. Some treated soil could also be used as clean backfill at any on-site location that does not require structural fill. Depending upon the time schedule for excavation, this may or may not be the same location from which the soil was removed. Backfilled areas would be regraded to conform to the surrounding topography. Most of these backfilled areas would be revegetated with input from the MNTP staff.

8.1.2.2 Pre-Sampling The Army will conduct pre-excavation sampling to provide data on potential areas of contamination as evidenced by stained or disturbed soils or where existing data indicate concentrations above the excavation design value but do not provide sufficient characterization to design an accurate excavation. Stain or suspect soils will be sampled as documented in Section 3.2.3 of the JOAAP Management Team Agreement (Appendix A).


8.1.2.3 Confirmatory Sampling Confirmatory sampling will be modeled after the confirmatory sampling procedures currently used and documented in the Sample and Analysis Plan appendix to the Remedial Design/Remedial Action Workplan, in effect for all final 1998 ROD sites, as discussed below. Confirmation sampling will be performed to verify that the lateral and vertical limits of soil contamination have been reached by the excavation activities. The results of this sampling activity will be used to confirm that the soil remaining does not exceed the lower cleanup value on average across the excavation and potentially impacted surrounding area, with the exception of lead (Pb) contaminated soils, which will be excavated to 500 mg/kg at all points. Confirmation sampling will extend beyond the area of excavation to encompass existing sampling points where the lower cleanup values for contaminants associated with the release area were exceeded (Excavation Fringe Area). This will provide assurance that the average concentrations of contaminants remaining within the impacted area are below the lower cleanup values and are protective for the most sensitive receptors. Due to the small, irregular shaped excavations anticipated at several of the sites, an unbiased, random approach to locating samples may not provide adequate assurances that cleanup goals have been met. Instead, a minimum number of confirmation samples will be collected from locations that are appropriate for a specific excavation, targeting areas that have the greatest potential for contamination. Some examples of potentially contaminated areas include: around building foundations and small disposal areas. Two different decision processes will be used to enumerate the number of samples required to confirm adequate source removal: one for trench excavations and one for area excavations. Trench excavations include excavations that occur along a ditch or pipeline, and are relatively uniformly contaminated along its length. Area excavations include all other types of excavations whether they are shallow or deep and narrow or wide. Lateral Extent Confirmation Sampling. Area Excavations. Discrete samples collected to confirm the lateral extent of area excavations will be located at a minimum of one per 50 feet along the edge of the excavation, or at a minimum one sample per face of an excavation. Selected locations will be associated with previous hot spots where appropriate. For excavations exceeding 5 feet in depth, additional samples will be collected from the sidewalls using the same sample collection frequency. Sidewall samples will be collected approximately 2 to 3 foot vertical intervals from the floor of the excavation. For excavations less than 5 feet deep, each sidewall sample will be collected (grab sample) from approximately one-half the depth of the excavation at the selected sample location. If underground piping enters an excavation, a confirmation grab sample will be collected from within 1 foot beneath the bottom of the pipe where it enters the excavation. Trench Excavations. Samples collected to confirm the lateral extent of trench excavations will be collected from the ground surface (or trench sidewalls if the trench excavation is greater than 5 feet deep) on both sides of the trench at the following locations along the trench:

Within the first 10 feet of the beginning of the trench


Within the first 10 feet of the end of the trench At least 1 additional location between the beginning and end of the trench but no less than 1

every 50 feet At any bends or tees (may take the place of the above listed sample requirement)

Sidewall samples will be collected (grab sample) across an area approximately between 2 to 3 feet above the base of the excavation. Excavation Fringe Area. The fringe area immediately surrounds the excavation and is defined by sampling points outside the excavation that exceed the lower cleanup value of contaminants of concern within the excavation area. Lateral extent confirmation sampling will be conducted on the fringe of the excavation encompassing all points that exceed the lower cleanup value for any constituent identified within the excavation area above the lower cleanup value. Samples will be taken at a minimum of 1 sample per 1000 square feet within the boundaries of the fringe area. For areas less than 3000 square feet, a minimum of 3 samples will be collected. Sampling points within the fringe area will be set to the depths of the data used to define the fringe. Vertical Extent Confirmation Sampling. Area Excavations. For area excavations, a minimum of 1 sample per 1000 square feet will be collected to confirm the vertical extent of contamination. For areas less than 3000 square feet, a minimum of 3 samples will be collected. Samples will target locations that have a higher potential for contamination (such as beneath hot spots, sumps, etc.) with any additional sample locations selected uniformly across the remaining floor of the excavation. Trench Excavations. For trench excavations, a minimum of 1 sample per 50 feet of the excavation will be collected to confirm the vertical extent of contamination. At least 2 vertical confirmation samples will be collected per trench excavation. Sample locations will be spaced uniformly along the trench, targeting locations that have a higher potential for contamination, such as at either end of the trench or at tees or bends in the trench. 3.2.3.3 Confirming Closure. Discrete samples will be analyzed for the suite set of contaminants found within the release areas that exceed the lower cleanup value. Methods for analyses (field and lab analyses) will be selected as part of the remedial design effort. Reporting limits will be set below the lower cleanup value for each constituent. Analytical results will be used to calculate the average concentration for each constituent across the excavation and fringe area for comparison to the lower cleanup value, with the exception of lead for which any point exceeding the cleanup value of 500 mg/Kg will undergo further excavation. Any additional excavation will be conducted in a rectangular area centered on the sample or samples that drove the average concentration above the lower cleanup value, according to the following conditions for lateral extent and vertical extent. Vertical Extent. For any excavation floor sampling location where additional excavation is required, an additional six inches of materials will be excavated at least five feet in each direction from each sampling point that drove the average concentration above the lower cleanup value. If adjacent sampling points are targeted for supplemental excavation based on high concentrations, excavation will encompass the area between the points. At a minimum, this will result in a supplemental excavation 10 feet wide, 10 feet long, and 0.5 feet deep, for a total of 50 cubic feet centered on the high sample location. For areas with adjacent sampling points with high concentrations, the dimensions of the supplemental excavation cannot be determined until results are reviewed; however, a minimum of an additional 50 cubic feet will be excavated as a result at selected sampling points of high concentration if average concentrations exceed


the lower cleanup value. Supplemental excavation for lead (Pb) will be designed similar to the approach above to remove all concentrations above the cleanup value of 500 mg/Kg. Lateral Extent. For any excavation side wall sampling location where additional excavation is required, additional excavation will be conducted 5 feet into the sidewall of the excavation and 5 feet on either side of sampling points that drove the average concentration above the lower cleanup value to the full depth of the adjacent excavation. If adjacent sampling points are targeted for supplemental excavation based on high concentrations, excavation will encompass the area between the points. At a minimum, this will result in a supplemental excavation of 10 feet wide by 5 feet long and as deep as the adjacent excavation. For areas with adjacent sampling points with high concentrations, the dimensions of the supplemental excavation cannot be determined until results are reviewed. Supplemental excavation for lead (Pb) will be designed similar to the approach above to remove all concentrations above the cleanup value of 500 mg/Kg. Final Confirmation. Confirmation sampling will be conducted within the bounds of the supplemental excavation area in accordance with the procedures above. The results of the supplemental sampling will be averaged with the initial confirmation sampling results to ensure that the residual average is below the lower cleanup value, except for lead (Pb) for which each point will be excavated to the cleanup value of 500 mg/Kg.

8.1.2.4 Soil Transportation It would be impractical and extremely expensive to establish a separate treatment area at each site in a SRU. Therefore, a central treatment area has been established in the MFG Area to process and bio-treat explosives and organic contaminated soils because the majority of this contaminated soil is within the MFG Area. Trucks would be used to haul the SRU 1 and SRU5 soil to the treatment area. Trucks transporting soil from the LAP Area to the treatment area in the MFG Area may have to cross Illinois Route 53 and must comply with the Regulations of Illinois Department of Transportation. Similarly, trucks transporting SRU2 and SRU3 soil from the MFG area to a disposal location will likely have to cross Illinois Route 53 and must comply with the Regulations of the Illinois Department of Transportation. Trucks that transport materials on Army lands are not required to be lined, tarped, or decontaminated in the soil transportation; however, transportation across lands that have been transferred to the USDA will require the same requirements as crossing a public road. The RD/RA Work Plan will specify the requirements based on the planned transportation route.

8.1.2.5 Soil Preparation for Treatment After reaching the treatment area, contaminated soil would be stored in a stockpile area. Soil would be blended and screened either at the excavation site or within the stockpile area, and any large stones, debris, and raw TNT will be removed using a series of shaker/separator units. Blending of hot-spot soil with less contaminated soil would be conducted, as necessary, to obtain a homogenized soil for feed into the treatment system. Debris and large stones will be stockpiled for possible pressure washing and will be reused or properly disposed. Any TNT chunks will be removed and stockpiled for open burn/detonation or incineration at a permitted facility, or processed to be blended back for treatment. All trucks used to transport soil will be routed through a wheel wash prior to exiting the treatment area. Wash water from the trucks and from the pressure wash operation will be routed to SB-1 and used as makeup water in the treatment area. If unexploded ordnance (UXO) is encountered, it will be screened and removed for open burn/detonation or for off-site incineration at a permitted facility.


8.1.2.6 Soil Disposal The Army will use the following options that exist for disposal of treated or untreated soils. Soils will be tested as appropriate and in accordance with procedures approved by USEPA and IEPA to determine whether the soils are RCRA hazardous wastes and whether RGs are exceeded. Based on the results of these tests, the disposal options for the soils will be as follows:

1. All soils which are contaminated with RCRA hazardous wastes must be: • Disposed at a RCRA Subtitle C facility, or • Treated and disposed at a RCRA Subtitle C facility, or • Treated and disposed at a RCRA Subtitle D facility or may be used as subgrade or

backfill, if the soils are not characteristically hazardous under RCRA, achieve RGs, and do not exceed LDRs under RCRA.

2. All soils which exceed RGs and are not RCRA hazardous waste must disposed as above or:

• Disposed at a RCRA Subtitle D facility, or • Used as subgrade fill material in capped landfills at JOAAP.

3. All remaining soils can be disposed as above, or

• Reused (e.g., as backfill) with regulatory and stakeholder acceptance.

These options are available for all soils. Applicable final rule-making under RCRA may amend this section.

8.1.3 SRU1: Explosives in Soil Four alternatives were evaluated in detail in this SRU:

1. No Action (Section 8.1.1.1); 2. Limited Action (Section 8.1.1.2); 3. Excavation/Treatment 4. Excavation/Disposal

8.1.3.1 Alternative 3: Excavation/Treatment This alternative includes the following actions:

• Pre-Sampling (Section 8.1.2.2) • Soil Excavation for Treatment or Disposal (Section 8.1.2.1); • Confirmatory Sampling (Section 8.1.2.3); • Soil Transportation (Section 8.1.2.4); • Soil Preparation for Treatment (Section 8.1.2.5); • Treatment; and • Soil Disposal (Section 8.1.2.6).

8.1.3.1.1 Bioremediation Process Amendment Materials Preparation/ Windrow Construction/Windrow Operation All actions involving biotreatment have been and currently are in operation at the JOAAP. This includes the addition of amendments, windrow construction, windrow monitoring and windrow removal. Details on the amendment material and ratio will be included in the remedial design. The cost for this action including O&M of the facility has been established by the past 4 years of operations and the cost of this


alternative will be all inclusive when discussing the treatment process. One unit cost will be provided that encompasses all aspects of the treatment process. Windrow Removal and Deposition of Treated Compost Treated soil may be used as clean backfill at any on base location that does not require structural fill. Depending upon the time schedule for excavation, this may or may not be the same location from which the soil was removed. Chemical determination of suitability of the treated soil must be performed before it can be used as backfill. The process for this determination will be further described in the design documents as agreed upon by Federal facilities signatories in coordination with USFS representatives. When the treatment of all explosive-contaminated and organic contaminated soil is complete from all sites, the facility will be disassembled, decontaminated and salvaged. Any parts of the facility that are not desired by the USDA (or future owner) and cannot be salvaged will be deposited in the Will County Landfill as construction debris or stored until the landfill becomes available.

8.1.3.2 Alternative 4: Excavation/Disposal This alternative includes the following actions:

• Pre-Sampling (Section 8.1.2.2) • Soil Excavation for Treatment or Disposal (Section 8.1.2.1); • Confirmatory Sampling (Section 8.1.2.3); and • Soil Disposal (Section 8.1.2.6).

8.1.4 SRU2: Metals in Soil Three alternatives were evaluated in detail in this SRU:

1. No Action (Section 8.1.1.1); 2. Limited Action (Section 8.1.1.2); 3. Excavation/Disposal (Section 8.1.3.2).

8.1.5 SRU3: Explosives and Metals in Soil Three alternatives were evaluated in detail in this SRU:

1. No Action (Section 8.1.1.1); 2. Limited Action (Section 8.1.1.2); 3. Excavation/Disposal (Section 8.1.3.2).

8.1.6 SRU5: Organics in Soil Four alternatives were evaluated in detail in this SRU:

1. No Action (Section 8.1.1.1); 2. Limited Action (Section 8.1.1.2); 3. Excavation/Treatment (Section 8.1.3.1) 4. Excavation and Disposal (Section 8.1.3.2).

[END OF SECTION]


9 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

This section evaluates and compares each of the alternatives described in Section 8.0 with respect to the nine criteria used to assess remedial alternatives as outlined in Section 300.430(e) of the NCP.

9.1 Nine Evaluation Criteria Section 300.430(e) of the NCP lists nine criteria by which each remedial unit alternative must be assessed. The acceptability and performance of each alternative against the criteria is evaluated individually so that relative strengths and weaknesses may be identified. The Threshold Criteria must be satisfied in order for an alternative to be eligible for selection. The Balancing Criteria are used to weigh major tradeoffs among alternatives. The Modifying Criteria are based on public comment received on the Proposed Plan. The remedial alternatives are evaluated against the following criteria for final actions. Similarly, the remedial alternatives are evaluated against the following criteria for interim actions, recognizing that the actions taken may not be the final actions. Threshold Criteria1. Overall Protection to the Human Health and the Environment addresses whether or not a remedy

provides adequate protection and describes how risks posed through each pathway are eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls.

2. Compliance with Applicable or Relevant and Appropriate Requirements addresses whether or not a remedy will meet all of the applicable or relevant and appropriate requirements of other Federal and State environmental statutes and/or provide grounds for invoking a waiver.

Balancing Criteria 3. Long-term Effectiveness and Permanence refers to the magnitude of residual risk and the ability of a

remedy to maintain reliable protection of human health and the environment over time once the cleanup goals have been met.

4. Reduction of Toxicity, Mobility, or Volume through Treatment is the anticipated performance of the treatment technologies that may be employed in a remedy.

5. Short-term Effectiveness refers to the speed with which the remedy achieves protection, as well as the remedy’s potential to create adverse impacts on human health and the environment that may result during the construction and implementation period.

6. Implementability is the technical and administrative feasibility of a remedy, including the availability of materials and services needed to implement the chosen solution.

7. Cost includes total, capital, annual operation and maintenance, and site closeout costs. [Total costs are discounted (at an annual rate of 7%) to net present value (NPV) in order to provide a standard basis of comparison across alternatives. All other costs are shown in current year dollars relative to when they occur. Calculation of NPV is in accordance with standard economic procedures. Tables 9-1 through 9-5 and the text show total costs (in NPV) for all SRUs and GRUs. Table 9-6 and Appendix B provide more detailed breakdown of the component costs. All costs are rounded as appropriate.]

Modifying Criteria 8. State Acceptance indicates whether, based on its review of the RI/FS and Proposed Plan, the State

concurs with, opposes, or has no comment on the preferred alternative.


9. Community Acceptance is assessed following a review of the public comments received on the Proposed Plan.


9.2.1 SRU1: Explosives in Soil The alternatives evaluated for this SRU are:

Alternative 1: No Action Alternative 2: Limited Action Alternative 3: Excavation/Treatment Alternative 4: Excavation/Disposal

Following is a summary of the comparative analysis of these alternatives. Overall Protection to the Human Health and the Environment Two of the alternatives, No Action and Limited Action, do not adequately provide protection to human health and the environment. Because the contaminated media remains in place, these two alternatives rely solely on natural attenuation or degradation to reduce the concentrations of the contaminants. Offsite migration has occurred and is expected to continue at most SRU 1 sites. The Limited Action alternative minimizes human health risk by preventing direct contact through restricted access, but does not minimize contaminant migration and does not mitigate potential ecological impacts in localized areas. The remaining alternatives are considered to be protective to both human health and the environment. These alternatives are relatively the same in the reduction of potential human health and environmental risk, because they eliminate the exposure pathways by the removal of the contaminated soil. However, until the RGs are met by one of these alternatives, the soil may pose both human health risks and environmental risks. At sites with groundwater contamination long term monitoring actions will be handled in accordance with the 1998 ROD and remedial design. The Excavation/Treatment alternative removes and treats the contaminated soil to levels below the RGs. Additionally, the potential for offsite migration is eliminated by the excavation of the contaminated media. This alternative permanently treats the soil which may then be returned to the site as backfill in approved areas. The Excavation/Disposal alternative also provides immediate and permanent protection of human health and the environment by removing the contaminated media to an offsite location. Some limited potential for future impacts to human health and the environment exist in this option in the event of a failure in the landfill containment controls. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) All alternatives except No Action and Limited Action comply or will comply with all applicable ARARs. The acceptable alternatives include remedial actions that provide for removing and treating soil (Excavation/Treatment), and removing the contaminated media to an alternate location (Excavation/Disposal). Long-term Effectiveness and Permanence


The No Action alternative does not adequately reduce the long-term risk to human health or the environment based on the current concentration of explosives in the soil and the proposed land use. Implementation of the Limited Action alternative will decrease the risk to human health via limiting access and natural processes. This alternative uses institutional controls to control access, but it poses a potential for human exposure. Under both alternatives, the continued presence and migration of contaminants may pose an unacceptable risk to the environment. The alternatives that excavate the contaminated media (Excavation/Treatment and Excavation/Disposal) quickly eliminate the potential future risk associated with direct contact and offsite migration. The residual risk to human health and the environment associated with these alternatives due to the presence of subsurface soils with concentrations below the RGs is acceptable. Excavation/Disposal will not be effective in the long term if the landfill fails. However, the landfill will be in compliance with RCRA and is designed to minimize the possibility of failure. Excavation/Treatment provides the most permanent solution since contaminants are treated to RGs. Reduction of Toxicity, Mobility, or Volume through Treatment The No Action and Limited Action alternatives do not actively reduce the toxicity, mobility, or volume of contamination. The Excavation/Treatment alternative permanently reduces the toxicity, mobility, but increases the volume of contamination by removal and treatment, which increases the volume by the addition of amendments. The Excavation/Disposal alternative removes the contaminated media from the site and transports it to another location where it will be properly contained so the mobility of contaminants in the soil will be reduced. However, the overall toxicity and volume of the excavated soil will not be affected by this alternative. The overall toxicity, mobility, and volume of contaminants on site will be reduced by this approach. The alternative that treats the contaminated soil (Excavation/Treatment) is preferable to the Excavation/Disposal alternative because it satisfies the statutory preference for treatment as the principle element. Short-term Effectiveness The No Action and Limited Action alternatives do not consist of any physical remedial actions onsite except fence installation. Therefore, they pose no to minimal risk to the community, workers, or the environment as a result of implementation and operation. Because the Excavation/Treatment activities occur on-base, the community will not be subject to any health risks due to the remedial actions. There is, however, a potential for worker exposure and a potential risk to the environment as a result of erosion and dust generation. Excavation/Disposal may affect the community, worker health, and the environment due to dust generation during the excavation, transportation and unloading of the contaminated soil and the possibility of landfill failure. The duration of time to achieve the RGs is as follows: Excavation/Treatment, approximately three years; and Excavation/Disposal, approximately one year. Implementability Technical feasibility is largely a factor of the amount of construction and O&M associated with an alternative. As a result, the alternatives that require site work (Excavation/Treatment and


Excavation/Disposal) are considered less implementable than those that do not (No Action and Limited Action). The No Action and Limited Action alternatives may not be compatible with the future land use, since areas with soil contamination above RGs may not be accepted by the USDA. An important factor in the implementability criterion is the amount of soil to be treated. For example, large quantities of soil will require longer periods of time to treat if excavated and bioremediated. Excavation/Treatment typically becomes more implementable as the amount of soil decreases, except that there is some minimum volume or threshold required to justify the start-up effort. However, an existing biotreatment operation at JOAAP is expected to reduce this threshold to zero. Excavation/Disposal becomes more implementable as the amount of soil decreases. Cost The following estimated cost includes capital, operational, and maintenance for each of the alternatives. These are present worth costs and are adjusted for the length of time to complete each alternative.

