PB95-964042
EPA/ROD/R04-95/259
March 1996
EPA Superfund
Record of Decision:
Marine Corps Logistics Base,
Operable Unit 1, Albany, GA
10/11/1994
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U. S. NAVY/MARINE CORPS INSTALLATION
RESTORATION PROGRAM
SUPERFUND
INTERIM RECORD OF DECISION
GROUNDWATER CONTAINMENT
MARINE CORPS LOGISTICS BASE, ALBANY, GEORGIA
OPERABLE UNIT ONE
POTENTIAL SOURCE OF CONTAMINATION THREE
SEPTEMBER 1994
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CONTENTS
ACRONYMS iv
DECLARATION FOR THE RECORD OF DECISION
DECISION SUMMARY
1.0 Site Name and Location 1
2.0 Site History and Enforcement Activities 2
3.0 Highlights of Community Participation 6
4.0 Scope and Role of Remedial Action at PSC 3 7
5.0 Site Characteristics 8
6.0 Summary of Site Risks 14
7.0 Description of Alternatives 15
8.0 Summary of Comparative Analysis of Alternatives 17
9.0 Selected Remedy 25
10.0 Statutory Determinations 28
RESPONSIVE SUMMARY
1.0 Overview 32
2.0 Background on Community Involvement 32
3.0 Summary of Public Comment and Agency Response 32
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List of Figures
Figure 1 Location map - MCLB Albany and PSC 3 1-a
Figure .2 Geologic section of the Albany area 8-a
Figure 3 Potentiometric surface of the Upper Floridan aquifer in the Albany area 9-a
11
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List of Tables
Table 1 Contaminants Exceeding Screening Criteria, PSC 3 10
Table 2 Analytes Detected in Groundwater, PSC 3 12
Table 3 Contaminants of Potential Concern in Groundwater, PSC 3 14
Table 4 Summary of Alternatives Evaluation 19
Table 5 Summary of ARARs to be Considered, PSC 3 20
Table 6 Estimated Influent Concentrations and Discharge Criteria, PSC 3 26
Table 7 Estimated Capital and Operations & Maintenance Costs, PSC 3 27
111
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List of Acronyms
The following list of acronyms, and abbreviations are provided to assist in the review of this
document.
ARAR Applicable or Relevant and Appropriate Requirements
bis Below Land Surface
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act
CFR Code of Federal Regulations
CLEAN Comprehensive Long-Term Environmental Action, Navy
DCE 1,2-Dichloroethene
ODD
DDE 1,1 -Dichloro-2,2-bis(4-chlorophenyl) ethylene
DDT Dichlorodiphenyltrichloroethane
DNR Department of Natural Resources
DOT Department of Transportation
EA Environmental Assessment
EIS Environmental Impact Statement
EP Extraction Procedure
EPA Environmental Protection Agency
EPD Environmental Protection Division
gpm gallons per minute
IAS Initial Assessment Study
IR Installation Restoration
IROD Interim Record of Decision
MCL Maximum Contaminant Level
MCLB Marine Corps Logistics Base
MCSC Marine Corps Supply Center
NAAQS National Ambient Air Quality Standards
NCP National Contingency Plan
NPL National Priorities List
O & M Operations and Maintenance
OSHA Occupational Safety and Health Administration
OU Operable Unit
iv
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PCBs Polychlorinated Biphenyls
PCE Perchloroethene, Tetrachloroethene
POTW Publicly Owned Treatment Works
PPB parts per b i 11 ion
PSC Potential Source of Contamination
RCRA Resource Conservation and Recovery Act
RFI RCRA Facility Investigation
RI/FS Remedial Investigation/Feasibility Study
RI/RA Remedial Investigation/Risk Assessment
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
SDWA Safe Drinking Water Act
SOUTHDIV Southern Division, Naval Facilities Engineering Command
SWMU Solid Waste Management Unit
TCE Trichloroethene
TOC Total Organic Carbon
USEPA United States Environmental Protection Agency
VGA Volatiles
VOCs Volatile Organic Compounds
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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
Marine Corps Logistics Base
Operable Unit One, Potential Source of Contamination Three
814RadfordBlvd
Albany, Georgia 31704-1128
STATEMENT OF PURPOSE
This Decision Document presents the selected interim remedial action to prevent migration of
contaminated groundwater for Potential Source of Contamination Three (PSC 3) 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 this site, if not addressed by
implementing the response action selected in this Interim Record of Decision (IROD), may
present an imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The primary objective of this interim remedial action is to prevent further migration of
contaminated groundwater at OU1, PSC3. This interim remedial action is necessary since
further migration of the groundwater may result in contamination of private wells located near
OU1, PSC 3. This selected remedy will employ hydraulic containment to prevent further
migration of the contaminated groundwater.
The selected remedy will include the following major components:
- Groundwater extraction to control migration of the contaminant plume.
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- on-site treatment of the extracted groundwater using an air stripper unit for the purpose
of achieving pretreatment levels prior to discharge to the local Publicly Owned
Treatment Works (POTW).
- on-site treatment of vapor-phase emissions from the air stripper unit.
- discharge of the treated groundwater to the POTW.
A final remedy, which addresses permanence and treatment to the maximum extent practicable,
as required by CERCLA, as amended, and the NCP, is being developed for this site and will be
contained in a subsequent final Record of Decision for this operable unit.
DECLARATION
This interim remedial action is protective of human health and the environment, complies with
federal and state applicable or relevant and appropriate requirements 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. Although
partially addressed in this remedy, the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element will be addressed by both this
and the final response action. Subsequent actions are planned to address fully the principal
threats posed by the conditions at this site. Remedial activities associated with this remedy
which continue beyond the interim action phase will require a review be conducted to ensure
that the remedy continues to provide adequate protection of human health and the environment
within five years after commencement of the remedial action. This review is necessary because
this remedy will result in hazardous substances remaining on site above health-based levels.
Because this remedy is an interim action ROD, review of this site and of this remedy will be
ongoing as the investigation and final remedial alternatives continue to be developed for this
Operable Unit.
Signature ^Ji D. Stewart Date
fajor General
)mmanding General, MCLB Albany
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PAGE 1/2
MAR-19-96 14,54 FROM = RCRA COMPLIANCE SECTION ID:404 347 S20S - PAGE
't
* *2 '< '
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
»
OCT251994
fTREET. N.E.
*IA 3CO69
OCTlt H«4
34»COUNTLAIMO STREET. N.E.
