PB94-964532
EPA/ROD/R09-94/119
November 1994
EPA Superfund
Record of Decision:
Fort Ord Landfills,
Operable Unit 2, CA,
8/23/1994
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Record of Decision
Operable Unit 2, Fort Ord Landfills
Fort Ord, California
July 15, 1994
United States Department of the Army
HQ, U.S. Army Garrison (Fort Ord)
Fort Ord, California 93941
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N32348-H
July 15, 1994
Record of Decision
Operable Unit 2, Fort Ord Landfills
Fort Ord, California
This document was prepared by Harding Lawson Associates (HLA Project No. 23366
04871) at the direction of the U.S. Army Corps of Engineers (CaE) for the sole use of
the CaE and the signatories of the Federal Facilities Agreement, including the Army,
the U.S. Environmental Protection Agency, the California Environmental Protection
Agency, including the Department of Toxic Substances Control (formerly, the Toxic
Substances Control Program of the Department of Health Services), and the Regional
Water Quality Control Board, Central Coast Region, the only intended beneficiaries of
this work. No other party should rely on the information contained herein without
prior written consent of the CaE and Army. This report and the interpretation,.
conclusions, and recommendations contained within are based, in part, on
information presented in other documents that are cited in the text and listed in the
references. Therefore, this document is subject to the limitations and qualifications
presented in the referenced documents.
United States Department of the Army
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N32348-H
July 15. 1994
1.0
2.0
2.10
2.11
2.12
2.13
CONTENTS
DECLARATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1
1.1
1.2
1.3
1.4
1.5
Site Name and Location. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Basis and Purpose. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Site Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Description of the Remedy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Statutory Determination. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1
1
1
1
2
DECISION SUMMARY
. .. ..... ...... . ........... """" .... '" .. . . . . ...
3
2.1
2.2
2.3
2.4
2.5
2.6,
2.7
2.8
2.9
Site Description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Site History. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Enforcement and Regulatory History. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Highlights of Community Pal1icipation ...........................,.... 4
Site Characteristics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 .
Scope and Role of Operable Unit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Summary of Site Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Remedial Action Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Description of Alternatives. . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.9.1 Alternative 1 - No Action. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.9.2 Alternative 2 - Containment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.9.3 Alternative 3 - Upper Aquifer Cleanup and Landfill Covering ..........7
2.9.4 Alternative 4 - Upper Aquifer Cleanup and Landfill Covering - Interim
Groundwater Extraction on 180-Foot Aquifer. . . . . . . . . . . . . . . . . . . . . . 8
2.9.5 Alternative 5 - Upper Aquifer Cleanup and Removal, Treatment. and
Disposal of Landfill Waste - Interim Groundwater Extraction on
180-Foot Aquifer. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Summary of Alternative Comparison. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
The Selected Remedy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
2.11.1 Selected Remedy: Soil Action """""""""""""""" 9
2.11.2 Selected Remedy: Groundwater Actions. . . . . . . . . . . .. . . . . ... . . . . . . 9.
Statutory Determinations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 10
2.12.1 Protection of Human Health and the Environment. . . . . . . . . . . . . . . . .. 10
2.12.2 Compliance with ARARs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 10
2.12.3 Cost Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 11.
2.12.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies. . . . . . . . . . . . . . . . .. 11
2.12.5 Preference for Treatment as a Principal Element. . . . . . . . . . . . . . . . . .. 11
Documentation of Significant Changes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 11
RESPONSIVENESS SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
13
3.0
3.1
3.2
3.3
Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
Background on Community Involvement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
Summary of Comments Received During the Public Comment Period and
Department of the Army Responses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
3.3.1 Remedial Alternative Preferences. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13
3.3.2 Technical Questions/Concerns Regarding Remedial Alternatives. . . . . .. 14
3.3.3 CostslFunding Issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 16
United States Department of the Army
iii
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. ..'., -. '-u,. ~._.~- -'''' . .....0. .
-... .-... --. _"k'_~.__-.._-,
'" .. _no. .... '-"'-- .
3.4
3.3.4 Enforcement.............................................. 16
Remaining Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 17
4.0
REFERENCES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 18
TABLES
1
2
Chemicals of Concern, Remediation Goals. and Discharge Limits
Evaluation of Alternatives
PLATES
1
2
3
4
Site Map .
Conceptual Groundwater Extraction and Treatment System for the Selected Remedy
Conceptual Landfill Cover System Design
Approximate Extent of Contaminated Groundwater Plume
APPENDIXES
A
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR THE SELECTED
ALTERNATIVE
A1.0
AZ.O
A3.0
A4.0
A5.0
GROUNDWATER CHEMICAL-SPECIFIC ARARS
SOIL CHEMICAL-SPECIFIC ARARs
LOCATION-SPECIFIC ARARS
ACTION-SPECIFIC ARARS
SUMMARY OF ARARS FOR MANAGEMENT OF TREATED GROUNDWATER
B
COMMUNITY RELATIONS ACTIVITIES
N32348-H
July 15, 1994
United States Department of the Army
iv
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1.0 DECLARATION
1.1
Site Name and Location
Fort Ord is located near Monterey Bay in
northwestern Monterey County, California,
approximately 80 miles south of San Francisco.
The base comprises approximately 28,000 acres
adjacent to the cities of Seaside, Sand City,
Monterey, and Del Rey Oaks to the south and
Marina to the north. The Southern Pacific
Railroad and Highway 1 pass through the
western portion of Fort Ord, separating the beach
front from the rest of the base. Laguna Seca
Recreation Area and Toro Regional Park border
FOl1. Ord to the south and southeast, respectively.
Land use east of Fort Ord is primarily
agricultmaL .
1.2
Basis and Purpose
This Record of Decision (ROD) addresses the
Fort Ord Landfills, also known as Operable
Unit 2 (OU 2), north and south of Imjin Road
(see Plate 1). A playing field and roads are
located on the landfill north of Imjin Road. The
north landfill covers approximately 30 acres, and
residences are located nearby. The landfill south
of Imjin Road (referred to herein as the main
landfill) encompasses approximately 120 acres
that have not been developed. This area is
covered by uneven sand dunes with grass,
shrubs, and bushes.
This decision document presents the selected
remedial action for OU 2 and underlying aquifers
(upper aquifer and 180-foot aquifer). The remedy
was selected in accordance with the
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as
amended by the Superfund Amendment and
Reauthorization Act (SARA), and, to the extent
practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
This decision is based on the Administrative
Record for Fort Ord.
The United States Environmental Protection
Agency (EP A) and the California Environmental
Protection Agency concm with the selected
remedy.
N32348-H
July 15, 1994
1.3
Site Assessment
Actual or threatened releases of hazardous
substances at the Fort Ord Landfills, if not
addressed by implementing the response action
selected in this ROD, may present a current or
futme threat to public health, welfare, or the
environment.
1.4
Description of the Remedy
The selected remedial alternative described in
this ROD addresses cmrent or potential
significant risks to human health and the
environment posed by au 2 at Fort Ord,
California. The selected remedy will involve the
following activities.
Placement of an engineered cover system
over the Fort Ord Landfills to restrict rainfall
infiltration and prevent leaching to
underlying groundwater of any remaining
chemical compounds in waste materials or
soil. Deed restrictions would be placed on
the property to ensme that the integrity of
the cover system is maintained and prevent
potential direct exposures of VOCs to the
environment or people associated with future
use of the site.
Extraction, treatment, and recharge of
groundwater that contains volatile organic
compounds (VOCs) from the upper aquifer at,
and downgradient of, the Fort Ord Landfills.
This action would remove VOCs from
groundwater that could pose threats to
human health and the environment.
.
Extraction, treatment, and recharge of
groundwater from the 180-foot aquifer
downgradient of the Fort Ord Landfills as an
interim action to prevent fUIther migration of
VOCs. The final cleanup remedy for the
180-foot aquifer will be addressed in the
basewide ROD.
United States Department of the Army
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... .. "" .h_..~... ..,
, ... ,-, ,. ....~
Declaration
1.5
Statutory Determination
The selected remedy is protective of human
health and the environment, complies with
federal and state applicable or relevant and
appropriate requirements for1his action. and is
cost effective. The remedy is intended to fully
address the statutory mandate for permanence
and treatment to tile maximum extent practicable
for the Fort Ord Landfills and underlying upper
aquifer. Subsequent actions to fully address
potential threats posed by the conditions in areas
of the 180-foot aquifer will be presented in
subsequent decision documents and/or the final
basewide ROD. The remedy utilizes permanent
solutions and aJternative treatment (or resow'ce
recovery) technologies to the maximum extent
practicable and satisfies the statutory preference
for remedies iliat employ treatment that reduces
toxicity. mobility. or volume as a principal
element. Because the remedy will result in
hazardous substances remaining onsite above
healili- sed levels. the 5-year review period will
ap ly this actio
1: omas F. Ellzey. Jr.
Colonel, U.S. Army
Commanding
FOrd
Joseph
BRAC E
Fort Ord .
~..
~. L..0 \.A.L .
C. WIse
Deputy Regional Administrator
U.S. Environmental Protection Agency
Region IX
9.2.3. qy
Date
N32348-H
July 15. 1994
~f
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Anilion)' J. LariHis:P.E ~-- .
Chief of Operations
Office of MilitaI}7 Facilities
California Environmental Protection Agency
. ~2;;bs~n;~:~:]
Executive Officer .
California Environmental Protection Agency
California Regional Water Quality Control Board.
Central Coast Region
rC~ ,...:.. i; I
(. ,-. 'y
Date.
United States Department of the Army
2
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2.0 DECISION SUMMARY
2.1
Site Description
Fort Ord is located near Monterey Bay in
northwestern Monterey County. California,
approximately 80 miles south of San Francisco.
The base comprises approximately 28.000 acres
adjacent to the cities of Seaside, Sand City.
Monterey, and Del Rey Oaks to the south and
Marina to the north. The Southern Pacific
Railroad and Highway 1 pass through the
western portion of Fort Ord. separating the beach
front from the re!'t of the base. Laguna Seca
Recreation Area and Toro Regional Park border
Fort Ord to tile south and southeast, respectively.
Land use east of Fort Ord is primarily
agricul tura!.
2.2
Site History
Since its opening in 1917, Fort Ord has primarily
served as a training and staging facility for
infantry troops. No permanent improvements
were made until the late 1930s, when
administrative buildings. barracks. mess halls,
tent pads. and a sewage treatment plant were
constructed. From 1947 to 1975, Fort Ord was a
basic training center. After 1975, the 7th InfantJy
Division (Light) was assigned to Fort Ord. Light
infantry troops are those that perform their duties
without heavy tanks, armor. or artillery. In 1991,
Fort Ord was selected for closme in 1993; the
majority of the soldiers were reassigned to other
Army posts. Although Army personnel still
operate the base. no active army division is
currently stationed there.
Both landfills at Fort Ord were used for
residential and commercial waste disposal. The
north landfill was used from 1956 to 1966. The
main landfill was operated from 1960 until 1987
and may have received a small amount of
chemical waste along with household and
commercial refuse. The main landfill facility
stopped accepting waste for disposal in May 1987
because of the initiation of interim closme~otthe
facility.
The disposal methods that were used at the north
landfill are unknown but are believed to have
N32348-H
July 15. 1994
been similar to practices used in the main
landfill. Waste received at the main landfill
facility was placed in tJ'enches approximately
30 feet wide. 10 to 15 feet apart, and 10 to
12 feet below ground surface (bgs). Waste was
normally placed in the tJ'enches to a height 'of
approximately 10 feet above the tJ'ench bottom
and covered with about 2 feet of native dune
sand deposits excavated dming trenching
operations; however. thicker refuse sections exist
within the landfill.
