PB99-963902
EPA541-R99-006
1999
EPA Superfund
Record of Decision:
USA Fort George G. Meade (TAA) OU
Fort Meade, MD
12/30/1998
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FINAL
RECORD OF DECISION
TIPTON AIRFIELD AREA
OPERABLE UNIT
FORT GEORGE G. MEADE
FORT MEADE, MARYLAND
DECEMBER 1998
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TAA Operable Unit Final Rtxxrt of Doosnn
TABLE OF CONTENTS
SECTION PAGE
DECLARATION FOR THE RECORD OF DECISION REMEDIAL ALTERNATIVE
SELECTION iv
1.0 DECISION SUMMARY 1-1
1.1 INTRODUCTION 1-1
2.0 SITE INFORMATION 2-1
2.1 SITE DESCRIPTION 2-1
2.1.1 Description ofAREEs 2, 4 and 12... 2-1
3.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES „ 3-1
3.1 PREVIOUS ASSESSMENTS AND INVESTIGATIONS 3-1
3.2 OTHER ARMY ACTIONS AND SAFETY PRECAUTIONS 3-2
4.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION 4-1
4.1 PUBLIC COMMENT PERIOD 4-1
4.2 PUBLIC MEETING 4-1
4.3 ADDITIONAL PUBLIC INFORMATION 4-1
5.0 SCOPE AND ROLE OF THE OPERABLE UNIT RESPONSE ACTION 5-1
5.1 SELECTION OF REMEDY 5-1
6.0 SITE CHARACTERISTICS , 6-1
6.1 SITE TOPOGRAPHY 6-1
6.2 ADJACENT LAND USE 6-1
6.3 SURFACE WATER HYDROLOGY 6-1
6.4 GEOLOGY / HYDROGEOLOGY 6-1
6.5 ECOLOGY 6-2
7.0 SUMMARY OF SITE RISKS 7-1
7.1 EXPOSURE ASSESSMENT .....7-1
7.2 HUMAN HEALTH RISK ASSESSMENT FOR AREES2, 4 AND 12... 7-2
7.3 ECOLOGICAL RISK ASSESSMENT FOR AREES2, 4 AND 12 7-3
7.4 CONCLUSION 7-4
8.0 DESCRIPTION OF THE "NO FURTHER ACTION" ALTERNATIVE 8-1
9.0 RESPONSIVENESS SUMMARY....... 9-1
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TAA OpwsWe Unit
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Number
Figure 1
Figure 2
LIST OF FIGURES
Site Location MAP of the Tipton Airfield Area
Surface Drainage Features at the TAA OU
Number
Table 1
Table 2
LIST OF TABLES
Summary of the Human Health Risk Assessment
Summary of the Ecological Risk Assessment
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LIST OF ACRONYMS
ARCOM
ASL
BEC
BRAC
CERCLA
COPCs
DRMO
FGGM
FTA
EIS
EPA
HHA
Hi
IAL
MCL
MDE
MDNR
NPL
ODA
O&M
PA
PRR
RBCs
Rl
ROD
SARA
SI
TAA
TAL
Army Reserve Command
Active Sanitary Landfill
BRAC Environmental Coordinator
Base Closure and Realignment
Comprehensive Environmental Response, Compensation
and Liability Act
Chemicals of Potential Concern
Defense Realization and Marketing Office
Fort George G. Meade
Fire Training Area
Environmental Impact Statement
U.S. Environmental Protection Agency
Helicopter Hangar Area
Hazard Index
Inactive Landfill
Maximum Contaminant Level
Maryland Department of the Environment
Maryland Department of Natural Resources
National Priorities List
Ordnance Demolition Area
Operations and Maintenance
Preliminary Assessment
Patuxent Research Refuge
Risk-Based Concentrations
Remedial Investigation
Record of Decision
Superfund Amendments and Reauthorization Act
Site Inspection
Tipton Airfield Area
Target Analyte List
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DECLARATION FOR THE RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
FOR THE TIPTON AIRFIELD AREA OPERABLE UNIT
Site Name and Location
Tipton Airfield Area Operable Unit (TAA OU)
Areas Requiring Environmental Evaluation (AREEs) 2, 4 and 12
Fort George G. Meade (FGGM)
Fort Meade, Maryland
Statement of Basis and Purpose
This Record of Decision (ROD) presents a determination that no further action is
necessary to protect human health and the environment for the TAA OU, which
includes the following AREEs:
• AREE2 - Helicopter Hangar Area (HHA);
• AREE4 - Fire Training Area (FTA); and
• AREE 12 - Inactive Landfill No. 3 (IAL3)
This determination was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), [42
U.S.C. §§ 9601 et seq.,] and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 C.F.R. Part 300.
The no further action decision is supported by documents contained in the
Administrative Record.
The State of Maryland concurs with the no further action remedy.
Description of the Selected Remedy
A no further action alternative is the selected remedy for the TAA OU.
Past military training activities resulted in the presence of unexploded ordnance (UXO)
at Fort Meade. The Army has previously taken multiple safety measures and actions at
the TAA'OU, some of which are summarized in this ROD. The Army issued a Decision
Document on July 9,1998 and a Decision Document Addendum in November 1998 to
document the safety measures and actions, including institutional controls on future
land use, for the TAA OU.
In addition, the Army conducted extensive environmental investigations of soils,
sediments, and surface waters to assess the environmental impacts of related site
activities. Results of these studies showed that risks posed to human health and the
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FAA Co«mci« unn
environment are within the EPA's acceptable risk range. The Army aiso studied the
groundwater of the TAA OU to evaluate the area-wide effects and the potential off-site
impacts related to chemical migration. The Army considered the previously established!
institutional controls and their protectiveness of human health and the environment with
regard to groundwater contamination.
The selected remedy represents a final remedial action determination with regard to
soils and an interim remedial action determination with regard to groundwater, which
together address the contamination at the TAA OU. The Army is currently evaluating
the source of the groundwater contamination, which is originating from an area outside
of the TAA OU. Final actions necessary to address groundwater will be presented in a
future Proposed Plan and ROD.
Declaration
The Rl reports, which include the Baseline Risk Assessment, document the findings-
associated with the TAA OU. These findings indicate that contaminants detected in the
soils at the TAA OU" do not pose an unacceptable risk to human health and the
environment. The risk calculated under the current and reasonably anticipated future
land use scenarios for the TAA OU is within the EFA's acceptable risk range,
Previously established institutional controls focus on maintaining these land use
assumptions.
The Rl reports also document some maximum contaminant level (MCL) exceedances
of volatile organics in groundwater. As a part of the Tipton Airfield Decision Document
(July, 1998), and the Decision Document Addendum (November, 1998), the Army
established a set of institutional controls which, among other things, prohibits the drilling:
of wells and the use of groundwater for any potable or nonpotable purposes except for
environmental studies. The establishment of these institutional controls eliminates the
exposure route to the contaminated groundwater and, therefore, is protective of human
health and the environment This response action, however, is limited to the TAA OU,
and is not intended to address the OU focusing on the overall groundwater
contamination. A final remedial action for the basewide groundwater OU will be
developed separately.
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Because hazardous substances will remain on-site above health-based levels, a review
will be conducted within 5 years after the date of this ROD to ensure that the remedy
continues to provide adequate protection of human health and the environment.