ATLAMTA. GCOROIA 3C069
CERTIFIED KAIL
RBTUHH RKCBiyr REOPgBTBD
1
4WD-FPB
Major Genoral J. D. Stewart
Marine Corps Logistics Base
814 HAdford Boulftvord
Albany, Georgia 3107-1128
SUBJi Inter Lm Record of Declaion
Operable Unit 1, PSC 3
Karino Corps Logistics Base
Albany, Georgia
Dear Sin
The U.S. Knvironae&tal Protection Agency (BFA)r has reviewed
the above referenced decision document and concur* with the
selected remedy for the interim remedial action at Operable Unit
1, PSC 3. The objective of this interim remedial action ia to
prevent further migration of contaminated groondwater at Operable
Unit I, PSC 3.
TM« interia remedial action ia necessary since further
migration of the groundwater may result in contamination of
private wells located near Operable Unit 1, PSC 3. The aelected
remedy includes groondwater extraction to control Migration of
the contaminant plune and oil-site treatment of the extracted
groundvatar prior to discharge to the Albany, Georgia, Publicly
Owned Treatment Works.
This concurrence is. with the understanding that the proposed
action is an interim action and that the need for any future or
final remedial action will be addressed following completion of
the remedial investigation for this Operable Unit. The BP& will
continue to assist the Marine Corps Logistics Base (MCLB) in
determining final remedial action decisions for this site.
Of
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MAR-19-96 14:55 FROM:RCRA COMPLIANCE SECTION 10=484 347 5205
PACE 2/2
He appreciate this opportunity to assist,
forward to working with you on future effort^
Sincaroly/
Patrick M. ttobln
Deputy Regional
ccx Harold F. Rebels, GAEPD .
Captain R. 6. Tyler, SftVP&C
the
and look
Ac nini0trator
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DECISION SUMMARY
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1.0 SITE NAME, LOCATION AND DESCRIPTION
MCLB Albany is an active facility occupying approximately 3,500 acres 5 miles east-southeast
of the City of Albany, Georgia. 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.
Operable Unit One (OU1), Potential Source of Contamination (PSC) Three is located in the
east-central portion of the Base, just inside the northern perimeter. Figure 1 shows the location
of MCLB Albany and the approximate location of PSC 3. OU1, PSC 3 is the former location of
a long-term landfill. This landfill is a 38-acre trench and area-type landfill used for the disposal
of solvents, paints, thinners, strippers, DDT, sludges, PCB's, garbage and paper from 1954 to
1988.
MCLB Albany currently serves as a military logistics center.
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0>
ALBANY
MCLB
ALBANY
SCALE
r—-
0 2,500 5,000
PSC26, PSC3 XS.
"7^T"~^~~
MCLB ALBANY
10,000 FT
FIGURE 1
VICINITY MAP
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2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
MCLB Albany, as it is known today, was commissioned on March 1, 1952, as the Marine Corps
Depot of Supplies. Construction of the base continued until early 1954, when the facility was
sufficiently complete to assume supply support for Marines east of the Rocky Mountains and in
the Atlantic Ocean area. The facility was renamed Marine Corps Supply Center (MCSC) on
July 29, 1954.
Between 1954 and 1967, MCSC Albany controlled and managed supplies at storage and issue
locations in the eastern half of the United States, the Atlantic Ocean, Caribbean Sea, and
Mediterranean Sea. The base has also functioned as a Marine Corps Depot Maintenance
Activity since February 1954.
MCSC Albany was redesignated Marine Corps Logistics Support Base, Atlantic, on April 1,
1976. During 1976, inventory control, financial management, procurement, and technical
support functions performed at MCSA Philadelphia were relocated to Albany. On November 1,
1978, the facility was renamed Marine Corps Logistics Base, Albany. The full spectrum of
logistics support functions required for the life cycle support of the Marine Corps Weapons
Systems and Equipment is now performed at this base.
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.
Initial Assessment Study (IAS)
An IAS was conducted by Envirodyne Engineers, Inc., at MCLB Albany in 1985 to identify and
assess Potential Sources of Contamination (PSCs) posing a potential threat to human health or
the environment due to contamination from past hazardous materials disposal practices. Eight
PSCs were identified at MCLB Albany based on historical data, aerial photographs, field
inspections, and personal interviews. All eight PSCs including PSC 1, East Disposal Area; PSC
2, Rubble Disposal Area; and PSC 3, Long-term Landfill were evaluated to determine
contamination characteristics, migration pathways, and potential receptors.
The primary pathways identified for migration of contaminants from the eight IAS PSCs include
erosion, surface water runoff, and groundwater transport. The predominant topographic slope is
toward the MCLB drainage canal, which originates on the MCLB Albany facility and flows
beyond the western edge of MCLB to ultimately discharge to the Flint River. The predominant
direction of regional groundwater flow is also toward the Flint River, which is located
approximately 2.7 miles west of the base. Potential receptors identified include aquatic
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organisms in the receiving waters, predators and other animals relying on these areas for food
and water, and humans using the Flint River for recreational purposes.
The IAS concluded that six of the eight PSCs, including PSCs 1, 2, and 3, warranted further
investigation under the NACIP Program to assess long-term impacts. The primary
recommendation of the study was to conduct a confirmation study to confirm or disprove the
existence of the suspected contamination and to quantify the extent of any existing problems.
Confirmation studies at these PSCs were recommended to determine: (1) whether a threat to
human health or the environment existed, (2) the extent of contamination, and (3) the potential
for contaminant migration.
Confirmation Study
A Confirmation Study was conducted by McClelland Engineers at the MCLB Albany facility in
1987 to verify the existence of contamination at nine PSCs: (a) the six PSCs recommended for
further evaluation by the IAS, and (b) three additional PSCs identified as threats to human health
or the environment (PSCs 9, 10, and 11). Three of these PSCs now comprise OU1 (PSCs 1, 2,
and 3).
The field investigations completed during the 1987 Confirmation Study at OU1, PSC 3, are
summarized below:
A total of seven soil borings were drilled at PSC 3 to total depths ranging from 25 feet to
49 feet below land surface (bis). Four monitoring wells were installed in soil borings. No
geophysical surveys were conducted, and no surface water samples were collected.
Four soil samples, two sediment samples, and one groundwater sample were collected for
laboratory analyses. Laboratory analyses included acid and base-neutral extractables, VOAs,
pesticides and PCBs, EP toxicity metals, total organic carbon (TOC), specific conductance, and
pH.
Methylene chloride was detected in one soil and two sediment samples. Phthalate esters
were detected in three soil samples. Lead was detected in two soil and two sediment samples.
Chromium, arsenic, and mercury were detected in two sediment samples. Only one groundwater
sample was collected for analysis and methylene chloride and bis(2-ethylhexyl) phthalate were
detected in this sample. Methylene chloride and phthalate esters are common laboratory and
sampling artifacts and EP toxicity metal concentrations are below Maximum Contaminant
Levels (MCLs) as defined by 40 CFR 161.
Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFT)
Subsequent to the 1987 Confirmation Study, the nine PSCs investigated were identified as Solid
Waste Management Units (SWMUs) by the Georgia EPD in the Part B RCRA Permit for MCLB
Albany. Terms of this permit required that an RFI be conducted at each of the PSCs to
determine the nature and extent of releases, and the potential pathways of contaminant migration
3
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to the environment. Applied Engineering and Science, Inc., completed the RFI and submitted a
final report in 1989.
During the RFI, a total of seven wells, ranging in depth from 30.41 feet to 110.53 feet bis, were
installed at PSC 3. Four groundwater samples were collected for laboratory analyses. No
geophysical surveys were conducted and no surface water or sediment samples were collected.
Laboratory analytical results for all samples except one were below quantitation limits or below
MCLs for metal concentrations. Only VOAs (trans 1,2-dichloroethene and trichloroethene) were
detected in the groundwater sample from one well.
Remedial Investigation/Risk Assessment (RI/RA) Report
The conclusions of previous investigations indicated a need for additional data collection at 25
PSCs at MCLB Albany. Data were sufficient to indicate the requirement for a Remedial
Response as described in the NPL to characterize the extent of contamination, assess releases,
and develop responses. As a result, ABB Environmental Services, Inc. (ABB-ES) was
contracted under the Comprehensive Long-Term Environmental Action, Navy (CLEAN)
contract to prepare Remedial Investigation and Feasibility Study (RI/FS) Workplans, Site
Screening Workplans, and associated planning documents for PSCs at MCLB Albany. The draft
RI/RA for OU1 and OU2 was released in January 1994. The results of this investigation for
OU1, PSC 3 are shown below.
Data obtained from the analyses of samples collected at OU 1, PSC 3 indicate that significant
contamination exists at this site. Contaminants of concern identified by the RA, in conjunction
with the distribution of contamination observed at PSC 3, indicate that the major contaminants
of concern are the following: the chlorinated compounds 1,2-dichloroethene (1,2-DCE), carbon
tetrachloride, chloromethane, tetrachloroethene (PCE), and trichloroethene (TCE), as well as the
pesticide 4,4'-DDT (and its degradation products 4,4'-DDD and 4,4'-DDE), and the PCB
Aroclor-1260. Elevated concentrations of inorganic analytes were reported at PSC 3, but the
distribution of the analytes is medium specific (e.g. high levels of cobalt were detected in sludge
samples but not in subsurface soil samples). Pesticides and PCBs are contaminants of concern in
the sludge, sediment, and the surface water; inorganic analytes have also been identified as
contaminants of concern in the surface soil, sludge, sediment, surface water, and groundwater.
4,4'DDT and its degradation products were detected throughout the surface soil samples
collected at PSC 3. The detected concentrations in the surface soil samples was generally within
an order of magnitude of background. Because of the widespread use of these pesticides in the
past, these concentrations are attributable to background. However, one sample contained very
high concentrations of DDT and DDE. This sample was collected from the center of the
apparent former disposal area. The PCB Aroclor-1260 was also detected in several surface soil
samples collected from different locations around PSC 3. Pesticides and PCBs were also
detected in subsurface soil and sludge samples collected at PSC 3. Subsurface soil samples
containing high levels of dichlorodiphenylethanes (DDT, DDD, or DDE or Aroclor-1260) were
collected from various locations throughout PSC 3. The locations that show the highest
concentrations correlate with aerial photographs showing activity in the area since the late
4
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1950's. Neither pesticides nor PCBs were detected in PSC 3 groundwater samples. Two areas
of groundwater contamination have been identified. The groundwater samples collected from
the western portion of PSC 3 contain high levels of chlorinated organics (carbon tetrachloride,
TCE, and PCE). This contamination is apparently from a source farther to the west. The
groundwater samples collected from the northeastern portion of PSC 3 also contain high levels
of chlorinated organics (1,2-DCE, TCE, PCE, and carbon tetrachloride). The source of this
contamination has not been determined. Acquisition of additional information is currently
ongoing and data will be summarized during the feasibility study.
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3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Proposed Plan for the Interim Corrective Measure at Operable Unit One, Potential Source of
Contamination Three was released to the public on July 12, 1994. This document was made
available to the public in the Information Repository located at the Dougherty County Public
Library, and in the Administrative Record located at the Environmental Branch Office, Bldg
5501, Marine Corps Logistics Base, Albany, Georgia 31704-1128. The public comment period
for the Proposed Interim Corrective Measure was July 12 - August 25, 1994. The public notice
of the Proposed Interim Corrective Measure was published in the Albany Herald and the Atlanta
Constitution on both July 12, 1994 and July 24, 1994. A public meeting was held on July 26,
1994 in Albany. At this meeting, representatives from USEPA, Georgia Environmental
Protection Division (GEPD), Naval Facilities Engineering Command, Southern Division
(SOUTHDIV), and MCLB Albany were available to answer questions about PSC 3 and the
interim corrective measure 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 Plan identified the preferred interim corrective measure at PSC 3 as Alternative
No. 2. Alternative No. 2 is described as follows: Installation of groundwater recovery wells,
installation of a shallow tray air stripper for treatment of contaminated groundwater, installation
of vapor-phase carbon units for off-gas treatment, and discharge of treated groundwater to the
City of Albany's Publicly Owned Treatment Works. Because no written or verbal comments
were received, USEPA, GEPD, SOUTHDIV, and MCLB determined that no significant changes
to the Proposed Plan's preferred interim corrective measure were necessary.
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4.0 SCOPE AND ROLE OF REMEDIAL ACTION AT POTENTIAL
SOURCE OF CONTAMINATION THREE
The response action presented in this document is an Interim Remedial Action since it represents
only one phase of the comprehensive investigation and remediation program at OU1, PSC 3.
This interim action is limited to hydraulic containment of contaminated groundwater at OU1,
PSC 3. A final remedy, which addresses permanence and treatment to the maximum extent
practicable, as required by CERCLA, as amended, and the NCP is being developed and will be
contained in a subsequent final Record of Decision for this operable unit.
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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 (bis).
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 2.
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 overburden, decreasing the amount of groundwater recharge to the
Upper Floridan aquifer from infiltration of precipitation, and controlling the rate of infiltration
of chemical contaminants. Maximum annual water-level fluctuations may be in the range of 10
to 15 feet, based on observed differences in water levels measured at different times of the year
over the last 5 years. Water levels in area wells are highest during February through April and at
a minimum during November through January, when the overburden wells are commonly dry of
water. Hydraulic properties of the overburden are controlled primarily by the amount of sand
and clay present.
