EPA  Superfund
       Record of Decision:
                                 PB95-964041
                                 EPA/ROD/R04-95/258
                                 March 1996
       Robins Air Force Base,
       (O.U. 3 - Groundwater), GA
       9/25/1995

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                        U.S. Air Force
               Installation Restoration Program
                          Superfund
               Interim Action Record of Decision
                   Robins AFB Zone 1, Georgia
                        Operable Unit 3
                         Groundwater
                          August 3,1995
WDCR531/004.DOC

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                            U.S. Air Force
                 Installation Restoration Program
                             Superfund
                 Interim Action Record of Decision
                      Robins AFB Zone 1, Georgia
                            Operable Unit 3
                             Groundwater
                             August 3,1995
                             Submitted by:
                Hazardous Waste Remedial Actions Programs
                      Oak Ridge National Laboratory
                       Oak Ridge, Tennessee 37831

                             Operated by:
                    Martin Marietta Energy Systems, Inc.

                                 For:
                        U.S. Department of Energy
WDCR931/004.DOC

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   CONTENTS



   Section

   Declaration for the Interim Action Record of Decision

   Decision Summary

         1.0    Site Name, Location, and Description
         2.0    Site History and Enforcement Activities
         3.0    Highlights of Community Participation
         4.0    Scope and Role of Operable Unit 3
         5.0    Summary of Site Characteristics
         6.0    Summary of Site Risks and Interim Cleanup Objectives
         7.0    Description of Alternatives
         8.0    Summary of Comparative Analysis of Alternatives
         9.0    Selected Interim Remedy
         10.0   Statutory Determinations

—  Responsiveness Summary

         1.0    Overview
         2.0    Background on Community Involvement
         3.0    Summary of Public Comment and Agency Response
  Tables

  5-1    Contaminants in Quaternary Aquifer in Zone 1 Above AWQC
  5-2    Contaminants in Upper Providence Aquifer in Zone 1 Above MCLs or Nonzero
         MCLGs
  5-3    Exceedances at Hannah Road

  8-1    Comparison of Alternatives Against CERCLA Criteria
  Figures

  1-1    Vicinity Map
  1-2    Zone 1

  5-1    East-West Lithostratigraphic Cross Section
  WDCR931/004.DOC

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  Declaration for the
Interim Action Record
     of Decision

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                    Declaration for the Interim Action
                             Record of Decision
 Site Name and Address

 Zone 1, Robins Air Force Base
 Operable Unit 3, Groundwater
 Warner Robins, Houston County, Georgia

 Statement of Purpose

 This Interim Action Record of Decision (IROD) presents the selected interim remedial action
 for Operable Unit 3 of the Zone  1  Robins Air  Force Base  (AFB)  Site, 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 Oil  and Hazardous Substances Pollution
 Contingency Plan (NCP).  This decision is based on the Administrative Record that is on file
 in the Directorate of Environmental Management Office, Building 300, Robins AFB, Georgia
 31098.

 This interim remedial action is taken to protect human health and the environment while final
 remedial solutions are being developed.

 Assessment of the Site

 Actual or threatened  releases of hazardous substances  from Zone 1, if not addressed by
 implementing the  response action selected in this IROD,  may present an  imminent and
 substantial endangerment to the public health or welfare or to the environment.

Description of the Selected Interim Remedy

The Zone 1 Robins AFB site is divided into three operable units.  Operable Unit 1 addresses
Landfill No. 4, the sludge lagoon, and the groundwater  immediately adjacent to the lagoon
and comprises source control.  Operable Unit 2 addresses neighboring wetlands and surface
waters, and Operable Unit 3 addresses the remaining groundwater beneath and adjacent to
Landfill No. 4 and the sludge lagoon.  The scope of this IROD is limited to Operable Unit 3.

The selected interim remedy for Operable Unit 3, groundwater, includes the following:

       •     Extraction of groundwater from at least two wells at the toe of Landfill No. 4.

       •     Treatment of the extracted groundwater in a  new treatment system that can
            meet standards for discharge to the Ocmulgee River.

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       •     Discharge of the treated effluent to the Ocmulgee  River under a revised
             National Pollutant Discharge Elimination System (NPDES) permit.

Statutory Determinations

This  interim action is protective of human  health and  the environment,  complies  with
Federal and State applicable or relevant and appropriate requirements (ARARs)  for this
limited-scope action, and is cost-effective.  Although this interim action is not intended to
address fully the statutory mandate  for permanence and treatment to the maximum extent
practicable, this interim  action does utilize treatment and  thus is in furtherance of that
statutory mandate.  Because this interim action does not constitute the final remedy for the
operable unit, the statutory preference for remedies that use  treatment that reduces toxicity,
mobility, or volume as a principal element,  although partially addressed in this interim
remedy, will be addressed by the final response action.  Subsequent actions are planned to
address fully the threats posed by the conditions at this operable unit.  Because this interim
remedy will result in hazardous substances remaining on the site  above health-based levels, a
review will be  conducted to ensure  that the interim remedy continues to provide adequate
protection of human health and the  environment within five years after commencement of
the remedial action. Because this is  an IROD, review of this site and of this interim remedy
will be ongoing as Robins Air Force  Base continues to develop final remedial alternatives for
the operable unit.
                                                       23  August  1995
  EUGENE L. TATTINI, Maj Gen, USAF
  Acting Commander
  Air  Force Materiel Command

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                       Decision Summary
WDCR931/002.DOC

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               1.0   Site Name, Location, and Description


 Robins AFB is an active facility occupying 8,855  acres approximately 18 miles south  of
 Macon, Georgia (Figure 1-1).  Robins AFB is bounded on the west by the City of Warner
 Robins,  on the north by a housing  subdivision in Houston  County,  on the south by
 unincorporated Bonaire, and on the east by the Ocmulgee River and its floodplain.

