United States Office of
Environmental Protection Emergency and
Agency Remedial Response
PB93-964005
EPA/ROD/R04-92/107
August 1992
SEPA Super-fund
Record of Decision:
Marine Corp Logistics Base,
GA
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"'-
NOTICE'
The appendiCes listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content of the document. All supptemental material is, however, contained in the administrative record
for this site.
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50272.101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R04-92/107
I ~
3. Recipienl'a Acceuion No.
4. Tille and Subtitle
SUPERFUND RECORD OF DECISION
Marine Corps Logistics Base, GA
First Remedial Action - Interim
7. Aulhor(a)
5. Aapart Date
08/14/92
6.
8. Perfonning Orl/8lllZ8tion Rept. No.
8. Perfonnlng Orgalnization Name and Addrea
10. Pl'ojectlTaklWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
12. $poIw«ing Organiz8lion N8Ina and Adch88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(G)
13. Type of Repoo1 & Period Cowtr8d
Agency
800/000
14.
15. SUpplementary No,"
PB93-964005
1&. Abalract (Uni1: 200 _nla)
The 3,20Q-acre Marine Corps Logistics Base (MCLB) site is an active military facility
in Albany, Georgia. Land use in the area surrounding the Base is agricultural or
recreational to the south and east, with residential and commercial areas to the north
and west. The site currently serves as a center to control acquisition and
distribution of combat and support materials for the U.S. Marine Corps. In addition,
the Base is used as a training facility for military personnel and other functions of
the Marine Corps. During operations, MCLB has generated various types of solid and
liquid wastes on site, including refuse and hazardous wastes. The hazardous wastes
include electroplating residues containing heavy metals, organic solvents from
stripping and cleaning operations, and waste fuel oil. Because of suspected
contamination from site operations, the Navy conducted several site investigations
between 1985 and 1989. Twelve potential sources of contamination, which were
identified for the RI/FS, were subsequently divided into five operable units for
remedial activities. This interim ROD addresses OU3, which is composed of two
potential sources of contamination: a former leaking transformer location (PSC 16),
and a chrome-plating waste spill area (PSC 17). Both areas are located in the
(See Attached Page)
17. Document AnaJyaia L De8c:ripto/8
Record of Decision - Marine Corps Logistics Base, GA
First Remedial Action - Interim
Contaminated Medium: Soil
Key Contaminants: Organics (PAHs,PCBs), metals (chromium, lead)
b. Iden1ifieralOpen-Endad Terma
c. COSA 11 ReIdIGrcq»
18. AVliIIibiity St8Jement
19. Sec:uri1y a- (This Report)
None
20. Security a- (This Page)
None
21. No. of Pagea
42
I
~ Price
(See ANSl-239.18)
See Instructions on levef8e
(Formerly ~)
Depar1ment of Conmerce
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EPA/ROD/R04-92/107
Marine Corps Logistics Base, GA
First Remedial Action - Interim
~stract (Continued)
west-central portion of the Base. Surface soil from PSC 16 was removed in a prior
action to a 44-inch depth and was replaced with clean soil. Future RODs will address
OUs 1, 2, 4, and 5 at the site, and will also address all related ground water
contamination. The primary contaminants of concern affecting the surface and subsurface
soil of PSC 16 and 17 are organics, including PCBs and PARs; and metals, including
chromium and lead.
The selected remedial action for this site includes covering PSC 16 with a multi-layer
cap, installation of ground water monitoring wells and excavating, and offsite
stabilization and disposal of hazardous soil from PSC 17. Land use restrictions on
future activities within the source areas will be implemented. The estimated total
present worth cost for this remedial action is $717,200, of which $242,200 is allocated
for PSC 16, including an estimated first-year O&M cost of $41,500, and $475,000 is
allocated for PSC 17, with no O&M costs.
PERFORMANCE STANDARDS OR GOALS: The proposed remedy for PSC 16 will meet ARARs;
however, because capping is not a treatment technology, no health-risk based clean-up
goals will be achieved. Contaminated soil from PSC 17 will be stabilized offsite in
accordance with RCRA land disposal standards. Although these actions are intended to be
final for soil, ground water contamination at OU3 will be investigated under a separate
ROD, at which time the ultimate level of remediation to be attained will be determined.
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! - -
u. S. NAVY /
MAI
-------
. ---
DECLARATION FOI\ TI-IE
INTERIM ACTION I~ECOJ~D
OF DECISION
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I)I~CISION SUMMARY
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CONTENTS
SECTION
DECLARATION FOR THE RECORD OF DECISION
DECISION SUMMARY
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
Site Name and Location
Site History and Enforcement Activities
Highlights of Community Participation
Scope and Role of Operable Unit
Site Characteristics
Summary of Site Risks
Description of Alternatives
Summary of Comparative Analysis of Alternatives
Selected Remedy
Statutory Determinations
RESPONSIVE SUMMARY
1.0
2.0
3.0
Overview
Background on Community Involvement
Summary of Public Comment and Agency Response
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DECLARATION FOR THE INTERIM ACTION
RECORD OF DECISION
SITE NAME AND ADDRESS
Marine Corps Logistics Base
Operable unit Three
Albany, Georgia 31704
STATEMENT OF PURPOSE
This Decision Document presents the selected remedial action for
Operable unit "Three of the Marine Corps Logistics Base, developed
in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) as amended by the
Superfund Amendments and Reauthorization Act (SARA), and to the
extent practicable, the National Contingency Plan (NCP). This
decision is based on the Administrative Record which is on file
in the Dougherty County Public Library, and the Environmental
Branch Office, Facilities and Service Division, Building 5501,
MCLB Albany, Georgia 31704.
This interim remedial action is taken to protect human health and
the environment from any threat, while final remedial solutions
are being developed.
Both USEPA and the State of Georgia concur on the selected
remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from
Operable unit Three, if not addressed by implementing the
response action selected in the Interim Record of Decision (ROD),
may present a current or potential threat to public health,
welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
There are 24 Potential Sources of Contamination (PSCs) at MCLB
Albany. Of these, 12 PSCs were identified for the Remedial
Investigation/Feasibility study (RIfFS) Process and were divided
into 5 Operable Units. Operable unit Three consists of PSC 16
and PSC 17. PSC 16 addresses a former transformer location. PSC
17 addresses a chrome plating waste spill area. The scope of
this Interim ROD is limited to Operable Unit Three.
The selected remedy for Operable Unit Three, PSC 16, includes the
following: -
- Installation of a multilayer cap over the surface area of
the site.
- Implementation of land use restrictions on future
activities within the source area.
-------
- Excavation and off-base disposal of sediment in the bottom
of the catch basin adjacent to PSC 16.
- Groundwater monitoring.
The selected remedy for Operable unit Three, PSC 17, includes the
follm..,ing:
- Excavation and stabilization of the contaminated soil,
with off-base disposal at a permitted landfill.
STATUTORY DETERMINATIONS
The selected interim remedial actions are protective of human
health and the environment, comply with Federal and state
requirements that are legally applicable or relevant and
appropriate to the remedial action, and are cost-effective. The
interim remed~al actions utilize permanent solutions and
alternative treatment technologies to the maximum extent
practicable for this site. Soils from PSC 17 will be treated and
disposed of off-base. However, soils at PSC 16 will remain on-
site. Because this interim remedial action does not constitute
the Final Remedy for the Site, the statutory preference for
remedies as a principle element will be addressed by the final
response action.
Because this remedy will result in hazardous substances remaining
on-site above health based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
Signature
F. X. amilton
Major General
Commanding General, MCLB Albany
~jij j -1 l:~t.