Alternative 1: No Action $ 0 Alternative 2: Limited Action $ 567,463 Alternative 3: Excavation/Treatment $ 6,952,296 Alternative 4: Excavation/Disposal $ 4,502,725

State Acceptance The State of Illinois concurs with the acceptability of Alternatives 3 and 4 based on these alternatives complying with the ARARs. The IEPA prefers Alternative 3: Excavation/Treatment. Community Acceptance One comment was received during the March 3, 2004, Public Meeting which was transcribed and is included in the Responsiveness Summary of this document. No other comments were received during the comment period. The one comment presented by members of the RAB was positive in nature. In general, the community has a preference for treating the contamination and appears to concur with the selected remedy.

9.2.1.1 Summary Evaluation of Alternatives for SRU1 Table 9-1 compares the alternatives considered for SRU1 with respect to the nine CERCLA evaluation criteria. The No Action and Limited Action alternatives are not recommended because they would not be protective of human health and the environment and would, therefore, not meet the threshold criteria. These two alternatives do not remove a probable source for groundwater contamination. In addition, natural attenuation, degradation or dilution processes in the Limited Action alternative are not effective for high concentrations of explosives in soils. The remaining two alternatives meet the threshold criteria for final remedial actions. The U.S. Army selected Excavation/Treatment as the recommended alternative for SRU1 for the following reasons. Treatment is recommended over Disposal because it will treat the soils at JOAAP that pose the majority of the risk to human health and the environment. This will also satisfy the regulatory preference of CERCLA for treatment over disposal.

Table 9-1 Evaluation of Remedial Alternatives for SRU1 (Explosives in Soil)

Evaluation Criteria Remedial Alternative

Alt

Threshold Balancing Modifying


1. O

vera

ll P

rote

ctio

n of

H

uman

Hea

lth a

nd th

e E

nviro

nmen

t 2.

Com

plia

nce

with

A

RA

Rs

3. L

ong-

term

E

ffect

iven

ess

and

Per

man

ence

4. R

educ

tion

in T

oxic

ity,

Mob

ility

or V

olum

e Th

roug

h Tr

eatm

ent

5. S

hort-

term

E

ffect

iven

ess

6. Im

plem

enta

bilit

y

7. C

ost (

Net

Pre

sent

W

orth

in $

1,00

0s)

8. S

tate

Acc

epta

nce

(und

er re

view

)

9. C

omm

unity

A

ccep

tanc

e

1. No Action ○ ○ ○ ○ ○ ● $ 0 ○ -

2. Limited Action ○ ○ ○ ● $ 567 ○ -

3. Excavation/Treatment √ ● ● ● ● ● ● $6,952 ● ●

4. Excavation/Disposal ● ● ● ● $4,503 -

Ranking Key: ● - Fully meets criteria - Partially meets criteria ○ - Does not meet criteria – Based on limited pubic comment no assumption is made on acceptance of other alternatives √- Indicates the Remedial Alternative selected

9.2.2 SRU2: Metals in Soil The alternatives evaluated for this SRU are:

Alternative 1: No Action Alternative 2: Limited Action Alternative 3: Excavation/Disposal

Following is a summary of the comparative analysis of these alternatives. Overall Protection to the Human Health and the Environment

Two alternatives, No Action and Limited Action, do not adequately provide protection to human health and the environment under the future land use scenario. The No Action alternative does not eliminate the potential for direct contact with metals in the surface soils or the potential for offsite transport. The Limited Action alternative minimizes human health risk by preventing direct contact through restricted access, but does not prevent contact for ecological receptors, and does not prevent migration of contaminants. Neither of these alternatives removes the UXO from Sites L2 and L3, which poses potential risks to both human health and the environment. The Excavation/Disposal alternative provides immediate and permanent protection of human health and the environment by removing the contaminated media to an offsite location. Some limited potential for future impacts to human health and the environment exists from migration of contaminated soil to other media in the event of a failure in the landfill containment controls.


Compliance with Applicable or Relevant and Appropriate Requirements The Excavation/Disposal alternative complies or will comply with all applicable ARARs. The No Action and Limited Action alternatives do not comply with or will not comply with some or all applicable ARARs. The exceedances of RGs in the No Action and Limited Action alternatives violate 35 IAC 807-185. Long-term Effectiveness and Permanence The No Action alternative does not adequately reduce the long-term risk to human health or ecological receptors, based on the current concentration of metals in the soil and the proposed land use. The presence of UXO at two of the sites poses a risk to both human health and the environment. Implementation of the Limited Action alternative will decrease the risk to human health by preventing direct contact with the metals-contaminated media, although it is not considered adequate to decrease potential risk to the environment or prevent offsite migration of the contamination. The Excavation/Disposal alternative excavates the contaminated media and quickly eliminates the potential future risk associated with direct contact and offsite migration. The residual risk to human health and ecological receptors associated with the presence of subsurface soils with concentrations above the RGs is acceptable. Reduction of Toxicity, Mobility, or Volume through Treatment

The No Action and Limited Action alternatives do not actively reduce the toxicity, mobility, or volume of contamination. Metals are not subject to any significant natural degradation or attenuation processes. Therefore, it is unlikely that concentrations will decrease over time. The Excavation/Disposal alternative removes the contaminated media from the site and transports it to another location. As a result, the toxicity and volume of the excavated material will not be affected by this alternative, but the overall toxicity, mobility, and volume of contamination on site will be reduced. The Excavation/Disposal alternative does not satisfy the statutory preference for treatment as the principal element. Short-term Effectiveness The No Action and Limited Action alternatives do not consist of any physical remedial actions onsite except fence installation. Therefore, they pose no to minimal risk to the community, workers, or the environment as a result of implementation and operation. Any short term impacts to the community as a result of the implementation of the Excavation/Disposal alternative would primarily result from the transportation of the contaminated soil to the landfill. There is potential for worker exposure and a potential risk to the environment as a result of dust generation during excavation, transportation and unloading activities. The duration of time to obtain the RGs is 12 months for the Excavation/Disposal alternative. The Limited Action and Excavation/Disposal alternatives will require long-term maintenance. Implementability


Technical feasibility is largely a factor of the amount of construction and O&M associated with an alternative. As a result, the alternative that requires site work (Excavation/Disposal) is considered less implementable than those that do not (No Action and Limited Action). Administrative feasibility is considered highest for alternatives that are least likely to gain administrative approval (No Action). The No Action and Limited Action alternative may not be compatible with future land use, because the USDA may not accept property that poses an unacceptable risk to human health and the environment. Cost The following estimated cost includes capital, operation, and maintenance for all alternatives. These are present worth costs and are adjusted for the length of time to complete each alternative.

Alternative 1: No Action $ 0 Alternative 2: Limited Action $ 534,301 Alternative 3: Excavation/Disposal $ 3,314,544

State Acceptance The State of Illinois concurs with the acceptability of Alternative 3 based on these alternatives complying with the ARARs. The IEPA prefers Alternative 3: Excavation/Disposal. Community Acceptance One comment was received during the March 3, 2004, Public Meeting which was transcribed and is included in the Responsiveness Summary of this document. No other comments were received during the comment period. The one comment presented by members of the RAB was positive in nature. In general, the community has a preference for disposal of the contamination and appears to concur with the selected remedy.

9.2.2.1 Summary Evaluation of Alternatives for SRU2 Table 9-2 compares the alternatives considered for SRU2 with respect to the nine CERCLA evaluation criteria. The No Action and Limited Action alternatives are not recommended because they would not be protective to human health and the environment and they do not meet the threshold criteria. In addition, natural degradation, attenuation or dilution processes in the Limited Action alternative are not effective for high concentrations of metals in soils. The Excavation/Disposal alternative meets the threshold criteria for final remedial action sites. The U.S. Army selected Excavation/Disposal as the recommended alternative.

Table 9-2 Evaluation of Remedial Alternatives for SRU2 (Metals in Soil)

Evaluation Criteria Remedial Alternative

Alt



1. O

vera

ll P

rote

ctio

n of

H

uman

Hea

lth a

nd th

e E

nviro

nmen

t 2.

Com

plia

nce

with

A

RA

Rs

3. L

ong-

term

E

ffect

iven

ess

and

Per

man

ence

4.

Red

uctio

n in

Tox

icity

, M

obili

ty o

r Vol

ume

Thro

ugh

Trea

tmen

t 5.

Sho

rt-te

rm

Effe

ctiv

enes

s

6. Im

plem

enta

bilit

y

7. C

ost (

Net

Pre

sent

W

orth

in $

1,00

0s)

8. S

tate

Acc

epta

nce

(und

er re

view

)

9. C

omm

unity

A

ccep

tanc

e

1. No Action ○ ○ ○ ○ ○ ● $ 0 ○ -

2. Limited Action ○ ○ ○ ● $ 534 ○ -

3. Excavation/Disposal √ ● ● ● ● ● $3,315 ● ●

Ranking Key: ● - Fully meets criteria - Partially meets criteria ○ - Does not meet criteria –Based on limited pubic comment no assumption is made on acceptance of other alternatives √- Indicates the Remedial Alternative selected

9.2.3 SRU3: Explosives and Metals in Soil The alternatives evaluated for this SRU are:

Alternative 1: No Action Alternative 2: Limited Action Alternative 3: Excavation/Disposal

Following is a summary of the comparative analysis of these alternatives. Overall Protection to the Human Health and the Environment Two of the alternatives, No Action and Limited Action, do not adequately provide protection to human health and the environment. The alternatives do not prevent migration of contaminants. Because the contaminated media remains in place, the No Action and Limited Action alternatives rely solely on natural dilution, attenuation and degradation to reduce the concentrations of the contaminants. The Limited Action alternative minimizes human health risk by preventing direct contact through restricted access. The Excavation/Disposal alternative provides immediate and permanent protection of human health and the environment by removing the contaminated media to an offsite location. Some limited potential for future impacts to human health and the environment exist in this option in the event of a failure in the landfill containment controls. Compliance with Applicable or Relevant and Appropriate Requirements


The Excavation/Disposal alternative adequately protects human health and the environment. The No Action and Limited Action alternative does not adequately provide protection to human health and the environment based on the potential for exposure and migration and will not comply with all ARARs. The Excavation/Disposal alternative complies with the ARARs. Long-term Effectiveness and Permanence The No Action alternative does not adequately reduce the long-term risk to human health or ecological receptors, based on the current concentration of explosives and metals in the soil and the proposed land use. Additionally, the potential for contaminant migration and presence of these compounds (including UXO) may pose a future risk to the environment. The Limited Action alternative uses institutional controls as a risk management strategy and is somewhat effective at reducing the potential for human exposure. The continued migration and presence of these contaminants may pose a potential risk to the environment. The alternative that excavates the contaminated media (Excavation/Disposal) quickly eliminates the potential future risk associated with direct contact and offsite migration. The residual risk to human health and ecological receptors associated with the presence of subsurface soils with concentrations below the RGs is acceptable. Additionally, this alternative does not require any long-term onsite controls, but will require long-term monitoring of residual contaminants. Reduction of Toxicity, Mobility, or Volume through Treatment The No Action and Limited Action alternatives do not actively reduce the toxicity, mobility or volume of contamination. The Excavation/Disposal alternative removes the contaminated media from the site and transports it to another location. Therefore, the toxicity and volume of the excavated material will not be affected by this alternative. However, the overall toxicity, mobility, and volume of contaminants on site will be reduced. None of these alternatives satisfy the statutory preference for treatment as the principle element. Short-term Effectiveness The No Action and Limited Action alternatives do not consist of any physical remedial actions onsite except fence installation and maintenance. Therefore, they pose no to minimal risk to the community, workers, or the environment as a result of implementation and operation. The Excavation/Disposal alternative may affect the community, worker health, and the environment due to the dust generation during excavation, offbase transportation or unloading of the contaminated soil. The duration of time to obtain the RGs for the Excavation/Disposal alternative is within 12 months. Implementability Technical feasibility is largely a factor of the amount of construction and O&M associated with an alternative. As a result, the alternative that requires site work (Excavation/Disposal) is considered less implementable than those that do not (No Action and Limited Action). The No Action and Limited Action alternatives may not be compatible with future land use because the USDA may not accept


property that poses an unacceptable risk to human health or the environment. Administrative feasibility is considered highest for alternatives that are least likely to gain administrative approval (No Action). Cost The following estimated cost includes capital, operational, and maintenance for all alternatives. These are present worth costs and are adjusted for the length of time to complete each alternative.

Alternative 1: No Action $ 0 Alternative 2: Limited Action $ 107,995 Alternative 3: Excavation/Disposal $ 942,691

State Acceptance The State of Illinois concurs with the acceptability of Alternative 3 based on this alternative complying with the ARARs. Community Acceptance One comment was received during the March 3, 2004, Public Meeting which was transcribed and is included in the Responsiveness Summary of this document. No other comments were received during the comment period. The one comment presented by members of the RAB was positive in nature. In general, the community has a preference for disposal of the contamination and appears to concur with the selected remedy.

9.2.3.1 Summary Evaluation of Alternatives for SRU3 Table 9-3 compares the alternatives considered for SRU3 with respect to the nine CERCLA evaluation criteria. The No Action and Limited Action alternatives are not recommended because they would not be protective of human heath and the environment and they would not meet the threshold criteria. In addition, natural dilution, attenuation or degradation processes in the Limited Action alternative are not effective for high concentrations of explosives and metals in soils. The remaining alternative meets the threshold criteria for final remedial actions. The U.S. Army selected Excavation/Disposal as the recommended alternative.


Table 9-3 Evaluation of Remedial Alternatives for SRU3 (Explosives and Metals in Soil)

Evaluation Criteria Threshold Balancing Modifying

Remedial Alternative Sel

ecte

d A

ltern

ativ

e 1.

Ove

rall

Pro

tect

ion

of

Hum

an H

ealth

and

the

Env

ironm

ent

2. C

ompl

ianc

e w

ith

AR

AR

s 3.

Lon

g-te

rm

Effe

ctiv

enes

s an

d P

erm

anen

ce

4. R

educ

tion

in T

oxic

ity,

Mob

ility

or V

olum

e Th

roug

h Tr

eatm

ent

5. S

hort-

term

E

ffect

iven

ess

6. Im

plem

enta

bilit

y

7. C

ost (

Net

Pre

sent

W

orth

in $

1,00

0s)

8. S

tate

Acc

epta

nce

(und

er re

view

)

9. C

omm

unity

A

ccep

tanc

e

1. No Action ○ ○ ○ ○ ○ ● $ 0 ○ -

2. Limited Action ○ ○ ○ ● $ 108 ○ -

3. Excavation/Disposal √ ● ● ● ● ● $943 ●

Ranking Key: ● - Fully meets criteria - Partially meets criteria ○ - Does not meet criteria - Based on limited pubic comment no assumption is made on acceptance of other alternatives √- Indicates the Remedial Alternative selected

9.2.4 SRU5: Organics in Soil The alternatives evaluated for this SRU are:

Alternative 1: No Action Alternative 2: Limited Action Alternative 3: Excavation/Treatment Alternative 4: Excavation/Disposal

Following is a summary of the comparative analysis of these alternatives. Overall Protection to the Human Health and the Environment One of the four alternatives, the No Action alternative, does not adequately provide protection to human health. This alternative does not eliminate the potential for direct human contact with PAHs in the surface soils or remove the potential for offsite transport via erosion. The Limited Action alternative is considered to be protective to both human health and the environment. This alternative minimizes human health risk by the prevention of direct contact via site restriction.


Of the remaining alternatives, both the Excavation/Treatment alternative and Excavation/Disposal alternative are considered to be protective of both human health and the environment, because they eliminate the exposure pathways by the removal of the contaminated soil. However, until the RGs are met by one of these alternatives, the soil may pose both human health risks and environmental risks. The Excavation/Treatment alternative removes and treats the contaminated soil to levels below the RGs. The potential for human contact and offsite migration is eliminated through the excavation of the contaminated soil. This alternative permanently treats the soil, which may then be returned to the sites as fill. The Excavation/Disposal alternative also provides immediate and permanent protection of human health and the environment by removing the contaminated soil to an off-base location. Some limited potential for future impacts to human health and the environment exist in this option in the event of a failure of the landfill containment controls. In summary, the Excavation/Treatment alternative reduces the risk to human health and the environment by removing and permanently treating the soil to contaminant levels below the RGs. The Excavation/Disposal alternative effectively relocates the contaminated media to a controlled area, thereby removing the risk to human health and the environment. The Limited Action alternative is considered to be protective of human health and the environment, although RGs will be obtained only by natural degradation and attenuation at some unknown time in the future. The No Action alternative does not provide adequate protection to human health, but concentrations may eventually obtain RGs due to natural degradation and attenuation. Compliance with Applicable or Relevant and Appropriate Requirements The No Action and Limited Action alternatives do not comply or will not comply with all ARARs. The Excavation/Treatment and Excavation/Disposal alternative comply with ARARs. Long-term Effectiveness and Permanence The No Action alternative does not adequately reduce the long-term risk to human health based on the current concentrations of PAHs in certain areas of the sites and the proposed land use. Continued migration may pose a risk to the environment in the future. The natural degradation, attenuation or dilution of organics is expected to reduce the organic concentrations to below RGs, thereby minimizing the human health and environmental risks over time. Implementation of the Limited Action alternative minimizes the risk to human health by reducing the potential for human exposure. The natural degradation, attenuation or dilution of organics is expected to reduce the organic concentrations to below RGs, thereby minimizing the human health risk. Additionally, long-term inspection of soils will occur in this alternative. The two alternatives that excavate the contaminated media (Excavation/Treatment and Excavation/Disposal) quickly eliminate the potential future risk associated with direct contact and offsite migration. The residual risk to human health and ecological receptors associated with the presence of subsurface soils with concentrations below the RG is acceptable. Additionally, these two alternatives do not require any long-term onsite controls.


