PB97-964503
EPA/541/R-97/033
November 1997
EPA Superfund
Record of Decision:
Fort Ord (Basewide Remedial Investigation Sites)
Marina, CA
1/17/1997
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Record of Decision
Basewide Remedial Investigation Sites
Fort Ord, California
January 13, 1997
United States Department of the Army
HQ, U.S. Army Garrison (Fort Ord)
Fort Ord. California 93941
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CONTENTS
1.0 DECLARATION 1
1.1 Site Name and Location : i
1.2 Basis and Purpose 1
1.3 Site Assessment 1
1.4 Description of the Remedies 4 1
1.5 Statutory Determination _ 2
2.0 DECISION SUMMARY 4
2.1 Site Description 4
2.2 Site History 4
2.3 Enforcement and Regulatory History 4
2.4 Highlights of Community Participation 4
2.5 Scope and Role of Response Actions 5
2.6 Summary of Site Risks 5
2.7 Remedial Action Objectives 5
2.8 Sites 2 and 12 5
2.8.1 Sites 2 and 12: Site History 5
2.8.2 Sites 2 and 12: Site Characteristics 6
2.8.3 Sites 2 and 12: Summary of Site Risks 7
2.8.4 Sites 2 and 12: Remedial Action Objectives 7
2.8.5 Sites 2 and 12: Description of Alternatives : 8
2.9 Sites 16 and 17 '. 9
2.9.1 Sites 16 and 17: Site History 9
2.9.2 Sites 16 and 17: Site Characteristics 10
2.9.3 Sites 16 and 17: Summary of Site Risks 11
2.9.4 Sites 16 and 17: Remedial Action Objectives 11
2.9.5 Sites 16 and 17: Description of Alternatives 12
2.10 Site 31 12
2.10.1 Site 31: Site History 12
2.10.2 Site 31: Site Characteristics 13
2.10.3 Site 31: Summary of Site Risks 13
2.10.4 Site 31: Remedial Action Objectives 14
2.10.5 Site 31: Description of Alternatives 14
2.11 Site 39 :. 15
2.11.1 Site 39: Site History 15
2.11.2 Site 39: Site Characteristics 15
2.11.3 Site 39: Summary of Site Risks 15
2.11.4 Site 39: Remedial Action Objectives 16
2.11.5 Site 39: Description of Alternatives 16
2.12 Surf ace Water Outfalls 17
2.12.1 Surface Water Outfalls: Site History 17
2.12.2 Surface Water Outfalls: Site Characteristics 17
2.12.3 Surface Water Outfalls: Summary of Site Risks 17
2.12.4 Surface Water Outfalls: Remedial Action Objectives 17
2.13 Sites 25 and 33 18
2.13.1 Sites 25 and 33: Site History 18
2.13.2 Sites 25 and 33: Site Characteristics 18
2.13.3 Sites 25 and 33: Summary of Site Risks 18
2.13.4 Sites 25 and 33: Remedial Action Objectives 18
2.14 Summary of Alternatives Comparison 18
2.15 The Selected Remedies 19
2.15.1 Sites 2 and 12: Selected Remedy 19
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January 13, 1997
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2.15.2 Sites 16 and 17: Selected Remedy 19
2.15.3 Site 31: Selected Remedy 20
2.15.4 Site 39: Selected Remedy 20
2.15.5 Surface Water Outfalls: Selected Remedy 20
2.15.6 Sites 25 and 33: Selected Remedy 20
2.16 Statutory Determinations 20
2.16.1 Protection of Human Health and the Environment 20
2.16.2 Compliance with ARARs 21
2.16.3 Cost Effectiveness .-. 21
2.16.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies 21
2.16.5 Preference for Treatment as a Principal Element 21
2.17 Documentation of Significant Changes 22
3.0 RESPONSIVENESS SUMMARY 23
3.1 Overview 23
3.2 Background on Community Involvement 24
3.3 Summary of Comments Received During the Public Comment Period and Department
of the Army Responses 24
3.3.1 Technical Questions/Concerns Regarding Remedial Alternatives 24
3.3.2 Costs/Funding Issues 25
3.3.3 Enforcement....- 25
3.3.4 Remaining Concerns 26
4.0 REFERENCES 27
TABLES
1 Chemicals of Concern and Remediation Goals
2 Summary of Remedial Alternatives Evaluation - Sites 2 and 12