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
unconfmed, 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
solution cavities can produce transmissivity values as high as 178,000 square feet per day
(ft2/day).
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Tola! Depth: 650 ft.
EXPLANATION
Upper Floridan Aquifer
•*« Well Idenlificilion
Geophysical Logs
C Calfper
Q Natural Qamma
R Resistivity
2.5 5 MILES
SCALE: 1" = 5 MILES
VtrtKel fcalf great!? ritggrrttrd
SCA LCVCL
Sourcei Hicks and Others (1087)
FIGURE Z
GEOLOGIC SECTION OF THE ALBANY AREA
MARINE CORPS LOGISTICS BASE
ALBANY, GEORGIA
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Published studies of the Upper Floridan aquifer indicate that the potentiometric surface slopes
westerly to southwesterly in the MCLB Albany area (Figure 3). 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 exclusively within this pine flatwoods
habitat. Although MCLB Albany is a potential habitat for this species due to the presence of
pine flatwoods, the red-cockaded woodpecker is not found at this installation.
The presence of two rare and threatened species has been confirmed at this facility. The
American alligator (Alligator mississippiensis), now in a threatened status, 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 listed rare 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.
5.4 NATURE AND EXTENT OF CONTAMINANTS
The nature, extent, and concentration of hazardous substance contamination at OU 1, PSC 3 was
studied during field investigations performed from March 1992 to the present. The following
summarizes the major observations from these investigations.
5.4.1 Contaminants Detected at PSC 3
Hazardous substances detected at PSC 3, and the media affected are listed in Table 1.
9
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•y^gSisP^^Xgy'v •""
7 \v » »M°^ .><^V_
S®
! ^
13L057
I3L0.5* ||?L04«
150— Potenttometrtc Isoptoth-Shows attttud* at which
water would have stood In tightly cased weds.
Dashed where approximately located. Contour Interval
Is 10 feet. Datum Is NGVD of 1929
ground water flow
" OQ.OOHIIITV CO»UKOII
^-.TT+T.-.TT
APPROXIMATE SCALE:
V-3 MLES
SOURCE: HCK3 AM) OTKR8. 1987
FIGURE 3
POTENTIOMETRIC SURFACE OF THE
UPPER FLORIDAN AQUIFER IN THE
ALBANY AREA, NOVEMBER 1985
MARINE CORPS
LOGISTICS BASE
ALBANY, GEORGIA
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Table 1
Contaminants Exceeding Screening Criteria
Potential Source of Contamination (PSC) 3
MCLB Albany
Analyte
Surface Soil
Subsurface
Soil
Sludge
Sediment
Surface
Water
Groundwater
Volatiles
Carbon
Tetrachloride
Chloromethane
1 ,2-Dichloroethene
(Total)
Tetrachloroethene
Trichloroethane
1,1,1-Trichloro-
ethane
1 , 1-Dichloroethane
1 , 1 -Dichloroethene
Carbon Disulfide
Chloroform
Vfethylene Chloride
X
X
X
X
X
X
X
X
X
X
X
Semivolatiles
Jenzo (a)
anthracene
Jenzo (a) pyrene
Jenzo (b)
luoranthene
Benzo (k)
luoranthene
Chrysene
?luoranthene
Phenanthrene
'henol
*yrene
X
X
X
X
X
X
X
X
•
X
10
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Table 1, continued
Anaiyte
Surface Soil
Subsurface
Soil
Sludge
Sediment
Surface
Water
Ground water
Pesticides and PCBs
4,4'-DDD
4,4'-DDE
4,4'DDT
Arochlor-1260
Dieldrin
alpha-Chlordane
gamma-Chlordane
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
norganics
Aluminum
Antimony
Arsenic
iarium
Jeryllium
Cadmium
Chromium
Cobalt
Copper
Cyanide
Lead
Manganese
Mercury
Nickel
Selenium
Silver
'hallium
Vanadium
Zinc
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X ^
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
To provide a focus for the Interim Remedial Action for OU1, PSC 3, a summary of the number
of samples with detections and the concentrations found in groundwater are presented in Table 2
for each contaminant at OU1, PSC 3.
11
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Table 2
Analytes Detected in Groundwater
Potential Source of Contamination (PSC) 3
MCLB Albany
Analyte
No. of Samples in which the
Analyte is Detected/Total No.
of Samples
Range of Detected
Concentrations, including
monitoring wells located on the
northern perimeter of PSC 3 (in
ppb - parts per billion)
Volatiles
Carbon Tetrachloride
Chloromethane
1,2-Dichloroethene (Total)
Tetrachloroethene
Trichloroethene
Acetone
Carbon Disulfide
Chloroform
Phenol
4/20
3/20
8/20
9/20
10/20
1/20
1/20
2/20
1/19
2
5 to 6
32 to 860
5 to 170
13 to 210
440
2
12 to 39
2
Semivolatiles
Di-n-butylphthalate
)i-n-octylphthalate
>is 2-Ethylhexylphthalate
1/19
2/19
8/19
1
2 to 8
Ito5
Inorganics
Aluminum
Antimony
Arsenic
Barium
Jeryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Cyanide
ron
19/19
4/19
4/19
19/19
3/19
4/19
19/19
9/19
3/19
17/19
1/19
19/19
132 to 12500
13 to 18
Ito4
6 to 200
1 to 3
1 to 9
15200 to 804000
5 to 23
7 to 18
Itol9
11
20 to 11800
12
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Table 2, continued
Analyte
Lead
Magnesium
Vtanganese
Mercury
Nickel
'otassium
Selenium
Sodium
Vanadium
Zinc
No. of Samples in which the
Analyte is Detected/Total No.
of Samples
15/19
19/19
19/19
6/19
4/19
19/19
9/19
19/19
16/19
18/19
Range of Detected
Concentrations, including
monitoring wells located on the
northern perimeter of PSC 3 (in
ppb - parts per billion)
Ito42
197 to 3900
3 to 1500
0.7 to 10
8 to 20
602 to 37900
Ito2
1680 to 24000
3 to 66
15 to 75
5.4.2 Contaminant Sources
PSC 3 is a former long-term landfill. This landfill is an approximate 38-acre trench and
area-type landfill used for the disposal of solvents, paints, thinners, strippers, DDT, sludges,
PCB's, garbage and paper from 1954 to 1988. The landfill is located approximately 2,800 feet
due west of the western edge of the Indian Lake Refuge Area at North Shaw Road. Landfill
operations included burning of disposal materials until the early 1970's. As a result,
contamination is present in subsurface soil and groundwater.
