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Final Building 83 Explanation of Significant Differences

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Final Building 83 Explanation of Significant Differences FINAL EXPLANATION OF SIGNIFICANT DIFFERENCES INSTALLATION-WIDE OPERABLE UNIT LAKE CITY ARMY AMMUNITION PLANT, INDEPENDENCE, MISSOURI November 2019 Prepared for: U.S. Army Environmental Command 2450 Connell Road, Bldg. 2264 Fort Sam Houston, TX 78234 Prepared by: Environmental Chemical Corporation (ECC) 1746 Cole Blvd., Bid. 21, Suite 350 Lakewood, CO 80401 Contract No.: W91ZLK-13-D-0014, Delivery Order 0005 40560808 Superfund FINAL EXPLANATION OF SIGNIFICANT DIFFERENCES INSTALLATION-WIDE OPERABLE UNIT LAKE CITY ARMY AMMUNITION PLANT, INDEPENDENCE, MISSOURI Contract No.: W91ZLK-13-D-0014, Delivery Order 0005 I hereby certify that the enclosed Explanation of Significant Differences, shown and marked in this submittal, is in compliance with the contract specifications and is submitted for government approval for the Environmental Remediation Services at Lake City Army Ammunition Plant, Independence, Missouri. Approvals 25 November, 2019 Project Manager - Michael Klosky, PE Date (MO #2006007191, expires 12/31/2020) Authorizing Signature This signature sheet documents the United States Environmental Protection Agency approval of the Final Explanation of Significant Differences Installation-Wide Operable Unit, Lake City Army Ammunition Plant, Independence, MO. Declared by: CP>U____________________ gsW8<a|C| I LTC Dana Crow Date I Commander j Lake City Army Ammunition Plant ! I I I N cu- l & l^o Xro \ t0l J.'LAiT') Mary P. Petej}s< Date Director, Superfund and Emergency Management Division United States Environmental Protection Agency, Region 7 I TABLE OF CONTENTS 1.0 INTRODUCTION................................................................................................1-1 2.0 SITE HISTORY, CONTAMINATION AND SELECTED REMEDY.................2-1 2.1 LCAAP Site History..................................................................................... 2-1 2.1.1 IWOU Contamination and Selected Remedy.....................................2-1 3.0 BASIS FOR THIS EXPLANATION OF SIGNIFICANT DIFFERENCES........3-1 3.1 Former Building 83 Site Description and Background.............................. 3-l 3.2 Previous Investigations................................................ 3-1 3.3 Risk Evaluation...........................................................................................3-2 3.4 Identification of Contaminants of Concern................................................. 3-3 3.5 Engineering Evaluation and Cost Analysis and Action Memorandum.....3-3 3.6 Removal Action 3-4 4.0 DESCRIPTION OF SIGNIFICANT DIFFERENCES........................................4-1 5.0 REGULATORY COMMENTS........................................................................... 5-1 6.0 STATUTORY DETERMINATION.............................................................. 6-1 7.0 PUBLIC PARTICIPATION................................................................................7-1 8.0 REFERENCES.................. 8-1 TABLES Table 3-1 Summary of Confirmatory Soil Sampling Results Table 3-2 Action Levels FIGURES Figure 1-1 LCAAP Location Map Figure 1-2 LCAAP Installation Layout Figure 3-1 Former Building 83 Location Map Figure 3-2 Site Map for Former Building 83 Figure 3-3 Post Remediation Site Conditions Figure 3-4 Former Building 83 Confirmatory Soil Sampling APPENDICES Appendix A LUCIP Revisions Appendix B Regulatory Response to Comments 1 ACRONYMS AND ABBREVIATIONS ACM Asbestos containing materials AOC Area of Concern Army United States Army CERCLA Comprehensive Environmental Response, Compensation and Liability Act CFR Code of Federal Regulations COC contaminant of concern CSR Code of State Regulations EE/CA Engineering Evaluation / Cost Analysis ESD Explanation of Significant Differences FFA Federal Facilities Agreement IWOU Installation-Wide Operable Unit LCAAP Lake City Army Ammunition Plant LS lead styphnate LUC Land Use Control LUCIP Land Use Control Implementation Plan MDNR Missouri Department of Natural Resources MO Missouri mg/kg milligrams per kilogram NCP National Contingency Plan ORM Other Regulated Material OU Operable Unit PCB polychlorinated biphenyls ppm parts per million RAO Remedial Action Objective RCRA Resource Conservation and Recovery Act RD/RAWP Remedial Design/Remedial Action Work Plan ROD Record of Decision RSL Regional Screening Level SI Site Investigation SVOC semi-volatile organic compound TA Request for Temporary Authorization for Demolition of Building 83 TCS thermal convection system TCE trichloroethene TNR Trinitroresorcinol USATCES United States Army Technical Center for Explosives Safety USEPA United States Environmental Protection Agency UU/UE Unlimited use and unrestricted exposure VOC