PB99-963908
EPA541-R99-012
1999
EPA Superfimd
Record of Decision:
Patuxent River Naval Air Station
OU 1 Soils, Pesticide Shop (Site 17)
St. Mary's County, MD
12/16/1998
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Record Of Decision
for
Operable Unit 1, Soils
Pesticide Shop (Site 17)
Naval Air Station Patuxent River
Patuxent River, Maryland
Engineering Field Activity Chesapeake
Naval Facilities Engineering Command
December 1998
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TABLE OF CONTENTS
SECTION PAGE NO.
ACRONYMS iv
1.0 DECLARATION FOR THE RECORD OF DECISION 1-1
1.1 SITE NAME AND LOCATION 1-1
1.2 STATEMENT OF BASIS AND PURPOSE 1-1
1.3 ASSESSMENT OF SITE 17-PESTICIDE SHOP 1-2
1.4 DESCRIPTION OF THE SELECTED REMEDY ....1-2
1.5 STATUTORY DETERMINATIONS 1-3
1.6 SIGNATURE AND SUPPORT AGENCY ACCEPTANCE OF REMEDY 1-3
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME, LOCATION, AND DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
2.2.1 History of Site Activities 2-1
2.2.2 Previous Investigations 2-7
2.2.3 Enforcement Actions 2-10
2.3 SCOPE AND ROLE OF RESPONSE ACTION AT SITE 17 2-10
2.4 SUMMARY OF SITE CHARACTERISTICS 2-11
2.4.1 Description of Contamination 2-11
2.4.2 Contaminant Migration 2-11
2.5 SUMMARY OF SITE RISKS... 2-16
2.5.1 Human Health Risks 2-16
2.5.2 Environmental Evaluation .....2-23
2.5.3 Development of Remediation Criteria (RC) 2-26
2.5.4 Assessment of Site 17 Risk and Contaminated Soil Volume . 2-29
2.6 DESCRIPTION OF ALTERNATIVES 2-30
2.6.1 Alternative 1 - No Action 2-33
2.6.2 Alternative 2: Impermeable Capping and Institutional Controls 2-33
2.6.3 Alternative 3: In-Situ Chemical Fixation/Solidification With Institutional Controls ....2-35
2.6.4 Alternative 4: Excavation and Off-Site Treatment/Disposal 2-36
2.6.5 Alternative 5: Excavation, On-Site Thermal Desorption, And Backfilling Of
Treated Soil 2-37
2.6.6 Alternative 6: Excavation Of Soil Hotspots, Off-Site/On-Site Treatment,
Backfilling/Disposal; and Soil/Gravel Cover Over Entire Site 2-38
2.6.7 Summary 2-41
2.7 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES 2-41
2.7.1 Threshold Criteria 2-41
2.7.2 Primary Balancing Criteria 2-45
2.7.3 Modifying Criteria 2-47
2.8 THE SELECTED REMEDY 2-47
2.8.1 Performance Standards of Preferred Remedy 2-48
2.9 STATUTORY DETERMINATIONS 2-50
2.9.1 Protection of Human Health and the Environment 2-51
2.9.2 Compliance with ARARs 2-51
2.9.3 Cost Effectiveness 2-53
2.9.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable 2-56
2.9.5 Preference for Treatment as a Principal Element , 2-56
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TABLE OF CONTENTS (Continued)
SECTION PAGE NO.
3.0 RESPONSIVENESS SUMMARY 3-1
3.1 COMMUNITY PREFERENCES 3-1
3.2 INTEGRATION OF COMMENTS 3-1
GLOSARRY 1
REFERENCES R-1
APPENDICES
A . LETTER OF CONCURRENCE
B PUBLIC MEETING TRANSCRIPTS
C TABLE OR ARARs
TABLES
SECTION PAGE NO.
2-1 Summary of Soil Analytical Results 2-12
2-2 Soil Data Compared to Soil Screening Levels (SSLs) and Groundwater Data %... 2-14
2-3 Statistical Summary of Data for Human Health COPCs 2-18
2-4 Exposure Factors for Human Health Evaluation {Reasonable Maximum Exposure) 2-20
2-5 Toxicity Criteria for Human Health 2-21
2-6 Summary of Human Health Risks 2-24
2-7 Summary of Maximum Hazard Quotients for Ecological COPCs.. , 2-25
2-8 Summary of Human Health, Ecological and Groundwater Protection RC 2-27
2-9 Summary of Salient Features of Alternatives 2-42
2-10 Summary of Comparative Analysis of Alternatives 2-43
2-11 Operable Unit 1, Soils 2-48
FIGURES
SECTION PAGE NO.
2-1 Facility and Site 17 Location Map 2-3
2-2 Site 17 and Immediate Surroundings .. 2-5
2-3 Site 17 Detail 2-6
2-4 Estimated Area of Soil Contamination Exceeding PRGs 2-29
2-5 Percentage DDTR Removed/Treated and Corresponding Volumes of Contaminated Soil 2-50
2-6 Comparison of Costs for Soil Volumes Removed/Treated under each Alternative.... 2-51
in
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ACRONYMS
ARARS Applicable Or Relevant and Appropriate Requirements
B&R Brown & Root (Environmental)
BAF Bioaccumulation Factor
BTAG Biological Technical Advisory Group
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
COCs Contaminants of Concern
COPCs Contaminants of Potential Concern
CKD Cement Kiln Dust
CPF Cancer Potency Factor
EE/CA Engineering Evaluation/Cost Analysis
EPA Environmental Protection Agency
EPC Exposure Point Concentration
FFS Focused Feasibility Study
Fl Fractional Intake
FR Federal Register
HI Hazard Index
HNUS Halliburton NUS
ICR Incremental Cancer Risk
IR Installation Restoration
IRI Interim Remedial Investigation
LDR Land Disposal Restriction
LOAEL Lowest Observed Adverse Effects Level
MCL Maximum Contaminant Level
MDE Maryland Department of the Environment
NAS Naval Air Station
NCP National Contingency Plan
NOAEL No Observed Adverse Effects Level
PRAP Proposed Remedial Action Plan
RBC Risk Based Concentration
RCRA Resource Conservation and Recovery Act
RfD Reference Dosage
ROD Record of Decision
iv
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SVOCs Semi-Volatile Organic Compounds
TCL Toxic Compounds List
TCLP Toxicity Characteristic Leaching Procedure
TSDF Treatment/Storage/Disposal Facility
VOCs Volatile Organic Compounds
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1.0 DECLARATION FOR THE RECORD OF DECISION
1.1 SITE NAME AND LOCATION
Site 17-Pesticide Shop is located at Naval Air Station (NAS) Patuxent River, Maryland. This Record of
Decision (ROD) addresses the contaminated soil at this site.
1.2 STATEMENT OF BASIS AND PURPOSE
. '
This ROD presents the following final remedy for Operable Unit 1 (OU 1) soil at Site 17:
Excavation of soil that poses an unacceptable risk to human health (soil with contaminant
concentrations that exceed human health and groundwater protection remediation criteria (RC)).
Excavated soil will be treated off-site treatment by incineration and disposed of at a Resource
Conservation Recovery Act (RCRA) Subtitle C facility.
Conduct site-specific soil toxicity and bioaccumulation tests during the remedial design and remedial
action (RO/RA) on the contaminated soil. The data from the site-specific soil toxicity tests will be
used to complete the ecological risk assessment to determine if there is an unacceptable risk to
ecological receptors.
If there is an unacceptable risk to ecological receptors, the Navy shall place a vegetated soil and
gravel cover over the contaminated soil that poses an unacceptable risk to ecological receptors. The
vegetated soil and gravel cover will protect ecological receptors by eliminating the pathway of
exposure to the receptors.
Institutional controls to limit the use of the property so that integrity of the gravel and soil cover will not
be compromised. The need for institutional controls to protect human exposure will be evaluated
following completion of confirmatory sampling.
The selected remedial action was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980, as amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986, and to the extent practicable, the National Oil and
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Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the administrative
record for Site17 which was developed in accordance with Section I13(k) of CERCLA, and is available for
public review. By excavation and removal of the contaminated soil in excess of human health and
groundwater protection levels, the U.S. Navy plans to remedy the primary potential threats to human
health: direct exposure to contaminated soil and migration of contamination into the groundwater. If
required by site-specific ecological toxicity tests, the use of a soil cover with a layer of gravel over the
entire site is proposed by the U.S. Navy to protect potential ecological receptors from the threat of
exposure to the residual contaminants in the soil. The State of Maryland acting through the Maryland
Department of Environment (MDE) concurs with the selected remedy for Site 17.
1.3 ASSESSMENT OF SITE 17-PESTICIDE SHOP
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing
the response action selected in this ROD, may present an imminent and substantial endangerment to
public health, welfare, or the environment.
1.4 DESCRIPTION OF THE SELECTED REMEDY
......... w
Pond 3 will be addressed as a separate operable unit.
The U.S. Navy has determined that excavation and offsite incineration of the approximately 1,300 cubic
yards of soil contaminated that exceed human health and groundwater protection levels, is appropriate for
the contaminated soil at this site. Potential exposure to the. soil and migration of the contaminants are the
principal threats posed by the site. This remedy involves excavation of the soil followed by off-site
incineration and landfilling of the ashes. The remaining contaminated soil over the area of approximately
51,000 square feet will be regraded and covered with a 2 feet barrier (consisting of soil and gravel) and
vegetation. The necessity of the soil/gravel barrier over the remaining contaminated area and the extent
of the barrier will be verified based on ecological protection criteria, which will be determined by site-
specific toxicity tests conducted during the remedial design and remedial action (RD/DA). The remedy will
also include demolition of aboveground buildings and structures and excavation of underground structures
such as a dry well and holding tank. At the time of excavation of underground structures, soil *
contaminated at levels that exceed groundwater protection levels established in the record of decision
(ROD) will also be excavated and incinerated off site.
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1.5 STATUTORY DETERMINATIONS
The remedy selected by both the EPA and U.S. Navy with State of Maryland concurrence for Site 17 is
protective of human health and the environment, complies with federal and state requirements that are
legally applicable or relevant and.appropriate requirements to this remedial action, and is cost-effective.
Because this remedy will result in contaminants remaining in soil on site above unlimited residential use
and ecological screening levels, the 5-year review process will apply to this action. This remedy uses
permanent solutions and alternative treatment technologies to the maximum extent practicable for this
site. The selected remedy satisfies the statutory preference for remedies that employ treatment as a
principal element to reduce toxicity, mobility, or volume of contaminants.
1.6 SIGNATURE'AND SUPPORT AGENCY ACCEPTANCE OF REMEDY
This ROD represents the selection of a remedial action under CERCLA for Site 17 OU1. The foregoing
represents the selection of a remedial action by the Department of the Navy and the United States
Environmental Protection Agency Region III with the concurrence of the Maryland Department of
Environment
Concur and recommend for immediate implementation:
Department of the Navy
By: ^Y&tf/ £ *>ft«^it/v^a Date: *ft //{^ 9%
Captain Paul Roberts
Commanding Officer
Naval Air Station
Patuxent River, Maryland
United States Environmental Protection Agency
By: *-JL~~<^ Date:
Abraham Ferdas, Director
Hazardous Site Cleanup Division (3HSOO)
U.S. Environmental Protection Agency, Region I
Philadelphia, Pennsylvania
1-3
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2.0 DECISION SUMMARY
2.1 SITE NAME, LOCATION, AND DESCRIPTION
This Record of Decision (ROD) is issued to describe the U.S. Navy's selected remedial action for
Operable Unit 1 (OU1), Soil at Site 17-Pesticide Shop, at the Naval Air Station (NAS), Patuxent River,
Maryland (Figure 2-1). The Pesticide Shop is one of several Installation Restoration (IR) sites located at
the NAS. Site 17 - Pesticide Shop is located in the central part of the NAS, at the intersection of Tate
Road and Payne Road (Figure 2-2).
Site 17 consists of the land surrounding Building 841 and nearby storage sheds that are surrounded by a
fence (Figure 2-3). As shown on Figure 2-2, the sediments in the stream south of Tate Road and
sediments in Pond 3 (located approximately 1000 feet south/southwest of the pesticide shop location) are
downgradient of Site 17, but are not considered a part of OU1 at this site for the purpose of this remedial
action. Open fields are located to the north and east of the site, while wooded areas are located east and
south (across Payne Road) of the site. Site 17 is next to Pond 4 and up gradient of Pond 3. The Navy in
conjunction with the State of Maryland has imposed a restriction on consumption of fish from the ponds.
Access to Site 17 is restricted. A security fence surrounds the site thus restricting access. The area
immediately west of the site (Pond 4 Area) is used for recreational purposes. Areas immediately north.
east and south of the site are undeveloped. Groundwater flows toward Pond 3, the Patuxent River and
the Chesapeake Bay. Base residential housing is located within a quarter (1/4) mile of the site on Payne
Road. The community of Lexington Park is about 'A of a mile west of the site and next to the installation
boundary.
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.2.1 History of Site Activities
Pest and weed control operations at the NAS were based at Building 841 from 1962 to 1989. Pesticides
used in the pest control operations have included chlorinated hydrocarbons, carbamates, hormones,
fungicides, and wood preservatives. Herbicides were also used. Some specific pesticides/herbicides
used at the NAS included 4,4'-DDT, sevin, malathion, aldrin, diazinon, naled, lead arsenate, dieldrin,
chlordane, pentachlorophenol (PCP), methoxychlor, entex, sodium arsenate, 2,4-D, and kepone.
Although pest control practices prior to 1962 cannot be documented, aerial spraying with 4,4'-DDT for
control of mosquitoes was reportedly carried out until the late 1950s (Fred C. Hart, March 1984). Aerial
spraying for control of Japanese beetles was done more recently (1969-1971) (HNUS, April 1995).
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2-3
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DRAFT
POND 4
SITE 17 \
NOTE: MAP BASED ON CH2M HILL 1991 RI
LEGENp
APPROXIMATE SITE BOUNDARY
200
SCALE IN FEET
400
DRAWN BY DATE
PIT 5/5/98
Brown A Root Envtromwntal
CONTRACT NO.
7194
OWNER NO.
0259
CHECKED BY DATE
APPROVED
^CCfeT/SCHED-AREA
SCALE
AS NOTED
SITE 17 AND IMMEDIATE SURROUNDINGS
NAS PATUXENT RIVER
MARYLAND
APPROVED BY
DATE
DATE
DRAWING NO.
FIGURE 2-2
REV.
FDRH CABD NO. SOUTH.AVDWG - REV 0 - 02/07/97
099812/P
2-5
CTO 0259
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AC AD: 7194cm 28.dwg 12/01/98 DT
to
I
FORMER ASPHALT
TRUCKWASH PAD
(APPROXIMATE
LOCATION)
FORMER LOCATION
TEMPORARY
STORAGE
TANKS
DRY WELL
(APPROXIMATE
LOCATION)
.'FORMER
yOISCHARGE
PIPE
APPROXIMATE
OUTLINE OF
REMOVAL ACTION. 1991
DRAINAGE PIPE
OVERHEAD POWER LINE
CURRENT FENCE LINE
CONTOUR LINES
// / REMOVAL ACTION AREA
NOTES:
FROM HAND DRAWN SKETCH MAP.
LOCATIONS MEASURED WITH TAPE-
MEASURE AND HAND-HELD COMPASS
100
i^HBH
SCALE IN"FEET
DRAWN BY DATE
PIT 5/5/98
[Itj T«tri Twh NUS, Inc.
CONTRACT NO.
7194
OWNER NO.
0259
DATE
APPROVED BY
DATE
SCALE
AS NOTED
SITE 17 DETAIL
NAS PATUXENT RIVER
MARYLAND
APPROVED BY
DATE
DRAWING NO.
FIGURE 2-3
REV.
0
CPRM CADD MX SOUtH.AV.DVO - REV 0 - 02/07/97
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From 1962 to 1979, hand held spraying equipment was cleaned and rinsed into sinks in Building 841. The
sinks were connected to an underground dry well system located at the northwestern corner of the
building, as shown in the site detail in Figure 2-3. Pesticide containers were triple-rinsed in the sinks prior
to being placed in the building dumpster. In addition, mixed unused pesticides and herbicides were also
poured down these sinks. The sink discharges were connected to this dry well system until 1979. In
1979, a concrete wash pad/holding tank was constructed northwest of Building 841 and the sink's
discharge was connected to the holding tank. Thus, in addition to receiving the rinse water from this pad,
the holding tank also received the drainage from the sinks in Building 841. Rinse waters draining into this
holding tank were periodically pumped out and disposed off site by a contractor. It has been estimated
that between 300 and 400 gallons per day of rinse water were generated from the vehicle, equipment, and
mixing sink washdowns. Building 1110 is a quonset hut that is reported to have been used for storage
purposes, but may have also been used for mixing pesticides.
Prior to 1979, an asphalt pad adjacent to Building 841 was used for rinsing pest control vehicles.
Therefore, until 1979, this rinse water drained onto the ground under the wash area or into a nearby
drainage ditch along Payne Road. This drainage ditch drained into a culvert that passed under Tate Road
and ultimately into Pond 3. In 1991, a removal action involving the sediments/soil in the drainage ditch,
culvert, and surrounding areas was performed. Confirmatory sampling included in this removal action
ensured that DDTR (total 4,4'-DDT, 4,4'-DDE, and 4,4'-DDD) and total chlordane concentrations did not
exceed concentration limits. Confirmatory sampling verified that DDTR was below 4 mg/kg and total
chlordanes were below 2 mg/kg.
2.2.2 Previous Investigations
i
The following is a summary of previous investigations and remedial activities conducted at Site 17 (details
are presented in the Engineering Evaluation/Cost Analysis report, EE/CA [HNUS, April 1995]):
An Initial Assessment Study (IAS) (NEESA, 1984) was performed to evaluate potentially contaminated
sites at NAS. The I AS showed that 14 sites including Site 17 required further study to confirm or deny
a problem at the sites.
A confirmation study was performed by CH2MHill in 1985 and 1987. Soil, sediment and surface water
samples were collected and analyzed for volatile organic compounds (VOCs), semivolatile organic
compounds (SVOCs), and pesticides. Installation of monitoring wells, and sampling of groundwater
for pesticides were also conducted.
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Fish from Pond 3 and a reference pond were collected and tissue samples were analyzed for
pesticides, herbicides and metals in 1985. Fishing activities were temporarily discontinued at Pond 3,
then subsequently resumed with fish consumption limits.
A State of Maryland inspection of the outfall from the storm water drain system for the concrete wash
pad in 1989 revealed elevated concentrations of malathion and chlordane. The April 4, 1989, Site
Complaint
Number SC-0-89-091 stated that malathion was detected at 36,433 milligrams per kilogram (mg/kg)
and chlordane was detected at 3,737 mg/kg. A malfunctioning valve on the holding tank was the
cause of the release into the drain system. The stormwater bypass from the rinse pad was then
discontinued.
An Engineering Evaluation/Cost Analysis (EE/CA) (CH2M Hill, 1990) was conducted in 1990 to
evaluate removal action alternatives for Sites 17 and 28. In support of this EE/CA, a pre-response
action was performed by CH2MHHI in 1989. Soil and sediment samples were collected and analyzed
for chlorinated pesticides, organophosphorus pesticides, herbicides, and metals.
In 1991, CH2MHHI performed a removal action involving: excavation of soil in the drainage ditch along
Payne Road; excavation of soil under a portion of Payne Road (including pavement); excavation of
soil/sediment material in the culvert that passes under Payne Road; excavation of soil in the drainage
ditch along Tate Road from Payne Road to the culvert passing under Tate Road; and excavation of
the discharge pipe from the concrete pad to the drainage ditch along Payne Road and adjacent soil.
The removal action included confirmatory sampling to ensure that total DDTR and dieldrin levels did
not exceed the action level of 4 mg/kg and total chlordanes did not exceed the action level of 2 mg/kg.
The depth of excavation ranged from 1.0 to 6.0 feet below ground surface.
