RECORD OF DECISION (RODS)Sep 18, 2006 · PETN Pentaerythritol tetranitrate QAP Quality Assurance...

EPA/ROD/R20060400014762006

EPA Superfund

Record of Decision:

ANNISTON ARMY DEPOT (SOUTHEAST INDUSTRIAL AREA) EPA ID: AL3210020027 OU 03ANNISTON, AL09/18/2006

FINAL RECORD OF DECISION

FOR

AMMUNITION STORAGE AREA ANNISTON ARMY DEPOT

ANNISTON ARMY DEPOT ANNISTON, ALABAMA

July 2006

Table of Contents

TABLE OF CONTENTS

1.0 THE DECLARATION 1-1 1.1 Site Name and Location 1-1 1.2 Statement of Basis and Purpose 1-1 1.3 Assessment of the Site 1-1 1.4 Description of Selected Remedies 1-1 1.5 Statutory Determinations 1-3 1.6 Data Certification Checklist 1-3 1.7 Authorizing Signatures 1-4

2.0 THE DECISION SUMMARY 2-1 2.1 Site Name, Location, and Brief Description 2-1 2.2 Site History and Enforcement Activities 2-1 2.3 Community Participation 2-2 2.4 Scope and Role of Operable Unit or Response Action 2-3 2.5 Site Characteristics 2-3

2.5.1 Environmental Setting 2-12 2.5.2 Nature and Extent of Contamination 2-12 2.5.3 Risk Assessment Conceptual Site Model 2-13

2.6 Current and Potential Future Land and Resource Uses 2-132.7 Summary of Site Risks 2-16

2.7.1 Summary of Human Health Risk Assessment 2-16 2.7.2 Summary of Ecological Risk Assessment 2-24 2.7.3 Basis for Action 2-31

2.8 Remedial Action Objectives 2-31 2.9 Description of Alternatives 2-32

2.9.1 Description of Remedy Alternatives and Components 2-31 2.9.2 Expected Outcomes of Each Alternative 2-36

2.10 Comparative Analysis of Alternatives 2-36 2.10.1 Overall Protection of Human Health and the Environment 2-38 2.10.2 Compliance with ARARs 2-38 2.10.3 Long-term Effectiveness and Permanence 2-44 2.10.4 Reduction of Toxicity, Mobility. and Volume Through Treatment 2-44 2.10.5 Short-Term Effectiveness 2-45 2.10.6 Implementability 2-46 2.10.7 Cost 2-46 2.10.8 State Acceptance 2-47 2.10.9 Community Acceptance 2-48

2.11 Principal Threat Wastes 2-48 2.12 Selected Remedy 2-48

2.12.1 Summary of Rationale for the Selected Remedy 2-48 2.12.2 Description of the Selected Remedy 2-48 2.12.3 Cost Estimate for the Selected Remedy 2-49 2.12.4 Estimated Outcome for the Selected Remedy 2-56

2.13 Statutory Determinations 2-57 2.13.1 Protection of Human Health and the Environment 2-57 2.13.2 Compliance with ARARs 2-57 2.13.3 Other Criteria, Advisories, or TBC Guidance for this Remedial Action 2-62 2.13.4 Cost- Effectiveness 2-62 2.13.5 Utilization of Permanent Solutions 2-62 2.13.6 Preference for Treatment as a Principal Element 2-62 2.13.7 Five- Year Review Requirements 2-63

Record of Decision Final i July 2006Anniston Army Depot

Table of Contents

2.14 Documentation of Significant Changes from Preferred Alternative of Proposed Plan 2-63

3.0 THE RESPONSIVENESS SUMMARY 3-1

4.0 REFERENCES 4-1

APPENDIX A SELECTION OF EXPOSURE PATHWAYS A-1

APPENDIX B DETAILED COSTS B-1

LIST OF FIGURES

Figure 2-1 Location of Anniston Army Depot 2-4 Figure 2-2 Location of SWMUs Within the ANAD ASA 2-5Figure 2-3 Conceptual Site Model for Human Receptors 2-14Figure 2-4 Conceptual Site Model for Ecological Receptors 2-15 Figure 2-5 Areas Exceeding the Recommended Lead Cleanup Level (1,350 mg/kg) at

SWMU 35 (Deactivation Furnace) 2-34Figure 2-6 SWMU 5 (Sinkhole) Limits of Site Boundaries for Land Use Controls 2-50Figure 2-7 SWMU 8 (Acid Disposal Pit) Limits of Site Boundaries for Land Use Controls 2-51Figure 2-8 SWMU 10/11 (TNT Washout Facility) Limits of Site Boundaries for Land Use

Controls 2-52Figure 2-9 SWMU 27 (South TNT Burial Pit) Limits of Site Boundaries for Land Use

Controls 2-53Figure 2-10 SWMU 35 (Deactivation Furnace) Limits of Site Boundaries for Land Use

Controls 2-54

LIST OF TABLES

Table 1-1 Remedies for the ASA SWMUs Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama 1-2

Table 1-2 Data Certification Checklist Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama 1-3

Table 2-1 Nature and Extent of Contamination and the Chemicals of Concern (COCs) at Six ASA SWMUs Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama 2-6

Table 2-2 Chemicals of Concern and Exposure Point Concentrations in Soil 2-17Table 2-3 Chemicals of Concern and Exposure Point Concentrations in Groundwater 2-17Table 2-4 Exposure Assumptions for the Human Health Risk Assessment 2-20Table 2-5 Toxicity Values for Evaluation of Ingestion and Inhalation Pathways:

Noncancer Effects 2-22Table 2-6 Toxicity Values for Evaluation of Ingestion and Inhalation Pathways:

Carcinogenic Effects 2-23Table 2-7 Risk Characterization Summary for Residential Land Use Chemicals of

Concern in Groundwater at SWMU 5 2-25Table 2-8 Risk Characterization Summary for Residential Land Use Chemicals of


Concern in Groundwater at SWMU 10 2-26 Table 2-10 Risk Characterization Summary for Residential Land Use Chemicals of


Concern in Groundwater at SWMU 27 2-28

Record of Decision Final ii July 2006Anniston Army Depot

Table of Contents

Table 2-12 Risk Characterization Summary for Residential Land Use Chemicals of Concern in Groundwater at SWMU 35 2-29

Table 2-13 Risk Characterization Summary for Industrial Land Use Chemical of Concern in Soil SWMU 35 2-29

Table 2-14 Media Areas and Volumes Exceeding Cleanup Levels, Anniston Army Depot,Ammunition Storage Area, Anniston, Alabama 2-33

Table 2-15 Key Technologies in Final Alternatives Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama 2-33

Table 2-16 EPA Evaluation Criteria Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama 2-37

Table 2-17 Comparative Analysis of Remedial Alternatives for Soil Anniston Army Depot,Ammunition Storage Area, Anniston, Alabama 2-39

Table 2-18 Comparative Analysis of Remedial Alternatives for Groundwater Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama 2-41

Table 2-19 Comparison of Capital and O& M Costs for the Final Soil Alternatives Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama 2-47

Table 2-20 Comparison of Capital and O& M Costs for the Final Groundwater Alternatives Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama 2-47

Table 2-21 Land-Use Control Performance Objectives for the Selected Remedies Anniston Army Depot, Ammunition Storage area, Anniston, Alabama 2-55

Table 2-22 Expected Outcomes for the Selected Remedy Anniston Army Depot Ammunition Storage Area, Anniston, Alabama 2-56

Table 2-23 Recommended Cleanup Level for Lead in Soil Anniston Army Depot Ammunition Storage Area, Anniston, Alabama 2-57

Table 2-24 Recommended Groundwater Monitoring Benchmarks Anniston Army Depot,Ammunition Storage Area, Anniston, Alabama 2-58

Table 2-25 ARARs and TBC Guidance for Remediation of SWMU 35 Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama 2-59

Table 2-26 Action-Specific ARARs and TBC Guidance for Remediation of the GroundwaterAnniston Army Depot, Ammunition Storage Area, Anniston, Alabama 2-61

Table A-1 Selection of Exposure Pathways, Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama A-1

Table B-1 Soil Alternative 3 - SWMU 35 Costs, Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama B-1

Table B-2 Summary of Discounted and Non- Discounted Costs for Alternative 3 - Monitored Natural Attenuation ( New & Existing Well Network) and Land Use Controls Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama B-4

Record of Decision Final iii July 2006Anniston Army Depot

Acronyms and Abbreviations

ACRONYMS AND ABBREVIATIONS

AL AlabamaADEM Alabama Department of Environmental ManagementANAD Anniston Army DepotARAR applicable or relevant and appropriate requirement ASA Ammunition Storage AreaASTM American Society for Testing and Materials(AWWSB) Anniston Water Works and Sewer BoardBEHP bis(2-ethy1hexy) phthalate BERA Baseline Ecological Risk AssessmentBTEX benzene, toluene, ethylbenzene, and xylenesCDC Centers for Disease Control CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 CFR Code of Federal RegulationsCOC chemical of concern COPC chemical of potential concernCSF cancer slope factorCSM conceptual site model CTE Central Tendency ExposureCY cubic yard1, l-DCE 1, 1-dichloroethene1,2-DCE 1,2-dichloroethene DERA Defense Environmental Restoration Account DQO Data Quality ObjectiveEPA U.S. Environmental Protection AgencyEPC exposure point concentration ERA ecological risk assessment ESE Environmental Science and Engineering, Inc. FFA Federal Facilities AgreementFR Federal RegisterFS Feasibility Study Ft FootHEAST Health Effects Assessment Summary TablesHI hazard indexHHRGO human health remedial goal optionHQ hazard quotient Hr HourID IdentificationIDW investigation-derived wasteIRIS Integrated Risk Information SystemKg KilogramL/d liters per dayLF linear foot LS lump sumLUC Land Use Control MCL Maximum contaminant level mg/kg milligrams per kilogram MNA Monitored natural attenuation NA not applicableNA/NFA No Action/No Further ActionNCEA National Center for Environmental Assessment NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List

Record of Decision Final iii July 2006Anniston Army Depot

Acronyms and Abbreviations

O&M Operation and maintenance ORD Office of Research and DevelopmentOSWER Office of Solid Waste and Emergency ResponseOU operable unit PA/SI Preliminary Assessment/Site InvestigationPETN Pentaerythritol tetranitrate QAP Quality Assurance Plan QC Quality Control RAGS Risk Assessment Guidance for SuperfundRAWP Remedial Action Work PlanRCRA Resource Conservation and Recovery Act of 1976RDX Royal demolition explosive, cyclo-l, 3,5-trimethylene-2,4,6-trinitramineRfC Reference concentration RfD Reference dose RGO remedial goal optionRI Remedial InvestigationRME Reasonable Maximum ExposureROD Record of Decision RT Round TripSAIC Science Applications International CorporationSAP Sampling and Analysis Plan SARA Superfund Amendments and Reauthorization Act of 1986SIA Southeast Industrial AreaSOP Standard Operating ProcedureSVOC semivolatile organic compoundSY square yardSWMU solid waste management unit TBC to be considered TNT 2,4,6-trinitrolueneUCL upper confidence limitµg/dL microgram per deciliterµg/L microgram per literUSACE U.S. Army Corps of EngineersUS ATHAMA U.S. Army Toxic and Hazardous Materials Agency USC United States Code VOC volatile organic compoundYr Year

Record of Decision Final iv July 2006Anniston Army Depot

Final Record of Decision

Final Record of Decision for

Ammunition Storage Area Anniston Army Depot

Anniston, Alabama

This Draft Record of Decision (ROD) documents the selected remedial alternatives for cleaning upcontaminated soil and groundwater at Anniston Army Depot's (ANAD'S) Ammunition Storage Area(ASA), Anniston, Alabama. Section 1.0 summarizes key information regarding this ROD. The DecisionSummary (Section 2.0) details the site, alternatives evaluated, Selected Remedies, and associatedcleanup levels for the chemicals of concern. This section also explains how the Selected Remedies fulfillstatutory and regulatory requirements. The third component of this ROD (Section 3.0) summarizesinformation about the views of the public and regulatory agencies regarding the remedial alternativesand general concerns about the site. References cited in this document are provided in Section 4.0.Appendix A includes the Selection of Exposure Pathways and Appendix B includes the detailed costsfor the Selected Remedies.

Record of Decision Final v July 2006Anniston Army Depot

The Declaration

1.0 THE DECLARATION

In this section, key information regarding this Draft Record of Decision (ROD) is provided, includingthe authorizing signatures for its implementation.

1.1 Site Name and Location

Anniston Army Depot (ANAD) is an active military facility located in northeastern Alabama in CalhounCounty. The majority of ANAD operations occur in the Ammunition Storage Area (ASA), whichoccupies approximately 13,000 acres and the Southeast Industrial Area (SIA), which occupiesapproximately 525 acres on the 15,200- acre installation.

Environmental restoration activities at ANAD are being conducted in accordance with a FederalFacilities Agreement (FFA), signed in 1990 (ANAD 1990). The FFA, a three-party agreement betweenANAD, the U.S. Environmental Protection Agency (EPA) Region 4, and the Alabama Department ofEnvironmental Management (ADEM), establishes the requirements and procedural framework forresponse actions at the non- National Priorities List (NPL) ASA and the NPL SIA. Environmentalresponse actions within the SIA are being addressed in separate documents. Areas within the ASAwhere soil and groundwater media have been impacted by historic site operations, and where potentialrisks are present, as well as those that require no further action, are the subjects of this ROD. Overall,the ANAD has been subdivided into Operable Units (OU) consisting of the Southeast Industrial Area(SIA) Groundwater (OU I), the SIA Soils (OU 2), all media at the ASA (OU 3), the Military MunitionsResponse Program (OU 4) and the Western Industrial Area ( OU 5). This ROD addresses the ASA (OU3).

1.2 Statement of Basis and Purpose

This ROD presents the Selected Remedies for OU 3, the ASA soil and groundwater, which were chosenby the EPA and the Army in accordance with Comprehensive Environmental Response, Compensation,and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and ReauthorizationAct of 1986 (SARA), and to the extent practicable, the National Oil and Hazardous Substances PollutionContingency Plan (NCP). This decision is based on the Administrative Record file for this OU. ADEMconcurs with the Selected Remedies. The ANAD anticipates that this will be the final decision for thisOU.

1.3 Assessment of the Site

The response action selected in this ROD is necessary to protect the public health, welfare, or theenvironment from actual or threatened releases of hazardous substances, pollutants or contaminants fromthe ASA, which may present an imminent and substantial endangerment to public health or welfare.

1.4 Description of Selected Remedies

This ROD has been prepared for the nine ASA Solid Waste Management Units (SWMUs) within theASA, including SWMU 5 (Sinkhole), SWMU 8 (Acid Disposal Pit), SWMU 10 (TNT WashoutFacility), SMWU 11 (TNT Washout Facility Leaching Beds), SMWU 14 (Laundry Waste LeachingFacility), SMWU 15 (Propellant Disposal Facility), SWMU 26 (North TNT Burial Pit), SWMU 27

Record of Decision Final 1-1 July 2006Anniston Army Depot

The Declaration

(South TNT Burial Pit), and SWMU35 (Deactivation Furnace), assessed as part of the RemedialInvestigation/Feasibility Study (RI/FS)[Science Applications International Corporation (SAIC) 2001and 20021. Potential risks were identified for exposure to soil at the Deactivation Furnace (SWMU 35)and groundwater at six SWMUs: SWMU 5 (Sinkhole), SWMU 8 (Acid Disposal Pit), SWMU 10 (TNTWashout Facility), SWMU 11 (TNT Washout Facility Leaching Beds), SWMU 27 (South TNT SouthBurial Pit) and SWMU 35 (Deactivation Furnace). No potential risks were identified for two of the ASASWMUs, SWMUs 14 and 15, and as a result, no further action/no action is being taken. For additionaldetails refer to the Remedial Investigation Report (SAX 2001). The selected remedy for soil consistsof delineation sampling, excavation, confirmation sampling, characterization sampling, offsite treatment,disposal and land use controls (LUCs). The selected remedy for groundwater consists of monitorednatural attenuation (MNA) utilizing an expanded monitoring well network and LUCs. As Table 1-1indicates, the Selected Remedies include remedial actions for each of the impacted media or no furtheraction.

Table 1-1 Remedies for the ASA SWMUs Anniston Army Depot Ammunition Storage Area, Anniston,

Alabama Media SWMU Selected Remedy

Soil SWMU 5 (Sinkhole) SWMU 8 (Acid Disposal Pit) SWMU 10 (TNT Washout Facility) SWMU 11 (TNT Washout Facility Leaching Beds) SWMU 14 (Laundry Waste Leaching Facility) SWMU 15 (Propellant Disposal Facility) SWMU 26 (North TNT Burial Pit) SWMU 27 (South TNT Burial Pit) SWMU 35 (Deactivation Furnace)

NFA/NANFA/NANFA/NANFA/NANFA/NANFA/NANFA/NANFA/NACharacterization sampling, excavation,confirmation sampling, off-site disposal,and Land Use Controls (LUCs) (e. g.,ANAD LUC Standard OperatingProcedure [SOP])

Groundwater SWMU 5 (Sinkhole)

SWMU 8 (Acid Disposal Pit) SWMU 10 (TNT Washout Facility) SWMU 11 (TNT Washout Facility Leaching Beds) SWMU 14 (Laundry Waste Leaching Facility) SWMU 15 (Propellant Disposal Facility) SWMU 26 (North TNT Burial Pit) SWMU 27 (South TNT Burial Pit) SWMU 35 (Deactivation Furnace)

Monitored natural attenuation (MNA) andLUCs (ANAD LUC SOP) MNA and LUCs (ANAD LUC SOP) MNA and LUCs (ANAD LUC SOP) MNA and LUCs (ANAD LUC SOP) NFA/NANFA/NANFA/NAMNA and LUCs (ANAD LUC SOP) MNA and LUCs (ANAD LUC SOP)

Surface Water SWMU 5 (Sinkhole) NFA/NA

Sediment SWMU 5 (Sinkhole) NFA/NANFA/NA= No Further Action/No Action TNT = 2,4,6-trinitroluene.