Reduction of Toxicity, Mobility, or Volume through Treatment The No Action alternative does not actively reduce the toxicity, mobility, or volume of contamination. Organics are subject to natural degradation or attenuation; therefore concentrations may eventually reach RGs. The Limited Action alternative does not actively reduce the mobility of the contaminants due to the lack of erosion controls. The toxicity and volume of the contamination will not be actively reduced, although concentrations may decrease over time due to natural degradation or attenuation processes. The Excavation/Treatment alternative permanently reduces the toxicity and mobility of contamination by removal and treatment. The Excavation/Disposal alternative removes the contaminated soil from the site and transports it to another location, so the toxicity and volume of the excavated material will not be affected by this alternative. The alternative that treats the contaminated soil (Excavation/Treatment) is preferable to the Excavation/Disposal alternative, because it satisfies the statutory preference for treatment as the principal element. Short-term Effectiveness The lack of remedial actions for the No Action alternative and the minimal site activity for the Limited Action alternative do not pose a risk to the community, workers, or the environment as a result of implementation and operation. Because the treatment occurs onbase, the community will not be subject to any health risks due to these remedial actions with the Excavation/Treatment alternative. There is, however, a potential for worker exposure and minimal risk to the environment as a result of dust generated during excavation and erosion for this alternative. Excavation/Disposal may affect the community, worker health, and the environment due to the offsite transportation of the contaminated soil. The duration of time to achieve the RGs for Excavation/Treatment is approximately six months, and for Excavation/Disposal is 12 months. Implementability Technical feasibility is largely a factor of the amount of construction and O&M associated with an alternative. As a result, the alternatives that require extensive site work (Excavation/Treatment and Excavation/Disposal) are considered less implementable than those that do not (No Action and Limited Action). Administrative feasibility is considered highest for alternatives that are least likely to gain administrative approval (No Action). Cost The following estimated cost includes capital, operational, and maintenance for all alternatives. These are present worth costs and are adjusted for the length of time to complete each alternative.

Alternative 1: No Action $ 0 Alternative 2: Limited Action $ 497,556 Alternative 3: Excavation/Treatment $ 479,190 Alternative 4: Excavation and Disposal $ 334,961


State Acceptance The State of Illinois concurs with the acceptability of Alternatives 3 and 4 based on these alternatives complying with the ARARs. The IEPA prefers Alternative 3: Excavation/Treatment. Community Acceptance One comment was received during the March 3, 2004, Public Meeting which was transcribed and is included in the Responsiveness Summary of this document. No other comments were received during the comment period. The one comment presented by members of the RAB was positive in nature. In general, the community has a preference for treatment of the contamination and appears to concur with the selected remedy.

9.2.4.1 Summary Evaluation of Alternatives for SRU5 Table 9-4 compares the alternatives considered for SRU5 with respect to the nine CERCLA evaluation criteria. The threshold criteria could not be met by the No Action and the Limited Action alternatives; hence these alternatives were not selected for the SRU. The threshold criteria could be met by the Excavation/Treatment and Excavation/Disposal alternatives. Each would reduce the risk of direct contact with organic compounds in soil and debris. Although the Excavation/Disposal alternative has a lower cost, it is not the selected alternative because it does not satisfy the statutory preference for treatment. The U.S. Army selected Excavation/Treatment as the recommended alternative for SRU 5.


Table 9-4 Evaluation of Remedial Alternatives for SRU5 (Organics in Soil)

Evaluation Criteria Threshold Balancing Modifying

Remedial Alternative Sel

ecte

d A

ltern

ativ

e 1.

Ove

rall

Pro

tect

ion

of

Hum

an H

ealth

and

the

Env

ironm

ent

2. C

ompl

ianc

e w

ith

AR

AR

s 3.

Lon

g-te

rm

Effe

ctiv

enes

s an

d P

erm

anen

ce

4. R

educ

tion

in T

oxic

ity,

Mob

ility

or V

olum

e Th

roug

h Tr

eatm

ent

5. S

hort-

term

E

ffect

iven

ess

6. Im

plem

enta

bilit

y

7. C

ost (

Net

Pre

sent

W

orth

in $

1,00

0s)

8. S

tate

Acc

epta

nce

(und

er re

view

)

9. C

omm

unity

A

ccep

tanc

e

1. No Action ○ ○ ○ ○ ○ ● $ 0 ○ -

2. Limited Action ○ ○ ○ ● $ 497 ○ -

3. Excavation/Treatment √ ● ● ● ● ● ● $ 479 ● ●

4. Excavation/Disposal ● ● ● ● ● $ 335 ● -

Ranking Key: ● - Fully meets criteria - Partially meets criteria ○ - Does not meet criteria –Based on limited pubic comment no assumption is made on acceptance of other alternatives √- Indicates the Proposed Remedial Alternative selected

9.2.5 Summary of Selected Remedies for all SRUs Table 9-5 presents a summary evaluation of selected remedies for each SRU. The total estimated net present worth of remedial actions for the SOU is $17,090,182.


Table 9-5 Summary of Recommended Remedial Alternatives for all SRUs (LAP and MFG Areas)

Evaluation Criteria


SRU Remedial Alternative 1. O

vera

ll P

rote

ctio

n of

H

uman

Hea

lth a

nd th

e E

nviro

nmen

t

2. C

ompl

ianc

e w

ith

AR

AR

s 3.

Lon

g-te

rm

Effe

ctiv

enes

s an

d P

erm

anen

ce

4. R

educ

tion

in T

oxic

ity,

Mob

ility

or V

olum

e Th

roug

h Tr

eatm

ent

5. S

hort-

term

E

ffect

iven

ess

6. Im

plem

enta

bilit

y

7. C

ost (

Net

Pre

sent

W

orth

in $

1,00

0s)

8. S

tate

Acc

epta

nce

(und

er re

view

)

9. C

omm

unity

A

ccep

tanc

e

SRU 1 Excavation/Treatment ● ● ● ● ● ● $6,952 ● ●

SRU 2 Excavation/Disposal ● ● ● ● ● $3,315 ● ●

SRU 3 Excavation/Disposal ● ● ● ● ● $ 943 ●

SRU 5 Excavation/Treatment ● ● ● ● ● ● $ 479 ● ●

Total $11,689

Ranking Key: ● - Fully meets criteria - Partially meets criteria ○ - Does not meet criteria

9.3 Cost Summary for Selected Remedies Table 9-6 provides a summary and component costs (capital and annual operation and maintenance) for each selected remedy. The component costs are discounted (at 7% per year) and aggregated to provide total costs (in NPV). The years shown in Table 9-6 are used in the economic analyses of the projects. They are the projected years from initial implementation of remedial design through the completion of a remedial action. Appendix B provides similarly detailed cost breakdowns for all remedial alternatives considered in this ROD, not just for the selected alternatives.


Table 9-6 Summary of Total and Component Costs for the Selected Remedy for Each SRU

Alternative

Soil Volume

(CY)

Capital

Annual O&M

(Tota1)(2) SRU Total Cost Years

(1)

SRU1

19,535

$6,952,296

$5,866,199

Excavation/ 3 $1,086,097 Treatment

SRU2

Excavation/

Disposal

12,865 $3,314,544 1 $3,151,224

$163,320

SRU3

Excavation/

Disposal 2,300 $942,691 1

$918,211

$24,480

SRU5

Excavation/ Treatment

1,475

$479,190

1

$434,580

$44,610

Notes: Capital Cost includes Site Closeout Cost

(1) – Years show the estimated time to complete from the start of remediation through completion of O&M.

(2) – Capital and Total O&M are presented in current year value

[END OF SECTION]


10 SELECTED REMEDIES Based upon consideration of the requirements of CERCLA, the detailed evaluation of alternatives, and public comments, the Army, with the concurrence of the USEPA and IEPA, has selected the following remedies for the interim portion of the four soil remedial units.

Table 10-1 Selected Remedies and Costs of Cleanup for each SRU

Sites Selected Remedy Costs of Clean up SRU1: Explosives in Soil Excavation/Treatment $ 6,952,296 SRU2: Metals in Soil Excavation/Disposal $ 3,314,544 SRU3: Explosives and Metals in Soil Excavation/Disposal $ 942,691 SRU5: Organics in Soil Excavation/Treatment $ 479,190 Grand Total Costs

Soil Remedial Units

$ 11,688,721

These selected alternatives include the design and implementation of several remedial actions. The primary objective of the final remedial actions is to effectively mitigate, minimize threats to, and provide adequate protection of human health and the environment. To meet this objective, the Army developed remedial action objectives (RAOs) for the SOU. These RAOs for final actions are summarized as:

1. Clean up contaminants to the site-specific and chemical-specific remediation goals (RGs);

2. Prevent human and environmental exposure to contamination at concentrations above the RGs;

3. Eliminate soil contamination as a continuing source of groundwater contamination;

4. Prevent migration of contaminants; and

5. Actions will not leave behind any RCRA characteristic wastes.

The implementation time to reach these goals will vary between each SRU and will be given later in this section. Long term monitoring is not a part of this estimate. Although this section presents details of the selected remedy, some changes with the USEPA and IEPA approval with input from stakeholders may be made based on the remedial design and construction process. Performance Objectives: The selected remedial action alternatives are expected to be able to meet the stated RAOs. To do this, they must perform properly, must be protective of human health and the environment, and must comply with all applicable ARARs. Technology-specific performance objectives will be specified in the Remedial Design Phase. Some of the selected alternatives have common remedial actions; therefore, rather than repeating the description of these remedial actions under each section, these common actions will be described first for the soil SRUs before referring to these actions under each SRU description.



10.1.1 Common Soil Operable Unit Actions The selected remedies for the soil treatment contain several common actions. Exceptions will be noted as the common elements are described. All the selected remedies include excavation, treatment, or disposal of soil containing contaminant concentrations above the RGs. Following is a description of the common actions that are included in the selected remedy.

10.1.1.1 Building Demolition Where appropriate, some existing building components and structures may need to be demolished prior to excavating contaminated soil (e.g. sumps). The RI/FS identifies these buildings. These buildings may be removed and salvaged. If building debris cannot be salvaged, it will be disposed at the WCLF. The disturbance to soil will be minimized during building demolition activities.

10.1.1.2 Pre-Sampling, Soil Excavation, Transportation, and Confirmatory Sampling Pre-sampling will be performed as documented in the JOAAP Management Team Agreement (Appendix A) in order to define the areas requiring excavation where such information is lacking or suspect. Areas that were identified as stained or suspect in the RI/FS will similarly undergo pre-sampling to determine contaminant presence and concentration. Contaminated soil will be excavated from the various sub-areas within each site, loaded into dump trucks, and transported to a central treatment area for stockpiling (if treatment is part of the remedy) or to a disposal facility. These trucks must comply with the Illinois Department of Transportation Regulations if the trucks travel on State roads. Trucks that transport materials on Army lands are not required to be lined, tarped, or decontaminated in the soil transportation; however, transportation across lands that have been transferred to the USDA will require the same requirements as crossing a public road. The RD/RA Work Plan will specify the requirements based on the planned transportation route. Conventional earthmoving equipment will be used for excavation. Soil excavation will continue until confirmatory sampling confirms that concentration levels in the soil meet the RGs as outlined in the JOAAP Management Team Agreement (Appendix A). The limits of excavation will be determined primarily based on the RI/FS maps/data and pre-sampling efforts. These limits will be confirmed with approval from the USEPA and IEPA using field screen tests, with final confirmatory samples (including both COC and TCLP tests, as appropriate) analyzed by a laboratory. Sites with associated surface waters will be monitored during remedial actions to address contaminant migration due to site activities. This monitoring will be outlined in the remedial design documentation. The need for any additional surface water monitoring will be evaluated during O&M Plan development following remedial actions. If unexploded ordnance (UXO) is encountered, it will be screened and removed for open burn/detonation or for off-site incineration at a permitted facility. If TNT chunks are encountered, it will be processed for treatment or disposal at a permitted off-site facility, processed to be blended back for treatment at JOAAP or turned over to the Bureau of Alcohol, Tobacco and Firearms (for reuse in training).

10.1.1.3 Soil Preparation This action is common to all alternatives where active treatment occurs. After reaching the treatment area, contaminated soil will be stored in a stockpile area. Soil will be screened and blended either at the


excavation site or within the stockpile area. Blending of hot-spot soil with less contaminated soil will be conducted to homogenize the soil for feed into the treatment system. Debris and large stones will be removed using a series of shaker/separator units. Debris and large stones will be stockpiled for possible pressure washing and will be reused or properly disposed. UXO or raw TNT encountered in soil preparation will be handled as described in Section 10.1.1.2. All trucks used to transport soil will be routed through a wheel wash prior to exiting the treatment area. Wash water from the trucks and from the pressure wash operation will be will routed to SB-1 and used as makeup water in the treatment process. If the selected remedy does not involve an active treatment process (e.g., Excavation/Disposal), the excavated soil will be transported to a permitted disposal facility. Soil will be excavated and may be screened by a mobile screener/separator for debris and large stones prior to transportation. UXO and raw TNT will be handled as mentioned earlier.

10.1.1.4 Backfilling, Regrading, and Revegetating Excavated Areas Excavated areas will be backfilled as required for safety, to prevent ponding, and to promote surface drainage. The source of the backfill soil will likely be from an on-site borrow location. Some treated soil may also be used as clean backfill at any on-site location that does not require structural fill. Depending upon the time schedule for excavation, this may or may not be the same location from which the soil was removed. Backfilled areas will be regraded to conform to the surrounding topography. Backfilling and reseeding of excavated areas and identification of sources of borrow will be done in consultation with USDA/FS. Surface water runoff from remedial action sites will be monitored at specified points to ensure compliance with NPDES and Illinois water quality standards. The substantive requirements of ARARs relating to jurisdictional wetlands will be met during the remedial design and remedial action phases.

10.1.1.5 Soil Disposal The Army will use the following options that exist for disposal of treated or untreated soils. Soils will be tested as appropriate and in accordance with procedures approved by USEPA and IEPA to determine whether the soils are RCRA hazardous wastes and whether RGs are exceeded. Based on the results of these tests, the disposal options for the soils will be as follows:

1. All soils which are contaminated with RCRA hazardous wastes must be: • Disposed at a RCRA Subtitle C facility, or • Treated and disposed at a RCRA Subtitle C facility, or • Treated and disposed at a RCRA Subtitle D facility or may be used as subgrade or

backfill, if the soils are not characteristically hazardous under RCRA, achieve RGs, and do not exceed LDRs under RCRA.

2. All soils which exceed RGs and are not RCRA hazardous waste must disposed as above or: • Disposed at a RCRA Subtitle D facility, or • Used as subgrade fill material in capped landfills at JOAAP.

3. All remaining soils can be disposed as above, or • Reused (e.g., as backfill) with appropriate regulatory and stakeholder acceptance.

10.1.1.6 Land Transfer Documentation


The property that is subject to this ROD is intended to be transferred to the USDA Forest Service for the purpose of establishing a tallgrass prairie. Due to the procedure for transfer of land from one Federal agency to another, a formal deed will not be recorded. However, any required institutional controls will be incorporated into the Army conveyance documents (the Environmental Condition of Property (ECOP) and Letter of Assignment) to inform the USDA Forest Service of applicable land use restrictions, and will be prepared in accordance with federal and state requirements (see section 11.2.2.3 for applicable ARARs). Additionally, the USDA Forest Service will be requested to incorporate and memorialize the land use restrictions in their official land management plans for the site. Based on the results of investigations leading to this Record of Decision, institutional controls (ICs) will be required as part of the remedy. The remedy will result in low levels of hazardous substances remaining in the soils at concentrations above the unrestricted reuse levels. The selected Remedial Goals and Remedial Action Objectives were specifically designed to be protective of human and ecological prairie receptors, and are not intended for unrestricted exposure scenarios (See Section 6 for more information). The institutional control objectives are as follows: • Prevent unrestricted exposure to soils with residual contamination above unlimited reuse levels. • Prevent the development and use of property for residential housing, elementary and secondary

schools, childcare facilities, or playgrounds, or industrial uses. The Army shall implement, maintain, monitor, report on and enforce the land use controls according to the Remedial Design (RD)/Remedial Action Work Plan that will be prepared after approval of this ROD. In accordance with the FFA, the Army will propose a deadline for the completion of the RD/RA Work Plan within 21 days of issuance of this ROD. The RD/RA Plan for Institutional Controls will summarize the institutional control objectives, the land use restrictions, and mechanisms that will be used to minimize future violations of land use controls on the ROD property. The ICs will be continued until the concentrations of hazardous substances in the soil and/or groundwater beneath are reduced to levels that allow for unlimited exposure and unrestricted use, and regulatory agreement is reached. Note – As a result of the 1998 ROD, there is an additional institutional control objective to prevent exposure/use of groundwater that is contaminated at Sites L1, L2, L3 and L14. See Record of Decision, Soil and Groundwater Operable Units, Manufacturing and Load-Assemble-Package Areas, Joliet Army Ammunition Plant, Wilmington, IL, October 1998 for additional information.

10.1.2 SRU1: Explosives in Soil Excavation/Treatment Described below are the remediation actions under the Excavation/Treatment remedy and the estimated treatment time and cost associated with this remedy. Some of the remedial actions were described in the common action section above and are only listed below. The Excavation/Treatment remedy includes:

• Building Demolition (Section 10.1.1.1); • Pre-Sampling, Soil Excavation, Transportation, and Confirmatory Sampling (Section 10.1.1.2); • Soil Preparation (Section 10.1.1.3); • Treatment; • Backfilling, Regrading, and Revegetating Excavated Areas (Section 10.1.1.4); • Soil Disposal (Section 10.1.1.5); • Treatment Area Decommissioning;


• Land Transfer Documentation (Section 10.1.1.6).

During remedial design or remedial action, the Army will determine the extent of explosives contamination associated with sewer lines as documented in the JOAAP Management Team Agreement (Appendix A). Contamination above the RGs will be excavated and treated. Some of the soils in SRU1 were contaminated by Resource Conservation and Recovery Act (RCRA) listed hazardous wastes, and as such "contain" these wastes. The Army based its detailed analysis of alternatives and selection of remedial technologies for these SRU1 soils on two determinations. First, media, such as soils, at JOAAP that were contaminated with RCRA listed hazardous wastes, are not themselves hazardous wastes unless they exhibit the characteristic for which the waste was listed. Second, once media contaminated with RCRA listed hazardous wastes are treated to below Remediation Goals (RGs), are not Toxic Characteristic Leaching Procedure (TCLP) hazardous wastes under RCRA, and do not exceed RCRA Land Disposal Restriction (LDR) concentrations, the media is no longer a RCRA hazardous waste.

10.1.2.1 Treatment (Bioremediation) Approximately 21,010 cubic yards (SRU 1 and SRU 5 soils) of explosive-contaminated soil will be treated using a Treatment process. There are several Treatment (bioremediation) technologies that are capable of meeting and substantially exceeding the RGs. Windrow composting was selected as the treatment process. This process has been proven on a full-scale operation and is currently used to treat explosives contaminated soils excavated from lands to be used for industrial purposes at JOAAP. Composting is a treatment process where organic compounds are biologically degraded or transformed by mesophilic and thermophilic microorganisms. The composting process consists of mixing the waste material with an amendment or bulking agent to increase porosity, enhance air mass transfer into the system, and enhance the microbial population that degrades the explosives. Windrow composting will include three major steps: a) amendment materials preparation, b) windrow construction, and c) windrow operation. The Treatment alternative is expected to treat the soil and reduce the explosive levels to below RGs based on results from the ongoing operation. One central treatment area has been constructed and soil from the different sites will be transported to that area. This treatment area includes a contaminated soil stockpile area, preparation area, treatment processes area, and a treated soil stockpile area. Run-off from rain and from the treatment itself is controlled to prevent any contamination due to the treatment operation. Explosives safety precautions and procedures are in place. Treated soil may be used as backfill in excavated areas. The USEPA and IEPA have approved the treatment technology selected. Any new or revised plans developed by the Army or its contractors to monitor and evaluate the treatment remedy will continue to be subject to review and approval by the USEPA and IEPA. Post-treatment testing will be performed on treated stockpile soils to ensure treated soil meet RGs prior to re-use.

