TENANT ACTIVITIES33
The installation provides host support to five tenant activities, including USADACS, an Occupational Health Nursing Office, the Defense Reutilization Marketing Office (DRMO), the
300th Supply Company, and the Defense Printing Service (DPSDO). Current tenant activities are summarized below:
U.S. Army Defense Ammunition Center and School (USADACS)—The U.S. Army Ordnance Ammunition, Surveillance and Maintenance School was activated at the installation in 1950. Additional school facilities were added in 1965 and a special weapons workshop was added in 1970. The school was redesignated the Army Material Command (AMC) Ammunition School in 1966 and the U.S. Army Material DARCOM Ammunition Center in 1971. Seven years later, in 1979, the center was redesignated as USADACS to recognize its central role in the implementation of the U.S. Army’s new mission to manage conventional ammunition for all of DOD. USADACS trains approximately 5,000 DOD military, civilian, and allied students every year in logistics, explosives safety, and a wide scope of Army and Joint Service ammunition items. Logistics engineers at USADACS provide procedures worldwide to ensure safe handling, transportation, and storage of ammunition and explosives. They design, prototype, and field APE; validate procedures and equipment; and provide instrumentation support onsite. Through the Demilitarization Technology Office, USADACS manages demilitarization research and development initiatives for the Army’s conventional ammunition and Joint Service large rocket motors. USADACS focuses on resource recovery, recycling, and developing environmentally acceptable alternatives to open burning, open detonation, and incineration of unwanted ammunition and explosives. Through the U.S. Army Technical Center for Explosives Safety (USATCES), USADACS provides explosives and chemical agent safety technical information and assistance to support the Headquarters of the Department of the U.S. Army (HQDA), major army commands (MACOMs), and the safety community Army‑wide. USATCES manages the Joint United States and Republic of Korea research and development (R&D) project to design and test new underground ammunition storage technologies.
Occupational Health Nursing Office—The Occupational Health Nursing Office is staffed by an occupational health nurse, medical clerk, and a part‑time occupational medical physician. The office provides physical examinations, immunizations, and treatment for minor illnesses for all civilian and military employees of the installation. The primary focus of the Occupational Health Nursing Office is to recognize and prevent work‑related injuries and illnesses.
Defense Reutilization Marketing Office (DRMO)—DRMO provides disposal services for surplus property generated by the military services, primarily through reutilization, transfer, donation, and sales. DRMO also is responsible for a Precious Metals Recovery Program and the disposal of hazardous property, and supports military communities with a Resource Recovery and Recycling Program. Other responsibilities include processing Federal property donations to states and friendly foreign countries. The DRMO property inventory includes air conditioners, automobiles, tents, typewriters, desks, scrap metal, and other wastes and materials. Information, including quantity, condition, and location of the property, is provided weekly to supply and procurement activities of the military services and the General Services Administration (GSA).
300th Supply Company—The 300th Supply Company, U.S. Army, falls under the 213th S&S Battalion, Wausau, Wisconsin, belonging to the 86th Army Command (ARCOM), Forest Park, Illinois. The unit’s mission is to receive, store, process, and perform in‑storage maintenance, and to issue all types of self‑propelled, towed, wheeled, and tracked equipment (Class VII) to division and nondivisional support units. All combat vehicles are combat loaded, as required, prior to issue. The unit’s mission also includes the receipt, storage, and issue of bridging equipment and fortification and construction materials.
Defense Printing Service (DPSDO)—Established in 1965 by the U.S. Navy, printing operations were conducted in Building 134 of USADACS until 1993. The basic function of the print shop was to perform all printing operations for the installation. Printing services were discontinued and replaced by reproduction processes because of the safety and environmental concerns caused by the many chemicals that were used during the printing process. It was reported in 1993 that approximately 76 gallons of various chemicals were used at this facility. No air pollution control devices (APCDs) were used in the print shop while it was in operation.