An interim remedial investigation (IRI) was performed by CH2MHJII in 1992. This study involved
additional soil, groundwater (including installation of additional monitoring wells), surface water, and
sediment sampling. All media were analyzed for Target Compound List (TCL) pesticides,
organophosphorus pesticides, and lead. Groundwater and sediments were also analyzed for
herbicides. The IRI report was issued in 1994.
Halliburton NUS (HNUS) conducted an engineering evaluation/cost analysis support investigation in
1994. This involved soil sampling and analysis for TCL pesticides to define the extent of
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contamination; groundwater sampling and analysis for TCL pesticides as a result of the IRI
recommendation; and surface water and sediment sampling and analysis for TCL pesticides to further
delineate the impact from the site. Sediment samples were also analyzed for teachability (i.e. the
tendency to migrate) of pesticides by Toxicity Characteristic Leaching Procedure (TCLP) testing.
HNUS prepared an Engineering Evaluation/Cost Analysis Report in 1995 (HNUS, 1995). This was
prepared in support of a removal action at three sites, including Site 17. The focus was on evaluating
removal action alternatives for soil and sediment, using an action level of 4 milligrams/kilogram for
.total DDTR and dieldrin.
In 1997, a chemical fixation/solidification bench-scale treatability study was conducted by Brown &
Root (B&R) Environmental for surface soil at this site. The study showed that the mobility of
pesticides and
metals of concern (as identified in earlier studies) was significantly reduced by treating the soil with
cement and cement kiln dust.
Also, in 1997, a thermal desorption and gas-phase destruction pilot-scale treatability study was
conducted by Eli Eco Logic (Eli Eco Logic, 1997) for surface soil at this site. The study showed that
over 99 percent removal/destruction of pesticides in the soil can be achieved by thermal desorption at
550 to 600 °C (approximately 1000 °F) followed by reduction (reacting the pesticides in gas phase
with hydrogen) to yield relatively innocuous compounds.
A predesign sampling effort was conducted by B&R Environmental in 1997 to determine whether
select metals are present in surface soil and to determine the geotechnical characteristics of the
surface soil.
In 1997, the Agency for Toxic Substances and Disease Registry (ATSDR) evaluated the
environmental information on the 46 IR sites at NAS, including Site 17, and assessed the potential for
human exposure at each site. The study concluded that none of the IR sites posed a current public
health hazard.
In 1998. B&R Environmental performed a focused feasibility study (FFS) for Operable Unit 1 (OU1)
(TtNUS, 1998) which examined different remedial alternatives to address the soil contamination at
Site 17. Navy presented the preferred remedial alternative at a public meeting on September 29,
1998. This FFS was the basis for developing the preferred alternative discussed in this ROD.
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In 1998, CH2M Hill collected and analyzed background soil samples for pesticides and inorganics at
Site 17 (CH2M) Hill, October 16,1998).
2.2.3 Enforcement Actions
A site complaint (SC-0-89-091 /April 4, 1989) was issued from the State of Maryland Department of the
Environment (MDE) for the release of pesticides from a pad to a drainage ditch. Subsequent actions
included the temporary banning of fishing in Pond 3, ceasing all operations at the Pesticide Shop, and
initiating a removal action. A consent order (CO-91-1 OS/December 26, 1990) was entered into with the
MDE for the removal action. Fishing in Pond 3 has been resumed, with an individual consumption limit.
2.3 SCOPE AND ROLE OF RESPONSE ACTION AT SITE 17
Site 17 represents one component of a comprehensive environmental investigation and cleanup presently
being performed at NAS Patuxent River. Past disposal operations at Site 17 have mainly contaminated
the soil. The principal potential risks are from this medium. The National Contingency Plan (NCP) (40
CFR 300.430(a)(1)(ii)(A)) states "Sites should generally be remediated in operable units when early
actions are necessary or appropriate to achieve significant risk reduction quickly, when phased analysis
and response is necessary or appropriate given the size or completion of total site cleanup." Accordingly,
the soil has been chosen as a separate operable unit (Operable Unit 1).
The selected remedial action identified in this ROD addresses Site 17, Operable Unit 1, i.e. soil
contamination associated with Site 17 as identified in the Interim Remedial Investigation, Engineering
Evaluation/Cost Analysis and Focused Feasibility Study reports. The selected remedy for this medium is
identified and the rationale for selection is described in Section 2.8.
The selected remedy will reduce the potential risk to human health and the environment associated with
site soils. The remedy consists of removal of above-ground and under-ground structures, the excavation
of soil containing the highest concentrations of pesticides that pose a potential threat to human health and
impact to groundwater, and the treatment of the excavated soil by incineration at a certified off site
hazardous waste treatment facility. The selected remedy may also consist of placing a gravel cover and
clean soil over the site if the remaining soil contains pesticides at levels that may pose a potential threat to
ecological receptors. During the remedial design and remedial action (RD/RA) phase, site-specific soil
toxicity tests will be conducted. The site-specific soil toxicity tests will consist of direct soil toxicity and
bioaccumulation tests. The results of the site-specific soil toxicity tests will be used to complete the
ecological risk assessment for soil at the site. If the site-specific soil tests reveal
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that the residual contaminated soil poses an unacceptable risk to ecological receptors, then the Navy shall
construct a vegetated soil and gravel cover over contaminated soil. The soil and gravel cover will
eliminate the pathway of exposure between the soil and ecological receptors. The soil cover will be
vegetated to minimize erosion. Cap maintenance, monitoring of cap integrity, and verification of cap
efficacy, as necessary will also be conducted.
i
This remedy is consistent with long-term remedial goals for Site 17. The selected remedial action will
remove the soil that poses the principal threat to human health from contact with the soil, which includes
soil containing contaminants that could migrate into the groundwater and adversely impact it. The
selected remedy will also minimize the risk arising from potential exposure to soil by ecological receptors.
The gravel layer and soil cover will eliminate the pathway of exposure to ecological receptors. This
remedy will not address groundwater or surface water and sediment in Pond 3 at the site. Remediation of
these other media, if necessary, will be addressed in the final ROD for the site.
2.4 SUMMARY OF SITE CHARACTERISTICS
Several investigations have been conducted at this site as summarized in Section 2.2.2. The following is
a summary of the findings related to the surface soil contamination at this site.
2.4.1 Description of Contamination
This section provides a summary of the analytical data for soil samples that were collected during previous
investigations at this site. Table 2-1 provides an overall summary of the analytical results from the Interim
Remedial Investigation and the 1994 EE/CA field activities. The surface soil data presented herein was
obtained from investigations that were performed after the 1991 removal action.
As shown by the data presented in Table 2-1, pesticides, in particular, 4,4-DDT, 4,4'-DDD, and 4,4'-DDE
(collectively referred to as DDTR) were the most widely detected and present at the highest
concentrations.
2.4.2 Contaminant Migration
Contaminant transport modeling was used to predict the potential migration of contamination from the soil
into the groundwater at the site. The potential impact of further transport of the contaminants through
groundwater to the surface water and sediment at Pond 3 was also assessed.
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TABLE 2-1
SUMMARY OF SOIL ANALYTICAL RESULTS
OPERABLE UNIT 1, SOIL
SITE 17: PESTICIDE SHOP
NAS PATUXENT RIVER, MARYLAND
Parameter
Range of Detected
Concentrations
Frequency of
Detection
PESTICIDES (BACKGROUND SOIL RANGE*31) (microgram per kilogram, M9/kg)
Heptachlor (ND)
Aldrin (ND)
Heptachlor Epoxide (ND)
Dieldrin (ND)
4,4'-DDE(1) (0.34 -670).
Endrin (ND)
4,4'-DDD(1) (1.75 -10.5)
4,4'-DDT(1> (0.43 -240)
Methoxychlor (ND)
Alpha-Ch!ordane(2) (ND)
Gamma-Chlordane<2) (ND)
79
109-26,000
670
720 - 37,000
13-76,000
130
5.7-1,800,000
6.1 -5,000,000
22,000
2,000 - 28,000
2,900 - 27,000
1/20
2/39
1/20
7/39
39/39
1/20
33/39
39/39
1/20
3/39
2/39
METALS (BACKGROUND SOIL RANGE(J))(milligram per kilogram, mg/kg)
Lead (7.2 -25.1)
Arsenic«'(1.4-4.1)
8.9 - 447
2.3-35.1
19/19
5/5
ND: Not Detected
1 The maximum background value of total DDTR = 810 ug/kg.
2 Fixed-base laboratory analytical results for chlordane.
3 Obtained from CH2M Hill Technical Memorandum (October 16,1998).
4 Arsenic was detected only in samples collected during a pre-design investigation by B&R
Environmental, 1997.
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The following detected pesticides and inorganics were evaluated in the modeling for migration of soil
contaminants via groundwater:
4,4'-DDD
4,4'-DDE
4,4-DDT
Dieldrin
Aldrin
Alpha and Gamma Chlordanes
Endrin
Heptachlor
Heptachlor Epoxide
Methoxychlor
Arsenic
Lead
The above listed contaminants include those that were detected at concentrations exceeding default Soil
Screening Levels (SSLs) obtained from EPA guidance (EPA. 1996), as noted on Table 2-2. Under a no
action scenario, using conservative assumptions considering maximum detected concentrations, the
following contaminants were predicted to have the potential to violate groundwater standards:
Dieldrin
Arsenic
Lead
The groundwater standards chosen were either Maximum Contaminant Levels (MCLs) under the Safe
Drinking Water Act or Tap Water Risk Based Concentrations (RBCs) from EPA Region III. The modeling
predicted that the concentration of dieldrin would exceed its RBC of 0.0042 ug/L, lead would exceed its
action level of 15 ug/L, and arsenic would exceed its MCL of 50 ug/L
The predicted increases in concentrations of dieldrin, arsenic and lead were: 0.037 ug/L, 73.6 ug/L, and
28.9 ug/L, respectively. The current concentrations of dieldrin in the groundwater (noted on Table 2-2)
already exceed the Region III Tap-water RBC value, therefore dieldrin is a contaminant of concern (COC)
that has already migrated from the soil to the groundwater and has a potential to continue to migrate.
2-13
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TABLE 2-2
SOIL DATA COMPARED TO Soil Screening Levels (SSLs) AND GROUNDWATER DATA
OPERABLE UNIT 1, SOIL
SITE 17: PESTICIDE SHOP
NAS PATUXENT RIVER, MARYLAND
Parameter
Soil Concentration
Range (ng/kg)
Frequency of
Detection In Soil
Soil Screening
Levels (ug/kg)
for
Groundwater
Protection
Groundwater
Concentration Range'3'
(Mg/L)
Frequency of Detection
in Groundwater
PESTICIDES
Heptachlor
Aldrin
Heptachlor Epoxide
Dieldrin
4,4'-DDE
Endrin
4,4'-DDD
4,4'-DDT
Methoxychlor
Alpha-Chlordane
Gamma-Chlordane
79
. 109-26,000
670
720-37,000
13-76,000
130
5.7-1,800,000
6.1-5,000,000
22,000
2,000 - 26,000
2,900-27,000
1/20
2/39
1/20
7/39
39/39
1/20
33/39
39/39
1/20
3/39
2/39
23.000
500
700
4
54,000
1,000
16.000
32,000
160,000
10,000
10,000
0.01U
0.01 U
0.0067-0.0088
0.052-0.46
0.01
0.0058
Not Analyzed
0.0046-0.1
0.092
0.0091-0.11
0.0094-0.14
0/7
0/7
2/7
6/7
1/7
1/7
NA
3/7
1/7
4/7
4/7
METALS
Lead
Arsenic
8.9-447mg/kg
2.3-35.1mg/kg
19/19
5/5
None Specified
29 mg/kg
1.1-5.7
4.5-6.1
5/7
2/7
1 Background value for total DDTR: DDE + ODD + DDT is reported to be approximately 810 pg/kg (CH2M Hill, October 16,1998)
2 Analysis performed by a fixed-base laboratory for chlordane.
3 Groundwater data was obtained from October 1996 and March 1997 sampling events, which is available in a memo from CH2M HUI to EFA
Chesapeake.
U: Not detected at the detection limit noted.
Shaded, cell indicates'that the soil concentration exceeds SSL.
-------
However, the current concentrations of arsenic and lead (also noted on Table 2-2) do not exceed their
respective groundwater standards. While there is a potential for both of these elements to continue to
migrate from the soil into the groundwater as predicted by the modeling results, only arsenic was retained
a COC in addition to dieldrin for RC development. In accordance with risk assessment procedures, lead
,was not retained as a COC because the EPA lexicologist input the mean soil lead concentration (91.7
mg/kg) and the mean groundwater lead concentration (5.2 ug/l) in the Integrated Exposure Uptake
Biokinetic Model for Lead in Children. The model predicted the mean concentration of lead (in ug/dl) in
children ages 0 to 84 months to be 3.3 ug/dl and 0.82 % of children are predicted to have a blood lead
level of 10 ug/dl. EPA considers risk to children unacceptable when more than 5% of the children are
predicted to have blood lead concentrations 10 ug/dl. Therefore, risk posed by lead in soil is within
acceptable limits under EPA guidance. However, arsenic and dieldrin were retained as COCs at the site
to protect groundwater.
The modeling results showed that none of the contaminants of concern (COCs) would exceed surface
water standards at the boundary of Pond 3. Therefore, potential remedial actions at the site should
address minimization of infiltration or reduction of concentration or mobility of arsenic and dieldrin for
protection of groundwater only. Details of the modeling process and results are presented in Appendix A
of the FFS (TtNUS, September 1998).
Contaminant migration through the surface runoff pathway was considered for its potential to occur via
erosion of contaminated surface soil followed by drainage into the ditch south of Building 841 along Payne
Road. No pathways of surface water/sediment migration away from the site other than this drainage ditch
are known. It was noted that the areas of soil contamination south of Building 841 that could have had the
greatest potential to contribute to surface runoff to the drainage ditch were excavated during the removal
action in 1991, and the excavated areas were backfilled to grade and covered with top soil and vegetation.
The remaining portion of the
site is not expected to contribute to contaminant migration through the surface runoff pathway owing to the
presence of erosion-retarding features such as gravel-covered areas and concrete pads. Moreover, the
presence of a vegetated area south of Building 841 hydrauiically downgradient of the contaminated soil,
but upgradient of the ditch, is expected to further retard contaminant migration due to surface water flow
from areas north of the building. Therefore, contaminant migration through the surface runoff pathway
was not considered as a significant pathway, and was not further evaluated.
2-15
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2.5 SUMMARY OF SITE RISKS
Potential human health and ecological risks associated with exposure to contaminated media at Site 17
were evaluated as part of the FFS. Although the current and potential (reasonably foreseeable) future
land use at the site is expected to be industrial, other scenarios of uncontrolled use were also evaluated.
Also, even though no current ecological receptors have been identified at the site, in the event that the site
is abandoned, it could become an ecological habitat and risks to potential receptors in such a hypothetical
habitat were also evaluated. Based on the estimated potential risks to receptors, Remediation Criteria
(RC) were developed for COCs in surface soil to establish concentrations that would reduce human health
and ecological risks to acceptable levels. Although there are no current groundwater users at the site and
no future groundwater users are expected, groundwater protection RC were also developed for COCs in
the soil.
2.5.1 Human Health Risks
The receptors evaluated in this risk evaluation were: future adult and child residents, current and future
site workers, future construction workers, and current adult and child trespassers. Each receptor was
evaluated based on exposure to soil through incidental ingestion, dermal contact and inhalation of dust
particles. Chemicals present in the soil were selected for detailed evaluation based on a comparison of
their concentrations with screening levels. Chemicals with concentrations exceeding screening levels
were identified as chemicals of potential concern (COPCs). COPCs were selected in accordance with the
screening procedure outlined in U.S. EPA Region III guidance (EPA 1993). Chemicals detected at
concentrations greater than the screening levels were then evaluated for their potential to cause a
cumulative incremental cancer risk (ICR) or cumulative hazard index (HI) using Cancer Potency Factors
(CPFs) or Reference Doses (RfDs), respectively.
Aldrin, dieldrin, 4,4'-DDE, 4,4'-DDD, 4,4'-DDT, and alpha and gamma chlordane were identified as
COPCs. Arsenic and lead were also detected in the soil samples. Lead concentrations were below
screening levels, and therefore not retained in the risk calculation as detailed in the FFS (TtNUS, 1998)
and subsequent review by EPA.
Cancer potency factors (CPFs) have been developed by EPA's Carcinogenic Assessment Group for
estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic chemicals.
CPFs, which are expressed in units of (mg/kg-day)-1, are multiplied by the estimated intake of a potential
carcinogen, in mg/kg-day, to provide an upper-bound estimate of the excess lifetime cancer risk
2-16
-------
associated with exposure at that intake level. An excess lifetime cancer risk is the increase in likelihood
of developing cancer during one's lifetime because of exposure to site-specific chemicals. The term
"upper bound" reflects the conservative estimate of the risks calculated from the CPFs. Use of this
approach makes underestimation of the actual cancer risk highly unlikely. Cancer potency factors are
derived from the results of human epidemiological studies or chronic animal bioassays to which anima!-to-
human extrapolation and uncertainty factors have been applied.
Reference doses (RfDs) have been developed by EPA to indicate the potential for adverse health effects
from exposure to chemicals exhibiting noncarcinogenic effects. RfDs, which are expressed in units of
mg/kg-day, are estimates of lifetime daily exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g., the amount of a chemical ingested from
contaminated drinking water) can be compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been applied (e.g., to account for the use of
animal data to predict effects on humans). These uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects to occur.
Calculation of Exposure Point Concentrations
Exposure point concentrations are estimated chemical concentrations that a receptor may contact and are
specific to each exposure medium. Exposure concentrations were calculated assuming the data were
lognormally distributed. The exposure concentration is represented by the lesser of the maximum
detected concentration and the 95% upper confidence limit of the mean (UCL) of the lognormal
distribution.
The statistical analysis of the data and the exposure point concentrations for COPCs are summarized in
Table 2-3. The exposure point concentrations for these COPCs are also presented in the risk calculation
tables in Appendix B of the FFS (TtNUS, 1998).
Exposure Assessment
The receptors evaluated in this risk evaluation were as follows:
future adult and child residents,
current and future site workers,
future construction workers, and
current adult and child trespassers.
2-17
-------
TABLE 2-3
STATISTICAL SUMMARY OF DATA FOR HUMAN HEALTH COPCs
OPERABLE UNIT 1, SOIL
SITE 17: PESTICIDE SHOP
NAS PATUXENT RIVER, MARYLAND
Chemical
Aldrin
Dieldrin
4,4'-DDE
4,4'-DDD
4,4'-DDT
Chlordanes
Frequency
of
Detection
2/39
7/39
39/39
33/39
39/39
3/39
Maximum
Detection
(mg/kg)
26
37
78
1800
5000
55
Minimum
Detection
(mg/kg)
0.19
0.72
0.013
0.006
0.006
2.0
Arithmetic
Mean
(mg/kg)
0.8
3.9
11.6
58.5
332
1.6
Standard
Deviation
(mg/kg)
3.9
8.7
18.2
272
954
8.3
95%
UCL1
(mg/kg)
15.6
1.8E04
178
5.9E04
1.0E05
27.4
EPC2
(mg/kg)
15.6
37
78
1800
5000
27.4
1 Represents the 95% upper confidence limit of the arithmetic mean of the log-transformed data
2 Exposure Point Concentrationlesser of the Maximum Detection and the 95% UCL
2-18
-------
Each receptor was evaluated based on exposure to soil through incidental ingestion, dermal contact, and
inhalation of dust particles. The exposure assumptions are summarized in Table 2-4 and presented in the
risk calculation tables in Appendix B of the FFS (TtNUS, 1998).
The intake equations for incidental ingestion, dermal contact and inhalation of dust particles are identical
to those outlined in EPA's Risk Assessment Guidance for Superfund (USEPA, 1989). These intake
equations require specific exposure parameters for each exposure pathway. Exposure parameters are
often assumed values, and their magnitude influences the estimates of potential exposure and risk. The
reliability of the values chosen can also contribute substantially to the uncertainty of the resulting risk
assessments. Many of the exposure parameters have default values, which were used in this risk
assessment. These assumptions, based on estimates of body weights, media intake levels, and exposure
frequencies and durations are provided by EPA guidance. The equations are presented in the risk
calculation tables in Appendix B of the FFS (TtNUS, 1998).