13
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6.0 SUMMARY OF SITE RISKS
The findings of an assessment of potential risks to human health and the environment as a result
of the groundwater contamination migrating offsite was reported in the Draft Remedial
Investigation/Risk Assessment (RI/RA) for Operable Units One and Two (OU1 and OU2)
(January 1994). This document was released prior to the completion of the investigation of
offsite monitoring wells. However, the domestic use of off-site groundwater is a potential future
exposure pathway used in RA calculations.
The results of the Draft RI/RA Report for OU1 and OU2 suggested potential adverse effects
from domestic use of groundwater based on the estimated excess lifetime cancer risk and hazard
indices. Trichloroethene, Carbon Tetrachloride, 1,2-Dichloroethene, and Tetrachloroethene
from monitoring wells located at the northern boundary of OU1, PSC 3 created a potential
increased lifetime cancer risk for the ingestion pathway. The concentrations of these
Contaminants of Concern for groundwater within the area of the planned interim action are
shown in Table 3, as compared to the Maximum Contaminant Level (MCLs) cited in the Safe
Drinking Water Act (SOWA).
Tables
Contaminants of Potential Concern in Groundwater
Potential Source of Contamination (PSC) 3
MCLB Albany
Analyte
Trichloroethene
1 ,2-Dichloroethene
Tetrachloroethene
Carbon Tetrachloride
Chloromethane
Concentration in area of
planned interim action (in
ppb - parts per billion)
68
310
170
2
Not detected
Maximum Contaminant
Level (MCL) for safe
drinking water (in ppb)
5
70
5
5
5
The draft RI/RA report found that the critical exposure pathway is related to the offsite
migration of on-site contaminant sources in groundwater. Based on the preliminary results of
the draft RI/RA report, MCLB Albany, Georgia EPD, and EPA have decided that there is
sufficient potential risk to the public and environment to warrant an interim action. The
principal goal is to decrease the risk to nearby private water well users of exposure to
contaminated groundwater. This will be done by mitigating the spread of the high concentration
portion of the groundwater plume at OU1, PSC 3 and retarding the migration of the
contaminants emanating from the source areas.
14
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7.0 DESCRIPTION OF ALTERNATIVES
Three alternatives were considered for addressing the contamination in the groundwater plume at
OU1, PSC 3. The first alternative would be to take no action at this time and simply allow the
groundwater to continue to migrate offsite. The second and third alternatives would provide for
an interim action which will provide a hydraulic containment system through groundwater
extraction. Both the second and third alternatives will initiate containment of both the sources
and high concentration areas of the groundwater plume.
The following is a description of the alternatives evaluated for PSC 3:
7.1 Alternative 1 - No Action
Pursuant to Section 300.430(e)(6) of the NCP, MCLB Albany is required to consider a no action
alternative. This alternative is useful as a baseline for comparison between potential alternatives.
Under this alternative, no further action would be taken with regard to the contaminated
groundwater.
7.2 Alternative 2 - Extraction and Treatment with Liquid Phase Carbon
This alternative involves the installation of an extraction and treatment system to initiate
hydraulic containment of the groundwater plume. This alternative will include the following
activities.
1) The contaminated groundwater will be extracted at a minimum of two (2) locations
along the northern boundary of OU1, PSC 3. The contaminated groundwater will be pumped at
a rate of approximately 20 gallons per minute (gpm) to reduce further migration of
contamination. This pumping rate may be modified during operation to optimize hydraulic
containment by adjusting flow from the extraction wells.
2) The extracted groundwater will be collected and piped to the treatment system, which
will consist of two liquid-phase carbon adsorbers in series.
3) The treated water will be discharged via the sanitary sewer to the City of Albany
Publicly Owned Treatment Works (POTW).
4) The remedy does not address source remediation, however; the remedy will address
migration of contaminated groundwater from source areas.
Approximately three (3) months will be required to complete the design and construction for this
alternative. Alternative 2 (listed as Alternative No. 1 in the Proposed Plan) satisfies all
identified ARARs for the interim action cited within this document.
15
-------
7.3 Alternative 3 - Extraction and Treatment with Air Stripping
This alternative involves the installation of an extraction and treatment system to initiate
hydraulic containment of the groundwater plume. This alternative will include the following
activities:
1) The contaminated groundwater will be extracted at a minimum of two (2) locations
along the northern boundary of OU1, PSC 3. The contaminated groundwater will be pumped at
a rate of approximately 20 gallons per minute (gpm) to reduce further migration of
contamination. This pumping rate may be modified during operation to optimize hydraulic
containment by adjusting flow from the extraction wells and to support subsequent actions.
2) The extracted groundwater will be collected and piped to the treatment system, which
will consist of a shallow tray air stripping unit followed by vapor-phase carbon units for
treatment of off-gas emissions.
3) The treated water will be discharged via the sanitary sewer to the City of Albany
Publicly Owned Treatment Works (POTW).
4) The remedy does not address source remediation, however; the remedy will address
migration of contaminated groundwater from source areas.
Approximately three (3) months will be required to complete the design and construction for this
alternative. Alternative 3 (listed as Alternative No. 2 in the Proposed Plan) satisfies all
identified ARARs for the interim action cited within this document.
16
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8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section provides the basis for determining which alternative (i) meets the threshold criteria
of overall protection of human health and the environment, State approval, and compliance with
ARARs, and (ii) provides the best balance between effectiveness and reduction of toxicity,
mobility, or volume through treatment, implementability, and cost, and (iii) satisfies community
acceptance.
Federal law requires nine criteria be used for evaluating the expected performance of remedial
actions. The nine criteria are introduced below and the present proposal is evaluated on the basis
of these criteria
1. Overall protection of human health and the environment. Requires that the alternative
adequately protect human health and the environment, in both the short and long-term.
Protection must be demonstrated by the elimination, reduction, or control of unacceptable risks.
2. Compliance with applicable or relevant and appropriate requirements (ARARs). The
alternatives must be assessed to determine if they attain compliance with applicable or relevant
and appropriate requirements of both state and federal law.
3. Long-term effectiveness and permanence. Focuses on the magnitude and nature of the
risks associated with untreated waste and/or treatment residuals. This criterion includes
consideration of the adequacy and reliability of any associated engineering controls, such as
monitoring and maintenance requirements.
4. Reduction of contaminant toxicity, mobility, or volume through treatment. The degree
to which the alternative employs treatment to reduce the toxicity, mobility, or volume of the
contamination.
5. Short-term effectiveness. The effect of implementing the alternative relative to the
potential risks to the general public, potential threat to workers and the time required until
protection is achieved.
6. Implementability. Potential difficulties associated with implementing the alternative.
This may include: the technical feasibility, administrative feasibility, and the availability of
services and materials.
7. Cost. The costs associated with the alternatives. These include the capital cost,
annual operation and maintenance and the combined net present value.