Date
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1.0
SITE NAME, LOCATION AND DESCRIPTION
MCLB Albany is an active facility occupying approximately 3,200
acres 5 miles east-southeast of the City of Albany, Georgia
(Figure 1). Land bordering MCLB Albany to the south, east and
northeast is primarily agricultural or recreational open space.
The land to the northwest and west of the Base is dominated by
residential and commercial areas of eastern Albany.
Both locations of Operable unit Three are located in the west-
central portion of the Base. PSC 16 (Figure 2A) is the former
location of an electrical transformer and supporting concrete
pad, approximately 12 feet by 16 feet in size, adjacent to
Building 7100. PSC 17 (Figure 2B) is located adjacent to the
Central Repair Building (Bldg 2200) between a drum staging area
and the Weapons Test Firing Building (Bldg 2226).
MCLB Albany currently serves as a military logistics center.
1
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5OOO
10.000
ALBANY
MCLB ALBANY Vi
FIGURE 1
VICJNITY MAP
'
ME*
coNcnert
SURFACE
tOUHUB/T
XX
Bica. ?i«
XXX"
UWEKOACU10
ajcnocM.
CONDUKS
X
N
N
\
\x
RGURE2A
FENCE SURROUNDING BUILDINGS 2200,
2226, AND PSC 17 100 FEET WEST
FIGURE 2 B
PSC 17 SCHEMATIC
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2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
MCLB Albany currently serves as a military logistics center,
controlling the acquisition, storage, maintenance, and
distribution of combat and support material for the Marine Corps.
In addition, the Base is used for training of military personnel
and other tasks and functions as directed by the Commandant of
the Marine Corps.
MCLB Albany has generated various types of solid and liquid
wastes over the years, including refuse and hazardous wastes.
The hazardous wastes include electroplating wastes containing
heavy metals; organic solvents from stripping and cleaning
operations; and waste fuel and oil.
Commencing in 1985, three investigations were performed to assess
and characterize PSCs identified at MCLB Albany. These
investigations included the 1985 Initial Assessment study (IAS),
the 1987 Confirmation study, and the 1989 RCRA Facility
Investigation (RFI). As a result of these investigations, MCLB
Albany was placed in Group 7 (Hazard Ranking System score of
45.91 to 43.75) of the National Priority List (NPL) for
Uncontrolled Hazardous Waste sites. MCLB Albany was placed on
the NPL in December 1989.
In July of 1991, the Department of the Navy, representing MCLB
Albany, entered into a Federal Facilities Agreement with the
Georgia Environmental Protection Division (GEPD) and the EPA to
establish a procedural framework and schedule for developing,
implementing, and monitoring appropriate response actions at the
site in accordance with CERCLA, RCRA, the NCP, Superfund guidance
and policy, and the Georgia Hazardous Waste Management Act
(GHWMA) . .
The following reports describe the results of investigations at
Operable Unit Three to date:
SOUTHNAVFACENGCOM, Multiple Use Natural Resources Management Plan
for Marine Corps Supply Center, Albany, Georgia, 1974.
SOUTHNAVFACENGCOM, Master Plan, MCLB Atlantic, Albany, Georgia,
1978.
Crawford, V.I., Environmental Engineering Survey, Marin~ Corps
Logistics Base (MCLB), Albany, Ga.: Naval Facilities Engineering
Command (NAVFACENGCOM), Southern Division, 1979.
Envirodyne Engineers, Inc., Initial Assessment Study -- Marine
Corps Logistics Base, Albany, Georgia, 1985.
3
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McClelland Engineers, Final Report, Confirmation study
Verification step, Marine Corps Logistics Base, Albany, Georgia:
Prepared for Southern Division, Naval Facilities Engineering
Command, 1987.
Applied Engineering and Science, Inc., RCRA Facility
Investigation Phase One Confirmation Study, MCLB Albany, Georgia,
1989.
USEPA, site Investigation Report for Operable unit Three, MCLB
Albany, Georgia, 1991.
ABB-ES, Initial Evaluation of the Remedial Investigation Data for
PSC 16 and PSC 17, Marine Corps Logistics Base, Albany, Georgia:
ABB Environmental Services, Inc., Tallahassee, Florida, 1992.
Remedial Investigation/Feasibility Study (RI/FS) Report, Operable
unit Three, MCLB Albany, Georgia, 1992.
Proposed Plans for Operable Unit Three, MCLB Albany, Georgia,
1992.
4
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3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Remedial Investigation/Feasibility study (RI/FS) Report and
the Proposed Plans for Operable unit Three were released to the
public on 13 July 1992. These documents were made available to
the public in the Information Repository located at the Dougherty
County Public Library, and in the Administrative Record. located
at the Public Affairs Office, Bldg 3500, Marine Corps Logistics
Base, Albany, Georgia 31704-5000. The public comment period for
the Proposed Plans was July 13 - August 13, 1992. The public
notice of the RI/FS Report and Proposed Plans was published in
the Albany Herald on July 12, 1992, and in the Atlanta Journal
and Constitution on July 16, 1992. A public meeting was held on
July 21, 1992 in Albany. At this meeting, representatives from
USEPA, GEPD, SOUTHDIV, and MCLB Albany were available to answer
questions about Operable Unit Three and the remedial alternatives
under consideration. No written or verbal comments were received
at the public meeting or during the public comment period.
However, a Responsiveness Summary is included as part of the
Interim Record of Decision.
The Proposed Plans identified the preferred remedy for PSC 16 as
Alternative 3. Alternative 3 is described in the Feasibility
study (FS), Operable Unit Three as follows: construction of a
multilayer cap, reinstallation and maintenance of fencing and
security, land use restrictions, installation of monitoring
wells, and monitoring of groundwater quality. The preferred
remedy identified for PSC 17 is Alternative 4B. Alternative 4B
is described in the FS, Operable Unit Three as follows:
excavation and transportation of contaminated soil to a permitted
facility, stabilization, and disposal at a landfill. Because no
written or verbal comments were received, USEPA, GEPD, SOUTHDIV,
and MCLB determined that no significant changes to the Proposed
Plans preferred remedies were necessary.
5
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4.0
SCOPE AND ROLE OF OPERABLE UNIT THREE
The overall strategy for remediation of the MCLB Albany NPL site
is currently divided into five operable units. The remedial
actions selected in this Interim ROD apply to Operable Unit
Three. Further investigations continue or are planned for the
remaining operable units.
Operable Unit Three is comprised of two PSCs: PSC 16, located
adjacent to Building 7100, and PSC 17, located adjacent to the
Central Repair Division (Bldg 2200). Both PSC's are located in
the west-central portion of the Base. The proposed interim
remedial actions are limited to the surface and subsurface soils
at PSC 16 and PSC 17. Groundwater contamination will be
investigated as media of potential contamination concurrently
with other PSC's under a separate operable unit.
The overall strategies of the selected remedies for Operable Unit
Three are:
Control the release of hazardous substances.
Minimize the potential direct exposure to hazardous
materials.
Control the potential for releases of hazardous substances
to the groundwater near the two PSC's.
rhese strategies will be achieved by the covering of PSC 16 with
a multilayer cap, and the excavation, stabilization and off-base
disposal of hazardous soils from PSC 17. The interim remedial
actions selected in this Interim ROD are intended to be final
actions for the soils at these PSC's.
These interim remedial actions will be consistent with any
planned future actions, to the extent possible.
6
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5.0
SUMMARY OF SITE CHARACTERISTICS
5.1
GEOLOGY
MCLB Albany is located in the Dougherty Plain district, which is
part of the Coastal Plain physiographic province. The-Albany
regional geology is characterized by layers of sand, clay,
sandstone, dolomite, and limestone that dip gently and
progressively thicken to the southeast. These sediments extend
to a depth of at least 5,000 feet below land surface (bls).