The Declaration

1.5 Statutory Determinations

The Selected Remedies are protective of human health and the environment; comply with federal andstate of Alabama requirements that are applicable, relevant, and appropriate to the remedial actions; arecost-effective; and utilize permanent solutions and alternative treatment and resource recoverytechnologies to the maximum extent practicable. In addition, the Selected Remedy for soil satisfies thestatutory preference for treatment as a principal element of the remedy (i.e., reduces the toxicity,mobility, or volume of hazardous substances, pollutants, or contaminants as a principal element throughtreatment). The Selected Remedies for the ASA soil and groundwater, were chosen in accordance withCERCLA, as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), andto the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

These remedies will result in hazardous substances and contaminants remaining on-site above levels thatallow for unlimited use and unrestricted exposure. LUCs, which will be the key measure to control siteaccess and use, will be defined in remedial design documentation. Consequently, statutory reviews willbe conducted at a frequency of no less than every 5 years after initiation of remedial action to examinethe selected remedies, correct any deficiencies and ensure that the remedies are protective of humanhealth and the environment. Statutory reviews will be conducted at the prescribed intervals until suchtime that the LUCs can be removed and land use is unrestricted.

1.6 Data Certification Checklist

A data certification checklist is provided in Table 1-2. This checklist certifies that the ROD containsspecific remedy selection information. References to page numbers where the information can be foundin the body of this document also are indicated.

Table 1-2. Data Certification Checklist Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

InformationInformation

in ROD ROD Section (Page Number)

Chemicals of Concern T Section 2.5.2 (Page 2-12), Table 2-2(Page 2-17), Table 2-3 (Page 2-17),and Section 2.7.1 (Page 2-16)

Baseline Risk T Section 2.7 (Page 2-16)

Cleanup Levels T Section 2.12.4 (Page 2-56), Table 2-23(Page 2-57), and Table 2-24 (Page2-58)

Source Materials T Section 2.11 (Page 2-48)

Current and Future Land and Groundwater Use T Section 2.6 (Page 2-13)

Land and Groundwater use with Remedy T Section 2.12.4 (Page 2-56)

Capital, Operation and Maintenance, PresentWorth Costs, Discount Rate, and Years

T Section 2.10.7 (Page 2-46)

Factors Influencing Remedy Selection T Section 2.12.1 (Page 2-48) ROD = Record of Decision.


The Declaration

1.7 Authorizing Signatures


The Decision Summary

2.0 THE DECISION SUMMARY

In this section, the details of the site, the alternatives evaluated, the Selected Remedies, and theassociated remedial action cleanup levels for the chemicals of concern (COCs) are provided. Thissection also explains how the Selected Remedies fulfill statutory and regulatory requirements.

2.1 Site Name, Location, and Brief Description

The Anniston Army Depot is located in northeastern Alabama in the southwestern section of CalhounCounty. ANAD is 110 miles west of Atlanta, Georgia; 50 miles east of Birmingham, Alabama; 100miles north of Montgomery, Alabama; and 25 miles south of Gadsden, Alabama. The town of Eulatonis less than 2 miles directly east of ANAD. The city of Anniston is located 10 miles east of ANAD andis surrounded by the suburban areas of Westend-Cobb Town, Blue Mountain, Oxford, and Hobson City.The CERCLIS ID number for the ANAD is AL3210020027. The 13,000-acre ASA containsapproximately 1,300 ammunition storage magazines with an ammunition maintenance workshopcomplex located in the center of the ASA. This complex consists of the operating buildings required formaintenance, demilitarization, and inspection of all types of ammunition and ammunition components.Also located within this service and storage area are the former Lance Missile Fueling Facility andammunition disposal areas. Chemical contamination of soil and groundwater in the ASA are the resultof former operations and related disposal practices at some of these waste units.

The U.S. Army is the lead agency responsible for the remedial action for the ASA and the ANAD is theactivity located at this facility. The lead regulatory agency is EPA Region 4 and the supportingregulatory agency is ADEM. The DoD Defense Environmental Restoration Account (DERA) is thesource of related cleanup monies for OU 3; other OUs may derive cleanup funding from other sources.

2.2 Site History and Enforcement Activities

The storage, maintenance, and industrial functions of ANAD historically have resulted in the generationof hazardous wastes. Typical waste-generating processes at ANAD have included vapor degreasing,metal cleaning, sandblasting, electroplating, and painting. Generated solid and liquid wastes haveincluded metals, cyanide, phenols, pesticides, herbicides, chlorinated hydrocarbons, petroleumhydrocarbons, solvents, acids, alkali chelating agents, asbestos, and creosote. Wastes generated atANAD were disposed on post in trenches, lagoons, landfills, or other holding vessels from the 1940sthrough the late 1970s. The majority of the waste generated and disposed has occurred within the SIA.

In 1986 and 1987, NUS Corporation (NUS) conducted a RCRA Facility Assessment (RFA) on behalfof the EPA to evaluate releases of hazardous waste or hazardous constituents (NUS 1987). Theassessment involved a records search and site inspection (sampling was not conducted) and resulted inthe identification of 38 current or former areas that managed hazardous or solid wastes. Using RCRAterminology, these 38 areas were identified as SWMUS.1 The RFA characterized the SWMUs, evaluatedeach for its potential to release hazardous waste constituents to the environment, and determined theneed for further investigation. Each SWMU was evaluated in terms of site description, physicalconstruction, waste characteristics, waste management practices, migration pathways, and evidence ofrelease. For SWMUs within the ASA, NUS recommended no further action at six SWMUs (SWMUs________________________1 Although many of the ASA SWMUs investigated in the RI were evaluated in the RFA, the SWMU numbers have

been changed and do not correspond to the SWMU numbers listed in the RFA report. Table 1-1 lists the SWMUsincluded in this ROD.



5, 14, 18, 26, 27, and 37), a sampling investigation at two SWMUs (SWMUs 10 and 15), and an RI atSWMU 11.

In 1989, ESE prepared an RI Report (ESE 1989) presenting a comprehensive overview of thecontaminant remediation activities for all of ANAD, including the ASA. Information compiled includeda summary of generated wastes, SWMU descriptions, soil boring data, and a history of groundwaterchemistry data for the SIA. The RI evaluated offsite impacts as well as impacts within ANAD, andincluded a summary of preliminary results of off-depot investigations and an off-depot endangermentassessment.

In 1993, Jacobs Engineering Group, Inc. (JEG) conducted an Expanded Site Inspection (ESI) todetermine whether there was sufficient evidence of release at any SWMU to require additionalinvestigation (JEG 1993). The objective of the ESI was to narrow data gaps and facilitate remedialplanning. The ESI focused on 15 SWMUs within the ASA. ESI tasks included record searches, fieldinvestigations, laboratory analysis, data interpretation, and presentation of findings. Field activitiesincluded soil boring and well installation; geophysical surveys; and sampling of soil, sediment,groundwater, and surface water for chemical analysis.

Background samples were not designated during the ESI planning; however, samples that appeared tobe free of site-related contaminants were designated "background" after the field investigation. Basedon the history of the SWMUs and results of the sampling, the ESI concluded that contamination fromvolatile organic compounds (VOCs) and semivolatile organic compounds (SVOCs) is not a problem atthe ASA. Metals (arsenic, beryllium, cadmium, chromium, lead, mercury, nickel, silver, vanadium, andzinc), explosives, nitrate/nitrite, petroleum hydrocarbons (as total petroleum hydrocarbons [TPH]), andtotal organic carbon (TOC) were detected above background concentrations. Based on the results of theESI, an RI/FS (SAIC 2001 and 2002) was required at 11 SWMUs (SWMUs5,8,10,11,14,15,18,26,27,35, and 37), and no further action was required at 4 SWMUs ( SWMUs 16,17, 34, and 36) under CERCLA. RCRA Corrective Action will be required in the future at SWMUs 16and 17 as a requirement of the pending RCRA Subpart X permit for those SWMUs.

The recommendations forthcoming from this latter study are the basis for the Proposed Plan (ANAD2002) and this ROD.

Environmental restoration activities within the OUs must comply with the CERCLA requirements andprocedures in accordance with the FFA. No enforcement activities have been undertaken at the ANAD.

2.3 Community Participation

The Proposed Plan for the ANAD ASA was made available to the public in April 2002. This plan andrelated documents are located in the Administrative Record file and at the following location:

Anniston Main Library 108 East 10th Street Anniston, AL 36201- 5662 Monday through Friday: 9 a.m. to 6:30 p. m. Saturday: 9 a.m. to 5 p.m. Sunday: 1 p.m. to 5 p.m.



The notice of availability of these documents was published in the Anniston Star on April 12,2002, anda public comment period was held from April 15 to May 15,2002. In addition, a public meeting andposter session was held on May 6, 2002, at the Anniston City Meeting Center to present the ProposedPlan to a broader community audience than had been involved already at the site. At this meeting,representatives from ANAD, EPA, and ADEM answered questions regarding problems at the site andthe remedial alternatives. This meeting also solicited a wider cross-section of community input on thereasonably anticipated future land use and potential beneficial groundwater uses at the site. The responseto the comments received during this period is included in the Responsiveness Summary of this ROD(Section 3.0).

After the ASA Proposed Plan (PP) was published and made available for public comment, SWMUs 18and 37, originally investigated in the ASA RI and presented in the PP, were removed from OU 3. Thischange reflects the designation of two new OUs ( see discussion in Section 2.4), the Military MunitionsResponse Program (OU 4) and Western Industrial Area (OU 5). Due to the geographic location ofSWMUs 18 and 37 they were incorporated into the Western Industrial Area and as a result, SWMUs18 and 37 are not included in this ROD but will be included in the ROD for OU 5.

2.4 Scope and Role of Operable Unit or Response Action

As with many Superfund sites, the concerns at the ANAD are complex and require a strategy to addresseach critical issue in terms of the scope and planned sequence of actions. At the ASA, the responseaction addresses specific site problems that involve different media (i.e., soil and groundwater) and arelocated in different parts of the ASA.

The entire ASA is designated as an operable unit (OU). All media are addressed under this responseaction at the ASA. The Proposed Plan addressing the ASA was released in April 2002. This RODfocuses on the response strategy for soil and groundwater impacted by site operations. Since that timetwo additional OUs have been identified. Two SWMUs (18 and 37) formerly in the ASA OU are nowincluded in OU 5. SWMUs 18 and 37 were grouped into OU 5 due to their location in the WesternIndustrial Area.

For the ANAD, the response strategy is being implemented based on OUs, which have been defined toaddress five distinct ANAD contamination problems:

‚ OU 1- SIA groundwater, ‚ OU 2- SIA Soil, sediment, and surface water, ‚ OU 3- ASA, all media, ‚ OU 4- Military Munitions Response Program, and ‚ OU 5- Western Industrial Area, all media.

The ASA comprises OU 3 at ANAD and this ROD presents the final decision for the cleanup of OU 3.

2.5 Site Characteristics

This section presents an overview of the ASA sites, including the environmental setting (Section 2.5.1)and nature and extent of contamination (Section 2.5.2). The site conditions are also depicted as aconceptual site model (CSM), which provides the framework for assessing risks to potential receptors(Section 2.5.3). A brief description of each of the nine ASA SWMUs is provided in Table 2-1. The


Table 2-1. Nature and Extent of Contamination and the Chemicals of Concern (COCs) at ASA SWMUs Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

depression or "sinkholen (approximately 150 R across and 25 R deep). Partially water filled with visible and submerged debris.

Wastes, including construction debris, empty ammunition containers, railroad ties, and empty containers, disposed of from 1942 to 1978.

Drums and other large debris removed from Sinkhole in 1978.

Groundwater exists within the residuum on site and flow is generally to WSW. Deeper aquifer on site is within karst in the bedrock

and sediment samples around sinkhole and sediments from within sinkhole. Sampled for metals, VOCs, SVOCs, PestlPCBs in surface and subsurface soils.

Groundwater - Installation of three wells encompassing sinkhole plus monitoring of two pre -existing wells northwest and east of sinkhole. Sampled for metals, VOCs, SVOCs, Pest.lPCBs.

SVOCs were present in surface soil samples.

Sediment has trace concentrations of organics (1 ,2-DCE and TCE) and inorganics above background levels (e.g., hexavalent chromium, copper, manganese, thallium, lead, and zinc); however the human health risks were within NCP thresholds.

Numerous metals detected in groundwater above background values as well as low concentrations of organics (1,l-DCE, benzene, TCE, and BEHP) that contribute to carcinogenic and noncarcinogenic risks via groundwater consumption.

formation. s * J

Former acid pit (-7,000 sf) used to I Soil - Initial soil gas survey for I Numerous metals (primarily lead and dispose paint stripper, alkalies, cadmium, phosphoric acid, and stripping paint. Wastes possibly containerized.

After waste disposal operations were discontinued, the concrete pit that had previously been used for cleaning metal parts was filled with

VOCs over entire site on 254 grid spacing and a follow up geophysical survey to locate pit. Collected soils from varying depths from seven soil borings. Sampled for metals, VOCs, SVOCs, PestlPCBs in surface and subsurface soils.

silver) detected above background levels in soil throughout the site. SVOC and VOCs were detected at low levels in surface and subsurface soil. Both the number and concentrations of VOCs were greater in subsurface soil. Future risk based upon resident child exposure to manganese at 9 ft below ground in RI is not viable pathway.

Soil: None I All Media:b

Sediment: None

Groundwater: Arsenic Iron Lead Manganese 1 ,I -DCE BEHP

Surface water: None

Soil: None

Sediment: Not Applicable Groundwater: Arsenic Iron Manganese 1,4-

None

All Media?

None

Table 2-1. Nature and Extent of Contamination and the Chemicals of Concern (COCs) at ASA SWMUs

sand. Information regarding unit construction and waste management operations at SWMU 8 is limited.

Groundwater on site exists within the residuum and flows toward SE at a significant gradient because of

This site (0.5 acres) includes Building 172 and a wastewater sedimentation tank.

Site is adjacent to SWMU 11 (see below), the leaching beds for the facility.

Explosives washout wastewater was discharged from Building 172 to the tank.

Groundwater exists on site within the residuum and also within the bedrock. In general, the groundwater Rows toward the NE on site.

Anniston Army Depot, Ammunition Storage Area, Anniston, ~labama

monitoring wells triangulated on anomalies noted in geophysical investgation.

SoiVsediment - Collection of seven soil samples in lose spatial pattern around sedimentation tank and Buildings 172 and 191. Sediment samples were collected from drainage swale north of sedimentation pit. Investigated for metals, VOCs, SVOCs, and explosives in surface and subsurface soils.

Groundwater - Installed two monitoring wells and used pre- existing well to triangulate building and sedimentation pit. Investigated for metals, VOCs, SVOCs, and explosives in groundwater.

Surface water - Surface water was not present.

detected in groundwater above background levels and pose potential human health riiks under the residential scenario.

to surface soil at the northern side of the facilii. Explosives were more prevalent and at higher concentrations in surface than subsurface soil. VOCs including acetone, benezene, toluene and one SVOC, styrene, were detected in soil. The excess incremental human health risks were within the NCP limits.

Groundwater has been affected by site operations. Elevated concentrations of metals (primarily lead and chromium) in groundwater are the result of leaching of soil and sediment contaminants and extend under SWMU 11 site. Organic contaminants, including explosives, are migrating from source areas to groundwater. Minor explosive constituents in groundwater, likely associated with SWMU 11.

dichlorobenzene N-nitrosodi-n- propylamine BEHP

Surface Water: Not Applicable

Human Health Ecological

None

Sediment: None

Groundwater: Aluminum Antimony Arsenic Chromium VI Iron Lead Manganese Thallium Vanadium RDX TNT

Surface Water: Not applicable

All Media?

None

Table 2-1. Nature and Extent of Contamination and the Chemicals of Concern (COCs) at ASA SWMUs 11 Anniston Army Depot, Ammunition Storage Area, Anniston, ~labama

of 24 TNT leaching beds. Each bed is 70 ft (length) x 8 fl (width).

Received slurries of explosive waste from munition operations in Building 172 from 1948 to mid- 1950s. From the mid-1 950 to late 1960s, wash water from pelletizing system filters was disposed. Octol pink water was disposed of at this site in 1978.

Leaching beds not used since 1978. In 1985, a clay cap was installed.

Groundwater exists on site within the residuum and also within the bedrock. In general, the aroundwater flows toward the east

and subsurface soil samples from constituents were detected in soils. 11 locations in a diagonally Except for acetone, and BTEX, organic staggered pattern within the site. constituents (i.e., SVOCs & pesticides) are Evenly-spaced sediment samples not site-related compounds. Explosives were collected from the drainage are concentrated at the northern end of the swales located to the east and facility. Acetone, ethylbenzene, xylenes, north of the site. styrene and two pesticides were detected

in soil. Metals, VOCs and one SVOC were Groundwater - Investigated detected in sediment. The excess human metals, VOCs, SVOCs, and health risks were within the NCP limits. explosives from seven monitoring wells that encircle the site and Groundwater has been affected by site were completed in the residuum. operations. Elevated concentrations of Installed two deeper wells into the several metals detected in groundwater. bedrock and also sampled for Organic contaminants, including metals, VOCs, SVOCs, and explosives, are migrating from source explosives. areas to groundwater. Plumes of

explosives (HMX & RDX) and metals (lead Surface water - Surface water was & chromium) are within the groundwater not present. on site. Potential human health risks were

g' I( washing machines at the Laundry I spatial coverage of site, Soil I surface soil. The detected VOCs do not 11 ~uilding (Building S-162). I borings were advanced in two I appear to be site-related contaminants.

I locations, one within in diameter of I Site-related metals detected above Building S-162 (demolished in the leaching beds and one background levels included: lead and 1973) was used from 1948 to 1973 adjacent the leaching beds. antimony. Human health risks were below to wash the clothing of workers Investigated for metals, VOCs, NCP and CDC guidelines.

Soil: None

Sediment: None

Groundwater: Aluminum Arsenic Chromium VI Iron Lead Manganese BEHP RDX TNT


None

Sediment: Not Applicable

Groundwater: None

All Media?

None

None

Table 2-1. Nature and Extent of Contamination and the Chemicals of Concern (COCs) at ASA SWMUs Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

who handled explosives.

Groundwater on site is located within the residuum and the bedrock beneath the site.

The 5-acre site consists of a fenced field with two open concrete-lined disposal units, consisting of concrete pads and small incinerators. Concrete troughs connect the disposal units and incinerators to sumps.

The site was used for burning popellants and was operational from I968 to 1978. Diesel fuel was used to ignite and burn the propellant.

The area is completely overgrown and the southern sump is filled with gravel.

Groundwater exists in both the residuum and bedrock on site. The groundwater in the residuum is relatively shallow (within 15 feet of surface) and is estimated to flow to sw.

and subsurface~soils.

Groundwater was not investigated based on prior information from 1992 groundwater samples indicating no adverse affects to groundwater.