Past tenant activities include a Forest Management Program that was initiated in 1962. This program permitted the sale of timber that resulted from the cutting of mature trees. It is unknown what, if any, equipment and buildings were used during this program.
PERMITTING STATUS34
The following sections describe SVDA’s permitting/regulatory status pursuant to the Resource Conservation and Recovery Act (RCRA) (Section 3.4.1); CERCLA (Section 3.4.2); the National Pollutant Discharge Elimination System (NPDES) (Section 3.4.3); and solid waste (Section 3.4.4), air (Section 3.4.5), water supply (Section 3.4.6), and underground storage tank (UST) (Section 3.4.7) regulations and programs.
RCRA Status341
SVDA is a RCRA large‑quantity generator, hazardous waste treatment facility, hazardous waste storage facility, and hazardous waste transporter with RCRA interim status (Appendix B). SVDA’s U.S. Environmental Protection Agency (USEPA) identification number is IL3210020803.
In 1994, SVDA generated 161,408.8 pounds of hazardous waste from the following sources (SVDA 1995g):
Reactive waste from ammunition demilitarization (USEPA hazardous waste code D003) (132,348.8 pounds)
Incinerator ash containing arsenic, cadmium, chromium, and mercury (USEPA hazardous waste codes D004, D006, D007, and D009) (4,858 pounds)
Smoke pot ash containing lead (USEPA hazardous waste code D008) (3,150 pounds)
Corrosive liquid containing sulfuric acid or potassium and sodium hydroxides (USEPA hazardous waste code D002) (2,849 pounds)
Waste paint and related materials (e.g., waste paint, grindings, and filters) (17,212 pounds)
Solvents, including waste petroleum naphtha and Safety Kleen® degreaser (USEPA hazardous waste code D001) (622 pounds)
Waste poisonous liquid and dieldrin insecticide (USEPA hazardous waste code P037) (40 pounds)
Waste flammable liquids (chemical agent test kits) containing ethanol and mercuric cyanide (USEPA hazardous waste codes P030, D001, and D009) (109 pounds)
Paint chips containing lead and cadmium (USEPA hazardous waste codes D003, D006, and D008) (220 pounds).
No disposal of hazardous waste occurs on the installation (SVDA 1992a). Hazardous waste generated at SVDA is disposed of offsite, and its removal and disposition is the responsibility of the DRMO. When necessary, DRMO collects waste from hazardous waste storage areas E1414, E704, and H420 (see Section 3.4.1.1) (Clarke 1996). Appendix G presents SVDA’s hazardous waste manifest log for the period between 1985 and 1994.
SVDA submitted a Part A Permit Application to USEPA Region V in November 1980. The Part A Permit Application has been revised several times since it originally was submitted. SVDA subsequently submitted a RCRA Part B Permit Application to the State of Illinois on 8 October 1985 (IEPA 1995e). The application has been revised a number of times in response to regulatory comments; the most recent version is dated 31 October 1993, with revised pages dated 3 March 1994. The Part B Permit Application has not been approved and SVDA continues to operate under RCRA interim status. The Part B Permit Application requests a permit for the following units:
Four hazardous waste storage units located in Buildings E701, E702, E704, and E1414
An explosive waste incinerator (EWI)
An open burning/open detonation (OB/OD) facility.
These units, as well as 90‑day hazardous waste storage areas and satellite accumulation areas for hazardous waste located at SVDA, are described in the following sections.
Hazardous Waste Storage Facilities3411
SVDA’s hazardous waste storage units are identical igloo‑type buildings designed to store ammunition. Buildings E701 and E702 were used to store 55‑gallon drums of lead azide sludge generated at SVDA from a lead azide electrolysis process that no longer is used. The lead azide sludge was removed in December 1997 (Clarke 1997). Building E704 is used to store potentially reactive wastes, including open burning ash and baghouse dust generated by a contaminated waste processor (CWP) and an APE 1236 Deactivation Furnace (which processed hazardous waste in the past, but is no longer operational). In addition, ignitable wastes are stored in Building E704. Building E1414 is used to store other hazardous wastes (including listed hazardous wastes and characteristic wastes) or suspected hazardous wastes (pending receipt of analytical results). The wastes usually are stored in their original containers or in 5‑, 30‑, 40‑, or 55‑gallon containers (SVDA 1993d). A records review conducted during the EBS confirmed that SVDA personnel inspect Buildings E701, E702, E704, and E1414 weekly and maintain records of the inspections.