D. FRKETIC
/Colonel, Military Intelligence
^"commanding /
Date
ABRAHAM FERDAS/
Director, Hazardous Site Cleanup Division
U.S. EPA Region III
Date
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1.0 DECISION SUMMARY
1.1 INTRODUCTION
On April 1,1997, Fort George G. Meade (FGGM) was proposed for inclusion on the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
National Priorities List (NPL). FGGM was added to the final NPL on July 28,1998.
A CERCLA remedial action is often divided into OUs. As defined in the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), an OU means a discrete
action that comprises an incremental step toward comprehensively addressing site
problems. This discrete portion of a remedial response manages migration, or
eliminates or mitigates a release, threat of a release, or pathway of exposure. The
cleanup of a site can be divided into a number of OUs, depending on the complexity of
the problems associated with the site. OUs may address geographical portions of a
site, specific site problems, or initial phases of an action, or may consist of any set of
actions performed over time or any actions that are concurrent but located in different
parts of a site. This ROD presents a determination that no further action is necessary
to protect human health and the environment at the TAA OU, which consists of AREEs
2,4 and 12 (see Figure 1), located at Fort Meade, Maryland. This no further action
decision is the final action for the TAA OU. Other OUs, including one addressing base-
wide groundwater, have been and will be defined by separate investigations.
Based on the previously taken safety measures and actions, including institutional
controls on future land use, and the results of the risk evaluation, it was determined that
the TAA OU poses no current or future potential, unacceptable human health risks.
Therefore, the conditions at the TAA OU do not require further action to be protective of
human health and the environment.
A feasibility study (FS), which normally develops and examines remedial action
alternatives for a site, was not performed for the TAA OU since the results of the risk
evaluation indicate that no further remedial action is required.
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2.0 SITE INFORMATION
2.1 SITE DESCRIPTION
Fort George G. Meade (FGGM) is located in Anne Arundel County, Maryland. Prior to
Base Closure and Realignment (BRAC), FGGM occupied 13,596 acres of land in the
northwest comer of Anne Arundel County. It is bounded on the north by the Baltimore-
Washington Parkway and by the Patuxent River to the south. The Amtrak railroad track
right-of-way and State Route 175 form the southeast and northeast boundaries,
respectively. The TAA OU is a BRAC parcel, located south of State Route 198 and
Highway 32.
The facility was authorized by Congress in 1917 as a training cantonment for troops
during World War I. The Federal government commandeered 4,000 acres, most of
which was then farm land, and named the installation Camp Meade in honor of Major
General George G. Meade. In January 1941, additional training areas were added
within the installation, expanding the post to 13,596 acres. During the 1940s, the facility
underwent widespread growth to accommodate several regiments who moved their
base of operations to FGGM, including the Second U.S. Army and the Eleventh
Cavalry. Tipton Army Airfield was completed in 1963, replacing a small airstrip which
had been in operation since 1928.
In 1988, the Defense Authorization Amendments and Base Closure and Realignment
Act of 1988 mandated the closure and/or realignment of approximately 9,000 acres,
encompassing the southernmost two-thirds of the installation. In 1991, the Army
transferred 7,600 of the 9,000 acres to the Department of the Interior's Patuxent
Research Refuge (PRR), formerly known as the Patuxent Wildlife Research Center
(PWRC). A second land transfer of approximately 500 acres to the PRR took place in
January 1993.
The Tipton Airfield Area parcel, comprised of one Inactive Landfill, the Tipton Airfield,
the airfield infrastructure and adjacent areas, covers approximately 366 acres of the
remaining property. The helicopter hangar area is located at the northwest comer of
the airfield, adjacent to the Little Patuxent River. The former fire training area is located
off Airfield Road and is north of the airfield and east of the helicopter hangar.
2.1.1 Description of AREEs 2,4 and 12
2.1.1.1 Site Location and Operational History of the Helicopter Hangar Area
(AREE 2)
The Helicopter Hangar Area (HHA) includes Building 90 (the Helicopter Hangar) and
adjacent areas located at the northwest comer of the airfield. The approximate extent
of the HHA is indicated on Figure 1. The HHA is roughly bounded by the Little Patuxent
River to the west, an unnamed tributary to the Little Patuxent River to the north,
Patuxent Road to the east, and the helicopter parking area to the south. The HHA is
located approximately 800 feet west of the FTA. The HHA covers approximately 5
acres.
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Use of the TAA OU as a military range has been documented as far back as the early
1920s. In Special Military Maps from 1923, the area, later designated as Tipton Airfield,
was identified as an artillery impact area. A 1941 South Cantonment Map shows that
two ranges were located within the future Tipton area. One was an anti-tank range to
the west of Bullard Hill. The other was an anti-aircraft range to the east of Bullard Hill.
In the summer of 1942, 81mm and 60mm mortars were used in this area for target
practice. During the same timeframe, live high-explosive shells were fired over the
heads of troops for training purposes.
Construction of the airfield was completed by 1963. The Helicopter Hanger (Building
90) and associated structures were constructed in the early 1980's. The HHA is
surrounded by a chain-link fence which secures the site from both the river and
Patuxent Road.
During operations, th.e 97th ARCOM performed maintenance and storage of helicopters
at Hangar 90. Typical activities included washing, disassembly, repair, and painting of
aircraft. In addition to the use of fuels such as aviation and diesel fuel, other materials
that were typically used, handled or stored included hydraulic and lubricating oils,
detergents, and solvents. Hangar 90 was cleared and taken out of service when it was
decommissioned in early 1996.
2.1.1.2 Site Location and Operational History of the Fire Training Area (AREE 4)
The Fire Training Area (FTA) is located north of Airfield Road and is about 800 feet east
of the HHA. The approximate extent of the FTA is indicated on Figure 1 . The FTA
covers approximately two acres. The northern half of the FTA is fenced off, enclosing
the fire training pit and adjacent training areas. The area was constructed around 1979
for training purposes by the Fort Meade Fire Department. Fires were typically set inside
the pit or in portable bum pans by using gasoline or aviation fuel. The fires were then
extinguished with water or aqueous film-forming foam, a synthetic extinguishing agent.
Other emergency response training, such as self-contained breathing apparatus
training and emergency rescues, were performed here.
The FTA is flat and sparsely vegetated with grass. A drainage swale and culvert were
located parallel to the gate that drained to wetlands/forested area just west of the FTA.
The fire training pit was constructed of a concrete berm about one foot high and twenty
feet in diameter which was surrounded by a concrete apron. An oil-water separator
located on the south side of the fire training pit was used in draining the pit. Water from
the separator was transported from the site via an underground pipeline to a sanitary
sewer. Both the fire training pit and the oil-water separator were removed in 1998.
2.1.1.3 Site Location and Operational History of Inactive Landfill 3 (AREE 12)
Inactive Landfill 3 (IAL3) is located on the Tipton Airfield parcel in the eastern portion of
the runway area. The approximate extent of IAL3 is indicated on Figure 1. According to
the Enhanced PA Report (USAEC, 1989), IAL3 was initially used as a sand borrow
area. During the late 1940s and 1950s, the area was used as a sanitary and "leaf-
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FIGURE 1
1000
1000 2000 Feet
/\y Proplan.shp
N
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2.1.1.3 Site Location and Operational History of Inactive Landfill 3 (AREE 12)
Inactive Landfill 3 (IAL3) is located on the Tipton Airfield parcel in the eastern portion of
the runway area. The approximate extent of IAL3 is indicated on Figure 1. According to
the Enhanced PA Report (USAEC, 1989), IAL3 was initially used as a sand borrow
area. During the late 1940s and 1950s, the area was used as a sanitary and "leaf-
dump" landfill. The Tipton Army Airfield was constructed over the fill area in 1963. The
airfield consists,of four hangars, an operations building, a fire station, taxiways and
runway, and a helicopter training area. A storm water management system is located
under the airfield.
