Appendix M: Installation Narrative Summaries - denix

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The Milan Army Ammunition Plant (AAP) handles explosive
ordnance. EPA placed the installation on the NPL in July 1987,
and the Army and EPA signed an interagency agreement (IAG)
in 1989. In FY91, the Army discovered the explosive compound
RDX in the City of Milan's municipal water supply wells. In
FY94, the installation formed a Restoration Advisory Board
(RAB). Representatives of the Army, the City of Milan, EPA,
and the State of Tennessee completed a contingency plan to
ensure that safe drinking water would be available to residents.
The city completed a new drinking water well field in 1998 using
funds provided by the Army. The installation completed 5-year
reviews in FY01 and FY05.
Since FY87, preliminary assessments (PAs) and site inspection
(SI) activities conducted at Milan AAP identified 25 sites
requiring further investigation. Subsequent studies expanded
the number of sites to 39. The installation grouped the sites into
five operable units (OUs). To date, the installation has signed
six Records of Decision (RODs), including one in FY92 for OU
1 groundwater treatment plant construction, one in FY93 to
extend a cap over the former O-Line Ponds soil, one in FY00
for the groundwater treatment facility construction at the
Western Boundary Area (OU 4 Region 1), and an interim ROD
for OU 5 in FY04. The cleanup progress at Milan AAP for FY02
through FY05 is detailed below.
In FY02, the Army completed construction and began operation
of a groundwater treatment facility for the Western Boundary
Area (OU 4). The installation completed bioremediation of
explosives-contaminated soil at Lines H and Z, and Areas M
and N. The regulators approved the draft feasibility study (FS)
for overall groundwater contamination. The Army submitted the
draft ROD for OU 4 Regions 2 and 3 to the regulators. The
Army completed remediation of the Y-103 rail classification
yard. The installation continued operation of the OUs 1 and 3
groundwater treatment systems.
In FY03, the installation continued operation of the OUs 1, 3,
and 4 groundwater treatment systems. The composting of Line
X contaminated soil proceeded on schedule. The installation
began two studies for examining groundwater quality. The Army
completed an inventory of the closed, transferred, and
transferring ranges and sites with unexploded ordnance (UXO),
Army
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discarded military munitions, or munitions constituents. The
inventory identified one closed site totaling 263 acres within the
installation's boundaries where there is possible UXO and
medium explosives safety risk.
In FY04, the Army awarded a performance-based contract for
the Installation Restoration Program (IRP) activities at Milan
AAP. The installation signed an interim ROD for OU 5. The
Army selected an interim ROD instead of a final ROD because
it will address groundwater issues in the installationwide
groundwater ROD. The installation continued operation of the
OU 1, 3, and 4 groundwater treatment systems. The Army
conducted pilot studies on the use of carbohydrates to
determine the applicability of these materials to biologically
degrade explosive compounds in groundwater. The installation
completed a PA for the Military Munitions Response Program
(MMRP) site and initiated the SI.
In FY05, the Army completed characterization of all
explosives-contaminated soils within the Northern Industrial
Areas of the facility. Milan AAP began injection of
carbohydrates to determine treatment capability for a
groundwater plume located within the OU 1/OU 2 area. The
installation produced a conceptual site model report to begin
evaluating a remedy for groundwater treatment. The Army
submitted technical memoranda to the regulatory community in
an effort to enhance groundwater treatment facilities
capabilities. In addition, the installation completed a 5-year
review and found no deficiencies. Based on the data generated
during the pilot study within OU 5, the Army was unclear about
whether the use of a carbohydrate for in situ treatment of soils
was appropriate. Due to the low volume of soil exceeding
remedial action (RA) goals, ex situ treatment appeared to be
the most efficient and economical means of treatment. The
Army submitted an SI report for comments for the MMRP sites.
The installation attended partnership training sessions with the
State, EPA, and Army, and established a charter to address
issues that would allow expedited remediation of Milan AAP.
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Milan AAP completed soil characterization and excavation for
all production lines. EPA Region 4 indicated some concerns
about whether the installation statistically evaluated its
sampling procedures. Based on review of documentation
provided by the regulators as well as other sources of
information, it appears that the Army can statistically validate
the soils sampling protocols used for determining cleanup. The
installation completed pre-design delineation of all off-site
groundwater plumes. Additional delineation will be required
during the design stage after three groundwater RODs are
completed. The installation also developed and submitted a
draft FS for groundwater to the regulatory community.
Comments were received from EPA and the State of
Tennessee, which identified unresolved issues about RA
objectives and preliminary remedial goals. A Tier II group of
management from EPA Region 4, State of Tennessee, Army
Environmental Center, Corps of Engineers, and installation
restoration personnel was developed to facilitate many of the
groundwater issues that have impeded the approval of the
sitewide groundwater FS.
RAB members toured all groundwater treatment systems and
bioremediation facilities. The RAB co-chair also participated in
discussions about the sitewide groundwater draft FS.
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Milan AAP completed the SI report for the MMRP site.
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Plan of action items for Milan Army Ammunition Plant are
grouped below according to program category.
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0 Complete all excavation of
explosives-contaminated soils in the Northern
Industrial Areas in FY07.
0 Complete FS for sitewide groundwater and RA
for OU 5 soils interim ROD in FY07.
0 Prepare ROD for OUs 1 and 3 groundwater
treatment systems in FY07.
0 Prepare explanation of significant
differences for OU 4 ROD to include Region 2
in FY07.
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There are no MMRP actions scheduled for FY07 or
FY08.
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