3 Summary of Remedial Alternatives Evaluation - Sites 16 and 17
4 Summary of Remedial Alternatives Evaluation - Site 31
5 Summary of Remedial Alternatives Evaluation - Site 39
PLATES
l Site Location Map
2 Soil Remedial Units 1,2 and 3-Site 12
3 Soil Remedial Units 1 and 2-Sites 16 and 17
4 Soil Remedial Unit 1 - Site 31
5 Soil Remedial Units 1 and 2 - Site 39
APPENDIXES
A APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR THE SELECTED
ALTERNATIVES
B COMMUNITY RELATIONS ACTIVmES
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January 13. 1997
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1.0 DECLARATION
1.1
Site Name and Location
Fort Ord is located near Monterey Bay in
northwestern Monterey County, California,
approximately 80 miles south of San Francisco.
The base comprises approximately 28.000 acres
adjacent to the cities of Seaside, Sand City,
Monterey, and Del Key Oaks to the south and
Marina to the north. The Southern Pacific
Railroad and Highway 1 pass through the western
portion of Fort Ord, separating the beach front
from the rest of the base. Laguna Seca Recreation
Area and Toro Regional Park border Fort Ord to
the south and southeast, respectively. Land use
east of Fort Ord is primarily agricultural.
1.2
Basis and Purpose
This Record of Decision (ROD) addresses the
following sites investigated under the Basewide
Remedial Investigation/Feasibility Study (RI/FS)
Program at Fort Ord: Remedial Investigation (RI)
Sites 2 and 12,16 and 17, 31, and 39 (Plate 1);
surface water outfalls OF-1 through -14, OF-16
through -30, OF-32 and -33; and two additional
sites, Sites 25 and 33. Surface water outfalls
OF-15, -34, and -35 are not addressed in this
ROD, but are addressed separately in the Interim
Action (IA) ROD (HLA. 1994a). This ROD does
not address issues pertaining to Site 3 (Beach
Trainfire Ranges), Monterey Bay, or ordnance and
explosives (OE). A separate ROD for Site 3, the
Beach Trainfire Ranges, is being prepared
because ecological risks at Site 3 are still being
evaluated. OE at Fort Ord will be addressed in a
separate process.
This decision document presents the selected
remedial actions for soil and groundwater at the
RI and other sites. The remedies were selected in
accordance with the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA), as amended by the
Superfund Amendment and Reauthorization Act
(SARA), and, to the extent practicable, the
National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based
on the Administrative Record for Fort Ord.
The United States Environmental Protection
Agency (EPA) and the California Environmental
Protection Agency (Cal/EPA), which includes the
California Regional Water Quality Control
Board - Central Coast Region (RWQCB) and other
State agencies, concur with the Army's selected
remedies.
1.3
Site Assessment
Actual or threatened releases of hazardous
substances at the RI and other sites, if not
addressed by implementing the response actions
selected in this ROD, may present a current or
future threat to public health, welfare, or the
environment.
1.4
Description of the
Remedies
The selected remedial alternatives described in
this ROD address current or potential significant
risks to human health and the environment posed
by Sites 2 and 12, 16 and 17, 31, 39; surface
water outfalls OF-1 through -14, -16 through -30,
OF-32, and -33; and Sites 25 and 33 at Fort Ord,
California as described in the Basewide Remedial
Investigation/Feasibility Study (RI/FS) (HLA.