 The Zone 1,  Robins AFB, National Priority List (NPL)  site is  located approximately
 4,500 feet east of Georgia Highway 247 in the central part of the base (Figure 1-2).  Zone 1
 consists of Landfill No. 4, which covers 45 acres, and the adjacent 1.5-acre sludge lagoon
 (Figure 1-2).

 Zone 1 is adjacent to a bluff that forms the western boundary of the  Ocmulgee  River
 floodplain. The floodplain extends about 1 to 2 miles eastward to the river.  Landfill No. 4
 originally was  constructed by disposing of fill material into the floodplain and wetland area
 from the bluff and advancing to  the east. The sludge lagoon was constructed on the northern
 boundary of Landfill No. 4 by excavating and building earthen dikes.  Surface water at Robins
 AFB generally drains from west to east into the Ocmulgee River floodplain.
WDCR531/002.DOC                         1-1

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 LEGEND
 	Cily Boundary

 	100 Year Flood
	Plain on RAFB
   Figure 1-1   ©J
VICINITY MAP

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                                 reatment Planl
                                                        rainage
                                                        VDitch
                              "TT7X--. . .  —=--^  .           -.-
                              C—^^KZ^Q.  . . Drainage Ditch;

 ote:
 Two Foot Contour Interval
Elevation Above MSL
                                                                  Figure 1-2
                                                                     ZONE 1

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              2.0   Site History and Enforcement Activities


 Robins AFB serves as a worldwide logistics management center for aircraft,  missiles, and
 support systems and is a major repair center for aircraft and airborne electronic systems.

 Robins AFB has generated various types of solid waste over the years, including refuse and
 hazardous waste.  The hazardous waste includes electroplating waste containing heavy metals
 and cyanide, organic solvents from cleaning operations and fire training exercises, and off-
 specification chemicals, such as pesticides.

 In  1982, Robins AFB conducted a basewide survey to identify  and assess past practices for
 disposing of hazardous waste. Disposal areas were grouped into eight zones that were based
 primarily on location and type of disposal activity. Zone  1 (Landfill No. 4 and the sludge
 lagoon) was considered to have the highest potential  for migration of hazardous substances
 and as a  result was placed on the CERCLA NPL by the U.S. Environmental Protection
 Agency (EPA) in  1987.  Landfill No. 4 reportedly operated from 1965 to 1978  for disposing
 of general refuse and industrial wastes.  The sludge lagoon  was  used  for disposing of sludge
 from the industrial wastewater treatment plant and other liquid waste from 1962 to 1978.
 Both the landfill and the sludge lagoon were closed and covered with clean fill in  1978.

 In June 1989, Robins AFB entered into a Federal Facilities Agreement with the Georgia
 Environmental Protection Division (GEPD) and EPA to establish a procedural framework and
 a schedule for developing, implementing, and monitoring appropriate  response actions at the
 site in accordance with CERCLA, the NCP, Superfund guidance and policy, and the Georgia
 Hazardous Waste Management Act (GHWMA).

 From 1991 to 1994, there were several disputes concerning the  ARARs for the groundwater
 at Zone 1.  These disputes eventually led to the February  28,  1994, Dispute Resolution of
 Initial Screening  of Alternatives  (ISA) for  Operable Unit 3.     The ISA defined the
 groundwater point  of  compliance  as Hannah Road, and the interim remedial goals as
 maximum contaminant  levels  (MCLs)  and  nonzero maximum contaminant  level goals
 (MCLGs) for the Blufftown and Providence Aquifers and  as ambient water quality criteria
 (AWQC) for the Quaternary Aquifer.

 The following reports describe the results of investigations at Zone  1, Operable Unit  3, to
 date:
                         •
HAZWRAP.  U.S.  Air Force Installation  Restoration Program.  Remedial Investigation
Zone 1, Additional Site Investigations at Zones 1  and 5,  Task S2 Report.   Robins AFB,
Georgia. November 1988.

HAZWRAP.  U.S.  Air Force Installation  Restoration Program.  Remedial Investigation
Zone 1. Robins AFB, Georgia.  May 1990.
WbCR931rtW2.DOC                         2-1

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 HAZWRAP.  U.S. Air Force Installation Restoration Program.  Feasibility Study,  Landfill
 No. 4 and Sludge Lagoon Source Control, Operable Unit 1, Zone 1.  Robins AFB, Georgia.
 February 1991.

 HAZWRAP.  U.S.  Air Force Installation Restoration Program.  Remedial Investigation
 Report, Zone 1, Operable Unit 3: Groundwater. Robins AFB, Georgia.  September 1993.

 HAZWRAP.   U.S.  Air  Force  Installation  Restoration Program.   Feasibility Study,
 Groundwater, Operable Unit 3, Zone I.  Robins AFB, Georgia.  February 1995.
WDCR931/002.DOC                          2-2

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              3.0   Highlights of Community Participation


 Community relations activities that have taken place at Robins AFB to date include the
 following:

       •     Federal Facility Agreement (FFA) process.  After the FFA was prepared by
             the Air Force, EPA Region IV, and the State, the document was published for
             comment.

       •     Administrative Record/Information Repository. The Administrative Record
             has been established in Building 300 on Robins AFB and is maintained by the
             remedial project manager (RPM).  The Environmental  Information Repository
             has  been established  at the Nola Brantley  Memorial Library,  721 Watson
             Boulevard, Warner Robins,  Georgia,  and in Building 300.  The  Building 300
             repository contains information used to support Air Force decision-making and
             is accessible through the Robins AFB Public Affairs Office.

       •     Community Relations Plan (CRP).  The CRP was updated in  August  1992
             and is presently being revised.  The CRP is being implemented by Public Affairs
             in coordination with the Air Force RPM.  The CRP provides the strategy and
             guidelines for open communication between the public,  regulatory officials, and
             Air Force officials.