& I , a - 7 ~ * .

Soil - An initial soil gas survey for VOCs was conducted using 22 locations with 504 spacing along the long axis of the concrete structures (sumps, troughs). Collected surface and subsurface samples from five borings situated based upon soil gas results. Investigated for metals, VOCs, SVOCs, PestlPCBs and explosives in surface and subsurface soils.

Groundwater - Collected samples from two pre-existing monitoring wells located on site. Investigated for metals, VOCs, SVOCs, PestlPCBs and explosives in groundwater.

close to background levels and do not indicate evidence of a contaminant release to subsurface soil.

5 W m F a c i l W Metals, VOCs, and low levels of SVOCs were detected in surface soil samples. Human health risks were below NCP and CDC guidelines.

Subsurface soil samples contained some metals and low levels of VOCs.

Groundwater sampling indicates that past operations have not affected groundwater. Human health risks were below NCP and CDC guidelines.

Quantity Surface Water: Not Applicable

Soil: None

All Media?

None Sediment: Not Applicable

Groundwater: None



with approximate dimensions of 54 ft (length) by 25 ft (width).

The site was used as burning grounds for decontaminated dunnage and burial pit for TNT- contaminated palettes.

Groundwater on site exists in the residuum and the bedrock on site. Shallow groundwater flows to SE and is influenced bv a stream to the east of the site.

The site (4500 sf) is rectangular with approximate dimensions of 54 ft (length) by 25 ft (width).

The site was used as burning grounds for decontaminated dunnage and burial pit for TNT- contaminated palettes.

Groundwater on site exists in the residuum and the bedrock on site. Shallow groundwater flows to west and is influenced bv streams east and west of the site.

The facility (- 1.25 acres) consists of a deactivation furnace located

Anniston Army Depot, Ammunition Storage Area, Anniston, ~ l a b a i

subsurface soils from two borings, one located within the former burn pit and one adjacent the burn pit. Surface and subsurface soils were analyzed for metals, VOCs, SVOCs, PestlPCBs, and explosives.

Groundwater - Installed a single well to supplement two pre-existing wells and triangulate the former pit. The groundwater was investigated for metals, VOCs, SVOCs,

Soil - Collection of surface and subsurface soils from two borings, one located within the former burn pit and one adjacent the bum pit. Surface and subsurface soils were analyzed for metals, VOCs, SVOCs, PestlPCBs, and explosives.

Groundwater - Installed a single well to supplement two pre-existing wells and triangulate the former pit. The groundwater was investigated for metals, VOCs, SVOCs,

Soil - Extensive surface soil sampling was conducted for lead at

VOCs and SVOCs were detected in surface and subsurface soil. Human health risks were below NCP guidelines.

Low levels of the explosive compound PETN are in the groundwater. No estimated risk from groundwater consumption.

Metals were detected primarily in subsurface soils. Trace amounts of VOCs I and SVOCs were detected in subsurface soils.

Low levels of the explosive compound PETN are in the groundwater. Eight metals were detected above background levels.

Nine metals exceeded backaround criteria 1 50 CY soil in surface soil, while in subshace soil,

Soil: None


Groundwater: None


Soil: None


Groundwater: Iron Lead


Soil: Lead

All Media? None

All Media:b

None

All MedW


used to deactivate small arms munitions by burning.

Building 393 was demolished in November 2000. Soil at the site was redistributed during demolition.

Groundwater on site exists in both the residuum and the bedrock. The shallow aquifer flows from SW to NE.

Anniston Army Depot, Ammunition Storage Area, Anniston, ~labama

grid. Seven additional surface soil samples were collected for metals, VOCs, SVOCs, and PestlPCBs based upon initial results. Three soil borings were advanced to collect subsurface samples in the locations where the lead concentrations were highest and these subsurface soil samples were analyzed for metals, VOCs, SVOCs, and PestlPCBs.

Groundwater - Installed three monitoring wells to supplement a pre-existing well on site. The new wells are situated to the north, east, and south of the former deactivation furnace. The four wells were sampled for metals, VOCs, SVOCs, I and P~SVPCBS.

COCs for aroundwater are based on wtential future resident exoosures. No

Lead was the most prevalent and concentrations were well above background. A small number of metals were detected at low concentrations in surface soil with no apparent distribution pattern.

Several metals were detected above background levels in groundwater, indicating furnace operations are likely to have impacted groundwater. Organic compounds were not detected in groundwater samples.

Waste Quantity

74.6 MG groundwater

SWMU 35,khere lead in soil was idekified as a COC. COCs insoil are based on current,future industrial/construction worker exposures. bSoil, surface water, sediment, and aroundwater.

Sediment: I None Not Applicable Groundwater: Aluminum Arsenic Chromium VI Iron Manganese Nickel Thallium Vanadium


BEHP = bii(2-ethylhexy)phtha~ate. - 1,1 -DCE = 1 ,l dichloroethene. RDX = royal demolition explosive. BTEX = benzene, toluene, ethylbenzene, and xylene. 1 ,2-DCE= 1,2-dichloroethene. SVOC = semivolatile organic compound. COC = chemical of concern. PETN = pentaerythritol tetranitrate. TNT = 2,4,64rinitrotoulene.

beg = below existing grade. VOC = volatile organic compound.


location of the ANAD is shown in Figure 2-1. The locations of the nine SMWUs within ANAD ASAare shown in Figure 2-2.

2.5.1 Environmental Setting

The ASA, situated west of Anniston, is in the vicinity of several small communities and is characterizedby gently rolling, wooded ridges and valleys. Surface water at ANAD flows into three major streams,Cane Creek to the north, Blue Eye Creek to the west, and Choccolocco Creek to the south. Geologic dataindicate the installation is underlain by variably weathered carbonate bedrock. Additional details on thesite characteristics are provided in the RI and FS for the ASA (SAIC 2001 and 2002). The groundwaterflow system in ANAD is the result of complex geologic structures, shallow flow in the weathered zone,conduit flow paths in bedrock and the weathered zone, and discontinuities of hydrogeologic units.Groundwater exists in two separate aquifers in the ANAD region, within the shallow residuum over thebedrock and within the carbonate bedrock (limestone, dolomite) and shale of the Upper CambrianConasauga Formation and undifferentiated Knox Group. ANAD is located within the Coldwater Springsrecharge basin, which is a complex overthrust fault groundwater system covering approximately 90square miles.

The shallow aquifer lies within a cherty residuum generally between 30 and 100 feet thick. Theresiduum is a sandy to silty clay with generally low permeability in the upper unconsolidated zone. Justabove the bedrock is a transitional zone that has a higher permeability because it contains substantialamounts of sand and gravel plus highly fractured bedrock above the consolidated bedrock. Thetransitional zone tends to behave as a semi-confined aquifer because of the lower permeability of theupper unconsolidated soils and the bedrock. The groundwater in the residuum and transitional zone isprimarily the result of precipitation infiltrating the surface and migrating downward to the top of thebedrock where the groundwater comes into hydraulic communication with the groundwater in thebedrock. Within the ASA, the groundwater generally flows to the northwest in the western half of theinstallation and primarily to the northeast and east in the eastern half of the installation. Localtopography and subsurface conditions cause variances within the general groundwater flow regimes andsmall, perched groundwater tables may exist because of lenses of clay or other low permeability soilsthat prevent or hinder the downward migration of groundwater.

The groundwater in the transitional zone serves as the primary source of water recharge to thegroundwater within the bedrock. The recharge occurs primarily through fractures and minor faultswithin the bedrock. The hydraulic communication is generally poor, but in that Knox Group rockcontains carbonates, localized areas can have high transmisivities because of multiple fractures anddissolution-enhanced fractures and voids (i.e., karst terrane). The karst terrane also accounts for small,regional areas of higher groundwater flow rates within the bedrock aquifer.

The ASA is within the Coldwater Spring recharge basin. Coldwater Spring is situated in the southerntip of the basin and is located approximately 1.5 miles south of ANAD. Coldwater Spring is the primarywater supply for the population in the Anniston area serving approximately 60,000 persons.Groundwater flow within the basin converges from the northwestern and southeastern boundariestoward the Jacksonville Fault and flows toward Coldwater Springs. The Jacksonville Fault bisects theColdwater Spring recharge basin on a northeast to southwest axis.

2.5.2 Nature and Extent of Contamination

The RI included sampling and monitoring of soil, sediment, surface water, and groundwater todetermine the nature and extent of contamination in the ASA. Of the nine SWMUs investigated (see Record of Decision Final 2-12 July 2006Anniston Army Depot


Figure 2-2), 6 SWMUs are targeted for remedial action, including SWMUs 5, 8, 10, 11, 27, and 35.SWMUs 18 and 37 were investigated in the ASA RI but are now included in OU 5 and are not addressedunder OU 3. Table 2-1 provides a summary description of each of the nine SWMUs sites, their history,the nature and extent of contamination, and the COCs identified in the baseline risk assessment (seeSection 2.7). Additional information on the site history and RI results is provided in the RI (SAIC 2001)and FS (SAIC 2002).

2.5.3 Risk Assessment Conceptual Site Model

Exposure pathways describe the course a chemical or physical agent takes from the source to theexposed receptor. An exposure pathway can be described in four components, namely: a source andmechanism for chemical release; a retention or transport medium (e.g., soil, groundwater); a point ofpotential contact with the contaminated medium; and an exposure route (e.g., ingestion, dermal contact,and inhalation). Both potential current and future exposure conditions are considered when identifyingexposure pathways. Pathways are considered to be complete when a source or chemical release ispresent, an exposure point where contact can occur exists, and an exposure route provides anopportunity for contact to occur. If one of these conditions is not found at a site, the pathway isconsidered incomplete and is not evaluated in the risk assessment. The exposure pathways evaluatedin the risk assessment are presented graphically in Conceptual Site Models (CSMs) for both human andecological receptors.

Figure 2-3 presents the CSM for human receptors at the ASA. Since the current use of ASA is industrialand is likely to remain so in the future (see Section 2.6), exposure to an industrial worker was assessed.A construction worker was also evaluated, since construction activities such as building, roadconstruction, or utilities installation, might be necessary in the future at the SWMUs. In accordance withEPA Region 4 guidance (EPA 1995), a hypothetical future residential scenario was included at allSWMUs. Residential land use of ASA is highly unlikely because of the storage and demilitarizationmission of the Depot. The ecological CSM, shown in Figure 2-4, includes terrestrial and aquaticreceptors since both terrestrial and aquatic habitats are present at one or more of the ASA sites.

2.6 Current and Potential Future Land and Resource Uses

ANAD is an active industrial facility covering approximately 15,200 acres. The majority of ANADoperations occur in the ASA and Southeast Industrial Area. The ASA covers approximately 13,000 acresand occupies the entire central and northern portions of ANAD. The ASA contains approximately 1,300ammunition storage magazines and operating buildings required for maintenance, demilitarization, andinspection of all types of ammunition and ammunition components. The Lance Missile Fueling Facilityand ammunition disposal areas are also located within the ASA. Access is controlled at the perimeterby fences and guards posted at entry points. According to the ANAD Master Plan ( NAD 1987), "... landuses are not expected to change significantly during the planned future development of Anniston ArmyDepot." Therefore, the most likely future land use of the ASA is industrial.

Currently, ANAD receives potable water from Coldwater Spring, supplied by Anniston Water Worksand Sewer Board (AWWSB). No active drinking water wells are currently located within the ASA. Forthe foreseeable future, water will continue to be supplied from Anniston Water Works.

Humans, livestock, and wildlife may be exposed to groundwater from a well, spring, or surface waterwithin 1 mile of the ANAD boundary. Groundwater is a source of Anniston's public water supply, whichis managed by AWWSB. Groundwater from wells and springs is used for residential and agricultural



purposes. In 2003, there were 55 homes in the vicinity of ANAD that use groundwater as their solesource of water supply. Surface water is used primarily for recreational and agricultural activities. Inaddition, 11 commercial catfish ponds are located on property adjacent to the ANAD SIA. Ten of theponds are filled directly from a well; the well has been engineered to preclude access. Another pond isfed from both a spring and that same well. These 11 ponds are approximately 100 to 300 ft from theANAD fence boundary.

2.7 Summary of Site Risks

A baseline risk assessment was conducted to determine the potential for adverse effects associated withexposures to chemicals present at sites within the ASA based on current and potential future land andresources uses. Baseline risks are potential risks to human and ecological receptors in the absence ofremediation or institutional controls at the site. The results of the human health risk and ecological riskassessments are provided in Sections 2.7.1 and 2.7.2, respectively. Section 2.7.3 describes the basis forproceeding with remedial actions at the six identified SWMUs.

2.7.1 Summary of Human Health Risk Assessment

A summary of the human health risk assessment results at the nine SWMUs evaluated in the RI,including the six SWMUs targeted for remediation, is presented in this section. The discussion focuseson industrial land use for soil (i.e., the reasonably anticipated future land use) and residential land usefor groundwater, and begins with a presentation of the COCs identified in the risk assessment. Thediscussion then parallels the major steps in the risk assessment process following the identificationCOCs: exposure assessment, toxicity assessment, and risk characterization (including associateduncertainty).

2.7.1.1 Chemicals of Concern

In the RI (SAIC 2001), chemicals that were analyzed for each of the media sampled (e.g., soil,groundwater, surface water, and sediment) at nine SWMUs underwent a screening process to determinewhich chemicals should be retained for evaluation in the baseline risk assessment. Risks to human healthwere calculated for those chemicals, identified as Chemicals of Potential Concern (COPCs). COPCs arethen evaluated to determine which are COCs, for which human health remedial goal options ( HHRGOs)will be developed. Constituents that exceed Applicable or Relevant and Appropriate Requirements(ARARs) may also be identified as COCs. Sites with no COCs require no remedial action. In accordancewith EPA Region 4 guidance (EPA 1995), COCs in the human health risk assessment are defined asCOPCs that significantly contribute to the risk for an exposure pathway for a receptor that either exceedsa lx10-4 cancer risk2 or a noncancer hazard index (HI) greater than 1.0. Also, if the concentration of aCOPC within a medium is higher than a state or federal ARAR (e.g., an MCL), that COPC is consideredto be a COC. Lead (which is not evaluated in terms of cancer risk or noncancer hazard) is identified asa COC if modeled blood lead levels exceed the proposed benchmark concentration developed by theCenters for Disease Control and Prevention (CDC). Under this guideline, blood lead levels must notexceed 10 micrograms per deciliter (µg/dL) in 95 percent of the population (EPA 1994a). Assuming thatthe future land use will remain industrial, the only COC identified in soil was lead at SWMU 35. When________________________2 Scientific notation also is referred to as exponential notation. An exponent indicates the number of times the base

(in this case 10) is multiplied by a number that appears to the upper right of the base. For example, 102 refers to thebase 10 multiplied by itself 2 times: 10 x 10 = 100. Exponents to the base 10 also can be expressed differently, with"exp" placing the " 10" in the base. Therefore, 102 alternately is represented as Exp+ 02. In this document bothconventions are used.



Table 2-2. Chemicals of Concern and Exposure Point Concentrations in Soil

SWMU 35

Lead I 27 I 3,870 1011 0 3,870 I Maximum

SWMU - Solid Waste Management Unit.

Table 2-3. Chemicals of Concern and Exposure Point Concentrations in Groundwater

Manganese 40 5,520 818 2,998 95% UCL BEHP 0.62 11 418 11 Maximum RDX 0.16 3.0 618 3.0 Maximum TNT 0.49 3.6 3l8 3.6 Maximum

SWMU n Iron 16,390 11 9,400 I313 11 9,400 IMaximum Lead 16.8 117 1313 117 IMaximum

Record of Decision 2-17 Final July 2006 Anniston Army Depot


Table 2-3. Chemicals of Concern and Exposure Point Concentrations in Groundwater

Chemical ofConcern

Concentration Detected (µg/L) Frequencyof

Detection

Exposure PointConcentration

Minimum Maximum Concentration (µg/L)

StatisticalMeasure

SWMU 35

Aluminum 196 101,000 4/4 101,000 Maximum

Arsenic 3.0 23 2/4 23 Maximum

Chromium (VI) 0.87 551 4/4 55 Maximum

Iron 479 257,000 4/4 257,000 Maximum

Manganese 31 6,640 4/4 6,640 Maximum

Nickel 3.4 539 3/4 539 Maximum

Thallium 2.2 2.2 1/4 2.2 Maximum

Vanadium 3.8 368 3/4 368 Maximum

considering cleanup of groundwater for hypothetical residential use (no groundwater use is expectedunder the industrial land use scenario), of the nine SWMUs assessed in the RI, six (SWMUs 5, 8, 10,11, 27, and 35) had COCs identified. COCs for soil and groundwater are presented in Tables 2-2 and2-3, respectively.

2.7.1.2 Exposure Assessment

The Baseline Risk Assessment (BRA) evaluated risks associated with current and future industrial andfuture residential land use scenarios. Industrial workers, construction workers, and resident children andadults were evaluated in the RI as part of these land use scenarios (see Section 4 of the RI). Theexposure pathways evaluated in the baseline risk assessment for the SWMUs at ASA are presented inthe CSM (see Figure 2-3). For the industrial land use scenario, the pathways evaluated include soilingestion, dermal contact with soil, and inhalation of suspended soil particulates. For residential landuse, groundwater ingestion and exposure to VOCs while showering were evaluated, as well as ingestionand dermal contact with surface water and sediment. The BRA considered residential exposure toCOPCs in the soil via inhalation of fugitive dust, ingestion, and dermal contact. The exposureassumptions for these scenarios are presented in Table 2- 4. These assumptions were combined with theexposure point concentrations (EPCs) to calculate intake or dose.

For soils, the focus of this ROD is on the industrial land use scenario since this is the current andreasonably anticipated future land use of the ASA ( ANAD 1987). Therefore, residential exposures werenot considered when determining COCs for soil and which SWMUs are to be targeted for remediationunder this ROD. For soils which present no excess risk under an industrial land use scenario but mayhave excess risk under a residential land use scenario, LUCs will be retained as a remedial alternativeto prevent an unanticipated land use change. Under the industrial land use scenario, lead was identifiedas a COC for SWMU 35. For groundwater, the hypothetical residential scenario was the basis forrecommendations because this was the only scenario under which exposure to this medium wasevaluated. Groundwater at SWMUs 5, 8, 10, 11, 27, and 35 contained COCs based on estimatedresidential risks. Sediment and surface water did not have any COCs at any SWMUs. Table A-1 of Record of Decision Final 2-18 July 2006Anniston Army Depot


Appendix A summarizes the receptors and pathways that were assessed in the RI and explains therationale for which were considered for this ROD and targeting SWMUs for remediation.