Toxicitv Assessment
Toxicity assessment defines the relationship between the magnitude of exposure and possible severity of
adverse effects, and weighs the quality of available toxicological evidence. This assessment results in the
development of toxicity criteria (e.g., reference doses and cancer slope factors). The toxicity criteria used
in this risk assessment are from EPA's Integrated Risk Information System (IRIS) (EPA 1998b) and Health
Effects Assessment Summary Table (HEAST) databases (EPA 1997b). The toxicity criteria for the
COPCs in this risk assessment are summarized in Table 2-5. In instances where no toxicity criterion was
available for a specific pathway, that pathway was not evaluated.
Risk Characterization
Risk characterization is the process of integrating the previous elements of the risk assessment into
quantitative expressions of risk. These risks are then used in remedial decision-making, defining
preliminary remediation goals, and selecting potential remedies or actions. The potential human health
risks are discussed in terms of carcinogenic and noncarcinogenic effects.
The potential for carcinogenic effects due to exposure to site-related contamination is evaluated by
estimating the incremental excess lifetime cancer risk. The risk is the incremental increase in the
2-19
-------
to
NJ
O
TABLE 2-4
EXPOSURE FACTORS FOR HUMAN HEALTH EVALUATION (REASONABLE MAXIMUM EXPOSURE)
OPERABLE UNIT 1, SOIL
SITE 17: PESTICIDE SHOP
NAS, PATUXENT RIVER, MARYLAND
Genera! Receptor Factors
Body weight
Inhalation rate (m3/day)
Exposure duration (years)
Current and Future Scenarios
Site Worker
70.0*
20.0*
25.0*
Recreational/
Trespasser
(Child)
Recreational/
Trespasser
(Adult)
Future Scenario
Child Resident
15.0'
12.0"
6.0*
70.0
20.0*
24.0"
15.0*
12.0"
6.0*
Adult
Resident
70.0*
20.0*
24.0*
Media-Specific Factors ~~ '
Soil (Surface/Subsurface):
Ingestion rate (mg/day)
Exposure frequency (days/year)
Skin surface area (cm2)
Soil to skin adherence factor (mg/cm)
100.0*
250.0*
5,300'f
1.0'
Construction
Worker
70.0*
13.6°
1.0*
200.0"
104.0*
4.520"'9
1.0'
100.0*
104.0*
5.300''"
1.0'
200.0*
350.0*
4,520*"
1.0'
100.0*
350.0*
5.300'8
1.0'
480.0"
250.0*
5.300''9
1.0'
a = £EPA. Human Health Evaluation Manual. Supplemental Guidance: Standard Default Exposure Factors, OSWER Directive 9285 8-03 March 25 1001
(Soil exposure factors used for sediment.) ««w.«-vj, m
-------
probability of developing cancer during one's lifetime in addition to the background probability of
developing cancer. It is defined by the equation:
Risk = Intake x CSF
where
Intake = amount of chemical taken into the body by a given exposure pathway
CSF = cancer slope factor for a specific chemical by a given exposure pathway
The risks for the various exposure pathways are summed to derive a cumulative risk. If the cumulative
risk exceeds 1E-04 (one in ten thousand), CERCLA generally requires that remedial action be undertaken
at the site.
The potential for noncarcinogenic effects due to exposure to site-related contamination is evaluated by
estimating the hazard quotient. The hazard quotient is the ratio of the intake to the chemical's
corresponding reference dose to determine if a threshold exposure has been exceeded. The hazard
quotient is defined by the equation:
Hazard Quotient = Intake / RfD
where
Intake = amount of chemical taken into the body by a given exposure pathway
RfD = reference dose for a specific chemical by a given exposure pathway
The hazard quotients for the various exposure pathways are summed to derive a hazard index. If the
hazard index exceeds one, a certain degree of health risk is indicated. This approach assumes that
noncarcinogenic hazards are additive. Synergistic or antagonistic interactions between chemicals are not
considered. The hazard index may exceed unity even if all of the individual hazard quotients are less than
one. The chemicals may then be segregated by similar mechanisms of toxicity in order to derive separate
hazard indices for specific target organs.
2-22
-------
The cumulative incremental cancer risks (ICR) for all exposure pathways ranged from 2.3E-04 (2 in
10,000) for the future construction worker to 6.8E-03 (7 in 1,000) for the future resident (Table 2-6). The
risks for both the future construction worker and future resident are primarily attributed to 4,4'-DDT, 4,4'-
DDE and 4,4'-DDD. The noncarcinogenic hazard indices for all exposure pathways are greater than the
EPA's benchmark of one which suggests that exposure to the COPOs is likely to result in adverse
systemic health effects.
Because the cancer risks for the COPCs exceeded the EPA's target risk level of 1E-04 and the hazard
index of one, all the COPCs are being retained as Contaminants of Concern (COCs) for Remediation
Criteria (RC) development.
2.5.2 Environmental Evaluation
A screening-level ecological risk assessment was conducted to evaluate impacts to potential receptors in
the environment. The screening-level ecological risk assessment selected contaminants based on
maximum concentrations exceeding EPA Region III Biological Technical Action Group (BTAG) screening
levels. Screening levels are concentrations of contaminants that have been observed to not have adverse
effects on plants or animals in the environment. The maximum detected concentrations of these
contaminants were divided by the screening level to obtain hazard quotients. If the hazard quotients
exceeded 1.0 or if no screening level was available, then the contaminant was retained as a contaminant
of potential concern. Table 2-7 presents a summary of the maximum hazard quotients associated with
detected COPCs whose concentrations exceeded screening levels. Endrin was detected in only one
sample out of 20, and its concentration was low enough to cause a HI that barely exceeded 1.0.
Therefore, it was not retained as a COC for RC development. Heptachlor was not retained as a COC
because its maximum hazard quotient was less than 1.0.
These COCs have been selected based on literature screening values, therefore a site-specific toxicity
study will be required to verify the potential impact to ecological receptors and to accordingly determine an
ecological RC.
2-23
-------
TABLE 2-6
SUMMARY OF HUMAN HEALTH RISKS
OPERABLE UNIT 1, SOIL
SITE 17: PESTICIDE SHOP
NAS, PATUXENT RIVER, MARYLAND
to
Receptor
Resident
Resident
Trespasser
Trespasser
Site Worker
Construction
Worker
Adult
Child
Adult
Child
Adult
Adult
Noncarcinogenic Risks
Hazard Quotients
Ingestion
15.5
145
4.61
43
11.1
53.1
Dermal
9.95
39.6
2.96
127
7.1
7.1
Total
25
185
7.6
170
18
60
Carcinogenic Risks
Incremental Cancer Risks
Inhalation
3.11E-07
NA
5.44E-08
3.80E-08
1.36E-07
3.70E-09
Ingestion
4.74E-03
NA
4.22E-04
9.85E-04
1.06E-03
2.03E-04
Dermal
2.06E-03
NA
3.06E-04
3.05E-04
7.67E-04
3.07E-05
Total
6.8E-03
NA
7.3E-04
1.3E-03
1.8E-03
2.3E-04
-------
TABLE 2-7
SUMMARY OF MAXIMUM HAZARD QUOTIENTS FOR ECOLOGICAL COPCs
OPERABLE UNIT 1, SOIL
SITE 17: PESTICIDE SHOP
NAS PATUXENT RIVER, MARYLAND
COPC
4,4'-DDD
4,4'-DDE
4,4'-DDT
Aldrin
Alpha-Chiordane
Gamma-Chlordane
Dieldrin
Endrin
Heptachlor
Heptachlor Epoxide
Methoxychlor
Arsenic
Lead
Screening Level (mg/kg)
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
NA
0.1
Maximum Hazard Quotient
18,000
760
50,000
260
280
270
370
1.3
0.79
6.7
220
NA
44,700
2-25
-------
2.5.3 Development of Remediation Criteria (RC>
This section develops remediation criteria (RC) for Site 17. The RC development is limited to soil at the
site considering potential hypothetical human receptors. Table 2-8 presents a summary of RC for human
health and groundwater protection.
2.5.3.1 Human Health RC
Remediation Criteria (RC) are developed to ensure that contaminants remaining on site are at levels that
are protective of human health. Of the receptors likely to be exposed to soils at Site 17, the site worker
and the child trespasser are the most sensitive. The cancer risk for the future residential receptor and the
noncancer risk for the future child residential receptor are greater than that of the site worker and the child
trespasser, respectively, but it is highly unlikely that the site will ever be used for residential purposes.
Since the most reasonable plausible site use is likely to be for industrial purposes, RC were developed
only for protection of the site worker and the child trespasser.
RC were developed for the following pesticides that were identified as COCs: aldrin, dieldrin, 4,4'-DDD,
4.4VDDE, 4,4'-DDT and chlordanes. The RC were developed using the exposure point concentrations
and exposure assumptions that were used to evaluate potential risk. These exposure point
concentrations (EPC) were proportioned to yield concentrations with a target cancer risk equal to 1E-06:
RC (carcinogenic) = (EPC) (1E-06) / (Calculated Risk Level)
In similar fashion, these exposure point concentrations were proportioned to yield concentrations with a
target hazard quotient of 0.25:
RC (noncarcinogenic) = (EPC) (0.25) / (Calculated Hazard Index)
A hazard quotient of 0.25 was selected because four of the six contaminants at Site 17 are evaluated as
noncarcinogens. All four contaminants contribute to the toxicity of the liver. Because the effects of the
contaminants on the liver are assumed to be additive and the benchmark for noncarcinogenic risk is equal
to one, it follows that the target hazard quotient for each contaminant should be one fourth of the target
value, hence a target hazard quotient of 0.25.
2-26
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TABLE 2-8
SUMMARY OF HUMAN HEALTH AND
GROUNDWATER PROTECTION RC
OPERABLE UNIT1, SOIL
SITE 17: PESTICIDE SHOP
NAS PATUXENT RIVER, MARYLAND
Parameter
Aldrin
Dieldrin
4,4'-DDD
4,4'-DDE
4,4'-DDT
Chlordanes
Heptachlor Epoxide
Methoxychlor
Arsenic
Lead
Human Health RC
Parts Per Million (PPM) or
Milligrams Per Kilogram (mg/kg)
ICR = 1E-06
0.08
0.09
7.5
5.2
5.3
5.0
9.0*
HQ = 0.25
0.3
0.6
NA
NA
8.9
8.0
Groundwater
Protection
RC
NA
0.08
NA
NA
NA
NA
NA
NA
23
NA
ICR = Incremental Cancer Risk
HQ = Hazard Quotient
NA - Not Applicable
Concentrations are in mg/kg (ppm).
* Based upon average concentration of 1 x 10E-4 (20 mg/kg) and 1 x 10E-5 (2 mg/kg)
2-27
-------
For all of the COCs, the RC developed based on carcinogenic risk is more restrictive than the RC
developed based on noncarcinogenic risk. Attainment of the RC corresponding to an ICR of IE-06 for
industrial receptors would result in an ICR of 8.5E-05 for a future adult resident and HI of 1.2 for the future
child resident, if the effect of arsenic is excluded. Based upon EPA toxicological review, the arsenic RC
to protect groundwater under residential and industrial exposures would result in a residual risk of arsenic
and these residual levels would pose an unacceptable risk (i.e. cancer risk greater than 1 x 10E-4) for
humans exposed to soil through inhalation, accidental ingestion, or skin contact. As a result, the average
concentration of arsenic that will be protective of human health, considering residential and industrial
exposure to soil, was selected as the RC. The arsenic RC level is 9.0 mg/kg. This is the average
between 2 mg/kg, which would result in a 1 x 10E5 and 20 mg/kg, which would result in a 1 x 10E-6.
Although residential use is unlikely at this site, the residential fCR and HI would meet the EPA's
acceptable ICR range of 1E-04 to 1E-06 and HI upper limit of 1.0. This suggests that institutional controls
may not be required for the site for humans. As a result, we will evaluate the risk following cleanup.
2.5.3.2 Groundwater Protection RC
Groundwater protection RC were being developed for the following COCs that were selected in Section
2.4.2: dieldrin and arsenic. These RC are residual concentrations in soil that would not adversely impact
the groundwater.
Because the current groundwater concentrations of dieldrin already exceed the RBC, its soil RC was
aimed at minimizing its migration from soil to levels that are below the detection limit of dieldrin.
Therefore, the RC for dieldrin will be set at levels that would reduce the soil leachate concentration (prior
to its entrance and mixing/dilution in groundwater) to levels below dieldrin's Contract Required
Quantitation Limit (CRQL) of 0.02 ug/L. Analysis to levels below 0.02 ug/L for dieldrin is not considered
practical.
The RC for arsenic was be developed to be less stringent criteria because the current groundwater
concentrations of this element are at an average of 4 ug/L, which is well below arsenic's MCL of 50 ug/L.
Therefore, the RC for arsenic will be aimed at attaining a future groundwater concentration (after
mixing/dilution) of soil leachate equal to 50 ug/L
2-28
-------
Based on these criteria, modeling was used to develop soil RC for dieldrin and arsenic as follows:
Dieldrin: 84 ug/kg
Arsenic: 23 mg/kg
Details of the model calculations are presented in Appendix A of the FFS (TtNUS, 1998).
2.5.4 Assessment of Site 17 Risk and Contaminated Soli Volume
DDTR are the most prevalent contaminants at the site. Because of the widespread occurrence of DDTR
(compared to other COCs) at levels that exceed both human health RC and background levels, the area
and depth of contaminated soil is expected to be defined by the sample locations where the DDTR levels
exceed these cleanup levels. Since a majority of the soil samples that were collected from the site were
surface soil samples and reported as total DDTR of 18 mg/kg (i.e., DDT+DDE+DDD) concentrations, the
extent of contamination was determined in the FFS on the basis of total DDTR concentrations exceeding
cleanup levels also expressed as total DDTR.
Figure 2-4 shows the soil sample locations with total DDTR concentrations. The hatched area in Figure
2-4 delineates the approximate horizontal extent of soil contamination where DDTR concentrations
exceeded the 1-2 mg/kg range, which is slightly higher than the background value of 0.81 mg/kg. This
area is an estimate of the approximate maximum extent of soil that may need to be addressed for
ecological protection. The need for, and the actual extent of, the area will be determined based on site-
specific ecological cleanup levels to be developed from a site-specific toxicity study that will be conducted
during the remedial design/action phase.
The estimated area of soil contamination within the hatched area on Figure 2-4 is 51,000 square feet. The
average depth of contamination is assumed to be approximately 2.0 feet based on data from a limited
number of soil samples that were collected from depths below 1.5 feet. Based on this estimated area and
assumed depth, the estimated volume of contaminated soil that contains DDTR at levels that exceed the
1-2 mg/kg range is approximately 3,800 cubic yards (5,100 tons).
Figure 2-4 also delineates the approximate horizontal extent of soil contamination where human health RC
are exceeded (shown as a cross-hatched area) within the hatched area. The total estimated area of soil
contamination is 13,400 square feet Based on data from a limited number of samples collected from
2-29
-------
depths below 1.5 feet, as mentioned above, the average depth of contamination that poses a risk to
humans is also assumed to be 2.0 feet. Based on this estimated area and the previously assumed depth
of contamination of 2.0 feet, the estimated volume of soil that poses a risk to humans is approximately
1.000 cubic yards (1,350 tons). Sample locations where the highest concentrations of arsenic and dieldrin
could potentially impact groundwater are also included within the hot-spots. Details of the volume
estimates are presented in Appendix C of the FFS (TtNUS, 1998).
2.6 DESCRIPTION OF ALTERNATIVES
Based on an evaluation of site conditions, potential risks, and legal requirements for Site 17, three
remedial action objectives were identified to protect the public from potential current and future health
risks, as well as to protect the environment:
Protection of potential human receptors from direct exposure to soil, containing pesticides at levels
exceeding human health RC.
Protection of potential ecological receptors from direct exposure to soil, containing pesticides and
inorganic contaminants at levels exceeding ecological RC. These specific levels will be determined
via site-specific toxicity tests during the remedial design (RD) phase.
Protection of groundwater from migration of arsenic and dieldrin from soil.
A detailed analysis of the possible remedial alternatives for Site 17 is included in the Site 17 FFS report
The detailed analysis was conducted in accordance with the EPA document entitled "Guidance for
Conducting Remedial Investigations and Feasibility Studies under CERCLA" (EPA, 1988) and the National
Oil and Hazardous Substances Contingency Plan (NCP).
All of the alternatives (except No Action) include removal of aboveground structures (buildings and
concrete pads) as well as underground structures (holding tank and dry well along with associated piping),
followed by on-site decontamination (by pressure washing) of metal for salvage, as appropriate, or direct
disposal at an approved rubble landfill. Decontamination waste water is assumed to require disposal at a
2-30
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DRAFT
AREA 1: 1B.BBB FT
NTAMINATION
EXCEEDING ECOLOGICAL
PRGs=51,
LEGgND
HAND AUGERED SOIL SAMPLE
LOCATION. WITH BORING NUMBER
TAKEN IN 1994
SOIL SAMPLES TAKEN IN 1991
ANALYZED ONSITE
SOIL SAMPLES TAKEN IN 1991
ANALYZED OfTSITE
MONITORING WELL
APPROXIMATE EXTENT OF AREA ABOVE
1.0 to 2.0 mg/kg ODTR level
APPROXIMATE EXTENT OF AREA ABOVE
HUMAN HEALTH PRGs
APPROXIMATE EXTENT OF AREA EXCAVATED
DURING PESTICIDE REMOVAL ACTION, 1991.
TOTAL DDT. DOE, ODD CONCENTRATION (ppm)
FROM HAND DRAWN SKETCH MAP.
1994 LOCATIONS MEASURED WITH
TAPE MEASURE AND HAND HELD COMPASS
1991 LOCATIONS APPROXIMATE
sc«[ IN ret:
CONTRACT NO.
7194y.
OWitff NO
0259
ESTIMATED AREA OF SOU CONTAMINATION
EXCEEDING PRd
PESTICIDE SHOP (SITE 17)
MAS PATUXENT RIVER
MARYLAND
FIGURE 2-4
2-31
a -
CTO0259
-------
Treatment/Storage/Disposal (TSD) facility off site. Any vadose zone soil (associated with the excavation
of underground structures) that is contaminated at levels exceeding ground water RC will also be
excavated and treated/disposed of at a RCRA TSD facility off site.
All of the conceptual design calculations for the alternatives are presented in Appendix C of the FFS
(TtNUS, 1998). Details of the cost estimates of the alternatives are presented in Appendix D of the FFS.
A summary of the remedial alternatives, which were, developed to address contamination associated with
Site 17 soil is presented below.
2.6.1 Alternative 1 - No Action
Description: Under this alternative no further effort or resources would be expended at Site 17.
Alternative 1 serves as the baseline against which the effectiveness of the other alternatives is judged.
Costs: There would be no costs associated with this alternative.
2.6.2 Alternative 2: Impermeable Capping and Institutional Controls
Description: This alternative combines containment and institutional controls. Accordingly, the two
components are: (1) capping to serve as a barrier to potential receptors and to minimize infiltration and
the consequent migration of contaminants; and (2) institutional controls.
Institutional controls would consist of access restrictions to prevent trespassing, recording of
contamination in the Base Master Plan including prohibition of excavation on site, land use restrictions to
control site development and residential development, including access to groundwater, and monitoring to
assess migration of contaminants in the environment. Potential contaminants from soil that could migrate
into groundwater are dieldrin and arsenic. Monitoring would consist of periodic sampling of groundwater
from 6 wells (onsite and downgradient of the site) and analysis for dieldrin and arsenic. Inspection and
maintenance of the cap would be required.