The sediments of interest at MCLB Albany (sediments that affect
the hydrology of the Upper Floridan aquifer) are of late middle
Eocene age and younger including, in descending order, the
undifferentiated overburden of Quaternary age, the Suwannee
Limestone, the Ocala Limestone, the Clinchfield Sand, and the
Lisbon Formation. The location and geological section of the
Albany area are presented in Figure 3.
5.2
HYDROGEOLOGY
There are two principal hydrostratigraphic units of interest at
the MCLB: the undifferentiated Quaternary overburden deposits
and the underlying Upper Floridan aquifer (Ocala Limestone) .
within the overburden, most sand or clay layers are
discontinuous; however, a thick clay zone apparently persists in
the lower half of the overburden throughout the MCLB Albany area.
This clay zone, ranging in thickness from 10 to 29 feet, serves
to cause intermittent perched groundwater conditions in the
l>.
overburden, decrease the amount of groundwater recharge to the
Upper Floridan aquifer from infiltration of precipitation, and
control the rate of infiltration of chemical contaminants.
Groundwater is normally found within the overburden and was
measured at depths ranging from 15 to 95 feet bls in MCLB Albany
monitoring wells in May 1991.
The Upper Floridan aquifer, consisting primarily of the Ocala
Limestone, ranges from about 200 to 275 feet thick in the area of
the MCLB. The aquifer is confined above by the clayey overburden
and below by a low-permeability layer in the Lisbon Formation.
Large quantities of water are stored and transmitted within the
aquifer and the Upper Floridan has recently been studied and
judged to be favorable for large-scale water withdrawal. The
aquifer is regionally unconfined, semi-confined, or confined by
the overlying soils, and the rate of recharge depends primarily
on the vertical hydraulic conductivity of the overburden. The
rate of mean annual recharge to the aquifer is reported to be on
the order of 6 to 14 inches per year (in/year). The Upper
Floridan aquifer is divided into an upper zone (with greater
density) and a lower zone (with greater permeability due to
sOlution-enlarged joints, bedding planes, and fractures). These
7
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*—I
.-I
Upp«r FlarliUn AqutUr
W»B
G»ophf*I:«l Legs
C Cillpw
Q Mitufil Qwimi
ft
II KM II
FIGURE 3
GEOLOGIC SECTION OF
THE ALBANY AREA
MARINE CORPS
LOGISTICS BASE
ALBANY, GEORGIA
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solution cavities can produce transmissivity values as high as
15,000 square feet per day (ft2/day).
Published studies of the Upper Floridan aquifer indicate that the
potentiometric surface slopes westerly to southwesterly in the
MCLB Albany area (Figure 4). The aquifer discharges water to the
Flint River and local streams where the streams have incised into
the aquifer or where the potentiometric surface exceeds the
surface water elevation. The relationship can be reversed
locally during dry periods when the potentiometric surface drops
and streams discharge to the aquifer.
5.3
ECOLOGY
The majority of forested land in the vicinity of the Base is
vegetated with longleaf pine flatwoods, the most extensive floral
community in the southern coastal plain. Also known as pine
flatwoods, pine flats, low pinelands, or pine barrens, this low
flat woodland habitat occurs transitionally between upslope xeric
sandhill communities and downslope shrub-dominated evergreen
wetlands. pine flatwoods occur throughout Florida, and northward
into Georgia, South Carolina, and North Carolina.
The high level of herbaceous productivity in the pine flatwood
habitat frequently supports a rich invertebrate faunal community.
This invertebrate community often supports a number of
insectivorous vertebrates, including 20 to 30 species of reptiles
and amphibians. A number of small mammals inhabit the flatwood
community although no mammal is exclusive to this habitat.
Depending upon the vegetative association, pine flatwoods provide
habitat for a diverse array of avifauna, including insectivorous
gleaners of pine needles and bark, flycatchers, a seed eating
assemblage, and nocturnal and diurnal aerial predators. The red-
cockaded woodpecker (Picoides borealis), a federally endangered
species, occurs almost e}~clusively within this pine flatwoods
habitatj however, there are no known records for this species at
MCLB Albany. .
The presence of two rare and endangered species has been
confirmed at this facility. The American alligator (Alligator
mississippiensis), has been documented in wetland habitats at the
Base; this semi-aquatic species is ubiquitous throughout the
southeast. Bachman's Sparrow (Aimophila aestivalis), a State and
federally endangered species, is also a possible resident of the
dry open pine forests at MCLB Albany; this large, secretive
sparrow is a year-round resident of southern Georgia.
9
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/ / 1IL*
/ / incjr
PolonlkxiKlrt IcopieUvShowe c-'llluric cl tvK£
havt stood b I'iil caofrd t»»it.
Dnehad whore opprcutnateiy locatoo. Canicur tntorvsi
Is 10 loot Datum U NGYD or 1S29
ecUon of
proondwatof Dow
FIGURE 4
POTENTIOMETRIC SURFACE OF THE
UPPER FLORIDAN AQUIFER IN THE
ALBANY AREA, NOVEMBER, 1985
MARINE CORPS
LOGISTICS BASE
ALBANY, GEORGIA
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5. 4 tJA'l'URE AND EXTEU'l' OF CmITAMH1A1ITS
The nature, extent, and concentration of hazardous substance
contamination at PSC 16 was studied during field investigations
performed in 1990 and 1991. Field studies at PSC 17 were
conducted in 1990, 1991, and 1992. The following summarizes the
major observations from the previous investigations.
5.4.1.
Contaminants Potential of Concern
Hazardous substances detected in the soil at PSC 16 and PSC 17
are listed in Tables 1A and lB. To provide a focus for remedial
action objectives, contaminants potential of concern (CPC) were
identified in the Baseline Risk Assessment of the RI report. The
following factors were considered in the selection of CPC:
- Concentration and frequency of occurrence
- Distribution in the soil at the site
- Regulatory criteria and toxicity
A summary of the number of samples with detections and the
concentrations found are presented in Tables 2 and 3 for each of
the CPC at PSC 16 and PSC 17. Of the CPC identified in the RI,
Aroclor-1260 (PCB) at PSC 16 and chromium (total) at PSC 17 were
the most widely distributed and typically at higher
concentrations than other constituents. They are considered to
be representative of the distribution of constituents at each
location.
5.4.2
Contaminant Sources
PSC 16 is the former location of an electrical transformer and
supporting concrete pad. During an inspection conducted as part
of a polychlorinated biphenyl (PCB) transformer change-out
program, evidence of leakage of transformer oil was observed on
the concrete pad beneath the transformer. As a result,
contamination is present in the subsurface soil.
At PSC 17, a spill of chrome plating waste occurred at a spot
approximately 40 feet northeast of Building 2226 sometime prior
to October 1989. The contaminants subsequently migrated
downhill, and now cover an area of approximately 425 square feet.
As a result, contamination is present in both surface and
subsurface soil.
11
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-.. .. .-..----. ---.---.---.- ..- --... .. ---- ..
.-.-----.--- ..-
._--. -------
Tuble 1/\
Contaminallt:1 of !'otcnlial ConcNn (PSC IG)
fu/r'; r.\CI.II/%all~'
'..11 lilny. nlJor~Ji;\
.-.----.---- -.----
Somlvolatiln
compou/1ds:
Sill racf~ ~3()il:;
SlIbSlJI fllco Soils
1,2,t\-Trichloroucnwno
HexachlorolJenzDllc
Per Ilachio r 0 I >e r IZP. r 10
1 ,2,4.!1-TfJlraclllorobn/17.U1I()
TelrachlorolJenzeJw (;~ iSOIlWIS)
Trichlorohenzc/1c (nntl ,;7,'1-)
x
X
X
X
X
X
Pestlcides
and PCBs:
Aroclor-12(jO (r'Clh)
X
--.---..,.-..---- '--'...-.'-'.--.'