2.7.1.3 Toxicity Assessment

For soils, the focus of this ROD is on the industrial land use scenario since this is the current andreasonably anticipated future land use of the ASA (ANAD 1987). Therefore, residential exposures werenot considered when determining COCs for soil and which SWMUs are to be targeted for remediationunder this ROD. For soils which present no excess risk under an industrial land use scenario but mayhave excess risk under a residential land use scenario, LUCs will be retained as a remedial alternativeto prevent an unanticipated land use change.. Under the industrial land use scenario, lead was identifiedas a COC for SWMU 35. For groundwater, the hypothetical residential scenario was the basis forrecommendations because this was the only scenario under which exposure to this medium wasevaluated. Groundwater at SWMUs 5, 8, 10, 11, 27, and 35 contained COCs based on estimatedresidential risks. Sediment and surface water did not have any COCs at any SWMUs. Table A-1 ofAppendix A summarizes the receptors and pathways that were assessed in the RI and explains therationale for which were considered for this ROD and targeting SWMUs for remediation.

The objectives of the toxicity assessment are to evaluate the inherent toxicity of the compounds underinvestigation and to identify and select toxicity values for use in risk characterization. Toxicityinformation was obtained preferably from the Integrated Risk Information System (IRIS) [EPA 1998al.If values were not available from IRIS, the Health Effects Assessment Summary Tables (HEAST) [EPA1997bl were consulted or provisional toxicity values from EPA's National Center for EnvironmentalAssessment (NCEA) were used.

Table 2-5 provides non-carcinogenic toxicity values for COCs identified in groundwater. Referencedoses (RfDs) for oral exposure indicate acceptable intake values for chronic exposure (noncancereffects). Reference concentrations (RfCs) for inhalation exposure reflect values for chronic exposure(noncancer 2 effects); these can be converted to inhalation RfDs by multiplying by 20 square meters(m2)/day and dividing by 70 kg. RfDs and RfCs represent a toxicological threshold below which noadverse health effects would be expected to occur. 1,4-dichlorobenzene and N-nitroso-di-n-propylamineare the only COCs that have no oral RfDs. Currently, inhalation RfCs are only available for1,4-dichlorobenzene, chromium (VI), and manganese. Target organs and critical effects for exposureto the COCs are shown in the table.

Table 2-6 presents cancer slope factors (CSFs) for COCs in groundwater for the oral and inhalationexposure routes. For carcinogens, EPA believes that there is no appropriate exposure threshold;extremely low levels of exposure to a carcinogen may result in chromosomal or enzyme changes leadingto cancer. The CSF is used to estimate the probability of a cancer effect occurring in an exposed receptorover a lifetime.

For lead, toxicological studies indicate that there may be no threshold of exposure to lead below whichadverse effects do not occur. Lead is classified as a B2 carcinogen (probable human carcinogen), butEPA does not provide a noncancer RfD or cancer toxicity value. Instead, biokinetic models were usedto estimate blood lead levels in resident children and adult workers (EPA 1994a and 1996, respectively)in accordance with EPA's recommendations.


Table 2-4. Exposure Assumptions for the Human Health Risk Assessment

Construction Worker

!nts Adult

----- Child Industrial Worker

General Body Weight kg Exposure Duration years Averaging Time - Noncancer days Averaging T i e - Cancer days

Soil Ingestion Ingestion Rate mg soillday Exposure Frequency dayslyear Conversion Factor ka soiVma soil

--

Dermal Contact Skin Surface Area Available Soil-to-skin Adherence Factor Dermal Absorption Factor (inorganics) Dermal Absorption Factor (organics) Exposure Frequency

5,800 1

0.001

0.01

250 1 E-06

20 I .32EtOS

250 Not e\

5,000 0.2

0.001

0.01

21 9 1 E-06

20 1.32Et06

219 uated

unitless

dayslyear kg soiVmg soil

m3 airlday m3 airlkg soil

dayslyear Uday

davdvear

Conversion Factor Fugitive Dust Inhalation Inhalation Rate

Particulate Emission Factor

Not evaluated ~ Exposure Frequency Groundwater Ingestion Ingestion rate I 1 Ex~osure Freauencv

I I . I . I~roundwater Showering (dermal contact, 1 ingestion rate 1 Uday Not evaluated Not evaluated - inhalation)' I Exposure Frequency I dayslyear

- - = Not analvzed. ' = Assumesihat intake of VOCs while showering is equivalent to the intake from ingesting 2 liters of water per day. CTE = Central tendency exposure. RME = Reasonable maximum exposure.

Record of Decision Anniston Army Depot

Final July 2006


2.7.1.4 Risk Characterization

Risk characterization is the process of quantifying human health effects using the intake or dose derivedfrom the exposure assessment in conjunction with the toxicity data presented in the toxicity assessment.The objective of the baseline risk characterization is to determine whether exposure to chemicals at theSWMUs under investigation pose risks that exceed target levels for human health effects.

The level of adverse noncarcinogenic effects from exposure to a given constituent is expressed as thehazard quotient (HQ). The HQ is the ratio of the estimated chronic daily intake of a chemical to the RfD.To evaluate exposure from more than one noncarcinogen, the chemical-specific HQs are summed foreach exposure route in a given environmental medium to obtain the HI. The HIS for each exposure route(e.g., soil ingestion, soil dermal contact, and inhalation of dust) may then be summed within a medium.After the HIS for each medium are calculated, the HIS may be combined across all relevant media (e.g.,soil, groundwater, surface water, and sediment) to estimate the total SWMU HI for each receptor.

Carcinogenic risks are estimated as the incremental (site-specific) excess probability of an individualdeveloping cancer over a lifetime (70 years) as a result of exposure to chemical carcinogens. Cancerrisks are calculated by multiplying the average daily intake over a lifetime by the CSF for thecarcinogen. The estimate of the total SWMU cancer risk must account for simultaneous exposure tomultiple carcinogens, exposure routes, and media. To accomplish this, the cancer risks calculated foreach individual carcinogen in an exposure route are summed to yield a cancer risk estimate for theexposure route. The cancer risks for each exposure route and the cancer risks for each medium are thensummed to obtain an estimate of the total cancer risk for the SWMU.

For lead, two biokinetic models were used to estimate blood levels of lead in resident children and adultworkers. LEAD 0.99d (EPA 1994a) is the model recommended by EPA for children and is based onuptake of lead originating from various sources in the environment. For adult workers, the riskassessment was conducted using a model (EPA, 1996) designed to evaluate and protect the hypotheticalfetus of an adult worker. Lead exposures pose an unacceptable risk if the modeled blood lead level ofthe resident child, or that of the hypothetical fetus of a female adult worker, exceed the proposedbenchmark concentration developed by the CDC (i.e., less than or equal to 10 µg/dL in 95 percent ofthe population). If blood lead levels exceed this guideline, SWMU- related exposures may present a riskto human health.

The risk characterization summary is presented by SWMU and COC in Tables 2-7 through 2-13. Cancerrisks, noncancer risks, and blood lead levels are presented separately.

Uncertainty is inherent in every step of the risk assessment process. Uncertainty is associated with theanalytical data (e.g., representativeness of the sample data and accuracy of the laboratory analyses) andcreates the potential for either overestimating or underestimating risks to receptors. Uncertainty also isa part of the exposure assessment and primarily is associated with the exposure scenarios evaluated, themodels used, and the exposure parameters used to estimate intake. In the baseline human health riskassessment, the industrial scenario is realistic and representative of current and likely future land use,whereas the residential land use scenario is not anticipated. The models and exposure parameters usedto estimate risk are conservative (i.e., would tend to overestimate risk) because the assumptions usedrepresent a reasonable maximum scenario (e.g., an industrial worker is exposed to contaminants at eachsite for 5 days per week, 50 weeks per year, for 25 years). The use of high-end values as exposurefactors is a well-established part of human health risk assessment and is intended to provide themaximum level of protection to public health.


Table 2-5. Toxicity Values for Evaluation of Ingestion and Inhalation Pathways: Noncancer Effects

1,4-dichlorobenzene - - - - - - 8.OE-01 100 d Liver effects

Aluminum 1 .OE+00 100 c - - - - - - - -

Antimony 4.OE-04 1,000 d - - - - - - Whole body, blood; inc. Mortality

Arsenic 3.OE-04 3 d - - - - - - Skin; hyperpigmentation, keratosis, vascular complications I I I I I I

BEHP I 2.OE-02 1 1,000 1 d - - - - - - Liver; weight increase

Chromium (VI) 3.OE-03 900 d 1.OE-04 300 d None reported ; nasal septum atrophy

Iron 3.OE-01 1 c - - - - - - - - Manganese 2.4E-02 1 d 5.OE-05 1,000 d Central nervous system; various effects

Nickel 2.OE-02 300 d - - - - - - Whole body; decreased body and organ weight

RDX 3.OE-03 100 d - - - - - - Reproductive system; inflammation

Thallium 8.OE-05 3,000 d - - - - - - Liver, blood; increased SGOT and serum LDH

TNT 5.OE-04 1,000 d - - - - - - Liver; liver effects

Vanadium 7.OE-03 100 b - - - - - - - -

a ~ f ~ = Reference dose. RfC = Reference concentration.

%ealth Effects Assessment Summary Tables (HEAST) [EPA 1997.

C~ational Center for Environmental Assessment (NCEA).

%.s. Environmental Protection Agency Integrated Risk Information System (IRIS) Database (December 1997).

BEHP = bis(2-ethy1hexy)phthalate. 1,l-DCE = 1 ,ldichloroethene. RDX = royal demolition explosive. TNT = 2,4,6-trinitrotoulene.


Table 2-6. Toxicity Values for Evaluation of Ingestion and Inhalation Pathways: Carcinogenic Effects

1,4-dichlorobenzene 2.4E-02 b - - - - Aluminum - - - - - - - -

Arsenic 1.5Et00 a 1.5Et01 a

BEHP 1.4E-02 a - - - -

aU.S. Environmental Protection Agency Integrated Risk Information System (IRIS) Database (December 1997).

%Iealth Effects Assessment Summary Tables (HEAST) [EPA 1997)

CNational Center for Environmental Assessment (NCEA).

BEHP = bis(2-ethy1hexy)phthalate. 1 ,I-DCE = 1,l-dichloroethene. RDX = royal demolition explosive. TNT = 2,4,6-trinitrotoulene.



2.7.1.5 Summary of Risks

Many aspects of the toxicity assessment are uncertain. In most cases, uncertainty in the risk assessmentwill tend to overestimate the actual level of risk. For example, the conditions under which theexperimental studies used to derive the toxicity values are conducted are different from typical humanexposure in an environmental setting (e.g., the study design, species, sex, and routes of exposure maydiffer). In general, conservatism is built into the existing toxicity values; in each stage of extrapolationfrom experimental conditions to real-life exposure a multiplier is used to incorporate a margin of safetyto the calculations. Some varieties of uncertainty may tend to lower, rather than raise, the estimated levelof risk. For example, toxicity values (CSF and RfD) are not available for some chemicals, preventingtheir inclusion in the total risk at the site. Overall, the uncertainty associated with the risk assessmentmay result in under- or overestimation of the actual risk by as much as an order of magnitude.

Soil and Sediment

Under an industrial scenario none of the nine SWMUs evaluated during the RI contain concentrationsof 4 COPCs that either exceeded a 1x10-4 cancer risk or a HI of 1.0. Lead detected in surface soil atSWMU 35 resulted in a calculated mean blood lead level of 11 µg/dL under the industrial scenario,which exceeds the EPA limit of 10 µg/dL. Remedial alternatives for soil are discussed beginning inSection 2.9. Based on the calculated risks, soil at SWMUs 5, 8, 10, 11, 14, 15, 26, and 27, warrants nofurther action/no action. None of the concentrations of COPCs present in sediment at SWMU 5 wereestimated to pose 4 excess incremental risks greater than the cancer risk level of 1x10-4 or HIS greaterthan 1.0 for noncarcinogens. Sediment at SWMU 5 requires no further action/no action.

Surface Water

Surface water was present at only SWMU 5 (Sinkhole) and the concentrations of COPCs at this SWMUdid not result in HIS greater than 1.0 for noncarcinogens. No carcinogenic COPCs were identified forthe site. No further action/no action is required for cleanup of surface water at SWMU 5.

Groundwater

Groundwater was investigated For future residential land use, of the nine SWMUs (5, 8, 10, at nine ofthe SWMUs ( 5, 8, 10, 11, 14, 15, 26,27, and 35) during the RI. either the carcinogenic risk exceeded1x10-4 or the HI exceeded 1.0 at six 11, 27, and 35). The estimated carcinogenic or noncarcinogenicrisks did not exceed these thresholds at SWMUs 14, 15, or 26, and, therefore, no further remedial actionis necessary for groundwater at these locations. Remedial alternatives for groundwater are discussed inSection 2.9.

2.7.2 Summary of Ecological Risk Assessment

The ERA for the ASA identified and evaluated the current and future risk to biota exposed underexisting conditions to site-related contaminants detected in surface soil, sediment, surface water,groundwater, and biota (aquatic animals, earthworms, and small mammals) in accordance with EPAguidance (EPA 1997c). Ecological risks were assessed at the nine ASA SWMUs: 5, 8, 10, 11, 14, 15,26, 27, and 35. No significant risk and no COCs were identified for any ecological receptor at anySWMU. Sections 2.7.2.1 through 2.7.2.4 briefly summarize the first seven steps of the eight-step ERA


Table 2-7. Risk Characterization Summary for Residential Land Use Chemicals of Concern in Groundwater at SWMU 5

Lead l l a - - - - - - - -

Manganese -- - - - - 17 7

1,1 -DCE -- 6.E-06 1 .E-05 - - - -

BEHP -- 1 .E-06 - - - - - -

Qalue exceeds Centers for Disease Control (CDC) target due to combined subsurface soil and groundwater exposure. - - = Not applicable. 1 ,I -DCE = 1 ,I dichloroethene. BEHP = bis(2-ethy1hexy)phthalate.


- - = Not applicable. BEHP = bis(2-ethy1hexy)phthalate.


L %hemica1 is a COC due to exceedance of maximum contaminant level (MCL). halue exceeds Centers for Disease Control (CDC) target due to combined soil and groundwater exposures. - - = Not applicable. 1 ,I -DCE = 1 ,I -dichloroethene. BEHP = bis(2-ethy1hexy)phthalate. RDX = myal demolition explosive. TNT = 2,4,6-trinotrotoluene.


Exposure Medium Point

Groundwater On-site Direct Contact

I I I I Noncancer Hazard Quotient I - - - - ~ ..----- ~ ~~ ~ -- - . - ~ - - ~ - - ~ -

I Chemical Mean Blood Lead Level Cancinogenic Risk Ingestion I of Concern I in Fetus at 95th Percentile lnaestion I Inhalation Child I Adult

~ r s e s c I - - I 3.E-04 I - - 3 - - Chromium IWa I - - I - - - - 0.2 - - I

aChemical is a COC due to exceedance of MCL.

ba lue reflects combined surface soil and groundwater exposures. - - = Not applicable. BEHP = bis(2-ethy1hexy)phthalate. RDX = royal demolition explosive. TNT = 2,4,64rinotrotoluene.

Table 2-1 1. Risk Characterization Summary for Residential Land Use Chemicals of Concern in Groundwater at SWMU 27

Chemical is a COC due to exceedance of maximum contaminant level (MCL). Walue reflects combined soil and groundwater exposures. - - = Not applicable. SWMU = Solid Waste Management Unit.


Point . - . .

Chemical . . of Concern I Cancinoaenic Risk I Ingestion I Inhalation I I

Ingestion Child I -

tirounawater un-site uirect ont tact ~lurnlnurn - - - - ti Y Arsenic 5.E-04 - - 5 2

Chromium (VI)a - - - - 1 0.5 Iron - - - - 55 23

Manganese - - - - 18 8 Nickel - - - - 2 - -

Thallium - - - - 2 - - Vanadium - - - - 3 - -

%hemica1 is a COC due to exceedance of maximum contaminant level (MCL). - - = Not applicable.

Table 2-13. Risk Characterization Summary for Industrial Land Use Chemical of Concern in Soil at SWMU 35

Walue exceeds Centers for Disease Control (CDC) target due to combined surface soil and groundwater exposures.


process. The eighth step, risk management, is not relevant because risks to ecological receptors werenot identified. The first two steps of the process constitute the screening-level risk assessment. The nextfive steps represent the baseline ecological risk assessment (BERA).

2.7.2.1 Screening-level Ecological Risk Assessment

One or more heavy metals, polycyclic aromatic hydrocarbons (PAHs), or pesticides in surface water,groundwater, sediment, and surface soil at ANAD ASA SWMUs were detected at maximumconcentrations that exceed EPA Region 4 ecological screening values and other conservativebenchmarks. Ecological chemicals of potential concern (COPCs) detected in sediment at SWMUs 5and26, groundwater at SWMUs 8, 27, and 35, and surface soil at SWMUs 8, 10, 11, 14, 15,26,27, and35 were evaluated further in Step 3 of the ERA process (EPA 1997c).

2.7.2.2 BERA Problem Formulation

The reevaluation of COPCs identified in the screening-level risk assessment for the ANAD ASAidentified the potential for adverse effects to ecological receptors at SWMUs 5 and 35 and eliminatedall other COPCs at other SWMUs from further evaluation. The reevaluation of COPCs was based onmeasured site and reference concentrations, site- specific information on exposure pathways, publishedtoxicity benchmarks, and modeled and predicted exposures to wildlife receptors, including some basedon site-specific prey tissue concentrations. Chromium, lead, manganese, and zinc in sediment at SWMU5 (sinkhole), and lead in surface soil at the Deactivation Furnace (SWMU 39, were considered likelyto pose a hazard to the assessment endpoints, sediment dwelling invertebrates, and soil-dwellinginvertebrates, respectively, because site concentrations exceed benchmarks associated with adverseeffects on these organisms.

2.7.2.3 BERA - Study Design and Data Quality Objectives

The site investigation for the ANAD ASA ERA was designed to answer questions that address theassessment endpoints. Based on the CSM for the ANAD ASA (see Figure 2-10) and the assessmentendpoints, the questions evaluated in the site investigation are: "Does lead in surface soil at SWMU 35reduce survival of soil-dwelling invertebrates compared to background surface soils?" and "Dochromium, lead, manganese, and zinc in sediment at SWMU 5 reduce survival of sediment-dwellinginvertebrates compared to background sediments?"