Detailed records on the amounts or types of
waste disposed of at the landfills are not
available; however. information collected during
field activities and from other somces indicates
that household and commercial refuse. dried
sewage sludge, constJ'uction debris, and small
amounts of chemical waste (such as paint, oil,
pesticides. electrical equipment, ink, and epoxy
adhesive) were placed in the landfill. The
composition of the waste is similar to that
encountered at any municipal landfill.
2.3
Enforcement and
Regulatory History
Environmental investigations began at Fort Ord
in 1984 at Fritzsche Army Airfield (FAAF) under
Regional Water Quality Control Board (RWQCB)
cleanup or abatement orders 84-92. 86-86, and
86-315. Investigations indicated the presence of
residual organic compounds from fire drill
burning practices at the Fire Drill Bmn Pit
(Operable Unit 1 or OU 1). The subsequent
Remedial InvestigationlFeasibility Study (RI/FS)
for OU 1 was completed in 1988. and cleanup of
soil and groundwater began under RWQCB
cleanup or abatement orders 86-87, 86-317, and
88-139. In 1986, fmther investigations began at
the Fort Ord landfill [Operable Unit 2 or OU 2),
and the preliminary site characterization was
completed in 1988. In 1990. Fort Ord was placed
on the EP A's National Priorities List (NPL)
primarily because of VOCs found in groUndwater
beneath OU 2. A Federal Facility Agreement
(FFA) was signed by the Army. EPA, the
California Environmental Protection Agency's
Department of Toxic Substances Control (DTSC;
United States Department of the Army
3
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Decision Summary
formerly the Toxic Substances Control Program
of Department of Health Services or DHS), and
RWQCB. The FFA established schedules for
commencing remedial investigations and
feasibility studies and requires that remedial
actions be completed as expeditiously as
possible. In 1991, the basewide Rl/FS began, and
Fort Ord was placed on the Base Realignment
and Closure (BRAC) list. .
2.4
Highlights of Community
Participation
On October 12. 1993. the United States Army
presented the Proposed Plan for Operable Unit 2
at Fort Ord to the public for review and comment
(Dames and Moore, 19930). The Proposed Plan
presented the prefened alternative and
sunimarized information in the OU 2 Rl/FS and
other documents in the Administrative Record.
These documents are available to the public at
the following locations: F0l1 Ord Post Library.
Building 4275. North-South Road. Fort Ord,
California. and Seaside Branch Library,
550 Harcourt Avenue. Seaside, California. The
administrative record is available at 1143 Echo
Avenue, Suite F, Seaside, California.
Comments on the Proposed Plan were accepted
during a 30-day public review-and-comment
period that began on October 12 and ended on
November 11, 1993. A public meeting was held
on October 19. 1993, at the Doubletree Hotel,
Portola Plaza, in Monterey, California. At that
time, the public had the opportunity to ask the
Army questions and express concerns about the
plan. In addition, written comments were
accepted during the public comment period.
Responses to the comments received during the
public comment period are included in the
Responsiveness Summary presented in
Section 3.0 of this document.
2.5
Site Characteristics
A basewide Rl/FS is under way to evaluate
environmental contamination. Within Fort Ord,
two Operable Units have been identified for
separate. expedited investigation and cleanup:
the Fritzsche Army Airfield Site (OU 1) and the
Fort Ord Landfills (OU 2). The term "operable
unit" refers to specific investigations that address
N32348-H
July 15. 1994
a geographic portion of a site or a specific site
problem.
The results of the RI at the Fort Ord Landfills
indicate that landfill materials were buried in
relatively uniform sand dune deposits in shallow
trenches approximately 30 feet wide that extend
from ground surface to 10 to 12 feet bgs (Plate 2).
Soil samples collected below the landfills do not
contain chemicals associated with the landfills.
Chemicals associated with landfilled materials,
however, have been detected in soil vapor
obtained from soil overlying the landfills and in
groundwater collected from beneath the landfills.
The chemicals are believed to have migrated
away from the landfilled materials as vapors or
as solutes in leachate. Chemicals are present in
two groundwater aquifers: the upper aquifer and
the 180-foot aquifer (Plate 3). The groundwater
in the upper aquifer occurs at approximately 50
to 100 feet bgs; groundwater in the 180-foot
aquifer occurs at approximately 100 to 300 feet
bgs. Results of the RI indicate that the greatest
number of chemicals and highest concentrations
were detected in the upper aquifer.
Water in the upper aquifer flows toward the west
and the Pacific Ocean. Due to extensive local
and regional pumping of water from the 180-foot
aquifer for agricultural and domestic use, the
natural flow toward the west is reversed. and
water in the 180-foot aquifer flows inland
(eastward). Beneath the landfill, the upper and
the 180-foot aquifers are separated by an
impermeable layer, or aquiclude. known as the
Salinas Valley Aquiclude. Near the Pacific
Ocean. however. the two aquifers are connected
because the aquiclude pinches out in this area.
Thus, chemicals in the upper aquifer can or may
(over many years) migrate into the 180-foot
aquifer.
Trichloroethene (TCE) was the most important
chemical detected, in terms of frequency and
concentration, in water samples obtained from
the upper and 180-foot aquifers. The maximum
. concentration of TCE detected in water samples
obtained during groundwater sampling of the
upper aquifer was 80 parts per billion. The
highest TCE concentration detected in the
180-foot aquifer was 50 parts per billion. The
allowable state and federal drinking water
standard. known as the Maximum Contaminant
United States Department of the Army
4
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Decision Summary
Level (MCL), is 5 parts per billion for TCE. In
addition to TCE. other VOCs have been detected
in groundwater beneath the site. including:
tetrachloroethene, benzene,
cis-l,2-dichloroethene. and dichloromethane
(Table 1).
2.6
Scope and Role o' Operable
Unit
OU 2 consists of three components: (1) a
shallow soil and waste material unit within the
landfill areas. (2) the upper aquifer, and (3) the
180-foot aquifer underlying the upper aquifer.
The first component, shallow soil and buried
waste materials in the landfill areas, covers a
total area of approximately 150 acres (Plate 1).
As described above. waste materials were buried
in shallow trenches at the main and north
landfills. The primary remedial objectives for
shallow soil and buried waste at the Fort Ord
Landfills are to prevent human exposure to the
buried waste. prevent infiltration of rainwater
into the contaminated aquifer, and prevent
release of methane offgas generated by
decomposition of waste in the landfill (if
necessary), through collection and treatment.
The second component. the upper aquifer, is not
currently used to supply drinking water. It is
identified in the Water Quality Control Plan -
Central Coast Basin (November 1989) as a
potential drinking water source. The upper
aquifer is also in hydraulic communication with
the underlying 180-foot aquifer. which is a
drinking water source. The primary remedial
objectives for the upper aquifer are hydraulic
control and containment of contaminated
groundwater in the upper aquifer. and extraction
. and treatment of groundwater exceeding aquifer
cleanup levels. Remedial actions for the first two
components are intended to be final remedial
solutions to risks posed by contaminants present
within these units.
The remedy for the third component, the 180-foot
aquifer, is an interim measure. The remedial
objectives for the 180-foot aquifer are protection
of drinking water. containment of northeasterly
groundwater flow, and removal of water
containing the highest concentrations of VOCs.
Initial results of the basewide RI indicate that
N32348-H
July 15. 1994
other source areas may impact the 180-foot
aquifer, which is used as a drinking water
resource. Additional data will be required before
a final remedial alternative for the 180-foot
aquifer is selected. Selection of the final remedy
will also require additional data to determine
how saltwater' intrusion is related to remediation
of the drinking water resources. The final
remedial measure for groundwater in the 180-foot
aquifer will be established in the final Fort Ord
Basewide Record of Decision.
2.7
Summary o' Site Risks
As part of the RI, a Baseline Risk Assessment
(BRA) was performed (Dames and Moore, 1993b).
A BRA is an evaluation of cun-ent or future
potential health risks and environmental impacts
that would be associated with a site were no
remedial action taken. Risk assessment
calculates potential health risks using
mathematical models to evaluate the ways in
which humans, or other receptors, are exposed to
chemicals at the site, as well as the known toxic
effects of the chemicals of concern.
The BRA assumed the following potentially
exposed populations: (1) current onsite resident
(child); (2) current onsite resident(adult);
(3) future onsite resident (assuming that drinking
water was obtained from the upper aquifer); and
(4) future onsite resident (assuming that drinking
water was obtained from the 180~foot aquifer).
The evaluations conducted for the BRA were
designed to conservatively estimate potential -
exposures of these hypothetical residents to the
chemicals currently present in soil and
groundwater. The potential for carcinogenic and
other health impacts was also considered.
Among the multiple exposure scenarios
evaluated in the BRA were: inhalation of
chemicals volatilized from groundwater or soil
into the air; ingestion of soil; and ingestion and
. dermal contact with water. These hypothetical
exposures were presumed to take place over
many years, up to 70 years for humans. The
BRA identified TCE as the primary chemical
contaminant of concern based on its frequency of
detection. concentration. and effects on human
health.
As part of the BRA, risks to the environment
were evaluated. Although the chemicals detected
United States Department of the Army
5
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Decision Summary
are toxic to biological receptors such as plants
and animals, the limited exposme pathways,
relatively low contaminant concentrations, and
small area where exposure might occur (in and
immediately surrounding the landfills) indicate a
low potential for hazards to wildlife.
Calculations performed in the BRA identified a
reasonable maximum exposw'e that results in the
highest calculated increased non-cancer and
cancer-related health risks. The hazard index (a
measure of non-cancer-related health risks) for all
detected chemicals fell below 1.0 for each of the
exposure scenarios in the BRA, indicating little
likelihood of non-cancer effects at OU 2. The
calculations were based on a scenario where
children living on the site would use untreated
upper aquifer groundwater for many years.
Using mathematical models described in the
BRA, the highest predicted risk of cancer, if no
action were taken at the site, is approximately 2
in 10,000. In other words, if untreated
contaminated water were to be used by children
over 30 years for drinking and showeringlbathing,
approximately two additional people out of
10,000 would be at risk of developing cancer.
Thus, if actual or threatened releases of
hazardous substances from this site were not
addressed by the selected remedy, they might
present a potential threat to public health,
welfare, or the environment. Under Superfund,
remedial action is required for this site because
this level of potential risk is above the acceptable
risk range.' "
2.8
Remedial Action Objectives
The remedial action objectives for the shallow
soils and waste materials are to restrict rainfall
inftltration and prevent leaching to underlying
groundwater of VOCs remaining in waste
materials or soil and to prevent potential direct
exposme to VOCs of the environment or people
who use the site in the future.
To protect human health and comply with
federal and state law, groundwater must be
returned to a condition that will allow beneficial
uses to occm, including potential fut\1l'e use as a
drinking water source, without unacceptable
risks to the users. Thus, the remedial action
objectives for groundwater include cleaning the
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July 15, 1994
upper aquifer to MCLs or lower, as shown in
Table 1. The provisional goals for the interim
action in the 180-foot aquifer also include
" cleaning groundwater to these same levels.
CW1'ently, no on- or off-base residents are
exposed to TCE, because no one consumes
untreated contaminated groundwater and no
residents occupy land overlying the landfill.
