PB99-963923
EPA541-R99-088
1999
EPA Superfimd
Record of Decision:
Patuxent River Naval Station
OU 1 Soils Bohneyard (Sites 6 and 6A)
St. Marys County, MD
9/29/1999
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Record Of Decision
for
Operable Unit 1, Soils
Bohneyard (Sites 6 and 6A)
Naval Air Station Patuxent River
Patuxent River, Maryland
Engineering Field Activity Chesapeake
Naval Facilities Engineering Command
September 1999
£138823 PS PSwiJc ex.
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Table of Contents
Section Page
Acronyms and Abbreviations iii
1.0 Declaration 1-1
1.1 Site Name and Location 1-1
1.2 Statement of Basis and Purpose 1-1
1.3 Assessment of Sites 6 and 6A, Bohneyard 1-1
1.4 Description of the Selected Remedy 1-1
1.5 Statutory Determinations 1-2
1.6 Signature and Support Agency Acceptance of the 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 Summary of Previous Investigations and Response Actions 2-4
2.2.3 Summary of Enforcement Actions 2-4
2.3 Highlights of Community Participation 2-5
2.4 Scope and Role of Response Action at the Bohneyard, OU-1.... > 2-5
2.5 Site Characteristics 2-5
2.5.1 Surface Water Features 2-6
2.5.2 Groundwater Features 2-6
2.5.3 Site Ecology 2-6
2.5.4 Sources of Contamination 2-6
2.5.5 Nature and Extent of Contamination 2-7
2.5.6 Contaminant Fate and Transport 2-8
2.6 Summary of Site Risks 2-8
2.6.1 Human Health Risks 2-8
2.6.2 Ecological Risks 2-11
2.7 Description of Alternatives 2-14
2.7.1 Alternative 1 - No Action 2-14
2.7.2 Alternative 2 - Cover and Institutional Controls : 2-14
2.7.3 Alternative 3 - Excavation and Offsite Disposal 2-15
2.8 Summary of Comparative Analysis of Alternatives 2-15
2.8.1 Threshold Criteria 2-15
2.8.1.1 Overall Protection of Human Health and the Environment 2-15
2.8.1.2 Compliance with ARARs and TBCs 2-16
2.8.2 Primary Balancing Criteria 2-16
2.8.2.1 Long-Term Effectiveness and Permanence 2-16
2.8.2.2 Reduction in Toxicity, Mobility, or Volume through
Treatment 2-16
2.8.2.3 Implementability • 2-16
2.8.2.4 Short-Term Effectiveness 2-16
WDC992150005.DOC/2/AMD
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Table of Contents (Cont.)
Section Page
2.8.2.5 Cost 2-17
2.8.3 Modifying Criteria 2-17
2.8.3.1 Community Acceptance 2-17
2.8.3.2 State Acceptance 2-17
2.9 Selected Remedy 2-17
2.9.1 Performance Standards of the Preferred Remedy 2-19
2.10 Statutory Determinations 2-20
2.11 Documentation of Significant Changes 2-21
3.0 Responsiveness Summary 3-1
3.1 Summary of Public Comments and Agency Responses 3-1.
Glossary
Appendices
A State Letter of Concurrence
B Public Meeting Transcripts
C Table of ARARs
Table
2-1 Summary of Potential Human Health Risks—Site 6 2-10
2-2 Summary of Potential Human Health Risks—Site 6A 2-10
2-3 Performance Standards for Protection of Human Health at Sites 6 and 6A 2-11
Figures
2-1 Location of Sites 6 and 6A 2-2
2-2 Sites 6 and 6A - Bohneyard Locations 2-3
2-3 Sample Locations Exceeding Performance Standards for Soil - Site 6 2-12
2-4 Sample Locations Exceeding Performance Standards for Soil - Site 6A 2-13
2-5 Detail of Selected Alternative for Sites 6 and 6A 2-18
WOC9921SOOOS.OOO2MMO
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Acronyms and Abbreviations
ARAR applicable or relevant and appropriate requirement
bgs below ground surface
BTEX benzene, toluene, ethylbenzene, and xylene
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
of 1980
CFR Code of Federal Regulations
COC Chemical of Concern
COMAR Code of Maryland Regulations
DDD dichlorodiphenyldi-chloroethane
DDE dichlorodiphenyldichloro-ethane
DDT dichlorodiphenyltrichloro-ethane
EE/CA Engineering Evaluation/Cost Analysis
EPA U.S. Environmental Protection Agency
ERA Ecological Risk Assessment
FFS Focused Feasibility Study
HRS Hazard Ranking System
IAS Installation Assessment Study
IR Installation Restoration
IRI Interim Remedial Investigation
LUCAP Land Use Control Assurance Plan
LUCIP Land Use Control Implementation Plan
mg/kg milligrams per kilogram
MDE Maryland Department of the Environment
msl mean sea level
NAS Naval Air Station
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPL National Priorities List
OSWER Office of Solid Waste and Emergency Response (EPA)
OU Operable Unit
PAH polynuclear aromatic hydrocarbon
PCB polychlorinated biphenyl
PRAP Proposed Remedial Action Plan
PS Performance Standard
WDC992150005.00C/2/AMO
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Acronyms and Abbreviations (Cont.)
RAO remedial action objective
RFA RCRA Facilities Assessment
RCRA Resource Conservation and Recovery Act
RI Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act of 1986
SSL soil screening level
SVOC semivolatile organic compound
TBC to be considered
TCE trichloroethylene
TCL target compound list
TPH total petroleum hydrocarbon
U.S.C. United States Code
U.S. Navy United States Department of the Navy
VOC volatile organic compound
WOC9921 S0005.DOC/2/AMO
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1.0 Declaration
1.1 Site Name and Location
This Record of Decision (ROD) addresses Operable Unit 1 (OU-1), soil, at Sites 6 and 6A (the
Bohneyard), located at Naval Air Station (NAS) Patuxent River in St. Mary's County,
Maryland.
1.2 Statement of Basis and Purpose
This ROD presents the selected remedial action for the Bohneyard, OU-1, NAS Patuxent
River.
The selected remedy was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the
Administrative Record for the Bohneyard site developed in accordance with Section 113(k)
of CERCLA, and is available for public review.
The United States Department of the Navy (U.S. Navy) and the United States
Environmental Protection Agency (EPA) Region III issue this ROD jointly. The Maryland
Department of Environment (MDE) concurs with the selected remedy for the Bohneyard,
OU-1 (see Appendix A). Public comments are discussed in Section 3.0, "Responsiveness
Summary."
1.3 Assessment of Sites 6 and 6A, Bohneyard
Actual or threatened releases of hazardous substances from the Bohneyard, OU-1, 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
The remedy for the Bohneyard, OU-1, is part of a comprehensive environmental
remediation currently being conducted at the NAS Patuxent River under the CERCLA
program. The selected remedy in this ROD is for controlling contaminated soil at the
Bohneyard. The major components of the selected remedy for OU-1 include the following:
• A concrete and asphalt parking lot will be constructed over approximately one-half of
Site 6.
WDC992150005.00Q2/AMD 1-1
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DECLARATION
* A cover comprised of 8 inches of topsoil over 4 inches of compacted gravel will be
placed over the remaining area of Site 6 in which concentrations of hazardous
substances are greater than the site worker exposure Performance Standards (PSs) set
forth in Table 2-1 of this ROD.
• At Site 6A, an asphalt cover will be constructed for storage and staging.
• Institutional controls will consist of access restrictions to prevent trespassing, limiting
access to groundwater underlying Sites 6 and 6A, and monitoring to assess whether
contaminants are migrating to the environment.
1.5 Statutory Determinations
The remedy for the Bohneyard, OU-1, selected by the EPA and the U.S. Navy with MDE
concurrence, is protective of human health and the environment. The selected remedy
complies with federal and state requirements that are legally applicable or relevant and
appropriate to the remedial action, and uses alternative treatment technologies or resource
recovery technologies to the maximum extent practicable.
The selected remedy is cost-effective, and it uses permanent solutions for the site. At this
site, treatment of contaminants is not practicable. For this reason, the selected remedy does
not satisfy the statutory preference for treatment
Because the selected remedy will result in hazardous substances remaining onsite above
health-based levels, a review will be conducted every 5 years after commencement of the
remedial action to ensure that the remedy continues to provide adequate protection of
human health and the environment. The review will be consistent with Section 121 (c) of
CERCLA, 42 United States Code (U.S.C) Section 9621 (c).
1-2 WOC992150005.DOC/2/AMD
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DECLARATION
1.6 Signature and Support Agency Acceptance of the Remedy
This ROD represents the selection of a remedial action under CERCLA for the Bohneyard-Sites 6 and
6A, OU-1. The foregoing represents the selection of a remedial action by the EPA and the U.S.
Navy, with the concurrence from the MDE.
Concur and recommend for immediate implementation:
United States Department of the Navy
Captain Paul Roberts, USN
Commanding Officer
Naval Air Station
Patuxent River, Maryland
United States Environmental Protection Agency
By:
Date: I
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2.0 Decision Summary
2.1 Site Name, Location, and Description
This ROD presents the U.S. Navy's selected remedial actions for OU-1 (soil) at Sites 6 and
6A (the Bohneyard).
NAS Patuxent River is located in St. Mary's County in southern Maryland, at the confluence
of the Patuxent River and Chesapeake Bay (Figure 2-1). The community of Lexington Park
is about 1 mile west of the site and next to the installation boundary. The Bohneyard is
located in the northwest part of the NAS (Figure 2-2).
The Bohneyard is located in the northwestern part of the NAS, at the intersection of Bonne
Road (now named Bonnie Road) and the taxiway, as shown in Figure 2-2. The Bohneyard
covers an area of approximately 10 acres ranging in elevation from about 35 to 45 feet above
mean sea level (msl) and gently slopes towards the west. Site 6 is bounded on the west and
northwest by Bonnie Road, and on the southwest by a taxiway. Site features consist of
buildings associated with a fuel farm on the northeastern side and trees on the southern,
eastern, and western sides. Site 6A is located east of Site 6 and consists of a supply yard
and storage facilities with a wooded area north of the site. The site is bounded by industrial
facilities to the east and south.
2.2 Site History and Enforcement Activities
The history of the Bohneyard, previous site investigations, and site enforcement activities
are summarized below.
2.2.1 History of Site Activities
Between 1943 and 1949, fly ash and bottom ash from the station's coal-fired power plant
were disposed of at Site 6. It is estimated that approximately 110,000 cubic feet, or 6,000
tons, of ash were deposited in a 6-inch layer over the entire site.
Beginning in 1955, Site 6 was used to store oily wastes. These wastes were stored in drums
and in a partially buried 10,000-gallon tank. Historical aerial photographs from 1952 show
that drums also were stored in sections of Site 6A. Starting in 1966, drums of waste
solvents, paints, and possibly pesticides also were stored. Other materials reportedly stored
here included oil/water separator sludge and paint thinner. Between 1979 and 1982, all
drums were removed from the area. Many of the drums reportedly leaked some of their
contents onto the ground. An estimated 8 tons of liquid wastes were disposed of or spilled.
Various other materials, such as scrap metal, vehicles, and equipment, also were stored at
Site 6.
In September and October 1989, sludge from the St. Mary's County Wastewater Treatment
Plant was spread at a rate of 50 dry tons per acre (200 wet tons per acre) over a part of Site 6
that is now a grass field.
WDC992150005.00O2/AMD . 2-1
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8623fQ47b.dgn- 02-AUG-1999
HOG POINT
N
SITE e
BOHNEYARO
SITE 6A
BOHNEYARD (EXPANDED)
CHESAPEAKE BAY
SWIMMING BEACH
GATE 1
CHESAPEAKE BAY
SEAPLANE BASIN
GATE 2
CEDAR POINT
CHESAPEAKE BAY
BOHNEYARO SITE
FIGURE 2-1
LOCATION OF SITES 6 AND 6A
NAS PATUXENT RIVER
MARYLAND
CH2MHILL
ISM
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NOTTOSCMLE
NOTE M*> baud
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DECISION SUMMARY
2.2.2 Summary of Previous Investigations and Response Actions
Investigations of Site 6 and Site 6A were conducted between 1984 and 1999. The
investigations are summarized in the following paragraphs.
Initial Assessment Study (IAS). The first investigation of Site 6 was the IAS conducted in 1984.
The IAS included a records review, personnel interviews, and a site visit. The IAS
recommended that a confirmation study be conducted at Site 6 to determine the presence of
contamination and to determine the potential for impacts on human health and the
environment.
Confirmation Study. A confirmation study was conducted at Site 6 in 1984. Soil, groundwater,
surface water, and sediment samples were collected.
RCRA Facilities Assessment (RFA). In 1989, as part of the Resource Conservation and Recovery
Act (RCRA) process, EPA conducted an assessment of waste handling and disposal
practices at Site 6 and other areas at the NAS. Site 6 was identified in the RFA as a location
of potential contamination.
Interim Remedial Investigation (IRI). The IRI was completed in 1991; the report was completed
in 1994. Soil and groundwater samples were collected.
Interim Remedial Action Activities. The 10,000-gallon waste oil tank was excavated on
October 2,1992, cleaned, and cut into scrap. The contents of the tank were removed and
disposed of offsite. There was no offsite soil disposal associated with the tank removal.
Engineering Evaluation/Cost Analysis (EE/CA). A field investigation in support of the EE/CA was
conducted in 1994 based on recommendations in the IRI. Soil and groundwater samples
were collected. The EE/CA was prepared to evaluate response options for contaminated
soil at Site 6.
Preliminary Ecological Risk Assessment. An ecological risk assessment was prepared in 1996 to
assess the potential risks to ecological receptors from contaminants at Site 6 and Site 17.
Predesign Investigation. In 1997, additional surface and subsoil samples were collected to
provide additional information regarding the nature and extent of contamination and to
evaluate characteristics of the Bohneyard soil.
Ongoing Remedial Investigation for the Bohneyard, OU-2. Groundwater, surface water, and
sediment are currently being investigated. The complete investigation report will be
prepared in 2000.
Focused Feasibility Study (FFS). An FFS was prepared in 1999 to: (1) provide the basis for the
remedial action for soil at the Bohneyard; (2) evaluate and screen remedial technologies;
and (3) develop remedial action alternatives.
2.2.3 Summary of Enforcement Actions
No enforcement actions have been taken specifically at Sites 6 and 6A. The U.S. Navy has
owned the property since the early 1940s, and has been identified as the responsible party.
2-4 WDC992150005.00C/2MMD
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DECISION SUMMARY
On June 30,1994, NAS Patuxent River was placed on the National Priorities List (NPL). The
NPL is the nationwide list, developed by EPA, which identifies sites covered under
CERCLA regulations for priority investigation and remedial action.
2.3 Highlights of Community Participation
The proposed remedial action for the Bohneyard, OU-1, described in the FFS and the
Proposed Remedial Action Plan (PRAP), was released to the public on July 27,1999, The
public comment period for the remedial action documents was held from July 26,1999, to
August 27,1999. A public meeting was conducted on August 10,1999, at the Frank Knox
Training Center, Building 2189, located outside Gate 2. A copy of the PRAP Notice of
Availability and the transcripts of the public meeting are provided in Appendix B.
The PRAP, as well as other technical documents related to the Bohneyard, was placed in the
Administrative Record at the following libraries:
Lexington Park Public Library Patuxent River Naval Air Station Library
1 Coral Place Cedar Point Road
Lexington Park, Maryland 20653 Patuxent River, Maryland 20670
All public participation requirements are consistent with CERCLA sections 113 (k) (2) (B)
(i-v) and 117.
2.4 Scope and Role of Response Action at the Bohneyard, OU-1
The Bohneyard is one of 46 Installation Restoration (IR) sites located at NAS Patuxent River.
Past disposal activities at the Bohneyard have primarily affected soil, surface water,
sediment, and groundwater in the vicinity of the Bohneyard.
This ROD addresses the first of two OUs at the Bohneyard. OU-1, covered by this ROD,
consists of contaminated soil. OU-2, which comprises groundwater and downstream
surface water and sediment, is currently under investigation. Creation of separate OUs
allows the U.S. Navy to eliminate exposure pathways that pose an unacceptable human
health or ecological risk from contamination in soil and reuse the property as a parking lot
for airplane refueling trucks.
The remedies evaluated for OU-1, described in subsection 2.7, will reduce the risk to human
health and the environment associated with soil at the Bohneyard and complies with
federal and Maryland environmental laws. The remedy will provide effective source control
and reduce the potential for contaminant migration.