The study design for the ANAD ASA provided analytical chemistry data and data on the magnitude ofeffects on growth and survival of test organisms exposed to environmental media from the ASASWMUs and reference locations. The toxicity tests for surface soil and sediment are standard tests withmethods approved by EPA or the American Society for Testing and Materials (ASTM) [i.e., ASTM E1676-971, standard guide for conducting laboratory soil toxicity or bioaccumulation tests with theLumbricid earthworm, Eisenia fetida (ASTM 1998), and EPA Test Method 100.0, Hyalella azteca10-day survival test for sediments ( EPA 1994b). These tests indicate whether the media collected fromthe site cause toxicity to the test organisms and quantify the magnitude of the toxic effect relative tomedia from reference locations. These tests are considered to be chronic tests (EPA 1994b; ASTM1998), and test durations are believed to be sufficiently long for adverse effects on sensitive life stagesto be observed at concentrations exceeding ecological screening values.

The measured endpoints were survival and growth for earthworms, and survival for amphipods. Thedesigns of the standardized toxicity tests define the statistical power and acceptable error levels when



using the test results as the basis for decision-making. The results of the toxicity tests indicate whethereffects from exposure to site media are significantly greater than effects from exposure to referencemedia. If observed effects are significantly greater in severity than reference, then the ecologicalsignificance of the magnitude of effects on assessment endpoints (i.e., the potential to reduce nativepopulations of the communities dwelling in the media) must be evaluated further.

The methods for collecting and controlling samples for toxicity tests and analytical chemistry aredescribed in the RI work plan and Sampling and Analysis Plan (SAP) [SAIC 1997a] and the addendumto the FSP, Part 1 of the SAP, Appendix A of the ERA work plan (SAIC 2000). The policy,organization, activities, and quality control (QC) protocols needed to achieve the study objectives aredescribed in the Quality Assurance Plan (QAP) [SAIC 1997b] of the RI work plan (SAIC 1994) and theaddendum to the QAP, Part 2 of the SAP, Appendix B of the ERA work plan (SAIC 2000).

2.7.2.4 Risk Characterization

The primary line of evidence to characterize the risk to ANAD ASA assessment endpoints at SWMUs5 and 35 is the toxicity tests. The toxicity tests indicate that there is no risk to sediment-dwellinginvertebrates exposed to metals (chromium, lead, manganese, and zinc) in sediment at SWMU 5 andno risk to soil-dwelling invertebrates exposed to lead in surface soil from vegetated areas at SWMU 35.Survival of sediment-dwelling amphipods, Hyalella azteca, and survival of earthworms, Eisenia fetida,in sediment and soil, respectively, was not significantly less than survival and growth in referencemedia. In accordance with the data quality objectives (DQOs) for the ANAD ASA (SAIC 2000), theseresults support the conclusion that the risk to ecological receptors is not ecologically significant.

2.7.3 Basis for Action

The response action selected in this ROD is necessary to protect public health, or welfare, or theenvironment from actual or potential releases of hazardous substances and pollutants or contaminants.

2.8 Remedial Action Objectives

The remedial action objectives for soil and groundwater follow:

• Soil- Prevent exposure (i.e., ingestion, inhalation, and direct contact) of industrial/constructionworkers to lead at SWMU 35 in excess of the recommended cleanup level. This cleanup levelis based on an evaluation of lead exposure levels with models to estimate blood lead levels inthe exposed population. Section 2.10 provides a comparative analysis of the remedialalternatives for soil.

• Groundwater- Prevent exposure to groundwater and restore groundwater to its expectedbeneficial uses wherever practicable through monitored natural attenuation using the maximumcontaminant levels (MCLs) as monitoring benchmark.3 Section 2.10 provides a comparativeanalysis of the remedial alternatives for groundwater.

________________________3 Refer to Section 2.12, Table 2-23 of this ROD for the monitoring benchmarks.



2.9 Description of Alternatives

Remedial action alternatives for soil and groundwater are presented in this section. Table 2-14 identifiesthe area size, depth, and volume associated with these media where one or more constituents exceedtheir respective cleanup levels (see Section 2.12.4). In addition, Figure 2-5 indicates areas withinSWMU 35 where lead exceeds the recommended cleanup level.

2.9.1 Description of Remedy Alternatives and Components

The FS (SAIC 2002) identifies and analyzes several possible remedial actions. This section presents adescription of the three alternatives that passed initial screening and were considered in detail for eachmedium. The key elements of feasible remedial action alternatives are presented in Table 2-15.

The following discussion presents an overview of the alternative, key technologies, construction andO&M requirements, system reliability, project life, and estimated costs.

2.9.1.1 Soil (SWMU 35)

Soil Alternative 1: No Action- CERCLA requires that the "no action" alternative be evaluated toestablish a baseline for comparison. Under this alternative, no action would be implemented to removeand/ or treat soils at a given SWMU regardless of whether or not there was a potential risk to human orecological receptors. The present worth and capital costs of this alternative are each $0 because noremedial action is implemented.

Soil Alternative 2: Delineation Sampling, Excavation, Confirmation Sampling, CharacterizationSampling, Off-site Treatment, Disposal or Reuse, and Land Use Controls- Under this scenario, theArmy would conduct additional soil sampling to complete the delineation of the lead-contaminated soilswith concentrations above 1,350 mg/kg, the benchmark cleanup level established by USEPA model forindustrial workers (EPA 1996). In addition, the Army would excavate and remove approximately 50cubic yards (CYs) of soil exceeding 1,350 mg/kg. Verification sampling would be performed to confirmthat soils containing lead concentrations above the approved cleanup level had been removed from thesite. Excavated soil would be characterized prior to disposal and soil found to be characteristic waste(e.g., W08) would be treated off-site and disposed in a RCRA Subtitle C or D landfill. The remainingRCRA nonhazardous soil is reused in a controlled environment under this alternative. RCRA non-hazardous soil would be treated only if required for the intended reuse of the soil (e.g., treated to belowa residential cleanup benchmark if designated for unrestricted land use).

The time to achieve the lead cleanup goal is less than 2 months from initiation of the remedy; however,the estimated remediation time frame is 30 years because of related O&M requirements. LUCs arerequired and will be implemented under this alternative. These controls may include physicalmechanisms, administrative actions, and legal mechanisms, any of which may be applied to a givenSWMU. This alternative utilizes a combination of LUCs, including the ANAD SOP for LUCImplementation and any others if determined to be necessary for protection of human health and theenvironment. Refer to Section 2.12.2 for additional LUC information. The total present value of SoilAlternative 2 is $76,270. The capital costs are $65,458, and annual O&M costs are $10,812.



Table 2-14. Media Areas and Volumes Exceeding Cleanup Levels Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

I SWMU 35 Soil I

111 750 1 27.8

Total 1,340 N A -50

ASA Groundwater

aRepresents a conservative estimate of the depth at which a given chemical of concern exceeds the associated recommended cleanup level. Additional soil delineation is recommended at SWMU 35 due to disturbances at the site. ASA = Ammunition Storage Area. ID = Identification. NA = Not applicable.

Table 2-15. Key Technologies in Final Alternatives Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Final Alternative 1 Final Final Technology (No Action) Alternative 2 Alternative 3

Soil - . ~~

No Action J

LUCS J J

Excavation/Removal J J

Treatment J J

Disposal J J

Groundwater

No Action J

Monitored Natural Attenuation J J

LUCS J J

Monitoring J J



Soil Alternative 3: Delineation Sampling, Excavation, Confirmation Sampling CharacterizationSampling, Off-site Treatment, Disposal, and Land Use Controls- Under this scenario, the Army wouldconduct additional soil sampling to complete the delineation of the lead-contaminated soils withconcentrations above 1,350 mg/kg, the benchmark cleanup level established by U.S. EPA model forindustrial workers (EPA 1996).

In addition, the Army would excavate and remove approximately 50 cubic yards (CYs) of soil exceeding1,350 mg/kg. Characterization sampling would be performed to confirm that soils containing leadconcentrations above the approved cleanup level had been removed from the site. Excavated soil wouldbe characterized prior to disposal and soil found to be characteristic waste (e.g., W 8 ) would be treatedoff-site and disposed in a RCRA Subtitle C or D landfill.

The time to achieve the lead cleanup goal is less than 2 months; however, the estimated remediationtime frame is 30 years because of related O&M requirements. LUCs are required and will beimplemented under this alternative. These controls may include physical mechanisms, administrativeactions, and legal mechanisms, any of which may be applied to a given SWMU. This alternative utilizesa combination of LUCs, including the ANAD SOP for LUC Implementation and any others ifdetermined to be necessary for protection of human health and the environment. Refer to Section 2.12.2for additional LUC information. The total present value of Soil Alternative 3 is $77,127. The capitalcosts are $66,315, and annual O&M costs are $10,812.

2.9.1.2 Groundwater (SWMUs 5,8,10,11,27 and 35)

Groundwater Alternative 1: No Action- CERCLA requires that the "no action" alternative be evaluatedto establish a baseline for comparison. Under this alternative, no action would be implemented at a givenSWMU regardless of whether or not there was a potential risk to human or ecological receptors. Thepresent worth and capital costs for this alternative are each $0 because no remedial action isimplemented.

Groundwater Alternative 2: Monitored Natural Attenuation and Land Use Controls (Existing WellNetwork)- Under Groundwater Alternative 2, the Army would monitor natural attenuation of thegroundwater concentrations of the COCs using the existing network of monitoring wells. Attenuationmechanisms expected to occur include aerobic or anaerobic biodegradation, physical phenomena (e.g.dispersion, volatization, and sorption), and chemical reactions (e.g. hydrolysis and dehydrohalogenation)(SAIC 2002). Initially, the Army would establish the baseline conditions by collecting four quarters ofgroundwater data from the monitoring wells located at the existing SWMUs plus the two downgradientwells outside of the ASA. After the initial year, the Army would conduct annual sampling of all wellsfor a period of 9 years. An annual monitored natural attenuation report would be generated for theregulatory agencies. Two 5-year reviews would be held over the estimated 10-year remediation timeframe. No new wells would be installed under this alternative. LUCs implemented by ANAD, wouldcontinue for at least the duration of the remedy.

The estimated remediation time is ten years. LUCs are required and will be implemented under thisalternative to prevent any use of the groundwater and any drilling of groundwater wells, with theexception of groundwater monitoring wells, until MCLs are attained. These controls may includephysical mechanisms, administrative actions, and legal mechanisms, any of which may be applied toa given SWMU. This alternative utilizes a combination of LUCs, including the ANAD SOP for LUCImplementation and any others if determined to be necessary for protection of human health and theenvironment. Refer to Section 2.12.2 for additional LUC information. The total present value of



Groundwater Alternative 2 is $827,984. The capital costs are $ 291,525, and annual O&M costs are$536,459.

Groundwater Alternative 3: Monitored Natural Attenuation and Land Use Controls (Expanded WellNetwork)- Under Groundwater Alternative 3, the Army would monitor natural attenuation of thegroundwater concentrations of the COCs utilizing an expanded groundwater monitoring network toinclude installing monitoring wells in locations downgradient of each of the six SWMUs to monitor forCOCS. Attenuation mechanisms expected to occur include aerobic or anaerobic biodegradation, physicalphenomena (e.g. dispersion, volatization, and sorption), and chemical reactions (e.g. hydrolysis anddehydrohalogenation) (SAIC 2002). The Army would conduct a year of quarterly monitoring from theexisting groundwater monitoring well network to establish the baseline conditions of COCs and naturalattenuation factors. The expanded groundwater-monitoring network will provide more completecoverage of the operable unit and allow for more accurate fate and modeling of the aquifer than the datafrom the existing well network. The Army would follow the baseline event with annual monitoring ofthe expanded network over a 9-year period and prepare annual monitored natural attenuation reports and5-year reviews (two).

The estimated remediation time frame is 10 years. LUCs are required and will be implemented underthis alternative to prevent any use of the groundwater and any drilling of groundwater wells until MCLsare attained. LUCs include physical mechanisms, administrative actions, and legal mechanisms, any ofwhich may be applied to a given SWMU. This alternative utilizes a combination of LUCs, including theANAD SOP for LUC Implementation and any others if determined to be necessary for protection ofhuman health and the environment. Refer to Section 2.12.2 for additional LUC information. The totalpresent value of Groundwater Alternative 3 is $1,460,450. The capital costs are $465,696, and annualO&M costs are $994,754.

2.9.2 Expected Outcomes of Each Alternative

As noted in Section 2.9.1, the remediation time frame would depend on the alternative implemented forthe ASA soils and groundwater. For the soil remedial action at SWMU 35, the industrial cleanup goalwill be achieved within a 2-month period of initiating the remedy. The overall remediation time frameis 30 years, which includes time to monitor and review the site's status. Available land uses uponachievement of cleanup levels are restricted to industrial land uses, and are subject to other LUCsincluding physical mechanisms, administrative actions, legal mechanisms and any others if determinedto be necessary for protection of human health and the environment. For groundwater, the 10-yearremediation strategy is to define contaminant trends and determine the impacts of natural attenuation.LUCs prohibiting the installation of groundwater wells, with the exception of monitoring wells, and thedrinking, or application to the ground, of groundwater will remain in place until unrestricted use/unlimited exposure (UU/UE) for groundwater is achieved. A modified groundwater-monitoring programwill be established during five year reviews.

2.10 Comparative Analysis of Alternatives

This section compares the relative performance of each remedial alternative against nine evaluationcriteria so that the advantages and disadvantages of each are clearly understood. Using the results of thisevaluation, ANAD compared the alternatives and selected the preferred cleanup alternative for the sitepresented in the Proposed Plan. The preferred alternatives for remediation of the soil and groundwaterare Soil Alternative 3 and Groundwater Alternative 3, respectively.



The nine criteria listed in the NCP (see Table 2-16) are categorized into three groups: (1) thresholdcriteria, (2) primary balancing criteria, and (3) modifying criteria. The alternative that ultimately isimplemented must satisfy the threshold criteria, which are the most important. Primary balancing criteriaare used to compare the major trade-offs among alternatives. Modifying criteria are considered afterpublic comment on the Proposed Plan.

Table 2-16. EPA Evaluation Criteria Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Criteria Description

Overall Protection of Human Health and theEnvironment

Addresses whether or not a remedy provides adequateprotection and describes how risks posed through eachpathway are eliminated, reduced, or controlled throughtreatment, engineering controls, or LUCs.

Compliance with Applicable or Relevantand Appropriate Requirements (ARARs)

Addresses whether or not a remedy will meet all of theapplicable or relevant and appropriate federal and stateenvironmental statutes and requirements or whether groundsexist for invoking a waiver.

Long-term Effectiveness and Permanence Refers to the ability of a remedy to maintain reliableprotection of human health and the environment over timeafter cleanup goals have been met.

Reduction of Toxicity, Mobility, andVolume Through Treatment

Refers to the anticipated performance of the treatmenttechnologies a remedy may employ.

Short-term Effectiveness Addresses the period of time needed to achieve protectionand any adverse impacts on human health and theenvironment that may be posed during the construction andimplementation period until the cleanup goals are achieved.

Implementability Refers to the technical and administrative feasibility of aremedy, including the availability of materials and servicesneeded to implement a particular option.

Cost Includes the estimated capital and operation andmaintenance costs and net present worth costs of eachalternative.

State/Support Agency Acceptance Indicates whether, based on a review of the remedialinvestigation and feasibility reports and Proposed Plan, thestate/support agency concurs, opposes, or has no commenton the preferred alternative at the present time.

Community Acceptance Assessed in the ROD following review of the publiccomments received on the Proposed Plan.

Each final alternative has been evaluated in detail using nine evaluation criteria, which are categorizedinto the following three criteria groups:

1. Threshold criteria: a. overall protection of human health and the environment, and b. compliance with ARARs.



2. Primary balancing criteria: a. long-term effectiveness and permanence; b. reduction of toxicity, mobility, and/or volume through treatment; c. short-term effectiveness; d. implementability; and e. cost.

3. Modifying criteria: a. state acceptance, and b. community acceptance.

Tables 2-17 and 2-18 provide a comparative summary of each of the alternatives against the evaluationcriteria for soil, sediment, and surface water, respectively.

2.10.1 Overall Protection of Human Health and the Environment

This section provides a comparative analysis of each alternative against the evaluation criteria humanhealth and the environment. This analysis compares and contrasts the three final alternatives for soil andfor groundwater remedies.

Soil

Final Soil Alternative 1 would not protect human health and the environment. Final Soil Alternatives2 and 3 would protect human health and the environment adequately by eliminating soils containing leadabove industrial risk values at SWMU 35. In addition, the Final Soil Alternative 3 allows for theimplementation of LUCs at SWMUs 35 to prevent future exposure of potential residents to surface andshallow subsurface soils. Except for the No Action Alternative, the final soil alternatives includemonitoring and maintaining the effectiveness of the remediation in protecting human health and theenvironment.

Groundwater

Final Groundwater Alternative 1, No Action, would not adequately protect human health and theenvironment. Final Groundwater Alternatives 2 and 3 would protect human health and the environmentthrough natural attenuation, monitoring, and LUCs. Groundwater Alternative 3 provides a bettercoverage of the affected groundwater areas and better protection in defining the areas requiring land-use controls. The wider coverage of the affected groundwater areas also provides better data formodeling the fate, transport, and natural attenuation of the groundwater.

2.10.2 Compliance with ARARs

This section provides a comparative analysis of each alternative against the ARAR compliance criterionfor soil and groundwater, respectively.

2.10.2.1 Soil

Each final soil alternative (except Final Soil Alternative 1, No Action) would be designed to meetchemical-, action-, and location-specific ARARs. The final soil alternative includes monitoring and


Table 2-17. Comparative Analysis of Remedial Alternatives for Soil Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Criterion

Overall Protection

Compliance with ARARs

Long-term Effectiveness

Reduction of Toxicity, Mobility, and Volume

Short-term Effectiveness

Implementability

Final Soil Alternative 1 : No Action

No reduction in human health risk. Potential for exposure to COCs remains.

Does not comply with chemical-specific ARARs for soil. Action- and location-specific ARARs are not applicable because no action is taken.

No mechanisms would be implemented to reduce risks.

Neither the toxicity, mobility, nor volume of lead would be reduced under this alternative.

There are no short-term hazards to site workers and the community because no remedial actions are implemented.

There are no technical or administrative implementability issues because no action is implemented.