1995a). Chemicals of potential concern (COPCs)
and their respective cleanup levels in soil and
groundwater at the RI sites are summarized in
Table 1.
The existing boundaries of the main landfill area
at the Operable Unit 2 (OU 2) landfill will be
designated as a Corrective Action Management
Unit (CAMU), which will allow remediation
waste to be placed there and used as a foundation
layer without triggering certain regulations
pertaining to disposal of waste. Soil remedies for
the RI Sites utilize the CAMU for placement of
excavated soil and/or debris from remedial
actions at the sites. The soil and debris will be
managed at the CAMU, incorporated within the
landfill cover soils (foundation layer), and capped
as part of the landfill.
The following is a description of the selected
remedies for each site :
Sites 2 and 12
Excavation of soil containing total petroleum
hydrocarbons (TPH) and construction debris.
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Declaration
Placement of debris and contaminated soil at
the OU 2 landfill.
Extraction and treatment of groundwater
containing volatile organic compounds
(VOCs) by granular activated carbon (GAG),
and disposal of treated water by (1) reuse
aboveground, or (2) injection or infiltration of
treated water back into the aquifer.
A deed restriction will be placed on the
property prohibiting drilling of water wells or
use or access to groundwater affected by site
contaminants.
Institutional controls prohibiting residential
use (such as deed restrictions) will be
required unless a post remediation risk
evaluation indicates the contaminant residual
levels are appropriate for unlimited use.
Sites 16 and 17
Excavation of soil containing TPH and
construction debris. Placement of debris and
soil at the OU 2 landfill.
A deed restriction will be placed on the
property prohibiting drilling of water wells or
use or access to groundwater affected by
contaminants.
Institutional controls prohibiting residential
use (such as deed restrictions) will be
required unless a post remediation risk
evaluation indicates the contaminant residual
levels are appropriate for unlimited use.
Site 31
Excavation of soil containing lead and
incinerator debris. Placement of debris and
soil at the OU 2 landfill.
Institutional controls prohibiting residential
use (such as deed restrictions) will be
required unless a post remediation risk
evaluation indicates the contaminant residual
levels are appropriate for unlimited use.
Site 39
Excavation of soil containing TPH,
cyclotrimethylene trinitramine (RDX), and
beryllium, and placement at the OU 2
landfill.
Excavation and segregation of spent
ammunition from soil containing residual
lead. Recycling of spent ammunition and
fragments at a metals refinery, and placement
of lead-containing soil at the OU 2 landfill.
Institutional controls prohibiting residential
use (such as deed restrictions) will be
required unless a post remediation risk
evaluation indicates the contaminant residual
levels are appropriate for unlimited use.
Surface Water Outfalls
No further action for the surface water
outfalls OF-1 through OF-14, -16 through -30,
-32, and -33 based on a screening risk
evaluation.
Surface water outfall OF-31 is addressed as
part of the Sites 2 and 12 remedial
alternative.
Sites 25 and 33
No further action for Site 25 based on a
site-specific risk assessment.
Institutional controls prohibiting residential
use (such as deed restrictions) will be
required unless a post remediation risk
evaluation indicates the contaminant residual
levels are appropriate for unlimited use.
A deed restriction for other than residential
type use based on a screening risk evaluation
for Site 33.
1.5
Statutory Determination
The selected remedies are protective of human
health and the environment, comply with federal
and state applicable or relevant and appropriate
requirements for these actions, and are cost
effective. The remedies are intended to fully
address the statutory mandate for permanence
and treatment to the maximum extent practicable
for the RI sites, surface water outfalls, and
Sites 25 and 33. These remedies utilize
permanent solutions and alternative treatment or
resource recovery technologies to the maximum
extent practicable, and satisfy the statutory
preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a
principal element.
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United States Department of the Army
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Declaration
Soil and debris from Sites 2 and 12, 16
and 17, 31, and 39 will be reused as
foundation layer material beneath the barrier
layer at the OU 2 landfill, thereby reducing
mobility.