       •     Restoration Advisory Board (RAB).   The Technical Review Committee
             (TRC) is being replaced by  the RAB, which has  representatives  from the Air
             Force, EPA Region IV, Georgia EPD, U.S. Fish and Wildlife Service, and the
             National Oceanic and Atmospheric Administration.  The RAB  also includes
             representatives  from  the City of Warner Robins Department  of Community
             Development, the Houston County Emergency Management Agency  (HEMA),
             and the surrounding local communities.

       •     Mailing List.   A  mailing list of interested parties in  the community is
             maintained by the installation and is updated regularly.

       •     Newsletter.   A quarterly newsletter  describing the status  of the IRP at the
             installation was last  distributed  to the  mailing  list in  December  1994.
             Information related to Zone 1 occasionally appears in the newsletter.

       •     Television.  The "Robins Report" is a 15-minute weekly television program
             broadcast locally.    Environmental   subjects are addressed  periodically.
             Information related to Zone 1 occasionally appears in the "Robins Report."
WDCR931/002.DOC                         3-1

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                  4.0   Scope and Role of Operable Unit 3


 Zone 1 is divided into three operable units (OUs).  OUs typically are developed to better focus
 on areas of contamination that are within the same geographic area or to focus on a particular
 medium, such as groundwater.

 OUS  activities address the eastward-migrating contaminated groundwater in Zone 1, other
 than the groundwater below the sludge lagoon, so that interim cleanup standards are achieved
 at the point  of compliance, Hannah Road.   The remedy for  the source  areas and  the
 groundwater below the sludge lagoon in Zone 1 is being addressed in OU1.  OU2 activities
 include  evaluating the effects that may have occurred  in the  wetland  area  from  the
 contamination in OU1. The interim remedial action selected in this IROD is applicable to
 OUS and will be consistent with any planned future action to the extent possible.

 The scope of the problems addressed by the  preferred interim remedial action for OUS will
 attain the remedial goals established in the February 28, 1994, Dispute Resolution of Initial
 Screening of Alternatives for Operable  Unit  Three,  Groundwater  (Initial  Screening of
 Alternatives [ISA]), at the designated point of compliance.

 The ISA defined the point of compliance as  Hannah Road.  The ISA  also documented  the
" standards that would be met for the groundwater at Hannah Road:

       •     Maximum contaminant level (MCL) and nonzero maximum contaminant level
             goals (MCLGs) for Providence and Blufftown aquifers

       •     Ambient water quality criteria (AWQC) for the Quaternary alluvial aquifer

 These standards will be referred to as "interim cleanup standards" or "interim remedial goals"
 in the remainder of the IROD.

 The ISA stated that the FS will develop,  at a minimum, three options:

       •     No action
       •     Pumping at the toe of the landfill
       •     Pumping at the toe of the landfill and along Hannah Road
WDCR93I/002.DOC                         4-1

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                  5.0   Summary of Site Characteristics
 5.1 Hydrogeology

 Robins AFB lies in the Atlantic Coastal Plain physiographic province.  The base is underlain
 by Cretaceous sediments that are about 350 feet thick.  Around Zone 1  and throughout the
 east side of the base, the Cretaceous sediment is overlain by Quaternary alluvial deposits.

 The alluvial deposits consist of a basal sandy gravel bed and an overlying clay bed. The two
 deposits are each about 7 to 10 feet thick.  A swamp established itself on top of the clay bed,
 creating a 6- to 7-foot bed of peat over the clay. This peat bed forms the uppermost natural
 unit in the local stratigraphy and the natural land surface in the swamp. The peat generally is
 saturated, and the water  level  within the peat  is at or near land surface.  The swamp  is
 inundated during flooding by the Ocmulgee River.

 The Cretaceous deposits underlying the site are divided into four geologic formations.  They
 are, in descending order, the Providence and Ripley formations, the Cusseta Formation, and
 the Blufftown Formation.  The Providence and Ripley formations are not differentiated in this
 study because they tend to act as one hydrologic unit. In this FS report, they are referred to
 as the "Providence Formation."

 The Providence Formation underlies the Quaternary gravel bed beneath the east part of the
 zone and extends upward to the land surface in the west part of Zone 1, where the Quaternary
 unit pinches out along the west valley wall of the floodplain.  The Providence Formation  is
 composed of beds of sand, gravelly sand, silty sand, and clay. . For this FS, the Providence
 Formation was subdivided into upper  and lower parts,  conforming to  the general depths
 where monitoring wells were completed.  The Providence Formation is saturated and yields
 large quantities of water to wells. A geologic cross section of Zone 1 is shown in Figure 5-1.

 The Cusseta Formation is  composed of about 15 to 50 feet of dense plastic clay  and  sand  in
 the vicinity of Zone 1. The unit is saturated but yields little water to wells.  Hydrologically,
 the Cusseta Formation is an aquitard for the underlying Blufftown Formation.

 The Blufftown Formation extends from the base  of the  lowest clay bed in  the Cusseta
 Formation down to the metamorphic basement rocks. The Blufftown Formation consists of
 saturated sand and gravel  beds  and yields significant quantities  of water to wells.  It is the
 primary aquifer for local water supply.  Robins AFB water supply wells are completed in this
 formation.

 The regional or general direction of groundwater  flow  within the Cretaceous formations
 beneath Zone 1 is from west to east,  generally toward  the  Ocmulgee River.   The entire
 floodplain of the Ocmulgee River is a discharge area for groundwater.  Where the Ocmulgee
River has eroded part of the Cretaceous sediment, there is a significant upward gradient from
 the deeper units toward the shallow Quaternary units and surface water.  Outside of the
floodplain,  there  is   a  generally downward gradient  in the Cretaceous  deposits, and
WDCR931/002.DOC                          5-1

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  groundwater recharge occurs.  Flow in the near-surface Quaternary units generally is toward
  the river or to smaller streams in the floodplain.  The drainage ditch that forms the north
  boundary of Zone 1 also acts to control local groundwater flow because shallow groundwater
  in the area discharges upward into the ditch from both the  north and the south.