10.1.2.2 Treatment Area Decommissioning When the treatment of contaminated soil is completed, the treatment area and associated facilities will be disassembled, decontaminated, and salvaged. Any parts of the treatment facility that can not be salvaged or are not desired by the future owner will be disposed in the WCLF or at another permitted facility if required as construction debris. Any treatment residuals will also be sampled and reused or properly disposed.


10.1.2.3 Remedial Time and Cost Once approval of the recommended alternative is received and funding obtained, the estimated time required for completion of cleanup activities at SRU1, using the assumptions of the FS conceptual designs, are:

• Three (3) years for excavation, treatment and disposal Upon completion of the final remedial actions, no further cleanup action will be required for SRU1. The total present worth of capital and annual costs of the Excavation/Treatment remedy is estimated to be $6,952,296. The total capital cost is $5,866,199, and the total annual O&M cost is $1,086,097. Based on the RI/FS data, an estimated 19,535 cubic yards of soil will be treated.

10.1.3 SRU2: Metals in Soil Excavation/Disposal Described below are the remedial actions under the Excavation/Disposal remedy and the time and cost associated with this remedy. Some of the remedial actions were described in the common action section above and are only listed below. The Excavation and Disposal remedy will include:

• Pre-Sampling, Soil Excavation, Transportation, and Confirmatory Sampling (Section 10.1.1.2); • Soil Preparation (Section 10.1.1.3); • Backfilling, Regrading, and Revegetating Excavated Areas (Section 10.1.1.4); • Soil Disposal (Section 10.1.1.5); and • Land Transfer Documentation (Section 10.1.1.6).

Approximately 12,865 cubic yards of metal-contaminated soil will be excavated and disposed. No raw TNT is expected to be present in the soil. Soils potentially containing UXO will be located, and the UXO removed and stockpiled for open burn/detonation or incineration at a permitted facility off-site. Otherwise, soil will not be screened; it will be excavated and disposed as specified in Section 10.1.1.5.

10.1.3.1 Remedial Time and Cost The estimated completion time for completion of the remediation of SRU2 is one (1) year including engineering design, excavation and disposal. Upon completion of the final remediation, no further cleanup actions will be required for SRU2. The total estimated present worth of capital and annual costs of the Excavation and Disposal remedy is $3,314,544.

10.1.4 SRU3: Explosives and Metals in Soil Excavation/Disposal Described below are the remediation actions for the Excavation/Disposal remedies and the time and cost associated with the remedy. Some of the remedial actions were described in the common action section above and are only listed below. The Excavation/Disposal remedy will include:

• Pre-Sampling, Soil Excavation, Transportation, and Confirmatory Sampling (Section 10.1.1.2); • Soil Preparation (Section 10.1.1.3); • Backfilling, Regrading, and Revegetating Excavated Areas (Section 10.1.1.4); • Soil Disposal (Section 10.1.1.5); and • Land Transfer Documentation (Section 10.1.1.6).

Approximately 2,300 cubic yards of explosives and metal-contaminated soil will be excavated and disposed. No raw TNT is expected to be present in the soil. Soils potentially containing UXO will be located, and the UXO removed and stockpiled for open burn/detonation or incineration at a permitted


facility off-site. Otherwise, soil will not be screened; it will be excavated and disposed as specified in Section 10.1.1.5. Some of the soils in SRU3 were contaminated by RCRA listed hazardous wastes, and as such "contain" these wastes. The Army based its detailed analysis of alternatives and selection of remedial technologies for these SRU3 soils on two determinations. First, media at JOAAP were contaminated with RCRA listed hazardous wastes, are not themselves hazardous wastes unless they exhibit the characteristic for which the waste was listed. Second, once media contaminated with RCRA listed hazardous wastes are treated to below RGs, are not TCLP hazardous wastes under RCRA, and do not exceed RCRA LDR concentrations, the media is no longer a RCRA hazardous waste.

10.1.4.1 Remedial Time and Cost The estimated completion time for completion of the remediation of SRU2 is one (1) year including engineering design, excavation and disposal. Upon completion of the final remediation, no further cleanup actions will be required for SRU3. The total estimated present worth of capital and annual costs of the Excavation and Disposal remedy is $942,691.

10.1.5 SRU5: Organics in Soil Excavation/Treatment Described below are the remediation actions under the Excavation/Treatment remedy and the treatment time and cost associated with this remedy. Some of the remedial actions were described in the common action section above and are only listed below. The Excavation/Treatment will include:

• Building Demolition (Section 10.1.1.1); • Pre-Sampling, Soil Excavation, Transportation, and Confirmatory Sampling (Section 10.1.1.2); • Soil Preparation (Section 10.1.1.3); • Treatment; • Backfilling, Regrading, and Revegetating Excavated Areas (Section 10.1.1.4); • Soil Disposal (Section 10.1.1.5); • Treatment Area Decommissioning; • Land Transfer Documentation (Section 10.1.1.6).

10.1.5.1 Treatment (Bioremediation) Approximately 1,475 cubic yards of organic chemical-contaminated soil will be treated using a Treatment process. There are several Treatment (bioremediation) technologies that are capable of meeting and substantially exceeding the RGs. Windrow composting was selected as the treatment process. This process has been proven on a full-scale operation and is currently used to treat explosives contaminated soils excavated from lands to be used for industrial purposes at JOAAP. Composting is a treatment process where organic compounds are biologically degraded or transformed by mesophilic and thermophilic microorganisms. The composting process consists of mixing the waste material with an amendment or bulking agent to increase porosity, enhance air mass transfer into the system, and enhance the microbial population that degrades the organic compounds. Windrow composting will include three major steps: a) amendment materials preparation, b) windrow construction, and c) windrow operation. The Treatment alternative is expected to treat the soil and reduce the organic levels to below RGs based on results from the ongoing operation. One central treatment area has been constructed and soil from the different sites will be transported to that area. This treatment area includes a contaminated soil stockpile area, preparation area, treatment


processes area, and a treated soil stockpile area. Run-off from rain and from the treatment itself is controlled to prevent any contamination due to the treatment operation. Treated soil may be used as backfill in excavated areas. The USEPA and IEPA have approved the treatment technology selected. Any new or revised plans developed by the Army or its contractors to monitor and evaluate the treatment remedy will continue to be subject to review and approval by the USEPA and IEPA. Post-treatment testing will be performed to ensure soil contaminant levels meet RGs.

10.1.5.2 Treatment Area Decommissioning When the treatment of contaminated soil is completed, the treatment area and associated facilities will be disassembled, decontaminated, and salvaged. Any parts of the treatment facility that can not be salvaged or are not desired by the future owner will be disposed in the WCLF or at another permitted facility if required as construction debris. Any treatment residuals will also be sampled and reused or properly disposed.

10.1.5.3 Remedial Time and Cost Once approval of the recommended alternative is received and funding obtained, the estimated time required for completion of cleanup activities at SRU5, using the assumptions of the FS conceptual designs, are:

• Twelve months for excavation, treatment and disposal Upon completion of the final remedial actions, no further cleanup action will be required for SRU5. The total present worth of capital and annual costs of the Excavation/Treatment remedy is estimated to be $479,190. Based on the RI/FS data, an estimated 1,475 cubic yards of soil will be treated.

[END OF SECTION]


11 STATUTORY DETERMINATIONS As the preamble of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) states, the purpose of the law is "to provide for liability, compensation, cleanup, and emergency response for hazardous substances released into the environment and the cleanup of inactive hazardous waste disposal sites." In addressing hazardous substances and sites, CERCLA provides that on-site remedial actions must meet the standards and criteria that are otherwise legally applicable to the substance, pollutant, or contaminant or that are relevant and appropriate under the circumstances [42 U.S.C. § 9621(d)(2)(A)]. Under the CERCLA process it should be noted that if no unacceptable risk is presented, and thus no action is required to meet the CERCLA criterion of protectiveness, no Applicable or Relevant and Appropriate Requirements (ARARs) analysis is needed for the site (ARARs Question's and Answer's, U.S. Environmental Protection Agency's OSWER Directive 9234.2-01/FS-4, June 1994). CERCLA provides the President authority to respond to releases of hazardous substances [42 U.S.C. § 9604(a)]. The authority to act is subject to the requirement that the response be "consistent with the NCP," and is not affected by the inclusion or lack of inclusion of the site on the National Priorities List (NPL). Id. Federal facilities are required to comply with CERCLA [42 U.S.C. § 9620(a)(1)] ("Each department . . . of the United States . . . shall be subject to, and comply with this chapter in the same manner and to the same extent, both procedurally and substantively, as any non-governmental entity . . ."). Additionally, all guidelines, rules, regulations and criteria that are applicable to evaluation of private facilities under the National Contingency Plan (NCP) and applicable to private remedial actions are equally applicable to federal facilities [42 U.S.C. § 9620(a)(2)]. Executive Order 12580 delegates the President's authority under various CERCLA sections, including § 9604(a), to the Secretary of the Department of Defense (DOD) for releases or threatened releases from facilities under the jurisdiction, custody, or control of the Secretary of Defense. See E.O. 12580, Sec. 2(d). DOD is considered the "lead agency" to plan and implement response actions under the NCP (40 CFR § 300.5). The Defense Environmental Restoration Program (DERP) states that the Secretary of DOD "shall carry out (in accordance with . . . CERCLA) all response actions with respect to releases of hazardous substances from . . . [e]ach facility or site owned by . . . the United States and under the jurisdiction of the Secretary" [10 U.S.C. § 2701(c)]. DERP also provides that DERP activities are to be carried out subject to, and in a manner consistent with, Section 120 of CERCLA [10 U.S.C. § 2701(a)]. In addition, the Base Closure and Realignment Act of 1988 and the Defense Base Closure and Realignment Act of 1990 require the DOD to comply with CERCLA §120 and Executive Order 12580. The assessment of applicable or relevant and appropriate requirements (ARARs) is an integral part of the remediation process mandated under the CERCLA and the Superfund Amendments and Reauthorization Act [42 U.S.C. §§ 9601-9675]. Potential ARARs are identified early in the Remedial Action process and refined throughout the process as a result of site characterization, the development, screening, and selection of remedial alternatives. The ROD describes all ARARs for the selected remedy. Guidance for assessing and selecting ARARs is provided in the U.S. Environmental Protection Agency's (U.S. EPA) manuals CERCLA Compliance With Other Laws, Parts I and II (U.S. EPA 1988; U.S. EPA 1989a) and other EPA directives and fact sheets. "ARAR" is a CERCLA term for requirements under environmental laws, such as the Resource Conservation and Recovery Act (RCRA), that may be either "applicable" or "relevant and appropriate" but not both [OSWER Directive 9234.1-01 (August 8, 1988)]. Identification of ARARs, which is done on a site-specific basis, is based on two determinations: whether a given requirement is applicable to the site, or, if not applicable, whether it is both relevant and appropriate.


As defined in the National Contingency Plan (NCP), applicable requirements are "those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federal environmental or state environmental or facility siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance found at a CERCLA site." [40 CFR §300.5]. In order to determine the first prong of the ARAR analysis, one must determine the legal applicability of the requirement. EPA has restated this concept in the NCP as identifying those requirements which “would be legally applicable if the response action were not undertaken pursuant to CERCLA” (National Oil and Hazardous Substances Pollution Contingency Plan, 55 FR 8666, 8742, March 8, 1990). Unlike the relevant and appropriate determination, this determination is based on the jurisdictional prerequisites of the requirement and the legally mandated provisions of the requirement. Relevant and appropriate requirements are "those cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federal environmental or state environmental or facility siting laws that, while not applicable to a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance at a CERCLA site, address problems or situations sufficiently similar to those encountered at the CERCLA site that their use is well suited to the particular site." [40 CFR §300.5]. Under this determination a requirement must be both relevant (addressing similar situations or problems) and appropriate (the requirement is well suited for use at the site). When there is more than one ARAR requirement, the most stringent requirement should be followed. Requirements under federal or state law may be either applicable or relevant and appropriate to CERCLA cleanup actions, but not both. However, requirements must be both relevant and appropriate for compliance to be necessary. In the case where both a federal and a state ARAR are available, or where two potential ARARs address the same issue, the federal regulation will be used unless the potential state ARAR is more stringent. An applicable or a relevant and appropriate requirement for an on-site remedial action must be substantive. Compliance with administrative requirements is not mandated for on-site actions (U.S. EPA 1988). Administrative requirements are those procedures "that facilitate the implementation of the substantive requirements of a statute or regulation" (U.S. EPA 1988). For example, CERCLA specifically exempts on-site actions from federal, state and local permitting requirements [42 U.S.C. § 9621(e)(1)]. Furthermore, only those state requirements that are more stringent than federal requirements are ARAR [40 CFR §300.5]. "More stringent" would also include those state laws or programs that have no federal counterpart as "they add to the Federal law requirements that are specific to the environmental conditions in the State" (U.S. EPA 1989a). State requirements must be adopted by formal means (i.e. promulgated) and be generally applicable (i.e., not just to Superfund sites, but to all circumstances addressed in the requirement) [42 U.S.C. § 9621(d)(2)(C)(iii)(I)]. Selection of ARARs is dependent on the hazardous substances present at the site, the site characteristics and location, and the actions or activities selected for a remedy. Thus, these requirements may be chemical-, location-, or action-specific. However, these categories are not always mutually exclusive, and there may be some conceptual overlapping. Chemical-specific ARARs are health- or risk-based numerical values for different chemical substances (U.S. EPA 1988). Action-specific ARARs are usually technology- or activity-based requirements or limitations (U.S. EPA 1988). Location-specific ARARs are restrictions or requirements for substances or activities based primarily on their specific physical location (U.S. EPA 1988). CERCLA §121(d)(4) provides several ARAR waiver options that may be invoked, providing that the basic premise of protection of human health and the environment is not ignored.


Finally, there is a category called "To Be Considered" (TBC) guidance. These are guidelines, guidance values, advisories, criteria, or proposed standards, issued usually by federal or state agencies, but which are neither legally binding nor promulgated. These are not potential ARARs but are “to-be-considered (TBC)” guidance [40 CFR § 400(g)(3)]. However, these guidelines may be used when they are necessary to ensure protection of public health and the environment and when they have not been superseded. If no ARARs address a particular circumstance at a CERCLA site, or if the ARARs available do not ensure protectiveness, then TBCs can be used to establish remedial guidelines or targets. These standards and advisories will be addressed in the text of this report as appropriate.

The selected remedies will comply with all Federal and any more stringent State ARARs. The major ARARs that will be attained by the components of the alternatives are list below. The list of ARARs below is intended to be comprehensive; however, implementation of the ARARs will be determined, and identification of ARARs may require further refinement, during remedial design and remedial action with U.S. EPA and IEPA approval. Protection to Human Health and the Environment All the selected remedies will remove or treat the contaminated soil from the sites and sub-areas. The removed soil will either be treated or disposed of in permitted facilities. The final remedies selected for the SOU will be protective to current and future users of these sites, and the remedies will prevent or minimize direct exposure of groundwater to the contaminated soil and minimize the leaching of contaminants from soil to groundwater. The selected final remedies will reduce the carcinogenic risks to fall within the USEPA's acceptable risk range of 10-4 to 10-6; in addition, the Hazard Index for non-carcinogens will be reduced to less than one. The potential risk to ecological receptors will be reduced to acceptable limits. There are no short-term threats associated with the selected remedies that can not be easily controlled, and there are no adverse cross-media impacts. The cross-media impacts are actually positive in nature because by treating the soil, in most cases the source of groundwater contamination is removed.

11.2 Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) and To-Be-Considered (TBC) Guidance

The selected remedies will comply with all Federal and any more stringent State ARARs. The major ARARs that will be attained by the components of the selected remedies are list below. The list of ARARs below is intended to be comprehensive; additional ARARs may be identified during remedial design and remedial action with USEPA and IEPA approval.

11.2.1 Action Specific ARARs


11.2.1.1

Institutional controls

ARARs for Specific Activities Common to Both the Excavation/Treatment Alternative for SRU1 and SRU5 and the Excavation/Disposal Alternative for SRU1, SRU2, SRU3, and SRU5

• The following will be applicable to each soil remedy: 40 C.F.R. 300.430(a)(1)(iii)(D). • Substantive portions of 35 Ill. Adm. Code 742 Subpart J -applicable for institutional controls to be

placed on the property (35 Ill. Adm. Code 742.1000) and Federally Owned Property: Land Use Control Memorandums of Agreement. (35 Ill. Admin. Code 742.1012.)

• In the event of property conveyance by the USDA, see section 9.3 of the 1998 ROD for notification and recording requirement information.

Fugitive dust emissions For emissions associated with building demolition, soil extraction, soil preparation, composting, and transportation, the following requirements will be ARARs:

• 35 Ill. Admin. Code 201.141, Prohibition of Air Pollution - applicable to actions that threaten or allow the discharge or emission of any contaminant into the environment which causes or tends to cause air pollution in the State of Illinois or which violates or prevents the attainment or maintenance of any applicable ambient air quality standard.

• 35 Ill. Admin. Code 212.301, Fugitive Particulate Matter - applicable if fugitive dust emissions are produced from the remedial activities conducted pursuant to each remedy. This section prohibits the emission of fugitive particulate matter from any process, including material handling or storage activity that is visible by an observer looking generally toward the zenith at a point beyond the property line of the source.

• 35 Ill. Admin. Code 212.314, Exception for Excess Wind Speed - applicable if wind speed is greater than 40.2 km/hr (25 mph).

• 35 Ill. Admin. Code 212.315, Covering for Vehicles - applicable if vehicles are utilized pursuant to any remedy to transport, on a highway, excavated soil to central treatment areas or off-site for disposal. Trucks that transport materials on Army lands are not required to be lined, tarped, or decontaminated in the soil transportation; however, transportation across lands that have been transferred to the USDA will require the same requirements as crossing a public road. The RD/RA Work Plan will specify the requirements based on the planned transportation route.

Investigation-derived waste

• EPA OSWER Publication 9345.3-03FS (January 1992) - TBC Guidance, for IDW produced for confirmatory or other sampling procedures.

Storm water discharges

• For storm water discharges from either composting or excavation activities, the substantive requirements of the Illinois NPDES permit program (35 Ill. Admin. Code 309) will be applicable. For excavation activities, the substantive requirements of the Illinois general permit for Construction Site Activities (NPDES Permit No. ILR10) will be followed. For composting activities involving non-hazardous contaminated soil, the substantive requirements of the Illinois General NPDES Permit for Industrial Storm Water (NPDES Permit No. ILR00) will be followed.

Onsite Open Burn/Detonation of UXO/TNT


If UXO is found, it will be screened, removed and stockpiled for either open burn/detonation on-site or off-site incineration at a permitted facility. UXO may be defined as scrap metal remaining from partial detonations or intact explosive items. The scrap metal will be transported to an appropriate incineration disposal facility. If the UXO disposal is by open burn/detonation on-site, as would be likely for intact UXO items, the following requirements will be ARARs and will be met through compliance with a JOAAP base-wide burn permit. Confirmation sampling will be specified in the RD. Any contaminated soils or liquids will be a pollution control waste and therefore a special waste pursuant to 35 IAC 808/809.