2.9
Description of Alternatives
The following five remedial alternatives were
evaluated in the FS, and Alternatives 1, 3, and 4
were developed for detailed analysis to assess
their pelformance in accomplishing cleanup of
groundwater and securing of the landfill.
Alternatives 2 and 5 were eliminated in the
initial screening of alternatives in the FS and
were not retained for further detailed analysis.
2.9.1
Alternative 1 . No Action
Estimated Construction Cost:
Estimated Annual Operation and
Maintenance (O&M) Cost:
Estimated Present Worth Cost:
Estimated Implementation
Timeframe:
Estimated Time for
Cleanup: No removal of contaminants;
therefore, remediation by natmal
process will be very slow.
" $0
$192,000
$2,950,000
o months
Alternative 1 assumes CWTent site conditions will
be unchanged except for implementation of a
groundwater monitoring program" to assess
movement of the contaminated groundwater
plume. The Superfund program requires
evaluation of the No Action alternative to
provide a baseline for comparison purposes. The
No Action alternative relies on natw-al
degradation (chemical reactions or the gradual
breakdown of the VOCs by naturally occurring
microorganisms) and dispersion processes (the
gradual spreading and continual dilution of the
VOCs as they mix with uncontaminated
groundwater) to eventually eliminate the
contamination. VOC concentration levels are
expected to be reduced over many years under
this alternative.
United States Department of the Army
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. . ..~. _...~-_.,
. ., ., "'1 .: 'n .~.I..
. .... -,,-.,-""".--'.'.',,-,."
Decision Summary
2.9.2
Alternative 2 . Containment
Costs for Alternative 2 were not developed
because it was eliminated during initial screening
of remedial alternatives. This alternative
includes containment of groundwater and waste
within the present boundaries. Because of the
high permeability of the dune sand deposits that
underlie most of Fort Ord, rainfall percolates
directly into the soil. When the infiltrated water
interacts with chemicals in the landfills, the
chemicals may be transported into the aquifers
below. Providing a cover system over the
landfills eliminates water infiltration and direct
exposure to the waste. Soil gas beneath the cover
system is extracted by means of weBs penetrating
the cover system, and treated by granular
activated carbon (GAC) to remove VOCs. The
details of the cover system design depend in part
on future land uses. Installation of the cover
system involves stripping the landfill surface of
the existing vegetation; regrading the remaining
sand; covering the surface of the landfill with
several layers of soil and impermeable material;
and installing the necessary equipment needed
for drainage control and, if necessary, irrigation.
A conceptual drawing of the cover system is
shown on Plate 3.
Construction of the proposed landfill cover
system impacts local flora and fauna. Restoration
of the original habitat and revegetation,
particularly of threatened or endangered speci~s,
will be conducted to mitigate the impacts of the .
cover system construction and is consistent with
the Habitat Management Plan (HMP) Uones and
Stokes, 1994). In addition, to mmimize impacts
to housing north of Imjin Road, the cover system
construction includes excavation on the
perimeter of the northern portion of the landfill,
thereby reducing the area of the cover system.
Exact design details regarding the cover system
design will be determined in the Remedial
Design. Excavated soil and debris (if any) are
disposed of in the main landfill area south of
Imjin Road prior to covering. The landfill areas
are revegetated with native plants or returned to
former uses after cover system construction.
Groundwater containment is achieved by
installing an extraction well field downgradient
of the landfills. A limited number of wells
screened in the upper and 180-foot aquifers are
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July 15, 1994
used to hydraulically contain flow in the
aquifers, preventing water in the upper aquifer
from leaving the site and reducing flow toward
supply wells in the 180-foot aquifer. Based on
information generated in the RI, it is believed
that several pumping wells in the upper aquifer,
and at least one well in the 180-foot aquifer. are
required to achieve containment. Proposed
extraction well locations are within the
boundaries of Fort Ord. If extracted groundwater
requires treatment, it would be passed through
granular activated carbon (GAC) , then recharged
to the subsurface or reused. Unlike .
Alternative 4, described below, Alternative 2
provides only containment without aggressive
removal of contaminated groundwater.
Alternative 2 was not considered for a detailed
analysis because this alternative would most
likely neither obtain regulatory approval nor
achieve remedial action objectives because it
does not comply with ARARs.
2.9.3
Alternative 3 . Upper Aquifer
Cleanup and Landfill
Covering
Estimated Construction Cost: $12,750,000
Estimated Annual Operation and
Maintenance (O&M) Cost:. $485,000
Estimated Present Worth Cost: $20,200,000
Estimated Implementation
Timeframe: 30 months
Estimated Time for Cleanup: 20 to 40 years
Under this alternative, groundwater extraction
wells are screened only in the upper aquifer, and
the system is designed to achieve groundwater
and chemical removal as well as containment in
the upper aquifer. Wells are placed such that the
groundwater plume is captured and treated. Up
to 10 pumping wells operating at a total of
170 gallons per minute are proposed to achieve
containment and removal of chemicals in upper
aquifer groundwater. The proposed upper
aquifer well field is shown on Plate 4. Under
this alternative, no action is taken for the
180-foot aquifer. A cover system on the landfills
is installed as described under Alternative 2.
Under Alternative 3, extracted water is treated to
remove VOCs by passing it tlu.ough CAC, then
recharged to the subsurface or reused.
United States Department 0' the Army
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Decision Summary
2.9.4
Alternative 4 . Upper Aquifer
Cleanup and Landfill
Covering. Interim
Groundwater Extraction on
180.Foot Aquifer
Estimated Construction Cost: $12,800,000
Estimated Annual Operation and Maintenance
(O&M) Cost: $485,000
Estimated Present Worth Cost: $20,250,000
Estimated Implementation
Timeframe:
Estimated Time for Cleanup:
30 months
20 to 40 years
This alternative supplements Alternative 3 by
including containment of water and chemicals in
the 180-foot aquifer by implementing an Interim
Action.
In addition to the actions identified in
Alternative 3, this alternative includes removal
and treatment of groundwater and chemicals
from the 180-foot aquifer. The Interim Action
generates additional performance data regarding
the aquifer's response to pumping and
subsequent changes in water quality which
would include additional information regarding
the impact of other source areas to the 180-foot
aquifer and the effect of salt water intrusion on
drinking water sources during groundwater
remediation. Collection of these data enables
final decisions to be made regarding remediation
of the 180-foot aquifer. Currently, one well
located near the main landfill and pumping at 15
. to 25 gallons per minute will be used to extract
water from the 180-foot aquifer, in addition to
the wells described in Alternative 3 for the upper
aquifer. Additional wells may be required in the
180-foot aquifer to provide hydraulic
containment. Water from both aquifers is treated
using GAC, then recharged to the subsurface, or
reused.
2.9.5
Alternative 5 . Upper Aquifer
Cleanup and Removal,
Treatment, and Disposal of
Landfill Waste. Interim
Groundwater Extraction on
180.Foot Aquifer
Costs for this alternative were not developed
because it was eliminated during initial
screening. Groundwater is removed and treated
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July 15, 1994
as described in Alternative 4. In addition, the
waste from the landfill area is excavated using
conventional earth-moving equipment. The
excavated waste is then segregated and disposed
of appropriately.
Alternative 5 was not considered for a detailed
analysis because this alternative is expensive
relative to the other alternatives, requires
implementation of difficult and unreliable
technologies to sort and segregate buried waste
materials, and most likely would not obtain .
community and regulatory acceptance.
2.10
Summary of Alternative
Comparison
Nine criteria established by CERCLA were used
to evaluate the alternatives in the detailed
analysis step. The nine criteria encompass
statutory requirements and include other
technical, economic, and practical factors that
assist in comparing the overall feasibility and
acceptability of the cleanup alternatives. The
nine criteria are summarized as follows:
Overall Protection of Human Health and the
Environment. Addresses whether or not a
remedy provides adequate protection and
describes how risks posed through each exposure
route are eliminated, reduced, or controlled'
through treatment, engineering controls, or
institutional controls.
Compliance with Applicable or Relevant and.
Appropriate Requirements (ARARs). Addresses
whether or not a remedy will meet all of the
ARARs or provide grounds for invoking a waiver
of the requirements.
Long~Term Effectiveness and Permanence. Refers
to the magnitude of residual risk and the ability
of a remedy to maintain reliable protection of
human health and the environment after cleanup
goals have been met.
Reduction of Toxicitv. Mobilitv. or Volume
Through Treatment. Evaluates the anticipated
performance of the treatment technologies that
may be employed in a remedy.
Short-Term Effectiveness. Refers to the speed
with which the remedy achieves protection, as
United States Department of the Army
8
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Decision Summary
welJ as the remedy's potential to create adverse
impacts on human health and the environment
that may result during the construction and
implementation period.
lmplementabilitv. Refers to the technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement the selected solution.
Cost. Evaluates capital and operating and
maintenance costs for each alternative by
performing present-wOlth cost analyses.
State Acceptance. Indicates whether, based on
its review of the RI/FS reports and Proposed Plan,
the state concurs with, opposes, or has no
comment on each alternative.
Community Acceptance. Assesses general public
response to the Proposed Plan folJowing a review
of the public comments received on the RI/FS
reports and the Proposed Plan during the public
comment period and open community meeting(s).
The selected remedy must meet the first two of
the nine CERCLA screening criteria described in
Section 2.8 above: prote~tion of human health
and the environment as well as compliance with
ARARs. The next five criteria are primarily
balancing criteria used for comparison with other
remedial action alternatives. The final two
criteria, state and community acceptance, are
used to address the concerns of state agencies
and slUTounding communities. Remedial action
alternatives 1, 3 and 4 discussed above were
evaluated on the basis of these criteria in the FS
(Dames and Moore, 1993c); Table 2 presents a
summary of this evaluation.
2.11
The Selected Remedy
Alternative 4 is the selected alternative based on
the assessment in the FS and as summarized in
Table 2. Alternative 4 met the first two screening
criteria and was judged to be superior in the
folJowing three balancing criteria:
Long-term effectiveness and permanence
.
Reduction of toxicity, mobility, and volume
of chemicals
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July 15, 1994
Short-tenn effectiveness
Cost effectiveness.
The State of California (CalIEP A, DTSC and
RWQCB) concurs with the selection of
Alternative 4. C01nmunity acceptance is
discussed in the responsiveness summaIY
(Section 3.0). Details regarding soil and
groundwater remedial actions under the selected
alternative are presented below.
2.11.1
Selected Remedy: Soil
Action
The goal of the cover system is to prevent
rainwater percolation through the landfills area
and into the underlying drinking water aquifers.
to collect and remove methane offgas (if
necessaIY), and to prevent exposure of sanitary
waste in the landfills to the sWTounding
environment. The cover system for the au 2
landfill surface soil and bmied waste is driven by
ARARs for landfill closure. Institutional control
(Le., deed restrictions) will be placed on the
property to ensure that the integrity of the cover
system is maintained and prevent potential direct
exposures of VOCs to the environment or people
associated with future use of the site.
2.11.2
Selected Remedy:
Groundwater Actions
The goal of this remedial action is to restore
groundwater to its beneficial use, which is, at.
this ~ite, as a drinking water sow'ce. Based on
information obtained during the remedial
investigation and on a careful analysis of all
remedial alternatives, the Army, EPA, and the
State believe that the selE}cted remedy will
achieve this goal. The remedy includes
institutional controls (Le., deed restrictions) that
prevent the use of groundwater within the
contaminant plume for domestic or agricultural
purposes. It may become apparent, during
implementation or operation of the groundwater
extraction system and its modification, that
contaminant levels have ceased to decline and
are remaining constant at levels higher than the
remediation goal over some portion of the
contaminated plume. In such a case, the system
peIformance standards and/or the remedy may be
reevaluated.