EWI (Building 2217) Treatment Facility3412
The EWI was built to demilitarize off‑specification and outdated munitions and disaggregated propellants from the current inventory of munitions stored at SVDA and to dispose of bulk propellants and explosives wastes generated during the manufacture and assembly process. Although the EWI was designed to treat hazardous wastes, it never has been used. Consequently, no wastes or residues have been generated as a result of operation of the EWI.
OB/OD Treatment Facilities3413
The OB/OD site is located within SVDA in a remote area inside the western boundary of the installation, along the Mississippi River. Reactive hazardous wastes in the form of propellants and explosives are managed at the OB/OD grounds. Although OB activities historically were conducted at a number of different areas in the vicinity of the OB/OD grounds, the Part B permit application was submitted for the newest OB pad (Site 50). The remaining OB areas are inactive and are undergoing evaluation under CERCLA (Sites 13 and 14). The existing OD area will continue to be used for open detonation (SVDA 1993d). The OD site was used almost daily in 1991 (IEPA 1991a). Currently, the amount of activity at the OD pad is determined by the amount of funding available for the demolition of explosives. The OB pad is not used except for emergencies; the last burn occurred in 1985.
The OB pad is designed to burn propellants that become obsolete or unstable. The dimensions of the OB pad are 300 feet long by 70 to 80 feet wide, generally running east to west. Standard procedures require that propellants be placed in pans prior to burning. OB pans are made of ¼‑inch carbon steel and are 5.5 feet wide, 16 feet long, and 13 inches deep. The propellants are layered at a depth of no greater than 3 inches in each pan, with each pan holding approximately 1,000 pounds. Each pan is elevated above a concrete pad by steel I‑beams (SVDA 1993d).
After the propellants are burned and cooled, operators collect ash from the pans with a brush or whisk broom, shovels, and a dustpan, and place the ash in a U.S. Department of Transportation (DOT)‑approved drum. The ash drum then is transferred to Building E704 where it is stored between OB events. All wastes treated by OB are characteristic only, exhibiting the characteristics of reactivity and/or toxicity as defined by the toxicity characteristic leaching procedure (TCLP). No USEPA‑listed wastes are treated at the OB pads. The waste residues resulting from OB are tested first for reactivity to confirm that OB has treated the reactivity characteristic, and then for the toxicity characteristic. If the residue is nonhazardous, it is disposed of offsite as solid waste. If the ash is characteristic for toxicity, it is disposed of offsite at a permitted RCRA facility (SVDA 1993d).
The OD site is used to detonate projectiles and ordnance that become obsolete. OD takes place in earthen pits. The construction material used for the OD site is uncompacted fill (loose soil). The OD ground has two long berms with three pits per berm. The OD operators transfer no more than 165 pounds net explosive weight (NEW) of projectiles and/or ordnance to a pit. Each pit is not less than 4 feet deep and covered with not less than 4 feet of earth. If OD takes place aboveground, the NEW limit is 10 pounds. As with OB operations, all wastes treated by OD are USEPA characteristic wastes only, exhibiting either the characteristic of reactivity, toxicity, or both. No USEPA listed wastes are treated at the OD site. After each series of shots (up to six pits), a search is made of the surrounding area for unexploded material. Material such as lumps of explosives or unfuzed ammunition is collected and prepared for the next round of shots (detonation). Fuzed or unstable ammunition, as determined by the supervisor and/or QA representative, is detonated in place (SVDA 1993d).