2.5 Site Characteristics
This section summarizes site features; sources, nature, and extent of contamination; and
contaminant fate and transport.
WDC992150005.DOC/2/AMO _ 2-5
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DECISION SUMMARY
2,5.1 Surface Water Features
An intermittent stream and its associated wetland habitat occur around the fringe of the
Bohneyard.
2.5.2 Groundwater Features
The shallow groundwater at the Bohneyard is unconfined and occurs at a depth of
approximately 10 to 12 feet. Groundwater flow patterns in the shallow aquifer are generally
controlled by the surface topography (CH2M HILL, 1985). The water level elevation data
from the 1985 Confirmation Study suggest that the groundwater beneath the western
portion of the site flows toward the west. Groundwater under the southeast corner may
flow toward the northeast and the groundwater beneath the northeast corner may flow
toward the northwest. Subsequent investigations (CH2M HILL, 1994; HNUS, 1995; and
CH2M HILL, unpublished data for OU-2 RI) were consistent with these findings.
2.5.3 Site Ecology
Approximately 80 percent of the Site 6 portion of the Bohneyard is open habitat covered by
mowed grasses and other herbaceous plants interspersed with patches of unmowed
herbaceous plants. The site contains a few small structures and four larger buildings.
Associated with past and current development of the site, there are patches of gravel,
pavement, and small areas of exposed soil.
A supply yard, other storage facilities, and open grassy areas to the southeast of Site 6 make
up the Site 6A portion of the Bohneyard. No aquatic habitats are present on the Bohneyard.
An intermittent stream and its associated wetland habitat occur around the fringe of the
Bohneyard and will be addressed as part of OU-2. No rare, threatened, or endangered
species are known to occur on either site.
2.5.4 Sources of Contamination
During the 1940s, fly ash and bottom ash from the station's coal-fired power plant were
disposed of on the Site 6 part of the Bohneyard. Approximately 110,000 cubic feet, or 6,000
tons, of ash were deposited in a 6-inch layer over the entire site.
Beginning in 1955, Site 6 was used to store oily wastes. These wastes were stored in drums
and in a partially buried 10,000-gallon tank. Historical aerial photographs from 1952 show
that drums also were stored in sections of Site 6A. Starring in 1966, drums of waste solvents,
paints, and possibly pesticides, also were stored. Between 1979 and 1982, all drums were
removed from the area. Many of the drums reportedly leaked some of their contents onto
the ground. Other materials reportedly stored include oil/water separator sludge and paint
thinner. Approximately 8 tons of liquid wastes were disposed of or spilled. Various other
materials, such as scrap metal, vehicles, and equipment, also were stored at Site 6.
In the fall of 1989, sludge from the St. Mary's Water Treatment Plant was spread at a rate of
50 dry tons per acre (200 wet tons per acre) over part of Site 6 that is now a grass field.
The 10,000-gallon tank was removed in October 1992 and cut into scrap metal. The contents
of the tank were removed and disposed of off the site. There was no offsite soil disposal
associated with the tank removal.
2-6 WOC992150005.DOC/2/AMD
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DECISION SUMMARY
2.5.5 Nature and Extent of Contamination
The highest concentrations of most contaminants are found within the boundaries of Site 6,
primarily in shallow samples (zero to 2 feet below ground surface [bgs]). Several inorganic
compounds were detected at concentrations elevated above background. Among these,
arsenic (maximum concentration of 40.6 milligrams per kilogram (mg/kg), chromium
(maximum concentration of 42.2 mg/kg), and cadmium (maximum concentration of
22.3 mg/kg) had their highest concentrations near the center of Site 6. However, samples
collected in the northeast comer of Site 6A and in the intermittent streambed immediately
north of that point also contained elevated concentrations of chromium (28.5 mg/kg and
41 mg/kg, respectively). Samples collected at depth (during the IRI, during the predesign
investigation, and in the vicinity of the waste oil tank) generally showed a reduction in
inorganic concentrations with depth. Samples in the vicinity of the waste oil tank followed
the overall trend, but with some exceptions in the 4.5- to 6-foot bgs range.
Several organics also were detected in soil samples. Volatile organic compounds (VOCs)
included trichloroethylene (TCE) and some of its degradation products. TCE was detected
in three shallow soil samples outside of the waste oil tank area (maximum concentration
0.002 mg/kg), along with several of the samples collected near the waste oil tank. In the
vicinity of the waste oil tank, TCE and its degradation products were detected at their
maximum concentrations at a depth of 4.5 to 6 feet bgs (0.04 mg/kg of TCE). Fuel-related
compounds, including benzene, toluene, ethylbenzene, and xylene (BTEX) were detected in
this location at a total concentration of 0.52 mg/kg.
Most of the samples collected were analyzed for semivolatile organic compounds (SVOCs).
The most common SVOC detections were polynuclear aromatic hydrocarbons (PAHs), with
the highest total PAH concentration detected at the southwestern corner of Site 6
(8.27 mg/kg). Although PAHs were detected only in surface soil samples, at one location,
detections continued to the full depth sampled (5 to 10 feet bgs). Samples collected during
the IRI also were analyzed for total petroleum hydrocarbons (TPH). The maximum
detected concentrations were found near the waste oil tank. TPH was detected in several
other surface soil samples, but at significantly lower concentrations.
Samples contained detectable concentrations of polychlorinated biphenyls (PCBs),
particularly in the vicinity of the waste oil tank, which is known to have contained PCB-
contaminated oil. Aroclor-1260 was detected at a maximum concentration of 13 mg/kg in a
sample collected from 6 to 7.5 feet bgs. Other samples contained concentrations at least one
order of magnitude lower in the vicinity of the waste oil tank, and two orders of magnitude
lower in other portions of the sites. Dichlorodiphenylrrichloro-ethane (DDT) and its
degradation products dichlorodiphenyldichloro-ethane (DDE) and dichlorodiphenyldi-
chloroethane (DDD) were detected in multiple shallow samples, with no distinguishable
pattern.
Inorganic contaminants are likely related primarily to fly ash and bottom ash historically
disposed of at Site 6. VOCs, SVOCs, and PCBs probably result from fuel use and storage of
waste oils and other materials at both Sites 6 and 6A. Pesticide detections probably result
from historical use of pesticides on the MAS, but it is possible that some elevated levels are
related to drum storage on the site.
WDC992150005.DOO2/AMO
2-7
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DECISION SUMMARY
2.5.6 Contaminant Fate and Transport
The contaminants in the soil at Site 6 and Site 6A are inorganics, VOCs, and PAHs. These
contaminants are expected to be present in the form of mineral constituents of fly ash
particles mixed with the native soil.
Because the inorganics are expected to be bound within fly ash particles, their availability
for dissolution is expected to be low. Also, the alkaline nature of fly ash due to the presence
of calcium oxides, magnesium oxides, and other alkaline oxides, reduces the likelihood that
leaching of metals will occur, as long as naturally occurring acids (such as acid rain) are
neutralized.
Chemicals may move through the soil and into groundwater. To determine whether
current concentrations of contaminants detected in soil at the Bohneyard are migrating to
groundwater at unacceptable levels, soil screening levels (SSLs) were calculated using a
soil-to-groundwater transfer model and site-specific data. SSLs were calculated for iron and
trichloroethylene (TCE) because these contaminants were detected in groundwater above
risk-based screening levels. The calculated SSLs for iron and TCE in soil were then
compared to the maximum concentrations detected in soil at the Bohneyard. The calculated
SSLs for iron and TCE are greater that the maximum concentration of these contaminants
detected in soil. Because soil concentrations for iron and TCE are below the calculated SSLs
using site-specific data, iron and TCE are not expected to migrate from soil to groundwater.
As a result, there is no expectation that current soil concentrations of iron and TCE will
impact groundwater at the site.
The TCE detected in groundwater could be the result of leaks from the partially buried tank
used to store waste oil. The tank was removed in 1992. However, soil samples collected in
the vicinity of the tank location exhibited detectable TCE concentrations (refer to Section
2.5.5). Although iron is present above risk-based levels in groundwater, the aluminum
concentration is also high. This suggests that the groundwater samples may have been
turbid, due to the presence of suspended solids in the samples.
2.6 Summary of Site Risks
As part of the investigations of the Bohneyard, OU-1, a human health risk assessment was
conducted to evaluate the potential risks to human health if no actions were to be taken at
the sites. In addition, a screening ecological risk assessment was conducted to evaluate the
potential risks to ecological receptors based on the future use of the Bohneyard. A summary
of the public health and ecological risks associated with the Bohneyard, OU-1, are
summarized below.
2.6,1 Human Health Risks
The human health risk assessment evaluated potential risks based on several scenarios
whereby exposure to soil contamination onsite could occur. The human health risk
scenarios evaluated the exposures of current and future site workers, potential future
construction workers, current and future adult and child trespassers, potential child
recreation users, and potential future adult and child residents. Each exposure scenario
identifies the reasonable maximum exposure to chemicals onsite under appropriate
circumstances for each scenario.
2-8 WDC99215fl005.DOO2/AMD
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DECISION SUMMARY
For carcinogens, risks are generally expressed as the incremental probability of an
individual's developing cancer over a lifetime as a result of exposure to the carcinogen.
Excess lifetime cancer risk is calculated from the following equation:
Risk = GDI x SF
where: risk = a unitless probability (e.g., 2 x 10'5) of an individual's developing
cancer.
GDI = chronic daily intake averaged over 70 years (mg/kg-day).
SF = slope factor, expressed as (mg/kg-day)-l.
These risks are probabilities that usually are expressed in scientific notation (e.g., IxlO"6). An
excess lifetime cancer risk of IxlQ-6 indicates that an individual experiencing the reasonable
maximum exposure estimate has a 1 in 1,000,000 chance of developing cancer as a result of
site-related exposure. This is referred to as an "excess lifetime cancer risk" because it would
be in addition to the risks of cancer individuals face from other causes such as smoking or
exposure to too much sun. The chance of an individual's developing cancer from all other
causes has been estimated to be as high as one in three. EPA's generally acceptable risk
range for site-related exposures is 10-* to 10A
The human health risk assessment found that cancer risks to all receptors at the Bohneyard
were within or below the range of acceptable excess lifetime cancer risks identified by EPA.
The cancer risks for Site 6 ranged from 2.3 x 10* for a future construction worker to 9.4 x 10"5
for the future resident. The cancer risks for Site 6A ranged from 1.1 x 10* for a future
construction worker to 3.7 x 10"5 for the future resident.
The potential for noncarcinogenic effects is evaluated by comparing an exposure level over
a specified time period (e.g., life-time) with a reference dose (RfD) derived for a similar
exposure period. An RfD represents a level that an individual may be exposed to that is not
expected to cause any deleterious effect. The ratio of exposure to toxicity is called a hazard
quotient (HQ). An HQ<1 indicates that a receptor's dose of a single contaminant is less than
the RfD, and that toxic noncarcinogenic effects from that chemical are unlikely. The Hazard
Index (HI) is generated by adding the HQs for all chemical(s) of concern that affect the same
target organ (e.g., liver) or that act through the same mechanism of action within a medium
or across all media to which a given individual may reasonably be exposed. An HI<1
indicates that, based on the sum of all HQ's from different contaminants and exposure
routes, toxic noncarcinogenic effects from all contaminants are unlikely. An HI > 1 indicates
that site-rekted exposures may present a risk to human health.
The HQ is calculated as follows:
Non-cancer HQ = CDI/RfD
where:
GDI = Chronic daily intake
RfD = reference dose.
GDI and RfD are expressed in the same units and represent the same exposure period (i.e.,
chronic, subchronic, or short-term).
WOC992150005.DOC/2/AMD 2-9
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DECISION SUMMARY
The noncarcinogenic hazard indices for all exposure pathways for Site 6 ranged from 0.32
for the adult trespasser to 4.9 for the future child resident. Cumulative noncancer hazards
were found to exceed EPA's recommended threshold for the future residential child and
adult, and for the child who visits the site for recreation. The noncarcinogenic hazard
indices for all exposure pathways for Site 6A ranged from 0.28 for the adult trespasser to 4.6
for the future child resident Cumulative noncancer hazards were found to exceed EPA's
recommended threshold for the future residential child and for the child who visits the site
for recreation.
Tables 2-1 and 2-2 show the carcinogenic risks and noncarcinogenic hazard indices for all
exposure pathways for Site 6 and Site 6A, respectively.
TABLE 2-1
Summary of Potential Human Health Risks
SitaB
NAS Patuxent River. Maryland
Receptor
Residential
Child Trespasser
Adult Trespasser
Site Worker
Construction Worker
Total Cancer Risk
9.4X10'05
1.7X1Q-05
1.1 x 10'05
2.8 X10"05
2.3 X10"08
Total Hazard Index
(Adult) 1
(Child) 4
1.5
0.32
0.76
0.63
.1
.9
TABLE 2-2
Summary of Potential Human Health Risks
SiteBA
NAS Patuxent River, Maryland
Receptor
Residential
Child Trespasser
Adult Trespasser
Site Worker
Construction Worker
Total Cancer Risk
3.7x10-os
6.7 xlO"06
4.2 X10'06
1.0x10'OS
1.1 X10'06
Total Hazard Index
(Adult) 0.96
(Child) 4.6
1.4
0.28
0.68
0.70
Noncancer hazards resulted from the presence of inorganic chemicals in soil. The chemicals
of concern for human health in soil at the Bohneyard are aluminum, arsenic, cadmium,
chromium, iron, silver, thallium, and vanadium.
To ensure that the potential noncancer hazards to human health are mitigated during the
remedial action, Performance Standards (PSs) were developed. These PSs identify
2-10
WOC9921S0005.DOC/2AMD
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DECISION SUMMARY
maximum allowable concentrations of each of the chemicals of concern for two scenarios.
PSs were developed for the potential future residential adult and child as the most-
conservative exposure scenario. In addition, PSs were developed for the current and future
site worker as the most likely exposure scenario. Table 2-3 provides the PSs developed for
each of the chemicals of concern. Figures 2-3 and 2-4 identify soil sample locations that
exceed PSs for surface soil at Site 6 and 6A, respectively.
TABLE 2-3
Performance Standards for Protection of Human Health at Sites 5 and 6A
Parameter
Aluminum
Arsenic*
Cadmium
Chromium*
Iron
Silver
Thallium
Vanadium
Residential Standard
4,220
4.1
0.75
18.1
2,350
18.7
0.45
4.5
Site Worker Standard
34.500
4.1
4.5
18.1
30,700
134
4.8
26.2
Concentrations are in mg/kg.
'Maximum background concentration
The results of the human health risk assessments conducted for soil at the Bohneyard
indicate that actual or threatened releases of hazardous substances from these sites, if not
addressed by the preferred alternative or one of the other active measures considered, may
present a current or potential threat to human health. The site-specific RAO for the
Bohneyard, OU-1, is to prevent or minimize contact of human receptors with soil where
concentrations exceed the PSs.
2.6.2 Ecological Risks
EPA has developed an 8-step process for conducting ecological risk assessments (ERAs).
Step 1 of this process consists of the following components: (1) a description of the environ-
mental setting (habitats and potential receptors) determined from available information and
a site visit; (2) a description of known source areas and contaminants; (3) a determination of
potential transport pathways from source areas; (4) an evaluation of potential exposure
pathways to determine which are likely to be complete, linking a potential source with a
potential receptor; (5) development of preliminary assessment and measurement endpoints;
and (6) determination of medium-specific ecological screening values that relate chemical-
specific media concentrations with the potential for adverse effects based on conservative
assumptions. Items 1 through 5 are used to develop a preliminary conceptual model of the
site.
The results of Step 1 (preliminary conceptual model) are used to define areas where
potential ecological risks could occur based on the presence of receptors, exposure
pathways, and possible sources of contamination. For adverse impacts to ecological
WOC992150005.DOC/2/AMO
2-11
-------
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VIHILL
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DECISION SUMMARY
receptors to be possible, a site must have a source of contaminants, a potential receptor or
receptors, and an exposure pathway linking the two. Contaminants are known to be
present in the surface soil at the Bohneyard. Ecological receptors are not likely to occur on
the Bohneyard under future use due to the lack of suitable habitat. Since ecological
receptors will likely not be present, there is no complete exposure pathway linking the
contaminants to an ecological receptor.