United States Department of the Army
9
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Decision Summary
The selected remedy will include groundwater
extraction for an estimated period of 30 years,
during which the system's performance will be
carefully monitored on a regular basis and
adjusted as warranted by the performance data
collected during operation. Modifications may
include any or all of the following:
.
Discontinuing pumping at individual wells
where cleanup goals have been attained
Alternating pumping wells to eliminate
stagnation points
. Pulse pumping to allow aquifer equilibration
and to allow adsorbed contaminants to .
partition into groundwater; and
.
Adding additional extraction wells to
facilitate or accelerate cleanup of the
contaminant plume.
The points of compliance for the remediation
goals are any monitoring wells screened in the
upper and 180-foot aquifers within the plume
area. Remedial DesignJRemedial Action
documentation will define at what point the
remediation goals will be considered to have
. been attained. To ensure that remediation goals
continue to be maintained, the aquifer will be
monitored in the vicinity of wells where
pumping has ceased until the Army, EPA, and
the State agree that cleanup is complete.
Remediation goals for chemicals present in
contaminated groundwater are either based on
ARARs or on values determined by the BRA and
are presented in Table 1.
The estimated total aggregate excess cancer risk
for all chemicals at their respective remediation
goals is 6 x 10-5. This cumulative risk is within
acceptable range, and is health protective.
2.12
Statutory Determinations
The selected remedy meets the requirements of
Section 121 of CERCLA to:
.
Be protective of human health and the
environment
Comply with ARARs
N32348-H
July 15, 1994
Utilize permanent solutions and alternative
treatment technologies or resource recovelY
technologies to the maximum extent
practicable
Satisfy the preference for treatment that
redt,Ices toxicity, mobility, and/or volume as a
principal element
Be cost effective.
2.12.1
Protection of Human Health
and the Environment
The selected remedy provides the greatest degree
of protection for both human health and the
environment. Implementation of the selected
remedy includes groundwater containment and
aggressive removal of contaminants from the
upper aquifer, and containment of contaminants
from the lBO-foot aquifer as the Interim Action.
Extracted groundwater from both affected
aquifers will be treated by GAC. Treated
groundwater will be discharged to the upper
and/or 180-foot aquifers by means of recharge
systems or reused at the surface. The landfill
will be closed in place and covered to eliminate
water infiltration and direct exposure to the
waste. In addition, a vapor control system will
be included, if necessary, in the final cover
system design (Plate 3).
Implementation of the selected remedy may make
short-term impacts on the surrounding
environment. An ecological survey of the au. 2
landfills area was presented in the Flora and
Fauna Baseline Study of Fort Ord (fones and
Stokes. 1992). Excavation activities for the
landfill may disturb local flora and fauna. Other
potential short-term environmental ~pacts from
this alternative include noise and dust from
construction activities. Mitigation measures will
be established in the Remedial Design phase of
this project to minimize potential short term
impacts to the surrounding environment, and
will comply, at a minimum, with mitigation
measures described in the HMP.
2.12.2
Compliance with ARARs
The selected remedy complies with ARARs.
United States Department of the Army
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< ~"
.-:~--
.. ,.'
Decision Summary
ARARs are "applicable" or "relevant and
appropriate" requirements that. the Army is
required to comply with. The categories of
ARARs are: action-specific, chemical-specific,
and location-specific. Action-, chemical-, and
location-specific ARARs for the selected
alternative are presented in Appendix A. In
addition to complying with ARARs, the Army has
the discretion to consider guidance and health
advisories as "to-be-considered" (TBC)
requirements. Those TBCs that the Army selects
become performance standards that must be
complied with.
2.12.3
Cost Effectiveness
The selected remedy is a cost-effective solution
for reducing risks to human health and the
environment. The estimated net present value
for the No Action alternative (Alternative 1) is
approximately $2.95 million. The estimated cost
of the selected remedy is approximately
$20.2 million, which is commensurate with the
higher level of protection of human health and
the environment. The cost is approximately
equal to the estimated cost for Alternative 3,
although the selected alternative yields a greater
level of protection of human health and the
environment than Alternative 3.
2.12.4
Utilization of Permanent
Solutions and Alternative
Treatment Technologies or
Resource Recovery
Technologies
The selected remedy uses permanent solutions,
alternative treatment technologies, and resource
recovery technologies to the maximum extent
practicabk. Landfill covering in place is similar
in permanence to removing the waste to another
landfill that would subsequently be covered.
RI data do not indicate that methane generated
by the landfill waste is of sufficient quantity to
warrant resource recovery.
Removal of VOCs from groundwater is permanent
and recharge of treated groundwater to affected
aquifers or sUi'face reuse represents resource
recovery. Groundwater extraction and treatment
of the 180-foot aquifer, however, is not
N32348-H
July 15. 1994
considered the final remedy for this aquifer.
This groundwater extraction will generate
additional performance data regarding the
180-foot aquifer's response to pumping and
subsequent changes in water quality. Collection
of these data will enable decisions to be made
regarding the selection and implementation of a
final remedy for the 180-foot aquifer. Because a
final remedy regarding the 180-foot aquifer is not
the subject of this ROD, its remedy will be
specifically addressed in a subsequent decision
document or the basewide ROD.
The decisive factors in selection of this remedy
are compliance with ARARs and protection of
human health and the environment.
2.12.5
Preference for Treatment as
a Principal Element
The selected remedy satisfies the statutory
preference for treatment as a principal element in
addressing the human health and environmental
threats posed by the Fort Ord Landfills. The
principal environmental threat identified during
the RI is posed by VOCs in groundwater. The
selected alternative treats extracted groundwater,
thereby removing the VOCs and reducing
potential risks to human health and the
environment. . VOCs will also be removed from
the vapor phase via the vapor control system.
Treatment would not be practical for buried
landfill materials because the waste contents are
of large volume, very heterogeneous and difficult
to separate. The buried waste is similar to waste
found at a. sanitary landfill. Many wastes in the
landfill have no suitable treatment technologies
other than disposal at another landfill.
2.13
Documentation of
Significant Changes
As described in the Responsiveness Summary
(Section 3.0), the Proposed Plan for OU 2 was
released for public comment on October 12,
1993, and a public meeting was held on
October 19, 1993. This Proposed Plan identified
upper aquifer cleanup and landfill covering with
interim groundwater extraction on the 180-foot
aquifer as the selected remedial response action.
United States Department of the Army
11
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_h"'''' _.. -. - - 0" .
. ..-. -..,. ...'..- .0 ..
.. "."'." -- .
.. _'.0 . - _.~. nO<
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Decision Summary
Comments collected over the 3D-day public
review period between October 12 and
November 11, 1993, did not necessitate any
significant changes to the conclusions or
procedures outlined in the OU 2 Feasibility
Study and Proposed Plan.
N32348-H
July 15, 1994
United States Department of the Army
12
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3.0 RESPONSIVENESS SUMMARY
3.1
Overview
At the time of the public review period for the
Army's Remedial Investigation/Feasibility Study
and Proposed Plan for the Fort Ord Landfills, the
Army identified a preferred remedial alternative.
The preferred remedial alternative consisted of
upper aquifer cleanup and landfill covering with
interim action on the 180-foot aquifer. This
remedial alternative was selected on the basis of
an evaluation of five remedial alternatives.
On the basis of the written and verbal comments
received, the Army's Proposed Plan was generally
accepted by the public. However, several
citizens expressed concern over the identification
of the preferred remedial alternative. In
particulaI', these individuals stated that they felt
the Army had not fully characterized the landfill
contents. These individuals also stated that the
landfill should be excavated and moved to
another location given that Fort Ord is a closing
installation. In addition, a number of parties
commented on the conceptual design of the
landfill cover system.
3.2
Background on Community
Involvement .
Community involvement in decisions regarding
the Fort Ord Landfills was minimal until .
Fort Ord was added to the National Priorities List
(NPL) in 1990. Environmental investigations at
the Fort Ord Landfills had been ongoing since
1986 with regulatory agency coordination
conducted at quarterly meetings held at Fort Ord.
Potential contamination of nearby City of Marina
water supply wells was a major contributing
factor to listing the entire Fort Ord base on the
NPL.
In 1991, Fort Ord was added to the Department
of Defense Base Realignment and Closure (BRAC)
List. The economic impact of Fort Ord's
imminent closure has created much community
interest relative to the potential economic reuse
of portions of Fort Ord. Specifically, the
FOlt Ord Landfills are under consideration for
N32348-H
July 15, 1994
reuse by the FOlt Ord Reuse Group (FORG) and
other interested parties.
Focused community involvement in the Fort Ord
Landfills has most recently involved the public
review of the Army's Remedial
Investigation/Feasibility Study and Proposed Plan
for the Fort Ord Landfills. The public comment
period began October 12.1993, and closed
November 11, 1993. A public meeting was held
on October 19,1993, to present the Army's
Proposed Plan to the public. This responsiveness
summary responds to written comments received
during the public comment period as well as
verbal comments expressed during the public
meeting.
3.3
Summary of Comments
Received During the Public
Comment Period and
Department of the Army
Responses.
Comments raised during the Fort Ord OU 2
Proposed Plan public comment period are
summarized below. The comments received
from the comment period are categorized by
relevant topics.
3.3.1
Remedial Alternative
Preferences
Several interested parties were concerned
that Alternative 4 was not the best choice of
al terna tives.
Department of the Armv Response: All
alternatives were evaluated against the
National Contingency Plan's (NCP) nine
criteria for the evaluation of remedial
alternatives. Of all the remedial alternatives,
Alternative 4 was selected as being the best
alternative. The EP A. DTSC. and RWQCB
concun'ed with the selection of Alternative 4
as the best alternative.
The nine criteria used for the evaluation of
remedial alternatives are as follows:
United States Department of the Army
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Responsiveness Summary
Overall protection of human health and
the environment .
Compliance with applicable or relevant
and appropriate requirements (ARARs)
Long-term effectiveness and permanence
Reduction of toxicity. mobility, or volume
through treatment
Short-telm effectiveness
Implementability
Cost
State acceptance
Community acceptance.
These criteria are discussed in Section 2.10, and
a summary of the evaluation of alternatives is
presented in Table 2.
Several interested parties expressed the
concern that Alternative 5, (excavation of
landfill contents) or a combination thereof
with Alternative 4, would be a better
remedial alternative.
Department of the Army Res-ponse: The
excavation and segregation of the landfill
waste as described in Alternative 5 is
extremely difficult because of the nature and
volume of the Waste. The health and safety
hazards would be particularly significant,
especially potential biohazards associated
with exposing landfill waste. Segregation of
waste, dust and leachate controls. and
impacts to native plant and animal life make
this alternative difficult to "implement. The
volume of waste generated would be
enormous, and would require removing
significant amounts of native soil because the
waste would be difficult to segregate.
Excavated soil would require analytical
testing, and then transfer to a landfill in some
other location. Additionally, this alternative
would also be prohibitively expensive. This
alternative does not cOITespond with agency
and regulatory preferences for "onsite"
solutions rather than "offsite" solutions which
N32348-H
July 15. 1994
transfer environmental problems or risks to
another area.
3.3.2
Technical
Questions/Concerns
Regarding Remedial
Alternatives
.