Under this alternative the area of contaminated soil containing COCs at levels that may exceed site-
specific ecological cleanup levels (to be determined at the time of remedial design/action phase) would be
covered by a cap containing an impermeable layer. Approximately 51,000 square feet is conservatively
assumed to be the maximum extent of area that would be covered by this cap. This area would also
2-33
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include those areas that are contaminated at levels exceeding human health and groundwater protection
RC. Components of the cap would consist of the following (from the bottom layer in ascending order):
1. Containment (impermeable) layer (such as Geo-composite Clay layer - GCL/High-Density
Polyethylene - HOPE)
2. Drainage layer (12 inches of coarse sand)
3. Separation layer (such as Geotextile)
4. Root-penetration/frost protection layer (18 inches of compacted clean soil)
5. Top soil layer (6 inches in thickness)
6. Vegetation
The approximate total thickness of the cap would be 3 feet.
At the time of remedial design, additional components to the cap such as a biotic barrier may be
considered if soil burrowing animals are expected to enter the site from surrounding areas. The biotic
barrier would be placed under the root-penetration/frost protection layer.
Demolition of aboveground structures and excavation of underground structures as described in the
introduction to Section 2.6, and site preparation (weed removal, grubbing, grading, etc.) would be required
prior to installation of the cap. The slope of the cap would be graded to permit even drainage of surface
water. The actual dimensions of the cap would be defined at the time of remedial design, with additional
soil sampling, as required.
Cost
Capital: $570,000
O&M: $16,500/yr
Present worth: $808,000(estimated over 30 years)
This alternative is expected to take 4 months to implement. For purposes of estimating and comparing the
costs of the alternatives, monitoring of groundwater and maintenance of the cap are assumed to continue
for 30 years.
2-34
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2-6-3 Alternative 3: tn-Situ Chemical Fixation/Solidification With Institutional Controls
Description: In this alternative, the contaminated soil containing COCs at levels that may exceed site-
specific ecological cleanup levels (to be determined during the remedial design/action phase) would be
treated in-situ or in place without excavation. This area of contaminated soil would also include
contaminant levels that exceed human health and groundwater protection RC. It is conservatively
presumed that soil down to a depth of an average of 2 feet bgs would be treated over an area of
approximately 51,000 square feet, or approximately 3,800 cubic yards in volume. The institutional controls
component of this alternative would consist of access restrictions to prevent trespassing, land use
restrictions to prevent residential development, and monitoring to assess the migration of contaminants in
the environment. Monitoring would consist of annual groundwater sampling (6 samples) and analysis of
all samples for dieldrin and arsenic.
The first phase of the remedial action would consist of demolition of aboveground structures and
excavation of underground structures as described in the introduction to Section 2.6. In the next phase,
treatment would consist of mixing fixating/solidifying agents into the soil using mechanisms such as
augers, rakes, etc. Based on the results of a treatability study (B&R Environmental, 1997), cement kiln
dust (CKD) would adequately solidify the soil and minimize mobility of pesticides. The ratio of soil to
cement kiln dust by weight was determined to be approximately 10:1. However, pesticides would not be
chemically treated and only their physical entrapment can be achieved, therefore the long-term
teachability (i.e., the ability to migrate in the environment by dissolving in rain water) of pesticides is
questionable. Approximately 500 tons of cement kiln dust is estimated to be required for the process.
Following mixing, the soil would be allowed to cure over a period of a few weeks. When field observations
indicate that curing is nearing completion, a soil cover with vegetative erosion control would be placed on
the surface of the treated soil.
Costs: The costs for this alternative are estimated to be as follows.
Capital cost: $620,000
Operating and Maintenance: $16,500/yr
Present-worth: $860,000 (estimated over 30 years)
2-35
-------
This alternative is expected to take 3 months to implement. For purposes of estimating and comparing the
cost of the alternative, the monitoring of groundwater and maintenance of the soil cover is assumed to
continue for 30 years.
2.6.4 Alternative 4: Excavation and Off-Site Treatment/Disposal
Description: This alternative consists of excavation of the soil contaminated at levels that may exceed
site-specific ecological cleanup levels (to be determined during remedial design/action phase), followed by
a treatment or a disposal option. This soil would also include areas where contaminant levels exceed
human health and groundwater protection RC. Alternative 4A (off-site incineration of the soil followed by
landfilling of the ash) or Alternative 4B (direct landfilling of the soil) would both require the use of a RCRA
Treatment/Storage/Disposal (TSD) Facility. Clean soil would be backfilled in the excavated area. Both
options would include demolition of above ground structures and excavation of underground structures as
described in the introduction of Section 2.6.
2.6.4.1 Alternative 4A
Under Alternative 4A, approximately 3,800 cubic yards of soil (over an area of 51,000 square feet and
average depth of 2 feet bgs), corresponding to a mass of approximately 5,100 tons is conservatively
assumed to require excavation. The excavated soil would be transported in 20 cubic yard rolloff boxes to
an incineration facility certified with a RCRA Part B permit. Following incineration, the ashes would be
treated by chemical fixation/solidification, if required for metals, and disposed of in a RCRA landfill
because of the RCRA-listed nature of the waste.
Costs: The costs for this alternative are estimated to be as follows.
Capital cost: $4,530,000
Operating and Maintenance: $0/yr
Present-worth: $4,530,000
This alternative is expected to take 6 months to implement. There is no monitoring of groundwater and
maintenance of the soil cover associated with this alternative.
2-36
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2.6.4.2 Alternative 4B
Under Alternative 4B, the same volume of soil (as described under Alternative 4A) would be excavated
and transported for direct landfilling at a RCRA Subtitle C facility. Alternative 4B is dependent on obtaining
a waiver of the Land Disposal Restriction (LDR) standards that are applicable to the soil because of the
presence of constituents that carry a RCRA listing. This waiver would be obtained from the EPA and must
be accepted by the State where the RCRA landfill is located and by the disposal facility.
Costs: The costs for this alternative are estimated to be as follows.
Capital cost: $1,400,000
Operating and Maintenance: $0/yr
Present-worth: $1,400,000
This alternative is expected to take 6 months to implement. There is no monitoring of groundwater and
maintenance of the soil cover with this alternative.
2.6.5 Alternative 5: Excavation. On-Site Thermal Desorption. And Backfilling Of Treated Soil
Description: In this alternative, the contaminated soil containing COCs at levels that may exceed site-
specific ecological cleanup levels (to be determined during remedial design/action phase) would be
excavated, treated on site and the treated soil backfilled in the excavated area. This soil would also
include areas where contaminant levels exceed human health and groundwater protection RC. It is
conservatively assumed that approximately 3,800 cubic yards of soil (over an area of 51,000 square feet
and average depth of 2 feet bgs) corresponding to a mass of approximately 5,100 tons would be
excavated and fed to a thermal desorption system. The remedial action would include demolition of
aboveground structures and excavation of underground structures as described in the introduction to
Section 2.6.
The thermal desorption system would heat the soil through direct contact with hot, forced air or indirectly
using hot oil or molten salt. The temperature of treatment required for achieving pesticide removal
efficiencies exceeding 99 percent is estimated to be approximately 1000 °F, based on treatability study
results (Eli Eco Logic International. Inc., 1997). The estimated processing rate of soil is approximately 100
to 125 tons per day. The volatilized pesticides would be conveyed to an off-gas treatment (air emissions
2-37
-------
control) system, which can vary from quenching/scrubbing/activated carbon adsorption, condensation, or
reductive hydrogenation. The most commonly used off-gas treatment units consist of the
quenching/scrubbing/activated carbon adsorption system. In such systems, filtration and activated carbon
adsorption is used for treatment of wastewater from the off-gas quenching/scrubbing process. It is
expected that off-gas treatment using reductive hydrogen treatment would not be selected because of
relatively higher costs. Residues from the off-gas treatment and wastewater treatment would be disposed
of by incineration off site.
The soil would be treated to meet ecological and groundwater protection RC and LDR standards for
pesticides. The treated soil would also meet human health RC. Any areas of soil containing levels of
arsenic and lead exceeding RC would be excavated and disposed of at RCRA TSD facility off site.
Following treatment, the soil would be stockpiled temporarily, cooled with water and backfilled.
Costs: The costs for this alternative are estimated to be as follows.
Capital Cost: $ 2,250,000
Operating and Maintenance: $0/yr
Present-worth: $2,250,000
This alternative is expected to take 4 months to implement. There would be no long-term monitoring
activities.
2.6.6 Alternative 6: Excavation Of Soil. Off-Slte/On-Slte Treatment. Backfilling/Disposal: and
Soil/Gravel Cover Over Entire Site
This alternative addresses the treatment of soil areas where contaminant levels exceed human health and
groundwater protection RC. Excavation and offsite treatment/disposal or onsite treatment would address
the contaminated soil. The alternative also includes placement of a soil and gravel cover over the
remaining area of the site, where soil is contained at levels that may exceed site-specific ecological
cleanup levels to be determined during the remedial design/action phase. The remaining area of the site
would be addressed by the use of a soil and gravel cover to minimize exposure of potential ecological
receptors to the residual contaminants. The site, conservatively assumed to cover an area up to
approximately 51,000 square feet, would be covered with a gravel layer followed by a layer of clean soil.
The disposal/treatment options would be: offsite hazardous waste landfilling {assuming a waiver of LDRs
can be obtained), offsite incineration at a RCRA TSD facility and onsite thermal desorption.
2-38
-------
Based on combinations of soil treatment and disposal, four options are being considered:
Alternative 6A: Excavation and Off-site RCRA Landfilling; Regrading; and Soil/Gravel Cover.
Alternative 6B: Excavation and Off-site RCRA TSD Facility Incineration; Regrading; and Soil/Gravel
Cover.
Alternative 6C: Excavation, On-site Thermal Desorption, and Backfilling of Treated Soil; and
Soil/Gravel Cover.
Alternative 6D: Excavation, On-site Thermal Desorption, and Off-site RCRA Landfilling of Treated Soil;
Regrading; and Soil/Gravel Cover.
In each of the options listed above, soil with contaminant levels exceeding RC for human health and
groundwater protection, would be excavated. Approximately 13,000 square feet of soil would be
excavated down to a depth of an average of 2.0 feet below ground surface (bgs). Approximately 1000
cubic yards of soil (or approximately 1,350 tons) would be excavated. Each of the options would include
demolition of aboveground structures and excavation of underground structures as described in the
introduction to Section 2.6.
2.6.6.1 Alternative 6A
Under Alternative 6A, the excavated soil (approximately 1,350 tons) would be transported off site and
disposed of at a RCRA-certified hazardous waste landfill. The implementation of this alternative assumes
that a waiver of LDRs can be obtained in a timely manner. Then the entire area of the site (those areas
where contaminant levels exceed ecological RC, would be regraded and covered with a soil and gravel
cover of two-foot thickness. The soil and gravel cover components would be as listed below (in ascending
order):
1. Geotextile layer (approximately 51,000 square feet)
2. Gravel layer (approximately 12 inches in thickness)
3. Common fill layer (uniform thickness of 6 inches, compacted volume of approximately 950 cubic
yards)
4. Top soil (uniform thickness of 6 inches, approximately 950 cubic yards volume)
5. Vegetation
2-39
-------
Cap maintenance and monitoring of the cap integrity and additional ecological tests (as required) to verify
the cap efficiency, will also be included.
2.6.6.2 Alternative 6B
Under Alternative 6B, the excavated soil would be transported off site and treated by incineration and the
ashes landfilled at a RCRA-certified TSD facility. The site would be regraded and a soil and gravel cover
would be placed over the entire site, as described under Alternative 6A. Cap maintenance/monitoring
would be included, also as described under Alternative 6A.
2.6.6.3 Alternative 6C
Under Alternative 6C, the excavated soil would be treated on site by thermal desorption (with air
emissions control) until human-health RC, groundwater protection RC and LDRs are met, then the treated
soil would be backfilled. The site would be regraded and a soil and gravel cover would be placed over the
site, as described above. Cap maintenance/monitoring would be included, also as described under
Alternative 6A.
2.6.6.4 Alternative 6D
Under Alternative 6D, the excavated soil would be treated on site by thermal desorption (with air
emissions control) until LDRs are met and disposed of off site at a RCRA-certified hazardous waste
landfill. The site would be regraded and a soil and gravel cover would be placed over the entire area of
the site, as described above. Cap maintenance/monitoring would be included, also as described under
Alternative 6A.
In each of the options of this alternative, the placement of the clean soil and gravel cover would provide a
barrier to potential ecological receptors. The necessity for and extent of this soil/gravel cover would be
determined at the time of remedial action based on results from a site-specific toxicity study. The Navy
would also institute records in the Base Master Plan regarding the contamination and prohibition of
intrusive activities.
2-40
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Costs: The estimated capital, O&M and present-worth costs of this alternative are as presented below:
Alternative 6A
Alternative 6B
Alternative 6C
Alternative 6D
Capital ($)
837,000
1,750,000
1,790,000
2,080,000
O&M ($/yr)
6,000
6,000
6,000
6,000
Present-worth
($)
906,000
1,820,000
1,862,000
2,150,000
Alternatives 6A and 6B would each take approximately 3 months to implement and Alternatives 6C and 6D
would each take approximately 4 months to implement. Long-term cap maintenance would be required
under each suboption. For purposes of estimating and comparing the cost of the alternatives, cap
maintenance is assumed to continue for 30 years.
2.6.7 Summary
Table 2-9 presents a summary of the salient features of each alternative.
2.7
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives presented in Section 2.6 were evaluated in the Final Draft FFS against nine
criteria identified in the NCP. The comparison of each alternative to the nine criteria is presented below.
A summary of the comparative analysis is presented in Table 2-10.
2.7.1
Threshold Criteria
Overall Protection of Human Health the Environment
Alternatives 4, 5 and 6 would offer a high level of protection of human health and the environment
because these alternatives would either remove or treat a majority of the contamination at the site.
Alternative 4A and 5 would be most protective because they would employ treatment of all the
contaminated soil in order to attain RC. Alternative 6 would also be protective because it would remove or
treat the portion of the soil posing the principal potential threat to human receptors, although it would
employ a non-treatment method (i.e., a barrier) to address the protection of ecological receptors, if
necessary. Alternative 6B, 6C and 6D would be more protective than 6A and 4B because the latter
2-41
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TABLE 2-9
SUMMARY OF SALIENT FEATURES OF ALTERNATIVES
OPERABLE UNIT 1, SOIL
SITE 17 - PESTICIDE SHOP
NAS PATUXENT RIVER, MARYLAND
Alternative
1. No Action
2. Impermeable Capping
3. In-situ Chemical
Fixation/Solidification
4A. Excavation (3,800 cy)/
RCRA Incineration
4B. Excavation (3,800 cy)/
RCRA Landfiliing
5. Excavation (3,800 cy)/
Thermal Desorption
6A. Soil Excavation
(1,OOOcy)/RCRA
Landfiliing
6B. Soil Excavation
(1,OOOcy)/RCRA
Incineration
6C. Soil Excavation
(1,ODOcy)/RCRA
Thermal Desorption/
Backfilling
6D. Soil Excavation
(1.000cy)/Thermal
Desorption/RCRA
Landfiliing
Main Components
None
-Cap all soils > ecological RC
-Institutional controls
-Monitoring
-In-situ treatment of all soils >
ecological RC
-Institutional controls
-Monitoring
-Excavate all soils > ecological RC
-Offsite RCRA incineration
(5,1 00 ton)
-Backfill clean soil
-Excavate all soils > ecological RC
-Offsite RCRA landfilling (5,100
ton)
-Backfill clean soil
-Excavate and treat all soils >
ecological RC
-Treatment (5.100 ton)
-Onsite backfill of treated soil
-Excavate all soils > human health
RC
-Offsite RCRA Landfiliing (1,350
ton)
-Backfill clean soil
-Excavate all soils > human health
RC
-Offsite RCRA Incineration (1 ,350
ton)
-Backfill clean soil
-Excavate all soils > human health
RC
-Onsite treatment (1,350 ton)
-Backfill treated soil
-Excavate all soils > human health
RC
-Onsite treatment (1 ,350 ton)
-Offsite RCRA Landfilling
-Backfill clean soil
Applicable Standards
Does not meet RC
-Provides barrier to potential
receptors
-Minimizes migration of
contaminants
-Prevents potential receptors
from risk of exposure
-Reduces mobility of
contaminants
-LDRs not applicable
-Meets all RC
-Meets LDRs
-Meets all RC
-Requires LDR waiver
-Meets all RC
-Meets LDRs
-Meets human health and
groundwater protection RC
-Provides a barrier to ecological
receptors
-Must obtain waiver of LDRs
-Meets human health and
groundwater protection RC
-Provides a barrier to ecological
receptors
-Meets LDRs
-Meets human health and
groundwater protection RC
-Provides a barrier to ecological
receptors
-Meets human health and
groundwater protection RC
-Provides a barrier to ecological
receptors
-Meets LDRs
Cost
present-
worth $
None
808,000
860,000
4,530,000
1,400,000
2,250,000
906.000
1,820,000
1,860,000
2,150,000
2-42
-------
TABLE 2-10
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
OPERABLE UNIT 1, SOIL
SITE 17-PESTICIDE SHOP
NAS PATUXENT RIVER, MARYLAND
PAGE 1 OF 2
Alternative
1. No Action
2. Impermeable
Capping
3. In-Situ Chemical
Fixation/Solidification
4A. Excavation
(3,800 cy)/RCRA
Incineration
4B. Excavation
(3,800 cy)/RCRA
Landfilling
5. Excavation
(3,800 cy)/
Thermal
Desorptlon
6A. Soil
Excavation
(1,OOOcy)/RCRA
Landfilling
6B. Soil
Excavation
(1,OOOcy)/RCRA
Incineration
Overall
Protection of
Human Health
and
Environment
Not Protective
Protective
Protective
Protective
Protective
Protective
Protective
Protective
Compliance
wlthARARs
and TBCs
Does Not
Comply
Complies
Complies
Complies
LDR Waiver
required
Complies
LDR Waiver
required
Complies
Long-Term
Effectiveness and
permanence
Not effective or
permanent
Depends on maintenance
& Monitoring
Depends on Monitoring
Effective and permanent
Effective and permanent
Effective and permanent
Effective with minimal
maintenance
Effective with minimal
maintenance
Reduction of
Toxicity, Mobility
and Volume
through treatment
None
None
Reduction of Mobility
Reduction of Toxicity
None
Reduction of Toxicity
None
Reduction of human
health toxicity
Implementability
Readily implementable
Easily implementable
Uniformity of
treatment
Easily irnplementable
Easily implementable
Determination of
operating parameters
Human health
delineation
Human health
delineation
Short-Term
Effectiveness
(Remedial action
duration)
No Concerns
Minimal Concerns
(4 months)
Minimal Concerns
(3 months)
Exposure to workers
can be controlled
(6 months)
Exposure to workers
can be controlled
(6 months)
Exposure to workers
can be controlled
(5 months)
Exposure to workers
can be controlled
(3 months)
Exposure to workers
can be controlled
(3 months)
Cost
(Present
Worth $)
0
808,000
860,000
4,530,000
1,400,000
2,250,000
906,000
1,820,000
State and
Community
Acceptance
To Be
Determined
To Be
Determined
To Be
Determined
To Be
Determined
To Be
Determined
To Be
Determined
To Be
Determined
To Be
Determined
ro
J>
OJ
-------
TABLE 2-10
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
OPERABLE UNIT 1, SOIL
SITE 17-PESTICIDE SHOP
NAS PATUXENT RIVER, MARYLAND
PAGE 2 OF 2
Alternative
6C. Soil
Excavation
(I.OOOcy)/
Thermal
Desorption/
Backfilling
6D. Hotspot
Excavation
(1,000cy)/
Thermal
Desorption/
RCRA
Landfilling
Overall
Protection of
Human Health
and
Environment
Protective
Protective
Compliance
wlthARARs
and TBCs
Complies
Complies
Long-Term
Effectiveness and
permanence
Effective with minimal
maintenance
Effective with minimal
maintenance
Reduction of
Toxicity, Mobility
and Volume
through treatment
Reduction of human
health toxicity
Reduction of human
health toxicity
Implementabillty
Human health
delineation &
determination of
operating parameters
Human health
delineation &
determination of
operating parameters
Short-Term
Effectiveness
(Remedial action
duration)
Exposure to workers
can be controlled
(4 months)
Exposure to workers
can be controlled
(4 months)
Cost
(Present
Worth $)
1.860.000
2,150,000
State and
Community
Acceptance
To Be
Determined
To Be
Determined
2
Notes:
1
2
3
4(A)
4(B)
5
6(A)
6(B)
6{C)
6(0)
Alternative 1: No Action
Alternative 2: Impermeable Capping and Institutional Controls
Alternative 3: In-Situ Chemical Fixation/Solidification and Institutional Controls
Alternative 4A: Excavation, Off-site RCRA Incineration
Alternative 4B: Excavation, Off-site RCRA Landfilling
Alternative 5: Excavation, On-site Thermal Desorption. and Backfilling of Treated Soil
Alternative 6A: Excavation of Soil, and Off-site RCRA Landfilling; Regrading, and over entire site.