8. Federal/State acceptance. The incorporation of any formal comments by the Georgia
Environmental Protection Division to the interim action.
17
-------
9. Community acceptance. The consideration of any formal comments by the
community to the Proposed Plan for the interim action.
The criteria listed above are categorized into three groups. The first, second, and eighth
categories are threshold criteria. The chosen final alternative must meet the threshold criteria to
be eligible for selection. The five primary balancing criteria include criterion three through
seven. The last criterion is termed the modifying criterion. The modifying criterion was
evaluated following issuance of the Proposed Plan for public review and comment.
An analysis was performed on the alternatives using the nine evaluation criteria in order to select
a site remedy. Table 4 presents a summary of this detailed analysis.
A brief summary of each alternative's strengths and weaknesses with respect to the evaluation
criteria follows:
Overall Protection of Human Health and the Environment
Alternative 1 does not provide protection of human health or the environment. Alternatives 2
and 3 are intended to serve as an interim action which will provide protection to both the public
and the environment by limiting migration of the contaminated groundwater plume.
Compliance with ARARs
Table 5 lists the ARARs for this interim remedial action. This table only lists those ARARs
pertinent to the limited scope of this interim remedial action. Therefore, the ARARs listed in
Table 5 pertain to the extraction and treatment system operations and not to any ARARs
associated with aquifer remediation goals. Such ARARs will be addressed in subsequent
remedial actions.
Both extraction and treatment alternatives support the health-based Federal and State ARARs
through the treatment of the contaminants to regulatory standards. Both alternatives will also
reduce the migration of contaminants and potential future exposure of the public.
Long-term Effectiveness and Permanence
The no action alternative could cause potential health and environmental impacts to occur
through a future exposure scenario. The extraction and treatment systems are intended as an
interim action until sufficient information can be accumulated to formulate the final solution for
OU1, PSC 3. The effectiveness and efficiency of the system will be evaluated for potential final
actions.
18
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Table 4
Summary of Alternatives Evaluation
Potential Source of Contamination (PSC) 3
MCLB Albany
Criterion
Overall Protection of
Human Health and the
Environment
Compliance with
ARARs
^ong-Term
Effectiveness and
3ermanence
leduction of Toxicity,
Mobility, or Volume
Short-Term
effectiveness
mplementability
Costs Capital
O&M
7ederal/State
Acceptance
Community
Acceptance
Alternative 1
No action
No reduction in
potential risks.
Does not meet ARARs
Could cause potential
health and
environmental impacts
to occur through a
future exposure
scenario.
Natural attenuation
may reduce
contaminant levels, but
is unpredictable.
No increased risk to
community and no risk
to workers because no
remedial action is
implemented.
Nothing to implement.
$0
$0
Federal/State will
likely not prefer this
alternative.
Sfo public comments
received during public
comment period.
Alternative 2
Liquid-Phase Carbon
Protective by limiting
migration of the
contaminant plume.
Will comply with
ARARs.
Intended as an interim
action until sufficient
information can be
accumulated to
formulate the final
solution for this OU.
Reduces the mobility
of the groundwater
plume.
No threat to nearby
communities due to
operation and
maintenance of
system. Work
completed within 3
months.
Proven technology
with equipment readily
available.
$135,000
$78,000
Federal/State favors
treatment over no
action.
^o public comments
received during public
comment period.
Alternative 3
Air Stripping Unit
Protective by limiting
migration of the
contaminant plume.
Will comply with
ARARs.
Intended as an interim
action until sufficient
information can be
accumulated to
formulate the final
solution for this OU.
Reduces the mobility
of the groundwater
plume.
No threat to nearby
communities due to
operation and
maintenance of
system. Work
completed within 3
months.
Proven technology
with equipment readily
available.
$142,000
$51,000
Federal/State favors
treatment over no
action.
No public comments
received during public
comment period.
19
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Table 5
Summary of Applicable or Relevant and Appropriate Requirements to be Considered
Potential Source of Contamination (PSC) 3
MCLB Albany
Actions
Standard,
requirements
Description
Comments
Chemical-Specific
Treatment of
contaminated
eroundwater
Safe Drinking Water
Act (SDWA) 40 CFR
141.
Safe Drinking Water
Act O.C.G.A. §
U-5-llOetseq. and
Rules, Chapter
391-3-5.
Georgia Water Quality
Control Act
O.C.G.A.§ 12-5-20 et
seq. and Rules,
Chapter 391-3-6.
Provides Maximum
Contaminant Levels
(MCLs).
Establishes MCLs
which are health-based
standards for public
water systems.
Establishes treatment
standards for public
water systems.
Final or proposed
MCLs exist for
groundwater
contaminants at
MCLB Albany.
Treatment of off gas
missions
rlean Air Act,
National Ambient Air
Quality Standards
(NAAQS) 40 CFR 50.
Air Quality Act of
1978 O.C.G.A. §
12-9-1 etseq. and
lules, Chapter
391-3-1.
NAAQS for
particulate matter may
be considered during
treatment.
Establishes standards
for ambient air quality
to protect public health
and welfare.
20
-------
Table 5, continued
Actions
Standard,
requirements
Description
Comments
Location-Specific
Protection of the
environment
10CFR1021, 40CFR
1500-1508
Georgia
Comprehensive Solid
Waste Management
Act, O.C.G.A. §
1 2-8-20 et seq. and
Rules, Chapter
391-3-4.
Endangered Wildlife
and Wildflower
Preservation Act of
1973 O.C.G.A. §
12-6-1 72 etseq. and
Rules, Chapter
391-4-10.
Protection of the
environment. Prepare
an Environmental
Impact Statement
(EIS) or
Environmental
Assessment (EA) or
Categorical Exclusion.
Establishes facility
location standards.
Critical habitat upon
which endangered or
threatened species
depends.
Any federal action that
will have a significant
impact on the quality
of the environment.
Action-Specific
Remedial action
Occupation Safety and
Health Administration
(OSHA)29CFR1910,
1926.
Georgia Hazardous
Site Response Act
O.C.G.A. § 12-8-90 et
seq.
Requires corrective
action for releases of
hazardous wastes,
constituents, and
substances.
OSHA requirements
will be complied with
during implementation
of onsite remedial
alternatives.
21
-------
Table 5, continued
Actions
Standard,
requirements
Description
Comments
Remedial action
'continued)
Georgia Hazardous
Waste Management
Act O.C.G.A. §
12-8-60 etseq. and
Rules, Chapter
391-3-11.
Establishes minimum
state standards which
define the acceptable
management of
hazardous waste for
owners and operators
of facilities which
treat, store, or dispose
of hazardous wastes in
the State of Georgia.