Several interested parties were concerned
about the design of the landfill.
Department of the Armv Response: The
Proposed Plan presented a conceptual design
for the landfill cover system that was not
intended to be a final design.. The final
design will be prepared under the direction
of registered engineers and reviewed by
appropriate regulatory agencies and the
Restoration Advisory Board (RAB). The final
design will meet all applicable requirements
and address the following concerns expressed
by interested parties:
Ability of the landfill to support deep-
rooted native vegetation
Ability of the landfill to withstand
natural disasters such as earthquakes on
the basis of strength, stability. and
sealing potential of the landfill cover
system
Ability of the landfill design to
accommodate stormwater runoff
Ability of the landfill cover system to
support reuse (restrictions) without
further risk of endangerment to human
health and the environment
Ability of the remedial action to
reasonably eliminate the risk of
.human/environment and contaminant
exposure paths. especially in areas
adjacent to housing areas and Imjin
Road.
Ability of the landfill design to control
and reuse any generated methane
Ability of the landfill design to prevent
existing vadose zone water from
percolating to groundwater
United States Department of the Army
14
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Responsiveness Summary
Interested parties expressed concern about
the characterization of the landfill contents
and the soil beneath the landfill; specific
concerns were as follows:
The Monterey County Department of
Health expressed concern that the
characterization of unsaturated soil below
the landfill was based solely on soil gas
testing and not on soil chemical analyses
Department of the Armv Response: The
characterization of unsaturated soil below
the landfill was based on both soil gas
testing and soil chemical analyses.
Approximately 330 soil gas samples and
220 soil samples were collected for
characterization. In addition, six test pits
were completed within the landfill area
as part of the site characterization
activities.
A concerned citizen stated that "it is
imperative that our community knows
exactly what waste materials are present
within the landfill." This citizen also
expressed concern about
90,000 unaccounted-for chemical weapon
vials buried at Fort Ord.
Department of the Army Response: The
characterization of landfill waste
materials was performed in accordance
with work plans reviewed and approved
by the United States Environmental
Protection Agency and the California
Environmental Protection Agency. The
characterization of the landfill waste
materials utilized a number of
investigation methods as listed below:
Soil gas sampling
Soil chemical sampling
Test pits to characterize waste
materials
Geophysical surveys to define tl1e
extent of waste materials.
N3234B-H
July 15, 1994
Soil gas and soil samples were analyzed
for a comprehensive list of organic and
inorganic chemicals.
The Army has conducted a
comprehensive archival search of the
possible use of chemical weapons at all
Army installations within 33 states,
including California. This archival
search is documented in a report
prepared by the U.S. Army Chemical
Material Destruction Agency (USACMDA)
entitled "Non-Stockpile Chemical
Material Program, Survey and Analysis
Report," dated November 1993. This
report indicates that the only known
chemical agent-related activity conducted
at Fort Ord was the use of Chemical
Agent Identification Sets .(CAISs) The
CAISs were reportedly used at Fort Ord
prior to 1974 for "field training of troops
at a site just off 10th Street Gate Road
past the landfill area off Imjin Road." In
1974, four CAISs in the Fort Ord
inventory were removed from the
installation and transported to Edgewood
Arsenal, Aberdeen Proving Ground and
were later sent to Rocky Mountain
Arsenal for destruction. To date,
however, environmental site
characterizations at 43 environmental
restoration sites, including the Fort Ord
Landfills, have not indicated the presence
of CAISs. The report indicates that there
is no known need for chemical agent.
remediation at Fort Ord and that Fort Ord
is not believed to present any immediate
threat to human health or safety due to
chemical agents.
Several interested parties expressed concerns
about cleanup of the various aquifers
underlying the landfill; according to
expressed concerns, the cleanup should:
Include injection/recharge into the
180-foot aquifer of some of, if not all of,
the extracted and treated groundwater
Identify the number of wells required for
containment in the 180-foot aquifer
United States Department of the Army
15
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Responsiveness Summary
Address shOl1.-tenn reduction of
groundwater pumping due to base
closme, pumping from the 400-foot
aquifer, or other influences that may alter
groundwater gradients and flow.
Department of the Annv Response: The
Department of the Army has undertaken
additional pre-design analyses to obtain more
information required to design the
groundwater extraction, treatment, and
reinjection system. The Proposed Plan
presented a conceptual design that was not
intended to be a final design. The final
design will be prepared under the direction
of registered engineei's and geologists and
reviewed by the regulatOl}' agencies and the
RAB. The final design will meet all
applicable requirements and address the
concerns expressed by interested paI1.ies.
In addition to the pre-design analyses, the
Department of the Army is conducting
basewide remedial investigations. The final
remedy for the 180-foot aquifer will be
identified as part of the basewide Feasibility
Study, Proposed Plan, and Record of
Decision. The final basewide Proposed Plan
will describe the remediation schedule and
final remedy for cleanup of the 180-foot
aquifer.
3.3.3
Costs/Funding Issues
Interested parties inquired about the cost for
the implementation of Alternative 5 - Upper
Aquifer Cleanup and Removal. Treatment,
and Disposal of Landfill Waste - Interim
Groundwater Treatment on 180-Foot Aquifer.
Department of Armv Response: Costs for the
implementation of Alternative 5 were not
estimated because this remedial alternative
was screened from frnther detailed analysis
in the Feasibility Study due to uncertain
regulatory and community acceptance,
engineering problems, and high costs. A
qualitative evaluation of the cost for
Alternative 5 indicated extremely high costs
for its implementation relative to other
remedial action alternatives.
N32348-H
July 15, 1994
A local Monterey area newspaper estimated
the cost for Alternative 5 to be approximately
$700 million based on extrapolation from
figmes provided in an interview with Harvey
Don Jones, U.S. Army Corps of Engineers. In
an interview following the public meeting on
October 19, 1993, Mr. Jones stated that the
estimated cost for the excavation of a 15-acre
landfill in northern California was
$70 million in 1985. The newspaper reporter
apparently assumed that the cost for the Fort
Ord Landfills (150 acres) would be
approximately 10 times iliat of the 15-acre
landfill because it covers approximately
10 times the area. The Army believes that
this extrapolation is not realistic and the
costs for excavation of the landfills area
would be significantly higher and
prohibitively expensive. .
3.3.4
Enforcement
One individual recommended that a ci\'ilian
committee be established to monitor ongoing
environmental restoration activities at Fort
Ord.
Department of the Armv Response: Since
first being placed on the National Priorities
List (SupeIfund) in February 1990, Fort Ord
has had an active Technical Review
Committee (TRC) as required by 1 0 USC
Section 2705(c). The responsibility of this
committee is to oversee environmental
restoration activities. at Fort Ord. This
committee is comprised of representatives
from the Army; representatives of federal.
state, local regulatory agencies; and a
designated civilian representative selected by
the Association of Monterey Bay Area
Governments.
As of July 1993 and the aIUlouncement of the
President's five-point plan to speed economic
recovery of communities at closing bases, the
Restoration Advisory Board (RAE) is required
for base realignment and closme activities.
The RAE will comprise representatives from
the Department of Defense (DOD) component,
EP A, State representatives, and members of
the local community. The RAE will be
jointly chaired by an Army representative
and a member of the local community and
United States Department of the Army
16
-------
.. .-..-.- - ...-........
... .
Responsiveness Summary
will also meet the requirement of 10 USC
Section 2705(c). The function of the RAB
wiU be to (1) act as a forum for discussion
and exchange of deanup information
between government agencies and the public,
(2) conduct regular meetings open to the
public at convenient times. (3) keep meeting
minutes and have them available to the
public, (4) develop and maintain a mailing
list of addresses and names of those who
wish to receive information on the
environmental restoration program, (5) review
and evaluate environmental restoration
documents, (6) identify environmental
restoration requirements, (7) recommend
priorities among sites or projects, and
(8) identify applicable standards and
proposed deanup levels that are consistent
with Section 121 of the Comprehensive
Environmental Response Compensation and
Liability Act (CERCLA), as well as with
planned land use.
The initial RAB establishment meeting for
Fort Ord was held February 7, 1994.
N3234B-H
July 15, 1994
3.4
Remaining Concerns
A number of concerns raised by the public
remain to be addressed as part of remedial
design. These concerns indude:
.
The design of the landfiU cover system as
discussed in Section 3.3.2.
.
The ability of the groundwater extraction and
treatment system to effectively contain and
remediate contaminated groundwater without
exacerbating saltwater intrusion problems.
These remaining concerns are considerations that -
will be incorporated into the Army's remedial
design. The associated remedial design
documents will be reviewed by the regulatory
agencies, the RAB, and will be available for
public review prior to implementation of
remedial actions.
United States Department of the Army
17
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4.0 REFERENCES
Dames and Moore. 1993a. Final Remedial
Investigation Report. D&M Job No.
13846-007-043. Prepared for the U.S. Army
Corps of Engineers. Omaha District under
Contract No. DACA45-89-C-0529. June.
-' 1993b. Baseline Risk Assessment. D&M
Job No. 13846-007-043. Prepared for the U.S.
Army Corps of Engineers. Omaha District under
Contract No. DACA45-89-C-0529. June.
_,1993c. Final Feasibibty Siudy Report.
Remedial Investigation and Feasibility Study.
Fort Ord LandfjJJs. Fort Ord. California. Prepared
for Omaha COE. October 1.
-' 1993d. Proposed Plan for the Final
Feasibility Study Report. Remedial Investigation
and Feasibility Study. Fort Ord Landfills.
Fort Ord, California. "U.S. Army Proposes
Cleanup Plan for the Landfills Site at Fort Ord.
California." Prepared for Omaha COE.
October 12.
N32348-H
July 15, 1994
Jones and Stokes, 1992. Draft Flora and Fauna
Baseline Study of Fort Ord. California. Prepared
for Omaha COE, July 1992.
Jones and Stokes, 1994. Installation-Wide
Multispecies Habitat Management Plan for Fort
Ord, California. Prepared for Sacramento COE,
February 1994.
U.S. Army Chemical Material Destruction
Agency, 1993. Non-Stockpile Chemical Material
PJ'Ogram. Survey. and Analysis Report.
November.
United States Department of the Army
18
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-..h ------,,'..'.
TABLES
-------
Table 1.
Chemicals of Concern, Remediation Goals, and Discharge LImits
Record of Decision
Operable Unit 2, Fort Ord landfills
Fort Ord. California
i Maximum Chemical Discharge Limits for Treated
Federal MCl State MCl Concentration Detected Aquifer Cleanup levels Water
Chemical of Concern (ppb) (ppb) (ppb) (ppb) (ppb)
Benzene 5.0 1.0 2.6 1.0 0.5
Carbon Tetrachloride 5.0 0.5 0.7 0.5 0.5
Chloroform 100 - 16.0 2.08 0.5
1.1-Dichloroethane - 5.0 12.0 5.0 0.5
1,2-Dlchloroethane 5.0 0.5 6.9 0.5 0.5
cis-1,2-Dlchloroethene i. 70.0 6.0 54.0 6.0 0.5
I
1.2-Dichloropropane 5.0 - 8.6 1.08 0.5
Dlchloromethane 5.0b -. 130.0 5.0 0.5
Tetrachloroethene 5.0 5.0 8.2 3.08 0.5
Trichloroethene 5.0 5.0 80.0 5.0 0.5
Vinyl chloride 2.0 0.5 8.0 0.18 0.1
a
Aquifer cleanup goals lower than federal or state MCl selected based on risk calculations In Baseline Risk Assessment (Dames and Moore. 1993b)' The estimated combined excess
cancer risk from exposure to all chemicals at the levels listed in Table 1 is 6 X 10-5. This cumulative' risk Is within the acceptable risk range. and Is health protective.
b
The federal MCl for dichloromethane became effective January 17,1994 (57FR31838).