Alternative 6B: Excavation of Soil and Off-site RCRA TSDF Incineration; Regrading, and Soil/Gravel over entire site.
Alternative 6C: Excavation of Soil, On-site Thermal Desorption, and Backfilling of Treated Soil; and Soil/Gravel over entire site.
Alternative 6D: Excavation of Soil, On-site Thermal Desorption, and Off-site RCRA Landfilling of Treated Soil; Regrading, and Soil/Gravel Cover over entire site.
-------
alternatives do not employ any treatment. Alternatives 2 and 3, on the other hand, would be somewhat
less protective because they would be the most dependent on institutional controls to prevent exposure to
contaminants and monitoring to verify minimization of migration of contaminants into the environment.
Although Alternative 4B does not employ any treatment, it addresses the removal of all the contaminated
soil followed by off site disposal at a secure landfill, which could also be protective. Alternative 1 would
not be protective of human health or the environment. Since Alternative 1 does not meet the threshold
criteria of protecting human health and the environment, it is eliminated from consideration and will not be
discussed further.
Compliance with ARARs and TBCs
Alternatives 2, 3,4, 5 and 6 would comply with Applicable or Relevant and Appropriate Requirements and
TBCs except that Alternatives 4B and 6A would require a waiver of the LDR standards from the EPA and
acceptance by the destination State and TSD facility for direct landfilling.
2.7.2 Primary Balancing Criteria
Long-Term Effectiveness and Permanence
Alternatives 4A and 5 would be most effective in the long term because of treatment of pesticides by
desorption/destruction. Alternative 6 would also be effective assuming that the soil and gravel cover
outside of the excavated area would be maintained in the long term. Alternatives 6B, 6C and 6D (all of
which employ treatment), would be more effective than Alternatives 6A and 4B because the latter
alternatives are more dependent on the reliability of an off site landfill. Alternatives 2 and 3 would be less
effective in the long term because the contaminants would remain on site and not be destroyed, and
consequently, these alternatives would be most dependent on institutional controls and monitoring in the
long term. However, the long-term effectiveness of Alternatives 2 or 3 can be monitored and corrective
measures may be taken as necessary.
Reduction of Toxlcity. Mobility and Volume Through Treatment
Alternatives 4A, 5, 6B, 6C and 6D offer the greatest reduction in toxicity through treatment by incineration
or thermal desorption. Alternatives 4A and 5 would treat approximately 5,100 tons of soil containing
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pesticides (mainly DDTR) at an average concentration of approximately 200 mg/kg. Alternatives 6B, 6C
and 6D would treat approximately 80 percent of the mass of contaminants treated under Alternative 4A
and 5, but within only approximately 30 percent of the mass of contaminated soil. Alternative 3 would
reduce the mobility of contaminants through chemical fixation/solidification. Alternatives 2, 4B and 6A
would not employ any treatment.
Implementabiiity
Alternatives involving offsite disposal/treatment (4A, 4B, 6A and 68} are easier to implement than the
other alternatives. Among these alternatives, Alternative 4A is the easiest to implement because, unlike
Alternative 6B, no delineation of soils exceeded Human Health and Ecological RC would be required.
Alternative 6B would be easier to implement than Alternatives 4B and 6A, because these latter
alternatives require LDR waivers, which may not be easy to obtain. Alternative 6A would be harder to
implement than Alternative 4B because, in addition to a LDR waiver, onsite soil contaminant delineation
would be required. Alternatives involving onsite thermal desorption (5, 6C and 6D) may be difficult to
effectively implement since low levels of certain contaminants (i.e. heptachlor) may be difficult to treat to
the established RC. Alternatives 2 and 3 involving onsite capping and in-situ fixation and solidification are
easy to implement, but they are more dependent on long-term responsibilities of monitoring and
maintenance which is an additional implementability burden.
Short-term Effectiveness
Alternatives 2, 3, 4, 5 and 6 would be effective in the short term. Any exposures to workers or the
community due to contaminants in the soil can be adequately controlled. Remedial action durations for
Alternative 6 would be approximately 3 to 4 months. Remedial action duration for Alternative 2 would be
approximately 4 months. Remedial action durations for Alternatives 3, 4 and 5 would be approximately 3,
6 and 5 months respectively. Short-term effectiveness concerns are not relevant for Alternative 1
because no actions would be undertaken.
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Cost
The present-worth costs of the alternatives would be as follows:
Alternative 2: $808,000
Alternative 3: $860,000
Alternative 4A: $4,530,000
Alternative 4B: $1,400,000
Alternatives: $2,250,000
Alternative 6A: $906,000
Alternative 6B: $1,820,000
Alternative 6C: $1,860,000
Alternative 6D: $2,150,000
2.7.3 Modifying Criteria
State Acceptance (to be modified)
The state concurs with the selected remedy. A letter of concurrence from MDE is presented in Appendix
A.
Community Acceptance (to be modified)
The preferred alternative and other alternatives considered in the FS for this site were presented to the
public on September 29, 1998. Comments obtained during the public meeting and the 30-day comment
period are presented in the transcripts (Appendix B) and responsiveness summary (Appendix C).
2.8 THE SELECTED REMEDY
The selected remedy for Site 17 is Alternative 6B: Excavation of Soil to Human Health Risk Levels, Offsite
RCRA Incineration; Regrading; and Installation of a Gravel Layer and Soil Cover Over Site; and
Institutional Controls limiting intrusive activities to maintain the integrity of the cover. Based on available
information and a current understanding of site conditions, the Navy believes that Alternative
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6B offers the best balance of the nine NCP criteria. Also, the selected alternative meets the statutory
requirements for Protection of Human Health and the Environment, Compliance with ARARs, Cost
Effectiveness, Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)
Technologies to the Maximum Extent Practicable, and Preference for Treatment as a Principal Element.
The major components of the selected remedy involve the following. The Navy shall demolish all above
ground and excavate underground structures (as detailed in the introduction to Section 2.6); excavate soil
' containing contaminants exceeding human-health and groundwater protection RC followed by off-site
incineration; regrade the site; and place a soil and gravel cover if required to meet site-specific ecological
cleanup levels. At the time of excavation of underground structures, the vadose zone soil immediately
surrounding these structures shall be tested to determine if contaminant levels exceed groundwater
protection RC, and if so, then the Navy shall also remove this soil. The areas where COCs exceed human
health RC and the assumed maximum areas to be capped are shown in Figure 2-4.
2.8.1 Performance Standards of Preferred Remedy
Soil Removal, Treatment, and Disposal
The Navy shall excavate soils containing concentrations of contaminants that are greater than the human-
health and groundwater protection remediation criteria (RC) listed on Table 2-11 of this ROD. The Navy
estimates that it will excavate approximately 1,000 cubic yards of soil (approximately 1,350 tons). This
excavation is estimated to cover an area of 13,000 square feet to an average depth of 2 feet below ground
surface. The Navy shall also excavate what is expected to be a relatively smaller volume of deeper
vadose zone soil along with the underground structures in order to attain groundwater protection RC. The
Navy shall then transport the excavated soil off site for disposal in a RCRA certified TSD facility that
employs incineration. The pesticides in the soil shall be incinerated to attain LDR standards and the
ashes shall be disposed of at a RCRA-certified landfill. The Navy shall perform a toxicity study to
determine whether there is a potential risk to ecological receptors due to residual contaminants following
soil removal. The results of the toxicity study will indicate whether ecological receptors have been
adequately protected from residual contaminants to which they may be exposed via the food chain or
direct contact.
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(1) A description and the location of Site 17, including a map, a description of its
approximate size and a description of the COCs detected at Site 17;
(2) The land use control objective (LUC) selected above;
(3) The particular controls and mechanisms to achieve these goals;
(4) A reference to this ROD; and
(5) Any other pertinent information.
Within 180 days following the execution of this ROD, the Navy, with the concurrence of EPA Region III
and in consultation with the State of Maryland, shall develop a Land Use Control Assurance Plan (LUCAP)
for NAS Patuxent River. The LUCAP shall contain Station-wide periodic inspection, condition certification
and agency notification procedures designed to ensure the maintenance by Station personnel of any site-
specific LUCs deemed necessary for future protection of human health and the environment, including the
LUC selected in this ROD. A fundamental premise underlying execution of the LUCAP is that through the
Navy's substantial good-faith compliance with procedures called for therein, reasonable assurances will
be provided to USEPA and the State of Maryland as to the permanency of those remedies which include
the use of specific LUCs.
Although the terms and conditions of the LUCAP will not be specifically incorporated or made enforceable
as to this or any other ROD, it is understood and agreed by the Navy, USEPA and the State of Maryland
that the contemplated permanence of the remedy reflected herein shall be dependent upon the StationOs
good-faith compliance with specific LUC maintenance commitments reflected herein. Should such
compliance not occur or should the LUCAP be terminated it is understood that the protectiveness of the
remedy concurred in may be reconsidered and that additional measures may need to be taken to
adequately ensure necessary future protection of human health and the environment.
2.9 STATUTORY DETERMINATIONS
Remedial actions must meet the statutory requirements of Section 121 of CERCLA as discussed below.
Remedial actions undertaken at NPL sites must achieve adequate protection of human health and the
environment, comply with applicable or relevant and appropriate requirements of both Federal and state
laws and regulations, be cost effective, and utilize, to the maximum extent practicable, permanent
solutions and alternative treatment or resource recovery technologies. Also, remedial alternatives that
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reduce the volume, toxicity. and/or mobility of hazardous waste as the principal element are preferred.
The following discussion summarizes the statutory requirements that are met by the selected remedy.
2.9.1 Protection of Human Health and the Environment
The preferred remedy will protect human health and the environment. The removal of the contaminated
soil hotspots for incineration at a RCRA-certified TSD facility will ensure that the principal threat (to human
health) is removed and treated. The installation of a soil and gravel cover over the area of soil
contaminated at levels exceeding ecological RC levels will protect ecological receptors from exposure to
contaminants by eliminating the pathway of exposure. Short-term risks resulting from exposure to
contaminated soil during excavation, transportation, or disposal can be adequately controlled by the use of
proper personal protective equipment and safe work practices.
2.9.2 Compliance with ARARs
The preferred remedy will be implemented to meet all applicable or relevant and appropriate requirements,
as listed in Appendix C. The excavated soil will be treated by incineration to meet Land Disposal
Restrictions. Land Disposal Restriction Standards that currently apply are summarized in Table 2-11.
According to these standards, to allow land disposal of soil classified as hazardous, a 90 percent
reduction in the concentrations of the hazardous constituents of that soil must be demonstrated. This
reduction must be evidenced with respect to either total concentrations for organics or TCLP leachate
levels for inorganics. However, the 90 percent reduction is not required provided that the chemical-
specific lower LDR limit has been achieved.
A RCRA-certified TSD facility will be employed for incineration of the soil containing COCs that are
present at levels greater than human health risk-based RC. The ashes from incineration will carry the
RCRA listing of the soil, and therefore would require disposal at a RCRA-certified landfill. Table 2-11
provides the human health and groundwater protection RC that will be met by removal of the hotspots. On
site, the use of a soil and gravel cover in conjunction with maintenance will ensure that ecological
receptors will not be exposed to soil containing COCs in excess of site-specific ecological cleanup levels
that will be determined at the time of remedial design/action. Construction and maintenance of the cover
will be in accordance with the State of Maryland regulations related to erosion and sediment controls
(COMAR 26.17.01) and storm water management (COMAR 26.17.02).
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Figure 2-5
Percentage DDTR Removed/Treated and Corresponding Volumes of Contaminated Soil, Site 17
Pesticide Shop
NAS Patuxent River, Maryland
-fc.
I
a
100%
80%
60%
40%
20%
0%
18mg/kgHuman
Health PRG
(Alternatives
6A, 6B, 6C and 60)
500 mg/kg Residual
6mg/kg
Residual
Note: Only the 18 mg/kg residual .
DDTR levels is a Cleanup Level. The 1-2 mg/kg
residual level is an assumed ecological PRG,
and the 6 mg/kg and 500 mg/kg levels
are fictitious numbers assumed solely for
the purpose of developing this graph
1000
L_
2000
1-2 mg/kg
Residual Level
(Alternatives
3,4A, 4B and 5)
3000
4000
Volume of Contaminated Soil (cy)
-------
95-V
Present-worth Costs
§
o
S
O»
§
O
O
. Alternative 1 .
Alternative 2
Alternative 3
Alternative 4A
Alternative 48
Alternative 5
-
^- No Ac
"
4
I
J
ion
_No Remo
Contamir
^ No Remc
^ Contami
H-
alof
ints
ra\ of
ants
(CRA Lancffi
(3.800 cy)
^~
Alternative 6A [ [^
Alternative 6B
-
Alternative 6C
-
Alternative 6D
Hotspot L
(LOCK
^
l^
-'
andfillinj
3cy)
Hots
Hotspot Th
Hotspot Th
ing
Thermal De;
- (3.800 C
RCR>
h«<
orption
f)
pot RCRA Incineration-
referred Alternative
(1,000cy)
smnal Desor;
(LOOOcy)
rmal Desorf
(1.000
tion/Backfillii
ion/RCRA L
y)
i Incineratio
800 cy)
ndfillinj
1
ison of Costs for Soil Vo
Operable Unit
NASPa
Figure 2-6
lumes Removed/Treated under each Alternative
1 Soil, Site 17-Pesticide Shop,
tuxent River, Maryland
-------
2.9.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent Practicable
Alternative 6 addresses a majority of contaminants within a relatively smaller volume of soil compared to
the volume excavated under Alternatives 4A, 4B and 5. Among the suboptipns of Alternative 6,
Alternative 6B cost effectively employs treatment with relatively lesser implementability concerns than
Alternatives 6C or 6D, and does not depend on obtaining an LDR waiver as does Alternative 6A. The
preferred remedy (Alternative 6B) addresses the portion of soil that poses the principal threat by
excavating and incinerating it in a RCRA-certified TSD facility. The preferred remedy employs a soil and
gravel cover over the remainder of the site as a barrier to potential ecological receptors, thereby limiting
the volume of soil excavated from the site. Therefore, the preferred remedy utilizes permanent solutions
and resource recovery to the maximum extent practicable. The preferred remedy (Alternative 6B) also
provides the best balance of trade-offs among the alternatives with regard to: long-term effectiveness and
permanence; reduction in toxicity, mobility or volume through treatment; short-term effectiveness;
implementability, and cost.
2.9.5 Preference for Treatment as a Principal Element Jttk
The preferred remedy utilizes treatment as a principal element to address the principal concern at this site.
The principal concern at this site is the potential threat of direct human exposure to pesticides in the soil.
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(1) A description and the location of Site 17, including a map, a description of its
approximate size and a description of the COCs detected at Site 17;
(2) The land use control objective (LUC) selected above;
(3) The particular controls and mechanisms to achieve these goals;
(4) A reference to this ROD; and
(5) Any other pertinent information.
Within 180 days following the execution of this ROD, the Navy, with the concurrence of EPA Region HI
and in consultation with the State of Maryland, shall develop a Land Use Control Assurance Plan (LUCAP)
for NAS Patuxent River. The LUCAP shall contain Station-wide periodic inspection, condition certification
and agency notification procedures designed to ensure the maintenance by Station personnel of any site-
specific LUCs deemed necessary for future protection of human health and the environment, including the
LUC selected in this ROD. A fundamental premise underlying execution of the LUCAP is that through the
Navy's substantial good-faith compliance with procedures called for therein, reasonable assurances will
be provided to USEPA and the State of Maryland as to the permanency of those remedies which include
the use of specific LUCs.
Although the terms and conditions of the LUCAP will not be specifically incorporated or made enforceable
as to this or any other ROD. it is understood and agreed by the Navy, USEPA and the State of Maryland
that the contemplated permanence of the remedy reflected herein shall be dependent upon the StationOs
good-faith compliance with specific LUC maintenance commitments reflected herein. Should such
compliance not occur or should the LUCAP be terminated it is understood that the protectiveness of the
remedy concurred in may be reconsidered and that additional measures may need to be taken to
adequately ensure necessary future protection of human health and the environment.
2.9 STATUTORY DETERMINATIONS
Remedial actions must meet the statutory requirements of Section 121 of CERCLA as discussed below.
Remedial actions undertaken at NPL sites must achieve adequate protection of human health and the
environment, comply with applicable or relevant and appropriate requirements of both Federal and state
laws and regulations, be cost effective, and utilize, to the maximum extent practicable, permanent
solutions and alternative treatment or resource recovery technologies. Also, remedial alternatives that
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Soil and Gravel Cover
If the site-specific toxicity study indicates that ecological receptors must be protected from the residual soil
contaminants, then a clean up level will be determined at that time. It is estimated that following soil
removal, the Navy may need to regrade a maximum area of approximately 51,000 square feet and place a
soil and gravel cover as a barrier between potential ecological receptors and residual contaminants. The
gravel and soil cover will consist of the following components:
1. Geotextile layer (approximately 51,000 square feet) to separate the clean cover from the underlying
contaminated soil.
2. Gravel layer (approximately 12 inches thick).
3. Common fill layer (uniform thickness of 6 inches, compacted volume of approximately 950 cubic
yards).
4. Top soil (uniform thickness of 6 inches, approximately 950 cubic yards volume) with vegetation.
Cap Maintenance
Following the soil removal and the gravel soil cover placement, the Navy shall maintain the cap over an
indefinite period of time. Maintenance shall consist of ensuring that surface drainage channels are
maintained, vegetation is preserved and erosion of the cover is minimized. Periodic testing of the efficacy
of the cover in protecting ecological receptors will be conducted, as necessary.
Institutional Controls
The Navy shall prohibit activities that interfere with or compromise the integrity of the soil cover at the
Site 17. This is the "land use control objective" for Site 17.
Within 90 days of receipt of the EPA acceptance letter of the draft final (or final) site-specific soil
toxicity testing report, the Navy shall develop a Land Use Control Implementation Plan (LUCIP) for
NAS Patuxent River with the concurrence of EPA Region III and in consultation with the State of
Maryland. The LUCIP shall include:
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3.0 RESPONSIVENESS SUMMARY
The Responsiveness Summary is a concise and complete summary of significant comments and
responses/resolution of these comments received from the public. The Responsiveness Summary
provides the lead agency with information on the views of the community. It also documents how the lead
'agency has considered public comments during the decision-making process and provides answers to
major comments. This Responsiveness Summary was prepared after the public comment period (which
ended on October 29. 1998) in accordance with guidance in "Community Relations in Superfund: A
Handbook" (OSWER Directive 9230.0-3B, January 1992).
3.1 OVERVIEW
The Proposed Remedial Action Plan as presented to the public identified the preferred remedy for Site
17, Pesticide Shop, Soil Operable Unit, as follows: "Excavation of soil that poses a risk to human health;
Off-site RCRA Incineration; Regrading; and Soil/Rip-rap Cover Over the Entire Site". The cover
component was included to address the protection of potential ecological receptors. Subsequently, the
EPA and Navy modified the cover component of the preferred remedy, as follows: (1) the level of
protection that may be required for potential ecological receptors would be determined through further
testing at the time of remedial design/remedial action; (2) the areal extent of cover would be determined
at the time when the aforementioned testing is performed; and (3) the cover, if required would include a
layer of gravel in replacement for rip-rap.
3.1 COMMUNITY PREFERENCES
A public meeting was held on September 29, 1998 at Lexington Park, in the vicinity of NAS Patuxent
River. The proposed remedial action plan for Site 17 was presented at this public meeting. No significant
comments that required a revision to the PRAP or this ROD were received at the public meeting or during
the public comment period that ended on October 29,1998.