Surface Water Control
40 CFR 122
Implement good site
planning and best
management practices
to control stormwater
discharges
Construction activities
at industrial sites
involving disturbance
of land.
Container Storage
40 CFR 264
Georgia Hazardous
Waste Management
Act O.C.G.A. §
\2-8-60etseq. and
Rules, Chapter
391-3-11.
Containers of
hazardous waste must
be maintained in good
condition, compatible
with hazardous waste
to be stored, closed
duirng storage, and
inspected weekly.
Establishes minimum
state standards which
define the acceptable
management of
hazardous waste for
owners and operators
of facilities which
treat, store, or dispose
of hazardous wastes in
the State of Georgia.
Storage of RCRA
hazardous waste not
meeting small quantity
generator criteria held
for a temporary period
before treatment,
disposal, or storage
elsewhere, in a
container.
22
-------
Table 5, continued
Actions
Standard,
requirements
Description
Comments
Transportation of
treatment residuals
40 CFR 262
Manifest requirements
49 CFR 172, 173, 178,
and 179
Waste must be
packaged and
transported in
accordance with DOT
regulations.
Treatment residuals
which exhibit a RCRA
hazardous waste
characteristic as
defined by Subpart C
of 40 CFR 261 and
offsite transportation
occurs.
The treatment
residuals, if considered
a RCRA hazardous
waste, must be
transported in
accordance with DOT
regulations.
Discharge of treated
mnmdwater
Georgia Water Quality
bntrol Act O.C.G.A.
§ 12-5-20 and Rules,
hapter 391-3-6
Pre-treatment
standards and permit
requirements for
Publicly Owned
Treatment Works,
criteria and standards
for injection wells, and
authorize DNR to
issue discharge
permits.
23
-------
Reduction of Toxicity, Mobility, and Volume
Both extraction and treatment alternatives reduce the migration of the contaminated groundwater
and treat the extracted groundwater prior to discharge. Both alternatives also reduce the volume
of contaminants presently in the groundwater to support the overall cleanup of the site.
Short-term Effectiveness
Short-term construction effects related to dust and noise generation are expected for both
treatment alternatives. The public and the environment will not be exposed to any risks during
the construction or operation of the treatment systems. Both alternatives are designed to
eliminate the accidental release of contaminated groundwater during the treatment process. The
off-gas from the air stripper will be treated prior to its release to the atmosphere and the treated
groundwater will be discharged to the sanitary sewer. The treatment building will also be
surrounded by a separate security fence to limit access to the area.
Implementability
Both treatment systems are proven technologies with equipment readily available from regional
suppliers. Due to the small size of the two systems, minimal land and construction effort will be
required. The air stripping technology is well proven and flexible to readily adapt to potentially
changing site conditions. The Liquid-Phase Carbon treatment alternative, however, will
potentially be more labor intensive and be less flexible to changing site conditions.
Costs
Costs for the construction and operation of the air stripping alternative are slightly less than the
Liquid-Phase Carbon treatment system. This is due to the reduced operation and maintenance
requirements of this alternative and the easy adjustment and modification of the system for
changing site conditions.
Federal/State Approval
The Technical Memorandum, Proposed Plan, and Draft IROD were issued for review and
comments by the Environmental Protection Agency and the Georgia Environmental Protection
Division and the EPA.
Community Acceptance
No comments were received during the public comment period. Community participation and
relations efforts are summarized in the Responsiveness Summary.
24
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9.0 SELECTED REMEDY
The selected remedy for the interim action of the groundwater plume at OU1, PSC 3, is
Alternative 3. Although alternatives 2 and 3 are both proven technologies which will protect
human health and the environment, alternative 3 was chosen as the selected interim remedial
action because of its lower total costs. The principle objectives of this action are to initiate a
first phase remedial action, which in combination with future remedial actions for groundwater,
will ultimately result in achieving the final remedial goals for the site. The groundwater will be
extracted at a minimum of two locations and pumped to a treatment unit. The contaminated
groundwater will be pumped at a rate of approximately 20 gallons per minute (gpm). Data
gathered during the operation will be used to adjust the pumping rate in order to optimize
hydraulic containment by adjusting flow from the extraction wells.
The extracted groundwater will be collected and piped to the treatment system consisting of a
shallow tray air stripping unit, followed by vapor-phase carbon units. The treated water will be
discharged via the sanitary sewer to the City of Albany's Publicly Owned Treatment Works
(POTW).
Air stripping is a process by which water containing VOCs is brought into contact with air. The
stripper will be designed to reduce the concentrations of chlorinated organics in the water. The
effectiveness of this technology is enhanced by exposing an increased surface area of
contaminated water to the airstream. Conventional air strippers spray water into the top of the
column and allow the water to trickle over the packing. Air is blown into the bottom of the
tower and contacts the water in a counter-current flow. All off-gases generated by the air
stripping unit will be treated with vapor-phase carbon units prior to venting to the atmosphere.
Operation of the treatment system will require the sampling of influent groundwater from the
two extraction wells and effluent of the treatment system on a regularly scheduled basis.
Samples of the treated effluent will be split with the City of Albany. Water level measurements
will also be taken at specified monitoring points during this sampling period. Formal
discussions were held between MCLB Albany and the City of Albany on May 23 and 24, 1994.
Based on these discussions, the City of Albany Public Works Department has approved the
discharge of the treated groundwater to the POTW. Table 6 presents the estimated influent
concentrations of the untreated groundwater into the system and water quality concentrations
required for discharge to the POTW.
25
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Table 6
Estimated Influent Concentrations to on-site Pretreatment System
and Discharge Criteria (after pretreatment)
for Contaminants of Potential Concern
Potential Source of Contamination (PSC) 3
MCLB Albany
Contaminants of Potential
Concern (based on Draft
Remedial Investigation/Risk
Assessment Report of Jan
94)
Carbon Tetrachloride
Chloromethane
1,2-Dichloroethene (Total)
Tetrachloroethene
Trichloroethene
Range of Estimated Influent
Concentrations to on-site
Pretreatment System based
on a total flow rate of 20
gallons per minute (gpm) (in
ppb-parts per billion)
1
3
309 to 419
52 to 70
54 to 70
City of Albany Publicly
Owned Treatment Works
(POTW) Influent
Requirements - after
pretreatment (in ppb-parts
per billion)
100
100
20
20
20
System start-up will run the first three months of operation and will include setting the flow rates
and making adjustments to the treatment system operation and off-gas controls.
Water level measurements and collection and analyses of groundwater samples will be
conducted every day for the first three days of operation and then every other day for the
remainder of the first week. Similar measurements will be taken once a week for the remainder
of the first month's operation and then once per month through the end of the third month of
operation. Water level measurements and groundwater sampling will then be conducted on a
quarterly basis for the remainder of the system operation.