  5.2  Nature and Extent of Contamination

  The  nature, extent,  and  concentration of hazardous substances in the  landfill  and sludge
  lagoon have been studied  in  detail  in numerous field sampling investigations,  which are
  referenced in Section 2. The primary classes of contaminants present at Zone 1 are metals and
  volatile organic compounds (VOCs),  primarily TCE.  The highest relative concentrations of
  metals and VOCs occur in the sludge  lagoon.  Maximum concentrations of VOCs  and metals
  in the sludge  lagoon were  detected  in  samples collected  8  to  10  feet  deep.   High
  concentrations of contaminants also were detected in leachate samples from the sludge in the
  sludge lagoon.  Contaminant concentrations decreased in soil nearer the surface of the sludge
  lagoon. Another primary source of TCE contamination is the suspected drum-disposal area in
  the western end of the landfill.

  The media of concern in OU3 is the groundwater. For better determining the contaminants of
  concern in the groundwater, four groundwater  sampling events were evaluated.  The four
  sampling events included two sampling events from January-February 1991 and April 1991
" that were reported in the OU3 RI report and the two  following sampling events, April 1993
 and September 1993.  The 1991 data  are presented in the OU3 RI report, and  the 1993 data
 are presented in the OU3 FS report.

 All of the contaminants that were sampled in each of the four sampling events were compared
 with  the interim remedial goals for each of the aquifers.  The  interim remedial goals are to
 meet the AWQC in the Quaternary alluvial aquifer and the MCLs and nonzero MCLGs in the
 Providence and Blufftown aquifers. The interim remedial goals apply to Hannah Road, the
 point of compliance-.   For comparison purposes  only, Tables 5-1  and  5-2  are presented
 showing contaminants that have exceeded interim remedial goals anywhere in Zone 1. Table
 5-1 presents the contaminants that have exceeded AWQC in the  Quaternary alluvial aquifer
 for all of Zone 1 and the number of exceedances in each sampling event.  Table 5-2 presents
 the contaminants  that have exceeded MCLs or nonzero  MCLGs in  the Upper Providence
 aquifer for all of Zone 1 and the number of exceedances in each sampling event.

 Several observations can be made in reviewing Table 5-1. The total  exceedances of the
 inorganic compounds drops significantly from the 1991 sampling events to the 1993 sampling
 events.  We believe  this  is  primarily  due to changes  in  the sampling protocol,  initiated at
 EPA's direction, but it also may be a result of improving groundwater quality in Zone 1 and
 changes in procedures.  The method  for collecting, transferring, and filtering groundwater
 samples was modified from  1991  through 1993.  The method for  purging the wells also was
 modified from April 1993  to September 1993 on the basis of EPA's comments.  The change in
 well-purging protocol decreased the amount of turbidity in the wells at the time of sampling,
 thus reducing the concentrations of total metals in the samples. We believe that  the change in
 WDCR931/002.DOC                          5-2

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 purging protocol allowed collection of samples that are more representative of groundwater
 quality at the site.

 The number of exceedances for organic compounds has been relatively stable over the four
 sampling events in comparison to the decreasing number of inorganic exceedances.  This fact
 may imply either a stronger organic compound contaminant source load or that the inorganic
 improvement is strictly due to improved sampling procedures.

 Table 5-2  indicates a  decreasing trend  in  exceedances for inorganic compounds, and
 exceedances for organic compounds have remained roughly the same.

 Additional evaluation in the FS focused on the contaminants that exceeded standards on more
 than one occasion in either of the 1993 sampling events. The 1993 events were used for this
 criteria because of the changes in groundwater-sampling procedures and because these events
 reflected the most current conditions in Zone 1.  The contaminants of concern that meet this
 exceedance   criteria  were  copper,  lead,   mercury,   benzene,   carbon   tetrachloride,
 tetrachloroethene, trichloroethene, and vinyl chloride.

 Contaminants that appear to be associated with a distinguishable plume are lead, carbon
 tetrachloride, tetrachloroethene, and trichloroethene. On the basis of a review of the physical
 and chemical characteristics associated with the organic compounds and the averages and
- ranges of concentrations of these contaminants, the organic contaminant that appears most
 likely to exceed interim remedial goals at Hannah Road is trichloroethene.

 For completing the  evaluation of  previous groundwater sampling events,  Table 5-3 was
 prepared to present the exceedances that occurred at the point of compliance, Hannah Road,
 for  the  sampling events.    Table  5-3  indicates that the number of  exceedances  drops
 significantly from 1991 to 1993.  As  with the analysis of all the sampling data above, we
 believe this is primarily a result of improved sampling procedures and improving groundwater
 quality.
 WDCR931/002. DOC                           5-3

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Table 5-1
CONTAMINANTS IN QUATERNARY AQUIFER IN ZONE 1 ABOVE AWQC
(Concentrations in Hg/L)
Contaminant
AWQC
Number of Exceedances/Number of Samples
by Sampling Event
Jan. 1991
April 1991
April 1993
Sept 1993
Inorganic Contaminants
Arsenic
Cadmium
Copper
Lead
Mercury
Zinc
0.14
0.7
6.5
1.3
0.15
60
4/24
2/24
16/24
22/24
11/24
10/24
3/23
0/23
15/23
19/23
7/23
6/23
0/31
0/31
6/31
9/31
5/31
2/31
0/31
0/31
8/31
3/31
3/31
0/31
Organic Contaminants
Carbon
Tetrachloride
Tetrachloroethene
Trichloroethene
Vinyl chloride
4.4
8.85
81
525
10/24
6/24
12/24
1/24
8/24
6/24
10/24
2/24
10/31
9/31
11/31
2/31
10/31
8/31
13/31
2/31
WDCR931/002.DOC
                                                  5-4