3.2 INTEGRATION OF COMMENTS
The following is a summary of the response to a comment that was received during the public meeting,
which required further investigation:
3-1
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One audience member asked Mr. Richard Ninesteel (of Tetra Tech NUS, Inc., the Navy's contractor)
certain details of the present-worth cost estimation. The present-worth is the amount of money (in
today's dollars) that would be used to pay for the capital cost of remedial action and the additional sum of
money that would earn adequate interest for the operation/maintenance in the long term. The audience
member requested to know the interest rate that was used in the calculation of present worth of the
proposed alternative. The discount rate used was 7 percent per annum, which is in accordance with
OSWER Directive No. 9355.3-20, June 25, 1993. Although interest rates cannot be predicted accurately
over a long duration of time, the exact interest rate is not considered by the Navy to be critical at this time.
In the PRAP the present-worth costs are mainly used for the purpose of comparison between
alternatives. Since the present-worth costs are predominantly associated with initial expenditure (capital)
rather than long-term operation/maintenance, a variation in the interest rate would not alter the relative
cost comparison of these alternatives.
3-2
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GLOSSARY
Administrative Record: A body of docu-
ments that form the basis for the selection
of a CERCLA response action and which
demonstrates the public's opportunity to
participate and comment on the selection
process.
. Applicable or Relevant and Appropri-
ate Requirements (ARARs): Related
federal and state environmental statutes,
laws, or provisions. Applicable require-
ments are those cleanup standards,
standards of control, and other sub-
stantive environmental protection re-
quirements, criteria, or other limitations
promulgated under federal or state law
that specifically address a hazardous sub-
stance, pollutant, contaminant, remedial
action, location, or other circumstance at
a CERCLA site. Relevant and appropri-
ate requirements are those cleanup
standards, standards of control, and other
substantive environmental protection
requirements, criteria, or limitations
promulgated under federal or state law
that, while not "applicable" to a hazardous
substance, pollutant, contaminant, reme-
dial action, location, or other circum-
stance at a CERCLA site, address prob-
lems or situations sufficiently similar to
those encountered at the CERCLA site
that their use is well suited to the par-
ticular site.
Background Samples: 1) Naturally
occurring levels: ambient concentrations
of chemicals present in the environment
that have not been influenced by humans
2) Anthropogenic levels: concentrations of
chemicals that are present in the
environment due to man-made, non-site
sources.
Bench-Scale Tests: Laboratory testing of
potential cleanup technologies.
Contaminated media from the site are
generally used to determine if the
treatment technology can be used to
cleanup the site. See also Treatability
Study.
Carcinogenic: Causing or inciting can-
cer.
Comprehensive Environmental Re-
sponse. Compensation, and Liability
Act (CERCLA): A federal law passed in
1980 and modified in 1986 by the Super-
fund Amendments and Reauthorization
Act (SARA). The act created a special
tax that goes into a Trust Fund, com-
monly known as Superfund, to investigate
and clean up abandoned or uncontrolled
hazardous waste sites. The Department
of Defense under the Defense
Environmental Restoration Fund funds
navy compliance with CERCLA/SARA
(see IR Program).
-------
GLOSSARY
Incremental Cancer Risk flCR): The
potential for incremental cancerous
human health effects due to exposure of
contaminants of concern.
Constituents of Concern (COCsV.
Compounds or analytes identified as a
possible source of risk based upon a
comparison between compound
concentrations and established screening
levels (e.g., Federal Drinking Water Stan-
dards).
Detection Limit: The minimum
concentration, which must be accurately
and precisely measured by the laboratory
and/or specified in the quality assurance
plan.
Downaradient: Down hill or down slope.
Ecological Receptors: Non-human,
native organisms that may be exposed to
site contaminants.
Ecological Risk Screening; The quali-
tative evaluation to assess the risk posed
to ecological receptors by the presence,
potential presence, and/or use of specific
COPC.
Exposure Pathway: A way that a person,
plant, or animal may be exposed to a
COPC. For example, water may be an
exposure pathway for fish.
Engineering Evaluation/Cost Analysis
(EE/CA): A brief report that evaluates
alternatives to cleanup contamination at a
site.
Feasibility Study (FS): Report that
summarizes the development and analy-
sis of remedial alternatives considered for
the cleanup of CERCLA sites. Focused
Feasibility Studies are for sites with
conditions that allow a limited number of
alternatives to be considered.
Gas-Phase Destruction: A treatment
technology that uses a gas, such a
nitrogen, and elevated temperatures to
treat hazardous substances, pollutants,
and/or contaminants.
Groundwater: Free water located
beneath the ground surface in pores of
materials such as sand, soil, gravel, and
in cracks or solution features in bedrock.
Often serves as a source of drinking
water.
Hazard Index (HI): A number indicative
of noncarcinogenic health effects, which
is the ratio of the existing level of
exposure to an acceptable level of
exposure. A value equal or less than one
indicates that the human population is not
likely to experience adverse effects.
Hazard Quotient (HQ): The ratio of a
single substance exposure level over a
specified time period to a reference dose
for that substance derived from a similar
exposure period.
Human Health Risk Assessment: The
qualitative and quantitative evaluation
performed in an effort to define the risk
posed to human health by the presence
or potential presence and/or use of spe-
cific COPC.
Installation Restoration (IR) Program:
A component of the Defense Environ-
mental Restoration Program created
-------
GLOSSARY
under CERCLA regulations and funded
by the Department of Defense. The pur-
pose of the Program is to identify, assess,
characterize, and clean up or control con-
tamination from past hazardous waste
disposal operations and hazardous ma-
terial spills at military activities.
Leachate: Water that collects
contaminants as it trickles through
wastes, or other materials. Leaching may
occur in farming areas, feedlots, landfills,
and hazardous waste sites, and may
result in hazardous substances entering
surface water, groundwater, or soil.
Maximum Contaminant Levels (MCLs);
The enforceable primary drinking water
standards under the Safe Drinking Water
Act (SDWA) with which public water sys-
tems must comply.
Media: Air, water, soil, or sediments,
which are the subject of regulatory
concern, investigation and cleanup.
Monitoring Well (MW): 1) A well used to
obtain water quality samples or measure
groundwater levels. 2) A well drilled at a
hazardous waste management facility or
Superfund site to collect groundwater
samples for the purpose of physical,
chemical, or biological analysis to
determine the amounts, types, and
distribution of contaminants in the
groundwater beneath the site.
National Priorities List: EPA's list of the
most serious uncontrolled or abandoned
hazardous waste sites identified for pos-
sible long-term remedial action under
CERCLA.
National Oil and Hazardous Substan-
ces Pollution Contingency Plan fNCP):
The federal regulation that guides deter-
mination of the sites to be corrected un-
der the CERCLA program and the pro-
gram to prevent or control spills into sur-
face water or other portions of the envi-
ronment.
Parts per Billion fppb): A way of ex-
pressing very small concentrations in air,
water, soil, food, or other products. A part
per billion is equal to about 1.5 oz of
liquid placed into 12,000,000 gal of
another liquid.
Parts per Million fppml: A way of ex-
pressing small concentrations in air,
water, soil, food, or other products. A part
per million is equal to about 1.5 oz of
liquid placed into 12,000 gal of another
liquid.
Pesticides: Substances or mixtures of
substances intended for preventing, de-
stroying, repelling, or mitigating any pest,
e.g., rats, weeds, or mosquitoes.
Pentachlorophenol (PCP1: Dark-colored
flakes and needle-like crystals, which
have a pungent odor when, heated. PCP
is used in wood preservatives, wood
products, starches, dextrin, glue and pest
control in herbicide formulation. PCP
causes a variety of systemic (affecting the
entire organism or bodily system)
problems that can lead to death. PCP is
a Group B2, probable human carcinogen.
Preliminary Assessment: The process
of collecting and reviewing available infor-
mation about a known or suspected
waste site or release.
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GLOSSARY
Record of Decision (ROD): A ROD is
a public document, which explains the
cleanup alternative to be used at a
CERCLA site. The ROD is based on
technical and financial analyses gene-
rated during the RI/FS and on considera-
tion of the public comments and com-
.munity concerns.
Remedial Investigation (Rl): The Rl is
prepared to report the type, extent, and
potential for transport of constituents of
potential concern at a hazardous waste
site, and directs the types of cleanup
options that are developed in the FS.
Remedial Design (RD): The phase of the
cleanup process where the specifics of
the design of the selected remedy, which
includes the preparation of technical
drawings, plans, and specifications,
needed to implement the cleanup.
Remedial Action (RA): The phase that
involves the construction, operation, and
implementation of the remedy to cleanup
the site.
Removal; 1) An action to. abate,
minimize, stabilize, remove or eliminate
the release or threat of release of a
hazardous substance, pollutant or
contaminant. 2) The cleanup or removal
of released hazardous substances,
pollutants and/or contaminants from the
environment
Risk Based Concentrations (RBCsl:
EPA Region ill has developed this list of
concentration levels for screening analy-
tical data from CERCLA sites to identify
COPC.
Sediment: 1) Material transported and
deposited by water. 2) Soil, sand, and
mineral washed from land into water,
usually after rain.
Semivolatile Organic Compounds
(SVOC): A group of organic compounds
composed primarily of carbon and hydro-
gen that are characterized by their low
volatility. SVOC include substances that
are contained in hydrocarbon products
like asphalt, oil, and tar.
Site Inspection (SI): The collection of
information from a property to assess the
extent and severity of hazards posed by
the property.
Target Analvte List (TAD: A list of
inorganic analytes including naturally
occurring elements and cyanide which
EPA has identified for use in assessing
potential hazards at CERCLA sites.
Target Compound List (TCP: A list
of organic compounds including VOC,
SVOC, pesticides and PCB which EPA
has identified for use in assessing poten-
tial hazards at CERCLA sites.
Thermal Desorption; A wide variety of
treatments processes used to physically
separate volatile and some semivolatile
contaminants from soil, sediments, and
sludge using elevated temperatures. The
vapors are subsequently collected and
treated.
To Be Considered (TBC): Non-
promulgated advisories (such as
reference doses or potency factors),
criteria, and guidance issued by Federal
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GLOSSARY
and state governments not having the void spaces (pores) of soil or rock are
standards of ARARs. partially filled with water.
Treatability Studies: A test of potential
cleanup technologies conducted in a
laboratory.
Toxicitv Tests: Biological testing (usually
conducted on earth worms or leaf lettuce)
to evaluate the adverse effects of a
contaminant.
Vadose (Unsaturated) Zone: The area
of the earth that is located above the
water table and capillary fringe, in which
Volatilization: Vaporization or evapora-
tion.
Volatile Organic Compounds (VOC): A
group of organic compounds composed
primarily of carbon and hydrogen that are
characterized by their tendency to readily
evaporate (or volatize) into the air from
water or soil. VOC include substances
that are contained in common fuels, sol-
vents, and cleaning fluids.
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REFERENCES
B&R Environmental, October 1997. Draft Treatabilitv Study Report for Site 17- Pesticide Shoo Soils. Naval
Air Station, Patuxent River, Maryland. October 1997.
B&R Environmental, May 1998. Draft Focused Feasibility Study Report for Surface Soil. Site 17. Naval Air
Station, Patuxent River, Maryland.
B&R Environmental, July 6,1998. Draft Addendum to the Feasibility Study Report. Site 17. Letter Report.
CH2M Hill, 1989. Pre Response Action Investigation.
CH2M Hill, 1990. Final Engineering Evaluation and Cost Analysis Report for NACIP Sites 17 and 28. Naval
Air Station. Patuxent River. Maryland. March 1990.
CH2M Hill. 1991. Report on PCB and Pesticide-Removal for Sites 28 and 17. Naval Air Station. Patuxent
River. Maryland. September 1991.
CH2M Hill, 1992. Draft Interim Remedial Investigation Report, Naval Air Station. Patuxent River. Maryland.
January 1992.
CH2M Hill, 1998. Human Health Risk Assessment for Site 6/6A Surface Soil. Naval Air Station, Patuxent
River, Maryland. Letter Report (February 28, 1998) addressed to Richard Ninesteel, TetraTech NUS, Inc.,
from Linnea Eng, CH2M Hill.
Eli Eco Logic, 1997. Pilot-Scale Treatabilitv Testing Report. DDT Residuals Decontamination and
Destruction using the ECO LOGIC Process. Testing on US Naval Air Station Patuxent River Site 17 Soil.
ELI Eco Logic International, Inc., 143 Dennis Street. Rockwood, Ontario, Canada, NOB 2KO. September 22,
1997.
Environmental Sciences Division Publication NO4650, prepared for U.S. DOE by Oak Ridge National
Laboratory, Oakridge Tennessee, 37831-6285.
HNUS, 1995. Engineering Evaluation/Cost Analysis for Sites 6. 17, & 24. Naval Air Station. Patuxent.
Maryland. April 1995.
R-1
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U.S. EPA, 1988. Guidance for Conductinq Remedial Investiqations and Feasibility Studies under CERCLA. ^^
Interim Final. OSWER Directive 9355.3-01, Office of Emergency and Remedial Response, Washington,
D.C., EPA/540/G-89/004. October 1988.
U.S. EPA, 1989. interim Guidance on Establishing Soil Lead Cleanup Levels at Superfund Sites. OSWER
Directive 9355.4-02. Office of Emergency and Remedial Response, Washington, D.C., September 1989.
R-2
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APPENDIX A
LETTER OF CONCURRENCE
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OF THE ENVIRONMENT
Broemng Highway Baltimore Maryland 21224
(410)631- 3000 1- 800 -633-6101 http://www. mde. state, md. us
Governor GIendening Jane T. Nishida
- Secretary
November 16,1998
Mr. Bayly Smith
Patuxent River Naval Air Station
Environmental Department
Public Works Building 504
Patuxent River MD 20670
RE: Record of Decision for Operable Unit 1. Soils. Pesticide Shop fSite 17V Naval Air Station.
Patuxent River. Maryland
Dear Mr. Smith:
The Maryland Department of the Environment (MDE), Waste Management Administration has
reviewed the above-referenced document. In accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act, this Record of Decision documents the
remedial action selected by the Navy for Operable Unit 1, Soils, Site 17 Pesticide Shop.
The remedy selected by the Navy is a soil and gravel cover over the former pesticide shop area to
mitigate exposure of human or ecological receptors to residual pesticide contamination in soil. Prior to
the placement of the cover, the Navy intends to remove the former pesticide shop structures along with
soil that exceeds human health based criteria. Based upon the acceptable level of protection to human
health and the environment provided by the remedy, the MDE concurs with the selected remedy.
If you have any questions, please contact me at (410) 631-3394.
' Kim Lemaster
Section Head
Federal/NPL Superfund Division
cc: Ms. Donna Jordan, EFACHES
Mr. Andrew Sochanski, U.S. EPA
Mr. Richard Collins
Ms. Hilary Miller
Ms. Shari Wilson
We
~ r "
ffocyctod Paper
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APPENDIX B
PUBLIC MEETING TRANSCRIPTS
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COPY
i
2
3
4 SITE 17, PESTICIDE SHOP
5 PROPOSED REMEDIAL ACTION PLAN
6 PUBLIC HEARING
7 SEPTEMBER 29, 1998
8
9
10
11
12
13 -----
14
15
16
17 The public hearing was taken on Tuesday,
18 September 29, 1998, commencing at 6:30 p.m., at
19 the Frank Knox Training Center, Patuxent River,
20 Maryland before Mary Clare Ochsner-Hammond, Notary
21 Public.
22
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1 PROCEEDINGS
2 -
3
4 CAPTAIN ROBERTS: If I could have your
5 attention, please. We'll go ahead and get
6 started. I'd like to welcome all of you to the
7 public hearing, which is the opening of the 30-day
8 phase of -- public comment phase that we go
9 through in any remediations that we do.
10 I'm pleased that you're here. We really
11 do want public comment. We want to hear your
12 comments on this and it's important to us in
13 setting these up and doing the advertising and so
14 on. We really do want your comments and support
15 this.
16 This public hearing concerns Site 17,
17 which is the.pesticide shop and our proposed
18 remediation action to clean that particular site
19 up. The person who is going to start the
20 presentation is Donna Jordan. You're going to
21 start. Right?
22 MS. JORDAN: Okay. Captain, are you
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1 ready?
2 CAPTAIN ROBERTS: Are you ready?
3 MS. JORDAN: Yes, sir.
4 CAPTAIN ROBERTS: Okay. We'll get into
5 the briefing and she is going to be addressing a
6 little bit on the process and why we hold the
7 public hearings and a little bit on that process
8 and where we are on the process on this particular
9 site. You're going to have to speak up a little
10 bit.
11 MS. JORDAN: It will be easier to see if
12 the lights are dim in back. Joe, could you get
13 that for us, please? No one's going to fall
14 asleep. Right? Okay. You can see this better
15 than you could when the lights are up.
16 Good afternoon, everyone. I'm Donna
17 Jordan, the lead project manager for NAS Pax
18 River. I'm going to talk to you about what the
19 Navy is proposing as a remedial action for the
20 soils, which is what we're calling Operable Unit
21 One, at Site 17 also known as the pesticide shop
22 for the base.
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1 I'm going to present this in a sort of
2 detailed explanation for those of you here who may
3 not be that familiar with the process that we're
4 following. So, those of you who are familiar, I'm
5 going to ask you to bear with me for the benefit
6 of those who may be hearing this for the first
7 time.
g The proposed plan. This is where we
9 enter the public participation phase of our
10 remediation here on the base. And what the public
11 participation document does, which is the proposed
12 plan, is it outlines and tells about what it is we
13 plan to do, to give the base a rationale for doing
14 the action.
15 it discusses potential impacts to human
16 health as well as the'environment and by
17 environment we're talking about ecological
18 receptors such as the bugs, the bunnies, the
19 worms; and the birds, those are ecological
20 receptors.
2i We'll also provide documentation for what
22 we're doing. We'll tell you where you could find
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1 supporting documentation if you're interested in
2 doing some further reading to sort of see how we
3 got up to this point. And it also discusses the
4 participation process as far as how we get to
5 remedy selection.
6 Now I'm going to talk about the IR
7 process. We started here with the site discovery,
8 which was in the early 1980s. From identifying a
9 site where we felt there might have been a
10 potential for relief, we did what we call a
11 preliminary assessment, look at the documentation,
12 find out what types of materials were used there
13 or stored there.
14 . And from there we went on and conducted
15 what we call a site inspection where we actually
16 take some samples of the soil and groundwater, if
17 applicable, and the sediments to find out what
18 type of material we're finding in the soil above
19 certain screening levels for human health and the
20 environment.
2i From there we move on into the remedial
22 investigation phase where we actually work to find
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1 the limits of the materials that we found. We
2 also refer to that as the contamination that we
3 found at the site. And from the remedial
4 investigation, we look at the nature and extent.
5 We then go on to the feasibility study to
6 look at different alternatives to address the
7 contamination that we found there. After we had
8 conducted the feasibility study, the next step
9 will be the proposed plan along with the Record of
10 Decision.
11 So, the proposed plan will document to
12 the public what we have done so far to date with
13 doing our investigation and what we plan to do for
14 the remedy. And the decision that we make as far
15 as what we will actually do to clean the site will
16 be documented in the Record of Decision and I'll
17 explain a little bit more about that later on.
18 From there we will have what we call the
19 remedial design where we actually put together
20 some type of scope of work, a plan of action, to
21 be implemented for the site. And then actually we
22 go out and implement our decision, which is called
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1 the remedial action.
2 After we put it into action, then we'll
3 need to monitor the work that we have done to make
4 sure we did achieve our goal of remedying the
5 site. And once we have demonstrated to the
6 regulators that we have met our goals, then we
7 will next move into discussing site closeout.
8 Okay, this deals more with the -- going
9 from IPS to Record of Decision. We have a list of
10 alternatives that we look at in the feasibility
11 study. So then, we need to identify what the
12 preferred alternative is. And there's some
13 criteria for that and I'll discuss that a little
14 bit later.