Spent ammunition from Site 39 will be
recycled.
Soil from the sites will be used as a resource
for fill material needed to construct the cap at
the OU 2 landfill, thereby reducing the
volume of imported fill required.
A review of the groundwater remediation at
Sites 2 and 12 will be conducted within five years
after commencement of the remedial action to
ensure that the remedy continues to provide
adequate protection of human health and the
environment.
Because the selected remedies may result in
contaminants remaining at the sites above levels
that allow for unlimited use, a five year review
will be performed after initiation of the selected
action.
_
Raymond J. Fatz
Deputy Assistant Secretary of the Army
(Environment, Safety, and
Occupational Health
OASA (I.L&E)
Daniel D. Devlin
Colonel, U.S. Army
Commander
Date
/Ila Mettee-McQutchon
Colonel, U.S. Army
\ Chief, BRAC/Environmental
Date
Gail Youngplood
BRAG Environmental Coordinator
Presidio of Monterey
Date
Darnel Opalski /*^^ 'Date
. nirrrfor Fr fieri I Facilities Cleanup Branch
U.S. Environmental Protection Agency
Region IX
n
Date
Antfibny J. Lan/ii#PV£T
Chief of Operations
Office of Military Facilities
California Environmental Protection Agency
Department of Toxic Substances Control
/. iZ
f f
tfogeV W. Briggs 7Date
Executive Officer
California Environmental Protection Agency
California Regional Water Quality Control Board,
Central Coast Region
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United States Department of the Army
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2.0 DECISION SUMMARY
2.1
Site Description
Fort Ord is located near Monterey Bay in
northwestern Monterey County, California,
approximately 80 miles south of San Francisco.
The base comprises approximately 28,000 acres
adjacent to the cities of Seaside, Sand City,
Monterey, and Del Key Oaks to the south and
Marina to the north. The Southern Pacific
Railroad and Highway 1 pass through the
western portion of Fort Ord, separating the
beachfront from the rest of the base. Laguna
Seca Recreation Area and Toro Regional Park
border Fort Ord to the south and southeast,
respectively. Land use east of Fort Ord is
primarily agricultural.
2.2
Site History
Since its opening in 1917, Fort Ord has
primarily served as a training and staging
facility for infantry troops. No permanent
improvements were made until the late 1930s,
when administrative buildings, barracks, mess
halls, tent pads, and a sewage treatment plant
were constructed. In the 1940s, major
construction of the Main Garrison was
performed. From 1947 to 1975, Fort Ord was a
basic training center. After 1975, the
7th Infantry Division (Light) was assigned to
Fort Ord. Light infantry troops are those that
perform their duties without heavy tanks,
armor, or artillery. In 1991, Fort Ord was
selected for closure. In 1993, the majority of
the soldiers were reassigned to other Army
posts. Fort Ord officially closed in
September 1994. Although Army personnel
still operate the base, no active army division is
currently stationed there.
2.3
Enforcement and
Regulatory History
Environmental investigations began at Fort Ord
in 1984 at Fritzsche Army Airfield fFAAF)
under Regional Water Quality Control Board
(RWQCB) cleanup or abatement orders 84-92,
86-86, and 86-315. Investigations indicated the
presence of residual organic compounds from
fire drill burning practices at the Fire Drill Burn
Pit (Operable Unit 1 or OU 1). The subsequent
Remedial Investigation/Feasibility Study (RI/FS)
for OU 1 was completed in 1988, and cleanup
of soil and groundwater began under RWQCB
cleanup or abatement orders 86-87, 86-317,
and 88-139. In 1986, further investigations
began at the Fort Ord landfill (OU 2).arid the
preliminary site characterization was
completed in 1988. In 1990, Fort Ord was
placed on the EPA's National Priorities List
(NPL) primarily because of volatile organic
compounds (VOCs) found in groundwater
beneath OU 2.