• For on-site Open Burning/Open Detonation of intact UXO, the substantive requirements set forth in the following sections will be applicable to open burn/open detonation activities during implementation of this remedial alternative: 35 Ill. Admin. Code 724.701, Environmental Performance Standards; 35 Ill. Admin. Code 724.702, Monitoring, Analysis, Inspection, Response, Reporting and Corrective Action; and 35 Ill. Admin. Code 724.703, Post-closure Care. Illinois EPA considers intact UXO to meet the definition of a solid waste as identified at 35 IAC 721.102(a)(1), 726.302(a)(1)(C) and 726.302(c) because it is discarded material or when the Department of Defense makes the decision to treat/dispose of the UXO by detonation or open burning (35 IAC 721.102(b)(1) and (2)).

When encounters with intact UXO occur, the requirements of 35 IAC Part 724 do not apply to the treatment or containment activities as stated in 35 IAC 703.124 and 724.101(g)(8). However, timely notification, to Illinois EPA’s Office of Emergency Response or project manager, of any live UXO encounter must be made to document the imminent and substantial threat. Post-detonation confirmation sampling will be specified in the RD. The related closure report(s) need to describe the encounter and what was done to respond to the threat. IEPA would anticipate that a majority of the substantive requirements would be followed. Water Collected During Remedial Activities Wash water from trucks and the pressure wash operation, any surface water collected during remedial activities, wastewater collected from the onsite sumps and other areas of standing water, or any other water collected during remedial activities will be containerized and either used as makeup water in the treatment process, discharged to SB-1 or containerized for off-site disposal. If the water is used in the treatment process, no additional ARARs have been identified other than those ARARs listed below for containers and those listed for the treatment process itself. If containerized for off-site disposal, the following requirements will be ARAR.

• If the water meets the definition of a hazardous waste, then the following requirements associated with containers will be applicable to this remedial alternative: 35 Ill. Admin. Code 722.134, Accumulation Time; 35 Ill. Admin. Code 724.271, Condition of Containers; 35 Ill. Admin. Code 724.272, Compatibility of Waste with Container; 35 Ill. Admin. Code 724.273, Management of Containers; 35 Ill. Admin. Code 724.275, Containment; and 35 Ill. Admin. Code 724.278, Closure.

• If the water meets the definition of a hazardous waste and is transported off-site for disposal, then the following requirements will be applicable to this remedial alternative: 35 Ill. Admin. Code 722.111, Hazardous Waste Determination; 35 Ill. Admin. Code 722.112, US EPA Identification Numbers; 35 Ill. Admin. Code 722.120, General Requirements; 35 Ill. Admin. Code 722.121, Acquisition of Manifests; 35 Ill. Admin. Code 722.122, Number of Copies; 35 Ill. Admin. Code 722.123, Use of the Manifest; 35 Ill. Admin. Code 722.130, Packaging; 35 Ill. Admin. Code 722.131, Labeling; 35 Ill. Admin. Code 722.132, Marking; 35 Ill. Admin. Code 722.133, Placarding; 35 Ill. Admin. Code 722.140, Recordkeeping; 35 Ill. Admin. Code 722.141, Annual Reporting; 35 Ill. Admin. Code 722.142, Exception Reporting; 35 Ill. Admin. Code 722.143, Additional Reporting; 35 Ill. Admin. Code 728.107, Waste Analysis and Recordkeeping; and 35 Ill. Admin. Code 728.109, Special Rules for Characteristic Wastes and Illinois Department of Transportation Regulations: 92 Ill. Admin.


Code 171; 92 Ill. Admin. Code 172; 92 Ill. Admin. Code 173; and 92 Ill. Admin. Code 177. • Irrespective of the hazardous waste determination, the water may be considered a special waste, thus,

the following requirements will be applicable: 35 Ill. Admin. Code 808.121, Generator Obligations; 35 Ill. Admin. Code 808.240, Special Waste Classes; 35 Ill. Admin. Code 808.241, Default Classification of Special Wastes; 35 Ill. Admin. Code 808.242, Special Handling Waste; 35 Ill. Admin. Code 808.243, Wastes Categorized by Source; 35 Ill. Admin. Code 808.244, Wastes Categorized by Characteristics; 35 Ill. Admin. Code 808.245, Classification of Wastes; 35 Ill. Admin. Code 808 Subpart D, Request for Waste Classification; 35 Ill. Admin. Code 808 Subpart H, Categorical and Characteristic Wastes; and 35 Ill. Admin. Code 808 Appendix A, Assignment of Special Waste to Classes; and 35 Ill. Admin. Code 808 Appendix B, Toxicity Hazard; 35 Ill. Admin. Code 809 Subpart B, Special Waste Hauling Permits; Subpart C, Delivery and Acceptance; Subpart D, Vehicle Numbers and Symbols; Subpart E, Manifests, Records and Reporting; Subpart F, Duration of Permits... and; Subpart G, Emergency Contingencies for Spills.

Land Disposal Restrictions

• Land disposal restrictions are triggered when RCRA hazardous waste is excavated from one unit (i.e. RCRA-characteristic soil, UXO, or TNT at the individual sites in the SRUs) and placed or managed in another land-based unit (i.e., if the soil is later used for backfill in the original or a new site or disposed of offsite at a RCRA Subtitle C or at the WCLF or other permitted facility after treatment). If land disposal restrictions are triggered, then the following substantive requirements will be applicable: 35 Ill. Admin. Code 728.101, Purpose, Scope and Applicability; 35 Ill. Admin. Code 728.103, Dilution Prohibited as a Substitute for Treatment; 35 Ill. Admin. Code 728.107, Waste Analysis and Recordkeeping; and 35 Ill. Admin. Code 728.109, Special Rules for Characteristic Wastes.

• For the waste codes D003, D006, D008 and any other waste codes identified during excavation, the

following corresponding sections of Illinois hazardous waste regulations, which prohibit land disposal of specifically identified wastes, will be applicable: 35 Ill. Admin. Code 728.134, Waste Specific Prohibitions and 35 Ill. Admin. Code 728.139, Waste Specific Prohibitions.

• If each identified waste meets individually assigned treatment standards, then the wastes may be land disposed. For the waste codes D003, D006, D008, K-46, and any other wastes codes identified during excavation, the corresponding specific regulations from the following treatment standards regulations will be applicable: 35 Ill. Admin. Code 728.140, Applicability of Treatment Standards; 35 Ill. Admin. Code 728.141, Treatment Standards expressed as Concentrations in Waste; 35 Ill. Admin. Code 728.142, Treatment Standards Expressed as Specified Technologies; 35 Ill. Admin. Code 728.144, Adjustment of Treatment Standards; 35 Ill. Admin. Code 728.145, Treatment Standards for Hazardous Debris; 35 Ill. Admin. Code 728.148, Universal Treatment Standards, 35 Ill. Admin. Code 728.149, Alternative LDR Treatment Standards for Contaminated Soil; 35 Ill. Admin. Code 728.150, Prohibitions on Storage of Restricted Wastes; 35 Ill. Admin. Code 728.Table T, Treatment Standards for Hazardous Wastes, and 35 Ill. Admin. Code 728.Table U, Universal Treatment Standards.

Transportation and Disposal of Hazardous Waste at a Subtitle C Facility

The regulations in this section are applicable for any hazardous waste or waste characterized to be hazardous (i.e. soil, debris, stones, UXO, raw TNT) that is transported off-site to a RCRA Subtitle C facility.

• 35 Ill. Admin. Code 722.134, Accumulation Time; 35 Ill. Admin. Code 724.271, Condition of


Containers; 35 Ill. Admin. Code 724.272, Compatibility of Waste with Container; 35 Ill. Admin. Code 724.273, Management of Containers; 35 Ill. Admin. Code 724.275, Containment; and 35 Ill. Admin. Code 724.278, Closure; 35 Ill. Admin. Code 722.111, Hazardous Waste Determination; 35 Ill. Admin. Code 722.112, US EPA Identification Numbers; 35 Ill. Admin. Code 722.120, General Requirements; 35 Ill. Admin. Code 722.121, Acquisition of Manifests; 35 Ill. Admin. Code 722.122, Number of Copies; 35 Ill. Admin. Code 722.123, Use of the Manifest; 35 Ill. Admin. Code 722.130, Packaging; 35 Ill. Admin. Code 722.131, Labeling; 35 Ill. Admin. Code 722.132, Marking; 35 Ill. Admin. Code 722.133, Placarding; 35 Ill. Admin. Code 722.140, Recordkeeping; 35 Ill. Admin. Code 722.141, Annual Reporting; 35 Ill. Admin. Code 722.142, Exception Reporting; 35 Ill. Admin. Code 722.143, Additional Reporting; 35 Ill. Admin. Code 728.107, Waste Analysis and Recordkeeping; and 35 Ill. Admin. Code 728.109, Special Rules for Characteristic Wastes and Illinois Department of Transportation Regulations: 92 Ill. Admin. Code 171; 92 Ill. Admin. Code 172; 92 Ill. Admin. Code 173; and 92 Ill. Admin. Code 177.

• In addition, the contaminated soil and UXO/TNT will be classified as a special waste; therefore, the following special waste regulations relating to manifesting and transport will be applicable: 35 Ill. Admin. Code 808.121, Generator Obligations; 35 Ill. Admin. Code 808.240, Special Waste Classes; 35 Ill. Admin. Code 808.241, Default Classification of Special Wastes; 35 Ill. Admin. Code 808.242, Special Handling Waste; 35 Ill. Admin. Code 808.243, Wastes Categorized by Source; 35 Ill. Admin. Code 808.244, Wastes Categorized by Characteristics; 35 Ill. Admin. Code 808.245, Classification of Wastes; 35 Ill. Admin. Code 808 Subpart D, Request for Waste Classification; 35 Ill. Admin. Code 808 Subpart H, Categorical and Characteristic Wastes; and 35 Ill. Admin. Code 808 Appendix A, Assignment of Special Waste to Classes; and 35 Ill. Admin. Code 808 Appendix B, Toxicity Hazard; 35 Ill. Admin. Code 809 Subpart B, Special Waste Hauling Permits; Subpart C, Delivery and Acceptance; Subpart D, Permit Availability and Symbols; Subpart E, Manifests, Records and Reporting; Subpart F, Duration of Permits... and; Subpart G, Emergency Contingencies for Spills.

Transportation and Disposal of non-hazardous Soil, Stones, and Debris to WCLF or Other Permitted Facility Under both alternatives, the non-hazardous debris and large stones and any demolition debris from the SRUs (buildings and sumps) will be transported and disposed of at WCLF or other permitted facility. Under the excavation/disposal alternatives for each SRU, excavated non-hazardous soil will be transported and disposed of at WCLF or other permitted facility. In addition, under the treatment/disposal alternatives for each SRU, any part of the bioremediation treatment areas that are demolished after remediation and cannot be salvaged that are non-hazardous will be disposed of at WCLF or other permitted facility. For all non-hazardous soil, stones, and debris disposed at the WCLF or other permitted facility, the applicable criteria of 415 ILCS 5/22.48 for non-special waste certification will be met. The soil/stones/debris will be exempted from the requirements for a special waste using the generator certification process contained in 415 ILCS 5/22.48.

• For the treated hazardous soil sent to WCLF or other permitted facility, the hazardous waste will be

treated to remove any characteristic and meet LDRs; thus, will no longer be considered a hazardous waste. For this treated hazardous waste, 35 Ill. Admin. Code 721.103 will be applicable. The soil may be classified as a special waste as well as the building waste, debris, and large stones in accordance with 35 Ill. Admin. Code 808.240; in that event, the following special waste regulations relating to manifesting and transport will be applicable: 35 Ill. Admin. Code 808.121, Generator Obligations; 35 Ill. Admin. Code 808.240, Special Waste Classes; 35 Ill. Admin. Code 808.241, Default Classification of Special Wastes; 35 Ill. Admin. Code 808.242, Special Handling Waste; 35


Ill. Admin. Code 808.243, Wastes Categorized by Source; 35 Ill. Admin. Code 808.244, Wastes Categorized by Characteristics; 35 Ill. Admin. Code 808.245, Classification of Wastes; 35 Ill. Admin. Code 808 Subpart D, Request for Waste Classification; 35 Ill. Admin. Code 808 Subpart H, Categorical and Characteristic Wastes; and 35 Ill. Admin. Code 808 Appendix A, Assignment of Special Waste to Classes; and 35 Ill. Admin. Code 808 Appendix B, Toxicity Hazard; 35 Ill. Admin. Code 809 Subpart B, Special Waste Hauling Permits; Subpart C, Delivery and Acceptance; Subpart D, Vehicle Numbers and Symbols; Subpart E, Manifests, Records and Reporting; Subpart F, Duration of Permits... and; Subpart G, Emergency Contingencies for Spills.

11.2.1.2

Additional ARARs for Activities Specific to the Excavation/Treatment Alternatives for SRU1 and SRU5

Bioremediation Treatment Area

The following Illinois requirements will be applicable to the containment building which treats any RCRA hazardous waste: 35 Ill. Admin. Code 724.113, General Waste Analysis; 35 Ill. Admin. Code 724.114, Security; 35 Ill. Admin. Code 724.1100, Applicability; 35 Ill. Admin. Code 724.1101, Design and Operating Standards; 35 Ill. Admin. Code 724.1102, Closure and Post-closure Care; 35 Ill. Admin. Code 724.211, Closure Performance Standard; and 35 Ill. Admin. Code 724.214, Disposal or Decontamination of Equipment, Structures and Soils. Transportation requirements for RCRA hazardous waste

For all transportation of RCRA hazardous waste using state roads from the excavated areas to a central treatment area, the following Illinois Department of Transportation Regulations will be applicable: 92 Ill. Admin. Code 171; 92 Ill. Admin. Code 172; 92 Ill. Admin. Code 173; and 92 Ill. Admin. Code 177. Use of Non-Hazardous Soil Below RG’s or Bioremediated Below RG’s as Backfill The non-hazardous soil below RG’s or non-hazardous soil bioremediated to RG’s may be used as backfill in areas that do not require structural fill. No environmental requirements have been identified to regulate the backfill of non-hazardous soil below RG’s. If the soil initially exhibited a characteristic of a hazardous waste (e.g. reactivity, corrosivity, toxicity, or ignitability) or contained a listed waste, than the treated soils must meet the following conditions in order to be used as backfill:

• Meet the RGs • Not exhibit a characteristic of a hazardous waste • Not contain a listed hazardous waste • Meet Land Disposal Restrictions at 35 IAC 728

11.2.2 Location-specific ARARs and TBC Guidance • Illinois Land Conservation Act of 1995 (Public Law 104-106): Act stipulating the transfer of

JOAAP property by the Army to the USDA for the establishment of the Midewin National Tallgrass Prairie. Subtitle C, Section 2931 states that the degree of cleanup shall not be restricted or lessened by this Act but is to be carried out under provisions of any environmental law.


• Executive Order 11990, entitled Protection of Wetlands, May 24, 1977; 40 CFR 6, Appendix A – Applicable for the avoidance and minimization of adverse impacts to wetlands during remedial actions at Site M2, SRU 1.

• Pertinent portions of the Fish and Wildlife Coordination Act, as amended (16 USC 661 – 663) – Relevant and appropriate requirement for federal agencies to take into consideration the effect that water-related remedial actions will have on fish and wildlife resources in Prairie Creek and Kemery Lake adjacent to L2, SRU1 and Grant Creek adjacent to M3, SRU3 and to take action to prevent loss or damage to these resources during remedial actions. Consultation with either the Fish and Wildlife Service or the State to develop measures to protect potentially affected wildlife is recommended.

•

• The following statutory and regulatory sections are applicable for the protection of the leafy prairie clover (Dalea foliosa), federally endangered plant; for the protection of the Upland Sandpiper (Bartramia longicauda), state-listed endangered bird of Illinois; and for the protection of several species classified as endangered, sensitive, or watch species by the state of Illinois that have been identified at JOAAP: Endangered Species Act of 1973 (16 USC 1531 et seq.; 50 CFR 402; Section 10/3 of the Illinois Endangered Species Protection Act (520 ILCS 10/3), Taking of animal or animal product, as defined in 520 ILCS 10/2 “to harm, …destroy, harass… or to attempt to engage in such conduct” unlawful; 520 ILCS 10/3), Taking of plant or plant product, as defined in 520 ILCS 10/2 as “to collect, pick, cut, dig up, kill, destroy, bury, crush, or harm in any manner.”; Section 10/5.5 of the Illinois Endangered Species Protection Act (520 ILCS 10/5.5) authorized incidental takings upon approval of a conservation plan developed according to the pertinent requirements of 17 IAC 1080 et seq.; Section 10/7 (520 ILCS 10/7), Inclusion of federally listed species on the Illinois List; 17 IAC 1010.30, Official List, adopted by the Illinois Endangered Species Protection Board as the Official List of Endangered and Threatened Fauna of Illinois; 17 IAC 1050, Official List, adopted by the Illinois Endangered Species Protection Board as the Official List of Endangered and Threatened Flora of Illinois.

• Fish and Wildlife Coordination Act (16 USC 661 et seq. and § 668 - relevant and appropriate for the protection of federal and state-listed endangered, sensitive, or watch species as listed in the bullet above.

• Pertinent portions of 17 IAC 1075, Consultation Procedures for Assessing Impacts of Agency Actions on Endangered and Threatened Species and Natural Areas, are TBC guidance for remedial activities at JOAPP. The Clean Water Act Section 404, 40 CFR 230 (1997), and 33 CFR 320-330 (1997) – applicable for protection of surface waters.

To Be Considered Guidance in Absence of Chemical-specific ARARs Under federal and Illinois law, there are no promulgated enforceable standards for the chemicals of concern (explosives, metals, and TPHs) in soils at the sites being addressed in SRUs 1, 2, 3, and 5. During the finalization of the 1998 ROD, concerns were raised about the protectiveness of soil cleanup goals established for prairie workers and ecological receptors exposed to contaminated soils at the sites in SRU1, 2, 3, and 5 intended for transfer to USDA and were given interim status. Consequently, through collaboration of representatives from the agencies on the JOAAP Management Team, cleanup goals for the soil contaminants at these sites were established in an agreement signed on August 21, 2003. Tables 6-1 and 6-2 present the cleanup goals for the soil contaminants at the interim sites. The cleanup approach agreed to by all parties on the team will result in the excavation of areas exceeding the excavation design value. Confirmatory sampling will be performed across the excavation and in adjacent potentially impacted areas to ensure that the average concentrations do not exceed the RG. Any areas exceeding 500 mg/kg for lead will be excavated.


The excavation design value for total petroleum hydrocarbons (TPHs) in soils at SRU 5 will be 2,500 mg/kg, which is the value stipulated in the 1998 ROD for the other sites in the soils operable unit. RGs developed by the Human Health Work Team for PAHs will be used for confirmation sampling following excavation of areas with TPH contamination as RGs.

11.3 Cost Effectiveness The selected final remedies for the SOU provide overall effectiveness proportionate to its costs. Although other remedies have lower or higher costs, the selected remedies were chosen because they have the best cost/benefit ratio. After balancing short- and long-term effectiveness and permanence, reduction in toxicity, mobility or volume of contaminant, and implementability to the overall cost of the selected remedies, the ratio of these criteria to cost is the best for the selected remedies compared to the other remedies. The overall net present worth cost of capital and operational and maintenance cost for the SOU remedies specific to this ROD is estimated to be $11,688,721.