IdfMG2685-mg
July 15. 1994
Harding Lawson Associates
1 of 1
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Table 2. Evaluation of the Preferred Alternative
Operable Unit 2, Fort Ord Landfills
Fort Ord, California
EPA Evaluation Criteria
Remedial
Alternatives
Retained for Reduction of
Detailed Analysis toxicity, mobility,
In the FS Protection of Long-term and volume or Implementability State and
human health and Compliance with effectiveness and mass through Short-term (technical and Present worth community
the environment ARARs permanence treatment effectiveness administrative) cost acceptance
Alternative 1: This alternative State law and Risk will remain, No active No short-term Easily Total present Not likely to be
will not effectively policies for until natural reduction of effects on Implementable. worth $2,950,000 acceptable to
No Action protect human restoration of degradation toxicity, mobility, humans or the agencies or the
health and the degraded water occurs. volume or mass environment. public - does not
environment. not met. Eventual 01 contaminants. Remedial action remediate
compliance, over objectives (RAOs) contamination
very long will not be nor protect
timefrarne, with achieved for a human health or
chemical-specific long time. the environment.
ARARs.
Alternative 3: Human health For the upper Cover system Cover system Impacts to Implementable. Total present Generally
protected by aquiler, will reduces risk from reduces mobility environment worth $20.200.000 acceptable; see
Upper Aquifer cover system and achieve landfill waste. of landfill waste during responsiveness
Cleanup and extraction wells. compliance with Reduces risks but not toxicity or construction summary.
Capping Some worker chemical and associated with volume. Upper requiring
exposure during action-specific upper aquifer aquifer mitigation.
- Construction 01 cover system ARARs. Including groundwater only. contamination Workers will
cover system construction. waste manage- 180-loot aquifer aggressively require protective
over the Impacts to ment and effluent risks will remain reduced. 180-foot measures.
landfill environment disposal. For the until natural aquifer
during 180-foot aquifer, degradation contamination not
- Estimated 6 construction, eventual occurs. actively reduced. .
extraction wells requiring compliance, over
installed In mitigation. Lack a very long
Upper Aquifer of action on the tlmelrame, with
180-loot aquifer chemical-specific
- GAC treatment represents a ARARs.
and disposal by residual risk to I
recharge to users.
uppermost
aquifers
Id/M02665-mg
July 15. 1994
Harding Lawson Associates
1 012
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Table 2. Evaluation 01 the Prelerred Alternative
Operable Unit 2, Fort Ord Landfills
Fort Ord, California
EPA Evaluation Criteria
Remedial
Altematlves
Retained for Reduction 01
Detailed Analysis toxicity, mobility,
In the FS Protection of Long-term and volume or Implementability State and
human health and Compliance with effectiveness and mass through Short-term (technical and Present worth community
the environment ARARs permanence treatment effectiveness administrative) cost acceptance
Alternative 4: Most effective in Will achieve Reduces risk Cover system Same general Implementable. Total present Generally
protecting human compliance with associated with reduces mobility short-term risks Slightly more worth $20,250,000 acceptable; see
Cleanup and health and chemical and both Upper and 01 limdfill waste as Altematlve 3. complex responsiveness
Capping environment action-specific 160-loot aquifers. but not toxicity or Time to achieve technically due to summary.
through ARARs,lncluding Cover system volume. Most RAOs may be greater number of
- Cover system remediation 01 waste manage- reduces risk from effective reduction reduced by active wells and addition
upper and 160- ment and effluent landfifled waste. lor both upper 160-loot aquiler 01 deeper wells.
- Estimated 6 loot aquilers and disposal. Provides most and 160-loot remediation.
extraction wells capping 01 waste. effective long-term aquilers.
screened In Some worker control.
upper aquifer exposure during
cap construction
- Estimated 1 and Impacts to
extraction well environment,
screened In requiring
160-loot mitigation.
aquifer
160-loot aquifer
- GAC treatment Interim action
and disposal remedy will meet i
by recharge to Interim goals.
uppermost FInal goals for
aquifers environmental
protection will be
established in
subsequent
decision
documents.
Id/MG2685-mg
July 15. 1994
Harding Lawson Associates
2 of 2
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PLATES
-------
Plate 1. Site Map
Record of Decision
Operable Unit 2
Fort Ord, California
. '.V.
'.:" '"0'
r.,'
.""
u
'"
~
FORT ORO)'" ,/
BOUNDARY ", CITY OF I
'. MARINA '
'.. I
'. .-
" /
"'. /:
.,..
.fJlltllIlIl1ll1l
..................
1I.lIlIlIlInlili
1I1I1I1I1I,nllll
.!!!~~!~~~~!!!!!!
3RD STREET
INTER GARRISON ROAD
EXPLANATION
(
Fort Ord Landfills showing approximate 20th century
date of operation as identified from historical aerial
photographs, subsurface exploration, and interviews
with site personnel. Extent of landfills is approximate.
N
I
....-
.;
-....
Approximate extent of Fort Ord Landfills (for illustrative
purposes only) .
o
!
2000
I
4000
I
~.~...-..
-;:.-::.-:.
Approximate extent of excavation along landfills perimeter
APPROXIMATE
SCALE IN FEET
2336604871
042994CIJ
-------
Plate 2.
Conceptual Groundwater Extraction and Treatment
System for the Selected Remedy
Record of Decision
Operable Unit 2
Fort Ord, California
./ Aboveground Water Treatment
/" Facility (Carbon Canisters)
-------
Plate 3.
Conceptual Landfill Cover System Design
Record of Decision
Operable Unit 2
Fort Ord, California
/ Vegetation
,
Foundation
Layer
Manufactured
/ Clay Barrier
0/ /
i
1'6"
j
Local Dune Sand
Existing Local Sand
Approx.
10-12'
bgs
....L
Minimum cover system thicknesses based on
California Code of Regulations, Title 23, Chapter 15,
Article 8, and present site conditions. Final thicknesses
will be determined in the Remedial Design.
. Manufactured barrier will provide the permeability
barrier equivalent to more than two feet of compacted
clay with a rating of to 1 x1 0.7 em/sec.
23366 04871
042994CB
-------
Plate 4. Approximate Extent of Contaminated Groundwater Plume
Record of Decision
Operable Unit 2, Fort Ord Landfills
Fort Ord, California
i.i:;;..i",
". 'II.
!!mmm
'''''.iil;
FORT ORO ).., ./
BOUNDARY./" ", CITY OF /
'. MARINA .
'" /
'. .'
~', /
, '. .
~ '" /
..... '..
-.....
.....
.....
......
o ............
......
......
......
IIUlnl...ltlna
..........It......
"" II IfUIUII "
IIIIIIIIIIIIIIIU
I!'!!!!!!!!!!!!!'
UJ
::>
~
:-
..
o
It
..,
"'"
~
~
.'"
:: '.....
,"" .....--
~ ~ ---"" ..... --..
~:E GROUNDWATER --- ..... .....
.. :;: CONTAMINANT ..... .....
~ PLUME ..... ...... '"::
JRD STREET
,
\
\
I
I
./
....-
--------
INTER GARRISON ROAD
EXPLANATION
o
Proposed Upper Aquifer extraction well
-
/
./
-....
Approximate boundary 01 au 2 contaminated
groundwater plume (for illustrative purposes only)
(
N
I
o
2000
4GCG
APPROXIMATE
SCALE IN FEET
23365 C":~1'
-------
APPENDIX A
APPLICABLE'OR RELEVANT AND
APPROPRIATE REQUIREMENTS FOR
THE SELECTED ALTERNATIVE
-------
A1.0
A2.0
A3.0
A4.0
A5.0
N32348-H
July 15, 1994
. ,- ...,'-.. MO"
.,. .. ....- - - ~ ...
,,-,'-"""".""""
APPENDIX A
CONTENTS
GROUNDWATER CHEMICAL-SPECIFIC ARARS ..,.......... . . ""'" . .,..... .
SOIL CHEMICAL-SPECIFIC ARARs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
LOCATION-SPECIFIC ARARS .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
ACTION-SPECIFIC ARARS ...............................................
SUMMARY OF ARARS FOR MANAGEMENT OF TREATED GROUNDWATER........
United States Department of the Army Aii
1
1
1
2
6
-------
...". .. .-- .. -... ".
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
FOR THE SELECTED ALTERNATIVE
The promulgated standards described below are
chemical-, location-, and action-specific ARARS
for the selected alternative, Upper Aquifer
Cleanup and Landfill Covering with Interim
Groundwater Extraction on the 180-foot aquifer.
The standards described below are "applicable,"
or "relevant and appropriate," or "To Be
Considered (TBCs)" for groundwater and landfill
remediation. These standards are designed to be
protective of human health and the environment
and to be tedmically achievable with existing
analytical and treatment technologies.
A1.0
GROUNDWATER
. CHEMICAL-SPECIFIC ARARS
Federal Chemical-5pecific ARARs
National Primary Drinking Water Standards
(40 CFR Part 141)
(Source: Safe Drinking Water Act, 40
V.S.C. ~300)
Chemical-specific drinking water standards
which contain Maximum Contaminant Levels
(MCLs) have been promulgated under the
Safe Drinking Water Act (SDWA).
Drinking-water goals (MCLGs) also have been
promulgated under the SDW A. MCLGs
above zero are considered chemical-specific
ARARs under the NCP
(40 CFR 300.430[e][2][i][B]). When MCLGs
are equal to zero (which is generally the case
for any chemical considered to be a
carcinogen), the MCL is considered to be a
chemical-specific ARAR, instead of the MCLG
(40 CFR 300.430[e][2][i][C]). These
requirements are considered relevant and
appropriate. Table 1 lists national primary
drinking water standards (federal MCLs) for
chemicals detected in groundwater during the
Operable Unit 2 Remedial Investigation.
N32348-H
July 15, 1994
State Chemical-Specific AIRARs
.
State Primary Drinking Water Standards
(California Code of Regulations [CCR] Title
22, Section 64435)
(Source: California Safe Drinking Water Act,
H&S Code, Div. 5. Part 1, Chapter 7,
Sec. 4010)
California primary drinking water standards
establish enforceable limits for chemicals that
may affect public health or the aesthetic
qualities of drinking water. However, only
those State requirements that are more,
stringent than federal standards are ARARs,
and in this case, relevant and appropriate.
These requirements (state MCLs) are
summarized in Table 1.
A2.0
SOIL CHEMICAL-SPECIFIC
ARARs
No ARARs for soil cleanup levels have been
promulgated by EP A or the State of California for
chemicals of concern at this site. If necessary,
soil cleanup levels may be derived from the
results of the Risk Assessment.
A3.0
LOCATION-5PECIFIC ARARS
. .
No special resources such as wetlands or other
environmentally or historically sensitive
locations have been identified near the landfills
by investigations performed during the RI and
Risk Assessment. Certain endangered plant
species, such as the sand gilia and the monterey
spineflower. have been identified as occurring at
Fort Ord by Jones & Stokes Uones &'
Stokes, 1992).
United States Department of the Army
A1
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Applicable or Relevant and Appropriate Requirements for the Selected Alternative
Federal Location-5pecific ARARs
.