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Table 5-2
CONTAMINANTS IN UPPER PROVIDENCE AQUIFER IN ZONE 1 ABOVE MCLs OR
NONZERO MCLGs
(Concentrations in Jig/L)
Contaminant
MCL,
Nonzero
MCLG
Number of Exceedances/Number of Samples
by Sampling Event
Jan. 1991
April 1991
April 1993
Sept. 1993
Inorganic Contaminants
Antimony
Cadmium
Lead
Nickel
6
5
15
100
NA*
1/21
4/21 '
0/21
7/21
0/21
1/21
0/21
0/22
0/22
1/22
0/22
0/22
1/22
0/22
1/22
Organic Contaminants
Benzene
Carbon
Tetrachloride
Chlorobenzene
Tetrachloroethene
Trichloroethene
5
5
100
5
5
0/21
5/21
0/21
3/21
8/21
0/21
4/21
0/21
3/21
7/21
2/22
5/22
0/22
2/22
7/22
1/22
5/22
1/22
2/22
8/22
* NA = Not Analyzed
WDCRS31/002.DOC
                                                  5-5

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Table 5-3
EXCEEDANCES AT HANNAH ROAD
Well No.
January 1991
April 1991
April 1993
September 1993
Quaternary Wells
LF4-15
LF4-15
LF4-15
LF4-15
LF4-15
LF4-15
LF4-16
LF4-16
LF4-17
LF4-17
LF4-17
LF4-17
LF4-18
LF4-18
LF4-19
LF4-19

Copper
Dieldrin
Lead
Mercury


Lead
Cadmium
Copper
Lead
Zinc


Copper
Lead
Arsenic
Copper
Dieldrin
Lead
Mercury
Zinc
Copper


Copper
Lead

Copper
Lead
Copper
Lead









Copper















Copper




Copper

Providence Wells
LF4-32
LF4-34
LF4-38
TOTAL

Lead
Lead
13
Antimony


14


Lead
2



2
WDCR931/002.DOC
                                                5-6

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                 6.0 Summary of Site Risks and Interim
                             Cleanup Objectives
 The current risk for Operable Unit 3 is the potential of contaminated groundwater reaching
 receptors downgradient of the site and causing adverse health effects.   Potential receptors
 include ecological species in the wetlands due to groundwater discharging to surface water,
 and humans through the potential ingestion of groundwater or contaminated organisms.  The
 objective of the interim remedial action is to reduce the migration of the contaminants from
 the site to reduce the risks to potential receptors.

 The ISA defined the  groundwater  point of compliance  as Hannah Road  and the interim
 remedial goals as MCLs and nonzero MCLGs for the Blufftown and Providence aquifers and
 as AWQC for the Quaternary aquifer.  The AWQC used were those published in the Georgia
 Rules and Regulations for Water Quality Control, Chapter 391-3-6-03, which were revised
 on  May 29,  1994.  In cases  when chemicals or compounds are  assigned more than one
 AWQC value in Chapter 391-3-6-03, the lowest value appropriate  for freshwater was used.
 Interim remedial actions will be considered to meet interim cleanup objectives if the interim
 remedial goals at Hannah Road will be met in the short term and the long term.
WDCR931/002.DOC                        6-1

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                     7.0   Description of Alternatives


 The following is a summary of the alternatives evaluated in the FS for the groundwater in
 Zone 1, other than groundwater addressed in OU1.  These alternatives, which are interim
 remedial actions,  have been evaluated by using a groundwater model.  The alternative is
 considered successful if it results in the interim remedial goals being met at Hannah Road.

 The general scope of the alternatives was presented in the ISA.  Alternatives 2 and 3 will
 supplement actions associated with remediating the Zone 1 groundwater at the sludge lagoon,
 addressed in OU1.

 Alternative 1:  No Action

 The No Action alternative consists of no additional measures for groundwater at Zone 1 other
 than the measures that will be taken as part of OU1.  Therefore, there are no capital  or
 operation  and  maintenance  (O&M) costs associated  with  this  alternative   and  no
 implementation schedule as part of OU3.

 Alternative 2:  Extraction of Groundwater at the Toe of Landfill No. 4 and
 Treatment

 In this alternative, groundwater will be extracted from at least two wells at the toe of Landfill
 No. 4, treated in a new groundwater-treatment system, and discharged either to the wetlands
 in Zone 1 or to the Ocmulgee River with other plant effluent.  The processes used to  treat the
 groundwater  depend on the discharge point.  For discharge to the wetlands, filtration, air
 stripping, or an equivalent VOC treatment method, and ion-exchange technologies will be
 used. For discharge to the Ocmulgee River, the same technologies except ion exchange will
 be required. The costs associated with discharging to the Ocmulgee River are as follow:

       Estimated Capital Costs:  $ 1,212,000
       Estimated Annual O&M Costs:  $70,000
       Estimated Present-Worth Costs:   $2,200,000

 The costs associated with discharging to the Zone 1 wetlands are as follow:

       Estimated Capital Costs:  $6,126,000
       Estimated Annual O&M Costs:  $255,000
       Estimated Present-Worth Costs:   $10,046,000

 Alternative 3: Extraction of Groundwater at the Toe of Landfill No. 4 and
 at Hannah Road and Treatment

 In Alternative 3, groundwater will be extracted from at least two wells at the toe of Landfill
No. 4 and one well  at Hannah Road,  treated in  a new groundwater-treatment system, and
 discharged  either to the wetlands in Zone 1 or to the Ocmulgee River  with  other plant
WDCR931/002. DOC                          7-1