Final Soil Alternative 2: Delineation Sampling, Excavation, Confirmation and Characterization

Sampling, Off-site Treatment, Disposal or Reuse, and Land-Use Controls

Protects human health and the environment through the planned remedial action.

Complies with chemical-, action-, and location- specific ARARs.

Provides for long-term effectiveness and permanence through soil removal and off-site treatment reuse and disposal, 5-year reviews, and monitoring and maintenance. Soil removal and off- site treatment and disposal are expected to reduce the magnitude of risk on-site, thereby offering a permanent solution to site-related contamination.

The mobility of the lead would be eliminated through excavation and off-site treatment/ reuseldisposal actions. The toxicity and volume of lead would be reduced and the volume increased with treatment at the off-site facility.

No significant risks to site workers or the community exist.

There are no technical or administrative implementability issues. Technologies are available and reliable. Disposal facilities are within 20 and 200 miles of ANAD for waste types generated. Inspection and maintenance of excavated areas are easily implemented.

Final Soil Alternative 3: Delineation Sampling, Excavation, Confirmation and

Characterization Sampling, Off-site Treatment, Disposal, and Land-Use

Controls

Protects human health and the environment through the planned remedial action.

Complies with chemical-, action-, and location- specific ARARs.

Provides for long-term effectiveness and permanence through soil removal and off-site treatment and disposal, 5-year reviews, and monitoring and maintenance. Soil removal and off-site treatment and disposal are expected to reduce the magnitude of risk on-site, thereby offering a permanent solution to site-related contamination.

The mobility of the lead would be eliminated through excavation and off-site treatmentldisposal actions. The toxicity of lead would be reduced and the volume increased with treatment at the off-site facility.

No significant risks to site workers or the community exist.

There are no technical or administrative implementability issues. Technologies are available and reliable. Disposal facilities are within 20 and 200 miles of ANAD for the waste types generated. lnspection and maintenance of excavated areas are easily implemented.

Table 2-17. Comparative Analysis of Remedial Alternatives for Soil Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama (Continued)

Criterion Final Soil Alternative 1: No Action

Present Value Cost: Capital $0 O&M $0 Present Worth $0

Final Soil Alternative 2: Delineation Sampling, Excavation, Confirmation and Characterization

Sampling, Off-site Treatment, Disposal or Reuse, and Land Use Controls

Final Soil Alternative 3 Delineation Sampling, Excavation, Confirmation and

Characterization Sampling, Off-site Treatment, Disposal, and Land Use

Controls

--

State Acceptance Not Acceptable. Acceptable. Acceptable.

Community Acceptance Not Acceptable. Acceptable. Acceptable.

ANAD=Anniston Army Depot. ARAR = Applicable or relevant and appropriate requirement. COC = Chemical of concern. FS = Feasibility Study. O&M = Operation and Maintenance.

Criterion Overall Protection

Compliance with ARARs

Long-term Effectiveness

Reduction of Toxicity, Mobility, and Volume

Table 2-18. Comparative Analysis of Remedial Alternatives for Groundwater Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Final Groundwater Alternative 2: Monitored Natural Attenuation and Land Use Controls

Final Groundwater Alternative 1: No Action (Existing Well Network) The No Action alternative would not include any Protects human health and the environment through land-use controls to prohibit the use of the natural attenuation processes, LUCs, and the existing aquifer. Therefore, the No Action monitoring program. Alternative, Groundwater Alternative 1, would not adequately protect human health and the environment.

Does not comply with chemical-specific ARARs Complies with chemical-, action-, and location- for groundwater monitoring. Action- and specific ARARs. location-specific ARARs are not applicable because no action is taken.

No mechanisms would be implemented to I Provides for lona-term effectiveness and reduce risks. permanence through natural attenuation, annual

reports, 5-year reviews, and LUCs. Natural attenuation is expected to reduce the magnitude of risk, thereby offering a permanent solution to site- related contamination.

Natural attenuation would reduce the mass, toxicity, mobility, volume, and concentration of contaminants in groundwater. However, there would be no mechanisms to monitor trends or identify related effects of natural attenuation.

Natural attenuation would reduce the mass, toxicity, mobility, volume, and concentration of contaminants in groundwater. Monitoring would support development and application of groundwater modeling and fate and transport assessments, which would be used to determine toxicity, mobility, and volume effects over time.

Final Groundwater Alternative 3: Monitored Natural Attenuation and Land Use Controls (Expanded Well Network)

Protects human health and the environment through natural attenuation processes, LUCs, and the monitoring program. Protection is enhanced by a more robust monitoring program that would improve the predictive capability of the site groundwater model.

Complies with chemical-, action-, and location-specific ARARs.

Provides for long-term effectiveness and permanence through natural attenuation, annual reports, 5-year reviews, and LUCs. Natural attenuation is expected to reduce the magnitude of risk, thereby offering a permanent solution to site-related contamination.

Natural attenuation would reduce the mass, toxicity, mobility, volume, and concentration of contaminants in groundwater. Monitoring would support development and application of groundwater modeling and fate and transport assessments, which would be used to determine toxicity, mobility, and volume effects over time. Expanded well network and data collection program would enhance the reliability and accuracy of analyses.

Criterion

Table 2-18. Comparative Analysis of Remedial Alternatives for Groundwater Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama (Continued)

Short-term Effectiveness

Implementability

Present Value Cost: Capital O&M Present Worth

State Acceptance

Community Acceptance

Final Groundwater Alternative 1: No Action There are no short-term hazards to site workers and the community because remedial actions are not implemented. No environmental impacts would result.

There are no technical or administrative implementability concerns.

Final Groundwater Alternative 2: Monitored Natural Attenuation and Land Use Controls

(Existing Well Network) On-site workers and the community will be protected through the groundwater monitoring and LUCs. No environmental impacts would result.

The technology to implement monitored natural attenuation and LUCs is available, reliable, and easy to implement. Use of LUCs is feasible; related measures have and are currently being implemented by the Depot. However, for monitored natural attenuation, the acceptability of using the existing well network by stakeholders may be at risk. Equipment and services to support sampling and analysis activities are readily available.

$0 $291,525 $0 $536,459 $0 $827,984

Not Acceptable. Acceptable.

Not Acceptable. 1 Acceptable.

ARAR = Applicable or relevant and appropriate requirement. LUC = Land Use Control O&M = Operation and Maintenance.

Final Groundwater Alternative 3: Monitored Natural Attenuation and Land Use Controls (Expanded Well Network)

On-site workers and the community will be protected through the groundwater monitoring and LUCs. No environmental impacts would result.

The technology to implement monitored natural attenuation and LUCs is available. reliable, and easy to implement. Use of LUCS is feasible; related measures have and are currently being implemented by the Depot. For monitored natural attenuation, the acceptability of using newly installed and the existing well network by stakeholders is high because a robust monitoring program is defined. Equipment and services to support sampling and analysis activities are readily available.

Acceptable.

Acceptable.


evaluation of the Selected Remedy. These institutional actions will document compliance with ARARsthrough reports, permits, and other methods. With the exception of SWMU 35, NA/NFA is necessaryfor soil in the ASA OU 3; compliance with ARARs is not applicable since no unacceptable risks arepresent.

Soil Alternative 1: No Action - The No Action Alternative, Soil Alternative 1, would not adequatelyprotect human health and the environment. The excess risk would remain and no measures to controlor eliminate the risk would be taken. Human health risks associated with the incidental ingestion,inhalation, and dermal contact of impacted soil would remain. In particular, the estimated blood leadlevels resulting from exposure to affected soil could potentially result in an unacceptable risk based onbenchmark concentrations proposed by the CDC.

Soil Alternative 2: Delineation Sampling, Excavation, Confirmation Sampling, CharacterizationSampling, Off-Site Treatment, Disposal or Reuse, and Land Use Controls - The applicable or relevantand appropriate requirements (ARARs) associated with this alternative would be achieved and areidentified in Section 2.13.2. The remedial technologies are reliable. The effectiveness of this alternativewould be ensured through 5-year reviews and monitoring and maintenance activities. This alternativewould not result in a reduction of the toxicity and volume of lead in the affected soil; however, the soilwould be relocated to a controlled environment for disposal or reuse. Excavated soils would becharacterized prior to disposal and soil found to be a characteristic waste would be treated to stabilizethe soil to decrease lead mobility. A slight increase in waste volume would occur as a result of thisremedy. LUCs would be required because this alternative would not achieve the cleanup goals forunrestricted use of the site.

Soil Alternative 3: Delineation Sampling, Excavation, Confirmation Sampling, CharacterizationSampling, Off-site Treatment, Disposal, and Land Use Controls - The ARARs associated with thisalternative would be achieved and are identified in Section 2.13.2. The remedial technologies arereliable. The effectiveness of this alternative would be ensured through 5-year reviews and monitoringand maintenance activities. This alternative does not specifically reduce toxicity or volume; however,it should be noted that if soils are deemed to be characteristic waste (e.g., D008) for disposal purposes,then the soils will require treatment to reduce the mobility (and hence toxicity) of lead and also resultin slightly increased volume for the treated soils. LUCs would be required because this alternative wouldnot achieve the cleanup goals for unrestricted use of the site.

2.10.2.2 Groundwater

Final Groundwater Alternative 1 does not comply with chemical-specific ARARs for groundwater. FinalGroundwater Alternatives 2 and 3 would be designed to meet chemical-, action-, and location-specificARARs. These final alternatives include monitoring natural attenuation and LUCs. Therefore,monitoring and reporting are essential components of the final remedy. These LUCs will control landuse until ARARs are met.

Groundwater Alternative 1: No Action - The No Action alternative would not include any LUCs toprohibit the use of the existing aquifer. Therefore, the No Action Alternative, Groundwater Alternative1, would not adequately protect human health and the environment.

Groundwater Alternative 2: Monitored Natural Attenuation and Land Use Controls (Existing WellNetwork) - The ARARs associated with this alternative would be achieved and are identified in Section2.13.2. The remedial technologies are reliable. The effectiveness of this alternative would be ensured



through the monitoring program and related LUCs. In general, this alternative would be protective ofhuman health and the environment and reduce the overall contaminant toxicity and volume of materialremoved in the long term through natural attenuation processes. This alternative, however, does notprovide for monitoring of the areas immediately downgradient of the individual SMWUs to determineif groundwater meets drinking water standards or risk-based guidance nor provide a point at which thegroundwater meets standards or risk- based guidance and bounds the limits of groundwater impacts.

Groundwater Alternative 3: Monitored Natural Attenuation and Land Use Controls (Expanded WellNetwork) - The ARARs associated with this alternative would be achieved and are identified in Section2.13.2. The volume, toxicity, and mobility of contaminants would be reduced through naturalattenuation processes. The remedial technologies are reliable. The effectiveness of this alternative wouldbe ensured through the monitoring program and related LUCs. In general, this alternative would beprotective of human health and the environment and reduce the overall contaminant toxicity and volumeof material removed in the long-term through natural attenuation processes. Under GroundwaterAlternative 3, the groundwater monitoring well network will be expanded. The Army will install a totalof eight additional monitoring wells hydraulically downgradient from six SWMUs to evaluategroundwater quality downgradient of SWMUs.

2.10.3 Long-term Effectiveness and Permanence

The final alternatives for soil and groundwater are compared to the long-term effectiveness andpermanence evaluation criterion in this section. The No Action Alternative for each medium does notachieve remediation objectives.

2.10.3.1 Soil

The Soil No Action, Alternative 1 does not provide long-term effectiveness. Both Final Soil Alternatives2 and 3 provide long-term effectiveness by excavation and disposal of soil to meet remediationobjectives. Final Soil Alternative 2 differs from Final Soil Alternative 3 in that it includes plans to reusenonhazardous soil in a controlled environment where human contact would be avoided. The hazardoussoil would be excavated and treated/disposed of in a RCRA Subtitle C facility under both alternatives.Both final soil alternatives, which include excavation at locations within SWMU 35 presenting humanhealth risks, provide the highest level of long-term effectiveness and permanence. LUCs ensurelong-term effectiveness and permanence by prohibiting any use of the property that would not beprotective of human health.


Both Final Groundwater Alternatives 2 and 3 provide for long-term effectiveness, permanence, andmonitoring through natural attenuation, groundwater monitoring, annual reports, 5-year reviews, andLUCs. Natural attenuation is expected to reduce the magnitude of risk, thereby offering a permanentsolution to site-related contamination. Final Groundwater Alternative 3 provides the highest degree ofrobust monitoring, long-term effectiveness, and permanence. The expanded well network (followinginstallation of new wells) and data collection program would enhance the reliability and accuracy ofanalyses.

2.10.4 Reduction of Toxicity, Mobility, and Volume Through Treatment

This section assesses each alternative with respect to its reduction of the toxicity, mobility, and/orvolume of contaminants. A comparative analysis also is provided for alternatives within each medium.Record of Decision Final 2-44 July 2006Anniston Army Depot


2.10.4.1 Soil

The toxicity, mobility, and volume of waste would not be reduced under the No Action Alternative(Final Soil Alternative 1). Final Soil Alternatives 2 and 3 serve to reduce toxicity, mobility, and volumeof the affected soils simply by removing these soils from SWMU 35. These soils do not pose anunacceptable risk for direct contact or ingestion under the current scenario whereby the site is not in use,but pose a potential threat for migration to groundwater. Under an active industrial use scenario,however, the soils at SWMU 35 pose a potential for elevated blood lead levels above CDC guidelines(> 10 µg/dL). It should be noted, however, that Final Soil Alternative 2 could involve the mixing ofnonhazardous soils with other soils for reuse elsewhere on ANAD. This action could actually increasethe volume of affected soils, although the toxicity of the soils would be reduced through dilution. UnderAlternative 3, the soil would be excavated, treated and disposed of at a secure facility, thereby reducingthe mobility of lead but not its toxicity. The volume of soil for disposal may increase if stabilization isrequired prior to disposal. The removal of soil from SWMU 35 will reduce the volume of affected soilsphysically on site.


As noted in Table 2- 18, Final Groundwater Alternative 1 would reduce the mass, toxicity, mobility,volume, and concentration of contaminants in groundwater through natural attenuation. However, therewould be no mechanisms to monitor trends or identify related effects of natural attenuation. Both FinalGroundwater Alternatives 2 and 3 also would achieve similar results. Both alternatives include plansto document and report on natural attenuation effects over time. With the expanded well network anddatabase planned for Final Groundwater Alternative 3, the ability to quantify these results would beenhanced along with the predictive capability of the groundwater models. The uncertainty of the resultswould be reduced, providing a higher degree of confidence in the stakeholder decision-making process.

2.10.5 Short-Term Effectiveness

Short- term effectiveness is evaluated to determine if there are impacts during the construction andimplementation phase until the remedial objectives are achieved. The short-term effectivenessevaluation criterion is discussed for the final soil and groundwater alternatives in the followingsubsections.

2.10.5.1 Soil

There are no significant risks to site workers or the community with the implementation of Final SoilAlternatives 2 and 3. Both alternatives would be conducted over the same time frame (30 years) andwould involve similar construction activities and practices. Environmental impacts relate specificallyto site impacts during the soil removal process for Final Soil Alternatives 2 and 3 and are expected tobe minimal and of short duration. Under Final Soil Alternative 1, there would be no short-term impactsbecause no action is implemented.


Monitored natural attenuation and LUCs will not result in significant environmental impacts duringimplementation of Final Groundwater Alternatives 2 and 3. On-site workers and the community will beprotected from groundwater exposures through LUCs and continued groundwater monitoring. TheDepot's community relations program will be critical to ensuring that the public is informed on the ASA



monitoring strategy and understands the results of the program. Remaining site risks are not expectedto be present if natural attenuation processes are proven to be effective. Results of the sampling programand CSM will support assessment of the short-term effectiveness of this alternative. No significantenvironmental impacts are anticipated for all alternatives. Under Final Groundwater Alternative 1, therewould be no short-term impacts because no action is implemented.

2.10.6 Implementability

Final Alternative 1 (No Action) for all media would be the easiest to implement; however, thisalternative would not accomplish remedial objectives. The implementability evaluation criterion isdiscussed for the final soil and groundwater alternatives in the following subsections. There are noimplementability concerns for Alternative 1 (No Action) for both soil and groundwater because noaction is completed.

2.10.6.1 Soil

There are no implementability (technical or administrative) concerns related to implementation of FinalSoil Alternatives 2 and 3 at ANAD. These alternatives would rely on standard construction techniquesand practices. Excavation and earth-moving equipment would be used to excavate soil requiringtransportation and disposal. Disposal facilities exist for hazardous and nonhazardous waste within 200miles or less of ANAD. Final Soil Alternatives 2 and 3 each would require the import of clean soil forbackfilling of excavated sites. Final Soil Alternatives 2 and 3 will require monitoring, inspection, orrepair of backfilled areas for 30 years. Monitoring requirements to determine the effectiveness of FinalSoil Alternatives 2 and 3 would be similar. Inspection and maintenance activities would be performedto evaluate each alternative's effectiveness.

Soil Alternative 2 would be slightly more difficult to implement because a secure backfill site wouldhave to be located to reuse the nonhazardous soil. The treated soil would have to meet leachingstandards to protect groundwater in the backfill location.

Environmental permits from the ADEM or local Soil Conservation District are required for bothalternatives. These permits require preparation of erosion and sedimentation control plans andimplementation of these controls to prevent off-site movement of soil by wind or water erosion duringearth-moving activities.


The technology to implement monitored natural attenuation and LUCs is available, reliable, and easyto implement for both Final Groundwater Alternatives 2 and 3. The administrative feasibility of LUCsis high; however, for monitored natural attenuation, the acceptability of using the existing well networkby stakeholders may be at risk under Final Groundwater Alternative 2. Final Groundwater Alternative3 is likely to be more acceptable to the regulators and community because of the use of a larger wellnetwork and a more comprehensive data collection strategy. Equipment and services to supportsampling and analysis activities are readily available.

2.10.7 Cost

The total costs, including the capital and O&M costs, for each alternative for soil and groundwater arepresented in this section. These costs are based on a present worth analysis, which represents the amount



of money that, if invested in Year 0 and disbursed as needed on an annual basis, would be sufficient tocover all costs associated with the remedial alternative. These cost estimates are accurate to +50 to -30percent, consistent with EPA guidance (EPA 1988). A discount rate of 7% was utilized to calculate thepresent worth of remedial options.