11.4 Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery Technologies) to the Maximum Extent Practicable

The Army, the USEPA, and the IEPA have determined that the selected final remedies represent the maximum extent to which permanent solutions and treatment technologies can be utilized in a cost-effective manner for the JOAAP SOU. The Army, the USEPA, and the IEPA have selected alternatives that are protective of human health and the environment and comply with ARARs. In addition, the Army, the USEPA, and the IEPA have determined that these selected remedies provide the best balance of tradeoffs between the five balancing criteria while considering the statutory preference for treatment as a principal element and State and community acceptance.

11.4.1 SRU1: Explosives in Soil The selected final remedy, Excavation/Treatment, provides the best balance among the four alternatives evaluated against the nine evaluation criteria. Based on available information, the selected final remedy utilizes permanent solutions to the maximum extent practicable, and satisfies the RAOs. Of the five statutory criteria met, reduction in toxicity, mobility, and volume, and long-term effectiveness and permanence were the most critical in the selection process. Although more expensive than Excavation/Disposal, Excavation/Treatment is recommended because it will treat the soils at JOAAP that pose the majority of the risk to human health and the environment. This will also satisfy the regulatory preference of CERCLA for treatment over disposal.

11.4.2 SRU2: Metals in Soil The selected final remedy, Excavation/Disposal, provides the best balance among the three alternatives evaluated against the nine evaluation criteria. Based on available information, the selected remedy utilizes permanent solutions to the maximum extent practicable, and satisfies the RAOs. Of the five statutory balancing criteria, reduction in toxicity, mobility, and volume, and cost-effectiveness were the most critical in the selection process.


11.4.3 SRU3: Explosives and Metals in Soil The selected final remedy, Excavation/Disposal, provides the best balance among the three alternatives evaluated against the nine evaluation criteria. Based on available information, the selected remedy utilizes permanent solutions to the maximum extent practicable, and satisfies the RAOs. Of the five statutory balancing criteria, reduction in toxicity, mobility, and volume, and cost-effectiveness were the most critical in the selection process.

11.4.4 SRU5: Organics in Soil

The selected final remedy, Excavation/Treatment, provides the best balance among the four alternatives evaluated against the nine evaluation criteria. Based on available information, the selected final remedy utilizes permanent solutions to the maximum extent practicable, and satisfies the RAOs. Of the five statutory criteria met, implementability, reduction in toxicity, mobility, and volume, and long-term effectiveness and permanence were the most critical in the selection process.

11.5 Preference for Treatment as a Principal Element The selected final remedies meet the NCP’s expectations to treat principal threat wastes and contain low level threats. Investigations conducted at the site yielded an estimated total of approximately 36,175 cubic yards of soil contaminated above the RGs requiring cleanup. The contaminants found at the highest concentrations at JOAAP, or the principal threat wastes, are explosives in soil. Treatment (bioremediation) is selected for SRU1 and SRU5, which represents approximately 21,010 cubic yards of explosives contaminated soil. Containment alternatives (Excavation/Disposal) were selected for approximately 15,165 cubic yards of contaminated soil which do not pose a principal threat. The final remedies selected for the SOU represents an acceptable balance between containment and treatment.

[END OF SECTION]


12 DOCUMENTATION OF SIGNIFICANT CHANGES The Proposed Plan for the interim SOUs at the JOAAP were issued for public comment on February 20, 2004. The Proposed Plan identified preferred alternatives for each of four SRUs with respect to soil at the JOAAP. A public meeting on the Proposed Plan was held on March 3, 2004. The public comment period ended on March 20, 2004. One comment was received at the public meeting from the RAB in support of the planned activities (“…we strongly support the document as presented and recommend…that its signing be expedited”). All actions are considered final actions. Due to a lack of further public comment, it was determined that no other significant changes to the remedies, as originally identified in the Proposed Plan, were necessary.

12.1 Documentation of Other Changes There are some minor differences in the information presented in the Focused Feasibility Study, and the Proposed Plan, on which this Record of Decision is based. These differences resulted from new information and from corrections of calculation errors discovered in the cost tables. These differences are summarized as follows:

• The cost of the Excavation/Treatment and Excavation/Disposal remedies for the SRUs have been recalculated because of an error in the cost assumption. The cost assumption was a site specific number that contained several components that were then separately added into the assessment. This recalculation caused an overall decrease in the cost of the remedies from those costs presented in the proposed plan.

• The time required to complete SRU1 remedial action was decreased from the 5 years presented in the proposed plan to 3 years. This change is due to desire by Army to complete the remedial action on an accelerated schedule.

[END OF SECTION]


13 REFERENCES Alliant Techsystems, 1997. Closeout Inspection of Wilmington, Illinois LAP Facility, prepared for Alliant Techsystems by Roy J. Caniano, Acting Director, Division of Nuclear Materials Safety, July 17, 1997, Report No. 040-08830/97002(DNMS). Argonne National Laboratory, 1995. Plant Uptake of Explosives from Contaminated Soil at the Joliet Army Ammunition Plant, prepared for USAEC, Report No. SFIM-AEC-ET-CR-95014. Dames & Moore, 1997. Feasibility Study, Soil and Groundwater Operable Units, Load-Assemble-Package (LAP) Area, Joliet Army Ammunition Plant, Joliet, Illinois, Volumes 1-3, prepared for USAEC, August 22, 1997 (Volume 2), September 4, 1997 (Volumes 1 and 2). Dames & Moore, 1996. Oleum Plant Remedial Investigation, Addendum No. 1 to the Phase 2 Remedial Investigation and Baseline Risk Assessment, Manufacturing (MFG) Area, Joliet Army Ammunition Plant, Joliet, Illinois, prepared for USAEC, July 3, 1996. Dames & Moore, 1995a. Baseline Risk Assessment, Load-Assemble-Package (LAP) Area, Joliet Army Ammunition Plant, Joliet, Illinois, Volumes 1-3, prepared for USAEC, February 3, 1995. Dames & Moore, 1995b. Determination of Class II Groundwater, Joliet Army Ammunition Plant, Joliet, Illinois, prepared for USAEC, September 20, 1995. Dames & Moore, 1994. Phase 2 Remedial Investigation, Load-Assemble-Package (LAP) Area, Joliet Army Ammunition Plant, Joliet, Illinois, Volumes 1 and 2, prepared for USAEC, December 5, 1994, Report No. SFIM-AEC-IR-CR-95023. Dames & Moore, 1994. Baseline Risk Assessment, Manufacturing (MFG) Area, Joliet Army Ammunition Plant, Joliet, Illinois, Volumes 1-3, prepared for USAEC, December 5, 1994, Report No. SFIM-AEC-IR-CR-95034. Dames & Moore, 1993. Phase 1 Remedial Investigation, Load-Assemble-Package (LAP) Area, Joliet Army Ammunition Plant, Joliet, Illinois, Volumes 1 and 2, prepared for USAEC, July 1, 1993, Report No. ENAEC-IR-CR-93097. Dames & Moore, 1993. Phase 2 Remedial Investigation, Manufacturing (MFG) Area, Joliet Army Ammunition Plant, Joliet, Illinois, Volumes 1 and 2, prepared for USAEC, May 30, 1993, Report No. ENAEC-IR-CR-93065. Dames & Moore, 1991. Phase 1 Results Report, Remedial Investigation, Manufacturing Area, Joliet Army Ammunition Plant, Illinois, Volumes 1 and 2, prepared for USATHAMA, March 15, 1991, Report No. CETHA-IR-CR-90127. Dames & Moore, 1988. Environmental Baseline Study, Group 3A and AT4-PVC Area, submitted to Honeywell Joliet LAP Facility, Joliet, Illinois Dames & Moore, 1986. Environmental Baseline Study, Proposed Burn Ground, Joliet, Illinois, submitted to Honeywell Joliet LAP Facility, Joliet, Illinois


Dames & Moore, 1986. Midwest Site Confirmatory Survey Assessment Report for Joliet Army Ammunition Plant, prepared for USATHAMA, Aberdeen Proving Ground, Maryland, November 26, 1986, Report No. AMXTH-IR-CR-86095. Donohue & Associates, 1983. Joliet Army Ammunition Plant--Phase II Technical Report, volumes 1 and 2, prepared for USATHAMA, Aberdeen Proving Ground, Maryland, August, 1983. Donohue & Associates, 1982. Installation Restoration Surveys: Joliet Army Ammunition Plant (JOAAP), Volumes 1 and 2, submitted to USATHAMA, Aberdeen Proving Ground, Maryland, November 10, 1982. ECG, Inc, 1998. Record of Decision Soil and Groundwater Operable Units Manufacturing and Load-Assemble-Package Areas, October 1998. ECHOS (Environmental Cost Handling Options and Solutions), 1995. Environmental Restoration Unit Cost Book and Assemblies Cost Book, Los Angeles, CA, 1995. Ecological Work Group, 2000. Ecological Preliminary Remediation Goals, Joliet Army Ammunition Plant, August 2000. Glass, William, 1994. A Survey of the Endangered and Threatened Plant and Animal Species of the Joliet Army Ammunition Plant and Joliet Training Area, Will County, Illinois. Division of Natural Heritage, Illinois Department of Conservation, Springfield, Illinois, March, 1994 Human Health Work Group, 2000. Joliet Army Ammunition Plant Human Health Preliminary Remedial Goals, Midewin National Tallgrass Prairie, August 2000. International Technology Corporation, 1998. Final Report, U.S. Department of Defense Removal Action, L6/Group 70 Area, Joliet Army Ammunition Plant, Wilmington, Illinois, Prepared for U.S. Army Corps of Engineers, Louisville District, March 1998 OHM Corporation, 1997. Feasibility Study, Soil and Groundwater Operable Units, Manufacturing (MFG) Area, Joliet Army Ammunition Plant, Will County, Illinois, Volumes 1-3, prepared for USAEC, September 29, 1997. OHM Corporation, 1996. Preliminary Remediation Goals, Manufacturing (MFG) Area and Load-Assemble-Package (LAP) Area, Joliet Army Ammunition Plant, Will County, Illinois, submitted to USAEC, April, 1996. Plexus Scientific, 1997. Enhanced Preliminary Assessment Screening, Land Transfer to Will County for Future Landfill, Joliet Army Ammunition Plant, Will County, Illinois, prepared for USAEC. Plexus Scientific, 1996. Enhanced Preliminary Assessment Screening, Land Transfer to U.S. Department of Agriculture, Joliet Army Ammunition Plant, Will County, Illinois, prepared for USAEC. U.S. Army 2004. Proposed Plan for the Interim Soil Operable Unit, Joliet Army Ammunition Plant, Will County, Illinois. U.S. Army, 1997a. Proposed Plan for the Soils Operable Unit, Joliet Army Ammunition Plant, Will County, Illinois.


U.S. Army, 1997b. Proposed Plan for the Groundwater Operable Unit, Joliet Army Ammunition Plant, Will County, Illinois. U.S. Army Corps of Engineers (USACE), 2004. Focused Feasibility Study Soil Operable Unit, Load-Assemble-Package and Manufacturing Area, February 2004. U.S. Army Environmental Center (USAEC, formerly the Toxic and Hazardous Materials Agency (USATHAMA), 1978. Installation Assessment of Joliet Army Ammunition Plant, Office of the Project Manager for Chemical Demilitarization and Installation Restoration; record Evaluation Report No. 128, Aberdeen Proving Ground, Maryland, September, 1978. U.S. Army Environmental Hygiene Agency (AEHA), 1990. Storm Water Outfall Evaluations, Joliet Army Ammunition Plant, Joliet, Illinois, Wastewater Management Consultation No. 32-24-0029-90. U.S. Army, U.S. Environmental Protection Agency (USEPA), and Illinois EPA (IEPA), 1989. Federal Facility Agreement for Joliet Army Ammunition Plant, Elwood, Illinois. U.S. Army Center for Health Promotion and Preventive Medicine (USACHPPM, formerly U.S. Army Environmental Hygiene Agency, AEHA), 1994. Final Ecological Risk Assessment, Joliet Army Ammunition Plant, Volume 1, Phase 1, November 1, 1994. USCHPPM (formerly AEHA), 1994. Health Risk Assessment for Consumption of Deer Muscle and Liver from Joliet Army Ammunition Plant, Joliet, Illinois. USCHPPM, 1996. Final, Phase 2 Aquatic Ecological Risk Assessment No. 32-EE-1420-93, Joliet Army Ammunition Plant, Joliet, Illinois, 14-17 June 1993. U.S. Army Corps of Engineers (USACE), 1989. Joliet AAP, Joliet, Illinois: Investigation and Evaluation of Underground Storage Tanks, prepared for USACE, Huntsville, Alabama by USACE, Omaha, Nebraska, September, 1989. USEPA, December 1991, Risk Assessment Guidance for Superfund Volume I, Publication 9285.701B, December 1991 and Volume II, EPA/540/1-89/001. USEPA, March 1989, Risk Assessment Guidance for Superfund Volume II, Publication EPA/540/1-89/001. USEPA, July 1989, Guidance on Preparing Superfund Decision Documents: The Proposed Plan, The Record of Decision, Explanation of Significant Differences, The Record of Decision Amendment, Publication EPA/540/G-89/007.

[END OF SECTION]


JOAAP Record of Decision Interim Soil Operable Units Final pg. 13-1

14 COMMUNITY PARTICIPATION RESPONSIVENESS SUMMARY

Joliet Army Ammunition Plant Record of Decision

RS 0 Overview The Proposed Plan for the Interim Soils Operable Unit was released on February 20, 2004. Copies of the Proposed Plan were available for pick up at the Joliet offices of MWH, inc. Copies were also made available at the information repositories (the JOAAP office and the Joliet Public Library). In accordance with Section 117, of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980, 42 U.S.C. Section 9617, the U.S. Army held a public comment period from February 20, 2004 to March 20, 2004, a period of thirty days. A public meeting was held on March 3, 2004 at the Wilmington City Council Chamber. At that meeting, the U.S. Army presented the Proposed Plans and responded to questions from the floor. One verbal comment was recorded in the meeting transcript as a collective statement from the RAB. The RAB voted to accept the comment at the May 5, 2004 meeting. Notifications were placed in the Joliet local newspaper concerning the Proposed Plan, public comment period and the public meeting. The purpose of this Responsiveness Summary is to document the Army’s response to the comment received during the public comment period. This comment was considered prior to selection of the final remedy for soil contamination at the Joliet Army Ammunition Plant in this ROD.

RAB Comment: (From the transcript as quoted by Dr. Mariann Hahn) “…we strongly support the document as presented and recommend that its signing be expedited.”

[END OF SECTION]

JOAAP Record of Decision Soil & Groundwater OUs – October, 1998 pg. RS - 1

Appendix A

JOAAP Record of Decision Interim Soil Operable Unit Final pg. 1

Joliet Army Ammunition Plant (JOAAP) Management Team Agreement

On Cleanup Approach and Goals

1. PURPOSE The purpose of this report is to document agreement of the JOAAP Management Team on the approach and cleanup goals for the interim restoration sites contained within JOAAP property that have been identified to be transferred to the US Department of Agriculture (USDA) for establishment of the Midewin National Tallgrass Prairie (MNTP) under the Public Law 104-106, Title 29.

2. BACKGROUND In 1998, the Army, in coordination with the USEPA and Illinois EPA, concluded its investigations of JOAAP restoration sites under CERCLA, through the development of a Record of Decision (ROD) documenting cleanup actions necessary for protectiveness of human health and the environment. At the time the ROD was being finalized, the USDA raised concerns over the protectiveness of the proposed cleanup goals for workers and ecological receptors within the MNTP to be established on the transferred lands. The ecological risk assessment conducted under the JOAAP restoration program to support the ROD, in accordance with accepted EPA guidelines at the time of its production, determined that the sites presented no ecological risk; therefore, all original cleanup goals were established based on protectiveness of human health. However, the US Department of Agriculture, US Forest Service, US Fish and Wildlife Service, and Illinois Department of Natural Resources strongly disagreed with the conclusion that there was no ecological risk. As a result, the Army, the Illinois Environmental Protection Agency and US Environmental Protection Agency signed an interim ROD for the USDA lands. The Declaration of the ROD states “Because the actions within SRUs [Soil Response Units] 1, 2, 3 and 5 for USDA lands are interim, the review of these lands and the interim remedies will be ongoing as final remedial alternatives are developed”. The interim remedial goals in the ROD for these sites were to be subject to reevaluation by a Management Group, consisting of representatives from the US Army, US Environmental Protection Agency, US Department of Agriculture, US Forest Service, US Fish & Wildlife Service, Illinois Environmental Protection Agency, and Illinois Department of Natural Resources. The specific sites covered under this agreement, as listed in Table 4-1 of the October 1998 Record of Decision, are sites L1, L2, L3, L5, L7, L8, L9, L10, L14, L23A, M2, M3, M4, and M12. In April 1999, the Management Team established two workgroups charged with developing proposed cleanup levels for each chemical of concern that are protective of human health and the environment and compatible with development of a tallgrass prairie. A Human Health Assessment Workgroup was established to evaluate the risk of exposure to contaminants in soil for workers conducting prairie establishment and maintenance activities on the property currently managed by, or intended for the USDA, consistent with USEPA current risk assessment for Superfund. The Army, USEPA, and IEPA


were to conduct this evaluation in consultation with the Secretary of Agriculture and the Illinois Department of Natural Resources. A Biological Technical Assistance Group (BTAG), composed of representatives of the Army, USEPA, IEPA, USDA, Illinois Department of Natural Resources, and Department of Interior/US Fish and Wildlife Service, was established to determine exposure levels for ecological resources on USDA lands that are protective of the environment and compatible with development of the tallgrass prairie. The exposure levels established by the BTAG were to be compared to the human health risk-based remediation goals established for USDA lands. Appropriate final remedial actions for USDA soils were then to be developed, evaluated and selected in accordance with the National Contingency Plan (NCP). Workgroup results consisting of preliminary remedial goals were presented to the Management Team in August 2000 for consideration in selecting final remedial goals for the site. Since August 2000, the Management Team has been meeting regularly to reach consensus on cleanup goals that are protective of human health and the environment, are compatible with the management goals of the MNTP, and recognize the need to implement cost-effective remedies to efficiently manage Federal funds.

3. ACCEPTED CLEANUP GOALS AND APPROACH

This report documents the results of negotiations to develop cleanup approach and goals that will protect human health and the environment while recognizing the uncertainties in predicting the risks to ecological systems, the need to reevaluate assumptions, and the need to implement cost effective remedies to efficiently manage public funds. 3.1 Cleanup Goals. The inherent uncertainties associated with risk assessment process, and the unique exposure factors and receptors associated with MNTP, limit the precision with which risk can be predicted. This results in a broad range of potential cleanup values that are considered protective with a corresponding range of cleanup costs. The Management Team has agreed to a cleanup approach that takes into consideration the upper and lower ends of the cleanup value range thus ensuring protectiveness and responsible use of cleanup funds. Table 1 presents the range of cleanup values developed by the Management Team for each contaminant of concern at the interim sites. 3.2 Cleanup Approach. After several attempts to reach consensus on a single cleanup value for each contaminant of concern, within the range of values developed, the Management Team agreed to an approach that essentially uses the full range of cleanup values. Under the agreement, the Army will excavate areas exceeding the excavation design value and conduct confirmatory sampling across the excavation and adjacent potentially impacted area to ensure average concentrations do not exceed the site RG value. The Management Team agreed that any area exceeding 500 mg/Kg for lead (Pb) will be excavated. This will ensure protectiveness without over-excavation. Details of the approach are provided below.