Endangered Species Act, 50 CFR. Part 402
(Source: 16 U.S.C. 1531)
The Act requires action to conserve endangered
species and critical habitats upon which
endangered species depend. Consultations with
the U.S. Fish and Wildlife Service will be
necessary to achieve compliance. This
requirement is applicable.
State Location-5pecific ARARs
.
Fish and Game Code, Chapter 15, Article 15,
Section 2090
The Code contains a raquirement to obtain
written findings from the state Department of
Fish and Game regarding the impact of
disturbances on the viability of an endangered
population. This requirement is relevant and
appropriate.
A4.0
ACTION-5PECIFIC ARARS .
Action-specific ARARs and determinations of
whether requirements are "applicable" or
"relevant and appropriate" are noted in the
following paragraphs. In addition, the action
with which each ARAR is concerned is noted in
the following text.
Federal Action.specific ARARs
.
Underground Injection Control (Ule)
(40 CFR 144.12; 144.26-27)
(Source: Safe Drinking Water Act, 42 U.S.C.
300)
The mc regulations require inventories and
monitoring of recharged water and require
that recharged fluids not contain
concentrations of chemicals that exceed
MCLs. These requirements are applicable to
any alternative involving recharge of treated~-
groundwater. Additionally, if reinjection
standards under the State's Antidegradation
Policy, Resolution No. 68-16, provide more
stringent requirements, these requirements
would be applicable.
N32348-H
July 15. 1994
National Pollutant Discharge Elimination
System (NPDES) Permit (40 CFR 122)
(Source: Clean Water Act, 33 U.S.C. 12511
NPDES permit requirements and standards
must be met for effluent discharges to sw-face
water. The effluent limitations and
monitoring requirements of an NPDES permit
legally apply to point source discharges such
as those from a treatment system with an
outfall to surface waters. If the selectcd
alternative results in a discharge to surface
waters, compliance with NPDES
requirements must be achieved. To
maximize opportunity for effective
management of treated water and minimize
chemical concentrations in discharges, the
Army proposed that concentrations of volatile
organic chemicals in treated water discharged
to the surface will be "not detectable" as
measw-ed by EPA Method 502.2, as shown in
Table 1.
.
Criteria for MuniCipal Solid Waste Landfills,
40 CFR Part 258, Subpart D
(Source: Resource Conservation and
Recovery Act [RCRA), 42 U.S.C. 6901)
These regulations became effective October 9,
1993, and are therefore not applicable to the
Fort Ord Landfills. While these regulations
may be relevant and appropriate, state
requirements provided in Title 14 and
Title 23 (described in more detail below) for
closure of landfills are more stringent than
Subpart D closure requirements and are also
included as ARARs in this section.
.
National Primary and Secondary Ambient Air
Quality Standards (NAAQS), 40 CFR 50
(Source: Clean Air Act, 42 U.S.C. 7409,
7601.)
Section 109 of the Clean Air Act, defines
National Primary and Secondary Ambient Air
Quality Standards (NAAQS), which are listed
in 40 CFR 50. Under certain circumstances,
such as particulate matter generated during
construction, these standards may be
applicable.
United States Department of the Army
A2
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. ill,
Applicable or Relevant and Appropriate Requirements lor the Selected Alternative
RCRA Regulations
Because California is authorized to
administer the RCRA program, State RCRA
regulations cited in CCR Title 22, listed
below, are considered federal requirements.
.
Health and Safety Standards for Management
of Hazardous Waste, CCR Title 22, Divisions
4.5, Chapter 14, Article 9,
Sections 66264.170-178
These standards apply to owners and
operators who store hazardous waste for
longer than 90 days in containers. They
cover use and management of containers,
containment, inspection, and closure. These
standards may be applicable to spent carbon
drums that are stored awaiting offsite
regeneration if they contain hazardous levels
of VOCs. These standards are relevant and
appropriate.
.
CCR Title 22, Division 4.5, Article 16,
Sections 66264.600-603
Applies to owners and operators of facilities
that treat, store, or dispose of RCRA
hazardous waste in miscellaneous units.
Carbon canisters used for groundwater
treatment are considered miscellaneous units.
Covers environmental performance standards,
monitoring. inspections. and post-closure
care. These standards are relevant and
appropriate.
.
Hazardous Waste Landfill Closure
Requirements CCR Title 22; Cahpter 14,
Article 6; Chapter 15, Articles 6, 7, 11, and
14
Title 22 provides for comprehensive
regulation of hazardous waste management,
including generation, transportation, storage,
and disposal of hazardous wastes and applies
to landfills that accepted hazardous waste
after November 19, 1980.
Title 22 requirements pertaining to landfill
closure and post-closure care are not
applicable because there is not documented
evidence that hazardous waste was ever
disposed of in the landfills. In addition,
N32348-H
July 15, 1994
physical evidence collected during the
remedial investigation supports the view that
the landfills were used for disposal of inert
construction materials and household-type
wastes only. If hazardous waste had been
disposed of at the landfills, then usually
higher concentrations of pollutants would be
observed in groundwater, soil, and soil gas at
the site. The levels detected are consistent
with levels detected near municipal landfills
throughout California. Because no
documentation or physical evidence of past
hazardous waste disposal exists, Title 22
requirements dealing with hazardous waste
landfills (closure and post closure care,
groundwater monitormg, and corrective
action programs) are not applicable to closure
of the Fort Ord Landfills.
Title 22 provides for comprehensive
regulation of hazardous waste management,
including generation, transportation, storage,
and disposal of hazardous wastes and applies
to landfills that accepted hazardous waste
after November 19, 1980.
Furthermore, Title 22 closure requirements
are not relevant and appropriate to landfill
closure based on site-specific conditions
because the waste is generally of low toxicity
and the contamination is dispersed over a
large area that bears little resemblance to the
discrete units regulated under RCRA, and
such regulations would not be appropriate.
. -
However, other sections of Title 22 dealing
with the management of hazardous waste are
applicable. Adsorbents and other solid
materials used for treatment of water
containing VOCs, such as activated carbon,
will contain the chemicals after use, and may
be hazardous waste. Title 22 regulations
pertaining to the treatment, storage, or
disposal of such hazardous wastes will be
applicable to the extent that wastes are
managed on site.
.
National Pretreatment Standards,
40 CFR Part 403-S
(Source: Federal Water Pollution Control
Act, as amended by the Clean Water Act)
United States Department of the Army
A3
-------
Applicable or Relevant and Appropriate Requirements for the Selected Alternative
Allows municipalities to determine
pretreatment standards for publicly owned
treatment works (POTWs) within its
jurisdiction. These standards are ARARs
only if treated or untreated groundwater is
discharged to a POTW. Conceptual
groundwater treatment system designs,
however, anticipate reusing treated
groundwater, or returning it to the aquifer
using surface infiltration.
.
Monterey Regional Water Pollution Control
Regulations
(Source: Clean Water Act 40 CFR 403.5 )
The requirements of the Clean Federal Water
Act pretreatment standards are ARARs for
discharge of groundwater to the local sanitary
sewer system. The Act allows municipalities
to determine pretreatment standards for
discharge to Publicly Owned Treatment
Works (POTWs) within its jurisdiction. The
Monterey Regional Water Pollution Control
Agency sets forth standards for monitoring
and reporting, along with effluent quantity
and discharge concentration limits.
State Action-5pecific ARARs
.
Water Quality Control Plan, Central Coast
Basm
(Source: Porter-Cologne Water Quality
Control Act, California Water Code,
Sections 13164, 13170, 13240, 13241)
The Basin Plan establishes numerical and
narrative water quality standards. The Plan
also contains requirements for.
implementation plans or action plans for
attaining compliance with these standards.
The requirements of the Basin Plan are
applicable to groundwater remediation
activities. Each Regional Board promulgates
and administers a Water Quality Control Plan
for ground and surface water basin(s) within
its region. The State Board also promulgates
statewide water quality control plans that the
regional boards administer. The Plans
establish water quality standards (including
beneficial use designations, water quality
objectives to protect these uses, and
N32348-H
July 15. 1994
implementation programs to meet the
objectives) that apply statewide or to specific
water basins. .
State Water Resources Control Board
Antidegradation Policy, Resolution No. 68-16
(Source: Porter-Cologne Water Quality
Control Act, California Water Code,
Sections 13164, 13170, 13240, 13241)
The State Water Resources Control Board's
(SWRCB) "Statement of Policy with Respect
to Maintaining High Quality of Waters in
California," Resolution 68-16, requires
maintenance of existing water quality unless
it is demonstrated that a change will benefit
the people of the State, will not unreasonably
affect present or potential uses, and will not
result in water quality less than that
prescribed by other State policies. Further,
the resolution requires that discharges of
waste to high-quality waters must meet waste
discharge requirements. These requirements
must result in treatment or control of the
discharge to ensure that pollution or
nuisance will not occur, and that the highest
water quality consistent with maximum
benefit to the people of the State is
maintained. Specifically, where any
activities result in discharges to high quality
waters, dischargers shall use the best
practicable treatment or control of the
discharge necessary to avoid pollution or
nuisance and to maintain water quality.
consistent with maximum benefit to the
people of the State. This requirement is
applicable to recharge of the treated water.
See Section 3.3.2, which states that
concentrations of volatile organic chemicals
in discharged treated water will be
nondetectable as measured by EP A
Method 502.2.
These discharge levels were chosen for OU 2
considering site-specific conditions,
including the contaminants to be discharged
and the designated beneficial uses of the
- receiving water, available treatment
technologies, and cost.
United States Department of the Army
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. '
Applicable or Relevant and Appropriate Requirements for the Selected Alternative
Discharges of Waste to Land, Title 23 CCR,
Division 3, Chapter 15
(Source: Porter-Cologne Water Quality
Control Act, California Water Code,
Section 13172)
This Chapter regulates discharges of waste to
land. Article 5, (Water Quality Monitoring
and Response Programs for Waste
Management Units) and Articles 8 and 9
(Closme and Post-Closure Maintenance) are
applicable to this action at the Fort Ord
Landfills. These regulations provide detailed
requirements for: monitoring of water quality
and, if a release occurs, for evaluation of the
impact of discharges, selection of response
programs, and setting of remedial objective
(Article 5); performance requirements for'
landfill covering (Article 8); and landfill
closme in an uTigated area (Article 9).
Specific requirements of Title 23, Chapter 15,
which are applicable, are discussed below.
.
Chapter 15. Landfill Closure, Articles 1, 8,
and 9
Section 2510(d). This section
defines/designates existing waste management
units (WMU) as "waste management units
which are operating, or have received all
permits necessary for construction and
operation on or before the effective date."
Because the Fort Ord Landfills were operating
and received all permits necessary for
operation on or before the effective date of
Chapter 15 (November 27, 1984), the landfill
is considered to be an existing site.
Section 2580(c) requires that Class III
landfills be closed pursuant to Section 2581.
Section 2581 provides specific closure
construction details that must be
implemented.
Section 2580(d) and (e) specify closure and
post-closure specifications regarding survey
monuments and vegetation selection.
Section 2581. Landfill Closure Requirements
provides specific requirements for the final
cover. Subsections (a)(1), (a)(2), (a)(3), and
(a)(4) detail the multi-layer cover design,
N32348-H
July 15, 1994
including acceptable soil types, thickness,
and permeability requirements.
Section 2581(b) provides grading
requiremen ts.