The site history indicates that the main disposal area was under what is now the
eastern portion of the runway area. According to the Enhanced PA report, during
construction of the airfield in 1963, much of the inactive landfill was excavated and the
materials were disposed off-post. The airfield construction plans, which include both
pre- and post-construction geotechnical soil boring logs, indicate that landfill materials
were removed from beneath all runway construction areas for structural reasons.
However, landfilled materials are still present in areas subjacent to the runways.
This 78-acre area boundary was developed based on the extent of historical
operations, aerial photographs, and subsequent site investigations.
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3.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
3.1 PREVIOUS ASSESSMENTS AND INVESTIGATIONS
Several environmental investigation! have been performed at FGGM since BRAG '88,
including an Enhanced Preliminary Assessment (PA) (USAEC, 1989), a study by the
Maryland Department of Natural Resources (MDNR), a Remedial Investigation
{USAEC, 1992a), a Site Inspection Study (USAEC, 1992b), a Draft Site Inspection
Addendum (which included an Environmental Impact Statement (EIS) and a Wetland
Identification Study) (USACE, 1991), and an Ordnance and Explosives Removal
(USAGE, 1997).
The Enhanced Preliminary Assessment (PA) includes a review of all available records
related to air, soil, surface water, and groundwater, and identifies six areas of concern
requiring additional investigation at FGGM: active and inactive landfills, underground
storage tanks, asbestos, unexploded ordnance, surface water, and burning grounds.
MDNR conducted an evaluation of the surplus property in January 1990. The study
describes the natural features and land uses associated with the 9,000 acres to be
excessed from FGGM and discusses the degree of development of the retained land.
In January 1990, an EIS for FGGM, Fort Holabird, and Fort Belvoir was prepared by
Rogers, Golden & Halpern, Inc. (RGH). The EIS focuses on the affected environmental
areas of these installations. The EIS described the existing conditions of FGGM's
9,000 acres slated to be excessed and evaluated the consequences of the use/reuse
scenarios.
In January 1991, a wetland identification study was prepared by RGH/CH2M Hiil, Inc. to
complete the study of the closure and use/reuse alternatives for the 9,000-acre parcel
at FGGM (USAEC, 1994). The report describes the methods used to identify wetlands
on the parcel and presents a map of wetlands distribution.
A Final EIS for the comprehensive base realignment and partial closure for FGGM and
Fort Holabird was prepared by the U.S. Army Corps of Engineers, Baltimore District, in
July, 1991. This report focuses on the environmental and socioeconomic impacts
associated with the planned base realignment and partial closure at FGGM and Fort
Holabird. The EiS covers only 1,400 acres of the 9,000-acre parcel at FGGM; the
remainder of the parcel was awaiting transferal to the PRR at the time of the final
report.
A Draft Site Inspection (SI) report was submitted by EA Engineering, Science and
Technology (EA) in January, 1992. This report discusses conditions at the Helicopter
Hangar Area (HHA), four inactive landfills (IAL1 to IAL4), the Defense Reutilization and
Marketing Office (DRMO) Salvage Yard, the Fire Training Area (FTA), the Ordnance
Demolition Area (ODA), underground storage tanks, and asbestos. The Final Si was
submitted in October 1992 (USAEC, 1992b).
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A Draft Site Inspection Addendum (SIA) report, prepared by Arthur D. Little, Inc.,
addresses data gaps identified in the previous SI report (USAEC, 1994a). The SIA
focused on the following six areas of investigation: DRMO Salvage Yard, the FTA, the
HHA, IAL2, the ODA, and Soldiers Lake. Another study, a Remedial Investigation
Addendum (RIA), was conducted concurrently with the SIA (USAEC, 1993a). Two
sites, the Active Sanitary Landfill (ASL) and the Clean Fill Dump (CFD), are included in
the RIA study. The results of the RIA are reported as a separate document. However,
some base-wide data, such as geology, general hydrogeology, and background soil
concentrations, are reported in both reports.
An Ordnance and Explosives (OE) Removal was conducted by Human Factors
Applications, Inc. (HFA) over the Tipton Airfield parcel, including the HHA and FTA, in
1996 (USAGE, 1997a). With the exception of the interior areas of the inactive landfill
sites and areas beneath water, all unpaved areas of the parcel were searched for
potential UXO to a depth of 4-feet.
Rl reports (USAGE, 1998a and USAGE, 1998b) of IAL1, IAL2, IAL3, the CFD, the FTA,
and the HHA were prepared by ICF Kaiser. In addition, an ecological risk assessment
was performed for the BRAG parcel, which included data from the inactive landfills, the
CFD, FTA, and HHA.
The Rl reports for the TAA OU were performed to characterize potential environmental
contamination from the TAA OU and to conduct baseline human health and ecological
risk assessments. The "Summary of Site Risks" section below presents the results of
the risk assessments.
3.2 OTHER ARMY ACTIONS AND SAFETY PRECAUTIONS TAKEN IN THE TIPTON
AIRFIELD AREA
The following is a list of many actions and safety precautions taken by the Army at the
TAA OU and surrounding areas:
• Ordnance Survey (1994>: The Army commissioned an ordnance survey covering all
areas of the airfield to assess the extent of ordnance remaining at the TAA OU and
surrounding areas. During this survey, ordnance was searched for to a depth of 6"
inches below the surface, and 10% of the remaining area was surveyed for
ordnance to a depth of 5 feet. During this action, a total of 1,400 ordnance items
were recovered from the TAA OU and surrounding areas.
• Ordnance Clearance (1995-1997): The Army searched for ordnance from all
accessible areas to a four-foot depth. Inactive landfill areas, wetlands, and all
paved surfaces were excluded. During this action, 1,548 ordnance items were
recovered, rendered safe, and disposed of. In addition, more than 33 tons of scrap
(concrete, metal, and miscellaneous debris) were recovered incidental to the
ordnance removal. Much of this material was recycled at local facilities.
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• Miscellaneous Debris Removal (Summer 1998): Several items, that were identified
during ordnance removal projects were recovered for disposal. Items removed
included several 55-gallon drums and an old vehicle-mounted storage tank.
• In 1998, the Army returned to the site to conduct additional ordnance removal from
a drainage swale located on the airfield. This effort led to the recovery of 420
additional items from areas previously inaccessible due to standing water, and
completed, the ordnance removal at all known areas on the airfield which had
identified concentrations of ordnance and explosives.
• Ordnance Safety Measures. Inactive Landfill 3 (1998): The Army performed
ordnance survey work in and around IAL3. The safety plan for this area includes
developing a long-term monitoring plan for the site. The first step in this effort was
to identify the depth of soil cover over any landfill debris at this site. The Army will
now develop a schedule for periodic surface sweeps of the area to ensure that no
ordnance items have migrated to the surface through frost action.
• Ordnance Safety Measures. Building Debris Site (1998): The Army took additional
ordnance safety measures at a 2!4-acre area designated as the Building Debris
Site. Because of its central location, this area has been made a priority for reuse.