3.2.1 Pre-excavation Sampling. The Army will conduct pre-excavation sampling to provide data on potential areas of contamination as evidenced by stained or disturbed soils or where existing data indicate concentrations above the excavation design value but do not provide sufficient characterization to design excavation. Stained or suspect soils will be sampled at the frequency outlined in Section 3.2.3 below.


Table 1: Proposed Cleanup Goals for Joliet AAP Interim Sites

Constituent

Lower Cleanup

Value mg/Kg

Basis for Low Value Upper

Cleanup Value mg/Kg

Basis for High Value

Antimony 50 Low Adverse Effects Level for plants 757 Human health based

Arsenic 21 Low Adverse Effects Level forinsectivores 84 2 x UTL based RI analysis

Barium 625 No Adverse Effects Level for Plants 1950 Low Adverse Effects Level for Insectivores

Cadmium 63 No Adverse Effects Level for Plants 220 Low Adverse Effects Level for Insectivores

Chromium 213 Low Adverse Effects Level forinsectivores 213 Low Adverse Effects Level for

Insectivores

Cobalt 240 No Adverse Effects Level for Plants 2400 Low Adverse Effects Level for Plants

Copper 190 No Adverse Effects Level for Plants 925 Low Adverse Effects Level for Plants

Lead 500 Low Adverse Effects Level for plants 500 Low Adverse Effects Level for Plants

Mercury 10 No Adverse Effects Level for Plants 13 Low Adverse Effects Level for Insectivores

Nickel 210 No Adverse Effects Level for Plants 2090 Low Adverse Effects Level for Plants

Silver 16 Low Adverse Effects Level for plants 9467 Human health based

Thallium 2 x UTL* Low Adverse Effects Level forCarnivores 86 Low Adverse Effects Level for

Carnivores

Zinc 720 No Adverse Effects Level for Plants 2500 Low Adverse Effects Level for Insectivores

2,4-DNT 20 Human Health Based 20 Human Health Based

2,6-DNT 20 Human Health Based 20 Human Health Based

HMX 2860 Low Adverse Effects Level forHerbivores 2860 Low Adverse Effects Level for

Herbivores


Table 1 (Continued): Proposed Cleanup Goals for Joliet AAP Interim Sites

Constituent

Lower Cleanup

Value mg/Kg

Basis for Low Value Upper

Cleanup Value mg/Kg

Basis for High Value

RDX 107 Low Adverse Effects Level for Plants 125 Human Health Based

TNB 17 Low Adverse Effects Level for Plants 386 Low Adverse Effects Level for Insectivores

2,4,6-TNT 459 200 Low Adverse Effects Level for Plants Human Health Based

* UTL - Upper Tolerance Limit of background population based on data collected during confirmation sampling and appropriate analytical method 3.2.2 Excavation Design. Two approaches to excavation design will be used: one for excavation of release areas where data indicate a release of a site contaminant has occurred and one for points that have concentrations exceeding the upper cleanup value but surrounding points do not indicate a release (anomalies). 3.2.2.1 Release Areas. The Army will design excavations at the sites to encompass areas of contaminant releases above the upper cleanup value based on existing data and any data collected from pre-excavation sampling. Depths of excavations will be based on available data and any pre-excavation sampling data. Based on data currently available, excavations are generally not expected to exceed four feet in depth. However, it may be necessary for some individual excavations to exceed four feet in depth where sampling indicates source areas exist that could result in significant ecological or groundwater impacts. As the lead agency, the Army will make a recommendation as to when the excavation for a specific site is completed in terms of depth and aerial extent. The final excavation will be approved by the USEPA and Illinois EPA in consultation with the US Forest Service, Illinois Department of Natural Resources and US Fish and Wildlife Service. 3.2.2.2 Anomalies. Where existing data indicate isolated points where upper cleanup values are exceeded, but no reasonable explanation for the exceedence exists, excavation will be limited to a 5 foot by 5 foot area surrounding the point to a depth of 1 foot below the sample point showing the high concentrations. If available, concentration gradients down the soil column will be used to tailor the excavation depth or possibly eliminate the site from consideration (e.g., high concentrations of naturally occurring metals are found only at depth, indicating no surficial release has occurred). Anomalies will be identified on a site-specific basis considering site history, comparison to constituents of adjacent sampling points, and proximity to adjacent points. The Feasibility Study and Remedial Design will highlight such sites. Confirmation sampling will not be conducted at these sites. 3.2.3 Confirmatory Sampling. Confirmatory sampling will be modeled after the confirmatory sampling procedures currently used and documented in the Sample and Analysis Plan appendix to the Remedial Design/Remedial Action Workplan, in effect for all final ROD sites, as discussed below. Confirmation sampling will be performed to verify that the lateral and vertical limits of soil contamination have been reached by the excavation activities. The results of this sampling activity will be used to confirm that the soil remaining does not exceed the lower cleanup value on average across the excavation and potentially impacted surrounding area, with the exception of lead (Pb) contaminated soils, which will be excavated to 500 mg/Kg at all points. Confirmation sampling will extend beyond the area


of excavation to encompass existing sampling points where the lower cleanup values for contaminants associated with the release area were exceeded (Excavation Fringe Area). This will provide assurance that the average concentrations of contaminants remaining within the impacted area are below the lower cleanup values and are protective for the most sensitive receptors. Due to the small, irregular shaped excavations anticipated at several of the sites, an unbiased, random approach to locating samples may not provide adequate assurances that cleanup goals have been met. Instead, a minimum number of confirmation samples will be collected from locations that are appropriate for a specific excavation, targeting areas that have the greatest potential for contamination. Some examples of potentially contaminated areas include: around building foundations and small disposal areas. Two different decision processes will be used to enumerate the number of samples required to confirm adequate source removal: one for trench excavations and one for area excavations. Trench excavations include excavations that occur along a ditch or pipeline, and are relatively uniformly contaminated along its length. Area excavations include all other types of excavations whether they are shallow or deep and narrow or wide.

For excavations exceeding 5 feet in depth, additional samples will be collected from the sidewalls using the same sample collection frequency. Sidewall samples will be collected approximately 2 to 3 foot vertical intervals from the floor of the excavation.

Trench Excavations. Samples collected to confirm the lateral extent of trench excavations will be collected from the ground surface (or trench sidewalls if the trench excavation is greater than 5 feet deep) on both sides of the trench at the following locations along the trench:

3.2.3.1 Lateral Extent Confirmation Sampling. Area Excavations. Discrete samples collected to confirm the lateral extent of area excavations will be located at a minimum of one per 50 feet along the edge of the excavation, or at a minimum one sample per face of an excavation. Selected locations will be associated with previous hot spots where appropriate.

For excavations less than 5 feet deep, each sidewall sample will be collected (grab sample) from approximately one-half the depth of the excavation at the selected sample location. If underground piping enters an excavation, a confirmation grab sample will be collected from within 1 foot beneath the bottom of the pipe where it enters the excavation.

Within the first 10 feet of the beginning of the trench Within the first 10 feet of the end of the trench At least 1 additional location between the beginning and end of the trench but no less than 1

every 50 feet At any bends or tees (may take the place of the above listed sample requirement)

Sidewall samples will be collected (grab sample) across an area approximately between 2 to 3 feet above the base of the excavation. Excavation Fringe Area. The fringe area immediately surrounds the excavation and is defined by sampling points outside the excavation that exceed the lower cleanup value of contaminants of concern


within the excavation area. Lateral extent confirmation sampling will be conducted on the fringe of the excavation encompassing all points that exceed the lower cleanup value for any constituent identified within the excavation area above the lower cleanup value. Samples will be taken at a minimum of 1 sample per 1000 square feet within the boundaries of the fringe area. For areas less than 3000 square feet, a minimum of 3 samples will be collected. Sampling points within the fringe area will be set to the depths of the data used to define the fringe. 3.2.3.2 Vertical Extent Confirmation Sampling. Area Excavations. For area excavations, a minimum of 1 sample per 1000 square feet will be collected to confirm the vertical extent of contamination. For areas less than 3000 square feet, a minimum of 3 samples will be collected. Samples will target locations that have a higher potential for contamination (such as beneath hot spots, sumps, etc.) with any additional sample locations selected uniformly across the remaining floor of the excavation. Trench Excavations. For trench excavations, a minimum of 1 sample per 50 feet of the excavation will be collected to confirm the vertical extent of contamination. At least 2 vertical confirmation samples will be collected per trench excavation. Sample locations will be spaced uniformly along the trench, targeting locations that have a higher potential for contamination, such as at either end of the trench or at tees or bends in the trench. 3.2.3.3 Confirming Closure. Discrete samples will be analyzed for the suite set of contaminants found within the release areas that exceed the lower cleanup value. Methods for analyses (field and lab analyses) will be selected as part of the remedial design effort. Reporting limits will be set below the lower cleanup value for each constituent. Analytical results will be used to calculate the average concentration for each constituent across the excavation and fringe area for comparison to the lower cleanup value, with the exception of lead for which any point exceeding the cleanup value of 500 mg/Kg will undergo further excavation. Any additional excavation will be conducted in a rectangular area centered on the sample or samples that drove the average concentration above the lower cleanup value, according to the following conditions for lateral extent and vertical extent. Vertical Extent. For any excavation floor sampling location where additional excavation is required, an additional six inches of materials will be excavated at least five feet in each direction from each sampling point that drove the average concentration above the lower cleanup value. If adjacent sampling points are targeted for supplemental excavation based on high concentrations, excavation will encompass the area between the points. At a minimum, this will result in a supplemental excavation 10 feet wide, 10 feet long, and 0.5 feet deep, for a total of 50 cubic feet centered on the high sample location. For areas with adjacent sampling points with high concentrations, the dimensions of the supplemental excavation cannot be determined until results are reviewed; however, a minimum of an additional 50 cubic feet will be excavated as a result at selected sampling points of high concentration if average concentrations exceed the lower cleanup value. Supplemental excavation for lead (Pb) will be designed similar to the approach above to remove all concentrations above the cleanup value of 500 mg/Kg. Lateral Extent. For any excavation side wall sampling location where additional excavation is required, additional excavation will be conducted 5 feet into the sidewall of the excavation and 5 feet on either side of sampling points that drove the average concentration above the lower cleanup value to the full depth of the adjacent excavation. If adjacent sampling points are targeted for supplemental excavation based on high concentrations, excavation will encompass the area between the points. At a minimum, this will result in a supplemental excavation of 10 feet wide by 5 feet long and as deep as the adjacent excavation. For areas with adjacent sampling points with high concentrations, the dimensions of the supplemental


excavation cannot be determined until results are reviewed. Supplemental excavation for lead (Pb) will be designed similar to the approach above to remove all concentrations above the cleanup value of 500 mg/Kg. Final Confirmation. Confirmation sampling will be conducted within the bounds of the supplemental excavation area in accordance with the procedures above. The results of the supplemental sampling will be averaged with the initial confirmation sampling results to ensure that the residual average is below the lower cleanup value, except for lead (Pb) for which each point will be excavated to the cleanup value of 500 mg/Kg.

3.3 Sewer Line Disposition. Storm sewer lines will be identified, located, and examined to determine the presence of contamination in the surrounding soils (bedding and outfalls soils) and any residual in the pipes. If average concentrations of contaminants in the surrounding soils are above the RGs, the soils and pipe will be removed to the extent necessary to address the soils. All excavations will undergo confirmation sampling. If the residual in the pipe is hazardous (10% or greater explosives concentration), the residual will be removed and treated. 4. CONCURRENCE

The undersigned members of the Joliet Army Ammunition Plant Management Team hereby concur on the cleanup goals and approach detailed in this agreement on the 21st day of August, 2003.

________________________________ __________________________________ Arthur M. Holz Diana Mally Joliet AAP Remedial Project Manager/ Remedial Project Manager Site Manager/Commander’s Rep US Environmental Protection Agency US Army ________________________________ __________________________________ Paul Lake Mark Tumeo Remedial Project Manager USDA Secretary’s Representative Illinois Environmental Protection Agency US Department of Agriculture ________________________________ __________________________________ Karla Kramer Don Meyer Assistant Field Supervisor Deputy Regional Forester Chicago, Illinois Field Office Region 9 US Fish and Wildlife Service US Forest Service

_______________________________ Stephen Davis Chief, Division of Resource Review and Coordination Illinois Department of Natural Resources


ADDENDUM Clarification of Pre-Excavation Sampling Decision Logic

During the Management Team meeting conducted on 22 Sep 03, various interpretations of how results of pre-excavation sampling would be used in determining the course of cleanup came to light. All signatories to the Joliet Army Ammunition Plant (JOAAP) Management Team Agreement On Cleanup Approach and Goals have agreed upon the following text to supplement Section 3.2.1 of the agreement: 3.2.1.1. If pre-excavation sampling determines the average concentration of any contaminant of concern is below the lower cleanup value, and no sampling points exceed the upper cleanup value, no further action is required at the site. 3.2.1.2. If pre-excavation sampling determines the average concentration of any contaminant of concern is below the lower cleanup value, but one or more sampling points exceed the upper cleanup value, the points will be removed in accordance with Section 3.2.2.2 (Anomalies). 3.2.1.3. If pre-excavation sampling determines the average concentrations of any contaminant of concern is above the lower cleanup value, regardless of whether any one point exceeds the upper cleanup value, excavation will be designed to reduce the average concentration below the lower cleanup value.

[END OF SECTION


Appendix B


Table 3-2 Cost Estimate for Limited Action Alternative

SRU1 - Explosives in Soil Description Unit Cost Unit Quantity Total Deed Restrictions Legal Time $ 125 hour 64 $ 8,000 Survey $ 2,500 day 8 $ 20,000

Subtotal $ 28,000 Fence Installation L1 $ 23.34 linear foot 2,850 $ 66,519 L2 $ 23.34 linear foot 0 $ - L7 $ 23.34 linear foot 0 $ - L8 $ 23.34 linear foot 0 $ - L9 $ 23.34 linear foot 0 $ - L10 $ 23.34 linear foot 0 $ - L14 $ 23.34 linear foot 200 $ 4,668 M2 $ 23.34 linear foot 4,200 $ 98,028

Subtotal 7,250 $ 169,215 Gate Installation L1 $ 749.97 gate 1 $ 750 L2 $ 749.97 gate 0 $ - L7 $ 749.97 gate 0 $ - L8 $ 749.97 gate 0 $ - L9 $ 749.97 gate 0 $ - L10 $ 749.97 gate 0 $ - L14 $ 749.97 gate 1 $ 750 M2 $ 749.97 gate 1 $ 750

Subtotal 3 $ 2,250 Sign Installation L1 $ 49.06 sign 10 $ 491 L2 $ 49.06 sign 25 $ 1,227 L7 $ 49.06 sign 38 $ 1,864 L8 $ 49.06 sign 33 $ 1,619 L9 $ 49.06 sign 35 $ 1,717 L10 $ 49.06 sign 35 $ 1,717 L14 $ 49.06 sign 4 $ 196 M2 $ 49.06 sign 14 $ 687

Subtotal 194 $ 9,518 Subtotal Capital Costs $ 208,983

Contingency 15% of Subtotal $ 31,347 Project Management 8% of Subtotal $ 16,719

Total Capital Costs $ 257,049 Periodic Costs (every 5 yrs for 30 yrs) Legal Time $ 125 hour 128 $ 16,000 Inspection $ 2,500 event 5 $ 12,500 Fence Repair $ 23.34 linear foot 2,823 $ 65,889 Sign Repair $ 49.06 sign 10 $ 491 CERCLA 5-year Review $ 25,000 report 1 $ 25,000

Subtotal Periodic Costs $ 119,880


Contingency 15% of Subtotal $ 17,982 Project Management 5% of Subtotal $ 5,994 Total Periodic Costs $ 143,856

Net Present Worth 7% 30 years $ 567,463


Table 3-3

Cost Estimate for Excavation/Treatment Alternative SRU1 - Explosives in Soil

Description Unit Cost Unit Quantity Total Site Preparation Mobilization $ 10,000 lump sum 0 - Work Plans $ 30,000 lump sum 0 - Silt Fence $ 2.02 linear foot 0 - Site Clearance $ 154 0 acre -

Subtotal - UXO Clearance

L2 - Mechanically Screened $ 30,000 acre 8 240,000

L2 - Mag and Flagged $ 10,000 acre 30 300,000

Subtotal 38 540,000

Concrete Demolition and Disposal (includes equipment, fuel, labor, removal, transportation to disposal facility, disposal)

L1 $ 101.50 cubic yard 15 1,523

L2 $ 101.50 cubic yard 15 1,523

L7 $ 101.50 cubic yard 120 12,180

L8 $ 101.50 cubic yard 90 9,135

L9 $ 101.50 cubic yard 135 13,703

L10 $ 101.50 cubic yard 75 7,613

L14 $ 101.50 cubic yard 30 3,045

M2 $ 101.50 cubic yard 0 -

Subtotal 480 48,722

Excavation (includes equipment, fuel, labor, excavation, confirmation sampling, screening, transportation to treatment facility)

L1 203,520 $ 32.00 ton 6,360

L2 $ 32.00 ton 15,000 480,000

L7 $ 32.00 ton 1,388 44,416

L8 $ 32.00 ton 600 19,200

L9 $ 32.00 ton 1,125


36,000

L10 $ 32.00 ton 57,600 1,800

L14 ton $ 32.00 630 20,160

M2 $ 32.00 ton 2,400 76,800

Subtotal 29,303 937,696

Treatment (includes equipment, fuel, office trailer, labor, utilities, amendment, windrow maintenance and monitoring, stormwater sampling and treatment, removing compost from treatment facility)

L1 $ 73.00 ton 464,280 6,360

L2 $ 73.00 ton 15,000 1,095,000

L7 $ 73.00 ton 1,388 101,324

L8 $ 73.00 ton 600 43,800

L9 $ 73.00 ton 1,125 82,125

L10 $ 73.00 ton 1,800 131,400

L14 $ 73.00 ton 630 45,990

M2 $ 73.00 ton 2,400 175,200

Subtotal 29,303 2,139,119

Site Restoration

Transport and Spread (compost) $ 6.60 cubic yard 41,024 270,758

Backfill Excavation (with compost) $ 1.10 cubic yard 23,442 25,786

Compaction $ 1.20 cubic yard 23,442 28,130

Revegetation $ 2.35 acre 75 176

Cleanup and Demobilization $ 7,500 lump sum 1 7,500

Subtotal 332,350

Site Closeout

Final Report $ 30,000 lump sum 1 30,000

Subtotal 30,000

Miscellaneous Costs Screened Material Disposal $ 35 ton 10 350 UXO and TNT Incineration $ 1,000 ton 30


30,000

TCLP Characterization $ 550 each 80 44,000

Subtotal 74,350

Subtotal Capital Costs 4,102,237

Contingency 15% of Subtotal 615,336

Project Management 6% of Subtotal 246,134

Engineering/Design 12% of Subtotal 492,268

Construction Management 8% of Subtotal 328,179

Residual Waste Management 2% of Subtotal 82,045

Total Capital Costs 5,866,199

Periodic Costs (every month for 5 years)

TDS Stormwater Sample $ 30 sample 26 780

Metals Stormwater Sample $ 100 sample 26 2,600

Explosives Stormwater Sample $ 250 sample 26 6,500

Stormwater Sampling Labor event $ 5,000 1 5,000

Stormwater Sampling Supplies $ 250 lump sum 1 250

Stormwater Sampling Report $ 3,000 lump sum 1 3,000

Treatment Facility Maintenance $ 2,500 month 1 2,500


Contingency 0% of Subtotal $ - Project Management 0% of Subtotal $ -

Total Periodic Costs $ 20,630

Net Present Worth 7% 4 years $ 6,952,296

Net Present Worth cubic yard $ 356

Notes: Cost estimate assumes use of the existing treatment facility so no treatment facility construction will be necessary. Cost estimate assumes costs for "decommissioning" treatment facility accounted for with existing work.