2.7 Description of Alternatives
To meet the RAO for OU-1, remedial technologies were screened to develop remediation
alternatives. Technologies were screened based on their suitability for specific site
characteristics, including contaminant types, quantities, and concentrations; and physical
site conditions. A detailed analysis of the possible remedial alternatives for OU-1 was
conducted as part of the 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, 1989) and the NCP. A summary of the remedial
alternatives evaluated for OU-1 is presented below.
• Alternative 1 - No Action
• Alternative 2 - Cover with Institutional Controls
• Alternative 3 - Excavation and Offsite Disposal
2.7.1 Alternative 1 - No Action
Description: The no-action alternative is required to be evaluated under CERCLA. Under
this alternative, no action would be performed to reduce the toxicity, mobility, or volume of
the contaminated soil at the Bohneyard. Contaminants at the site would be left where they
are. The no-action alternative serves as a baseline against which the effectiveness of the
other alternatives is compared.
2.7.2 Alternative 2 - Cover and Institutional Controls
Description: Consistent with the U.S. Navy's plans for reuse of Site 6 as a parking lot for
aircraft fueling trucks, a concrete/asphalt parking lot would be constructed over about one-
half of Site 6. A cover comprised of soil over gravel would be placed over the remaining
area of Site 6 in which soil contaminant concentrations are greater than the site worker
exposure PSs. The cover will consist of 4 inches of compacted gravel with 8 inches of
topsoil for vegetative purposes. At Site 6A, an asphalt cover will be constructed for storage
and staging.
The protecriveness of this remedy would depend on (!) maintaining the integrity of the
concrete parking lot, asphalt cover and soil cover, (2) prohibiting access to groundwater at
Sites 6 and 6A, and (3) continued use of Sites 6 and 6A for industrial or commercial
purposes.
Because contaminated soil would be left in place, a review would be conducted every 5
years to evaluate whether human health and the environment continue to be protected by
this alternative.
WOC992150005.DOQ2/AMO
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DECISION SUMMARY
2.7.3 Alternative 3 - Excavation and Offsite Disposal
Description: Under this alternative, soil that is contaminated at levels exceeding residential
exposure PSs would be removed from the Bonneyard and would be disposed of offsite at a
nonhazardous waste landfill. Excavated areas would be backfilled with clean fill and
would be revegetated. Institutional controls and 5-year reviews would not be needed to
protect human health and the environment because soil posing potential risks would be
removed permanently.
'•—-
2.8 Summary of Comparative Analysis of Alternatives
To determine the preferred alternatives, the remedial alternatives for OU-1 described in
Section 2.7 were evaluated against nine evaluation criteria identified in the NCP at 40 C F R
Section 300.430(e)(9).
The NCP outlines the approach for comparing remedial alternatives. Evaluation of the
alternatives uses "threshold" criteria, "primary balancing" criteria, and "modifying"
criteria.
To be considered for remedy selection, an alternative must meet the two threshold criteria:
"overall protection of human health and the environment" and "compliance with
applicable or relevant and appropriate requirements (ARARs)." The primary balancing
criteria, "long-term effectiveness and permanence," "reduction in toxicity, mobility, or
volume through treatment," "implementability," "short-term effectiveness," and "cost" are
then considered to determine which alternative provides the best combination of attributes.
The threshold and primary balancing criteria are technical criteria based on human health
and environmental protection, cost, and engineering feasibility. The alternatives are further
evaluated against the two modifying criteria: "acceptance by the state" and "acceptance by
the community," before selecting the preferred remedy.
Each of the alternatives presented in subsection 2.7 were compared using the threshold,
primary balancing, and modifying criteria. The summary analysis and evaluation of each
remedial alternative against the threshold and primary balancing criteria is provided below.
The FFS provides a detailed analysis and evaluation of the comparative analysis of
alternatives against the primary and modifying criteria.
The state and community acceptances are assessed in Section 3.0, "Responsiveness
Summary."
2.8.1 Threshold Criteria
2.8.1.1 Overall Protection of Human Health and the Environment
Alternative 1 (no action) will not protect human health or the environment from soil
contamination at the site. It will, therefore, not be considered further in this analysis.
Alternative 2 would protect human health and the environment by containing contam-
inated soil that exceeds the PSs onsite under a concrete cover, a soil and gravel cover, or an
asphalt cover. Institutional controls would restrict access to the site and limit its use to
industrial activities. Alternative 3 would provide the highest level of protection of human
WDCW2150005.00Q2/AMD 2.15
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DECISION SUMMARY
health and the environment because this alternative would remove contaminated soil from
the site.
2.8.1.2 Compliance with ARARs and TBCs
Alternatives 2 and 3 would comply with all ARARs and (to be considered) TBCs. Major
ARARs for Alternatives 2 and 3 are:
• Sediment and Erosion Control requirements (Annotated Code of Maryland,
Environment Article, Title 4, Subtitle 1; COMAR 26.17.01)
• Stormwater Management requirements (Annotated Code of Maryland, Environment
Article, Title 4, Subtitle 2; COMAR 26.17.02)
2.8.2 Primary Balancing Criteria
2.8.2.1 Long-Term Effectiveness and Permanence
Alternative 2 would be effective in the long-term because covering has been demonstrated
to provide long-term effectiveness provided it is properly maintained. This alternative
provides for a means for protecting and monitoring the environment. It controls the
sources of contamination at the site by containing them beneath the cover. Alternative 3
would be the most effective in the long-term because all sources of contamination would be
removed from the site.
Five-year site reviews will be required since contamination would remain in place at the
site under this alternative. Long-term monitoring will be conducted to track future
contamination migration and evaluated during the 5-year site reviews.
2.8.2.2 Reduction in Toxicity, Mobility, or Volume through Treatment
The primary contaminants of concern are metals. Treatment of metal contamination at
levels detected in the soil at the Bohneyard is not fully effective. Therefore, none of the
alternatives uses treatment to reduce the toxicity, mobility, or volume of soil contamination.
2.8.2.3 Implementability
Alternatives 2 and 3 are implementable using conventional, well-demonstrated, and
commercially available technologies. Alternatives 2 and 3 have been proven to be reliable
and readily implementable. Concrete covering, asphalt covering, and installing a soil cover
over contaminated soils under Alternative 2 is a commonly used technology in terms of
installation, operation, and maintenance. Excavation and offsite disposal of soils under
Alternative 3 also are easily implementable, because excavation equipment and approved
disposal facilities are commonly available.
2.8.2.4 Short-Term Effectiveness
Alternative 2 would be more effective than Alternative 3 in the short term. Alternative 2
would achieve the remedial action objective (preventing human contact) more quickly than
Alternative 3. Alternative 2 will take 2 months to achieve the RAO, as opposed to 12
months under Alternative 3. In addition, excavating, handling, and transporting
contaminated soil would be required under Alternative 3, and, thus the potential for
unacceptable exposure is higher during excavation under Alternative 3 than under
2-16 . WDC992150005.00O2MMO
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DECISION SUMMARY
Alternative 2. However, any exposures to workers or to the community can be adequately
controlled.
2.8.2.5 Cost
The total estimated present-worth cost of Alternative 2 is $1,720,000. Both the MAS and the
IR program will provide the funding for Alternative 2. The NAS and the IR program will
provide $1,220,000 and $500,000, respectively. The estimated present-worth cost of
Alternative 3. is $2,600,000.
2.8.3 Modifying Criteria
2.8.3.1 Community Acceptance
Community relations activities to date for OU-1 include establishing an Administrative
Record, briefings to the Restoration Advisory Board regarding findings of the RI and FFS,
and release of the PRAP for public review and comment on July 27,1999. A public meeting
was conducted on August 10,1999, at the Frank Knox Training Center, Building 2189,
located outside Gate 2.
At the public meeting, two community members said they preferred Alternative 3
(excavation) over the Navy's preferred alternative, Alternative 2 (covering), while one
community member supported the Navy's preferred alternative. These and other concerns
that were raised by the local community at the public meeting and the Navy's responses to
these concerns are provided in the responsiveness summary (Section 3 of this ROD). The
transcripts from the public meeting are provided in Appendix B.
2.8.3.2 State Acceptance
With respect to state acceptance, the MDE has reviewed the PRAP and has concurred with
the selected remedial action, Alternative 2.
2.9 Selected Remedy
The U.S. Navy's selected remedy is Alternative 2. By containing contaminated soil with
gravel and soil, a concrete cover, or an asphalt cover, this alternative effectively addresses
soil contamination that exceeds remediation goals at the Bohneyard. On the basis of
available information and the current understanding of site conditions, Alternative 2
appears to provide the best balance with respect to the nine NCP evaluation criteria.
Alternative 2 achieves a level of protection comparable to Alternative 3 at approximately
one-half the cost and limits the exposure of workers to contaminated soil during excavation.
A schematic of the selected remedy is displayed in Figure 2-5.
Consistent with the U.S. Navy's plans for reuse of Site 6 as a parking lot for aircraft fueling
trucks, a concrete parking lot would be constructed over about one-half of Site 6. A cover
comprised of soil over gravel would be placed over the remaining area of Site 6 in which
soil contaminant concentrations are greater than site worker exposure PSs. The cover will
consist of 4 inches of compacted gravel with 8 inches of topsoil for vegetative purposes. At
Site 6A, an asphalt cover will be constructed for storage and staging. Institutional controls
would consist of access restrictions to prevent trespassing at the Bohneyard, land use
controls to control site development and access to groundwater, and monitoring to assess
WDC9921SOOOS.OOC/2/AMO
2-17
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LEGEND
.
NO; TO SCALE
MOTE Mipb*uMogn|A
. Buildings
«... Approximate Location
-------
DECISION SUMMARY
whether contaminants are migrating to the environment. Because contaminated soil would
be left in place, a review would be conducted every 5 years to evaluate whether human
health and the environment continue to be protected by this alternative.
2.9.1 Performance Standards of the Preferred Remedy
Performance standards related to the selected alternative are discussed below.
Cover Design Criteria: Concrete, asphalt, and soil cover (described below) will be placed
over soil at the Bohneyard in which concentrations of hazardous substances shown on
Table 2-1 are greater than the site worker PSs. A concrete parking lot would be constructed
over about one-half of Site 6. The 8-inch-thick concrete wearing surface will be underlain
by a compacted gravel subbase ranging in thickness from 6 to 10 inches. The compacted
subbase will be separated from the ground surface by geotextile grade separation material.
A cover comprised of soil over gravel would be placed over the remaining area of Site 6 in
which concentrations of hazardous substances are greater than the site worker exposure
PSs. The cover will consist of a minimum of 4 inches of compacted gravel with minimum of
8 inches of topsoil for vegetative purposes.
At Site 6A, an asphalt cover will be constructed for storage and staging. The cover design
shall include construction of durable, flexible pavement that resists cracking. The asphalt
cover will be a minimum of 2 inches thick. The cover shall prevent direct contact with the
underlying contaminated soil, and control surface water run-on and runoff.
Design and construction of the cover at the Bohneyard will be in accordance with master
U.S. Navy specifications.
Land Use Controls: The protectiveness of the remedy selected in this ROD depends on (1)
maintaining the integrity of the concrete parking lot, asphalt cover and soil cover described
above, (2) prohibiting access to ground water at Sites 6 and 6A, and (3) continued use of
Sites 6 and 6A for industrial or commercial purposes. The remedy is not designed to protect
human health if Sites 6 and 6A are used for residential purposes. Accordingly, unless the
remedy selected in this ROD is revisited and all necessary steps, including additional
response actions, are taken to protect human health and the environment, NAS Patuxent
River shall prohibit except as provided below;
• Future excavation and any other activity that would disturb the integrity of the concrete
parking lot, asphalt cover, or soil cover described above;
• Access to groundwater underlying Sites 6 and 6A; and
• Residential use of Sites 6 and 6A.
These shall be the "land use controls" for Sites 6 and 6A.
Land Use Control Implementation Plan: NAS Patuxent River shall develop, in
consultation with EPA and MDE, a Land Use Control Implementation Plan (LUCIP). The
LUCIP shall include a description of Sites 6 and 6A, including a map, a description of its
size, and a description of the contaminants of concern; the land use controls selected above;
the particular mechanisms to implement these controls; a reference to this ROD; and any
other pertinent information.
WOC9921S0006.00O2/AMO 2-19
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DECISION SUMMARY
Assuring Continued Effectiveness of Land Use Control: The Navy, MDE and EPA intend
to negotiate a Land Use Control Assurance Plan (LUCAP) in the near future, which will
establish procedures for ensuring that the land use controls for Sites 6 and 6A and all other
IR sites at Patuxent River Naval Air Station remain effective and protective in the long-
term. In the meantime, NAS Patuxent River shall implement the procedures outlined below
to ensure the continued effectiveness of the land use controls for Sites 6 and 6A.
NAS Patuxent River shall conduct an annual visual inspection of Sites 6 and 6A to verify
that the land use controls for these sites have been implemented and are being properly
maintained. NAS Patuxent River shall promptly notify EPA and MDE of any deficiencies
noted, any corrective measures taken or to be taken, and the schedule for taking such
corrective measures.
In addition to a visual inspection, NAS Patuxent River shall annually review the status of
the land use controls for these sites. Any non-compliance issues will be appropriately
resolved with EPA and MDE.
NAS Patuxent River shall annually prepare and forward to EPA and MDE a report, signed
by the Station Commanding Officer, certifying the continued retention of the land use
controls for Sites 6 and 6A.
The above requirements for inspecting, reviewing and certifying the continued effectiveness
of land use controls at Sites 6 and 6A are intended to be in addition to, and not a
replacement for, requirements in the Operation and Maintenance Plan for the remedy
selected in this ROD. The Operation and Maintenance Plan will be developed following
signing of this ROD.
At least sixty days (except in emergency situations) prior to implementation of any major
change in land use at Site 6 and 6A, NAS Patuxent River shall notify EPA and MDE of the
contemplated change. The notification shall be provided to obtain EPA and/or MDE's
concurrence with the NAS Patuxent River's determination as to whether the contemplated
change will or will not necessitate the need for re-evaluation of the selected remedy or
implementation of specific measures to ensure continued protection of human health and
the environment.
NAS Patuxent River also agrees to immediately notify EPA and MDE if, despite its best
efforts to ensure compliance the land use controls for Sites 6 and 6A, any major change in
land use at Site 6 and 6A is discovered which has not been previously reviewed by U.S.
EPA and MDE. Such notifications will provide all pertinent information as to the nature
and extent of the change and describe any measures implemented or to be implemented (to
include a timetable for future completion) to reduce or prevent human health or ecological
impacts.
2.10 Statutory Determinations
The Navy's selected remedy, Alternative 2, is anticipated to meet the following statutory
requirements of CERCLA Section 121:
• Protection of human health and the environment
2-20 WDC99215000S.DOG2/AMD
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DECISION SUMMARY
• Compliance with applicable or relevant and appropriate requirements of federal and
Maryland environmental laws
• Cost-effectiveness
• Use of permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable
At this site, treatment of metal contaminants is not practicable. For this reason, the preferred
alternative does not satisfy the statutory preference for treatment.
The preferred alternative addresses soil contamination at the Bohneyard, providing for
containment that prevents direct contact with onsite personnel. Institutional controls will
protect human health and the environment further by limiting future land use and by
providing continued long-term monitoring of the contaminants remaining on site.
The selected remedy is expected to comply with ARARs. ARARs are federal and state
environmental statutes that are either directly applicable or relevant and appropriate in the
development and evaluation of remedial alternatives at a particular site. Chemical-,
location-, and action-specific ARARs have been evaluated for the Bohneyard, OU-1.
Location- and action-specific ARARs that have been evaluated for Bohneyard, OU-1, are
presented in Appendix C. Chemical-specific ARARs, or Performance Standards (PSs) were
calculated to identify maximum allowable concentrations of each of the chemicals of
concern for various human health risk scenarios, as described in subsection 2.6.1.
This alternative also meets base long-term operational needs by reusing and centralizing an
area for parking aircraft fueling trucks near petroleum storage tanks adjacent to the
runway/taxiways. In addition, centralization will allow the base to redevelop
approximately 23 acres, which are currently used to park the fueling trucks.
2.11 Documentation of Significant Changes
The selected remedy. Alternative 2, is the same alternative recommended in the PRAP. The
selected remedy also is identical to the recommended alternative presented at the August
10,1999, public meeting.
There were no significant changes to the recommended remedial action alternative in the
PRAP.