2.10.7.1 Soil

As Table 2-19 indicates, Final Soil Alternative 2 has the lowest estimated total cost, except for the NoAction Alternative. The costs for Final Soil Alternatives 2 ($76,270) and 3 ($77,127) are within 1percent of each other. These total costs (present worth) include the capital cost for design and equipmentand associated tasks, as well as O&M activities for the expected 30-year period of remediation.Appendix B includes additional details on these costs.

Table 2-19. Comparison of Capital and O&M Costs for the Final Soil Alternatives Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Final Soil Alternative Capital Cost O&M Cost (present worth) Total Cost

1 $0 $0 $0

2 $65,458 $10,812 $76,270

3 $66,315 $10,812 $77,127O& M = Operation and Maintenance.


As Table 2-20 indicates, Alternative 2 has the lowest total cost (present worth), when compared toAlternative 3. The higher costs associated with Alternative 3 are associated with the installation of eightnew wells and the associated sampling and analysis required for the larger well network and analysissuite. Appendix B details the basis for the costs of these alternatives.

Table 2-20. Comparison of Capital and O&M Costs for the Final Groundwater Alternatives Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Final Groundwater Alternative Capital Cost O&M Cost (present worth) Total Cost

1 $0 $0 $0

2 $291,525 $536,459 $827,984

3 $465,696 $994,754 $1,460,450 O&M = Operation and Maintenance.

2.10.8 State Acceptance Cost

The State of Alabama has expressed support for Alternatives 2 and 3 for both soil and groundwater, atSWMUs that require remedial action. The state does not support Alternative 1 for each medium becauseit does not satisfy threshold criteria for protection of human health and the environment or utilizetreatment.



2.10.9 Community Acceptance

There were no adverse comments received on ANAD’s Selected Remedies or any of the other treatmentalternatives during the public comment period.

2.11 Principal Threat Wastes

Principal threat wastes are those source materials considered to be highly toxic or highly mobile thatgenerally cannot be contained or would present a significant risk to human health or the environmentshould exposure occur. The lead contaminated soils at SWMU 35 constitute a principal threat wastebecause these soils pose a potential source for groundwater contamination. In addition, theconcentrations of soil exceed regulatory benchmarks for lead in soils under both the residential andindustrial scenarios and result in estimated blood-lead levels in excess of the target limit (10 µg/dL)established by the CDC. The remedies recommended under Soil Alternatives 2 and 3 are designed toaddress the lead soils by removing them from the site and, as such, fulfill the requirement of the NCPto address principal threat wastes, where practical.

2.12 Selected Remedies

In this section, the rationale for the Selected Remedies (Section 2.12.1) is presented and followed bya description of the remedy for soil and groundwater (Section 2.12.2). The cost estimate and expectedoutcome of implementing the Selected Remedies are then presented in Sections 2.12.3 and 2.12.4,respectively.

2.12.1 Summary of Rationale for the Selected Remedies

There were several factors that supported the prioritization and ultimate selection of the SelectedRemedies for soil and groundwater. Because Alternatives 2 and 3 for soil and groundwater protecthuman health and the environment, comply with ARARs, and for soil, use treatment and permanentsolutions as principal elements of the remedy, ANAD examined each alternative individually, and withrespect to each other, regarding the remaining evaluation criteria. Consistent with the NCP, thealternative was evaluated with respect to its long- term effectiveness and permanence; implementability;reduction in toxicity, mobility, and volume; and acceptance. Costs then were examined to determine anoption's overall effectiveness. As a result of this analysis, Soil Alternative 3 and GroundwaterAlternative 3 were selected as the most responsive and cost-effective remedies over their respectivealternatives. The rationale for selecting these alternatives and a cleanup that meets industrial cleanuplevels in the short-term, while attaining UU/UE cleanup levels over the long-term, is that the selectedalternatives provide the best demonstration of remedy effectiveness (more robust monitoring approach)and the best administrative controls to ensure prevention of exposure to contaminants that currently posean unacceptable risk to human health.

2.12.2 Description of the Selected Remedies

This ROD addresses all known waste units and environmental concerns within the ASA OU. TheSelected Remedies are expected to be the final actions for this OU and remedial actions will beundertaken at waste units with COCS above cleanup levels. The Selected Remedies includes remedialstrategies for the impacted media and the SWMUs addressed in this ROD. The remedies include:



‚ Soil Alternative 3: Delineation Sampling, Excavation, Confirmation andCharacterization Sampling, Treatment, Off-site Disposal, and Land Use Controls- Thisalternative will be used at SWMU 35.

‚ Groundwater Alternative 3: Monitored Natural Attenuation and Land Use Controls(Expanded Well Network)- This alternative is for ASA groundwater at SWMUs 5, 8, 10,11,27, and 35.

A description of these alternatives is provided in Sections 2.9.1.1 to 2.9.1.2 for soil and groundwater,respectively.

LUCs are defined as physical, legal, or other mechanisms used to restrict property use. The LUCs willbe implemented to mitigate risk associated with exposure to contamination either during or followingcleanup, when it is not feasible to reduce or eliminate those risks by removing or treating thecontaminated media to unrestricted use levels. LUCs will be applied as part of remedies at the SWMUs,where remedial action is required and will result in contaminated media being left in place at levels thatdo not allow for unrestricted use. These SWMUs, include SWMU 35, due to lead contamination in soil,and SWMUs 5, 8, 10, 11, 27, 35, due to groundwater contamination. Figures 2-6 through 2-10 show theapproximate limits of LUC boundaries that will be implemented for these SWMUs. The specific sizesand locations of the LUCs will be addressed in the RD/RWAP. A LUC Remedial Design (LUC RD) orLUC remedial action work plan (LUC RAW) will be prepared as the land use component of the RD orRAW on a schedule consistent with, and enforceable under, the Federal Facility Agreement. The LUCRD or LUC RAWP shall contain implementation and maintenance actions, including periodicinspections. Following completion of and consistent with the timeline developed in the RD or RAW,the Army will implement, monitor, maintain, enforce and report on the LUCs. Specific implementation,maintenance, inspection, and contingency requirements concerning the LUCs at each SWMU will bedetailed in the RD/RAWP. The LUCs include the ANAD SOP for LUC implementation, which requiresLUCs to be listed in the Installation Master Plan. The RD or RAWP will also provide the qualityassurance and control (QA/QC) protocols and review requirements to be undertaken by the Army duringthe life of the remedial actions.

Table 2-21 outlines the LUC performance objectives and identifies the key elements of the objective,the implementing organization, the geographic area addressed by the LUC, and the expected durationof the LUC. The Army will retain responsibility for ensuring the integrity of the selected CERCLAremedies in this ROD. This responsibility for remedy integrity means that the Army must ensure thatLUC Performance Objectives are met and that the remedy(ies) remains effective. The Army will notchange the designated land use identified as part of the remedy(ies), terminate, or modify the LUCswithout first obtaining EPA concurrence.

The overall goal of the LUCs is to prevent exposure to contaminants within the ASA at the SWMUs thatcurrently pose unacceptable risk to human health. The LUCs will be maintained until the concentrationof contamination is at such levels as to allow for unrestricted use and exposure. The boundaries ofSWMUs to be covered by the LUCs are shown in Figures 2-6 through 2-10. The LUCs address soil andgroundwater as discussed in this ROD.

2.12.3 Cost Estimate for the Selected Remedy

The estimated total costs (present worth) for the Selected Remedies for soil (Soil Alternative 3) andgroundwater (Groundwater Alternative 3) are $77,127 and $1,460,450, respectively. Table B-1 in


The Decision Summan,

Table 2-21. Land-Use Control Performance Objectives for the Selected Remedies, Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Prevent residential reuse ofthe gitSE.'

Description

SWMU 35

SWMU 35

SWMU 35

Implementing Organization

Anniston Armv ~epot w ~ ~ i , Directorate of R i Management

Geographic Boundary

Encommssed bv the Land-use - I ExPecled

the ASA

&se Fires 2-8 through 2-1 0.

the LUGS will continue until the conmmbn of Canaynination i!3 at such tevek as to abw for u n r W use



Appendix B presents the detailed costs for soil remediation at SWMU 35. Table B-2 includes theremedial costs for groundwater. These costs represent an order- of- magnitude engineering cost estimatethat is expected to be within +50 to -30 percent of the actual project cost.

2.12.4 Estimated Outcome for the Selected Remedy

This section presents the expected outcomes of the Selected Remedy in terms of resulting soil andgroundwater uses and risk reduction achieved as a result of implementing the Selected Remedy. Table2-22 highlights these expected outcomes.

Table 2-22. Expected Outcomes for the Selected Remedy Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Feature Outcome

Remediation Time Frame The remedial time frame ranges from 10 years (groundwater) to 30 years(soil).

Available Land Uses Land use will continue to be industrial within the ASA. For groundwater,available land uses beyond industrial will be determined at the end of the10-year monitoring time frame. LUCs will be in place for current andfuture land uses.

Residual Risk Human receptors will not be adversely affected upon completion of soilremediation (i.e., contamination will be cleaned up to at least industrialcleanup levels). The ROD requires LUCs for soil and groundwater. WithLUCs, groundwater uses will be restricted and residential use prohibited;therefore, human receptors will be protected.

Socio-Economic andCommunity Impacts

Impacts would occur only if property were to be transferred. Newproperty owners would be required to comply with any associated LUCs.In the event of property transfer, the use of restrictions noted in Table2-21 will be placed in the deed, thereby prohibiting any unacceptableuses by future transferees.

Environmental and EcologicalBenefits

Remediated soil will eliminate potential industrial worker exposure tolead. In addition, groundwater monitoring and LUC mechanisms will beused in tandem to prevent exposures of the local community and on-siteworkers to contaminated groundwater.

The cleanup level for lead in soil and the recommended groundwater monitoring benchmarks, identifiedin Tables 2-23 and 2-24, will be used to determine when the expected outcome is achieved. Theshort-term impact of the groundwater remedy is to prevent human exposure through the use ofrestrictions on well installation (other than monitoring wells) and the long term expected outcome is theachievement of UU/UE benchmarks, which will be demonstrated through monitoring.



Table 2-23. Recommended Cleanup Level for Lead in Soil Anniston Army Depot, Ammunition storage Area, Anniston, Alabama

Chemical Target HQTarget Cancer

Risk Recommended Cleanup Level (Industrial Worker)a [mg/kg]

Lead NA NA 1,350a The industrial worker cleanup level for lead in soil is based on the U.S. Environmental Protection Agency (EPA) model for adult workers (EPA 1996). County census data were used to justify a more realistic blood level(1.7 µg/dL and average geometric standard deviation (1.93). HQ = hazard quotient.

2.13 Statutory Determinations

Under CERCLA Section 121 and the NCP, ANAD must select remedies that are protective of humanhealth and the environment, comply with ARARs, are cost-effective, and use permanent solutions andalternative treatment or resource recovery technologies to the maximum extent practicable. In addition,CERCLA includes a preference for remedies that employ treatment that permanently and significantlyreduces the volume, toxicity, or mobility of hazardous wastes as a principal element and a bias againstoff- site disposal of untreated wastes. The following sections discuss how the Selected Remedies meetthese statutory requirements.

2.13.1 Protection of Human Health and the Environment

The selected remedies for all 9 SWMUs will protect human health and the environment. As discussedin Section 2.7.1.4, lead detected in soil at SWMU 35 corresponded to a mean blood lead level thatexceeded EPA target blood lead level of 10 µg/dL. For the nine other SWMUs, future industrial workerexposure to soil resulted in a cancer risk below 1x10-4or a HI less than 1.0. Therefore, SWMU 35 is theonly site requiring remedial action for soil. Cancer risks to future residents exposed to groundwater wereestimated to be greater than 1x10-4and/or HIS were higher than 1.0 at SWMUs 5, 8, 10, 11, 27, and 35.The Selected Remedies, which include Soil Alternative 3 and Groundwater Alternative 3, will protecthuman health. The cancer risks from potential exposure will be reduced to 1 x10-6 and noncancer risksto an HI of 0.1. Potential risks to industrial workers from exposure to soil from ingestion or incidentalcontact with groundwater will be achieved through the monitoring program and associated LUCs.

The short-term risks associated with the Selected Remedies will be controlled. In addition, no adversecross-media impacts are expected. LUCs will also be applied to limit access and prevent workerexposures to contaminated groundwater within the ANAD boundaries. Risks to ecological receptorswere not identified at any SWMU.

2.13.2 Compliance with ARARs

The Selected Remedies comply with all federal and state of Alabama ARARs. The key ARARssignificant to the Selected Remedies are presented in Tables 2-25 and 2-26 for soil (SWMU 35) andgroundwater (SWMUs 5, 8, 10, 11, 27, and 35), respectively. Chemical-specific ARARs are defined forgroundwater (see Table 2-24) and will be used as monitoring benchmarks. Location-specific ARARsare not likely to be of concern given the remedial alternatives selected; however, potential requirementsare noted for completeness. ARARs also are indicated for specific aspects of the Selected Remedies and



Table 2-24. Recommended Groundwater Monitoring Benchmarks Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Thallium 0.1 1 x loo6 0.1 0.3 No CSFs No CSFs 2 2

Vanadium 0.1 1 x10-08 11 26 No CSFs No CSFs - - Ownh (PW

1 ,4-Dichbrobenzene 0.1 1 x 1 P No RfDs No RfDs 8 4 75 - 1 ,l -Dichbroethene 0.1 1 x10-08 14 33 0.1 0.05 7 7

bis(2-Ethylhexyl) 0.1 1 x10-08 31 73 13 6 6 6 phthalate N-nitrosodi-n- 0.1 1 x lom No RfDs No RfDs 0.03 0.01 - - propylamine RDX 0.1 1 x l @ 5 11 2 0.8 - - 2,4,6-Trinitrotoluene 0.1 1 x10"8 0.8 2 6 3 - - Source: Science Applications International Corporation (SAC) 2001.

The values are concentrations of the constituent that are protective of a residential child [15 kg, intake of 1 liter per day (Ud) for 6 years] and residential adult (70 kg adult, 2 Ud water intake for 30 years) against non-carcinogenic effects.

qhe values are the concentrations of the constituent that are protective of a residential child and adult against carcinogenic effects.

The value listed under maximum contaminant level (MCL) for lead is the action level set by the US. Environmental Protection Agency for water at the tap. AL = Alabama. CSF = Cancer slope factor. MCL = Maximum contaminant level. RDX = Royal demolition explosive, cyclo-l,3,5-trimethylene-2,4,6-trinibrrmine. RfD = Reference dose. pglL = microgram per liier. HighlighM values indicate cleanup targets for UUlUE of groundwater.


Table 2-25. ARARs and TBC Guidance for Remediation of SWMU 35 Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Action Impacts of Remediation on Floodplains

Impacts of Remediation on Wetlands

Impacts of Remediatiin on Wilderness Areas, Wildlife Resources, Wildlife Refuges, or Scenic Rivers Impact of Remediation on Threatened Species or ~r i i ical Habitat

Characterization of Primary and Secondary Waste Streams Land Disposal of RCRA Hazardous contaminated Soil

ADEM Admin. Code R. 335-1 4-3-.01(2) - potentially applicable

ADEM Admin. Code R. 335-1 4-9-.00 incorporates the following federal citations by reference:

40 CFR $268.3 - potentially applicable 40 CFR $268.7 - potentially applicable 40 CFR $268.9 - potentially applicable 40 CFR $268.35 - potentially applicable 40 CFR $268.38 - potentially applicable 40 CFR $268.40 - potentially applicable 40 CFR $268.48 - potentially applicable

Federal citah Executive Order 1 1988 - TBC guidance

40 CFR $6 Appendix A (1999) - TBC guidance Executive Order 1 1990

40 CFR $6 Appendix A (1999) - potentially . . . . -

app~icaMe Provisions of the Fish and Wildlife Coordination Act (16 USC 661 et seq) 56662 .. - and 663 - - pot&tially applicable Provisions of the Endanaered S~ecies Act of 1973 (1 6 USC 1531 et Gq)

'

50 CFR 402 (1 998)

Provisions of the Fish and Wildlife Coordination Act (1 6 USC 551 et seq.- potentially applicable

40 CFR $268.49 (63 FR 28556, May 26, 1998) - potentially applicable

Table 2-25. ARARs and TBC Guidance for Remediation of SWMU 35 Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama (Continued)

I Additional Rmuiremants for Storage of

ADEM Admin. Code R. 33514-5-.(32(5)- poasnti&'appl~ ADEM Admin. Code R. 335-14-5-.03(2) - potentially applicable AoEM Admin. Code R. 335-14-5~.03(3) - potsnticllly applicable ADEM Admin. Code R. 335-14-5-.03(4) - poteMally appl3ca#e ADEM Admin. Code R. 335-14-5-.Q3(5) - poteMJly appJkW ADEM Admii. Code R. 335-14-5-.03(6) - -JIy a p p l W ADEM Admin. Code R. 335-14-5-.07(2) - po0nliqlly appllca#e - - - ADEM Admin. Code R. 335-14-5-.07(5) - &dal ly appllcaMe I ADEM Admin. Code R. 335-14-5-.09(b) - potentially applicable

AMM Admln, Cade R. 335-14-3-.01(3) - potentially appllcabk 1 40 CFR $1 f i (1998) - potrrntially - ..

ADEM Admin. Code R. 335-1W.W

Incorporates the following federal citations by reference:

40 CFR $1 72 - potWaNy applicable 40 CFR $1 73 - potentially applicable 40 CFR $1 78 - potWally applicable 40 CFR 5179 - pote-ly ADEM Admin. Code R. 335-14-3--04 - potentially appliible ADEM Awn. Code R. 33514-3-08 - patsntially applicable ADEM Admin. Code R. 33514-8-.09 through 335-14&.13 - - pQtenUrrlly appl'mble

ADEM Admin. Code R. 335-14-940 kmrporatea the fullowing federal citations by reference:

40 CFR @68.7(a)(I) - -ly applicable 40 CFR 5268.7(a)(2) - potentially applicable flament. L

- ARAR = Applicable & relevant and appropriate requirement. CF R = Code d Regulatim. FR = Fera l Regkfer. RCRA = Reaaurce Conservath and Reeov6ry Act af 1976. TBC = To be considered. USC = United States Code.