Table 3-4

Cost Estimate for Excavation/Disposal Alternative SRU1 - Explosives in Soil

Description Unit Cost Unit Quantity Total Site Preparation Mobilization $ 10,000 lump sum 0 - Work Plans $ 30,000 lump sum 0 - Silt Fence $ 2.02 linear foot 0 - Site Clearance $ 154 acre 0 -


L2 - Mechanically Screened $ 30,000 acre 8 240,000


Subtotal 38 540,000


L1 $ 101.50 cubic yard 15 1,523

L2 $ 101.50 15 cubic yard 1,523

L7 $ 101.50 cubic yard 120 12,180

L8 $ 101.50 cubic yard 90 9,135

L9 $ 101.50 cubic yard 135 13,703

L10 $ 101.50 cubic yard 75 7,613

L14 $ 101.50 cubic yard 30 3,045

M2 $ 101.50 cubic yard 0 -

Subtotal 480 48,722

Excavation (includes equipment, fuel, labor, excavation, confirmation sampling)

L1 $ 32.00 ton 6,360 203,520

L2 $ 32.00 ton 15,000 480,000

L7 $ 32.00 ton 1,388 44,416

L8 $ 32.00 ton 600 19,200

L9 1,125 $ 32.00 ton 36,000

L10 $ 32.00 ton 1,800


57,600

L14 $ 32.00 20,160 ton 630

M2 $ 32.00 ton 2,400 76,800

Subtotal 29,303 937,696

Disposal

Soil Transportation and Disposal $ 20.00 ton 26,372 527,440

Hazardous Waste Transportation and Disposal $ 200.00 ton 2,930

586,000

Subtotal 29,302 1,113,440

Site Restoration

Backfill Excavation $ 1.11 cubic yard 23,442 26,021

Borrow Materials (includes delivery and spreading) $ 7.25 cubic yard 23,442

169,955




Subtotal 231,782

Site Closeout


Subtotal 30,000

Miscellaneous Costs

UXO and TNT Incineration $ 1,000 ton 30 30,000

TCLP and Soil Characterization $ 550 sample 80 44,000

Subtotal 74,000

Subtotal Capital Costs 2,975,640






Total Capital Costs 4,255,165

Periodic Costs (every month for 1 year) TDS Stormwater Sample $ 30 sample 26 780


Metals Stormwater Sample $ 100 sample 26 2,600

Explosives Stormwater Sample $ 250 sample 6,500 26

Stormwater Sampling Labor $ 5,000 event 1 5,000

Stormwater Sampling Supplies lump sum 250 $ 250 1


Treatment Facility Maintenance $ 2,500 month 2,500 1




Net Present Worth $ 4,502,725



Table 4-1

Cost Estimate for Limited Action Alternative SRU2 - Metals in Soil

Description Unit Cost Unit Quantity Total Deed Restrictions Legal Time $ 125 hour 48 $ 6,000 Survey $ 2,500 day 6 $ 15,000

Subtotal $ 21,000 Fence Installation L2 $ 23.34 linear foot 0 $ - L3 $ 23.34 linear foot 0 $ - L5 $ 23.34 linear foot 3,300 $ 77,022 L23A $ 23.34 linear foot 1,950 $ 45,513 M4 $ 23.34 linear foot 1,800 $ 42,012 M12 $ 23.34 linear foot 3,150 $ 73,521

Subtotal 10,200 $ 238,068 Gate Installation L2 $ 749.97 gate 0 $ - L3 $ 749.97 gate 0 $ - L5 $ 749.97 gate 1 $ 750 L23A $ 749.97 gate 1 $ 750 M4 $ 749.97 gate 1 $ 750 M12 $ 749.97 gate 1 $ 750

Subtotal 4 $ 3,000 Sign Installation L2 $ 49.06 sign 25 $ 1,227 L3 $ 49.06 sign 18 $ 883 L5 $ 49.06 sign 21 $ 1,030 L23A $ 49.06 sign 7 $ 343 M4 $ 49.06 sign 6 $ 294 M12 $ 49.06 sign 11 $ 540



Total Capital Costs $ 327,654 Periodic Costs (every 5 years for 30 years)

Legal Time $ 125 hour 96 $ 12,000 Inspection $ 2,500 event 5 $ 12,500 Fence Repair $ 23.34 linear foot 1,290 $ 30,109 Sign Repair $ 49.06 sign 4 $ 196 CERCLA 5-year Review $ 25,000 report 1 $ 25,000

Subtotal Periodic Costs $ 79,805 Contingency 15% of Subtotal $ 11,971

Project Management 5% of Subtotal $ 3,990 Total Periodic Costs $ 95,766



Table 4-2

Cost Estimate for Excavation/Disposal Alternative SRU2 - Metals in Soil


Subtotal - UXO Clearance L2 - Mechanically Screened $ 30,000 acre 1 30,000 L2 - Mag and Flagged $ 10,000 acre 30 300,000 L3 - Mag and Flagged $ 10,000 acre 25 250,000

Subtotal 56 580,000 Concrete Demolition and Disposal (includes equipment, fuel, labor, removal, transportation to disposal facility, disposal)

L2 $ 101.50 cubic yard 15 1,523 L3 $ 101.50 cubic yard 0 - L5 $ 101.50 cubic yard 0 - L23A $ 101.50 cubic yard 0 - M4 $ 101.50 cubic yard 0 - M12 $ 101.50 cubic yard 0 -

Subtotal 15 1,523 Excavation (includes equipment, fuel, labor, excavation, confirmation sampling)

L2 $ 32.00 ton 1,050 33,600 L3 $ 32.00 ton 450 14,400 L5 $ 32.00 ton 3,248 103,936 L23A $ 32.00 ton 4,950 158,400 M4 $ 32.00 ton 4,800 153,600 M12 $ 32.00 ton 4,800 153,600

Subtotal 19,298 617,536 Disposal Soil Transportation and Disposal $ 20.00 ton 17,368 347,360 Hazardous Waste Transportation and Disposal $ 200.00 ton 1,930 386,000

Subtotal 19,298 733,360 Site Restoration Backfill Excavation $ 1.11 cubic yard 15,438 17,136 Borrow Materials (includes delivery and spreading) $ 7.25 cubic yard 15,438 111,926

Compaction $ 1.20 cubic yard 15,438 18,526 Revegetation $ 2.35 acre 105 247 Cleanup and Demobilization $ 7,500 lump sum 1 7,500

Subtotal 155,335 Site Closeout


Final Report $ 30,000 lump sum 1 30,000 Subtotal 30,000

Miscellaneous Costs UXO Incineration $ 1,000 ton 10 10,000 TCLP and Soil Characterization $ 550 sample 138 75,900

Subtotal 85,900 Subtotal Capital Costs 2,203,654

Contingency 15% of Subtotal 330,548 Project Management 6% of Subtotal 132,219 Engineering/Design 12% of Subtotal 264,438

Construction Management 8% of Subtotal 176,292 Residual Waste Management 2% of Subtotal 44,073

Total Capital Costs 3,151,224 Periodic Costs (every month for 1 year) TDS Stormwater Sample $ 30 sample 22 660 Metals Stormwater Sample $ 100 sample 22 2,200 Stormwater Sampling Labor $ 5,000 event 1 5,000 Stormwater Sampling Supplies $ 250 lump sum 1 250 Stormwater Sampling Report $ 3,000 lump sum 1 3,000 Treatment Facility Maintenance $ 2,500 month 1 2,500

Subtotal Periodic Costs $ 13,610 Contingency 0% of Subtotal $ -

Project Management 0% of Subtotal $ - Total Periodic Costs $ 13,610

Net Present Worth $ 3,314,544



Table 5-1

Cost Estimate for Limited Action Alternative SRU3 - Explosives and Metals in Soil


Subtotal $ 3,500 Fence Installation L3 $ 23.34 linear foot $ - 0 M3 $ 23.34 linear foot 0 $ -

Subtotal 0 $ - Gate Installation L3 $ 749.97 gate 0 $ - M3 $ 749.97 gate 0 $ -

Subtotal 0 $ - Sign Installation L3 $ 49.06 sign 18 $ 883 M3 $ 49.06 sign 8 $ 392


Contingency 15% of Subtotal $ 716 Project Management 10% of Subtotal $ 478


Legal Time $ 125 hour 32 $ 4,000 Inspection $ 1,250 event 5 $ 6,250 Fence Repair $ 23.34 linear foot 390 $ 9,103 Sign Repair $ 49.06 sign 1 $ 49 CERCLA 5-year Review $ 20,000 report 1 $ 20,000





Table 5-2

Cost Estimate for Excavation/Disposal Alternative SRU3 - Explosives and Metals in Soil




Subtotal 25 250,000


L3 $ 101.50 cubic yard 0 - M3 $ 101.50 cubic yard 0 -

Subtotal 0 - Excavation (includes equipment, fuel, labor, excavation, confirmation sampling)

L3 $ 32.00 ton 450 14,400

M3 $ 32.00 ton 3,750 120,000

Subtotal 4,200 134,400

Disposal

Soil Transportation and Disposal $ 20.00 ton 3,780 75,600

Hazardous Waste Transportation and Disposal $ 200.00 ton 420

84,000

Subtotal 4,200 159,600

Site Restoration


Borrow Materials (includes delivery and placement) $ 7.25 cubic yard 3,360

24,360


Revegetation $ 2.35 134 acre 57


Subtotal 37,256

Site Closeout



Subtotal 25,000

Miscellaneous Costs

UXO and TNT Incineration $ 1,000 ton 10 10,000

TCLP and Soil Characterization $ 550 sample 47 25,850

Subtotal 35,850

Subtotal Capital Costs 642,106






Total Capital Costs 918,211

Periodic Costs (every month for 3 months)

TDS Stormwater Sample $ 30 sample 7 210 Metals Stormwater Sample $ 100 sample 7 700

Explosives Stormwater Sample $ 250 sample 7 1,750








Net Present Worth $ 942,691



Table 6-1

Cost Estimate for Limited Action Alternative SRU5 - Organics in Soil


Subtotal $ 7,000 Fence Installation L1 $ 23.34 linear foot 2,850 $ 66,519 L5 $ 23.34 linear foot 3,300 $ 77,022

Subtotal 6,150 $ 143,541 Gate Installation L1 $ 749.97 gate 1 $ 750 L5 $ 749.97 gate 1 $ 750

Subtotal 2 $ 1,500 Sign Installation L1 $ 49.06 sign 10 $ 491 L5 $ 49.06 sign 21 $ 1,030




Legal Time $ 125 hour 32 $ 4,000 Inspection $ 1,250 event 5 $ 6,250 Fence Repair $ 23.34 linear foot 450 $ 10,503 Sign Repair $ 49.06 sign 2 $ 98 CERCLA 5-year Review $ 20,000 report 1 $ 20,000



Periodic Costs (every 6 months for 20 years)

PAHs Surface Soil Sample $ 185 sample 8 $ 1,480 Soil Sampling Labor $ 1,250 event 1 $ 1,250 Soil Sampling Supplies $ 250 lump sum 1 $ 250 Soil Sampling Report $ 5,000 lump sum 1 $ 5,000


Project Management 5% of Subtotal $ 399 Total Periodic Costs $ 9,576



Table 6-2

Cost Estimate for Excavation/Treatment Alternative SRU5 - Organics in Soil


Subtotal - UXO Clearance L1 $ - acre 0 - L5 $ - acre 0 -

Subtotal 0 - Concrete Demolition and Disposal (includes equipment, fuel, labor, removal, transportation to disposal facility, disposal)

L1 $ 101.50 cubic yard 15 1,523

L5 $ 101.50 cubic yard 15 1,523

Subtotal 30 3,046


L1 $ 32.00 ton 1,913 61,216

L5 $ 32.00 ton 300 9,600

Subtotal 70,816 2,213

Treatment (includes equipment, fuel, office trailer, labor, utilities, amendment, windrow maintenance and monitoring, stormwater sampling and treatment, removing compost from treatment facility)

L1 $ 73.00 ton 1,913 139,649

L5 $ 73.00 ton 300 21,900

Subtotal 2,213 161,549

Site Restoration

Transport and Spread (compost) $ 6.60 cubic yard 3,098 20,447

Backfill Excavation (with compost) $ 1.10 cubic yard 1,770 1,947




Cleanup and Demobilization $ 5,000 1 lump sum 5,000

Subtotal 29,567

Site Closeout


Subtotal 25,000

Miscellaneous Costs Screened Material Disposal $ 35 5 ton 175

TCLP Characterization $ 550 ton 25 13,750

Subtotal 13,925









TDS Stormwater Sample $ 30 sample 9 270

PAHs Stormwater Sample $ 185 sample 9 1,665











Notes: Cost estimate assumes use of the existing treatment facility so no treatment facility construction will be necessary. Cost estimate assumes costs for "decommissioning" treatment facility accounted for with existing work.


Table 6-3

Cost Estimate for Excavation/Disposal Alternative SRU5 - Organics in Soil

Description Unit Cost Unit Quantity Total Site Preparation Mobilization $ 7,500 lump sum 0 - Work Plans $ 25,000 lump sum 0 - Silt Fence $ 2.02 linear foot 0 - Site Clearance $ 154 - acre 0

Subtotal - UXO Clearance L1 $ - acre 0 - L5 $ - acre 0 -

Subtotal 0 - Concrete Demolition and Disposal (includes equipment, fuel, labor, removal, transportation to disposal facility, disposal)

L1 $ 101.50 cubic yard 15 1,523

L5 1,523 $ 101.50 cubic yard 15

Subtotal 30 3,046


L1 61,216 $ 32.00 ton 1,913

L5 $ 32.00 ton 300 9,600

Subtotal 2,213 70,816

Disposal

Soil Transportation and Disposal ton $ 20.00 2,213 44,260

Subtotal 2,213 44,260

Site Restoration


Borrow Materials (includes delivery and placement) $ 7.25 cubic yard 1,770

12,833




Subtotal 21,971


Site Closeout


Subtotal 25,000

Miscellaneous Costs

TCLP and Soil Characterization sample $ 550 69 37,950

Subtotal 37,950









TDS Stormwater Sample 270 $ 30 sample 9

PAHs Stormwater Sample 1,665 $ 185 sample 9











D E P T . O F V E T E R N AFFAIRS NATIONAL USDALAP AREA USDAMFO AREA

N S T A T E OF ILLINOIS INDUSTRIBL PARK WILL COUNTY LANDFILL

FIGURE I

JQLlgT ARMY AblMUNITION PLANT WILL C O U N N , ILLINOIS

JANUARY 22,2004 PREPARED FOR

DEPARTMENT OF tne ARMY PREPARED BY

U,S. ARMY CORPS OF ENQINECRS LOUISVILLE, KY

Entire &a Will B e Pre-Sampled

Figure 3

Site L1

J#IBTARMYAMMUBJIION P U T WILL COUNTY, ILLINOIS

OCTOr l R 1% 2003 PREPARED FOR

DEPARTMENT OF THE ARMY P R I M R I D BY'

Y.5. ARMYCORPS OF EMblNEERS < .

L~UISWILLS m

Figure 4

Site 12

J#IBTARRWILMMUBIIION P U T WILL COUNTY, ILLINOIS

o e t o r m 14 2003 PRCPARPD FOR

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U.5. ARMY CORPS OF ENblNEERf. < .

L ~ U I S ~ I L L S m

Figure 5

Site 17

DLIETARHYIUIMUNCTIO# P U T WIL L COUNTY, iLLINOIO

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LI ARMY C O W S O f EMelNEERS . . L ~ U K ~ I L L S m

Figure 7

Site L9

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OCTOE EA I 4 ZOO3 PREPARED FOR

DEPARTMENT OF mr; arrw PREPARED W

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Figure 8

Site L10

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o e t o r m 14 2003 PRCPARPD FOR

DEPARTMENT OF THE ARMY P I W A R I D BY'

1.5. ARMY CORPS OF ENGINEERS L ~ U I S ~ I L L S m

Figure 9

Site L14

AS t i Pillow To Be moved -- And Disposed ?{f ,4t Y

Will County La df~l l T

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Figure 10

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JOLlET ARMY AMMUNCTION PLANT WILL COUNTY, ILLINOIS

OCTOI I R 1% 2003 PREPARED FOR

DEPARTMENT OF THE ARMY PREPARED B Y

U.S. ARMY CORPS OF ENGINEERS < . . . . r o u ~ s v ~ r r ~ m

Figure 11

Site L3

WILL COUNTY, ILLINOIS octorm -14 t003

PREPARED FOR DEPARTMENT OF THE ARMY

P R l P i R l D B Y U.S. ARMY C O W S OF E M l N B R S . .

L~UIWILLS m

Figure 12

Site L5

J#IET'ARMYILMMUMIION PLANT WIL L COUNTY, ILLINOIS

octorm qq t003 PREPARED FOR

DEPARTMENT OF THE ARMY P R l P i R l D B Y

at ARMY C O W S OF EMGlNEERf . . roulsvl~rq m

Figure 13

She L23

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. . - . ... . . .

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l e bu - 8k KG ka01R6

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STATE OF ILLINOIS IWDUSTRRL PARK W I L L C O U N T Y LANDFILL

I Figure 14

r JOLlET ARMY AMMUNllOW PLANT WILL QOUNTY, ILLINOIS

oOTo@ER 14,2003 PREPARIO FOR

BIWRTMINT OF T H l ARMY e m e u c n BY

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LOUISWLL~ m

SRU-2 %it§ TO 'B' Exc~&ed' And %onfirmed For Lead. A entage 0f.Cmfirms.d Samples f3e TCLP Fa Lead To' Ensure

ardous Material ere Left In ace After Pmyx!iiel ? , ... Actions. . .

Selected Samples Will Atso Re Analyzed Far Swtfate To Ensure

IAC ARARS Are Being Met.

A

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rtartar.rbp DEPT.OF VETERAN AFFAIRS N A T D H A L

STATE OF ILLINOIS INDUSTRRL PARK WILLCOUNTY LANDFILL

Figure 15

Site MI2

JOLIET ARMY AMMUNITION PLANT WILL LOUNTY, ILLINOIS

OCTOI ER 14, 2DO3 PREPaREP FOR

DEPARTMENT OF THE ARMY PREPARED B Y

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Figure 16

Site M3

JOLIITARHYILMMUNCTION P U T WILL COUNTY, ILLINOIS

o c t o r m 14 2003 PRCPARPD FOR

DEPARTMENT OF THE ARMY P R I M R I D B Y '

U.5. ARMY CORPS OF EN6lNEERf < . . . .

L~UISWILLS m

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