WDC992150005.00O2/AMO 2-21
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3.0 Responsiveness Summary
As described in subsection 2.8, the remedial alternatives for OU-1 were evaluated against
seven of the nine evaluation criteria identified in the NCP at 40 C.F.R. Section 300.430(e)(9).
The last two of the nine evaluation criteria in the NCP are state acceptance and community
acceptance. The Responsiveness Summary is a concise and complete summary of state and
community acceptance. The Responsiveness Summary provides the lead agency (U.S.
Navy) 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 August 27,1999, in accordance with the guidance
document, Community Relations in Superfund: A Handbook (Office of Solid Waste and
Emergency Response [OSWER] Directive 9230.0-3B, January 1992).
3.1 Summary of Public Comments and Agency Responses
A public meeting was conducted on August 10,1999, at the Frank Knox Training Center,
Building 2189. Two community members said they preferred Alternative 3 (excavation)
over the Navy's preferred alternative, Alternative 2 (covering); while one community
member supported the Navy's preferred alternative. The Navy, EPA, and MDE believe that
despite the fact that two community members preferred Alternative 3 (excavation) over
Alternative 2 (covering), Alternative 2 is the most efficient and cost effective way to
remediate the Bohneyard. The soil at the Bohneyard is contaminated with inorganic (metal)
contamination at relatively low levels (levels above background but below industrial
exposures). Unless the offsite disposal includes some form of treatment, the Navy will
assume future liability which cannot be easily quantified. Since metal contamination at
relatively low levels is not amenable to treatment, there is an additional liability that the
Navy will assume with off-site disposal. Further justification of the preferred alternative is
provided as a response to Question #4 below.
The community concerns have been studied, and responses are provided below. The public
meeting transcripts are provided in Appendix B.
1. What was the criteria for listing the NAS Patuxent River on the NPL?
Navy Response: NAS Patuxent River was evaluated by EPA based on Hazard Ranking
System (HRS) II guidelines. The goal of the HRS process is to develop a site-specific hazard
ranking score, evaluating the relative threat associated with actual or potential releases to
air, surface water, soil, and groundwater. The hazard ranking score is used as a screening
tool for determining whether a site is to be included on the NPL. The Navy uses the NPL
score to prioritize sites for cleanup funding.
After surveying available data, NAS was given a score of 50. Since the EPA cut-off level for
NPL inclusion is 28.5, NAS is therefore subject to inclusion on the NPL. This ranking is
generated for the entire base as a whole, not for one particular site. The NAS Patuxent
River was proposed to be listed on the NPL on January 18,1994. The NPL inclusion date is
WDCM2t5000S.DOC/2MMD 3-1
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RESPONSIVENESS SUMMARY
June 30,1994. The inclusion date was posted in the Federal Register (59FR 27989) on
May 31,1999.
2. What are Soil Screening Levels (SSLs), and how do they apply to the Sites 6 and
6A?
Navy Response: Chemicals may move through the soil and into groundwater. To
determine whether current concentrations of contaminants detected in soil at the
Bohneyard are migrating to groundwater at unacceptable levels, soil screening levels (SSLs)
were calculated using a soil-to-groundwater transfer model and site-specific data, SSLs
were calculated for iron and trichloroethylene (TCE) because these contaminants were
detected in groundwater above risk-based screening levels. The calculated SSLs for iron
and TCE in soil were then compared to the maximum concentrations detected in soil at the
Bohneyard. The calculated SSLs for iron and TCE are greater that the maximum
concentration of these contaminants detected in soil. Because soil concentrations for iron
and TCE are below the calculated SSLs using site-specific data, iron and TCE are not
expected to migrate from soil to groundwater. As a result, there is no expectation that
current soil concentrations of iron and TCE will impact groundwater at the site.
The TCE detected in groundwater could be the result of leaks from the partially buried tank
used to store waste oil. The tank was removed in 1992. However, soil samples collected in
the vicinity of the tank location exhibited detectable TCE concentrations (refer to Section
2.5.5). Although iron is present above risk-based levels in groundwater, the aluminum
concentration is also high. This suggests that the groundwater samples may have been
turbid, due to the presence of suspended solids in the samples.
3. How is contaminated groundwater addressed?
Navy Response: Groundwater monitoring-well sampling was conducted as part of the
ongoing Remedial Investigation for Operable Unit (OU) 2. The nature and extent of
contamination in OU-2 will be discussed in detail as part of the RI for OU-2.
Analytical results from groundwater samples collected in 1996 and 1997 were screened
against Maximum Contaminant Levels (MCLs) for drinking water, where available, to
assess whether chemicals detected in soil were causing potentially unacceptable levels of
contamination in groundwater. Where MCLs were not available, Maximum Contaminant
Level Goals (MCLGs) were used for screening. If neither of these values were available, the
current EPA Region III Risk-Based Concentration (RBC) for tap water was used as a
screening criterion.
Two chemicals were detected in groundwater at concentrations exceeding these screening
criteria: iron and trichloroethene. The maximum concentrations of thallium and lead also
exceed the screening criteria. However, thallium was only detected once in an upgradient
well. Lead was only detected once in one well, at a concentration that is just slightly above
the MCL. In addition, during the three previous rounds of sampling, lead was detected at
concentrations that were an order of magnitude below the MCL. Due to this, thallium and
lead are not evaluated further. No screening values were available for calcium, magnesium,
potassium, sodium, or 4-methyl-2-pentanone. Because the four inorganic chemicals for
which screening values were not available are common human nutrients, no further
evaluation will be conducted. The maximum concentration of 4-methyl-2-pentanone in
3-2 WOC992150005 DQC/2/AMD
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RESPONSIVENES
groundwater was 5 ug/L, detected in only one well and flagged 'B' to indicate that similar
levels also were detected in blank samples. As a result, 4-methyl-2-pentanone will not be
further evaluated.
A human health and ecological risk assessment for exposure to groundwater will be
conducted as part of the RI/FS for OU-2.
4. What is the justification for selecting Alternative 2 vs. Alternative 3?
Navy Response: Alternative 2 effectively addresses soil contamination that exceeds
remediation goals at the Bohneyard. Even though contaminated soil remains onsite, the
risk of exposure to the soil is eliminated or greatly reduced, therefore it is protective of
human health. The asphalt and soil cover will be regularly maintained. On the basis of
available information and the current understanding of site conditions, Alternative 2
provides the best balance with respect to the NCP evaluation criteria.
Under Alternative 3, there is a liability associated with excavation of contaminated soil.
Under Alternative 3, the contaminated soil would be excavated and sent to a secure off-site
landfill. Unless the off-site disposal includes some form of treatment, the Navy will assume
future liability which cannot be easily quantified. Since metal contamination at relatively
low levels is not amenable to treatment, there is an additional liability that the Navy will
assume with off-site disposal.
Alternative 2 is projected to be completed in a shorter time than Alternative 3 (2 months as
opposed to 12 months), therefore Alternative 2 will begin protecting human health and the
environment sooner than Alternative 3.
Alternative 2 also poses less short term risk to workers. Alternative 3 requires that workers
excavate contaminate soil, which potentially exposes them to hazardous substances.
Alternative 2 does not require that workers be exposed to hazardous substances in the
soil because it does not require excavation.
Alternative 2 is protective of human health, and is substantially more cost-effective than
Alternative 3. The cost of Alternative 2 to the Installation Restoration program is $500,000,
and the cost of Alternative 3 to the Installation Restoration program is $2.6 million. EPA,
Navy and MDE are satisfied that the cost estimates, though they contain some uncertainty,
are the best available predictors of the relative costs of Alternatives 2 and 3, and the best
currently available information for making a decision about cost-effectiveness.
5. How is the cost estimate in the PRAP developed, and what is it used for?
Navy Response: The cost of the alternative is one of the nine NCP criteria used in selecting
the preferred alternative. Cost estimates for each alternative were developed by following
the standard CERCLA procedures. Specifically, for each remedial alternative, a detailed
cost analysis was developed based on conceptual engineering and analyses. Unit prices
were based on published construction cost data, quotes from vendors and contractors,
and/or engineering judgment. Costs are expressed in terms of 1998 dollars, hi order to
allow the costs of remedial alternatives to be compared on the basis of a single figure, the
present worth value of all capital and annual costs was determined for each alternative.
The EPA CERCLA RI/FS Guidance Document (EPA, 1988) recommends that a 5 percent
discount rate be used in present-worth analyses.
WOC9K1S0005.DOC/2/AMO 3-3
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RESPONSIVENESS SUMMARY
The cost estimates for all the alternatives are provided to an accuracy of +50 percent to -30
percent (the actual cost may range from 30% lower to 50% higher of the estimated cost),
therefore are all compared on the same basis. EPA, Navy and MDE are satisfied that the
cost estimates, though they contain some uncertainty, are the best available predictors of the
relative costs of Alternatives 2 and 3, and the best currently available information for
making a decision about cost-effectiveness. The Navy will obtain more accurate estimates
as the design is developed.
6. What are the stormwater discharge procedures for the concrete containment
structure?
Navy Response: The fuel farm will contain a concrete containment structure as part of the
concrete cover at Site 6. Steps will be taken as part of the fuel operation to avoid spills into
the ground and sewers. The base fuel farm personnel will inspect the contents of the
containment structure; if the contents only contain stormwater, the contents will be
released. Fuel that is captured in the concrete containment structure will be disposed of in
accordance with State and Federal regulations.
3-4 WDC9921S0005.00O2/AMO
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Glossary
ARARs — Applicable or Relevant and Appropriate Standards, Limitations, Criteria, and
Requirements; these are federal or state environmental rules and regulations.
Backfill — Filling an excavated area.
Cancer Risk: Cancer risks are expressed as numbers reflecting the increased chance that a
person will develop cancer if exposed to chemicals or substances. For example, EPA's
acceptable risk range for Superfund sites is 1 x 10"» to 1 x 10-*. This means that the
probability of cancer should not be greater than 1 in 10,000 chance to a 1 in 1,000,000 chance
above background.
CERCLA — Comprehensive Environmental Response, Compensation, and Liability Act
(1980), also known as the Superfund Law, as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA). CERCLA provides the organizational structure and
procedures for responding to releases of hazardous substances, pollutants, and
contaminants from inactive hazardous waste disposal sites.
GDI—Chronic Daily Intake—Exposure expressed as mass of a substance contacted per unit
body weight per unit time, averaged over a long period of time (seven years to a lifetime).
COC - Contaminant of Concern. Chemical compounds that have been identified-as a
concern for human health and the environment at detected concentrations.
Ecological Receptors — Living organisms (other than human beings or domesticated animals)
that could be affected by contamination in the environment.
EPA — United States Environmental Protection Agency.
Exposure Pathways: Describes the course a chemical or physical agent takes from the source
to the exposed individual. Elements of the exposure pathway are: (1 j the source of the
released chemical; (2) the contaminated medium (e.g., soil); (3) a point of contact with the
contaminated medium; and (4) an exposure route (e.g., ingestion or inhalation) at a contact
point.
FFS—Focused Feasibility Study — An FS that is limited in scope to one operable unit or
medium (such as soil), although measures will be taken to minimize impacts on other units
or media at the site.
FS—Feasibility Study — Analysis of the practicability of a proposal; e.g., a description and
analysis of potential cleanup alternatives for a site such as one on the National Priorities
List. The feasibility study usually recommends selection of a cost-effective alternative. It
usually starts as soon as the remedial investigation is underway; together, they are
commonly referred to as the "RI/FS."
Groundwater — Subsurface water that occurs in soils and geologic formations that are fully
saturated.
WOC992150005.DOO2/AMD Q-1
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GLOSSARY
HI—Hazard Index—A number indicative of non-carcinogenic health effects, which is the MB
ratio of the existing level of exposure to an acceptable level of exposure. A value equal to or ^^
less than one indicates that the human population is not likely to experience adverse effects.
HO—Hazard Quotient—The ratio of a single sxibstance exposure level over a specified time
period (e.g. subchronic) to a reference dose for that substance derived from a similar
exposure period.
Institutional Controls — Administrative methods to prevent human exposure to contaminants,
such as by restricting land development.
IRI—Interim Remedial Investigation—Similar to a Remedial Investigation, but carried out
prior to NAS listing on the NPL. An in-depth study designed to gather data needed to
determine the nature and extent of contamination at a site, establish site cleanup criteria,
identify preliminary alternatives for remedial action, and support technical and cost
analyses of alternatives.
Performance Standards - Criteria that must be met by the selected remedial alternative in
order to ensure that the action meets all remedial action objectives, including protection of
human health and the environment.
Present-Worth Cost - Total cost, in current dollars, of the remedial action. The present-worth
cost includes capital costs required to implement the remedial action, as well as the cost of
long-term operations, maintenance, and monitoring.
MDE— Maryland Department of the Environment. 4Mk
Media — Soil, groundwater, surface water, or sediments at a site.
NCP - National Oil and Hazardous Substances Contingency Plan. Provides the
organizational structure and procedures for preparing for and responding to discharges of
oil and releases of hazardous substances, pollutants, and contaminants.
NPL - National Priorities List. EPA's list of the most serious uncontrolled or abandoned
hazardous waste sites in the United States.
OU —Operable Unit— Term for each of a number of separate activities undertaken as part
of a Superfund site cleanup. For example, cleanup of soil and groundwater could be two
separate operable units.
Public Comment Period—The time allowed for the members of an affected community to
express views and concerns regarding an action proposed to be taken by EPA, such as a
rulemaking, permit, or Superfund remedy selection.
RAOs—Remedial Action Objectives— Objectives of remedial actions which are developed
based on contaminated media, contaminants of concern, potential receptors and exposure ,
scenarios, human health- and ecological-risk assessment, and attainment of regulatory
cleanup levels, if any exist.
RCRA — Resource Conservation and Recovery Act. A 1976 regulation of the management of
hazardous waste to ensure the safe disposal of wastes. The intent of the RCRA program is
to protect public health and the environment by controlling hazardous waste.
G>2 WOC992150005.DOC/Z/AMO
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GLOSSARY
RfD—Reference Dose—An estimate (with uncertainty spanning perhaps an order of
magnitude or greater) of a daily exposure to the human population, including sensitive
subpopulations, in which the exposure is likely to be without appreciable risk of deleterious
effects during a lifetime.
Removal Action — Short-term immediate actions taken to address releases of contamination
that require quick and timely response.
ROD—Record of Decision—A public document that explains which cleanup alternative was
selected for a Superfund site.
Sediment — Solid material transported by water that is deposited in layers along channels of
flow.
Surface Water — Water that occurs on the ground surface, usually in the form of a lake,
stream, river or other body of water.
WOC992150005.00O2/AMO G-3
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Appendix A
State Letter of Concurrence
WOC9921SOOOB.DOG2/AMO
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FROM ' 1333,03-16 10=52 8312 P.32/02
MARYLAND DEPARTMENT OF THE ENVIRONMENT
•2500 Broening Highway • Baltimore Maryland 21224
(410) 631- 3000 • 1- 800 -633-6101 • http:// www. rode, state, md. us
Parris N. Glendening Jane T. Nisluda
GoVern°r ' • Secretary
September 16,1999
Mr. Bayly Smith
Environmental Division
Public Works Department
22554 Peary Road., Building 504
Naval Air Station
Patuxent River MD 20670
Re: Record of Decision. Sites 6 and 6A. Operable Unit \ fCoT^jn^d s^ Patuxent River
Naval Air Station
Dear Mr. Smith:
The Maryland Department of the Environment (MDE), Waste Management
Administration has reviewed the above-referenced document. This Record of Decision (ROD)
documents the Navy's decision to construct soil and asphalt covers at two areas of the
Bohneyard (Sites 6 and 6A).
The soil and asphalt covers, along with institutional controls, are intended to prevent
human exposure to the organic and inorganic contaminants identified in the soil and thereby
mitigate th« associated risk. As discussed in the ROD, the Navy is continuing to evaluate the
groundwater at this site as Operable Unit 2.
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.
Sincerely,
Kim Lemaster
Section Head
Federal/NPL Supcrfund Division
cc: Mr. Andrew Sochanski
Mr.JeffWaite
Mr. Richard Collins
Mr. Karl Kalbacher
TTYUw,i-«o^735.22St "Together We Can Clean Up"
*i» Maryland R«tay Service *
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Appendix B
Publie Meeting Transcripts
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PAGE
In The Matter Of :
PROPOSED REMEDIAL ACTION PLAN
BOHNEYARD OPERABLE UNIT 1 - SOIL
August 10, 1999
For The Record, Inc.