Section 2597. Landfill Closure Requirements
provides specific requirements for landfill
closure in ul'igated areas. Subsections (h)(l)
and (2) require quantification of water
entering, leaving, and remaining onsite and
design of monitoring systems that will detect
penetrations of final cover by precipitation or
applied irrigation water.
.
Chapter 15. GroWldwater Monitoring and
Cleanup (Article 5)
Article 5 includes applicable requu'ements for
groundwater monitoring and cleanup.
Article 5 was updated in 1991 to be in
compliance with federal regulations regarding
land waste disposal. Sections of Article 5
that are appropriate to the selected
alternative include:
Section 2550(a) requires owners and
operators of existing landfills to monitor
ground and surface water and perform
unsaturated zone monitoring as feasible.
Section (d) specifies that monitoring
requirements are applicable dming the active
life, closure, and post-closure periods, unless
all waste residues, contaminated containment
systems components, and contaminated
geologic materials have been removed or .
decontaminated at closme.
Section 2550.1. Required Monitoring and
Response Program. This section specifies
actions including monitoring and corrective
actions required if WMU operations have
impacted ground or surface water.
Section 2550.2 Water Quality Protection
Standard:- This section requires that the
discharger must propose standards to satisfy
the substantive portions of Waste Discharge
Requirements. The standards consist of five
parts:
Section 2550.3. List of Chemicals of
Concern (see Table 1);
United States Department of the Army
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Applicable or Relevant and Appropriate Requirements for the Selected Alternative
Section 2550.4. Concentration Limit for
each Chemical of Concern in each
monitored medium (see Table 1);
Section 2550.5. List of Monitoring Points
and Background Monitoring Points at
which the Standard is applied
Section 2550.5. Description of the Point
of Compliance
Section 2550.6. The length of the
Compliance Period.
Sources of Drinking Water Policy, Resolution
No. 88-63
(Source: Porter-Cologne Water Quality
Control Act, California Water Code,
Section 13140)
This resolution specifies that all ground and
surface water is existing or potential sources
of drinking water unless IDS is greater than
3,000 ppm, the well yield is less than
200 gallons per day from a single well, or the
groundwater is unreasonable to treat using
best management practices or best
economically achievable treatment practices.
The resolution is applicable to the site.
o
Califomia Integrated Waste Management
Board Regulations for Solid Waste Landfills,
Title 14 CCR, Chapter 3, Article 7.8
(Source: California Public Resources Code,
D~is~n3~ .
The only requirement Title 14 provides with
regard to closure at solid waste landfills that
is more stringent than Title 23, Chapter 15, is
a requirement to control trace gases "to
prevent adverse acute and chronic exposure
to toxic and/or carcinogenic compounds."
This requirement is applicable to landfill
closure.
Monterey Bay Unified Air Pollution Control
District (MBUAPCD) Regulation n (New
Sources) and Regulation X (Toxic Air
Contaminants)
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July 15. 1994
(Source: Rule 207; Rule 1000)
The MBUAPCD regu)ates New Sources under
requirements described in Regulation II,
Rule 207, and restricts specific discharges of
organic compounds to the atmosphere
through remedial actions (such as fugitive
odors from consolidation of waste and
removal of organic compounds from
groundwater) in accordance with Rule 1000
of the above-mentioned regulation. The
'MBUAPCD requirements may limit emissions
of total and individual organic compounds
(benzene, vinyl chloride, PCE, TCE, or
methylene chloride) on a site-specific basis
and/or may require emission co;ntrols.
Under Rule 207, emissions of most
individual organic compounds are generally
restricted to 25 lbs/day using Best Available
Control Technology (BACT). Emissions may
be as high as 137 lbs/day under certain
circumstances such as using offsets to
balance the emissions. The limit for vinyl
chloride under Rule 207 is 5.48 lbs/d~y.
Under Rule 1000, the emission limits are
health-based and are expressed in terms of
allowable increased risks of no more than 1
in 100,000 (or 1 x 10-5). Whichever rule is
the more stringent rule of the two would'
apply.
In addition, the MBUAPCD regulates releases
of certain identified or potential air toxics at
levels determined to be "appropriate for -
review." In some cases, a Risk Assessment
may be required. The MBUAPCD
requirements are ARARs for removal of
landfilled waste from the subsurface and for
control and treatment of landfill gases.
AS.O
SUMMARY OF ARARS FOR
MANAGEMENT OF TREATED
GROUNDWATER
.
Discharge to Swface Water
National Pollutant Discharge Elimination System
(NPDES) substantive permit requirements and/or
substantive portions of RWQCB Waste Discharge
Requirements (WDRs) are ARARs for effluent
discharge. The effluent limitations and
monitoring requirements of an NPDES
United States Department of the Army
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Applicable or Relevant and Appropriate Requirements for the Selected Alternative
permit/WDRs are applicable to point source
discharges such as those from a treatment system
with an outfall to surface waters or storm drains.
The storm drain system at Fort Ord discharges
both to the Pacific Ocean and to inland basins.
The RWQCB establishes effluent discharge
limitations and permit requirements based on
Water Quality Standards set forth in the Water
Quality Control Plan, Central Coast Basin.
.
Effluent Infiltration to Subswface
Regulations governing underground recharge of
t.reated wat.er are applicable, and are therefore
ARARs, if treated groundwat.er is recharged. The
Federal Safe Drinking Water Act. requires an
Underground Injection Control (VIC) permit
which, in California, is administ.ered by the EP A
. for wells not related t.o oil and gas activities. The
VIC regulations (40 CFR 1441.13(c)) allow
infiltration of groundwat.er that has been treated
and is being recharged into the same formation
from which it was drawn. The VIC permit is not
required as long as the substantive requirements
of the permit are met. This recharge is allowed if
approved by the EP A pursuant to provisions for
remediation of releases under CERCLA.
The California Toxic Injection Well Act
(California Health and Safety Code Section
25159.24[a]) provides an exemption for recharge
wells provided that the recharge is conducted for
the purpose of improving the quality of the
groundwater in the formation.
.
Discharge to Sewer
Substantive requirements of the Federal Clean
Water Act Pretreatment Standards (40 CFR 403.5)
are ARARs for discharges of groundwater to the
local sanitary sewer system. The Clean Water
Act allows municipalities to determine
pretreatment standards for discharges to Publicly
Owned Treatment Works (POTWs) within its
jurisdiction. The Monterey Regional Water
Pollution Control Agency sets forth standards for
monitoring and reporting, along with effluent
quantity and discharge concentration limits.
These ARARs regarding quality of treated
groundwater discharges will be met.
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July 15, 1994
Reuse
Water may be reused onsite to the extent.
possible. For example, treated groundwater may
be used to irrigate landscaped areas and playing
fields. Onsite reuse would not require a water
reclamation requirement permit from the
RWQCB. Water may also be used offsit.e for
irrigation, subject to approval from the Monterey
County Water Resources Agency.
.
Discharge Limits for Treated Water
To maximize opportunity for effective
management of treated water and minimize
chemical concentrations in discharges, the Army
proposes that concentrations of volatile organic
chemicals in discharged treated water wi!] be
"not detectable" as measured by EP A
Method 502.2. These discharge-limits were
chosen for au 2 after considering site-specific
conditions, including the contaminants to be
discharged and the designated beneficial uses of
the receiving waters, available treatment
technologies and cost, and are provided in
Table 1.
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APPENDIX B
COMMUNITY RELATIONS ACTIVITIES
-------
APPENDIX B
COMMUNITY RELATIONS ACTIVITIES CONDUCTED FOR
FORT LANDFILLS, OPERABLE UNIT 2
The following activities have been conducted
as part of the Army's public relations and
information transfer efforts regarding
environmental restoration activities at
Fort Ord. Presentations, briefings, and/or tours
were given to the following groups or
organizations, or the following meetings.
Superfund presentation to the San Jose
Senior Citizens Group. 06/22/93.
Monterey County meeting. 06/21/93.
Meeting regarding the acquisition of
Fort Ord property by the University of
California. 06/12/93.
Activity
.
Meeting regarding the parcelization
process for Fort Ord base closure in
accordance with the Community
Environmental Response and Facilitation
Action (CERF A). Participants included the
USEP A, Fort Ord Reuse Group, DTSC,
RWQCB, and the Army Environmental
Center. 06/03/93.
Presentation to Pebble Beach Prope11y
Land Owners. 12/07/93.
Public meeting and public comment
period for the Interim Action Feasibility
Study (lAFS). 11/30/93.
California Central Coast Regional Water
Quality Control Board meeting regarding
the Proposed Plan for OU 2. 11/12/93.
Association of 7ID Veterans. 06/01/93.
Marina California, City COWlcil meeting
regarding the Fort Ord Landfills-Operable
Unit 2 (OU 2). 11/09/93.
Fort Ord Reuse Group meeting regarding
the status of SupeIfWld sites throughout
the installation. OS/20/93.
Technical Review Committee meeting
10/27/93.
SuperfWld presentation for Aptos Junior
High, Aptos, California. 04/23/93.
Public meeting and public comment
period for the Fort Ord OU 2 Landfills
Remedial InvestigationlFeasibility Study
(RIIFS). 10/19/93.
Technical Review Committee meeting.
04/21/93. .
.
SuperfWld presentation for the
Watsonville JWlior High School career day
in Watsonville, California. 04/16/93.
.
Fort Ord SuperfWld public relations public
meeting. 09/21/93.
Update with the District Attorney
regarding the progress of Fort Ord's
cleanup activities. 04/16/93.
SuperfWld presentation to the American
Society of Military Engineers in MOWltain
View, California. 07/09/93.
Biological and technical assistance team
meeting regarding the Fort Ord beach front
firing ranges. 04/06/93.
Fort Ord NatlU'al Resources Trustee Day.
06/30/93.
.
SuperfWld presentation for the Pacific
Grove Rotary Club in Pebble Beach,
California. 03/23/93.
EP A Federal Facilities Conference. 06/22-
06/24/93.
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July 15, 1994
United States Department of the Army
B1
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Appendix B
.
CERFA meeting. 03/04/93.
Installation walking toW" and Superfund
presentation to Sierra Club senior citizens'
group. 02/23/93.
Fort Ord Environmental Impact Statement
Public Meeting discussion concerning
Fort Ord disposal and reuse. 02/11/93.
.
Presentation to RAND. 01/19/93.
Technical Review Committee meeting.
01/13/93.
.
Discussion with the National
Oceanographic and Atmospheric
Administration (NOAA) regarding the
proposed sand falls study on the Fort Ord
beach ranges. 01/13/93.
Meeting with Walter Wong. 12/09/92.
.
Environmental restoration presentation
and site toW" for Hartnell College students.
10/14/92.
.
Technical Review Committee meeting.
10/09/92.
.
Walking toW" and Superfund presentation
for Cypress High School students from
Seaside, California. 09/20/92.
o
Meeting with Fort Ord majority counsel
for the Senate Arms Service Committee
and Majority Counsel for the House
Energy and Commerce Committee
regarding the impact of proposal
parcelizatioD legislation. 08/20/92.
.
Community relations meeting with high
school students from the Upward Bound
program. 07/15/92.
Technical Review Committee meeting.
07/08/92.
.
Seminar regarding the Environmental
Restoration of Closing Military Bases in
Sacramento, California. 06/23 - 06/25/92.
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July 15, 1994
Base Realignment and Closure
Environmental Impact Statement status
meeting with Army. COE. U.S. Fish and
Wildlife Services, California Fish and
Wildlife, and Jones & Stokes. 08/25-
01/26/92.
United States Department of the Army
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