90‑Day Hazardous Waste Storage Areas3414
Buildings H420 and C101 are designated as 90‑day hazardous waste storage areas (SVDA 1992a). At one time, Building E1601 was designated as a 90‑day hazardous waste storage area, but no hazardous wastes have ever been stored there (Clarke 1996, SVDA 1993d). Wastes collected in SVDA’s satellite accumulation areas are transported to Building H420, E1414, or E704 for storage prior to disposal (Clarke 1996).
Building H420 is used as a 90‑day hazardous waste storage area as well as a storage area for electrical transformers. During the EBS site visit, it was noted that a small pallet of spray paint cans, polychlorinated biphenyl (PCB) transformers, and non‑PCB transformers were stored in Building H420.
Building C101 is designated to receive propellants, explosives, and pyrotechnics (propellants and explosives) stored in two military vans at the OB/OD site when circumstances, such as inclement weather, prevent the materials from being detonated as scheduled. Such a situation never has occurred; consequently, Building C101 never has been used as a 90‑day hazardous waste storage area. If materials could not be detonated as schedule, the waste at the OB/OD site is a RCRA hazardous waste and SVDA’s procedures require transferring the munitions from the military vans by a flatbed truck and/or a tractor trailer to the 90‑day storage unit. Upon arrival, a label is to be placed on the propellants and explosives, identifying them as hazardous waste and acknowledging the date of arrival for tracking the 90‑day storage limit. The propellants and explosives will be burned or detonated the following day if weather permits, or soon thereafter (SVDA 1993d).
Satellite Accumulation Areas for Hazardous Waste3415
SVDA’s Waste Management Plan (SVDA 1992a) identified four satellite accumulation areas for hazardous waste: the cement pad under the baghouse at the EWI/CWP complex; the Motor Pool (Building 103); the APE Fabrication Shop (Building 117); and the Pilot Model Shop (Building 140). The cement pad under the baghouse at the EWI/CWP complex has been used for approximately 10 years as a collection site for carbottom ash generated at the CWP (Clarke 1996). The satellite accumulation areas at the Motor Pool, the APE Fabrication Shop, and the Pilot Model Shop have been used since the 1950s to store primarily nonhazardous wastes, coolants, and lubricants. When 55 gallons of wastes are accumulated, a pallet is filled, or a job is completed, the materials accumulated in these buildings are transported to one of the storage areas in Building H420, E1414, or E704 for ultimate disposal (Clarke 1996).
CERCLA Status342
In January 1979, the U.S. Army completed an investigation of past and current uses of toxic and hazardous materials at SVDA and their likelihood for release. The results of this investigation are provided in the U.S. Army Toxic and Hazardous Materials Agency (USATHAMA) Installation Assessment (USATHAMA 1979). A Preliminary Assessment of SVDA subsequently was performed in January 1984, a Hazard Ranking was completed in August 1984, and the installation was proposed for the NPL in October 1984. With a Hazard Ranking System (HRS) score of 42.2, SVDA was listed on the final NPL in March 1989. A Preliminary Draft Remedial Investigation (RI) report that addressed 30 sites was completed by Dames & Moore in June 1994. Engineering Evaluations/Cost Analyses (EECAs) were developed for the SAA Burn Area and the Artillery Ballistic Test Site (Sites 15 and 33), the CF and CL Plant Areas (Sites 3 and Sites 24 through 28), the Open Burning Ground (Sites 13 and 14), and the Fire Training Area (Site 67) in July 1995, April 1995, February 1994, and October 1993, respectively. Soil remediation has been completed at the Trinitrotoluene (TNT) Washout Facility (Sites 21 and 22) and the Fire Training Area (Site 67). Design activities to remove metals and explosives‑contaminated debris at the Old Burning/Demolition Ground are in progress. Closure of a deactivation furnace (APE 1236) also was completed in January 1996. Remediation has not yet been initiated at the CF and CL areas. The EECA for Sites 15 and 33 is still under review, and remediation of this area will not be addressed until funding issues are resolved (Clarke 1996).