The selected response action for the site is a combination of additional ordnance
clearance and construction of a vehicle parking lot at the site. Completion of this
work is scheduled for late-Fall 1998.
• A total of twelve storage tanks have been removed from the TAA OU. New storage
tanks were installed to serve the hangars and facilities at the TAA OU. Other work
included radon and asbestos surveys of buildings at the TAA OU.
In summary, the Army's prior response actions address the explosives risks related to
UXO and protect human health and the environment. The specifics of the Tipton
Airfield Decision Document (July, 1998), and the Decision Document Addendum
(November, 1998) include the establishment and enforcement of institutional controls,
initially via the FGGM Master Plan and, subsequent to properly transfer, via deed
restrictions. The existing institutional controls include prohibitions on conducting any
surface or subsurface excavations, digging, or other disturbances of soil, or beyond
paved surface, without prior written approval of the government with the exception of
emergency repair of existing utilities, and on using the groundwater at the TAA OU for
any potable or nonpotabte purposes except for environmental studies. Furthermore,
the existing institutional controls prohibit residential use of the property without
evaluation of residential exposure risks.
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4.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
4.1 PUBLIC COMMENT PERIOD
The Army provided a 30-day comment period from November 8, 1998 to December 7,
1998, to provide an opportunity for public involvement in the decision-making process.
During the comment period, the public was invited to review the Proposed Plan and the
environmental investigation reports. These reports were made available to the public
and are located" in the Administrative Record. The Administrative Record is the body of
documents that forms the basis for the selection of a particular response at a site. The
Administrative Record includes documents that support the response decision, relevant
documents that were relied upon in selecting the response action, and documents that
were considered but not used in the decision making process.
The Administrative Record was made available to the public at the locations listed
below.
1) Provinces Public Library
2624 Annapolis Road
Severn, MD 21144
Phone: (410)222-6280
Hours: Mondays, Tuesdays and Thursdays -1:00 p.m. to 9:00 p.m.;
Wednesdays and Saturdays - 9:00 a.m. to 5:00 p.m.; and
Fridays - 1:00 p.m. to 5:00 p.m. .
2) U.S. Army
Directorate of Public Works
Attn: ANME-PWE, Bldg. 239
2-1/2 Street and Ross Road
Fort Meade, MD 20755
Phone: (301)677-9854
4.2 PUBLIC MEETING
The Army held a public meeting on the Proposed Plan on November 17,1998 at 7:00
p.m., in the Pershing Hall basement conference room, at Fort Meade, to accept oral
comments. This meeting provided an opportunity for the public to comment on the
Proposed Plan. A copy of the transcript is located in the Fort Meade Administrative
Record. No comments were received during the public meeting.
4.3 ADDITIONAL PUBLIC INFORMATION
The Proposed Plan provided a summary of the actions considered and the results of
environmental studies conducted at the TAA OU. The public is encouraged to consult
the Administrative Record for a more detailed explanation.
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Final Pecort at becssnn
The notice of availability of the Proposed Plan document was published in the Capitol
Gazzette on November 8,1998 and in the Baltimore Sun on November 9,1998. A
Responsiveness Summary, included as part of this ROD, has been prepared to
respond to the comments, criticisms, and any new relevant information received during
the comment period. Upon signing the ROD, the Army will publish a notice of
availability of this ROD in the Baltimore Sun and the Capitol Gazzette, and place the
ROD in the Administrative Record located in the repositories mentioned above.
DACA31-94-D-0064
ESPSOW
December 1998
TAA Operable Unit
Fort George O. Me»d»
Final Document
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TAA OpersM* Unit _ Final Rocora of Deasan
5.0 SCOPE AND ROLE OF THE OPERABLE UNIT RESPONSE ACTION
5.1 SELECTION OF REMEDY
This ROD, the first for the Fort Meade NPL site, presents the selection of the final
remedial alternative for the surface and subsurface soils at the TAA OU and an interim
remedial alternative for groundwater contamination at the TAA OU only, which together
address all of the known contamination at the TAA OU. This ROD does not address
other OUs at Fort Meade, in particular that addressing the source and overall extent of
the groundwater contamination. The remaining OUs are currently under independent
investigations and will be addressed separately in future Proposed Plans and RODs.
No further action is necessary at the TAA OU to protect human health and the
environment. Under the no further action alternative, no remedial action will be taken at
the TAA OU based upon both the current level of risk posed by contamination at the
TAA OU and the protectiveness provided by prior removal actions. This is the final
response action for the TAA OU.
DACA31-94-D-0064 TAA Operate Unit
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December 1998 Final Document
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TAA Openi^ unit Fimif Record of Oeoson
6.0 SITE CHARACTERISTICS
6.1 SITE TOPOGRAPHY
The TAA OU lies within the Coastal Plain Physiographic Province. The site is
characterized by low rolling uplands and low-gradient streams. Within the TAA OU, the
relief varies over a range of approximately 90 feet (ft); the lowest elevation (90 ft)
occurs within the Little Patuxent River which forms the western boundary of the TAA
OU; whereas tlfe highest elevation (180 ft) occurs on the northern boundary of the TAA
OU, between the airplane hangers and State Highway 32. The majority of the site
topography, which has been modified to accommodate the airfield, slopes gently to the
west or south.
6.2 ADJACENT LAND USE
The TAA OU is bordered to the north by State Highway 32. The OU is bounded to the
south, east, and west by the Department of Interior's Patuxent Research Refuge (see
Figure 1). The Little Patuxent River forms the western boundary of the OU. Inactive
Landfill 2 (IAL2), a 10-acre site which abuts a portion of the southern boundary of the
OU, is being retained by the Army.
6.3 SURFACE WATER HYDROLOGY
Figure 2 shows the surface drainage features at the TAA OU. Runoff originating within
the perimeter portions of the TAA OU is conveyed by drainages west or south to
tributaries or drainages of the Little Patuxent River. Runoff from the central portion of
the area flows into a stormwater collection and conveyance system beneath the airfield
which discharges, via french drains, to the Little Patuxent River or its drainages.
6.4 GEOLOGY / HYDROGEOLOGY
FGGM is located on the unconsolidated sands, clays, and silts of the Coastal Plain
which were deposited from the Cretaceous to the Quaternary geologic periods. The
Coastal Plain sediments dip and thicken to the east and southeast.
The surficial deposits present beneath the TAA OU are primarily from the lower
Cretaceous age Potomac Group. Quaternary alluvium and river terrace deposits are
locally present adjacent to the Little Patuxent River. The Potomac Group consists of,
from youngest to oldest, the Patapsco Formation, Arundel Clay, and Patuxent
Formation. The lower portion of the Patapsco Formation outcrops at the TAA OU. It
consists of up to 40 feet of siity sands. Airfield construction fill was locally obtained
from this unit The Arundel Formation consists of massive beds of red, brown and gray
clay with local zones of more permeable layers. The Arundel Clay is approximately 265
feet thick where it was penetrated at IAL2. The Patuxent Formation consists of a thick
sequence of sand-rich sediments which are underlain by crystalline bedrock of the
Baltimore Mafic Complex at 600 to 800 feet below ground surface.