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 effluent. The processes used to treat the groundwater depend on the discharge point.  For
 discharge to the wetlands, filtration, air stripping,  or an equivalent VOC treatment method,
 and ion-exchange technologies will be used. For discharge to the Ocmulgee River, the same
 technologies except ion exchange will be required.  The costs associated with discharging to
 the Ocmulgee River are as follow:

       Estimated Capital Costs:  $1,526,000
       Estimated Annual O&M Costs:  $81,000
       Estimated Present-Worth Costs:  $2,780,000

 The costs associated with discharging to the Zone 1 wetlands are as follow:

       Estimated Capital Costs:  $6,732,000
       Estimated Annual O&M Costs:  $270,000
       Estimated Present-Worth Costs:  $10,892,000
WDCR931/002.DOC                          7-2

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                8.0   Summary of Comparative Analysis
                                of Alternatives


 8.1 Overall Protection of Human Health and the Environment

 The focus of this IROD is to prevent hazardous substances in groundwater from reaching
 Hannah  Road and  causing the interim  remedial goals  to be exceeded.   According to
 groundwater modeling and the associated assumptions in designing the extraction system,
 Alternative 2 and Alternative 3 achieve the interim remedial goals of this operable unit for
 protecting public health and  the  environment, given proper installation, operation,  and
 maintenance. Protection of the environment and the ecology in the surrounding wetlands
 from releases of hazardous substances is best provided by  Alternative 2 and Alternative 3.
 The results of groundwater modeling indicate that in  Alternative 1 the level of contaminants
 will exceed the AWQC in the Quaternary Aquifer at the point of compliance in the future.

 8.2 Compliance with ARARs

 According to the groundwater modeling effort,  Alternative 1 will not comply with interim
 cleanup objectives.  Future compliance with ARARs at Hannah Road is based entirely on
 estimates resulting from the groundwater-modeling exercise for TCE and lead.  Alternatives 2
 and 3 will comply with the chemical-specific ARAR of meeting AWQC in the Quaternary
 aquifer and MCLs and nonzero MCLGs in the Providence and Blufftown aquifers at Hannah
 Road.  Each of the alternatives will comply with  the permitting and technology requirements
 of the Federal and State air programs.

 As  part of each  alternative, a National Pollutant Discharge Elimination System  (NPDES)
 permit will have to be either modified or obtained, so  this particular chemical-specific ARAR
 will be achieved in all cases.

 Alternatives 2 and 3  will comply with location- and action-specific ARARs, which primarily
 include wetland and floodplain requirements.

 8.3 Long-Term Effectiveness and Permanence

 This interim action is not designed or expected to be final, but the selected remedy represents
 the  best balance of tradeoffs among alternatives with  respect to pertinent criteria,  given the
 limited scope of the action.

 8.4 Reduction of Toxicity, Mobility, or Volume Through Treatment

Alternatives  2  and 3 should  remove approximately  the same mass of TCE  and other
contaminants from the groundwater, given the plume characteristics and the capture zone of
the  two  alternatives.  The two alternatives will reduce the toxicity of the groundwater  and
decrease the TCE mass that will migrate  to Hannah Road.  Approximately 2,300 pounds of
TCE will be removed annually.
WDCR931/002.DOC                         8-1

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 Groundwater will be treated on the site in a new treatment facility. Treatment of groundwater
 will remove contaminants to levels that are in accordance with the NPDES permit before the
 groundwater is discharged to local surface water.

 Treatment for  volatiles will be performed by equipment that  will be approved during the
 Remedial Design by the GEPD, U.S. EPA and Robins AFB.

 8.5 Short-Term Effectiveness

 Alternative 2 and Alternative 3  provide short-term effectiveness in that the interim cleanup
 standard is always achieved at Hannah Road,  In Alternative 1, according to the groundwater
 model, the interim cleanup standard will be exceeded within the next 4 years.

 Given the schedule  for OU3, the selected alternative is not expected to be implemented until
 approximately 1997.

 The design, construction,  and startup of the treatment system probably will take between 1
 and 2 years. The design of the treatment system has started already and should be completed
 no more than 6 months after the signing of the IROD.

 8.6 Implementability

 Each alternative is  considered technically and administratively  feasible for construction and
 operation.  Commercial services and materials are readily available.  Obtaining local permits
 for implementing the selected remedy is not expected to delay the project.

 8.7 Cost

 The costs for each alternative are presented in Section 7.  The assumptions used in developing
 the cost estimates for each alternative are presented in  Appendix B of the OU3 FS report.

 The cost estimates have been developed strictly for comparing the three proposed alternatives.
 The final costs of the  project  and the resulting feasibility will depend on actual labor and
 material costs, competitive market conditions,  actual  site conditions, the final project scope,
 the implementation schedule,  the firm selected  for final  engineering  design, and other
 variables.  Therefore, final  project costs will vary from the cost estimates.

 The cost estimates  are order-of-magnitude estimates  having an intended accuracy range of
+50 to -30 percent.  The range applies only to the alternatives as they are defined in Section 4
 of the FS report and does  not account for changes in the scope of the  alternatives.  Selection
 of specific technologies or processes for configuring  remedial alternatives  is intended not to
 limit flexibility during remedial design but to provide a basis for preparing cost estimates.  The
 specific details of remedial actions and cost estimates will be refined during final design.

The cost estimates  consist of total capital costs, which include the  costs of construction,
allowances, contingencies, engineering, permitting,  and legal  advice, and of services during
WDCR931/002.DOC                          8-2

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 construction and the present worth of O&M costs determined over an appropriate period of
 up to 30 years at a 5 percent discount rate.

 8.8  EPA/GEPD Acceptance

 U.S. EPA Region 4 and the Georgia Environmental Protection Division have reviewed and
 approved the Proposed Plan for OU3 at Zone 1.