Groundwater samples will be collected and analyzed from the influent header prior to the
treatment system and the effluent pipe prior to sanitary sewer discharge. These samples will be
analyzed for VOCs using EPA Method 8240. Analytical results will be summarized into a
quarterly report for submittal to the USEPA Region IV, Georgia EPD, and the City of Albany.
Water level measurements will be taken in conjunction with the groundwater sampling events to
monitor the capture zone of the treatment system. Maps of the potentiometric surface will be
included within each of the quarterly monitoring reports.
26
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The estimated costs of the selected Interim Remedial Action is presented in Table 7.
Table 7
Estimated Capital and Operations & Maintenance (O&M) Costs
for the Selected Interim Remedial Action
Potential Source of Contamination (PSC) 3
MCLB Albany
Alternative
Air Stripping
Estimated Capital
Cost
$142,000
Estimated O&M
Cost (Total)
$51,000
Total Estimated Cost
$193,000
27
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10.0 STATUTORY DETERMINATIONS
MCLB Albany, USEPA, and Georgia EPD concur that the extraction and treatment system using
an air stripper unit will satisfy the CERCLA § 121(b) statutory requirements of: providing
protection of human health and the environment, attaining applicable or relevant and appropriate
requirements directly associated with this action, being cost-effective, utilization of permanent
solutions and alternative treatment technologies to the maximum extent practicable, and a
preference for treatment as a principle element.
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Although the groundwater within the contaminated plume at OU1, PSC 3 is not currently used
as a source of drinking water for local residents, under future use scenarios it presents a potential
threat to human health and the environment. The interim action remedy initiates protection of
human health for the future users through mitigation of the spread of the plume until a final
action is determined. The remedy also provides protection to the environment by providing
treatment of the extracted groundwater prior to discharge to the City of Albany POTW.
10.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARAR's)
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of
1980 was passed by Congress and signed into law on December 11, 1980 (Public Law 96-510).
This act was intended to provide for "liability; compensation, cleanup, and emergency response
for hazardous substances released into the environment and the cleanup of inactive waste
disposal sites." The Superfund Amendments and Reauthorization Act (SARA), adopted on
October 17, 1986 (Public Law 99-499), did not substantially alter the original structure of
CERCLA but provided extensive amendments to it. In particular, § 121 of CERCLA specifies
that remedial actions for cleanup of hazardous substances must comply with requirements or
standards under federal or more stringent state environmental laws which are applicable or
relevant and appropriate to the hazardous substances or particular circumstances at a site.
Inherent in the interpretation of applicable or relevant and appropriate requirements (ARARs) is
the assumption that protection of human health and the environment is ensured.
The final cleanup levels for the groundwater are not addressed in this IROD because such goals
are beyond the limited scope of this action. The final cleanup levels will be addressed by the
final remedial action ROD for OU1.
The treatment system for the extracted groundwater will meet all Federal and State water quality
standards. Additionally, the air stripper will be designed to meet the Federal and State air
quality standards. The treated groundwater will meet the influent limitations of the City of
Albany POTW.
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A listing of ARARs (chemical-specific, location-specific, and action-specific) are provided in
Table 5 of this document. Pursuant to 300.430(f)(l)(ii)(C) of the NCP an alternative which does
not meet federal or state ARARs can be selected if the action is an interim measure that would
become part of a final action which will attain ARARs.
Chemical-Specific ARARs
The principal contaminants of concern in the off-site groundwater are Trichloroethene,
Tetrachloroethene, 1,2-Dichloroethene, Carbon Tetrachloride, and Chloromethane. Therefore,
available chemical-specific criteria that have been promulgated under federal and state law that
are applicable to this response action are listed in Table 5. All contaminants of concern will be
included in the list of compounds to be analyzed on a routine basis.
Location-Specific ARARs
Location-specific requirements "set restrictions upon the concentration of hazardous substances
or the conduct of activities solely because they are in special locations" (53 Fed. Reg. 51394).
Table 5 lists location-specific ARARs that might be pertinent to this remedial action.
Action-Specific ARARs
Performance, design, or other action-specific requirements set controls or restrictions on
particular kinds of activities related to the management of hazardous waste (52 Fed. Reg.
32496). Selection of a particular remedial action at a site will invoke the appropriate
action-specific ARARs that may specify particular performance standards or technologies, as
well as specific environmental levels for discharged or residual chemicals. Federal and state
regulations appear in Table 5.
10.3 COST EFFECTIVENESS
The interim action remedy employs a proven technology which affords overall effectiveness
proportional to its costs such that the remedy represents reasonable value. This action will
utilize a relatively inexpensive technology to initiate control of the source and mitigate the
spread of the contaminated groundwater. This limited scale containment operation should
reduce the cost of the overall remediation at OU1, PSC 3 by retarding the migration of the high
concentration portion of the plume.
10.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
The objectives for this interim action are to stabilize the site by mitigating the spread of the
groundwater plume. This action should provide protection of human health and the
environment. However, it does not fully address, the principle threats to human health and the
environment posed by the plume at OU1, PSC 3. This is not the final action planned for the
groundwater contamination. Subsequent actions will address fully the principle threats posed by
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the conditions at the site. Utilization of a permanent solution will be addressed in the final
decision document for the site.
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
This interim action satisfies the statutory preference for treatment of the discharged effluent as a
principle element of the containment system.
10.6 DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for Interim Remedial Action of the OU1, PSC 3 plume was released for
public comment on July 12, 1994. The Proposed Plan identified Alternative 3 (listed as
Alternative No. 2 in the Proposed Plan), extraction and treatment by air stripping, as the
preferred alternative. No written or verbal comments were submitted during the public comment
period. Therefore, it was determined that no significant changes to the remedy, as it was
originally identified in the Proposed Plan, were necessary.
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COMMUNITY RELATIONS
RESPONSIVENESS 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 26,
1994, at the Dougherty County Chamber of Commerce to discuss the Proposed Plan for the
Interim Corrective Measure for PSC 3 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 One, PSC 3. 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 Albany 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 Albany was placed on the NPL. Installation Restoration
(IR) Program fact sheets have been prepared and made available at the Public Affairs Office at
MCLB Albany. Documents concerning Operable Unit One, PSC 3 can be found in the
Information Repository at the Dougherty County Public Library, and the Administrative Record
at the MCLB Albany Environmental Branch 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 26, 1994.
3.2 PUBLIC COMMENT PERIOD
Comments and questions received during the public comment period that ran from July 12 to
August 25, 1994 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 Other Comments and Questions
No other comments and questions were received during the public comment period.
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