At the TAA OU, the water table is present, generally at depths less than 10 feet below
ground surface, within the lower portion of the Patapsco formation. The water table
aquifer extends down to the top of the Arundel Clay and has a maximum saturated
thickness of approximately 25 feet in this area. Unconfined groundwater flow is
DACA31-94-D-0064 TAA Operable Unit
ESPS03-8 Fort George G. Meade
December 1998 Final Document
$-1
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ICOPIfK HANGAR ARC A
r-'
i FIRL I RAINING ARfA
INACTIVE
LANDFILL 3
— SIRLAM OK DRAINAGE
s= ROAD
« BUILDING
APPROXIMATE FXTENI Of [NVIKONMtNIAI SlUDY
AREAS ADDRESSFD IN IHt PROPOSED PLAN
BALTIMORE DISTRICT
US Army Corps of Engineers
CONTRACT NO. DACA31-94-D-0064 FORT GEORGE G. MEADE
ICF KAISKR
FILE: TA-SW
DATE: 11-14-98
FIGURE 2
TIPTON AIRFIELD
DRAINAGES
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TAA OpwaWs Unit Find Recant ot Qvysion
controlled by topography and flow is generally west or south toward the Little Patuxent
River. The Arundel Clay acts as a regional confining layer below the Patapsco aquifer.
However, groundwater is locally found in confined or semi-confined sand lenses within
the upper portions of the Arundel Clay. The Patuxent Aquifer, which is present
between the Arundel Clay and bedrock, is a regionally important groundwater source.
Regional groundwater flow in the Patuxent aquifer is to the east-southeast.
6.5 ECOLOGY
" •»
The habitat in the TAA OU has been heavily altered and is likely to only support limited
flora and fauna typical of disturbed urban/light industrial areas. As delineated, the TAA
OU contains no wetlands or protected or endangered species. Wetlands, protected
species, sensitive environments are present in nearby areas of the PRR and the Little
Patuxent River. Any drainage from the TAA OU would flow, via surface runoff or the
airfield stormwater management system into the Little Patuxent River. An ecological
risk assessment has concluded that there is a very limited potential for adverse effects
to terrestrial plant and invertebrate communities and to aquatic life (USACE, 1998a).
DACA31-94-D-0064 TAA Operable Unit
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December 1998 Final Document
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Final RtconJ of Dtasion
7.0 SUMMARY OF SITE RISKS
7.1 EXPOSURE ASSESSMENT
The Rl report included both ecological and human health risk assessments to address
the potential current and future risks posed to human health and the environment
associated with the TAA OU. The risk assessment included estimates of the risk posed
to human health and the environment assuming the continuation of the current
industrial (non-residential) land-use scenario. The current land-use scenario estimates
the level of risk posed by Fort Meade's current use of the land. The current land-use
scenario is based on the assumption that the property remains under government
authority to enforce existing institutional controls and continues in current or like use.
When title to this BRAG property is transferred, the institutional controls on future land
use will be embodied in the deed. The U.S. Government will retain the ability to enforce
those use restrictions established in prior Decision Documents as described below. In
addition, after transfer of title to the property, in the unlikely event that the TAA OU's
use as an airport would change, title to the property will revert back to the U.S.
Government. A human health risk assessment will need to be conducted for residential
receptors in the unlikely event that the TAA OU would be developed for residential use.
Existing institutional controls, as established by the Tipton Airfield Decision Document
(July, 1998) and the Decision Document Addendum (November, 1998), include a
prohibition on conducting any surface or subsurface excavations, digging, or other
disturbances of soil, or beyond paved surfaces, without prior written approval of the
government with the exception of emergency repair of existing utilities, and on using the
groundwater at TAA for any potable or nonpotable purposes except for environmental
studies. Furthermore, the existing institutional controls prohibit residential use of the
property without evaluation of residential exposure risks.
The human health risk assessment was based on exposure to soil. Groundwater was
also evaluated, but due to the establishment of a separate base-wide groundwater OU
and the establishment, as part of the prior removal action, of protective institutional
controls, remediation of base-wide groundwater will not be addressed in this ROD. The
ecological risk assessment was based on exposure to soil, sediments, and surface
water.
Health risks are based on a conservative estimate of the potential carcinogenic risk or
potential to cause other health effects not related to cancer. Carcinogenic risks and
non-carcinogenic risks were evaluated as part of the risk assessment; three factors
were considered: (1) nature and extent of chemicals at the TAA OU, (2) the pathways
through which human and ecological receptors are or may be exposed to those
chemicals at the TAA OU, and (3) potential toxic effects of those chemicals.
Cancer risks are expressed as numbers reflecting the increased chance that a person
will develop cancer, if he/she is directly exposed (e.g., through working at the TAA OU)
DACA31-94-D-0064 TAA Operable Unit
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TAA Open,** Unit ; Fiatt RKQrt «
to the chemicals found in the groundwater and soil at the TAA OU over a period of time.
For example, EPA's acceptable risk range for Superfund sites is 1 x 10/4 to 1 x 10"*,
meaning there is one additional chance in ten thousand (1 x 1CT*) to one additional
chance in one million (1 x 10~") that a person will develop cancer if exposed to a
Superfund site. The risk associated with developing other health effects is expressed
as a hazard index (HI) which is the ratio of the existing level of exposure to
contaminants at a site to an acceptable level of exposure. Below a hazard index of 1,
adverse effects-are not expected. A hazard index is also used to evaluate ecological
risks.
7.2 HUMAN HEALTH RISK ASSESSMENT FOR AREES 2, 4 AND 12
There are two potential pathways of exposure to humans identified for trespassers and
site/excavation workers based on current and reasonably anticipated future land use:
• Direct contact (dermal contact and incidental ingestion) with surface soils; and
• Direct contact (dermal contact and incidental ingestion) with subsurface soils at
IAL3, the FTA, and the HHA.
Concentrations of chemicals of potential concern detected in the soil and groundwater
during the Rl were compared to risk-based screening levels and background levels.
Health risk levels, determined using EPA guidance to ensure that conservative
estimates of potential health effects, differ depending on the assumed land use
because human exposure differs with land use. As outlined above, a conservative
estimate of risk was developed incorporating the potential exposure pathways including
direct skin contact with contaminated soil accidental ingestion of soil and sediment, and
inhalation of contaminated soil particles. Plausible receptors that may be exposed to
soil at the TAA OU and which were evaluated in the risk assessment included daily
workers and occasional recreational users.
Low levels of pesticides and explosive-related chemicals were widely, if infrequently,
found. Metals were ubiquitous and found in naturally occurring soils at the site. Based
on the reasonably anticipated future land-use, risk associated with direct contact with
soil under occupational or recreational scenarios were below or at the low end of EPA's
acceptable risk range of 10"* to 10/6 and all hazard indices were less than 1, as
summarized in Table 1 below. Additionally, since the risks are driven by metals, they
may be partially or wholly due to naturally occurring substances.
DACA31-94-D-0064 TAA Operabto Unit
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December 1998 Final Document
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TM Oaenbf* Unit
Fifiot Record of Doctston
TABLE 1 - SUMMARY OF THE HUMAN HEALTH RISK ASSESSMENT
In the following table, cancer risk estimates are compared with the USEPA's target
risk range (TRR) for health protectiveness atSuperfund sites of 1x10" to 1*10-*.
The potential for adverse non-carcinogenic effects was assessed by comparing the
non-carcinogenic hazard indices to a value of 1. A hazard index (HI) less than 1
indicates that adverse non-carcinogenic health effects would not be expected to
occur. ,
Medium of Concern
Surface soli
Receptors:
Site worker and trespasser
Pathways:
Incidental ingestion by site workers:
Dermal absorption by site workers:
Incidental ingestion by trespassers:
Dermal absorption by trespassers:.