Court Reporting and Litigation Support
6O3 Post Office Road
Suite 309
Waldorf, MD USA 20602
(301) 870-8025 PAX: (3O1) 870-8333
Original File 9O8WPAXASC, 75 Pages
Min-U-Script® File ID: 1562939810
Word Index included with this Min-U-Script»
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Pagel
(21
PI
PROPOSED REMEDIAL ACTION PLAN
SITES 6 AND 8A. 8OHNEYARO
OPERABLE UNIT 1 - SON.
PUBLIC HEARING
AUGUST tO. 1999
H »l
tun
(17) The pubfc hearing wa» lateen on Tuesday,
[ia] August 10. 1999. commencing at 6-J8p.m.. at the
(19) Frank Kncx Training Center, Patuxer* River.
IZOI Maryland before Mary dare Ctthcner-Hanmond.
pi] Notary Pubic.
t
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10:3013423030 PAGE 4X13
BOHNEYAKD OPERABLE UNIT 1 - SOIL
Pag«S
111 of the Environment, and the EPA. As we work on
m these projects and as we keep going through steps
PI and looking at alternatives, et cetera, we're in
;
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AUG-3B-93 14:33 FROM : ENW I RONHENTAL.
MOnrx tYAKl> OPEKAJBLfc UNIT I - SOIL
preliminary assessment, maybe taking a couple
soil samples, run the samples, getting some
documentation on what the site had contained at
one time, going out and doing some additional
site work and then if we find that we need to,
that site moves to the remedial investigation
feasibility study, which is a much larger scope
of investigating the site. And also coming up
with alternatives for addressing the site.
New is the proposed plan and Record of
Decision.The proposed plan is when we send out
to the public information on what it is we plan
to do at a particular site and that information
gets documented in the Record of Decision and
I'll go into that a little bit later on in the
presentation.
Then we have the remedial design and
design what it is we want to do at the site and
then that design is implemented. Once the design
has been implemented and the action is complete,
then we continually monitor the remedy to make
sure that it stays in place and that it is
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August 10,1999
Pag* 9
Pi
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effective.
The Record of Decision.That serves as
legal documentation for the remedy that we
selected at the installation restoration site.
It's a requirement under the Comprehensive
Environmental Response, Compensation, and
Liability Act, CERCLA. Also known as Superfund.
And it outlines the technical aspects of the
remediation, what it is we're trying to do and
why and get the technical basis for that and it
also serves as information to be shared with the
public.
This isn't a really good picture of the
site, but this is the current site condition of
Site 6 and 6A. which is known as the Bohncyard.
In the back, when you came into the room earlier,
you might have noticed two color plans and
they're right back there.
I had the board turned around so you can
see them.To my left is the current condition at
Site 6 and 6A. the Bohneyard. Right now the base
is using that for fuel operations.
Page 10
(i|
(2]
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W
Pi
(a)
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[iffll
(til
[141
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Next to it is the future plan for the
Bohncyard, which will consolidate all the fuel
operations here at Pax River for the fuel trucks.
They'll be located in one area. The entire
Bohneyard site encompasses about ten acres.
It got the name because of the location.
It's on Bonne Road and it was just a storage
yard, hence Bohneyard. So, that's how we came up
with the name.Therc's some buildings out there
now that are associated with their fuel
operations.
Site 6A is the site located east of Site
6 and that area is mainly used just for storage.
A little bit of history of Site 6 and 6A. I'll
start with Site 6 first. Site 6 was used
actually early in the forties and it received
bottom ash from the coal-fired plant here on
station and spread across the site.
Later on, it started receiving drums
containing oily waste and later on those drums'
contents expanded to waste paints, oils, thinners
and lubricants. Later on, late seventies/early
Page 11
W eighties, operations ceased and the drums were
H eventually removed from the site.
pj In'89 the base received a sludge
w application from the nearby wastewater treatment
(si plant and then in 1992 there was a large,
partially buried tank that contained waste oil
that was later removed.
m This is what the site used to look like
Pi when it was in operation with the drum storage.
After the drums were removed, they had the sludge
in application, and then the results of the sludge
i2| application: Nice, green grass.
is) And this is the storage compound. And I
141 don't have my pointer, but if you look over in
is] the top, sort of like the middle left area, you
is) can see storage and that's for the ROICC,
IT) Resident Officer In Charge of Construction. He's
aj using that right now as a storage area for
'«) equipment.
2oj Site 6A came along later in the program.
211 We already started looking at Site 6 and once the
base became a National Priority Listed site, we
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Pag* 13
00)
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02)
M3]
(t4)
(is)
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«i]
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got a hold of some earlier aerial photographs and
it -was determined that this adjacent area to Site
6 also had some drum storage. So. we needed to
take a look at that site also.
Summary of site risk for both sites. As
far as having any cancer-causing contaminants, we
found everything to be within the acceptable
range for cancer risk.Thc concern is mainly in
noncanccr causing and this is due to some of the
metals that we detected out there, such as
arsenic, chromium, aluminum, silver, and it is
not acceptable for the noncancer risk, which is
why we're going to be doing an action out there
at Site 6 and 6A.
We also looked at the ecological portion
and this took some time to look at because the
ecological assessment piece has really been
evolving over the last several years as far as
learning more about how to assess an area and we
have been working very closely with the EPA's
biological technical assistant group to do this.
What we do for these sites, we're given
Pag* 14
(t) the current size of the site and then what we're
(2j planning to use the site for.There was really
n not going to be much habitat left out there.
HI There's not much ouc there now. So, that part
isj isn't going to change much. It's going to be
PI even less out there once we start and get the
pi fuel operations consolidated. So, essentially,
(*] we have no ecological risk at the site.
pj We just completed a Focused Feasibility
lie] Study for both sites and that's where we looked
(til at what we could dp to remedy these areas and
(tz) rather than look at a very large list of
Ii3) different alternatives for addressing the site.
(u| we first looked at what the base wanted to use
(is) the site for and then we tailored our
IK) alternatives to that usage. And what we looked
(in at were three alternatives.
d«) The first alternative is just a
(isj no-action alternative.That's something we have
(TO to include in all our feasibility studies. If we
(2i) do nothing, what is the cost? Are we doing —
(22) are we going to be protecting the health of the
(i] environment by doing nothing? We have to look at
(2) that.
[3] The next alternative. We looked at
(4) putting some type of cover in and then putting
is] institutional controls in place. What is meant
[si by institutional controls, is just making sure
IT) that whatever we decide to do out there does not
la) get impacted later. So, when you say, for
(9) instance, you cannot put a day care facility out
ID) here or you may not be able to dig beyond two
(ii) feet out here, something like that.
This is different from deed restriction
ii3i because we don't have the authority to actually
li4) restrict the transfer of the property. Only GSA
[is] does that, but what this allows us to do is to
lie) have more flexibility over the reuse of this
117) area.
lie) The third alternative that we looked at
) was just to dig and haul. And taking things
i off-site — and based on the cost, it's cheaper.
) Aside from Alternative 1, which has no cost.
[221 Between Alternatives 2 and 3,2 was the better
Page 15
Page 16
in alternative.
[2] To evaluate the alternatives, we had to
01 look at what we call the nine criteria.The
(4) National Contingency Plan.The nine criteria arc
is) broken down into three tiers. The first tier is
IE) the threshold criteria, that being one of the
re most important criteria as far as making sure we
18) have overall protection of human health and the
Pi environment.
(to) The next group is what we call the
(HI balancing criterta.To take a look at the
(ij| effectiveness of the remedy. Are we doing
(tat anything to reduce the amount of items that are
) out there? Is this something that can be easily
(is) implemented? Short term, is it going to work?
) And then we also look at cost.
(IT) The last criteria is the modifying
(IB) criteria and this is very important to us in the
(is) program because this is where we get the
I community acceptance and the State of Maryland
(2i| acceptance. And if the community cannot accept
(22) our alternative, then the State of Maryland does
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Page 17
[i] not support us either.
izi Alternative 2, to cover with
pi institutional controls, it met our criteria —
[4j the nine criteria we just looked at. We cannot
is) treat the metals that are out there.The metals
[6] are Just not conducive to treatment. So, that
(7j was something that we cannot look at.
;ai It is something that the National
[9] Contingency Plan wants us to look at when we're
(io| investigating the site. Is there something we
(111 can do to treat the material to reduce the
;i2i amount?That isn't something that we could do
[isi with the metals in the soils.
(MI Institute controls could be easily
[is] implemented and it meets the base's long-term
(is; operational needs and it allows the base — by
[IT] being able to consolidate the fuel operations, it
[t»l frees up about 23 acres here on the base for them
[i9] to use for something else.
[2oi And at the end of this meeting in the
pi] public comment period, if you decide for some
[221 reason we don't really like what it is that we're
Pag* 18
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PACE axis
BOHNEYARD OPERABLE UNIT 1 - SOIL
Hi
pj
(to)
in]
[121
i
poj
Rt|
expense? Dees the EPA or some other outfit pick
up some of the bill or is this all on die station
that has to —
MS. JORDAN: No, it comes out of our
installation rcstoratkm.The only dung that
the base is paying for — at this point, they're
just paying for their concrete cover for the
parking spots.
MS. KREITZEH: That they'll use.
They'll use the concrete?
MS. JORDAN: Right. Right.
MR. TARR: Madeleane. die two prices you
see under Alternatives 2 and 3? Under
Alternative 2. the 1.7 is the concrete covering,
die asphalt, and that's the whole parking lot.
MS. KREtTZER: The concrete cover and
the asphalt?
MR. TAHR: Yeah, that's all one. big
cover.
MS. KREITZER: I thought it was only die
concrete cover.
MR. TARR: It's the whole remedy. And
Pag* 22
(it that includes the O&M for 30 years, spending
la $20.000 a year to check it every once in the
[3] while and sample and so forth.
W MS. KREITZER: In the here it doesn't
[si say anything about how long it's going to hold
M up.
pj MR. TARR: Well —
la) MS. KREITZER: And I did read in here
[oj diat die — you didn't want a lot of people in
(ioi Uiere. You don't want kids over dierc.
in) MR. TARR: RIGHT.
(12) MS. KREITZER: You don't want housing
[taj over there.
•w MR. TARR: Right.The 1.7 is —
[is) MS. KREITZEP: So. if the base closes.
[is) down die line —
IT) CAPTAIN ROBERTS: Madeleane. there's a
1*1 couple diiflgs. First of all. there's die
i9i location. If you look at where diis diing is
located, it's right in the middle of all of our
fuel tanks.
[22) MS. KREITZER: I didn't hear.
Page 24
HI CAPTAIN ROBERTS: It's in the middle of
12) all our fuel tanks.This is where we store all
P) of our jet fucL So, we don't put things in
(4) there like that anyway. Okay?
;sj MS. KREITZER: Well, that makes sense.
m CAPTAIN ROBERTS: It doesn't make sense
(7) to put them in there, stored next to all these
(*) fuel tanks, okay? That's one reason, okay? The
M other thing is when you looked at what do you
io) have to do to protect human healdi?
What do you have to do to protect die
i2| ecology, the bunnies and so on and so forth, and
i3) if you look at what's in there, the metals and so
on. to simply cover it in place — we know what's
there, okay? When you don't taice things out. of
i8) course, you're going to have to monitor. Any
place you go — basically, any she that you
have — if you remember the pesticide shop?
MS. KREITZER: Yeah.
CAPTAIN ROBERTS: Any time you don't
2it take all of it out and get rid c.i :.t. you have to
22| monitor. That's the way the laws read —
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ID MS. KREITZER: Well, that makes sense.
Pi CAPTAIN ROBERTS: — and that's the way
PI it works.
(4i MS. KREITZER: Why not do it if there's
isi a doubt in mind? I mean, how great's the doubt
[si as to whether this is going to work?
m CAPTAIN ROBERTS: I don't think there's
[si much doubt as to the feasibility and that this
[9] will work. I think the data is there in the
do] studies that we did.
[i ij MS. KREfTZER: Okay. Five years down
mi the line, if you find you've got a problem, what
liaj are we going to have to do? Take off the asphalt
IMI and dig it out — take it out? I just, in my
(isi head —
(isi CAPTAIN ROBERTS: Can you help me with
(17) that, Andy, on the monitoring in this
[is] alternative?
[<9{ MR, SOCHANSKI: One of things we looked
(20] at — well, again, metals in soils, they don't
[2i] really migrate that much and we don't have a
(22i groundwater problem. So, they're there in the
•'
(11 soil.
ra And originally, we were looking at some
131 son of cover out there and I guess six months or
[4i a year ago the base mentioned, Hey, we'd like to
(si use this area as a parking lot. So, you know,
[5] considering that option, a parking lot in cover
PI seemed ideal and —
(si MS. KREITZER: How about long term?
OT MR. SOCHANSKI: Long term? I mean,
1101 you're going to have concrete out there 6 inches
in) for the parking area. Asphalt is going to be, I
(121 guess, 5.6 inches.
(<3) MS. KREITZER: The parking is not going
(14] to be on the asphalt?
[is] MR. SOCHANSKI: 6A is going to be
(t«l covered with asphalt.
[1 ri MS. KREITZER: And the other one is
(U) concrete?
[isi MR. SOCHANSKI: The other one is going
to be concrete. Beyond the areas in 6 that's
concrete, there's going to be gravel and then a
soil cover and then grass around the fringes.
Page 25
Pag* 28
m So, the only real monitoring we're going to have
(2i to do is make sure the asphalt doesn't crack, the
PI concrete doesn't crack and the gravel and soil
(4j and grass that's actually on the fringe areas
pi isn't eroding away.
(el MS. KREITZER: How about water? I
PI mean —
18] MR. SOCHANSKI: And the design is going
(9j to take care of water runoff, yeah.
no] CAPTAIN ROBERTS: And metals don't
(i 1] migrate like some of the other things that we've
[12] talked about that migrate.
i MS. KREITZER: And they don't have
(14] anything from the fuel tanks that — the stuff
[is] that leaked, the barrels that leaked and all that
(16) stuff? I'm not trying to give you a hard time.
[i7i CAPTAIN ROBERTS: No, no, they're good
Iii] questions. I'm sorry, what was your question?
l«) MS. KREITZER: Well, they had those
[201 drums out there.They said there was leakage.
pu CAPTAIN ROBERTS: There was some leakage
122| and that's what we're finding in the site. Most
Page 27
in of it is metals, okay? And so. it's not like
tz) when we dealt with pesticides or those types of
pj things that migrate through the soil very easily.
w The metals don't migrate. So, we know what's
is) there, okay?
[6j The original look was, well, when you're
m in the kind of situation we have, what you do is
m put some kind of cover or cap on it, okay? Well,
w in this case we decided to turn it into a win-win
(io) in that we were going to put a cap on it, but
nil we'd also put it in as a kind that we could use
;i2i that would consolidate and improve our
:i3| operations — our fuel operations, so we could
MI consolidate all of our fuel trucks at the fuel
;isi farm.
i«i So, we did two things at the same time:
IT] We consolidated the fuel truck operations. We've
taj met the requirements to the environmental — all
i»i the environmental requirements. So, the money
201 that we're doing is actually improving our
operations, consolidating it, and what it does is
221 where the fuel trucks are now?
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HI MS. KREITZER: Yeah.
12] CAPTAIN, ROBERTS: It's going to open up
(3j 23 acres that we can use for future development
w on the base.
til MS. KREITZER: That makes sense, but
(«) what about taking the din out first? That's too
(7) expensive? Is that the idea? And then taking —
l»j I'm using the same site —
(8j MS. JORDAN: That's an additional two
(loj point — two point is just to do the digging.
in) That doesn't include —
[tz] MS. KREITZER: I tfrtnlr that asphalt and
113] all that is fine, but I mean if you — then you
(HI wouldn't have to make continual monitoring and
(is) then wouldn't that be —
(iei CAPTAIN ROBERTS: Usually, what you'll
(IT] find — and you can help me again on this one,
[it] Andy — my understanding is, under the
IIBI circumstances of this particular site with what
t3o) we have — a normal approach is some type of a
tan cover, okay?
(23 And it just happens that this particular
Page 31
might have some erosion that we have to replace.
Those heavy metals aren't going to migrate
Lai anywhere. We don't have a groundwater problem.
[4| We've already done the studies and all that. We
pi know we don't have that.
(6) MS. KREITZER: So, what are you checking
(7i for?
iai CAPTAIN ROBERTS: So, what we have is
Pi some of those heavy metals in that top dirt. So,
io) the most cost-effective —
MS. KREfTZER: After five years, what
12) are you looking at, the surface?