Notos:
PCBs = polychlorirlalud li!vL'!:!.!.Yl::_. .-.------- ..---- -._u_..--..
---------.--.-
Table 11',
COI'-!TMJIIJANTS OF POTENTIAL CONCERN
PSC-17
r-U/F~ t.1CLB ALBANY
ALBANY. GEOnGIA
__-0____'_',--------
Sur lace Subsurface
Sarnivolatllo Compounds: Soil Soli
Bonzo{a)anthracono X
Bonzo{b and/or k)/luoranlhollo X
Chrysans X
Pyrollo X
Pesticides and PCBs:
- ----------.. ---
Aroclor-12GO (PCU5) X
Inoroanlcs:
Chromiulll (lrlvalon!) X X
Chromium (hoxavalonl) X X
Load X X
--.-..- ---...---- ----.__.---
1:':
-------
..-- - --,---_.. -- ------
.._--,
. . -. _h.-'___._", U- -.. .
. '---.--'
'j ABLE :2
~;( J:'A:.tAII'f OF ~IJlI~Unr-ACE ~OIL [)ATA ..
\' SC Hi
r.H.I.III\II'''IIY
1\11';111)'. (;001 ui'l
---'-.'
.-----..-.---...--.. --_. ...---.-..---..---_u_--- .. --,.--.
COI.II'OUIIU
IIIEulJUICY
Of
liE 1"[<: 11 0 II
!Ii:! lC I ED
COtICUllllf,11011
---.-..-..- ---.- .~_._- -. -.
-.. _._.-.---.-..---
SEIAIVOI.AlllE onOAIIIC!> (l/g:l-g)
1.2.4 - T,ichlolObollzono
Iloxochloroo'JllzolIO
l'olllaclliClotJOIIZI.W,O
1,2.4.5- Tolrochlcl'oboll7.ono
Tolrochlaobollzollo (2bom«o)
1 lic hlocohollZ uno (nol 1,2.4-)
:if{i
:I~/..J -- UO,III/)
(;(~I .1 - :>.;>ooJ
1.(1110.111.. (.O,lIlH)JII
:'.tJolI.J/1
n.III1I1.III. ;'IIII.O{ltJ JII
"(Yo! JII .. .W.lltXIJII
:):r.
li;'()
1!1
~ , ! ~ ,
,'/I-
;.I..t
PESl1CIOES/I'CU$ (ug/hll)
AlOctOl - 12CO
(ji~)
J:I.C!IJO ,; . ;\\O.CO?C
Noles:
J = eslinalod voJUO.
N = pro8urnpliw O\icJOIICO (',/ ,',{OOOIlCO ollllutu inl
tlO = noldolocllId.
tlA = not Malyzod
till = nollopcx lod
C ~ cOllfirnod by GC/M3.
1 ConcolIl/alionln mg/k(l. Oock{1ouflu cOllc""lIlIliIJIl" 1101",',0.) "" PSC II ),lId..!} ""'1<1 :,;",,1'110.
. _lnch~~£!..~!IY.!.~I~!!!"'!!!~.!Q~1 USEPA $..npli'.'!I'.. .--' -.-..-.....-.. .-- ..''''''- --... ..... .. . -...-. -'-'
--.- --_.. - --- ---.
TAULE 3
SUMMARY OF USEPA. HJ!J1 AND ABB-ES, 1992 SUflFACE SOIL DATA 1
PSC H
MCLB 1\lbany
Albany, Georgia
-f:11E6UElic{'or--rtr.,NGEoF-ijE1EcTEO--
DETECTIOIJ cor.JCENTMTlON
AVEMGE
CONCENTRATION ~
COMPOUND
-.---------.
SEMNOLATILE onC:W-lICS (ug/kg)
Bonzoio) o1nll1lac ono
Bonzo (b/k) flu o/(l111hone
Chrysono
Pylon 0
1 .~
I~
1/2
1 f.!
ir~
G~O J
1,-100 J
6BO J
1,4ro
620.
1,050
GOO.
1,050
PCBs/PESTICIDES (ug/kg)
Aroclol-1260
123
If.?
1(j() J
METALS (mgJkg)
Chromium (tobl)
Chlomium VI
Leod
B/~1
Ir3
8r~
5.3.J-':9,oa:)
07.0
:>.0-3,900
7,036
29
517
AVEJlIIGE
COIICEIIII\A 11011
17,5W
!I~~I
1 ~i.50()
:>.IJOO
r.I,4UJ
10, !JIIIJ
1:!I,UJ:1
..-.-...- ...~--
----.-.---.-
Notes:
1 Soil dopths down 10 18 inchos
~ Non-dol~c~ w.0ro assl\1'lod ",o-hol/ 01 Stllllplo OuaIl~tQlion Urnit (SOl.) for calculation 01 ovorage.
POIOlllho$IS IOUICDlo olomonlwll$ nol dotodod ;. l.'lc:1:oround :;:)1111'10. Voluo il rXtlondlosis is ~Ie dotoclion tirnil
J = ostimnlodvufue
ND = Nd dotoctod
. Maximum conconlrlliion gilon 1.>0011150 IIVOIOOO COIIC'IHlltali(; i~ II/onlor U,nll muximum.
.~. . ".'---'_U' --'---~'--------_._.
13
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6.0
SUm£~RY OF SITE RISKS
The actual or threatened releases of hazardous substances from
Operable unit Three may present a current or potential threat to
public health, welfare, or the environment.
6.1
PSC :L6
Risk assessments were conducted on PSC 16 to quantify public
health and ecological risks associated with exposure to soils.
Only subsurface soils were evaluated in the risk assessment, as
surface soils (to a depth of 44 inches) were removed in a prior
action and replaced with clean soil. The CPC's identified at PSC
16 are listed in Table 1A. The only potential exposure for the
PSC could occur at some future date as a result of construction
for either military or residential use. Construction workers
could be exposed to subsurface soils for a limited time period by
incidental ingestion of, and/or dermal contact with soils. The
inhalation pathway was not evaluated because the CPC's are not
volatile, and significant wind erosion of particles would not be
anticipated from an excavation.
A total carcinogenic risk estimated for current and potential
future nonresidential and residential use of the PSC is three in
100,000 (3X10-3) and a noncarcinogenic hazard index of 0.7 was
estimated for these exposures. The carcinogenic estimated risk
is within USEPA's target risk range of one in 10,000 (10-4) to
one in one million (10-6). The substance which contributes most
significantly to risk is a PCB, Aroclor 1260. The hazard index
(HI) is less (more protective) than the target HI of 1 identified
by USEPA. The noncarcinogenic HI represents an overestimate of
actual risk. This is because the chemicals which dominate the
HI, two tetrachlorobenzene isomers (1,2,4,5-tetrachlorobenzene)
with relatively high toxicity were used in the risk assessment to
represent the other isomers. Thus, the actual hazard is probably
lmver .
The developed nature and lack of any open space at PSC 16
preclude the use of this PSC by any terrestrial ecological
receptors. In addition, the top 44 inches of soil were excavated
and replaced with clean soil, thus ecological receptors are not
at risk of exposure to chemicals detected at PSC 16.
6.2
PSC 17
Risk assessments were conducted on PSC 17 to quantify public
health and environmental risks associated with exposure to soils.