Table 2-26. Action-Specific ARARs and TBC Guidance for Remediation of the Groundwater

Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Monitored Natural Attenuation t I

Land Use Controls I

Federal Citation

Guidance for 'Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action, and Underground Storage Tank Sites" (EPA 1999) - TBC guidance

40 CFR )300.430(a)(l)(iii)(D) -applicable

Construction of Groundwater Monitoring Wells

Primary Drinking Water Standards

ADEM recommends the use of the Handbook of Suggested Practices for the Design and Installation of Groundwater Monitoring Wells (EPA 1991) - TBC Guidance

ADEM Admin. Code R. 335-7-2 applicable

Environmental Investigations Standard Operating Procedures and Quality Assurance Manual, Section 6, "Design and Installation of Monitoring Wells" (EPA 1997a) - applicable

140 CFR ) 141 applicable

Investigation-Derived Waste I I EPA's IDW Publication (EPA 1992) - TBC guidance

Land Use Controls I I Policy for Assuring Land Use Controls at Federal Facilities (EPA 1998b) - TBC guidance

ADEM = Alabama Department of Environmental Management. ARAR = Applicable or relevant and appropriate requirement. CFR = Code of Federal Regulations. EPA = US. Environmental Protection Agency. IDW = Investigation-derived waste. RCRA = Resource Conservation and Recovery Act of 1976. TBC = To be considered.

Record of Decision 2-6 1 Final July 2006 Anniston Army Depot


are referred to as action-specific ARARs. These apply primarily to remedial activities related to themanagement of soil excavated in the case of soil remediation and monitoring well construction in thecase of the groundwater remedy.

2.13.3 Other Criteria, Advisories, or TBC Guidance for this Remedial Action

During the assessment of the Selected Remedies, ANAD considered a number of nonbinding criteria,referred to as To Be Considered (TBC) Guidance (see Tables 2-25 and 2-26). This guidance will beconsidered during the design and implementation of the Selected Remedies.

2.13.4 Cost-Effectiveness

In the judgment of ANAD and the EPA, the Selected Remedies are cost-effective and represent areasonable value for the money to be expended. In making this determination, the following definitionwas used: "A remedy shall be cost-effective if its costs are proportional to its overall effectiveness." Thiswas accomplished by evaluating the " overall effectiveness" of those alternatives that satisfied thethreshold criteria (i.e., were both protective of human health and the environment andARAR-compliant). Overall effectiveness was then compared to costs to determine cost-effectiveness.The relationship of the overall effectiveness of this remedial alternative was determined to beproportional to its costs; hence, the Selected Remedies represents a reasonable value for the moneyspent.

2.13.5 Utilization of Permanent Solutions

ANAD and the EPA have determined that the Selected Remedies represent the maximum extent towhich permanent solutions and treatment technologies can be utilized in a practicable manner at the site.Of those alternatives that are protective of human health and the environment and comply with ARARs,the Selected Remedies provide the best balance of trade-offs in terms of the five balancing criteria whilealso considering the statutory preference for treatment as a principal element, the bias against off-sitetreatment and disposal, and state and community acceptance.

The Selected Remedies treat selected source materials at SWMU 35, constituting the principal threatsat the site, through the use of excavation, treatment and disposal technologies, LUCs and includesnatural attenuation of contamination in groundwater. The remedies also satisfy the criteria for long- termeffectiveness by including LUCs for current and future land use. The Selected Remedies do not presentrisks different from other treatment alternatives. There are no special implementability issues that setthe Selected Remedies apart from any of the other alternatives evaluated.

2.13.6 Preference for Treatment as a Principal Element

The Selected Remedy for soil addresses principal threats posed by the site through the use of acombination of several technologies, including excavation, treatment, disposal, and LUCs. Excavatedsoil will be characterized prior to disposal and soil found to be characteristic waste will be treated priorto disposal. In using treatment as a portion of the remedy for soil, the statutory preference for remediesthat employ treatment as a principal element is satisfied.



2.13.7 Five-Year Review Requirements

This Selected Remedies will result in hazardous contaminants remaining at the ASA above levels thatallow for unlimited use and unrestricted exposure. Therefore, a statutory review will be conductedwithin 5 years after initiation of the remedial action.

2.14 Documentation of Significant Changes from Preferred Alternative ofProposed Plan

SWMUs 18 and 37, originally investigated in the ASA RI and presented in the PP, were removed fromOU 3. This change reflects the designation of two new OUs, the MMRP (OU 4) and Western IndustrialArea (OU 5). SWMUs 18 and 37 were removed from OU 3 and are now included in OU 5 and will beaddressed in the ROD for OU 5.


The Responsiveness Summary

3.0 THE RESPONSIVENESS SUMMARY

As noted in Section 2.3, the Proposed Plan was made available to the public in April 2002. The publicwas offered the opportunity to comment on this plan during the public comment period, April 15 to May15, 2002, as well as at a public meeting (May 6, 2002). No public comments were received during thistime frame on the Selected Remedy. The EPA Region 4 and the ADEM supported the Proposed Planand offered no additional comments beyond those provided during the preparation of the FS.


References

4.0 REFERENCES

ANAD (Anniston Army Depot). 2002. Ammunition Storage Area Proposed Plan. Prepared by ScienceApplications International Corporation (SAIC) for U.S. Army Corps of Engineers (USACE)Mobile District. March.

ANAD. 1990. Federal Facilities Agreement Between ANAD, USEPA, and ADEM. June.

ANAD. 1987. Anniston Army Depot Master Plan Report. Higgenbothem and Associates, PC, forDirectorate of Engineering and Logistics, Anniston Army Depot, Anniston, Alabama.September.

ASTM. 1998. 1998 Book of ASTM Standards, Volume 11.05. Biological Effects and EnvironmentalFate; Biotechnology; Pesticides. American Society for Testing and Materials, WestConshohocken, Pennsylvania.

Environmental Science and Engineering, Inc. (ESE). 1989. Remedial Investigation: Anniston ArmyDepot. Volumes 1 and 2. Contract No. DAA-15-85-D-0017. U.S. Army Toxic and HazardousMaterials Agency (USATHAMA). January.

ESE. 1981. Anniston Army Depot Resource and Conservation and Recovery Act Studies: FinalEngineering Report.

EPA (U.S. Environmental Protection Agency). 1999. Use of Monitored Natural Attenuation atSuperfund, RCRA Corrective Action, and Underground Storage Tank Sites, EPA Office of SolidWaste and Emergency Response (OSWER) Directive 9200.4-17P, April.

EPA. 1998a. Integrated Risk Information (IRIS). IRIS website: www.epa.gov/ngispgm3/iris/substfl.htm

EPA. 1998b. Assuring Land Use Controls at Federal Facilities.

EPA. 1997a. Environmental Investigations Standard Operating Procedures and Quality AssuranceManual, Section 6 - Design and Installation of Monitoring Wells, May 1996, Revised 1997.

EPA. 1997b. Health Effects Assessment Summary Tables. FY-97 Update. Office of Research andDevelopment, Office of Solid Waste and Emergency Response. EPA/540/R-97-036.

EPA. 1997c. Ecological Risk Assessment Guidance for Superfund, Process for Designing andConducting Ecological Risk Assessments. Interim Final. EPA-540-R-97-006. EnvironmentalResponse Team, Edison, New Jersey. June.

EPA. 1996. Recommendations of the Technical Review Workgroup for Lead for an Interim Approachto Assessing Risks Associated with Adult Exposures to Lead in Soil. Technical ReviewWorkgroup for Lead. December.

EPA. 1995. Supplemental Guidance to Risk Assessment Guidance for Superfund (RAGS): Region 4Bulletins (Data Collection and Evaluation, Toxicity Assessment, Exposure Assessment, RiskCharacterization, Development of Risk-Based Remedial Options). Interim Draft, Office ofTechnical Services, Atlanta, Georgia. September.


References

EPA. 1994a. LEAD 0.99d. A PC Software Application of Uptake/Biokinetic Model for Lead in Children.Office of Solid Waste and Emergency Response (OSWER). EPA/540/R-93/081. February.

EPA. 1994b. Methods for Measuring the Toxicity and Bioaccumulation of Sediment- associatedContaminants with Freshwater Invertebrates. EPA-600/R-94/024. Office of Research andDevelopment (ORD), Cincinnati, Ohio.

EPA. 1992. Investigation-Derived Wastes (IDW), EPA OSWER Publication 9345.3-03FS, January.

EPA. 1991. Handbook of Suggested Practices for the Design and Installation of GroundwaterMonitoring Wells.

EPA. 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA.OSWER Directive 9355.3-01. EPA/540/G-89/004. Office of Emergency and RemedialResponse. October.

Jacobs Engineering Group. 1993. Expanded Site Inspection, Ammunition Storage Area, Anniston ArmyDepot, Anniston, Alabama. Draft Final, November.

SAIC (Science Applications International Corporation). 2002. Ammunition Storage Area ProposedPlan. Prepared by Science Applications International Corporation (SAIC) for U.S. Army Corpsof Engineers (USACE) Mobile District. March.

SAIC 2002. Ammunition Storage Area Feasibility Study. Final. Prepared by SAIC for USACE MobileDistrict. Contract No DACA21-95-D-0022. March.

SAIC 2001a. Interim Record of Decision for Southeast Industrial Area Onpost Groundwater OperableUnit. Anniston Army Depot, Alabama. Prepared by SAIC for USACE Mobile District. March.

SAIC 2001b. Draft Record of Decision for Southeast Industrial Area Soil Operable Unit. AnnistonArmy Depot, Alabama. Prepared by SAIC for USACE Mobile District. June.

SAIC. 2001. Ammunition Storage Area Remedial Investigation. Final. Prepared by SAIC for USACEMobile District. Contract No DACA21-95-D-0022. August.

SAIC. 2000. Work Plan for the Ecological Risk Assessment for the Ammunition Storage Area atAnniston Army Depot, Anniston, Alabama. Final. June.

SAIC. 1997a. Final Anniston Army Depot, Ammunition Storage Area, Remedial Investigation, Samplingand Analysis Plan. September.

SAIC. 1997b. Final Anniston Army Depot, Ammunition Storage Area, Remedial Investigation, QualityAssurance Plan. September.

SAIC. 1994. Final Work Plans, RI/FS Plans, Ammunition Storage Area, Anniston Army Depot,Anniston, Alabama. October.


APPENDIX A

SELECTION OF EXPOSURE PATHWAYS

Record of Decision Final July 2006Anniston Army Depot

Scenario Timeframe

Medium

Spillddischargel deposition to soil



TABLE A-1 SELECTION OF EXPOSURE PATHWAYS

Anniston Army Depot - Ammunition Storage Area, Anniston, Alabama

Exposure Medium

Contaminants are in soil may be

:ransferred to air and are available for

xposure to receptors

Contaminants are in ;oil and are available

for exposure to receptors.

Contaminants are in ;oil and are available

for exposure to receptors

Exposure Receptor Point Population

Contaminants I in soil are I Residents

transferred to air as fugitive I

dust and I Industrial Workers exposure to :ontaminants in 3ir is evaluated.

Construction Workers

Contaminants are in soil and 2xposure to soi is evaluated.

Contaminants are in soil and zxposure to soi is evaluated.

Residents

lndustrial Workers

Construction Workers

Residents

Rationale for Selection or Receptor Exposure Type of Exclusion

Age Route Analysis of Exposure Pathway

Adults considered under h is ROD. No COCs identified for construction

Adults Air inhalation Quantitative workers for this exposure route - no1 considered under this ROD.

Future land use is industrial, so Childrenladults Ingestion Quantitative residential exposure to soil not

considered under this ROD.

Adults Ingestion Quantitative Lead was identiied as a COC for SWMU 35 and, thus, SWMU 35 is

Adults Ingestion Quantitative considered under this ROD.

Future land use is industrial, so Childrenladults Dermal contact Quantitative residential exposure to soil not

considered under this ROD Lead was identified as a COC for SWMU 35 and thus SWMU 35 is for re$edia&, under Industrial Workers

TABLE A-1 SELECTION OF EXPOSURE PATHWAYS

Anniston Army Depot - Ammunition Storage Area, Anniston, Alabama

ReQeptoa Age -

Adults Construction Workers

and, thus, SWMU 35 is for remediation under this

Contaminants are in

groundwater and exposure to groundwater

as drinking water and

during showering is evaluated.

Contaminants are in surface inraterlsedimenl

Ingestion Quantitative

COCs were identified at SWMUs 5, 8,10,11,27, and 35 for residential exposure to groundwater. These six SWMUs are targeted for remediatin under this ROD.

Contaminants in lroundwater remain ir groundwater and are available for exposure

to receptors.

Future Groundwater Residents Showering (dermal)

Contaminants in soil may be transferred to

surface waterlsediment by

surface water runoff and are available for ?xposure to receptors

Ingestion Quantitative I

1 Future land use is industrial, so residential exposure to surface watei and sediment is not considered under this ROD.

and expasure I Residents to surface

Future Surface Water Runoff

Dermal wntaci inraterlsediment is evaluated.

APPENDIX B

DETAILED COSTS

Record of Decision Final July 2006Anniston Army Depot

Table B-1. Soil Alternative 3 - SWMU 35 Costs Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Design Engineering Services

Work PhdDesign/liealth and Safety Plan I I I I

L S I $5,000.00 I 1 I $5,000 1 Includes overhead cost --

LS $2,a00.00 1 $2,000 Includes overhead cost

LS $5,OOO.00 1 $5,000 Includes overhead aost Defineation Samplik@Repsrt

Delineath Sample Calkt i in

Quality AswranceExcavatiQn Oversight

1 Assumes collection of 30 surface m p k by

1 I : I Scientist ($Whr x 20 hrs)+moWdemob, 8 hrs)

I I (Analysi of 30 samples at $50/sample=$l5QQ)

1 Assume 10 p e m t of Engineering Services $21200 Cost. Includes overhead cost Project Management

I Soil Excavation1 TranspartatlorJBaddiWRevegetatian

LS $3,OOO.00 1 $3,000 Assumes Gradall, D6, and all equipment(supplles

LF $2.00 1 ,OoO $2,000 Assumes installation of silt fence and 2QOLF diiersion

Engineering and Safety Contrds

Assumes 15 samples x $Wsample (20 hrs Scientist x $55/hr, inctudes mobldemob 4 hrs).

Level D, assumes 20x Means cost (.80/CY) ta account for sampling, segregation, and waste- type veriacatlon delays

Sail Excavation (14 thickness)

- miles Soil Transportation Assumes 80 tons (30 nonhazardous and

50 hazardous). Hazardous waste facility 300 mi, . Nonhazardous facility is 40 mi. roundtrip (5 truck loads) Nonhazardous landfill located in Emelle, AL.

Table B-1. Soil Alternative 3 - SWMU 35 Costs Anniston Army Depot, Ammunition Storage Area Anniston, Alabama (Continued)

Select Fill

Topsoil CY $42.85

Revegetation l sy l $1.25

TreatmentlDisposaVReuse Hazardous Waste Treatment (Land Ban cy $42.50

Requirements) Hazardous Waste Disposal

Nonhazardous Waste Disposal

Profit (1 0%)

Contingency (25%)

Capital Cost Subtotal

O&M (1 yrl

lncludes &inch layer purchase, trucking, dumping, grading, and compaction. Backfill source within 10 miles of ANAD

lncludes 6-inch layer purchase, trucking, dumping, grading, and compaction

Seeding, liming, fertilizing, and mulching disturbed areas

Treated with admixture to reduce lead concentration in leachate for land disposal.

Nonhazardous landfill located in Emelle, AL. I

Repair Eroded Areas I sy I $4.52 1 200 1 $840 1 Includes grading and reseeding I Inspections/Reports LS $1 500.00 1 $1,500 Includes quality assurance inspection during

repairs

DesignProject Management LS $1,000.00 1 $1,000

First Year O&MSubtotal I I I 1 $3,340 1 I Long-term Care

CERCLA 5-yr Reviews I 5-yr I $3,000.00 I 6 $6,472 Present worth, 5-yr reviews for 30 yrs

Table B-1. Soil Alternative 3 - SWMU 35 Costs Anniston Army Depot, Ammunition Storage Area Anniston, Alabama (Continued)

Description Unit Unit Cost Number of Units b m Cost Comments

InspectionlReportslRepairs 9-yr $1,000.00 $1,000 Repairslinspections every 9 years for 30 yrs

Present Worth Long-term Care Subtotal $7,472

Total Present Worth of O& M and Long Term Care $10,812

Total Present Worth of Alternative $77,127

AL = Alabama. ANAD = Anniston Army Depot. CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act of 1980. O&M =Operation and maintenance. RT = Round trip. SWMU = Solid Waste Management Unit. CY = cubic yard hr = hour LF = linear foot LS = lump sum Yr = yeart

Appendix B

Table B-2. Summary of Discounted and Non-Discounted Costs for Alternative 3 Monitored Natural Attenuation (New & Existing Well Network) and Land Use Controls

Anniston Army Depot, Ammunition Storage Area, Anniston, Alabama

Base Management Plan (hrs) 1 24 Baseline Sampling Year 1 I Obtain samples (event) Analytical Cost (event) Develop S&A and O&M Plan (hrs) Baseline Report (hrs) Geophysical Survey

Install Monitoring Wells (ea) Sampling & Analysis of Monitored Natural Attenuation Parameters Obtain Samples (lot) A n a w l Cost (lot) Develop S&A Plan (hrs) Develop Groundwater Model and Report 1 240

Sampling & Analysis of IDW I Ana~yt i i~ Cost (lot) I I

Subtotal Design and Project Management Office Overhead Field Overhead

Subtotal Continaencv " a

Total Capital Costs (Non-Discounted) Total Capital costs (Discounted) O&M COSTS Sample Existing Wells (events) (9 years) 9 $24,000 $24,000 $216,000 Sample Analysis (events) (9 years) 9 $20,934 $20,934 $188,406 Annual Report (hrs) ( 9 years) 240 $65 $1 5,600 $140,400 Maintenance of Wells (event) (9 years) 9 $1 ,ooO $1,000 $9,000 Five-Year Reviews (hrs) (2 events) 120 $65 $7,800 $15,600 Well Abandonment (ea) (1 event) 38 $1,125 $42,750 $42,750

Subtotal $1 12,084 $612,156 Design and Project Management 10% $61,216 Office Overhead 5% $30,608 Field Overhead 15% $91,823 Subtotal $792,787 Contingency 25% $198,197 Total O&M Costs (Non-Discounted) $994,754 Total O&M Costs (Discounted) 7% $1,353,223 Total Ca~ital and O&M Costs INon-Discounted $1.460.450 , . , . Total ~ a b t a l and O&M Costs i~iscounted) ' I 1 1,986,737

IDW = Investigation-derived waste. ea = each hrs = hours. O&M = Operation and Maintenance.

Record of Decision B-4 Final July 2006 Anniston Army Depot

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