MR. TARR: Surface.
CAPTAIN ROBERTS: Looking to make sure
i£) the concrete isn't cracking.
t«i MS. KREITZER: And the asphalt?
IT] CAPTAIN ROBERTS: And the cover around
it) it isn't eroding. So, that's not a large —
i9) MS. KREITZER: I'm not trying to —
MI CAPTAIN ROBERTS: No, they're very good
questions. Because you have been — you have
[2zj seen other circumstances where we said we've got
Pag* 30
Page 32
(i) location we're in the fuel farm where we have all
12] these fuel tanks and fuel lines and so on and so
(3] forth, is probably the ideal solution. Because
[4] using that cap, which is one of the standard
(5) procedures under the conditions we have, will
[«] also improve base operations. So, it's a
[/) win-win.
l«) MS. KREITZER: So, you wouldn't want to
to) take the dire out and then cap because of
(loj whatever reasons?
(Ml MR. TARR: It's not cost-effective and,
H3} two, with the cover you can manage the risk.
|i3) It's contained. It's not going anywhere.
(u) MS. KREITZER: Okay. But in five years,
lii] if it's any problems will that be —
lit] MR. TARR: Addressed.
tiT] MS. KREITZER: I know it will be
(i«l addressed but will the cost be —
(ioi CAPTAIN ROBERTS: If you really look at
pot it in my mind — and you can help me with this,
1211 these people who are experts — the problem we
1231 might have is where we put the soil and gravel we
MI to take a bunch din off out here.
[2] MS. KREITZER: Yes, and I just wondered
01 about if it was cost-effective to do that? No.
(4| Is that the bottom line?
[si CAPTAIN ROBERTS: But the pesticides,
l«) you really didn't have a choice.The levels of
PI contaminants that we had — if you remember, we
(»i exceeded the human health standard and the
(9) ecological standard. The pesticide shop was
ioi pretty bad and pesticides migrate.
in] So, the idea there was to get rid of the
[i2] real heavy concentration of contaminants and have
] it burned and then fill h in and cover it again.
[MI Remember? We were going to cover that one.
i So. I think under the circumstances, if
(i«t you took that anywhere else — not just here at
l Pax River — under those circumstances that we
(ill have a general approach is some kind of a cap or
(19] a cover. Is that right, Andy, normally?
(20) MR.SOCHANSKI:Yes.And,Madeleane.
(2i) one of the reasons why we only found metals I
122) believe, is even though the site was used to
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Page 33
in store drums, oily waste, paints, eventually
is) solvents and that son of thing, is — remember
O) from the history sludge was applied.
i<] It was filled, and that probably helped
is] to eliminate some of those volatile contaminants
(el that might have stayed in the soil. So, there
c/i might have been a natural bioremediation of those
(«l contaminants and that's probably one of the
Pi reasons •why at the end from now today, we arc
(io) just finding metals and they're just slightly
[t i) above the risk range that warrants some action.
[i2] CAPTAIN ROBERTS: Would the coal
113] residue, the coal ash. contribute to the metal?
(MI MR. SOCHANSKI: It very well could.
(ts| MS. KREITZER: Yeah, you've got two
(i6) kinds of ash going in there. What is the
(IT) difference between those two?
(i8) MR. TARR: Nothing.There's no
[i9l difference, just terminology.
(201 MS. KREITZER: Terminology is different?
I2t) MR. TARR: Basically the slag that is
(22) left over as a result of burning coal.That's
Page 34
) all it is.
(2j MS. KREITZER: I was curious because I
Pi didn't know what the difference was.
M CAPTAIN ROBERTS: That's a very good
(si question. Many of those that we have dealt with
(«l we've taken soil. And in these circumstances
PI it's not cost-effective or, in our opinion,
[si necessary. I just wanted to point that location
19) OUt.
[to] In that fuel farm, you're not going to
[ii] do much over there anyway.You can't put a
[12] school.You can't put a day care.You can't put
[tat those kinds of things there anyway because we're
(14) sitting in the middle of fuel tanks.
(is) MS. KREITZER: Thank you.
lie] CAPTAIN ROBERTS: Yes?
[IT] AUDIENCE MEMBER: Isn't it likely that
(iai being used for fuel storage and fuel tank trucks
(i9i and so forth, that it's going to — the asphalt
1201 or the cement is going to deteriorate more
;-2i] rapidly than it would under ordinary
221 circumstances?
[i) MS. JORDAN: Well, the concrete is going
[21 to he reinforced so we will the lessen the chance
Pi of that happening. And just because there is a
M crack in the asphalt or concrete doesn't mean
is] that we have to all of a sudden dig up all the
(6j soil. We can just come in patch what's cracked
PI and it's fairly easy to patch.
[a] And we still feel it would be more
Pi cost-effective just to monitor it. It's not
HO expensive to go out there and just take a look,
tin because we have fuel people out there anyway in
i the operation.
) We think that that's very inexpensive to
i do and as far as having to patch the asphalt, we
[is] feel it is going to be cheaper than trying to
] take it off-site and it costs a lot to take
[IT] things off-site and dispose of them.
(it) AUDIENCE MEMBER: Now, he did say it's
(19) going to free up 23 acres that they now are using
(20) for fuel areas?
[21] MS. JORDAN: That's correct.
(22] AUDIENCE MEMBER: Now. will you have to
Pago 35
ED clean up those 23 acres also?
(2) MS. JORDAN: Not under the IS. program.
[31 MR. TARR: As of right now, we don't
(4i know of any problems over there. It's just
is] basically an asphalt parking lot with the storage
(6) of fuel trucks,« cetera.
(?) AUDIENCE MEMBER: Donna, just to add to
m that, where the fuel trucks are going to be
m parking, they're actually going to be parked on
(to) the concrete and there's 8 inches of reinforced
l concrete there.There is a little bit of asphalt
i that's going to be added to the existing asphalt
|iai that's already out there.
ti4j I understand where you're coming from.
Typically, if you drop diesel fuel or some type
f of petroleum product on that, it will erode the
(IT] asphalt a lot faster than normal.
(iai Where the trucks are going to be and
[iai where they're going to be accessing this area,
[20] it's all concrete. We have two concrete access
pi) ways where the trucks will be coming in and
[22i coming out and the ready paths where the trucks
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ID will be stationed will all be concrete.
Pi AUDIENCE MEMBER: The other thing to
PI remember is we have a series of cache basins that
M will take any spills away from the contaminated
(si area. So, it won't be sitting on the concrete
(51 for a period of time.
PI MS. KREITZER: You'll have the means to
w wash it —
t* AUDIENCE MEMBER: Yes.
no) MS. KREITZER: — and the clean it up?
(it) AUDIENCE MEMBER: Right.Yes.
(»] AUDIENCE MEMBER: I'm wondering if you
(ioi can compare the effectiveness of the areas where
(MI there's concrete versus the asphalt versus the
(is] impacted soil or gravel, and are the areas
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Hi rid of the thing, that then it would seem to me
(zi that that requires a certain scries of monitors,
i including well water, and might assume that since
m you put the cement or asphalt over it that the
is) rate is not going to be increased. It may or may
IE] not be true. It depends on the earth's strata
m and a whole lot of other complicated factors.
it) MS. JORDAN: The groundwatcr, we are
PI continuing to look at. We're just working on the
[to] soil right now, but Operable Unit 2 will be the
[Hi next unit for Site 6 and 6A.That's when we get
[121 more discussion on ground —
its) AUDIENCE MEMBER: The question is — and
[MI this would scare any citizen — what was the —
[is] what are the criteria used to determine that this
lie) was one of the most serious sites in the country?
[i7| Because it seems like if it's such a serious site
liaj that you can't just asphalt over it. What is the
(is) significance of that statement?
TO MR. SOCHANSK1: The NPL listing was a
1211 listing of the base oa the National Priorities
1221 List, not this site specifically. That is —
HI AUDIENCE MEMBER: So. there's things
12] that are worse? Is what we're saying?
[3] MS. JORDAN: The pesticide shop is
(4) considered worse than this site.
[si MR. SOCHANSKI: And as far as scoring on
to the National Priorities List, they looked at
m several areas of sites within the base and used
[8] that to rank it and propose it for the NPL
(91 listing and subsequent —
[101 AUDIENCE MEMBER: So. that doesn't
[itl necessarily have anything to do with this issue.
nz] even though it's listed right on this page?
(is) MR. SOCHANSKI: No.
(i4i AUDIENCE MEMBER: Which is a little
its] disconcerting without some disclaimer. Okay.
(i«l MR. SOCHANSKI: That's provided for
[I?) historical perspective. One thing under the NPL
pa) program, we have to address all die sites that
[191 are contaminated.
ia>) CAPTAIN ROBERTS: What happens to you
is, if you have a couple of very bad sites, which
we've had. they put you on the National Priority
Pag«41
Pag» 42
Pag»43
til List. All your sites then have to go through
Bl this process where you're going to be on this
PI because the base is on the National Priority
[4j List.
(si AUDIENCE MEMBER: So, all of them have
[«l to go through — does that imply a more stringent
Pi perusal than they would otherwise because you're
(«l on that list? And that means the place or
m something like?
HO] CAPTAIN ROBERTS: Right.
] AUDIENCE MEMBER: Thank you.Just
[12] curious.
[13] AUDIENCE MEMBER: We have two cost
[14] figures given to us. one of 2.6 million and one
[is] of 2.7 million. And what I'd like to know is how
was this data derived? Specifically, is this the
t result of competitive bid estimates or are these
[ii] just staff estimates?
tie] MS. JORDAN: No, they're not the result
(so) of competitive bid estimates. It's —
l AUDIENCE MEMBER: These are staff
(22| estimates then?
HI MS. JORDAN: Right. Engineers' best
[2] guess judgment on the activities that would be
[3| involved, type of materials that would be
(4| involved, and some known cost about how much
[51 we're currently paying for certain activities,
«l like hazardous waste disposal. We have enough
m information in databases on that to get a very
m good figure to use for that, but these costs were
PI not competitively bid.
[105 AUDIENCE MEMBER: So, in other words,
{ill what would your confidence factor be in these? I
[i2i mean, do you think is it 95 percent probability
[in that these are accurate or a 60 percent
[14) probability or 30 percent probability?
us] MS. JORDAN: I'd say more than 5O
da percent, but how we look at it is there isn't one
[IT] cost that we would consider to be more credible
Ii8i than the other. So, they're both on equal
li9) playing fields, so to speak. Both costs would be
1201 considered in a ballpark of greater than 50
[21] percent estimate and it's just an estimate
[221 because until we get into actuals, you don't
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(i| realty know how much it's going to cost.
PI AUDIENCE MEMBER: In other words, you're
pi choosing a plan of action based upon a cost
(4j consideration, which is an estimate of maybe a SO
(si percent probability of accuracy?
|6| MS. JORDAN: But both of them are on
(7) that same arena.
(i) CAPTAIN ROBERTS: Well. I would add to
PI that. She gave a list of what we had on the
(toi alternatives, and cost was only one thing out of
(til a number them.There are many things that are
(i2i looked at and considered in selection of
(>3j alternatives. If you look here, cost is only
(uj one. okay?
(is) The issue we've gotten into here is the
lie] effectiveness of soil removal versus capping.
[i;) Where a cap or a cover meets — helps meet and
(in solve the ecological problems, human health, it
(i9i meets the ecological, okay?
pal And if that site was sitting somewhere
(zil else, not just where it's at now — when we do
(22) all these analyses, when you look at a lot of the
Page 47
We did our regular analysis. We were
[21 looking at some type of a cover or cap and when
!3i we were doing that and we said, well, if we do
chat, look at where it's at, we ought to
consolidate our fuel truck operations and we
[6i could use the property, instead of just capping
(7| it and not use it for anything. So, that evolved
(a) out of looking at the alternatives.
[9| AUDIENCE MEMBER: But I think
101 Madeleane's concern about removal, which would be
probably at least as effective as capping. If
the heavy metals were removed, it would be as
til effective an alternative as capping it.
However, it seems that the decision was
based upon cost factors as to whether we would
18) remove or cap. or remove and then cap to make it
i7i into a parking lot and the cost criteria seems to
iai be very nebulously arrived at and that was the
point that I was trying to raise. Does that
201 follow up on your —
MS. KREITZER: Because if you get rid of
it instead capping it, then you don't have a.
Pags 46
(i] practices that were going on out there, some type
(2j of cover would probably be the recommended
n solution, okay?
(4] In this particular case, as you've
(5] heard, they said they were looking at some type
t«l of a cover or cap.Then, we went back and said
(7i if we do that, we can consolidate fuel
(il operations.
m So, we didn't come in and say, We want
(to) to use it for a parking lot, let's put a cap on
(til it. Ic came the other way. When we looked at
(i?) the alternatives, we were looking at some kind of
(i3j a cap for it and said if we do a cap, why don't
(ui we do a real good cap with all this concrete and
[13 we can consolidate our operations on base and
[ui then it's win-win. We protect the site and we
(i7i improve the operations on the base.
iu) It did not come from — I think people
(is) are getting the idea that we said, We've got this
(Ml site and we want to use it for fuel trucks, so
tail this is what we're going to do.That is not the
pa) case. It came around the other way.
(t) problem.
(21 AUDIENCE MEMBER: And it's—so in
01 other words, really removing does not preclude
[4i using it as a parking lot later, as a fuel depot
(si or whatever. The decision not to remove seems to
i«] be a cost decision and that decision is —
(7i CAPTAIN ROBERTS: The cost difference
[«l you see here is simply to remove the soil. It is
m not asphalt. It is not concrete. It is nothing
[io] else. It is simply the cost of removing the
(Hi soil. So. any other use, you're going to have to
(121 come up with additional funding to do the
1131 concrete, the asphalt, if that's what you wanted.
This seemed to be a win-win situation to do it
i this way.
(t«3 MR. SOCHANSKI: George and Madeleane, if
(i7i you look at Alternative 3- Alternative 3 is $2.6
(is] million estimated for excavation. So, let's say
Ha) that is within the ballpark. It could be a
[20) little low, but chances sure, you know, it's
(2ij somewhere in the ballpark.
pa] If they decided to excavate, it's
Pag«48
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ji] somewhere around $2.6 million. Now, if you want
(2] a parking lot, asphalt or concrete, you're
Ol talking about somewhere in the neighborhood of
[
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HI Sitting —
(2] MR.TARR: We would still have to manage
PI it. We would still have to manage the soil no
(41 matter where it goes. If we leave it on-site or
(5) if we dig it up and send it to another landfill,
l«] which would be a permanent disposal site, but if
Pi there were ever any problems associated with that
til landfill, say gxoundwater problems —
p) MS. KHEIT2ER: You mean in Kentucky?
no) MR.TARR: Say in Kentucky.
(t ti MS. KREITZER: Well, right now my
jig problem isn't Kentucky.
[131 MR. TARR: I know. I'm just saying no
Ii4] matter where the soil resides, we're still going
lisi to have a waste to manage and —
[is] MS. KREITZER: You're not going to have
(IT] it though.The people who are running it are —
(1*1 MR. TARR: No. no. we would still have
(i»i a —•
poj MS. KREITZER: I'm not trying to give
(2ii you guys a hard time, honest.
(221 MR. TARR: I know that.
Pag«54
(1) MS. KREiTZER: These are questions thai
!2l are in my head.
01 MR. SOCHANSKI: Madeleane. we're just
(4) pulling out to a bigger scale. What we're saying
(sj is we still have a problem if we move it from one
t«l location, which is near and dear to your heart,
PI to another location, which you don't care as much
m about. But we're just trying to get you to
pj acknowledge that we still haven't made that waste
(to; go away. We just put it out of sight.
(HI MS. KREITZER: You haven't put it out of
(t2i sight. It's out of here.
in) MR. SOCHANSKI: Right, out of here.
(MI It's still existing somewhere elae.The EPA is a
(isi federal agency. It's got to look at the whole,
(ill big picture.We've just picked it up and moved
(IT] it from one area to another. But we saved money
(t»i by not hauling it to Kentucky and we're still
its) making it equally inaccessible to the people. We
po) sort of solve the problem on-site without having
pi) to go to the expense of trucking it to Kentucky.
(22j It's still a problem.
dl AUDIENCE MEMBER: If you move it to
(2i Kentucky, you're still responsible for it.