NPDES/State Permits343
SVDA was issued an NPDES permit (number IL0027049) by the Illinois Environmental Protection Agency (IEPA) on 28 August 1996 (IEPA 1996c). The permit is effective from 1 September 1996 through 31 August 2001 (IEPA 1996c). The permit authorizes SVDA to discharge from the STP at Outfall 001 on the Apple River. Monitoring requirements include pH, five-day BOD, and total suspended solids. A permit for storm water discharge is not required because of SVDA’s Standard Industrial Classification (SIC) code was not listed in the stormwater regulations.
On 16 April 1993, SVDA was issued IEPA Permit 1993‑SC‑2894, which allows the application of approximately 40,000 gallons per year of aerobically digested sewage sludge to agricultural lands at rates not to exceed the agronomic nitrogen demand of the crop grown. The permit has a number of special conditions, including the requirements that SVDA semiannually submit to IEPA a summary of the quantity of sludge generated and disposed of, and that annual sampling and analysis of the sludge be performed. The operating permit expires on 31 March 2003 (Clarke 1999). SVDA has disposed of sewage sludge at either of two locations on the installation since 1988 (with the exception of 1995) (Melaas 1996). The land application of sewage sludge is discussed further in Section 4.1.12.4.
On 30 April 1993, SVDA was issued IEPA Permit 1993‑GB‑2883, which allows SVDA to construct water pollution control facilities consisting of replacement of the sludge removal and surface skimming equipment in the existing primary and secondary clarifiers, and conversion of the existing anaerobic digester to an aerobic digester using a submerged turbine aerator. The permit does not have an expiration date.
Solid Waste Permits344
SVDA has no Federal solid waste disposal permits. A 12.86‑acre closed sanitary landfill consisting of two cells is located near the H‑Area. The landfill is lined with a 5‑foot clay liner with a maximum permeability of 1 × 10‑8 cm/sec. The landfill is identified by IEPA as facility number 0158100002. It has operated under IEPA permit numbers 1982‑2‑DE‑EX, 1982‑127‑SP, 1984‑1‑OPX, 1989‑01‑OPX, and most recently under IEPA experimental permit number 1991‑001‑OPX, issued on 20 March 1991. Permit 1991‑001‑OPX expired on 19 March 1993; however, the landfill ceased operation prior to that date (IEPA 1991c). Cell #1 ceased accepting waste on 30 May 1990 and was closed on 15 June 1991 (IIW 1995). Cell #2 ceased accepting waste effective 18 September 1992 (IEPA 1992), and closure of Cell #2 was completed on 19 November 1993 (IEPA 1993). In February 1995, SVDA submitted to IEPA a certification of completion of closure, and the State of Illinois subsequently determined in April 1995 that the landfill had been closed in accordance with the closure plan (IEPA 1995d). The 15‑year post‑closure care period for the landfill began on 23 November 1993. Quarterly monitoring of eight groundwater monitoring wells is conducted at the landfill and will continue through the post‑closure care period.
During operation, the landfill received noncontaminated packaging material and wood, household waste, and general office waste. In 1991, it was reported that SVDA produced approximately 1,900 cubic yards of uncompacted solid waste per year, 70 to 90 percent of which was office paper (SVDA 1991f). Since closure of the sanitary waste landfill, solid wastes have been collected and disposed of offsite by Moring Disposal in Forreston, Illinois (Clarke 1996).