 8.9  Community Acceptance

 The local community has been invited to submit comments and attend a public hearing related
 to the  proposed activities at OU3 at Zone 1.  No comments were received  during the
 comment period.  Comments from the public  hearing and responses  to the comments are
 presented in the "Responsiveness Summary" of this IROD.  The comments from the public
 hearing do not affect the proposed interim remedy  at OU3 and were supportive of the
 proposed actions.

 A summary of the comparative analysis  presented above for the nine CERCLA criteria is
 shown in Table 8-1.
WDCR93J/002.DOC                        8-3

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Table 8-1
COMPARISON OF ALTERNATIVES AGAINST CERCLA CRTTERU
Alternative
1.
2, with discharge to
Ocumulgee River
2, with discharge to
Zone 1 wetland!
3, with discharge to
Ocumulgee River
3, with discharge to
Zone 1 wetlands
CERCLA Criteria
Short-Term
Effectiveness

V
V
V
V
Long-Term
Effectiveness

V
V
V
V
Reduction of
ToxldtY,
Mobility, or
Volume

V
V
V
V
Overall Protection
of Human Health
and the
Environment

V
V
V
V
Implementabllltr

V
V
V
V
Compliance
wlthARARs

V
V
V
V
EPA/GEP0
Acceptance

V
V
V
y
Communry
Acceptance
•

V
V
V
V
Coat
Capital
$0
$1,122,000
$6,126,000
$1,526,000
$6,732,000
O&M
$0
$70,000
$255,000
$81,000
$270,000
Present
Worth
$0
$2,192.000
$10,046,000
$2,780,000
$10,892,000
•Community acceptance will be evaluated on the basis of public comments received on the proposed plan and previous documentation.
WDCR931AX36.DOC

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                       9.0   Selected Interim Remedy
 The preferred interim remedial alternative for OU3  is Alternative 2, with discharge of the
 treated effluent to the Ocmulgee River. Although Alternative 2 and Alternative 3 adequately
 address all of the CERCLA evaluation criteria, Alternative 2 does so at the least cost and
 therefore is the selected interim remedy. Discharge will be to the Ocmulgee River rather than
 to the wetlands because of the significantly higher cost of discharging to  the wetlands as a
 result of additional  treatment required to meet lower discharge standards.  Therefore,  the
 complete preferred interim remedial action includes extracting groundwater from at least two
 wells at the toe of Landfill No. 4, and  treatment  of the extracted groundwater  in a new
 treatment system, that can meet cleanup standards, and discharge of the treated effluent to the
 Ocmulgee River.  Because the effluent is being discharged to the Ocmulgee River, metals
 treatment and ion exchange may not be required to meet the permit discharge levels.
9.1  Remediation Goals

The specific objectives of the selected interim remedy are as follow:

1. Control groundwater contamination so that hazardous substances do not exceed interim
   cleanup standards at Hannah Road.

2. Treat the  extracted  groundwater to meet  required  standards for effluent  discharge.
   Removal and treatment of groundwater will  reduce the mass of hazardous substances in
   the groundwater.
WDCR931/002.DOC                         9-1

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                       10.0  Statutory Determinations


 Under its legal authorities, Robins AFB's primary responsibility at this site is to undertake
 remedial actions that achieve adequate protection of human health and the environment. The
 statutory determination for this IROD is presented before Section 1.  The focus of this IROD
 is to attain the interim cleanup objectives established at the point of compliance, Hannah
 Road. The following sections discuss how the selected interim remedy meets these statutory
 requirements.

 10.1 Protection of Human Health and the Environment

 The interim remedial goals for the groundwater are stated in the ISA. The evaluation of the
 Providence and Blufftown aquifers goals is based on protecting human health.  The evaluation
 of the Quaternary alluvial aquifer is based  on protecting the environment  and protecting
 humans from the adverse effects of consuming organisms from surface water.

 The primary concern related to  public health is the potential ingestion of groundwater.  The
 concern applies to groundwater in the Providence and Blufftown aquifers. The specific goals
 for protecting public health are MCLs and MCLGs.

 The interim remedial goal for OU3 for environmental protection is reducing the release of
 groundwater contaminants so that adverse effects on the wetlands, on the aquatic life, and on
 human health from organism consumption related to the surface water do not occur.  Because
 groundwater from the Quaternary alluvial aquifer discharges on the site to wetlands or surface
 water, AWQC are the goals for environmental protection in this aquifer.

 10.2 Compliance with Applicable or Relevant and Appropriate
 Requirements

 The selected interim remedy will comply with all ARARs. A detailed discussion of ARARs is
 in the OU3 FS. The following were identified as ARARs for Operable Unit 3:

      •     Ambient  water quality criteria  as chemical-specific ARARs in the Quaternary
            aquifer at Hannah Road

      •     MCLs and nonzero MCLGs as chemical-specific ARARs in the Providence and
            Blufftown aquifers at Hannah Road.

      •     RCRA disposal requirements, 40 CFR 264, and land disposal restrictions, 40
            CFR 268, are ARARs for groundwater-treatment residuals.

      •     Clean Water Act requirements for direct discharge of treatment-system effluent
            (40 CFR  122).
WDCR931/002.DOC                         10-1

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        •     Georgia Air Quality Act requirements for treatment of air  emissions from
             removal of VOCs from the extracted groundwater.

        •     Requirements to prevent adverse effects  from construction in a  100-year
             floodplain under Executive Order 11988, 40 CFR 6, and 40 CFR 264.18(b).

        •     Requirements to minimize destruction, loss,  or degradation of wetlands under
             Executive Order 11990 and 40 CFR 6.

 10.3  Cost-Effectiveness

 The selected interim remedy has been determined to provide overall effectiveness proportional
 to its costs. The selected interim remedy is protective of public health and the environment
 and is less expensive than Alternative 3.

 10.4 Use of Permanent Solutions and Alternative Treatment Technologies
 (or Resource Recovery Technologies) to the Maximum Extent Practicable

 The interim action  is not designed or expected to be final, but the selected interim remedy
 represents the best  balance of tradeoffs among alternatives with respect to pertinent criteria,
 given the limited scope of the action.