01 MR. SOCHANSKI: Right.
14) AUDIENCE MEMBER: I was wondering if
is} perhaps Captain Roberts could speak to the
!si possible redevelopment ideas for the 23 acres
m that will be freed up from that fuel storage.
(8j CAPTAIN ROBERTS: I'm sorry, I couldn't
PI hear very well. I'm a. helo pilot. You have to
to] speak up.
ii| AUDIENCE MEMBER: I was wondering if you
121 might comment on the potential for redevelopment
is) of those 23 acres that might be available now for
uj other uses if 6A and 6 are the new fuel storage
is) areas.
i8l CAPTAIN ROBERTS: If you look at where
1 n we've got that 25-acre area, it's right over by
;«) Cedar Point Road. It's over there across from
[is} Test Article Prep where the V-22 is, right along
201 Cedar Point Road.That's prime, prime area for
development, okay?
(22j We haven't said — have any ideas of
Page 55
PagaSS
dl exactly what might be there. Future programs
(2) might need support there. It's a prime location.
(3) So, that's 23 acres if there was ever a future
(4) need here for any increases for new programs or
(5) anything, that property would be a prime location
l«l to able to accommodate a new program or a new
[7i requirement here and I think that's important.
M Also, the long-term future of the base
Pi is to have areas like that that you're able to
Pol provide some development to maintain the
(in viability of the base in the future. If you get
[12] yourself to a point where you can't have good
(is) development — and we've had a lot here in some
|i4] prime sites — and have additional areas like
list that available for development, it really makes
us] us viable for the future and the long-term
[IT] strategic viability of the base is important and
[it] this also helps us in that situation.
[191 AUDIENCE MEMBER: Are the comments that
[2ot might be made here recorded and meant to be
(2ii heavily weighted more than or the same as
(22) comments here?
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HI MS. JORDAN: The same. We have a
M2i reporter here that is recording comments and
'pi questions that come up and those comments and
(4) questions, along with what the response is, has
(si to be documented in a Record of Decision.
!6i AUDIENCE MEMBER: Because I won't
[7] belabor this point here, but I'll make more
is] comments on the notes there, but I notice in
\9i reading this paragraph somewhat carefully it
(ioi says, not necessarily emphasizing that there was
[11] groundwater well measurements, but it says here
[i2] calculated. It was calculated based on —
[131 MS. JORDAN: What paragraph arc you
(u) talking about?
Its] AUDIENCE MEMBER: I'm looking at page 5
tie] on where apparently the answer to one of my
(IT] questions was that one well didn't come in, but
[181 the way this is worded, it's talking about not
(19) even measurement. It's talking about
[2o| calculations.
(2i] MS. JORDAN: Right.
[22] AUDIENCE MEMBER: And then it's saying
Pag* 58
til that these soil screening levels that were
(21 calculated indicated the current concentration
(3j for these chemicals in the soils are not likely
[4i to be present.That seems like hedging on top of
is] hedging. So. I would hope that in the future —
(ei and I don't know that I hear this and this is the
[7] comment I would make — that in the future there
(•1 would still be groundwater well checking of the
[9] things because this is pretty nebulous. As I
[to] read more carefully what you may be trying to
ruj tell me. I just I hope that's in the plans.
[i2j MS. JORDAN: Yes.
to) AUDIENCE MEMBER: That's in the current
(i4) contracts?
(is) MS. JORDAN: That's Operable Unit 2.
[is] That will be the next area of Site 6 and 6A that
(IT) we will be addressing, the groundwater, which we
(is) will be calling Operable Unit 2. Andy, did you
us] want to address his question about the Soil
(201 Screening Level calculation?
MR. SOCHANSK1: Yeah.The Soil
Screening Level calculations that are done is, we
Page 59
11] use that as a basis to look for the transfer of
pi contamination from soil into the groundwater.
[31 And that's based upon soil type and various other
W parameters.
(si And then that's compared to actual soil
[8] concentrations, what's the contaminant in there.
m And what we actually found out is that we didn't
[a] have a problem using that information in
(9) calculating impact to groundwater. We didn't see
io] any impact to groundwater and then that's further
11] confirmed by the groundwater data at the site.
121 AUDIENCE MEMBER: Weil, it's talking to
13} unacceptable levels and I guess I'd have to spend
u) more time looking at what you're saying.
isi MR. SOCHANSKI: The SSLs calculate —
t6) AUDIENCE MEMBER: Based on seeing
IT] something that was unacceptable — from reading
t«l this, right — and then there were calculations,
I guess, to project to, I guess, some other area
120) where the groundwater might be impacted. But the
(211 chemicals are iron, lead, and something I can't
221 pronounce.
Page 60
in MR. SOCHANSKI: TCE.
(2} AUDIENCE MEMBER: TCE.Thank you.TCE
M sounds bad. How bad is that? I know what the
W others are. But anyway, I'll just make a note
(S) not to belabor it here because I'm not totally
[6) satisfied.
en MR. SOCHANSKI: Okay.
N AUDIENCE MEMBER: And you can follow up
Pi on it.
no) MR. SOCHANSKI: If I might try to answer
Hi] it.
AUDIENCE MEMBER: I just tried to read
) the paragraph here, being the first time I was
] exposed to this.
its) MR. SOCHANSKI: What they actually did
(is] was look at the contamination in the soil
[17] transferred to groundwater and came up with some
(it) numbers.
[ifil AUDIENCE MEMBER: So. it's real up to
120) this point?
I2U MR. SOCHANSKI: Correct. Then they
[22] compared that with the groundwater data
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Page 61
in downgradient of the site.
pj AUDIENCE MEMBER: Okay. But that was
PI projected based on calculation at that point'
Hi MR. SOCHANSKI: Correct.
is; AUDIENCE MEMBER: That's what I'm trying
18) to understand. Keep going.
pj MR. SOCHANSKI: Based on the soils and
[•I the soil concentrations —
PI AUDIENCE MEMBER: They did not —
lioj MR. SOCHANSKI: So. what they end up
in] doing is comparing that information and seeing
(isi what the model actually predicts. If iron's
(mi going to be in groundwater or lead or arsenic
(i4j or —-
(«s) AUDIENCE MEMBER: I think that's how I
(i«l understood it, but we're both getting our minds
(IT) together here, wouldn't you feel comfortable if
(it) rather than basing it on calculated projection
(IB) that you at least, I hope, periodically are going
(»! to test with something real?
[2t] MR. SOCHANSKI: Yes.And then what they
[22] did was compare that data to the groundwater data
Page 62
01 downgrade, okay? Chemicals detected downgrading
Pi in groundwater. So, we actually did compare
PI current groundwater data to those calculated
W levels.
HI AUDIENCE MEMBER: I see it the opposite
Pi way, that it started with the groundwatcr basis
01 and then was calculated — projected, based on
(i] the calculations. I see it the opposite way.
pi But I won't belabor it.
lien AUDIENCE MEMBER: But those calculations
(it) are based on the assumption that rainwater
(12} continues to percolate through the soil and move
(lai those contaminanu-That's without any
(MI treatment.
(isi AUDIENCE MEMBER: I agree with that. It
nsi seems obvious that you're better off having put
[IT] the cement over it, since the problem follows you
[it] for eternity. If you did it tight, of course,
[to) you could probably have it incinerated, but
[Toj that's too costly. I understand the whole
pt| situation, I think.
(zai AUDIENCE MEMBER: Those contaminants
[11 tend to be rather immobile.They bind well to
PI the soil and it depends on the type of soil.
13] Those soils there, due to the pH, physical and
W chemical composition of soils, hold those things
[sj very well.
[6] But one thing that could tend to cause
m those things to move is lots of water flushing
[81 through the system. You take that away and it's
19] very unlikely to move from the site.That's why
(ioi capping is such a good remedy.
It t] The reason the sludge was applied — for
(i2i another reason, was it raised the pH of the soil
[i3] and further buffered the chemicals into the soil
[14] to bind up with metal, further locking them
(is] on-site.They're going to lock up even better
(is) now when they're used as a storage site.
[IT] Take the water away, and they're almost
[is] completely immobile. Of course, you monitor this
us] to make sure, but they're locked up on-site and
[20] they're not going to go anywhere.The risk
(ji) calculations are based on the site being left as
[22] iS.
Page 63
It] AUDIENCE MEMBER: Not to belabor, all I
(2) would say in summary is I hope there will be
pi future well groundwater monitors. You know,
W those five year things didn't seem to include
[si that.
m US. JORDAN: Right. We're just
[7) addressing soil here. As I mentioned earlier, we
m do address die groundwater. That's the thing
[91 we're talking about when we're talking about
iQl monitoring what the latest data has shown. So,
(11) we're not forgetting about the groundwater
[i2| totally. We just want to move ahead with die
t soil right now, but we are going to be addressing
t the groundwater.
(is) AUDIENCE MEMBER: I was just wondering.
[i«] it seems with this alternative there's so much
(IT] impervious material being laid down on die site.
IIBJ Is there anything being planned, I guess, from
list the green factor to kind of mitigate and soften
(20) that impact to the vegetation and trees or if
izii there is, an impact.
[2Z| AUDIENCE MEMBER: There are no trees on
Page 64
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August 10, 1999
Pag* as
Hi the site now.
12] AUDIENCE MEMBER: Well, the trees that
Pl border the site that may be effected by this
i«i diversion of natural ground —
is, AUDIENCE MEMBER: Trees aren't impacted.
[6] It's all grass. When we put the asphalt down,
m we'll grass — leave some grass and a few trees
(si removed, but very, very few.
[9] AUDIENCE MEMBER: Well, I guess I
[to] misinterpreted. Tc looked like that 6A was going
[Hi to be completely asphalted and right now it's not
[i2] completely impervious, is mat right?
Ii3i AUDIENCE MEMBER: Well, it's gravel.
(u| It's not a natural surface anyway, but it's not
[is] impervious. It's gravel.
list AUDIENCE MEMBER: Okay.
[in MS. JORDAN: Are there any additional
na] questions or comments?
[i9) AUDIENCE MEMBER: Well, I guess the only
[20] thing that she's getting at I think is that when
pi] this actually went — as somebody over here
[22] described it — to the final containment area, we
lost sight of it.
[zi The implications were that when it hits
(3| this final containment area, it's no longer of
[«l any concern at all, but if that track — the Navy
is) has to track that forever, what happens to the
is) stuff that goes in the containment area after
m it's there? Where does it go after the
is) containment?
pi MS. JORDAN: You mean if we take it
riot off-site somewhere?
n1| AUDIENCE MEMBER: Well, it doesn't
(121 disappear. I assume it just sits there forever
mi in this containment. She's asking does it get
(M] impacted into the soil or anything? Does it go
list to the containment?
HOI AUDIENCE MEMBER: I think what he's
[i n talking about. Donna, is if there were —
[it] AUDIENCE MEMBER: Just runoff, all
[191 runoff.
po} MS. JORDAN: Right. It will be
. (211 contained.There's a valve there and the fuel
operation people, they have to check that before
Page 66
m
M
tioi
[i ti
tig
ii3i
iui
(is)
121)
they can release that.
AUDIENCE MEMBER: What happens to — the
question is. what happens to what ends up in the
containment area, whatever that fuel or —
AUDIENCE MEMBER: If the station —
AUDIENCE MEMBER: Is that taken
somewhere? Is it burned or is it —
MR. TARR: No, if it's just plain
rainwater, what they'll do is look inside the
containment structure, and if they don't see any
fuel laying on top, they'll manually open the
valve and everything will drain out of the
containment structure, which —
AUDIENCE MEMBER: To the soil, which is
her concern.
MR. TARR: Into a —
AUDIENCE MEMBER: Into the soil.
MR. TARR: — adjacent to the site, and
be allowed to percolate back into the ground,
away from the area of concern.
AUDIENCE MEMBER: But that's —
MR. TARR: But if there's fuel in the
[il containment structure, then that is manually
B) cleaned up by Navy personnel before anything is
PI released.
W AUDIENCE MEMBER: And properly —
[si MR. TARR: Disposed of.
m AUDIENCE MEMBER: That was the basic
fT] concern.
m CAPTAIN ROBERTS: Wherever we have fuel
[el operations, we have to take steps to make sure
[ioi that when we have a fuel spill of any kind, that
mi we don't import into sewers, into the ground, ct
(121 cetera.
i If you look at where we have our fuel
(i4j trucks, it's like a big pad with walls around it
[is] and then there are cache containment areas. Any
(i*l spill will go into that and catch it. It's all
[i7i concrete too.
[iai That fuel is then taken out of there —
[i9] taken and burned. It can't be used in the
[201 aircraft or anything else, anywhere.There's a
[211 lot of rules and regulations around fuel tanks
(2zi and all those areas. We don't — we don't have
Page 67
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[i| spills into the ground out of—
M AUDIENCE MEMBER: So, it's probably
P) never just flushed even if, as he's saying, it
M didn't seem to be have any visual fuel floating
(5| on top or — you would probably still not just
(s) flush it.
Pi CAPTAIN ROBERTS.- Oh, no. I mean —
Hi AUDIENCE MEMBER: He was saving you
tsi would flush it.
[ioi AUDIENCE MEMBER: Into a containment
(ti) area?
(12) AUDIENCE MEMBER: That's what I heard
[is] him say.
!t4| MR. TARR: They'll Hush it, open the
(is) valve and it will drain out, as long as it's
(is) visually inspected for no fuel.
(in CAPTAIN ROBERTS: It's all checked,
da) sampled. You can't —
09] AUDIENCE MEMBER: So, you'd sample it?
POJ CAPTAIN ROBERTS: There has to be some
(211 regulators. You can't do things like that
(22) AUDIENCE MEMBER: I understand what I
Hi
Pi
PI
M
(si
E«l
t«l
(iij
tu|
us]
iisj
tin
(i8j
liej
(MI
izii
32]
hope you're saying.
CAPTAIN ROBERTS: If you look at the way
we manage our fuel, the safety systems we have,
and go over and look at the platform where those
trucks arc right now, you'll see they're all
barricaded, sealed, and any spill goes into a
containment area and it's captured.
The fuel has to be burned. It cannot be
used for anything else. When you have rainwater,
you can't just open the valve. You've got to
view it, make sure all you have is rainwater.
And I think the MPB guys will tell you, you just
can't run around dumping fuel into the ground.
AUDIENCE MEMBER: Can I bring up one
point to make sure there's no misunderstanding?
The concrete pad that we're going to install is a
staging area.There is no fuel transfer. It's a
parking area for fuel trucks. So, the chances of
spillage are minimal.The trucks are going to be
parked there and then when they're needed, they
still handle any potential spills, but there
isn't a constant fuel transfer occurring on this
Paga 69
Page 70
[i] pad.
12) AUDIENCE MEMBER: When you have a
01 concrete cap or asphalt cap on top of this field,
[4| in designing the cap has any consideration been
(si given to extending the edge of the cap below
is] ground as a possibility of keeping the soil in
[7| tact under the cap to prevent migration of water?
IB] So, 1 mean, if the cap is just flat on top of it.
m it's one thing. If it's flat like that and it
[io] goes down 2 feet, you would in a sense have a
[111 container for the soil that's contaminated.
[12] AUDIENCE MEMBER: I don't follow the
;i31 question.
;uj CAPTAIN ROBERTS: He's saying if it's
is] flat is it going down in the —
is) AUDIENCE MEMBER: Every drop of water -
'7] the way we have the cap designed, the concrete
t«l pad itself, the water that hits the concrete pad
drains to these concrete stumps. So, we don't
(20) get any run-on coming from the soil on to the
[211 concrete or we don't have any runoff going to the
(221 concrete on to the soil. Everything drains into
Page 71
(i) the containment area.
PI AUDIENCE MEMBER: Okay, that answers my
(3) question. You have a different thought process.
M MS. JORDAN: Any additional comments?
is) Questions? Okay. We still have about, I guess,
t«l a little over two weeks in the public comment
period. So. if something else strikes you before
m the comment period is over — good, bad or
Pi indifferent — we would really like to hear your
01 comments. If you could fill it out and mail it
i] to the base so we can look at that, we would
21 appreciate it. Okay.Thank you.
si CAPTAIN ROBERTS: Is there is any other
4| comments for this part of the public hearing
si before we start the RAB on some of the other
8) sites? I really appreciate the questions and
?! comments. I do. I think it's important that we
«l get those and there's a thorough understanding of
«1 what it is we're doing and why we're doing it.