Subsurface toll
Receptors:
Future excavation workers
Pathways:
Incidental ingestion:
Dermal absorption:
AREE2
Cancer
Risk
1x10*
2x10*
2x10'7
3X10''
1x1 0*
3x1 O-7
Hazard
Risk
<1 (6x1 Q-3)
<1 (ixia2)
<1 (4x1 0-3)
<1 (4x1 0"3)
<1 (2x10'1)
<1 (4x1 0'2)
AREE 4
Cancer
Risk
9x1 0-7
2x10*
2x10'7
2x10'7
3x10'7
6x10*
Hazard
Risk
<1 (6x1 0-3)
<1 (1x1 Or2)
<1 (3x1 0-3)
<1 (4X10-3)
<1 (4x10'2>
<1 (9X104)
AREE 12
Cancer
Risk
8x10-7
2x10*
2x1 0-7
2x1 a7
9x1 0-7
2x1 0-7
Hazard
Risk
<1 (5x1 0"3)
<1 (1x10'2)
<1 (3X10-3)
<1 (3X10-3)
<1 (1x10-1)
<1 (3x1 0'2)
As always, the physical hazards associated with UXO are a potential concern. Fort
Meade has already conducted UXO surveys at the TAA OU to address this risk. As
discussed previously, an Ordnance and Explosives (OE) Removal was conducted by
Human Factors Applications, Inc. (HFA) over the Tipton Airfield parcel, including the
HHA and the FTA, in 1996 (USAGE, 1997a). With the exception of the interior areas of
the inactive landfill, all unpaved areas of the parcel were searched for potential UXO to
a depth of 4-feet. Other UXO work performed by the Army is also discussed in this
ROD.
7.3 ECOLOGICAL RISK ASSESSMENT FOR AREES 2, 4 AND 12
The following pathways were identified as sources of potential exposure:
• Root uptake from contaminated soil;
• Contact and absorption, incidental ingestion, and feeding on contaminated food
and soil; and
• Bioaccumulation from vegetation or animal prey.
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Final Document
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TAA QpenUo Unit
Final Record of Decision
The ecological risk assessment evaluated exposure of terrestrial receptors from surface
soil exposures from the TAA OU, which is expected to be used as an airport. The TAA
OU will be managed as an active airport and will take measures to discourage
terrestrial ecological receptors for safety concerns.
Several metals (including chromium, zinc, aluminum, and vanadium) and low levels of
pesticides exceeded the ecological screening criteria for the various plant and
invertebrate receptors. Management of the TAA OU as an airport will discourage a
diverse plant community. This will also significantly reduce the natural habitat of
terrestrial receptors. By considering the reasonably anticipated future land use and
expected management practices associated with an airfield, the results support the
selected remedy of no further action at the TAA OU.
Table 2 summarizes general findings regarding the potential for adverse effects to
ecological resources "based on comparison of chemical concentrations detected onsite
to literature-based toxicity references values (TRVs).
TABLE 2 - SUMMARY OF THE ECOLOGICAL RISK ASSESSMENT (ERA)
Medium of Concern
Surface soil
Effects to:
(a) Terrestrial plant
communities; and
(b) Terrestrial invertebrate
communities (as
represented by
earthworms)
Pathways: direct contact with
chemicals
AREEs 2,4 and 12 (ERA Findings)
Minimal risk - Chromium exceeded the
earthworm TRVs at all sample locations.
However, detected background concentrations of
chromium also exceeded plant TRVs, suggesting
the on-site concentrations are, at many locations,
reflective of the local/regional soil type, in which
case earthworms are likely to be adapted to
these levels.
7.4 CONCLUSION
Because the human health and ecological risk assessments concluded that site
conditions, in light of the existing institutional controls established under the prior
response action, do not pose an unacceptable risk to potential human and ecological
receptors, no further action is deemed appropriate to protect human health and the
environment.
DACA31-94-D-0064
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December 1998
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Final Document
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TAA OptnOo Un* Final Record ot Decision
8.0 DESCRIPTION OF THE "NO FURTHER ACTION" ALTERNATIVE
The selected remedy for the TAA OU is no further action. At the time of this ROD,
future land-use of the TAA OU was determined to be an industrial airport. The TAA OU
was used as a military airfield from the early 1960s to September 1995, when it was
closed. The airport conversion of this airfield was initially planned as a partnership
between Howard County and Anne Arundel County. Anne Arundel County currently
has one lease on three buildings at the TAA OU. The second lease, which is pending,
will include additional hangar areas, the runway and taxiways.
The current land-use scenario is based on the assumption that the property remains
under U.S. Government authority to enforce existing institutional controls and continues
in current or like use. When title to this BRAC property is transferred, the institutional
controls on future land use will be embodied in the deed. The U.S. Government will
retain the ability to enforce those use restrictions established in prior Decision
Documents. In addition, after transfer of title to the property, in the unlikely event that
the TAA OU's use as an airport would change, title to the property will revert back to the
U.S. Government. A human health risk assessment will need to be evaluated for
residential receptors in the unlikely event that the TAA OU would be developed for
residential use. The only cost associated with this remedy is the costs related to
conducting the five-year review which is expected to be minimal.
Because hazardous substances wiH remain on-site above health-based levels, a review
will be conducted within 5 years after the date of this ROD to ensure that the remedy
continues to provide adequate protection of human health and the environment.
DACA31-94-D-0064 TAA OperaW* Unit
ESPS03-6 Fort George G. Meade
December 1998 Final Document
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TAA operable unit FinafRecort of Decision
9.0 RESPONSIVENESS SUMMARY
The purpose of the Responsiveness Summary is to provide the public with a summary
of citizen comments, concerns, and questions regarding the TAA OU. Two
commentors responded during the 30-day public comment period from November 8,
1998 to December 7,1998. Responses to these comments are provided in the
Responsiveness Summary, which is included as part of this ROD.
In addition, no verbal comments were presented during the November 18, 1998 public
meeting regarding the TAA OU.
OACA31-94-D-0064 TAA Operable Unit
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December 1998 Final Document
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RESPONSIVENESS SUMMARY
MOTH: THESE COMMENTS WEBE TRANSCRIBED VERBATIM' FROM EACH COMMENT-PR'S SUBMITTAL.
COMMENTS ON THE PROPOSED PLAN - TIPTON AIRFIELD AREA OPERABLE UNIT (TAA OU)
FORT GEORGE G. MEADE, MD
Of the two comments received during the Public Comment Period, one was submitted in writing and the
other via telephone conversation.
Comment:
Response:
One commentor (hereafter referred to as Commentor 1) wrote that "After careful review
of the Proposed Plan as well as accompanying documents and review of the public record
in this matter, I find the Proposed [Planj inadequate to protect the interest of the surround-
ing community."
The Proposed Plan, was developed in accordance with CERCLA, the NCP and appropri-
ate State laws. As a part of the Tipton Airfield fTAA OU) Decision Document (July, 1998),
and too Decision Document Addendum (November. 1998). the Army established a set of
institutional controls which, among other things, prohibits the drilling of wells and the use
of grouhdwater for any potable or nonpotable purposes except for environmental studies.