 Of the alternatives that are protective of human health and  the environment and comply with
 ARARs, Robins AFB has determined that the selected interim remedy provides  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;
 and cost while also considering the statutory preference for treatment as a principal  element
 and considering  state and community acceptance.

 On the basis of groundwater modeling, Alternative 2 and Alternative 3 are equally effective in
 the reduction of TCE and lead in groundwater to achieve remedial goals.

 10.5 Preference for Treatment as a Principal Element

 Treatment of the groundwater is a principal element of the selected interim remedy.  Because
the groundwater is below the source of contaminants, the sludge lagoon,  and the  landfill,
Alternative 2, which includes extraction wells  downgradient of the sludge lagoon and the
landfill, will be effective in removing and treating the hazardous substances in groundwater in
Zone 1  so that interim cleanup objectives are achieved. Therefore, the statutory preference
for remedies that use treatment as a principal element is satisfied.

 10.6  Documentation of Significant Changes

No significant changes from the Proposed Plan were made.
WDCRS31/002.DOC                          10-2

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                    Community Relations
                  Responsiveness Summary
WDCRS3I/003.DOC

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            Community Relations Responsiveness Summary
                                   1.0 Overview

 Robins AFB, EPA, and GEPD held a public meeting on May 18, 1995, at the Museum of
 Aviation to discuss the results of the RI/FS, present the Proposed Plan, and solicit comments
 and questions from the public.
            2.0 Summary of Public Comment and Agency Response

 Comments and questions raised during the public meeting held on May 18, 1995, and those
 received during the public-comment period are summarized below.

 1.     One resident suggested that the recent  flood may have caused contaminants in the
        upper aquifers to migrate into the lower aquifers.  With this possibility, he suggested
        that the groundwater quality in the different aquifers be restudied.  This resident, who
        is a physician, also expressed a concern about activities using toxic chemicals at the
        base and their affect on employees.  He presented a plaque to the base to be placed
        near the sludge lagoon to recognize past environmental destruction so that all can
~       learn from these activities.

 Robins AFB Response: More than 90 groundwater samples are collected semiannually from
 different locations and depths in Zone 1.  These sampling events will provide information on
 whether the groundwater conditions in Zone 1 have changed. Regarding his other comments,
 Robins has an active pollution prevention program to eliminate or reduce the use of toxic
 chemicals whenever possible and when this is not feasible, wastes will be managed to minimize
 any releases to the environment.  Exposure to chemicals in the sludge lagoon and landfill
 should not occur because a fence has been installed around these areas. Remediation activities
 performed in these areas will be conducted by personnel that have received Occupational
 Safety and Health Act (OSHA) training and have proper personnel protection.

 2.      One resident asked if methyl ethyl ketone had been discarded in the sludge area.

 Robins AFB Response:  Methyl ethyl ketone (2-butanone) may have been discharged with
 other solvents to the sludge lagoon prior to 1978. Of the 88 groundwater samples collected in
 spring 1993, two samples contained methyl ethyl ketone.  None of the groundwater sampled
 collected  in fall 1994 contained methyl  ethyl ketone.  Any  residual methyl ethyl ketone
 remaining in Zone 1 is within the capture zone of the groundwater removal system.
 WDCR931/003.DOC

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 3.      One resident added that the concern is the vinyl chloride at the bottom of the sludge
        lagoon.

 Robins AFB Response: Vinyl chloride has been detected in the groundwater at Zone 1, but
 with less frequency than detection of trichlorethene.  The vinyl chloride in the groundwater is
 within the capture zone of the groundwater removal system.

 4.      One resident asked about the quality of the water that  will be discharged from the
        groundwater treatment system.

 Robins AFB Response: The discharge will meet the present National Pollutant Discharge
 Elimination System (NPDES) permit limits. The base will not be asking for any changes to
 the permit.

 5.      One resident asked about the fishing problem and if this was related to mercury.

 Robins AFB Response:  Robins intends to comply with its NPDES permit.  Compliance with
 this permit is the procedure EPA, EPD, and the base follow to provide protection to human
 and ecological receptors.

 6.     One resident, another physician,  commented that except in an isolated case of workers
       climbing into fuel tanks, he has not had patients  that had pathological effects from
       chemicals handled at Robins.   He also commended  Robins on  their restoration
       activities and progress.
WDCR931/003.DOC

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CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Major General William P. Hallin
Commander
215 Page Road   j
Suite J*32>--     j  ,.» .
Robins Air Force] Baser Georgia  31098-1662

SUBJ:  Interim Record of Decision for Operable Unit Three
       (ground water) Robins Air Force Base NPL Site
       Warner Robins, Georgia

Dear Major General Hallin:

     The U.S. Environmental Protection Agency (EPA) has reviewed
the above referenced decision document and concurs with the
selected interim remedy for remedial action at Operable Unit
Three/ as supported by the previously completed Remedial
Investigation and Feasibility Study.

     The selected interim remedy is to install extraction wells _
into the Quartenary and Upper Providence aquifers, and treat  the
ground water to remove organics to meet the limits in the NPDES
Permit.  EPA understands that Robins Air Force Base and GA EPD
have agreed that the NPDES Permit may require treatment of
metals.  The trejated water will be discharged to the Ocmulgee
river in accordance with an NPDES permit.  This interim remedial
action is protective of human health and the environment,
complies with Federal and state requirements for an interim
remedy and is ccfst effective. .                            i  :

     It is understood that the selected remedy for Operable Unit
Three is an interim remedy and that a final remedial action will
be proposed for this site.

                              Sincerely,
                             Patrick M. Tobin
                             Deputy Regional Administrator
cc: William Downjs, RAFB
    Danny Heater, GA BPC
    Bobby Ficquette, AF

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