Both surface and subsurface soils were evaluated. The CPC's
identified at PSC 17 are listed in Table lB. Both current and
potential juture uses of the PSC were considered in the exposure
assessment. Current use of the PSC is limited to Base workers
that could work near or walk by the area. Exposure pathways
14
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identified for this use were incidental ingestion and direct
contact with surface soils and inhalation of wind-eroded
particles. There is no current exposure to subsurface soils.
the future, use of the PSC could continue as it is presently.
Alternately, the PSC could be developed for residential uses.
In
Exposures associated with future residential use of the PSC
include exposure of both children and adults to surface soils via
incidental ingestion and direct contact with soils, and
inhalation of wind ~roded soil particles. Workers could also be
exposed to subsurface soils during construction at the PSC.
Exposure pathways would include incidental ingestion and direct
contact with soils for a limited period of time.
Figures 5 and 6 present"carcinogenic risks and noncarcinogenic
hazard indices, respectively, associated with exposures to
surface soils. A total carcinogenic risk estimated for current
and potential future nonresidential use of the PSC is one in ten
million (1X10-7). This is less (more protective) than the
acceptable risk range of 10-4 to 10-6 specified by USEPA. The
noncarcinogenic HI for this use is 0.1. This is also more
protective than the target HI of 1 identified by USEPA. For
future residential land use, a total carcinogenic risk and
noncancer hazard index associated with exposure to surface soils
of five in one million (5X10-6) and 5, respectively, is
estimated. The estimate of carcinogenic risk is within the
acceptable risk range specified by USEPA. The noncancer HI is
greater than the target HI of 1 identified by USEPA. Exposure of
construction workers to subsurface soils is estimated to result
in a total hazard index of 0.04. No carcinogenic CPC's were
identified in subsurface soils. The hazard index is more
protective than the target HI of 1 identified by USEPA.
An ecological risk assessment was conducted to determine the
possible adverse effects associated with surface soil exposure by
terrestrial wildlife. Terrestrial organisms (i.e., birds,
mammals, reptiles, and terrestrial invertebrates) at PSC 17 may
be exposed to chemicals in surface soil via incidental ingestion
of surface soils, ingestion of prey items that have
bioaccumulated chemicals in their tissues, and dermal uptake. A
food web model (i.e., a model evaluating which species eat which
species, and how much each consumes) was developed to estimate
the potential dietary exposure levels of contaminants for several
potential receptor species representing various trophic levels
within the ecological community at MCLB Albany.
The average concentrations of trivalent chrome and hexavalent
chrome used in the food web model are greater than any
concentrations detected in the spill area except for the point of
spillage. This results in the model representing a very
conservative scenario for the PSC.
15
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FIGURES
CANCER RISK ESTIMATES
FOR SOIL EXPOSURES
HAZARD INDEX ESTIMATES
FOR SOIL EXPOSURE
gagBKsgEiBia^^
lh
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The results of the ecological risk assessment indicate that
possible adverse effects are associated with surface soil
exposure by terrestrial wildlife. These possible effects consist
of long-term effects on survival and reproduction, which may have
population-level consequences. The overall type and distribution
of contaminants in surface soils strongly suggests effects from
lead and chromium. CPC's are listed in Table lB.
Five indicator species were selected to represent exposure to
terrestrial organisms surface soil and food sources:
short-tailed shrew
woodcock
garter snake
red fox
red-tailed hawk
Estimated HI's for all modeled receptor species exceeded 10,
suggesting that environmental contamination associated with acute
exposures at PSC 17 could potentially impact ecological receptors
that use this area of the Base.
Adverse chronic effects are indicated only for small mammals
(i.e., short-tailed shrew). The risk analysis suggests that
other receptors (i.e., reptiles, birds, and predatory mammals)
would be much less likely to be adversely affected due to chronic
exposures to any CPC's at the PSC. Possible adverse chronic
effects are predicted for small birds and reptiles. The surface
soil contaminants, lead and chromium, contribute most
significantly to the overall hazards predicted at PSC 17.
17
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7.0
DESCRIPTION OF ALTERNATIVES
The following is a description of the alternatives evaluated in
the FS for Operable Unit Three
7.1.
Alternative 1. -- No Action
Consideration of a no-action alternative is required by the NCP.
Under Alternative 1, no response actions would be implemented.
Estimated
Estimated
Estimated
Estimated
capital Costs: $0
First-Year Operations and Maintenance
Present Worth Costs: $0
Implementation-Time-Frame: 0 Months
(O&M) :
$0
7.2
Alternative 2 -- Limited Action
The limited action alternative incorporates the maintenance of
the chain link fencing/security measures currently implemented at
PSC 16 and PSC 17, groundwater quality monitoring, and the
institution of future land use property restrictions. The
contaminated soils will remain in-place and untreated. Costs are
associated with the installation of monitoring wells, and the
collection and laboratory analyses of groundwater samples.
Estimated
Estimated
Estimated
Estimated
capital Costs PSC 16: $28,100
First-Year O&M PSC 16: $37,000
Present Worth Costs PSC 16: $188,300
Implementation Time-Frame PSC 16: 1 Month
Estimated
Estimated
Estimated
Estimated
Capital Costs PSC 17: $9,000
First-Year O&M PSC 17: $21,000
Present Worth Costs PSC 17: $99,900
Implementation Time-Frame PSC 17: 1 Month
7.3
Alternative 3 -- Multilayer Cap
Alternative 3 will incorporate the construction of an impermeable
clay liner and a flexible membrane liner beneath the surface of
the contaminant areas. Reinstallation and maintenance of
security and fencing and land use restrictions will be
implemented and groundwater monitoring wells will be installed to
monitor the groundwater quality. The surficial capping of the
PSCs will reduce the infiltration of surface water and the
potential migration of the contaminants. The surface layer will
consist of bituminous concrete at PSC 16, and loam and seed at
PSC 17.
Estimated.Capital Costs PSC 16: $64,700
Estimated First-Year O&M PSC 16: $41,500
Estimated Present Worth Costs PSC 16: $242,200
Estimated Implementation Time-Frame PSC 16: 2 Months
18
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Estimated
Estimated
Estimated
Estimated
Capital Costs PSC 17: $80,700
First-Year O&M PSC 17: $25,200
Present Worth Costs PSC 17: $190,000
Implementation Time-Frame PSC 17: 2 Months
7.4
Alternative 4A -- Excavation and Incineration
Alternative 4A involves the excavation of the contaminated soils
at PSC 16 and the transportation of these soils to an offbase
incinerator for treatment and disposal of the residual ash. The
incineration of the soils will potentially destroy up to 99.9% of
the contaminants.
Estimated
Estimated
Estimated
Estimated
Capital Costs PSC 16: $327,800
First-Year O&M PSC 16: $0
Present Worth Costs PSC 16: $327,800
Implementation Time-Frame PSC 16: 2 Months
7.5
Alternative 4B -- Excavation and stabilization.
Alternative 4B incorporates the excavation and transportation of
the contaminated soils from PSC 17 to a permitted facility for
stabilization and disposal at a landfill. Stabilization of the
soils will reduce the solubility and mobility of the
contaminants, thereby reducing the potential migration of the
contaminants.
Estimated
Estimated
Estimated
Estimated
capital Costs PSC 17: $475,000
First-Year O&M PSC 17: $0
Present Worth Costs PSC 17: $475,000
Implementation Time-Frame PSC 17: 3 Months
7.6
Alternative SA -- Excavation and Disposal at Landfill
Alternative 5A requires the excavation of the contaminated soils
from PSC 16 and their disposal at an offbase permitted landfill.