The establishment of these institutional controls eliminates the exposure route to the
contaminated groundwater and, therefore, is protective of human health and the environ-
ment This response action, however, is limited to the TAA OU, and is not intended to
address the OU focusing on the overall groundwater contamination. A separate base-
wide groundwater operable unit is currently under independent investigations and a final
remedy for groundwater will be addressed separately in future Proposed Plans. Because
hazardous substances will remain on-site above health-based levels, a review will be
conducted within 5 years after the date of this ROD to ensure that the remedy continues
to provide adequate protection of human health and the environment By considering the
reasonably anticipated future land use and expected management practices associated
with an airfield, the investigation results support the selected remedy of no further action
at the TAA OU. Specific questions/comments are addressed below.
Comment: Commentor 1: Commentor 1 wrote that a contractor to the county"... stated on the record
that the SOLE concern regarding the airport was operational. He as also stated publicly,
though not at the RAB that the removal of UXO was a waste of money. Clearly the
representative for the county who proports (sic) to operate this facility has no interest in
the environmental impacts, safety impacts and/or affect (sic) and safety of the surround-
ing community both presently and in the future. This FOSL is based upon the premise
that the county will adhere to certain guidelines and restrictions. Clearly it is the intent of
the County to disregard all such guidelines, as such transfer, if affected, must be accom-
plished with the dear understanding 99 stated on the record by the representative of
the county that all environmental covens (sic) and restrictions will be at best minimally
met at most ignored. This renders the Proposed Plan in its present form as unacceptable.
Further due to the state (sic) position of the county representative, it is clear that this
Proposed Plan is being presented under fraudulent terms with guidelines which at their
inception are a mockery. While there have been "assurances* issued regarding this plan,
the fact remains that NO party to this proposed plan or any agreement has given any
definitive statements other than "cuz we say so." The local community is not willing to risk
such long-term commitment on such childish responses without any real material to back
up the denial.*
Response: During the period of time that the property is leased, the Army will retain ownership of
Tipton Airfield. The Army will be responsible for ensuring the Lessee complies with all
institutional controls in place for the property. In summary, the Army's prior response
to Comments
Proposed Plan
TAAOU
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Comment:
Response:
RESPONSIVENESS SUMMARY
NOTE: THESE COMMENTS WERE TRANSCRIBED •VERBATIM- PROM EACH COMMCNTOR'S SUBMITTAL.
actions address the explosives risks related to unexptoded ordnance (UXO) and protect
human health and the environment The specifics of the Tipton Airfield Decision Docu-
ment (July, 1998), and the Decision Document Addendum (November, 1998) include the
establishment and enforcement of institutional controls, initially via the FGGM Master Plan
and, subsequent to property transfer, via deed restrictions. The existing institutional
controls include prohibitions on conducting any surface or subsurface excavations,
digging, or other disturbances of soil, or beyond paved surface, without prior written
. approval of the government with the exception of emergency repair of existing utilities
and on using the groundwater at the TAA OU for any potable or nonpotabte purposes'
except for environmental studies. Surface sweeps for UXO will be performed at years 3
and 7, and every five years thereafter. The Army will periodically review the need to
continue surface sweeps. Furthermore, the existing institutional controls prohibit residen-
tial use of tile property without evaluation of residential exposure risks.
When title to this BRAG property is transferred, the institutional controls on future land use
will be embodied in the deed. The U.S. Government will retain the ability to enforce the
use restrictions. After transfer of title to the property, in the unlikely event that the TAA
OU's use as an airport would change, title to the property will revert back to the U.S.
Government
In addition to the U.S. Government's stated intentions to assure future compliance with all
applicable land use restrictions, a representative of Anne Arundel County has given the
Army and the regulators subsequent assurances that aU land use restrictions will be
observed.
Commentor 1: "The Proposed Plan addresses in general the transfer of acreage based
upon the dean up of UXO, however, there were significant comments made to the clean
up. Further I see no where the matter of the future breakdown of the UXO is addressed
and its possible impact on the surrounding communities and potential liability factors.
With out this information, cogent comment on the transfer is impossible.*
The Army addressed the future breakdown of UXO through the sampling of surface and
subsurface soils and groundwater during remedial investigations and ordnance removal
activities. All samples were analyzed for ordnance constituents and associated break-
down products. The vast majority of ordnance items recovered at Tipton were practice
munitions that contained wax filler instead of high explosives. Based on the number and
type of items found during the ordnance removal activities conducted at Tipton. there is
no indication that breakdown of ordnance poses a risk to human health and the environ-
ment
As reported in the remedial investigation reports for Tipton, no soil samples collected to
date have shown the presence of residual, explosive breakdown products. In only one
wed (MW3-2), two groundwater samples showed a presence of explosive breakdown
products at the low parts per billion range. The carcinogenic risk for these constituents is
5x10'7, which is we« below EPA's acceptable risk range. The Hazard Index of DNT
(Dinitrotoiuene) for this well was 2, above EPA's acceptable Hazard Index of 1. However,
due to the isolated nature of this finding and the establishment of institutional controls for
the property, human health and the environment is protected.
The Army retains responsibility for conducting additional groundwater investigations and
remediations as necessary.
Response to Comments
Proposed Plan
TAAOU
-------
RESPONSIVENESS SUMMARY
NOTE THESE CQMMgNTSWERg TRANSCRIBED •VERBATIM* FROM EACH COMMSNTOR'S SUBMTTTAL.
Comment:
Response:
Commentor 1: 'Throughout the report, there are repeated references to the groundwater
contamination. Yet it is also repeated that no one knows where the contamination is from
and is probably "off site" with such non specific information it is not prudent to allow either
the Army or EPA to be released from this site until the absolute protection of the local
community can be addressed."
While there is some groundwater contamination associated with the Upton sites, no risk
has been shown to exist either because contaminant levels are below levels of concern or
because no target receptors exist due to the implementation of institutional controls.
The Rl reports also document some maximum contaminant level (MCL) exceedances in
one well of volatile organtes in groundwatef. Benzene was detected at 8.7 ppb, with a
MCL of 5.0 ppb. As a part of the Tipton Airfield Decision Document (July, 1998). and the
Decision Document Addendum (November, 1998), the Army established a set of institu-
tional controls which, among other things, prohibits the drilling of wells and the use of
groundwater for any potable or nonpotable purposes except for environmental studies.
The establishment of these institutional controls eliminates the exposure route to the
contaminated groundwater and, therefore, is protective of human health and the environ-
ment This response action, however, is limited to the TAA OU, and is not intended to
address the OU focusing on the overall groundwater contamination. Final remedial action
for the base-wide groundwater will be developed separately.
Comment:
Response:
"This section addresses the fact that the Little Patuxent river will not be transferred, yet
HANGER 90 will be. There are, along the bank, projecting into and near the Little
Patuxent, pipes running from unknown origins. Without knowing exactly how the line is
drawn, (e.g. at the surface, through the water tables, etc.) with this specific information a
cogent analysis cannot be made of the Proposed plan, thereby making the land defini-
tions objectionable.
"As previously state (sic) this property is to be least (sic) to the County for an airfield.
However, without specific information of the "lines* liability cannot be determined and a
lease cannot be appropriately evaluated."
Currently, the buildings and all underlying property are to be leased and subsequently
transferred to Anne Arundei County. The origins of the two pipes that discharge into the
Uttie Patuxent River emanate from the area around Hangar 90. These pipes have been
traced to their source. They will be sealed or re-plumbed as required to meet applicable
Maryland State regulations. These actions will be completed prior to land transfer.