15 From there we move into the proposed
16 plan, as I mentioned earlier, and then the public
17 has 30 days to comment on the proposed plan.
18 We'll make a decision on the remedy that we're
19 going'to select and then we'll document it in the
20 Record of Decision.
21 Okay, the purpose of the Record of
22 Decision. This is a legal document which
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1 certifies and states in writing what the remedy is
2 that we're selecting and it's done in accordance
3 with CERCLA. If you're not familiar with the term
4 CERCLA, it's an acronym that stands for
5 Comprehensive Environmental Response Compensation
6 Liability Act which was passed in 1980 and the
7 National Contingency Plan or the NCP are the
8 regulations that implement the law, CERCLA.
9 It's a technical document. So, it
10 discusses a lot of engineering comments and it
11 also lists our remediation goals and it also is
12 the source of information for the public. So, if
13 there is a question about why the Navy did choose
14 this action, you can always go back to the Record
15 of Decision to look at what's stated in there.
16 The Record of Decision is a comprehensive
17 document. The declaration, which is one of the
18 first items you get to when you open the Record of
19 Decision, has declaration statements and it is
20 signed by the EPA and the Department of Defense.
21 There's also a decision summary which
22 talks briefly about what the site contained and
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1 why we selected this particular remedy for the
2 site and it also discusses the remedy. And also,
3 the Record of Decision contains a responsiveness
4 summary where if we have any questions or comments
5 that came from the public during the public
6 comment period, we address them in the
7 responsiveness summary which is attached to the
8 document.
9 This is an overview of Pax River. I know
10 this is kind of hard to read. It just sort of
11 gives you an idea of what we're talking about
12 here. And this is -- we're about here.
13 MR. TARR: Go up, keep going.
14 MS.. JORDAN:. Right out in here, okay.
15 MR. TARR: Go to about two o'clock. Back
16 to the left, left, down. Right there.
17 MS. -JORDAN: Okay. Site 17. It's hard
18 to see, but we just kind of wanted to give you an
19 overview of the whole base before we went on to
20 show you the actual site. This is the pesticide
21 shop, building 841, and then there's also another
22 storage building, 110.
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10
1 MR. TARR: 1110.
2 MS. JORDAN: 1110. Back here. And these
3 buildings will also be demolished as part of the
4 remedy of the site. Okay. The proposed plan
5 contains various sections. One is the
$ introduction, just sort of like some information
7 about the base and about this document and what we
8 hope to gain from you-all reviewing this document
9 and commenting on it.
10 Then we'll talk about site background,
11 our history of the site, then we'll have a section
12 that talks about the different remedial or
13 remediation alternatives that we looked into for
14 addressing the contamination at the site. And
15 then we'll evaluate the alternatives. And later
16 on Rich Ninesteel is going to talk about the
17 criterias used for making that evaluation.
18 Then they'll be a preferred alternative
19 selected and then it also- talks about how to get
20 your comments addressed and where to send-your
21 comments or call if you have questions or need
22 other information.
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1 Okay. Site 17. The history is, this was
2 the main facility or the facility for pest control
3 operations here at Pax River and it was from the
4 early sixties until the late eighties. And what
5 had happened is because it was a pest control
6 operation a lot of the equipment was rinsed, a lot
7 of unused product was dumped out into the ground,
8 and also there was a sink which had a drywell,
9 just a pipe from the sink going into the ground,
10 where some of the rinsate materials or the unused
11 portions were rinsed from the sink and placed into
12 the ground.
!3 There were also -- some of the vehicle
14 trucks were rinsed, when they were finished making
15 their rounds, into an ash pad. There was also a
16 holding tank that was installed there. And the
17 tank contained some of the materials that were
18 placed there and any type of residual materials
19 that came out, also disposed there at the site.
20 This is a picture of the site. It's been
21 fenced off. The fence was put up some years ago
22 as part of a remedial action to keep people out so
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12
1 that they would not be exposed to the pesticides
2 there at the pesticide shop and this is 841, which
3 was the main building. That's 1110 in the back.
4 And this is a schematic of Site 17 and this is
5 from the removal action that was done -- was it
6 '94?
7 MR. TARR: Ninety-one.
8 MS. JORDAN: Ninety-one. Where we
9 removed some of the contaminated material because
10 when it rained, it was moving some of the material
11 down to this ditch which drained off into a
12 pond -- pond three across the street. Okay, the
13 removal action was done in '91 and we cleaned up
14 an area around the concrete pad and the asphalt
15 driveway and the ditches as I mentioned earlier.
16 We conducted or completed some
17 confirmatory samples that were collected and that
18 was just to make sure that we had actually removed
19 the contamination that we'wanted to remove. So,
20 we did collect the confirmatory samples to make
21 sure that the levels that were remaining there
22 were safe for human health.
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1 Okay. At this point I'm going to turn it
2 over to Rich Ninesteel from Tetra Tech. He's
3 going to talk about the focused feasibility study
4 which was conducted by Tetra Tech and at the end
5 I'll come up and talk about the schedule of
6 upcoming events. Rich?
7 MR. NINESTEEL: Thank you. Again, my
8 name is Rich Ninesteel. I work for Tetra Tech.
9 We were hired by the Navy to perform the
10 feasibility study and prepare the proposed plan
11 that you-all got copies of tonight. We'll also be
12 working very shortly on submitting the draft broad
13 as part of the process here.
14 Just a little overview of the focused
15 feasibility study. The overall goal of the
16 feasibility study is to develop a range of
17 alternatives'for the decision makers to look at,
18 everything from no action to containment
19 alternatives, where the waste material is left
20 on-sit'e, to alternatives that involve treatment
21 both on- and off-site.
22 We looked at six alternatives of which
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14
1 there were several suboptions. Just to go through
2 the alternatives. By law, we have to evaluate the
3 no action alternative. It's really a baseline
4 against which all the other alternatives are
5 measured.
6 Alternative No. 2 was an in-place capping
7 alternative where all the contaminated soil was
8 left on-site and we looked at placing a cap over
9 all of the contaminated soils. This is a drawing
10 we put together of what the conceptual cross
11 section of what the cap would look like.
12 It involved a synthetic liner at the
13 bottom with a drainage layer on top for positive
14 drainage of any rainfall. And then there was also
15 a compacted soil layer and a vegetative layer on
16 top. And again, this would just contain the
17 contaminated-soils in place.
18 'We also looked at an in-situ treatment
19 alternative. It involved'fixation and
20 stabilization. This technology would involve
21 mixing a cement slurry with the soil, basically to
22 form an impermeable mass which --on top of which
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15
1 we would place a soil cap.
2 And this is just a schematic of how the
3 plan would be implemented. We would mobilize
4 equipment to the field, treat the material at the
5 soil's in-place, place a compacted soil layer
6 above the treated soils and following that there
7 would be institutional controls put in place to
8 prevent any disturbance of the cap and there'd be
9 long-term monitoring.
10 The fourth alternative had two
11 suboptions. The overall alternative looked at
12 excavation of all the soils that were above all
13 the standards that we were comparing to. And the
14 first alternative looked at treatment off-site
15 using incineration, which essentially gets
16 virtually complete destruction of the DDT in the
17 soil.
18 And the second option looked at
19 landfilling of the soils off-site. This was --
20 this also involved some regulatory -- jumping
21 through some regulatory hoops. The soils that we
22 have out there, once you pick them up, they're
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1 RCRA waste and they're subject to the requirements
2 of RCRA. In which case, soils contaminated with
3 the levels of DDT, which is our main
4 contaminant -- our main pesticide --we would
5 require treatment.
6. So in this case, we would have --we
7 would have had to request a waiver of the
8 treatment standards that would allow us to place
9 the material in the landfill without treatment.
10 This is really just again a schematic.
11 Mobilization followed by excavation of the soils
12 that exceeded the ecological PRGs.
13 Maybe a quick step backwards. We have
14 soils here that range from the low part per
15 million level of DDT, which is the main site
16 contaminant, all the way into the hundreds of
17 parts per million. We in a risk assessment --
18 risk approach to establishing cleanup levels.
19 There "are human health standards or PRGs, which is
20 preliminary remediation goals.
21 For the contaminant, the main contaminant
22 which is DDT, and its breakdown products we're
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17
1 looking at a number of approximately 18 parts per
2 million as a cleanup level to be protective of
3 human health, but from an ecological standpoint
4 we're looking at environmental receptors. We have
5 an actually lower cleanup level of approximately
6 two parts per million.
7 That's because the receptors -- the
8 ecological receptors, the animals, are in direct
9 contact with the soil and also DDT is a compound
10 that can accumulate and so we have a lower level
11 here. This alternative was cleaning up all the
12 way down to the ecological PRG of about two. And,
13 again, we had the two options of off-site
14 treatment.
15 The fifth alternative we looked at in the
16 feasibility study involved excavation of all the
17 soils and on-site thermal desorption with
18 backfilling of the treated soil on-site. And,
19 again,' this is a simple block-flow diagram of what
20 would have happened. Excavation, treatment and
21 placing back on-site and then vegetating the
22 material.
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1 The sixth alternative has four suboptions
2 and this is where we looked at different options
3 for the hotspot soils, which we defined as those
4 above the 18 part per million level, which is the
5 PRG for human health. And another alternative for
6 the lesser contaminated soils those between two
7 parts per million and 18 parts per million, which
8 would be all remaining soils which exceeded the
9 ecological PRG.
10 So, we looked at these options. And all
11 involved excavating the soils that exceeded --
12 that were the hotspot soils, that's about a
13 thousand cubic yards. And then leaving the
14 remainder on-site which would be another 3,000
15 cubic yards.
16 The first suboption, 6A, involved
17 excavating the hotspot soils and taking them
18 off-site and landfilling in a RCRA landfill.
19 Again,'this would require-the waiver of the
20 treatment standards that were required for this
21 type of soil. And then the remaining soils that
22 were left on-site would be regraded and capped
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19
1 with clean soil.
2 6B, again, excavation of the hotspots,
3 but in this case off-site incineration at a
4 permitted RCRA incinerator and, again, capping the
5 residual soils with a soil cover. Alternative 6C.
6 Excavation of the hotspots and then on-site
7 thermal desorption and then backfilling of the
8 treated soils, regrading and clean soil cover.
9 And then alternative 6D. Again, on-site
10 thermal treatment -- thermal desorption, but in
11 this case, off-site landfill disposal of the
12 treated soils and then the remaining soils capped
13 with a soil cap. This is, again, just a flowchart
14 of what I talked about'. Excavation, one type of
15 treatment -- one out of four types of treatment --
16 and then capping the remaining soils.
17 This is just a map of the soils that are
18 on-site to get an idea of the percentages of soils
19 that exceed the ecological PRGs and then also
20 those that exceed the human health. The darker
21 areas that have the double cross-hatching are the
22 soils that exceed the human health standard, about
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1 18 PPM. That's approximately one-fourth of the
2 material that's out there.
3 The remaining, the lighter hatching on
4 the map, are all the other soils. And again, that
5 would be the extent of -- the maximum extent of
6 effected soils on the site. This is just an
7 overview of the range of costs that we have.
8 If we exclude No. 1, which was no action,
9 we have costs that range from less than $1
10 million -- approximately $770,000 on a present
11 worth, which was alternative 6A, all the way up to
12 over $4 million. Just a quick explanation of
13 present-worth cost.
14 As you can see, for any option, we have a
15 capital cost. That is the cost of implementing
16 the clean up in -- at time zero. In many of these
17 alternatives -where there is some level of
18 contamination left on-site, there is long-term
19 operation and maintenance'which we refer to as O&M
20 cost. And what the present-worth calculation does
21 is, it gives you a standard where you can compare
22 apples to apples for all cost options.
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1 What it looks at is taking a present-day
2 worth of what you have to pay for the capital,
3 plus put in the bank to pay for the long-term O&M
4 costs. And that way we can compare the costs of
5 alternatives that have different capital and O&M
6 cost on a constant basis.
7 Under CERCLA, it defines three types of
8 evaluation criteria, grouped into these three
9 categories. There are a total of nine criteria
10 that were in the feasibility study for each
11 alternative that we had to evaluate.
12 There's the threshold criteria, which are
13 statutory requirements that a chosen alternative
14 must satisfy.. There are five balancing criteria
15 that are used to weigh the pros and cons of the
16 different alternatives. And then there are two
17 modifying criteria that are looked at at the end
18 of the process during the public comment period.
19 ' The threshold criteria. Number 1,
20 overall protection of human health and the
21 environment. And the environment is defined as
22 the ecological receptors that might be present at
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22
1 the site. Again, this describes how -- when we
2 evaluate this, we describe how the alternative
3 will achieve and maintain protection of human
4 health and the ecological receptors on-site.
5 Also, we have to comply with applicable
£ or relevant and appropriate requirements and these
7 are -- the acronym for that is ARARs. We --
8 basically we have to comply with ARARs, all that
9 apply, and if not, we would have to look at
10 getting a waiver.
11 The balancing criteria. Here's where we
12 look at one alternative versus another. One of
13 them is long-term effectiveness and permanence.
14 Obviously, the more permanent a solution -- for
15 example, incineration, you get greater than 99.99
16 percent destruction of the contaminant of concern.
17 That is a very permanent solution. Whereas,
18 capping is a less permanent solution. You are not
19 destroying the material, you're leaving it
20 on-site. Reduction of toxicity, mobility, and
21 volume.
22 CERCLA has a strong preference for the
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1 reduction of toxicity, mobility, and volume.
2 Again, that's just a way of making sure that the
3 potential hazards related to the site are reduced
4 by the alternative you're looking at. Short-term
5 effectiveness, again, looks at really during the
6 construction phase just to make sure that whatever
7 is being implemented is protective of the workers
8 and the local population and environment.
9 Some of the balancing criteria to
10 continue implementability, of course, we have to
11 choose an alternative that can be implemented.
12 It's a matter of -- that's what the construction
13 people look at it and make sure that whatever
14 we're looking at on paper can actually be
15 implemented in the field.
16 And then cost. Cost is an important
17 factor. Certainly when we're spending government
18 money, we look for a cost-effective solution that
19 will achieve the goals at-the lowest possible
20 price. And then the modifying criteria. -We look
21 for State acceptance of the alternative that we're
22 choosing and then community acceptance, which is
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1 the reason we're here tonight, to present the
2 alternatives to the public.
3 Based on comments we receive, it is
4 possible that if necessary -- DOD, the Navy, and
5 EPA will look into your input -- will look at your
6 input on the chosen alternative and, if necessary,
7 go back and reevaluate the alternatives.
8 The chosen alternative -- the preferred
9 alternative, I should say, is alternative 6B. And
10 we're presenting that tonight as the Navy's
11 preference and the EPA's preference and to solicit
12 your input on this choice. Again, this is the
13 excavation of the hotspot soils, approximately a
14 thousand cubic yards, and off-site incineration,
15 which is complete -- virtually complete --
16 destruction of the DDT in those soils and then
17 regrading the material that's left, the soils that
18 are contaminated between 2 PPM and 18 PPM and
19 covering with a two foot soil cover.
20 We feel that it is the most cost-
21 efficient approach. We will have a graph in a
22 minute here that will show under this alternative
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1 we are destroying over 80 percent of the pesticide
2 mass that's in the soil, but only affecting about
3 approximately 26 percent of the contaminated soil.
4 We think it's a good optimum.
5 - Once you start getting into the lower
6 contamination -- lower contaminated soils, the
7 soil volume increases dramatically and the costs
8 go up dramatically, also. Why don't you go to the
9 next slide? This is just a quick review. It
10 might be tough,to review the numbers here, but
11 this is a presentation of the PRGs, the
12 preliminary remediation goals, the cleanup levels
13 that we are working toward on this site.
14 When you add up -- as I mentioned before,
15 there are DDT and its metabolites -- when you add
16 up the concentrations for the ecological
17 receptors, we're talking again approximately 2
18 PPMs. For human health -- protecting human health
19 it's approximately 18.
20 ' There are other compounds that are of
21 concern on this site, but our data shows that by
22 far the controlling parameter that is out there is
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1 DDT. That's the most widespread, the most
2 frequently detected. And our evaluation of the
3 data also shows that by cleaning up the DDT we are
4 also cleaning up the hotspots of the other
5 pesticides that are on-site.
6 This is the curve I was referring to.
7 Basically we -- this is the point that represents
8 the human health cleanup criteria. Again, there's
9 approximately a thousand cubic yards of soil
10 material which represents about --a little bit
11 over 80 percent of the mass of DDT at the site.
12 What this curve shows is that as you try
13 to get lower and lower values -- clean up to lower
14 and lower values, the amount of soil that you're
15 dealing with increases dramatically, such that
16 back on the costing table you could see where the
17 cost from going from just the partial incineration
18 here of the hotspots to the treating all soil
19 types 'by incineration, for instance, would go from
20 a little less than $2 million to almost $5
21 million. So, here we're getting the most bang for
22 our buck and we are still protective of human
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1 health and the environment in the overall
2 alternative.
3 This is a bar chart showing the costs of
4 all the different alternatives. This is the
5 preferred alternative right here -- excuse me,
6 right here. So, we're kind of in the midrange of
7 costs. We've not selected the lowest nor the
8 highest, but again, it is relative to the cost-
9 effectiveness of the preferred alternative.
10 Just as a review of how we meet the
11 statutory requirements. We are protective of
12 human health and the environment. Human health by
13 removing all soils that exceed the human health of
14 protectiveness of PRGs, taking them off-site and
15 incinerating. And the environment by capping over
16 the residual contaminants -- contaminated soils
17 that are left on-site essentially preventing --
18 giving a barrier between the contamination and so
19 that potential ecological- receptors cannot reach
20 those soils. We comply with all the statutes that
21 are the applicable requirements.
22 Again, I discussed the cost-
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1 effectiveness. We -- there is a strong bias
2 within CERCLA to use treatment as a principal
3 element. Here we are looking at destruction by
4 incineration of the hotspot soils which also gives
5 a permanent solution that is a completely
6 irreversible process.
7 And again, as I said, the levels that we
8 are removing are protective of human health and
9 also groundwater. All the soils that can
10 eventually impact groundwater by leaching long
11 term will be removed and incinerated and, as I
12 said before, the residual soils will be capped in
13 place.
14 The treatment off-site at the RCRA
15 permitted incinerator will meet the land disposal
16 requirements. So, no waiver is required and the
17 residuals will be treated to extremely low levels
18 at the facility. And the soils that are left
19 on-site, again, will be protective of human health
20 and the environment.
21 Again looking at the fact that we utilize
22 a permanent solution, we're treating the
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1 proportion of the soils that pose the principal
2 threat, the highest contamination hotspots, and we
3 believe this alternative offers the best balance
4 and trade offs from long-term effectiveness and
5 permanence by treating the hotspot soils by
6 incineration. Again, we're reducing toxicity
7 through treatment of these hotspot soils.
8 The short-term effectiveness. We're
9 looking at a very short construction time frame
10 dealing with excavation and hauling off-site and
11 it's easily implemented. This is a standard
12 technology used on numerous sites in the past and
13 we believe it is a cost-effective solution.
14 The preference for treatment is a
15 principal element that is embedded in the CERCLA
16 requirements. Again, we are"treating the hotspots
17 and we're addressing the principal threat to life
18 by incinerating those soils. This is just kind of
19 a nice drawing of the way-things will go.
20 We're going to excavate, transport off-
21 site, treat, the residuals will end up in a
22 landfill connected with the treatment facility.
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1 Very simple process. That 'really concludes the
2 technical portion of the presentation. I think
3 Donna would like to talk about the overall
4 schedule for implementation.
5 MS. JORDAN: Yes, Rich. Okay. As you
6 can see by the schedule, we plan to move pretty
7 quickly on this. So, at the end of the comment
8 period, which will be a month from now, we plan on
9 having the Record of Decision ready by the 13th of
10 November. This is a very aggressive schedule.
11 This is what we would like to see happen.
12 So, don't hold us to that date, but we do want to
13 work very quickly to get this implemented. Right
14 now we are anticipating OHM, who's the remedial
15 action contractor or our RAG as we like to call
16 them, OHM was the contractor that did the
17 landfill, Site 11, that you may be familiar with.