Estimated
Estimated
Estimated
Estimated
Capital Costs PSC 16: $198,200
First-Year O&M PSC 16: $0
Present Worth Costs PSC 16: $198,200
Implementation Time-Frame PSC 16: 2 Months
7.7
Alternative SB -- Excavation and Soil Washing
Alternative 5B combines the excavation of the soils from PSC 17,
the washing of the contaminated soils and the backfill of the
treated soils into the excavation area. A small quantity of
residual wastes from the soil washing process would be
transported and disposed of off-base at a permitted landfill.
Washing the soils with a liquid medium will strip the
contaminants from the soils into a concentrated residual process
waste.
19
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Estimated
Estimated
Estimated
Estimated
Capital Costs PSC 17: $606,100
First-Year O&M PSC 17: $0
Present Worth Costs PSC 17: $606,100
Implementation Time-Frame PSC 17: 4 Months
20
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8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
8.1
PSC 16
8.1.1
Overall Protection of Human Health and the Environment
The human health risk assessment determined that the potential
exposure to the contaminants in the subsurface soils at PSC 16 is
limited to two pathways. These include dermal contact and
incidental ingestion by construction workers, for potential
future land use. The ecological risk assessment determined that
no exposure pathways currently exist at PSC 16 for ecological
receptors, due to the absence of surface soil contamination.
While the human health risk assessment identified risks which are
within or less than the USEPA's target risk, it was determined
that remediation of the PSC would be a prudent course of action.
Therefore, the overall protection of human health was evaluated
for all five of the remedial alternatives applicable for PSC 16.
Alternative 1 and 2 would provide little or no protection, due to
the limited actions taken to eliminate the potential exposure
pathways. Alternative 3 would protect human health by
eliminating the potential ingestion and dermal contact with the
identified subsurface contaminants. PCBs tend to be immobile,
however, monitoring of the groundwater would further ensure the
protection of the public. Alternatives 4A and 5A would provide
the long-term protection to the public by the excavation and off-
base treatment/disposal of the soils. However, potential
exposures to the construction workers and public would be
encountered during the excavation of the contaminated soils.
8.1.2 Compliance with ARARs
Alternatives 1 and 2 would not comply with the chemical-specific
ARARs because no actions would be implemented to meet the RCRA
storage of hazardous waste requirements. Alternatives 3 and 5A
would meet the federal and state ARARs, but would not meet the
health-based TBC's because these alternatives only contain the
contaminants and do not treat them. The containment of the
contaminants will be accomplished by the capping of the area or
the excavation and off-base disposal of the soils at a permitted
facility. Remedial alternative 4A can comply with all of the
chemical-, location-, and action-specific ARARs.
8.1.3
Long-term Effectiveness and Permanence
Alternative 1 does not provide any long-term protection against
the dermal contact and ingestion of the contaminated soils.
Alternati~e 2 provides a minimum degree of long-term protection
against the contaminants. With proper maintenance,
reinstallation of fencing, implementation of the land use
restrictions and the monitoring of the groundwater quality,
21
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Alternative 3 would provide the necessary long-term protection
required for human health. Remedial alternatives 4A and 5A would
both provide long-term protection and permanence for the public.
Alternative 4A would excavate and treat the contaminated soils to
concentrations below risk-based criteria. Alternative SA would
only relocate the contaminated soils from PSC 16 to a secure
landfill, but would protect the public for potential future uses
of the area.
8.1.4
Reduction of Toxicity, Mobility, and Volume
Remedial alternatives 1 and 2 would not address any of these
concerns. Alternative 3 would only eliminate the potential
mobility of the contaminants by the capping of the exposed
surface area and not the toxicity or volume. Alternative 4A
would reduce the mobility and volume of the contaminants through
the thermal treatment of the soils. The residual ash may require
further treatment prior to its disposal to ensure the reduction
of the toxicity and mobility in the permitted landfill.
Alternative 5A would only reduce the mobility of the contaminants
through the relocation of the soils to a secure landfill.
8.1.5
Short-term Effectiveness
Short-term construction effects related to dust and noise
generation are expected for all alternatives except Alternatives
1 and 2. Construction workers and the general public may be at
risk during the excavation of the contaminated soils (dermal
contact and ingestion), ~lt proper engineering controls and
personal protection equipment would be implemented to reduce the
potential temporary exposure pathways.
Jo.
Alternative 3 would require approximately 2 months to install the
multilayer cap over the surficial area of PSC 16. Alternatives
4A and SA are also estimated to by completed within a 2 month
period (each). The excavation of the soils would include the
confirmatory soil sampling of the exposed soils to ensure that
the contaminants exceeding the target clean-up concentrations
have been removed and treated/disposed. The excavation of the
soils from PSC 16 would cause a temporary concern related to the
structural stability of Building 7100 by exposing the foundation
and excavating soils from beneath the structure. Additional
concern is related to the backfilling of the excavated area
beneath the building to ensure proper compaction to continue to
support the building structure.
8.L6
Implementability
Alternati~e 2 would require a minimal effort to implement the
existing fencing and security measures and land use restriction.
The installation and sampling of the groundwater monitoring wells
could also be readily completed at the PSC location for both
22
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Alternatives 2 and 3. The installation of a multilayer cap over
the surficial area of PSC 16 under Alternative 3 is a viable
remedial option. Because of the concerns related to the
excavation of the soils and the proper backfill to support the
building foundation, an impermeable cap would minimize any
potential impact of the building. In addition, the surficial
cover surrounding PSC 16 would readily support the installation
of a cap' having a paved cover abutting the existing parking lot
and concrete pad storage area. Alternatives 4A and 5A both
require the excavation of the soils from adjacent to and beneath
the building foundation. Beyond this short-term concern, both
the incineration and direct land burial of the soils are proven
and have available permitted facilities within a radius of
approximately 1700 miles and 200 miles, respectively.
8.1.7
Costs
Costs for Alternatives 3 are estimated to be significantly less
than Alternatives 4A and SA.
8.2
PSC 17
8.2.1
Overall Protection of Human Health and the Environment
The human health risk assessment determined that the potential
exposure to the contaminants in the surface soils at PSC 17
consists of three pathways. These include dermal contact and
incidental ingestion and dust inhalation by Base workers and
residential (future use only) occupants. Only construction
workers would be exposed to subsurface soils at some future date
of construction occurred at the PSC.
The ecological risk assessment determined that three exposure
pathways currently exist at PSC 17 for ecological receptors.
These include the incidental ingestion of surface soils,
ingestion of prey items that have bioaccumulated the
contaminants, and dermal uptake. Based on this risk assessment,
several terrestrial receptors could be potentially impacted by
the contamination identified at PSC 17.
Alternatives 1 and 2 would provide little or no protection for
the public and environment. Alternative 3 would eliminate the
exposure pathways for both the existing and future conditions at
PSC 17. Alternatives 4B and 5B would protect the public and
environment for all current and future conditions through the
excavation and treatment of the soils. Alternative 48 would
stabilize the contaminants in the soils, while 5B would extract
the contaminants through soil washing and permit the backfill of
the clean soils in the excavated area.
23
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8.2.2 Compliance uith ARARs
Alternatives 1 and 2 would not comply with the chemical-specific
ARARs. Alternative 3 and 4B would meet the ARARs, but would not
satisfy the health-based federal and state TBC's because the
contaminants are only contained. Alternative 5B would meet all
of the chemical-, location-, and action-specific ARARs through
the treatment of the soils.