Air Permits345
On 4 January 1996, IEPA granted SVDA a Federally Enforceable State Operating Permit (FESOP) (ID #015810AAB) (IEPA 1996b) to operate emission sources and air pollution control equipment consisting of the following:
Oil‑fired combustion sources, including a total of 53 boilers, heaters, hot air units, and space heaters, and 6 stationary emergency generators
Fuel storage tanks and dispensing operations, specifically, 7 aboveground storage tanks (ASTs) and 35 USTs
A CWP (Building 2215), which is controlled by a gas cooler, cyclone, and baghouse
Welding operations conducted in the APE Shop (Building 117), Pilot Model Shop (Building 140), and Sheet Metal Shop (Building 124)
Grinding operations
Five surface coating (i.e., paint) booths located in the APE Shop (Building 117); Pilot Model Shop (Building 140); CF Plant Receiving, Inspection and Painting Building (Building 711); Surveillance Workshop (Building 716); Stencil, Packing, and Shipping Building (Building 742); Special Weapons Depot (Building 802); and Less‑Than‑Carload (LCL) Building (Building 933)
Nine solvent degreasing units located in the Vehicle Maintenance Shop (Building 103); Water Supply/Treatment Building (Building 107); Heating Plant (Building 114); Roundhouse (Railroad Equipment/Engineering Maintenance) (Building 115); APE Shop (Building 117); Pilot Model Shop (Building 140); CF Plant Heating Plant (Building 704); CF Plant Receiving, Inspection, and Painting Building (Building 711); and the Surveillance Workshop (Building 716)
Woodworking operations conducted in the Carpentry Shop (Building 122) and Transportability Test Facility (Building 140)
Photographic/printing operations conducted in the Photography Laboratory (Building 54) and the X‑Ray Laboratory (Building 507)
Firefighter training operations
Wastewater treatment operations
SVDA personnel (Bahr 1996) noted that, although addressed under the FESOP, no surface coating booths are located in Buildings 716 and 802. Moreover, Buildings 711 and 742 each contain two surface coating booths.
The FESOP includes conditions that limit the air emissions from each of the above activities. The permit also includes monitoring, recordkeeping, and reporting requirements to ensure that the control measures are being carried out. The FESOP expires on 1 January 2001 (IEPA 1996b).
Water Supply Permits346
SVDA is identified as Facility Number 0155077 by IEPA’s Division of Public Water Supplies. Four drinking water wells are located on the installation. The wells are installed at depths between 1,115 and 1,205 feet below land surface (BLS). Well #1 (Building 107) has a capacity of 650 gallons per minute (gpm), Well #3 (Building 701) has a capacity of 700 gpm, and Well #12 (Building 260) has a capacity of 600 gpm (IEPA 1994). Well #2 (Building 645) is out of service (Roberts 1996, IEPA 1994). SVDA maintains a 250,000‑gallon elevated storage tank (Building 904) that was built in 1950 (SVDA 1979b). Drinking water is distributed through approximately 139,000 feet of water mains, which are cast iron, ductile iron, or asbestos‑cement pipes between 4 and 12 inches in diameter (IEPA 1994).
SVDA’s water supply is both chlorinated and fluoridated at three Treatment Application Points (TAPs). Water from Wells #1, #3, and #12 is chlorinated and fluoridated at TAP 01, TAP 03, and TAP 04, respectively. Chlorine is provided by a gas chlorination system at each TAP. Each pump house is equipped with a separate vented chlorine room where 150‑pound chlorine gas cylinders are chained. Fluoridation is provided by undiluted 23 percent hydrofluorosilic acid injected into the well discharge line from a scale‑mounted solution drum at each well site (IEPA 1994).
The IEPA Division of Public Water Supplies issued SVDA a Public Water Supply Construction Permit (Permit No. 0091‑FY1995) on 13 March 1995 that grants SVDA permission to inject a proprietary blended phosphate product at three drinking water wells to control lead corrosion. The permit allows SVDA to construct or install three metering pumps at a maximum capacity of 2 gallons per hour (gph), piping, and necessary controls and appurtenances. During an inspection on 9 June 1994, the IEPA inspector noted that SVDA was not maintaining adequate fluoridation of their water supply and that the facility required a standard operating procedure (SOP) for cross‑connection control requirements (IEPA 1994). These issues were resolved promptly (Stewart 1996).
UST Permits347
Fifty‑two USTs located at SVDA are registered with the State of Illinois. A data base search (Appendix B) revealed that seven incidents involving leaking USTs (LUSTs) have been reported to IEPA. The status of present and former USTs at SVDA is discussed in Sections 4.2.
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