18 They will be coming back and plan to mobilize
19 around the middle of November.
20 We plan to have everything all taken care
21 of, all the confirmatory sampling results and
22 saying we've met our goal, by the first week of
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1 January of '99. Available information can be
2 found at the Lexington Park Public Library.
3 There's the address and telephone number. Also,
4 you can call the Naval Air Station at this address
5 and phone number.
6 MR. TARR: That's the public library and
7 the library on station.
8 MS. JORDAN: Okay. And that's the
9 library on base. That's the Commanding Officer's
10 address. If you want to send comments, please
11 forward it to this address. Okay, on the back
12 table there are handouts that give descriptions on
13 the types of contaminants that we have at Site 17.
14 There is also a copy of the presentation in the
15 back and I think that's it. Are there any
16 questions?
17 AUDIENCE MEMBER: What type of cap are we
18 talking about? And what's the material and how
19 deep is it?
20 -MS. JORDAN: We're mainly talking about
21 soil. We're planning to put down a barrier, a
22 marker, it's not really like a geotextile but more
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1 of just a marker to show where we brought in the
2 clean soil. And that will help us with our
3 maintenance to check it to make sure that the cap
4 hasn't been disturbed and we'll be monitoring and
5 maintaining that cap and we'll be laying some type
6 of soil and vegetating over that.
7 AUDIENCE MEMBER: Approximately how
8 thick?
9 MS. JORDAN: About two feet. That is
10 what the EPA biological technical team has deemed
11 to be acceptable to eliminate the pathway for the
12 ecological receptors, two feet down.
13 AUDIENCE MEMBER: Is money available for
14 this now?
15 MS. JORDAN: Yes,'it is. Yes, it is.
16 AUDIENCE MEMBER: How high is the water
17 table there? Does the groundwater contamination
18 and groundwater treatment need to be considered?
19 -MS. JORDAN: Okay. The water table is
20 actually pretty shallow. It is between five and
21 eight feet down below the surface and currently
22 what we're finding is that it is actually
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1 discharging into the pond. We have detected some
2 very low levels of pesticides in the groundwater.
3 The groundwater is going to be handled
4 later on and we're looking at that as part of the
5 remedial investigation for the groundwater on Site
6 17. So, we're still working on that to find out
7 whether or not we need to do anything to that.
8 AUDIENCE MEMBER: Is there going to be
9 any checking to see if there any fluctuation in
10 the groundwater after the first of the year?
11 MS. JORDAN: Yes. Another question?
12 AUDIENCE MEMBER: What interest rate
13 assumptions are you making when you calculate the
14 present worth?
15 MR. NINESTEEL: They're pretty
16 conservative. Probably 6 percent -- well,
17 probably about 3 percent inflation, 6 percent
18 return and I'd have to check the numbers exactly.
19 AUDIENCE MEMBER:- And 6 percent interest
20 possibly?
21 MR. NINESTEEL: I would have to check in
22 the feasibility, but it's pretty standard numbers
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1 that are used.
2 AUDIENCE MEMBER: That's throughout the
3 life of the --
4 MR. NINESTEEL: The numbers really run
5 for 30 years because beyond that the cost of --
6 the O&M cost beyond 30 years really doesn't have
7 any substantial impact on the present work goals.
8 AUDIENCE MEMBER: Would you feel
9 comfortable making a 30-year projection of
10 interest rates?
11 MR. NINESTEEL: You have to use
12 something. And, again, the reason is to get
13 common comparison on the alternatives.
14 AUDIENCE MEMBER: I'm talking about if
15 the assumptions are not realistic, then the
16 conclusions also might not be realistic.
17 MR. .NINESTEEL: But I think in this case
18 if you look at -- the O&M costs are rather level
19 compared to the capital costs and so I think if
20 you looked at varying assumptions that went into
21 the conclusions, it would still be the same even
22 if you vary the interest rate.
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1 AUDIENCE MEMBER: Okay.
2 MR. NINESTEEL: Because the numbers are
3 so low right now.
4 MS. JORDAN: Any other questions? I
5 invite you to get copies of everything that's on
6 the back table. Please review it. If you have
7 any questions or comments, please submit them to
8 us. We're very interested in hearing what you
9 have to say about this. We really would like to
10 hear from you. Okay, Captain?
11 CAPTAIN ROBERTS: If you have any other
12 questions, we are certainly willing to hang around
13 and talk about them, any issues you might want to
14 bring up, if you want to get our comments. Also,
15 if anyone's interested in touring the facility,
16 Mr. Bailey here is the point of contact and you
17 can take a look at where the site is. He's good
18 at this. Okay?
19 Any other questions or comments? I
20 appreciate you coming out and being interested in
21 our project. I think it's one of the examples of
22 our approach to doing these projects. We try to
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1 use common sense. We want to do what is right,
2 look at an alternative that meets the
3 requirements, addresses the issues, and do what is
4 right, for example, the incineration. And also do
5 it -- do what is reasonable.
6 And I think this is an example of the way
7 we look at these and look at those processes. So,
8 I think this is a good example of doing that. All
9 right. Well, I was certainly happy to have you
10 here. We'll hang around to talk to you as long as
11 you like.
12 AUDIENCE MEMBER: If I could make one
13 comment, I'm certainly not the person to tell the
14 Navy what to do, but before you were here on your
15 tour, incineration is a really ugly word in St.
16 Mary's County. And I certainly would strongly
17 urge you to do a public service announcement or
18 whatever you do to handle that so that the public
19 understands clearly that -incineration will be done
20 off-site and what's going on with that because
21 there's a real potential for misrepresentation.
22 CAPTAIN ROBERTS: Wisconsin, correct?
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1 MR. 'NINESTEEL: Michigan.
2 CAPTAIN ROBERTS: Transported to
3 Michigan.
4 MR. NINESTEEL: That was certainly one of
5 the main criteria that went into the overall
6 evaluation of this.
7 AUDIENCE MEMBER: And you have good
8 .people, I'm sure, that told you that. I just
9 wanted to state the obvious.
10 CAPTAIN ROBERTS: And we looked at some
11 of the alternatives that they had in on-site
12 incineration. We're very aware of how ugly that
13 happens to be and the emotions that surround that
14 right now. We're very aware of that. In fact, it
15 was part of the consideration when we looked at
16 all the alternatives.
17 Onrsite incineration, low temperature,
18 also carries a lot of risks with it with the --of
19 the land, of construction- rehab when you get down
20 to the levels that you have. So you could, in
21 fact, swing that cost, money, and then still not
22 achieve your goals. There's an additional risk
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1 coming in there, also. So, it's a good point that
2 we need to continue to emphasize that it is in
3 fact in Michigan.
4 MR. BAILEY: Captain?
5 CAPTAIN ROBERTS: Yes?
6 MR. BAILEY: I would just like to say
7 that this is the proposed plan. If you have any
8 additional comments that you can think of and you
9 don't think of them right now, there is a sheet on
10 the back and just tear it off and you can mail it
11 right back to us at the return address.
12 And the presentation that was up there
13 was done in detail so you could take this
14 presentation home with you, stick it in the
15 proposed plan and then you'd have a lot of look at
16 that you might want to think about during the
17 30-day comment period. And then, you can call
18 Theresa and you can call her and she can answer
19 any questions you have.
20 Please take this thing home with.you and
21 any other members that didn't show up like George
22 maybe can help us with that or Madeline, but it
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1 can go like it says right to that address.
2 MR. TARR: No, no. That's the libraries,
3 additional information can be found at the
4 libraries.
5 MR. BAILEY: Take the proposed plan home,
6 look at the time lecture sheets and whatever you
7 want to call this thing and put them together. If
8 you have anything additional then send it in on
9 this sheet.
10 I would like to introduce one more person
11 here who's joined us is Jenny over here. She's
12 the engineer in charge of the project when it goes
13 to construction phase. She works at the base
14 ROICC office and we're glad to have her on our
15 team. She works in the public works facility.
16 So, we're glad to have her on our side. She will
17 be wearing her boots for sure.
18 CAPTAIN ROBERTS: Okay. Good thank you.
19 - MR. BAILEY: We do have a state
20 representative here, which is Kim Lemaster who's
21 right there. And it's funny how the regulators
22 sit together. Everybody, the legal officer is
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1 here, the public works officer is here, the CO is
2 here, some of the engineers are here, the
3 regulators, the public is here, my boss is here,
4 new boss right there.
5 So, this is a very good group here and
6 there are contractors that did a lot good work on
7 this. So, if you do have anything else, let us
8 know because we do want to clean this thing up and
9 when you drive by this you're going to se'e green
10 grass pretty soon. That thing will be gone. So,
11 you have 30 days to let us know what you think.
12 CAPTAIN ROBERTS: Okay. Thank you
13 (Whereupon, the public hearing was
14 concluded.)
15
16
17
18
19
20 -
21
22
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CERTIFICATE OF.REPORTER
I, Mary Clare Ochsner-Hammond, do hereby certify that
the foregoing proceedings were stenographically recorded by me
and reduced to typewriting under my supervision; that I am
neither counsel 'for, related to, nor employed by any of the
parties to the action in which these proceedings were
transcribed; that I am not a relative or employee of any attorney
or counsel employed by the parties hereto, nor financially or
otherwise interested in the outcome in the action.
MARY CLARE OCHSNER-HAMMOND
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APPENDIX C
TABLE OF ARARs
-------
-------
CHEMICAL-SPECIFIC ARARs & TBCs
ARARortBC
(Citation)
Safe Drinking-water Act
MCLs (40 CFR Part
141)
Reference Doses (RfDs)
and Cancer Slope
Factors (CSFs) (IRIS)
Soil Screening Guidance
(EPA's Technical
Background Document,
May 1996)
Cleanup Levels for Lead
(Interim Guidance on
Establishing Soil Lead
Cleanup Levels at
Superfund Sites, EPA
1989)
EPA's Health
Advisories
EPA's Ambient Water
Quality Criteria
(pursuant to Section 304
(a) (1) of the Clean
Water Act
Maryland Drinking
Water Regulations
(COMAR 26.04.01)
Status
Relevant and
Appropriate
TBC
TBC
TBC
TBC
Relevant and
Appropriate
Relevant and
Appropriate
Synopsis of
Requirement
Enforceable standards
for contaminants in
public water supply
systems
Basis for evaluating
carcinogenic and non-
carcinogenic risk to
human health
Soil Screening Levels
(SSLs) are provided for
protection of human
health from various
pathways of exposure
including migration of
contaminants to
groundwater
Soil cleanup levels for
lead in industrial soils
are in the range: 500 to
l,000mg/kg.
Groundwater cleanup
level is 15 ug/L.
Limits on levels of
certain intermittently
encountered
contaminants in public
water supply
Legally non-enforceable
standards for surface
water quality,
commonly adopted as
enforceable standards
Establishes MCLs for
drinking water
Action to be taken to
Attain
Soil PRGs take into
account protection of
groundwater from
further impact
Soil PRGs for human
health protection were
estimated based on RfDs
and CSFs
SSLS were used as a
preliminary screening
tool for selecting COCs
for evaluating impacts to
groundwater. PRGs
were developed for
these COCs using site-
specific modelling.
Used for assessing
exposure to potential
human receptors and
impacts to groundwater.
Used for assessing
impacts to groundwater
for certain contaminants
that do not have MCLs
Used for assessing
impacts to surface water
and sediments in Pond
3.
State MCLs are identical
to federal MCLs. Used
to assess impacts to
groundwater
A:\ARAR17.DOC
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LOCATION-SPECIFIC ARARs & TBCs
ARAR or TBC
(Citation)
Status
Synopsis of
Requirement
Action to be taken to
Attain
Coastal Management
Act
Relevant and
Appropriate
Federal activities or
projects located in or
directly affecting the
coastal zone must be
consistent to the extent
practicable with
Maryland's Coastal
Management Program
Remedial action under
the selected remedy is
not expected to
adversely impact the
coastal zone. However,
the remedial action work
plan may require
approval from the MDE,
which is responsible for
implementing the
coastal program.
Chesapeake Bay Critical
Area Protection Law
Relevant and
Appropriate
New development in the
critical areas (1000 feet
landward of the tidal
waters of the bay and its
tributaries) must
minimize impacts to the
water quality and
conserve plant, fish and
wildlife
Impacts due to the
remedial action at the
site on Pond 3 (which
may ultimately
discharge to the bay) are
expected to be minimal
and will be adequately
controlled.
A:\ARAR17.DOC
-------
ACTION-SPECIFIC ARARs & TBCs
or TBC (Citation)
Status
Synopsis of Requirement
Action to be taken to
Attain
RCRA Subtitle C Hazardous
Waste Requirements
Identification and Listing (40
CFR26I)
Generator Requirements (40
CFR 262)
Transportation Requirements
(40 CFR 263)
Standards for Owners and
Operators of TSDF (40 CFR
264) and Interim Status (40
CFR 265)
Land Disposal Restrictions
(40 CFR 268)
Applicable
Regulations that govern
generation, treatment
/storage/ transportation and
ultimate disposal of
hazardous wastes
Soil at the site would be
hazardous waste
because it contains
listed pesticides.
Therefore, all remedial
activities from
excavation, stockpiling,
transportation and
incineration must be
conducted in
accordance with RCRA
regulations. The
selected incinerator and
the landfill selected for
disposal of the ashes
will be RCRA-certified.
Maryland Hazardous Waste
Regulations (COMAR 26.13)
Applicable
State's authorized RCRA
program govern all the CFR
requirements, except LDRs
All of the remedial
activities will be
conducted in
compliance with these
requirements. The
selected incinerator is
likely to be located
outside the State of
Maryland, and
consequently, the
destination state's
hazardous waste
regulations will be
complied with.
Maryland Stormwater
Management Regulations
(COMAR 26.17)
Applicable
Criteria and procedures for
stormwater management
Land-disturbance
(excavation) and
construction
(landclearing and
grading) activities will
involve areas exceeding
the 5,000 square feet.
Erosion and
sedimentation controls
Maryland Air Pollution Control
Regulations (COMAR 26. 1 1)
Applicable
Regulations governing air
quality and air emissions
and other aspects of the
regulation will be
followed.
Particulate dust
emissions during
excavation, land
clearing, grading,
loading of soil on trucks
will be controlled using
dust suppressants and
engineering methods of
mitigation
A:\ARAR17.DOC
-------
Executive Order (60 FR, 154),
8/10/95 (Office of the Federal
Environmental Executive:
Guidance for Presidential
Memorandum on
Environmentally and
Economically Beneficial
Landscape Practices on Federally
Landscaped Grounds)
TBC
Guidance for presidential
memorandum on
environmentally and
economically beneficial
landscape practices on
federal landscaped grounds
Native species of
vegetation will be used
on the soil cover
A:\ARAR17.DOC
-------
CHEMICAL-SPECIFIC ARARs & TBCs
ARAR or TBC
(Citation)
Safe Drinking-water Act
MCLs (40 CFR Part
141)
Reference Doses (RfDs)
and Cancer Slope
Factors (CSFs) (IRIS)
Soil Screening Guidance
(EPA's Technical
Background Document,
May 1996)
Cleanup Levels for Lead
(Interim Guidance on
Establishing Soil Lead
Cleanup Levels at
Superfund Sites, EPA
1989)
EPA's Health
Advisories
EPA's Ambient Water
Quality Criteria
[pursuant to Section 304
(a) (1) of the Clean
Water Act
Maryland Drinking
Water Regulations
(COMAR 26.04.01)
Status
Relevant and
Appropriate
TBC
TBC
TBC
TBC
Relevant and
Appropriate
Relevant and
Appropriate
Synopsis of
Requirement
Enforceable standards
for contaminants in
public water supply
systems
Basis for evaluating
carcinogenic and non-
carcinogenic risk to
human health
Soil Screening Levels
(SSLs) are provided for
protection of human
health from various
pathways of exposure
including migration of
contaminants to
groundwater
Soil cleanup levels for
lead in industrial soils
are in the range: 500 to
l,000mg/kg.
Groundwater cleanup
level is 15 ug/L.
Limits on levels of
certain intermittently
encountered
contaminants in public
water supply
Legally non-enforceable
standards for surface
water quality,
commonly adopted as
enforceable standards
Establishes MCLs for
drinking water
Action to be taken to
Attain
Soil PRGs take into
account protection of
groundwater from
further impact
Soil PRGs for human
health protection were
estimated based on RfDs
and CSFs
SSLS were used as a
preliminary screening
tool for selecting COCs
for evaluating impacts to
groundwater. PRGs
were developed for
these COCs using site-
specific modelling.
Used for assessing
exposure to potential
human receptors and
impacts to groundwater.
Used for assessing
impacts to groundwater
for certain contaminants
that do not have MCLs
Used for assessing
impacts to surface water
and sediments in Pond
3.
State MCLs are identical
o federal MCLs. Used
o assess impacts to
groundwater
A:\ARAR17.DOC
-------
LOCATION-SPECIFIC ARARs & TBCs
ARARorTBC
(Citation)
Status
Synopsis of
Requirement
Action to be taken to
Attain
Coastal Management
Act
Relevant and
Appropriate
Federal activities or
projects located in or
directly affecting the
coastal zone must be
consistent to the extent
practicable with
Maryland's Coastal
Management Program
Remedial action under
the selected remedy is
not expected to
adversely impact the
coastal zone. However,
the remedial action work
plan may require
approval from the MDE,
which is responsible for
implementing the
coastal program.
Chesapeake Bay Critical
Area Protection Law
Relevant and
Appropriate
New development in the
critical areas (1000 feet
landward of the tidal
waters of the bay and its
tributaries) must
minimize impacts to the
water quality and
conserve plant, fish and
wildlife
Impacts due to the
remedial action at the
site on Pond 3 (which
may ultimately
discharge to the bay) are
expected to be minimal
and will be adequately
controlled.
A:\ARAR17.DOC
-------
ACTION-SPECIFIC ARARs & TBCs
AR or TBC (Citation)
Status
Synopsis of Requirement
Action to be taken to
Attain
RCRA Subtitle C Hazardous
Waste Requirements
Identification and Listing (40
CFR261)
Generator Requirements (40
CFR262)
Transportation Requirements
(40CFR263)
Standards for Owners and
Operators of TSDF (40 CFR
264) and Interim Status (40
CFR 265)
Land Disposal Restrictions
(40 CFR 268)
Applicable
Regulations that govern
generation, treatment
/storage/ transportation and
ultimate disposal of
hazardous wastes
Soil at the site would be
hazardous waste
because it contains
listed pesticides.
Therefore, all remedial
activities from
excavation, stockpiling,
transportation and
incineration must be
conducted in
accordance with RCRA
regulations. The
selected incinerator and
the landfill selected for
disposal of the ashes
will be RCRA-certified.
Maryland Hazardous Waste
Regulations (COMAR26.13)
Applicable
State's authorized RCRA
program govern all the CFR
requirements, except LDRs
All of the remedial
activities will be
conducted in
compliance with these
requirements. The
selected incinerator is
likely to be located
outside the State of
Maryland, and
consequently, the
destination state's
hazardous waste
regulations will be
complied with.
Maryland Stormwater
Management Regulations
(COMAR26.I7)
Applicable
Criteria and procedures for
stormwater management
Land-disturbance
(excavation) and
construction
(landclearing and
grading) activities will
involve areas exceeding
the 5,000 square feet.
Erosion and
sedimentation controls
and other aspects of the
regulation will be
followed.
Maryland Air Pollution Control
Regulations (COMAR 26. M)
Applicable
Regulations governing air
quality and air emissions
Particulate dust
emissions during
excavation, land
clearing, grading,
loading of soil on trucks
will be controlled using
dust suppressants and
engineering methods of
mitigation
A:\ARAR17.DOC
-------
Executive Order (60 FR, 154),
8/10/95 (Office of the Federal
Environmental Executive:
Guidance for Presidential
Memorandum on
Environmentally and
Economically Beneficial
Landscape Practices on Federally
Landscaped Grounds)
TBC
Guidance for presidential
memorandum on
environmentally and
economically beneficial
landscape practices on
federal landscaped grounds
Native species of
vegetation will be used
on the soil cover
A:\ARAR17.DOC
-------
>>
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