8.2.3
Long-term Effectiveness and Permanence
Alternative 1 does not provide any long-term protection against
exposure to the contaminants, and Alternative 2 only provides a
minimal degree of protection. The installation of a cap over PSC
17 (Alternative 3) would require the continued monitoring of the
groundwater quality to ensure long-term effectiveness. Remedial
Alternatives 4B and 5B would provide a permanent solution to the
exposure scenarios by the excavation and stabilization/treatment
of the soils. The backfilled soils would either by clean fill or
the treated soils form the soil washing process. Confirmatory
soil sampling would also ensure that all of the contaminated soil
exceeding the target clean-up concentrations have been excavated
and treated.
8.2.4
Reduction of To~{icity, Mobility, or Volume
Remedial Alternatives 1 and 2 would not address any of these
criteria. Alternative 3 would reduce the mobility of the
contaminants in the soils by reducing the infiltration of the
surface water. Alternative 4B would reduce the toxicity and
mobility of the onsite contaminants in the soil by excavation and
treatment of the contaminated soil. Alternative 5B would address
the mobility and volume of the contaminants by the washing of the
soils. The contaminants would be concentrated in a process
residual requiring further treatment prior to its disposal
offbase at a permitted landfill facility.
8.2.5
Short-term Effectiveness
Short-term construction effects related to dust and noise
generation are expect for all alternatives except for
Alternatives 1 and 2. Construction workers and Base personnel
with access to this restricted area may potentially be at risk
during the PSC preparation for the capping of PSC 17, or during
the excavation of the soils for Alternatives 3, 4B, and 5B.
Alternatives 4B and 5B would require approximately 2 months, 3
months, and 4 months, respectively, to complete the remediation
activities.
24
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8.2.6
Implementability
Alternatives 2 and 3 would require the implementation of land use
restrictions and installation of monitoring wells around PSC 17.
Alternative 3 would also require the installation of an
impermeable cap over the area. This can readily be accomplished
as the area is relatively flat and void of structures. The
construction materials and equipment are readily available for
this type of operation. Alternatives 4B and 5B would require the
excavation of the soils by general construction equipment.
Remedial Alternative 58 would also require the temporary
installation of a soil washing unit, and electrical and water
service connections.
8.2.7
Costs
Costs for Alternative 3 are estimated to be significantly less
than the other alternatives. However, Alternative 48 will
eliminate the current and potential future exposure pathways from
PSC 17. Alternative 4B will also not require 0 & M, as
Alternative 3 (scheduled groundwater monitoring) .
25
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9.0
SELECTED REMEDY
Based upon consideration of the requirements of CERCLA and the
detailed analysis of the alternatives (since no public comments
were received), SOUTHDIV in consultation with USEPA, GEPD, and
MCLB Albany have determined that the most appropriate remedy for
PSC ~6 is Alternative 3, and for PSC 17 the most appropriate
remedy is Alternative 4B.
The complete remedy for PSC 16, located adjacent to Building
7100, includes:
- Installation of a multilayer cap over the surface area,
including a flexible membrane liner, sand drainage layer,
gravel layer, and bituminous concrete surface layer.
- Re-installation and maintenance of security fencing.
- Implementation of land use restrictions on future
activities within the source area.
- Excavation and off-base disposal of sediment in the bottom
of the catch basin adjacent to PSC 16.
- Installation of monitoring wells and monitoring of
groundwater quality.
The complete remedy for PSC 17, located adjacent to the Central
Repair Division (Bldg 2200), includes:
- Excavation of the contaminated soil.
- Transport off-base to a stabilization facility.
- Stabilization of the contaminated soil.
- Disposal at a permitted landfill.
- site restoration, including backfilling the area with
clean soil and revegetation.
The estimated costs of the selected remedies are presented in
Table 4.
9.1
REMEDIATION GOALS
The specific objectives of the selected remedy are to:
1.
CDntrol the release of hazardous substances.
2. Minimize the potential direct exposure to hazardous
materials.
26
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TABLE 4
SELECTED REMEDY COST ESTIMATE
PSC 16 PSC 17
Estimated Capital Costs $64,700 $475,000
Estimated First-Year O&M Costs $41,500 $0
Estimated Present Worth Costs $242,200 $475,000
Estimated Implementation Time Frame 2 Months 3 Months
27
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3. Control the potential for releases of hazardous
substance to the groundwater near the two PSCs.
4. Collect data on aquifer and contaminant response to
remediation measures.
This is an interim action that addresses only a portion of the
MCLB installation and does not address any groundwater
contamination that may exist. Groundwater contamination will be
investigated as media of potential contamination concurrently
with other PSCs under a separate operable unit. However, the
actions described in this Interim ROD are intended to be final
actions for the soil at these PSCs. Although these actions are
intended to be final for soils, the remaining contamination at
PSC 16 will be defined (by sampling) as part of the remedial
actions to comply with the Base permit under the Georgia
Hazardous Waste Management Act (GHWMA).
The ultimate level of remediation to be attained will be
determined in a final remedial action for these PSCs. This
remedial action will be monitored carefully to determine the
feasibility of achieving this level with this method and to
ensure that hydraulic control of a contaminated plume, if one
exists, is maintained. After the period of time necessary, in
EPA's judgment, to arrive at a final decision for the PSCs, a
final ROD for groundwater, which specifies the ultimate goals,
remedy, and anticipated time-frame, will be prepared. Upon
completion of an RIjFS (for groundwater), this interim system may
be incorporated into the design of each PSC remedy specified in
the final action ROD.
l<
28
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10.0
STATUTORY DETERMINATIONS
Under its legal authorities, the EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify.that when
complete, the selected remedial action for this site must comply
with applicable or relevant and appropriate environmental
standards established under Federal and State environmental laws
unless a statutory waiver is justified. The selected remedy also
must be cost-effective and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatments
that permanently and significantly reduce the volume, toxicity,
or mobility of hazardous wastes as their principal element. The
following sections discuss how the selected remedies meet these
statutory requirements.
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy for PSC 16, multilayer cap with
reinstallation and maintenance of the fencing and security, land
use restrictions and monitoring wells, will protect human health
and environment from potentially adverse exposure risks
associated with the current use of the PSC. The multilayer cap
will minimize surface water infiltration and, thereby, reduce the
potential migration of contaminants in the soils. Additionally,
the cap will eliminate the potential exposure route (e.g.,
ingestion of soils). The maintenance of fencing and security
measures and land use restrictions will also support the overall
protection of the public and environment by ensuring that the
potential current and future use exposures are eliminated through
access restrictions. Groundwater monitoring will provide a
continuous monitoring mechanism to ensure that the contaminants
are not migrating.
The selected remedy for PSC 17, excavation and transportation of
contaminated soils to a permitted facility for stabilization and
disposal at a permitted landfill, will protect human health and
the environment by the stabilization of the contaminants in the
soils and final disposal of the stabilized materials at a
permitted landfill. The excavation and treatment of the soils
will eliminate the potential exposure pathways for both the
public (military and residential) and environment. In addition,
the present and future use of PSC 17 will not present any adverse
health effects to construction workers. However, excavation,
transportation, and stabilization of the soils must be controlled
to protect the public and environment from fugitive dust
emissions.