Comment:
"As previously stated, the lessee has stated on the record that adherence to the deed will
not be a primary concern. In addition, the army, while in control of the property has been
unable and/or unwilling to restrict movement and access to the named property. A action
item and deed restriction to limit the liability of the Army when it has been clearly proven
that such limitation is not possible or plausible simply to remove the army from the site
give (sic) rise to increased liability by the local county. There is no argument that can
justify the blind acceptance of increased liability by the local community in light of the
position of the county and the ongoing inability of the army and/or EPA to administer any
R«*ponw to Comments
Proposed Plan
TAAOU
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RESPONSIVENESS SUMMARY
NOTE.' TH6S6 COMMENTS WERE TRANSCRIB6D *VEBaATlM' FROM EACH COMMEMTOB'S SUBMITTAf..
guidelines. Further, the EPA in its effort to rush this matter through thereby easing the
local politics have failed to make any reasonable arguments or alternative regarding the
access to contaminated area other that to say, is ok as long as everyone plays by the
rules. The rules don't wbrk, have been stated that they will not be enforced and have
been unenforceable by the Army to date. The EPA's position is puzzling at best politically
convenient at worst*
Response: During the period of time that the property is leased, the Army will retain ownership of
Tipton Airfield. The Army will be responsible for ensuring the Lessee complies with ail
institutional controls in place for the property! The specifics of the Tipton Airfield Decision
Document (July, 1998), and the Decision Document Addendum (November, 1998) include
the establishment and enforcement of institutional controls, initially via the FGGM Master
Plan and, subsequent to property transfer, via deed restrictions. The existing institutional
controls include prohibitions on conducting any surface or subsurface excavations,
digging, or other disturbances of soil, or beyond paved surface, without prior written
approval of the government with the exception of emergency repair of existing utilities,
and on.using the groundwater at the TAA OU for any potable or nonpotable purposes
except for environmental studies. Furthermore, the existing institutional controls prohibit
residential use of the property without evaluation of residential exposure risks.
When title to this BRAG property is transferred, the institutional controls on future land use
will be embodied in the deed. The U.S. Government will retain the ability to enforce the
use restrictions. After transfer of title to the property, in the unlikely event that the TAA
OU's use as an airport would change, title to the property will revert back to the U.S.
Government
1
Comment:
Response:
In addition to the U.S. Government's stated intentions to assure future compliance with all
applicable land use restrictions, a representative of Anne Arundd County has given the
Army and the regulators subsequent assurances that all land use restrictions will be
observed
With regards to the statement that this matter is being "rushed through," it should be
noted that this Record of Decision is the culmination of work that began in 1988 which
includes multiple investigations, cleanup efforts of various magnitudes, ordnance removal
projects and extensive public involvement
Commentor 1: "The issue of UXO as a CERCLA issue has not been completely deter-
mined. As such the Army picked and chose it way through CERCLA with regard to UXO.
Thereby, failing to address clean up which may be necessary as a result of break down or
release as a result of the current UXO deposits. Further there is extensive evidence of
ACID and AGIO storage, (forinstance (sic) the container found in landfill 3) the complete
extent of storage and/or disposal has not been determined and as such it is too soon to
state ANYTHING with regard to CERCLA Especially in light of the recent liability rulings,
I fail to see how any document can be considered without a dear delineation of liability
status.'
While we agree that the UXO/CERCLA issue has not been resolved nationally, we did not
allow that unresolved issue to interfere with the investigation and removal of unexploded
ordnance at Tipton. Fort Meade, EPA Region III and Maryland Department of Environ-
ment have been diligent in addressing all issues related to safety and residual contamina-
tion related to unexploded ordnance. The following are unexploded ordnance removal
actions that have been taken at Tipton:
Response to Comments
Proposed Plan
TAAOU
-------
RESPONSIVENESS SUMMARY
NOTE: These COMMON vveMT«ANSCH»ta^^8ATi^ PROM EACH coMMeaoR-s SUBMITTAC
! The Army commissioned an ordnance survey covering all areas
ng a areas
of the airfield to assess the extent of ordnance remaining at the TAA OU and surrounding
areas. During this survey, ordnance was searched for to a depth of 6' inches below the
surface, and 10% of the remaining area was surveyed for ordnance to a depth of 5 feet
Dunng this action, a total of 1.400 ordnance items were recovered from the TAA OU and
surrounding areas.
flnjnance Qtea.ra.nce f199$-1$97); The Army searched for ordnance from all accessible
areas to a four-foot depth. Inactive landfill areas, wetlands, and all paved surfaces were
excluded. During this action, 1.548 ordnance items were recovered, rendered safe, and
disposed of. In addition, more than 33 tons of scrap (concrete, metal, and miscellaneous
debris) were recovered incidental to the ordnance removal. Much of this material was
recycled at local facilities.
In 1998, the Army returned to the site to conduct additional ordnance removal from a
drainage swale located on the airfield. This effort led to the recovery of 420 additional
items from areas previously inaccessible due to standing water, and completed the
ordnance removal at all known areas on the airfield which had identified concentrations of
ordnance and explosives.
1; Several items, that were identified during
"—•-~ r - n T : T r IU-—X-J—J_X1. •»•»•••••••• •«•••• wt %• IM« wwt 9 I\4VIIUIIW VUIIIIU
ordnance removal projects were recovered for disposal. Items removed included several
55-galton drums and an old vehicle-mounted storage tank.
Ordnance Safety Measures. Inactive LandfM 3 MflM); The Army performed ordnance
survey work in and around IAL3. The safety plan for this area includes developing a long-
term monitoring plan for the site. The first step in this effort established that there is a
minimum 3' soil cover over any remaining landfill debris at this site.
The Army will now implement a schedule for periodic surface sweeps of the area to
ensure that no ordnance items have migrated to the surface through frost action.
Ordnance Safety Measures. Building Debris Site <1998V The Army took additional
ordnance safety measures at a 2'A-acre area designated as the Building Debris Site.
Because of its central location, this area has been made a priority for reuse. The selected
response action for the site is a combination of additional ordnance clearance and
construction of a vehicle parking lot at the site. Ordnance safety measures, including
earthwork and preliminary site grading were completed in late-Fall 1998. Paving comple-
tion is scheduled for Spring 1999.
There was no add container located in Inactive Landfill No. 3. However there were two
acfcf neutralization pits located on the Tipton property. The pit at Hangar 90 has been
removed and the associated piping has been capped to preclude further use. The pit at
Hangar 85 has been inspected for structural integrity and surrounding soils have been
sampled. This pit is correctly plumbed into the sanitary sewer and can be operated
properly in the future.
Based on the sampling results and the inspection of the pit's structural integrity, no
further action for these sites, beyond the on-going re-plumbing is warranted.
RttporiM to Comment* Proposed Plan
5 TAA OU
-------
Comment:
Response:
RESPONSIVENESS SUMMARY
MOTS: THg56COMM6>ffSvvefigT
-------
RESPONSIVENESS SUMMARY
NOTE: THgse COMMENTS were TRANSCRIBED 'VERBATIM' FROM EACH COMMEMTOR'S SUBMHTAL.
Furthermore, the existing institutional controls prohibit residential use of the property
without evaluation of residential exposure risks.
RatpoflM to Commtftts Proposed Plan
7 TAA OU
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