volatile organic compound 11 Explanation of Significant Differences, Installation Wide Operable Unit Environmental Remediation Services. Lake City’ Army Ammunition Plant Contract No.: W91ZLK-13-D-0014, Delivery Order 0005 1.0 INTRODUCTION This document is an Explanation of Significant Differences (ESD) for the Record of Decision (ROD) at the Lake City Army Ammunition Plant (LCAAP or Installation), Independence, Missouri (MO) (United States Environmental Protection Agency [USEPA] Identification: MO3213890012) (Figure 1-1) for the Installation-Wide Operable Unit (IWOU) (USEPA, 2008). The purpose of this ESD is to add Former Building 83 as an Area of Concern (AOC) with a Land Use Controls (LUC) remedy into the IWOU ROD and associated IWOU Land Use Control Plan (LUCIP) (Appendix C of the IWOU Remedial Design/Remedial Action Work Plan [RD/RAWP; ARCADIS, 2008]). The addition of Former Building 83 as an AOC to the IWOU ROD and LUCIP will allow Former Building 83 to be closed as a separate operable unit. The IWOU ROD was signed by the United States Army (Army), the USEPA and the Missouri Department of Natural Resources (MDNR) in 2008 (USEPA, 2008). The IWOU ROD addressed contaminated soil and groundwater at 30 AOCs, Figure 1-2. This ESD, prepared in accordance with Section 117(c) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Superfund Amendments and Reauthorization Act of 1986, and the National Contingency Plan (NCP), Title 40 of the Code of Federal Regulations (CFR) Part 300, Section 435 (c)(2)(i) (40 CFR 300.435(c)(2)(i)), and documents significant differences to the selected remedies identified in the above ROD concerning the long-term management of Former Building 83. This ESD does not impact the remaining components of the selected remedies identified in the above referenced ROD. The Army acts as the lead agency for CERCLA activities at LCAAP. The USEPA and MDNR act as lead regulatory agencies, ensuring that cleanup activities conducted by the Army meet the requirements of CERCLA, the Superfund Amendments and Reauthorization Act of 1986, the NCP, and the site's Federal Facility Agreement (FFA). The purpose of this ESD is to provide information in support of a modification to the portions of the selected remedy described in the above referenced ROD for the implementation and management of LUCs at Former Building 83. This ESD summarizes information that led to the proposed changes to the remedy and confirms that the remedy will still comply with the statutory requirements of CERCLA. The two site-specific changes to the ROD, presented in greater detail herein, include: 1) The addition of Former Building 83 as an area of concern 2) The identification of LUCs as the selected remedy at Former Building 83. These proposed changes do not fundamentally alter the overall remedy for the applicable Operable Units (OUs) and are appropriately addressed in this ESD. This ESD will become part of the Administrative Record pursuant to Section 300.825 (a)(2) of the NCP. An Administrative Record containing information associated with CERCLA cleanup activities at the LCAAP was established in Building 6 at the LCAAP. In addition, an i-i Explanation of Significant Differences, Installation Wide Operable Unit Environmental Remediation Services, Lake City Army Ammunition Plant Contract No. : W91ZLK-13-D-0014, Delivery• Order 0005 electronic copy of the Administrative Record is maintained at the Mid-Continent Public Library, North Independence Branch (Independence, MO). All documents in the Administrative Record are available to the public. 1-2 Explanation of Significant Differences, Installation Wide Operable Unit Environmental Remediation Services. Lake City Army Ammunition Plant Contract No. : W9IZLK-I3-D-00I4, Delivery Order 0005 2.0 SITE HISTORY, CONTAMINATION AND SELECTED REMEDY 2.1 LCAAP Site History LCAAP is an active, Government-owned, Contractor-operated facility encompassing 3,935 acres located at the intersection of Highways 7 and 78, between Independence and Blue Springs, MO (Figure 1-1). LCAAP was established in 1941 to manufacture and test small caliber ammunition for the Army and has remained in continuous operation except for one 5-year period from 1946 to 1950. LCAAP is the only major small arms manufacturing facility for the Army. The USEPA proposed adding LCAAP to the National Priorities List on October 15, 1984. Final listing occurred on July 22, 1987, effective August 21, 1987. The Army, MDNR, and USEPA Region 7 signed a CERCLA Section 120 FFA that went into effect on November 28, 1989. Contaminants of concern (COCs) for the IWOU include volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), metals, perchlorate, polychlorinated biphenyls and explosives. • LCAAP land uses are classified as industrial for the purpose of identifying potential human receptors and exposure
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