MS. KREITZER: It's not criticism.
i] CAPTAIN ROBERT: No, no. 1 don't
22] consider it as criticism. I think they're very,
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ID: 30 1
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August 10, 1999
0 very, very good questions. I think those are the
(2i kinds of things that we ought to be addressing
01 and make sure that it's clear — when we get to
•4) this point in a project and you have a selected
;sj alternative, I think it needs to be very clear
;si why we have selected that alternative and what
. (7j that alternative does to protect the environment
(a) and what it does to protect the people, right?
Pi MS. KHEITZER: I think so.
(io) CAPTAIN ROBERTS: That's exactly the way
(HI we've always done business. So, I think these
(i2i are very, very good qucstions.And brought out
(is) some various things that might have caused some
IK) confusion by the slides even. You brought things
(is) up and 1 started asking people some questions
(t$i too. So, it's very, very good and I appreciate
(IT) your comments.
pal If you want to put some something in and
[i9) turn those in, too, that's great. All your
[so) comments are on there. I do view this as one of
en those few chances when you're working with these
izzi kinds of sites where you have an opportunity to
Pag* 73
Pag« 74
[i] make it a win-win.
ra In many cases, you know, just like our
(3) cap down there, that landfill was so bad, we
HI capped it. We're burning the fuel off. It's
(si going to be there forever. We're going to have
[si to monitor it forever and we'll never be able to
Pi use it for anything.
lai This is one of those few occasions where
(9i we're going to meet the environmental
[toi requirements and it's going to improve the
(MI efficiency of the base where we can reuse it for
[i2i something else, which was an afterthought when'we
(is) looked at what the future of that site might be.
(MI So, it's one of those win-wins mat we
(isi very seldom get in this business, the way I view
(is) it. okay. Any other questions? Okay. What we
(IT] will do now is we'll switch from die public
li8i meeting into the Restoration Advisory Board.
[isi (Whereupon, the public meeting was
120) concluded.)
IPZI
CERTIFICATE OF REPORTER
I. Mary Clare Ochsner-Hammond, do hereby certify that
the foregoing proceedngs were recorded by me via stenotype and
reduced to typewriting under my supervision: that I am neither
counsellor, related to. nor employed CyanyoMhs partial to
the action In which these proceedings were transcribed; that I am
not a relate or employee o« any attorney or counsel employed by
the parties hereto, nor llnancially or otherwise Interested in
the outcome m the action.
MARY CLARE OCHSNER-HAMMONO
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-J'-.i J 5 s (d 1 HKOM : HNV1 KUNMtNiAi
BOjfi.N£YARD OPERABLE UNIT 1 - SOIL
PAut b-- i O
August 10, 1999
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amount 16:13; 17:12
analyses 45:22
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application 12:4.11.12
applied 33:3; 63:11
appreciate 72:12,16;
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belabor 57:7; 60:5; 62.9;
64:1
below 40:4.71:5
best 5:5; 38:20; 44:1
better 15:22; 62:16;
63:15
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26:20
bid 43:17,20; 44:9
big 22:18; 54:16; 68:14
bigger 54:4
bill 22:2
bind 63:1,14
biological 13:21
bioremediation 33:7
bit 7:2; 8:2; 9:15; 11:14;
36:11;38:19
Board 3:8,9, 21; 5:17;
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Bonne 11:7
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10:15,21,11:2,5,8
border 65:3
both 13:5; 14:10; 44:18.
19; 45:6; 61:16
bottom 11:17; 32:4
breaking 20:21
brief 6:7
bring 20:15,16; 50:21;
70:14
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brought 73:12,14
buffered 63:13
build 52:13
buildings 11:9
bunch 32:1
bunniea 24:12
buried 12:6
burned 32:13; 67:7,
68:19:70:8
burn ing 33:22; 74:4
business 5:21; 6:1.
73:11:74:15
cache 37:3.68:15
calculate 59:15:57:12,
12; 58:2; 61:18,62:3.7
calculating 59:9
calculation 58:20; 61:3;
57:20; 58:22; 59:18; 62:8,
10;63:21
call 2:8; 16.3,10:58:18
came 10:16,11:8; 12:20;
38 1.11:46:11.22:60:17
can 6:3, 5; 10:19.12.16:
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3.4,5.7.8, 17; 74:3
capacity 38:2
capped 74:4
capping 45:16:47.6. II,
13.22:63.10
CAPTAIN 1A. 6:10.16;
23 17; 24:1.6.20; 25:2.7,
16;27:10,17.21; 29:2, 16;
30:19:31:8,14,17.20;
32:5; 33.12; 34:4,16;
42:20:43:10; 45:8:48:7;
55.5,8.16; 68:8; 69:7.17,
20; 70:2; 71:14; 72:13,21;
73:10
captured 70:7
care 15.9:27:9; 34:12;
54:7
carefully 57:9:58:10
case 28:9; 46:4.22; 52:5:
74:2
catch 68:16
causa 63:6; 73:13
causing 13:9
ceased 12:1
Cedar 55.18.20
cement 34:20; 40:22;
41:4:62:17
CERCLA 10:7
certain 41:2; 44:5
cetera 3:5; 5:3; 36:6;
68:12
Chance 7:17.21; 35:2;
48:20:70:18:7321
change 14:5
Charge 12:17
chase 21:16
cheap 40:21
cheaper 15:20:35:15
check 19:18:23:2:66:22:
69:l7;2t:20;31:6:58:8;
39:15
chemical 63:4; 58:3;
59:21:62:1:63:13
Chesapeake 4:16.22
choice 32:6
choosing 453
Chris 38:17; 50:20
chromium 13; 11
circumstances 29:19;
31:22:32:15, 17; 34:6. 22
citizen 41:14
Clean 2:ll;4 7,36.1;
37:1O; 52:5; 68.2
For The Record, Inc. -- (301)870-8025
Min-U-Script«
(1) $2.6 million - clear
08/31/99 TUB 18:12 [TX/RX NO 7741)
-------
Aur,--jl-99 15:31 FROM 7 ENVIRONMENTAL
August 10, 1999
10:3013423030 PACE
BOHNEYARD OPERABLE UNIT 1 - SOU.
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compare 37:13; 61:22;
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competitive 43:17, 20
competitively 44:9
complete 9:20; 14:9
completely 63:18; 65:11.
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composition 65:4
compound 12:13
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concentration 32:12;
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constant 70:22
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detected 13:10; 62:1
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clear - find (2)
Min-U-Scrtpc® For The Record, Ir.c. - (3015870-8025
88/31/99 TfE 16:12 [T.X/RX NO 77411
-------
AUC-31-33 IS: O2 r-b.uM : ENV I RONHENTAL.
BOHNEYARD OPERABLE UNIT 1 - SOIL
ID: 3U13423030
PAGE 7/
August 10,
fine 29 13
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For The Record, Inc. - (301)870-8025
Min-X7-Script»
(3) fine-lot
08/31/99 TL'E 16:12 [TX/RX NO 77411
-------
•3.1
August 10, 1999
t 233 30
BOHLNEYARD OPERABLE UNIT 1 - SOIL
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51:15.22; 54:4.10.11.12,
13; 59:7:67:12; 68:18;
69:1.15:72:10; 73:12
outfit 22:1
outlines 10:8
over 8:2; 12:14; 13:18;
15:16; 19:17; 23:10,13;
33:22; 34:tl;36:4;41:4.
18:55:17.18; 62:17;
65:21;70:4;72:6.8
overall 16:8
ovenrlew4:ll
own 52:10
pad 68:14; 70:16; 71:1.
18.18
page 42:12; 57:15
paints 11:21; 33:1
paragraph 57:9,13;
60.13
parameters 59:4
park 21:4; 36:9; 70:20;
22:8.15; 26:5.6.11,13;
36:5.9; 38:2; 46:10; 47.17.
48:4:49:2.5.8:70:18
part 2:6,13.22.14:4;
50:17;72:14
partially 12:6
particular 8:10,9 13.
29:19.22:46:4
partnering 4:21
partnership 3:11; 5:4.9.
14,18
Tatcb 35:6,7.14
paths 36:22
Paul 18:13
Pajti5;4:- 21.7.1-1;
8:13; 11.3. 5: i~
paying 22:6,7. 14:>
people 4:3. l6;5 12.64;
21:5; 23.9:30:21.35.11:
, 40:10.46:18; 53-17;
j 54:19,66:22; 73 8,15
i percent 44:12,13. U. Ifa.
21:45:5
j percolate 67.12; 67 19
performance 37. is
perhaps 55-5
period 17 21.18 17;
• 37:6; 38:8; 72 7.8
periodically 61:19
permanent 19:15.53:6
personnel 68:2
perspective 42:17
perusal 43:7
pesticide 18:9; 24:18;
32* 42:3:52:2; 28:2:
32:5.10
petroleum 36:16
pH ;3:3
phase 8:18
photographs 13.1
physical 63:3
pick 22:1; 54:16
picture 10:13:18:3;
54:16
piece 13:17
pilot 55:9
place 7:5,15,9:22; 15:5:
24:14.17; 43:8;51:12,22;
52:7
plain 67:8"
plan 7:1,19;8:2,5.15;
9:10.11.12; 11:1; 16:4;
17:9; 19:10; 45:3; 37 16;
64:18; 14:2; 18:1.19:
10:17; 58: H
plant 11:17; 12.5
platform 70:4
playing 44:19
please 18:12; 19-8:4:4.9.
20;S:15:62
pleasure 7:11
point 22:6; 29:10. 10; .
34.8:47.19:50:22, 51.IS;
55.18.20; 56 12:57 7;
60:20; 61:3,70:15. 7V4;
51:15
pointer 12:M '
policy 8:17
portion 3:11; 13:15
position 6:19:7:15
possibility 71:6
possible 55 6
sciential 55:12, 7O 21
5'actlces 46:1
preclude 48.3
predicts 61 12
tots - predicts (4)
Min-U-Script®
For The Record, Inc. - (3011870-8025
08/31/99 TUE 18:12 [TX/RX NO 77-11 |
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AUG-31-33 lb;O
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31-99 13:04 FROM;ENVIRONMENTAL
August 10, 1999
BOHNEYARD OPERABLE UNIT 1 - SOIL
staff 43 is, 21
Stage 8:18; 3:14
staging 70:17
stand 18:11
standard 30:4; 32:8,9-
*7 19; 40:5
start 7:1; IMJ. U.6;
18:13.72.15; 11:19;
1221; 18.8, 17; 62:6;
73.15
State 16:20,22
statement 41:19
station 11:18; 22:2; 67:5;
37-1
stay 49:12,12:33:6:9:22
step 8.21; 5:2:68:9
still 18:9; 35:8; 49:10, 15;
51.4,19; 52:9,11,14,17,
22:53:2,3.14.18:54:5,9,
14. 18,22; 55:2; 58:8;
69:5; 70:21; 72:5
storage 11:7,13:12:9,
13,16,18; 13:3; 34:18;
36:5; 49.5; 55.7.14.63:16
store 24:2; 33:1; 24:7
strata 41:6
strategic 56:17
strikes 72:7
stringent 43:6
structure 6?. 10,13; 68:1
Studies 14:20:25-10;
31:4
study 9:7; 14:10
stuff 7:8:27:14.16;52:1;
66:6
stumps 71:19
subsequent 42:9
sudden 35:5
Summary 13:5; 64:2
Superfund 10:7
support 17:1; 56:2
Suppose 49:7
sure 2:14.18:9:22:15:6;
16:7; 27:2; 31.14; 63:19;
68:9:70:11.15:73:3
surface 31:12,13; 37:16;
38:17:65:14
surrounding 39:18,20
switch 74:17
system 63:8; 70:3
table * 19
•act 71:7
tailored 14:15
talk 3:15; 7.9; 20:17;
27:12: 49:3; 52:18; 57:14.
18,19; 59:12; 64:9.9;
66:17; 8:8
tank 12:6; 34:18; 23:21;
2
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Appendix C
Table of ARARs
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Table C-1
Action-Specific ARARs
r Focused Feasibility Study of Sites 6 and 6A- Patuxent River Naval Air Station
Action
Clean Air Ad (CAA) 40 USC 3
NAAQS
NESHAPs
Requirement
Prerequisite
Citation
ARAR
r401*t*eq.* ~~
Establishes national ambient air quality standards tor IS
cnleria pollutants (carbon monoxide, lead, nitrogen oxides,
sulfur dioxide, and airborne particulates).
Establishes standards tor emissions of hazardous air
pollutants.
stationary sources.
Emissions of criteria
pollutants
Emissions oi hazardous
air pollutants.
stationary sources that may
cause or contribute to
air pollution that may
endanger human health or
the environment
40 CFR Part 50
40 CFR Part 61
40 CFR Part 60
Applicable
Not an ARAR
Not an ARAR
Paniculate emissions during remedial actions
must be controlled in compliance with these
regulations.
Hazardous air pollutants will not be discharged as
the result ol remedial activities at Sites 6 and 6A.
Remedial activities at Sites 6 and 6A will not result
in significant air emissions from a stationary
source.
tCRA IdenUlcaUon and Ustfng ol Huantou* Waste*
Seneral PrtUwrtmtntRsguIi
Discharge to
POTW
Establishes standards to determine whether or not a
waste is hazardous as listed in 40 CFR 261 or is
hazardous based on characteristics.
Hazardous or unidentified
waste material.
40 CFR Part 261
Not an ARAR
Based on TCLP results for Site 6, none of the
soils are expected to be characteristic
hazardous waste.
Horn lor Existing and Nw» Source* of PoUuUnl*
Prelreatment standards. Control the introduction ol
pollutants into POTWs so as to: prevent inter-
ference with the operation of a POTW; prevent
pass through of pollutants through a treatment
works; and improve opportunities to recycle
and reclaim municipal and industrial wastewater
and sludges.
Discharge to POTW.
40 CFH Part 403
Applicable
Discharges of water from Sites 6 and 6A
during construction of the remedy or from
decontamination of equipment to a POTW
must comply with these regulations.
klaryUtnd Wator Pollution Control tefluMfcMW
Discharge to
water* of the Slate
Designates use of waters of the Slate and establishes
water quality criteria to protect that use.
Discharge to waters of the
Slate.
COMAR 26.08.02
Applicable
Discharges ol water trom Sites 6 and 6A
during construction of the remedy or from
decontamination of equipment must comply
with these regulations.
taryUnd Pratnatmeflt Regulation*
Pretreatment
requirements
Require* industrial discharges into publidy owned
treatment works (POTWs) to comply with pratreatmenl
requirements.
Discharges of wastewater
to a POTW.
COMAR
26.08.06
Applicable
Discharges of wastewater from Sites 6 and 6A
during construction of the remedy or from
decontamination of equipment must comply
with these regulations.
Page 1 of 2
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Table C-1
Action-Specific ARARs
Focused Feasibility Study of Sites 6 and 6A - Patuxent River Naval Air Station
Action
Requirement
Prerequisite
Citation
ARAB
Determination
Comment*
Maryland Nonpolnt Source Pollution Control Uw$
Erosion and sediment
control requirements
Regulates erosion and sediment control during
construction activities end atormwaler runoff.
Construction activities
resulting in erosion and
sedimentation.
Annotated Code of
Maryland, Environment
Article. Tilts 4, Subtitle 2;
COMAR 26.17.01
Applicable
Any remedial actions at Sites 6 and 6A that involve
land disturbance must be conducted in compliance
with these laws.
Maryland StormwiUr Management Rtgutotlon*
Slormwater
Management
Criteria
Requirements to maintain runoff characteristics at pre-
devetopment levels. AX land-disturbing activities must be
in compliance with local stormwater management
programs.
Land disturbance activities
on sites greater than 5,000
square feet in size.
Annotated Code of
Maryland, Environment
Article, Title 4. Subtitle 2:
COMAR 26.17.02
Applicable
Hunolf generated from Sites 6 and 6A during
remedial activities must comply with these
regulations.
n the table below each general heading,
ARAR - Applicable or relevant and appropriate requirement.
CAA - Clean Air Act.
CERCLA • Comprehensive Environmental Response, Compensation, and
Liability Act.
CFR - Code for Federal Regulations.
>JAAQS - National Ambient Air Quality Standards (primary and secondary).
NESHAP - National emission standards for hazardous air pollutants.
OSHA - Occupational Safety and Health Administration
H3TW - Publicly owned treatment works.
RCRA - Resource Conservation and Recovery Act.
SIP - Stale Implementation Plan
rCLP - Toxicity Charactensiic Leaching Procedure
VI |MU3IIUUI i
• QfJOVIIK* JWUPTKHU /VWi
Page£tf2
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