29
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10.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARAR's)
The selected remedies for PSC 16 and PSC 17 will comply with
ARAR's. The following were identified as ARAR's for Operable
unit Three:
Clean Air Act (CAA), National Ambient Air Quality standards
(NAAQS's) and National Emissions Standards for Hazardous Air
Pollutants (40'CFR 50, 40 CFR 61)
USEPA Regulations on Approval and Promulgation of
Implementation Plans (40 CFR Part 52, Subpart L - Georgia)
occupational Health_and Safety Act Regulations for air
contaminants (29 CFR .1910.1000)
RCRA General and Location Standards for Permitted Hazardous
Waste Facilities (40 CFR 264, Subparts A through F)
USEPA Rules for Controlling PCB's under the Toxic Substances
Control Act (TSCA) (40 CFR 761.125, Subpart D, G and K)
Endangered Species Act (16 U.S.C. 1531, 50 CFR Parts 81,
225,402)
RCRA Facility Location Regulations (40 CFR 264.18)
RCRA Closure and Post-Closure Requirements (40 CFR 264,
Subpart G)
RCRA Regulations for Generation of Hazardous Waste (40 CFR
262 )
RCRA Transportation Regulations and DOT Standards (40 CFR
263, 49 CFR, Parts 171 through 179)
RCRA Subtitle D Solid Waste Regulations (40 CFR 241 and 257)
CAA - NAAQS's for Particulates (40 CFR 50)
RCRA Standards for Environmental Performance of
Miscellaneous Units (40 CFR 264, Subpart X)
RCRA Regulations on Land Disposal Restrictions (Land Ban)
(40 CFR 268)
RCRA Regulations for Use and Management of containers (40
CFR, Subpart I)
RCRA Regulations for Waste Piles (40 CFR 264, Subpart L)
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RCRA Incinerator Standards (40 CFR, Subpart 0)
OSHA - General Industry Standards, Recordkeeping and
Reporting, and Standards for Hazardous Waste Site Operations
(29 CFR Part 1926, 29 CFR Part 1904, 29 CFR Part 1910)
USEPA Rules for Controlling PCB's under TSCA (40 CFR 761,
Subparts D, G and K)
Federal Insecticide, Fungicide, and Rodenticide Act (FFRA)
and Regulations (40 CFR 165)
Georgia Air Quality Control Law and Georgia Air Quality
Control Rules (Code of Georgia, Title 12, Chapter 9 DNR
Chapter 391-3-1)
Georgia Hazardous Waste Management Act (Code of Georgia,
Title 12, Chapter 8, Article 3)
Georgia Hazardous Waste Management Rules (Rules and
Regulation of the state of Georgia, Title 391, Article 3,
Chapter 11)
The proposed remedy for PSC 16 will meet the ARAR's. However,
because capping is not a treatment technology, health-risk base
cleanup goals (TBC's) will not be achieved for the PSC location.
Capping designs must be constructed in accordance with RCRA
closure requirements. Chemical- and action-specific ARAR's will
also have to be met during the construction of the cap,
specifically the air quality criteria stipulated by both Federal
and State regulations.
The excavation, transportation, and stabilization of the
contaminated soils from PSC 17 will require compliance with the
chemical-specific ARAR's involving air quality. Engineering
controls, personal protection equipment for the workers, and air
monitoring will be implemented during the remedial process
operations to protect the public and environment. Other Federal
RCRA regulatiqns regarding the general and location standards for
permitted hazardous waste facilities will be met by the proposed
remedy. Location-specific ARAR's applicable to PSC 17 include
the RCRA Facility Location regulations and the Fish and Wildlife
Coordination Act and Conservation Act of 1980. The proposed
remedy will comply with these ARAR's through the implementation
of the soil excavation and off-base stabilization and disposal.
The action-specific ARAR's include RCRA regulation, air quality,
OSHA and insecticide (DOT and DOE) regulations. All of these
criteria will be complied with either during, or by the
implementation of, the proposed remedy. The proposed remedy will
not, however, meet health-based TBC's. .
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.
I
10.3 COST EFFECTIVENESS
The selected remedies for Operable unit Three have been
determined to provide overall effectiveness proportional to their
cost. The selected remedy for PSC 16 is protective of public
health and the environment and is less expensive than
alternatives 4A and SA. The proposed remedy for PSC 17 is
protective of public health and the environment and while more
expensive than Alternative 3, will eliminate the current and
potential future exposure pathways.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES (OR RESOURCE RECOVERY TECHNOLOGIES) TO THE MAXIMUM
EXTENT PRACTICABLE
It has been determined that the selected remedies for Operable
unit Three represent the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-
effective manner for PSC 16 and PSC 17. Treatment of PSC 16 was
found to be impractical due to cost considerations and the
possible negative impact on the adjacent building foundation from
the required excavation. The selected remedies provide the best
balance of tradeoffs in terms of long-term effectiveness and
permanence, reduction in toxicity, mobility or volume achieved
through treatment, short-term effectiveness, implementability,
cost, while also considering the statutory preference for
treatment as a principle element and considering state and
community acceptance.
with proper maintenance to ensure that the multilayer cap remains
intact and continues to minimize infiltration, long-term
effectiveness at PSC 16 will be attained. The maintenance of
fencing and security measures, and scheduled groundwater sampling
will support the long-term monitoring of the remedial
alternative's effectiveness. Risks posed by ingestion of
contaminated soils will be eliminated by capping. Erosion will
be minimized by construction of a paved surface layer. Land use
restrictions will further eliminate potential exposure pathways
to the public and environment.
There will be no long-term risks associated with the
stabilization and disposal of the soils from PSC 17 in a
permitted landfill. The design mix for the stabilization of the
contaminants in the soils ensures that the potential leachate
will not exceed RCRA Land Disposal Regulations requirements (TCLP
mg/l). In addition, the actual disposal method of stabilized
soils will ensure that the public and environment are protected
from exposure to the metals. No long-term management or O&M
requirements at MCLB Albany will be associated with this remedial
alternative. The contaminated soils will be removed from the
Base, treated, and disposed in a permitted landfill.
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10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
At PSC 16 the selected remedy does not employ any type of
treatment. However, at PSC 17 the excavated soil will employ a
stabilization treatment. Therefore, the statutory preference for
remedies that employ treatment as the principal element is
satisfied for PSC 17.
10.6 DOCUMENTATION OF SIGNIFICANT CHANGES
No significant changes from the proposed plan were made.
...
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C () 1\11 iVil) N I rry I{ E IJA T ION S
RESJ)ONSJ\7I~~:N:ESS SUMMARY
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COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
1.0 OVERVIEW
MCLB Albany along with SOUTHDIV, USEPA, and GEPD held a public
meeting on July 21, 1992, at the Dougherty County Chamber of
Commerce to discuss the results of the RIfFS Report and Proposed
Plans and solicit comments and questions from the public.
However, no citizens appeared. Accordingly, no questions or
comments were received during the public meeting.
2.0
BACKGROUND ON COMMUNITY INVOLVEMENT
An active community relations program providing information and
soliciting input has been conducted by MCLB Albany for Operable
unit Three. Interviews of citizens on Base and in Albany were
conducted in the spring of 1990 to identify community concerns.
No significant concerns that required focused response were
identified. Most comments received were concerning the potential
for contamination of water resources. However, those interviewed
indicated that they place great trust in MCLB and their efforts
to rectify past waste disposal practices. In addition, the Base
has formed a Technical Review Committee that includes members
representing the city of Albany and Dougherty County. The local
media has also been kept informed since MCLB was placed on the
NPL. IR Program fact sheets have been prepared and made
available at the Public Affairs Office at MCLB Albany. Documents
concerning Operable Unit Three can be found in the Information
Repository at the Dougherty County Public Library, and the
Administrative Record at the MCLB Public Affairs Office.
3.0
SUMMARY OF PUBLIC COMMENT AND AGENCY RESPONSE
3.1
Public Meeting
No comments or questions were received during the Public Meeting
held on July 21, 1992.
3.2
Public Comment Period
Comments and questions received during the public comment period
that ran from 13 July to 13 August are summarized below.
3.2.1
Technical Comments and Questions
No technical comments and questions were received during the
public comment period.
3.2.2
Oth~r Comments and Questions
No other comments and questions were received during the public
comment period.
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