A Federal Facility Agreement (FFA) was signed
by the Army, EPA, Cal/EPA's Department of
Toxic Substances Control (DTSC; formerly the
Toxic Substances Control Program of the
Department of Health Services or DHS), and
RWQCB. The FFA established schedules for
performing remedial investigations and
feasibility studies and requires that remedial
actions be completed as expeditiously as
possible. In 1991, the basewide RI/FS began for
Sites 2 and 12,16 and 17. 31, and 39, as well as
other sites, and Fort Ord was placed on the
Base Realignment and Closure (BRAC) list.
The final draft of the Basewide RI/FS was
submitted in October 1995. A Proposed Plan
summarizing remedial actions planned for
these sites, the surface water outfalls, and
Sites 25 and 33 was submitted for public
review and comment on May 7, 1996 (HLA,
1996a). A separate Proposed Plan for RI Site 3
was submitted on May 7,1996, because
finalization of an environmental cleanup level
was still being performed and would require
separate scheduling (HLA, 1996b).
Highlights of Community
Participation
On May 7,1996, the Army presented the
Proposed Plan for the RI Sites, surface water
outfalls, and Sites 25 and 33 at Fort Ord to the
public for review and comment (HLA, 1996a).
The Proposed Plan presented the preferred
alternatives for each site and summarized
information in the Basewide RI/FS and other
documents in the Administrative Record:
These documents are available to the public at
the following locations: Chamberlain Library,
Building 4275, North-South Road, Presidio of
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Decision Summary
Monterey Annex (formerly Fort Ord),
California, and Seaside Branch Library,
550 Harcourt Avenue, Seaside, California. The
Administrative Record is available at
Building 4463, Gigling Road, Presidio of
Monterey Annex (formerly Fort Ord),
California, Monday through Friday from
9:00 a.m. to 3:00 p.m.
Comments on the Proposed Plan were accepted
during a 60-day public review-and-comment
period that began on May 7 and ended on July
8, 1996. A public meeting was held on May 18,
1996, at the Embassy Suites Hotel in Seaside,
California. At that time, the public had the
opportunity to ask the Army questions and
express concerns about the plan. In addition,
written comments were accepted during the
public comment period. Responses to
comments received during the public comment
period are included in the Responsiveness
Summary presented in Section 3.0 of this
document. Any significant changes to the
Proposed Plan are included in Section 2.17.
2.5
Scope and Role of
Response Actions
This ROD addresses planned remedial actions
for RI Sites 2 and 12,16 and 17, 31, 39, surface
water outfalls OF-1 through -14. -16
through -30, -32, and -33, and Sites 25 and 33,
as described in the basewide RI/FS and the Site
Analytical Report (HLA. 1995a, 1995b). The
planned remedial actions for these sites will be
final remedies for protection of human health
and the environment.
2.6
Summary of Site Risks
Potential human health risks and
environmental impacts were evaluated in the
Human Health Risk Assessment and Ecological
Risk Assessment, respectively (HLA. 1995a).
The Human Health Risk Assessment for each
site evaluated the following potential risks
associated with exposure to chemicals of
potential concern:
Potential adverse noncancer health risks
were evaluated using the EPA's hazard
index quotient. The EPA's threshold level
of concern for noncancer effects is a hazard
index greater than 1.
Potential cancer health risks were evaluated
using EPA and other toxiciry values. The
National Contingency Plan (NCP) states that
the point of departure for acceptable cancer
risks is 1 x 10" , or a 1 in 1,000,000 chance
that an individual exposed under the
scenario evaluated would develop cancer.
Risks in the range of 1 x 10"6 to 1 x 10"* (a 1
in 10,000 chance of developing cancer)
should be evaluated on a case by case basis.
Blood-lead levels were evaluated using
blood lead level modelling procedures. The
EPA's threshold blood-lead level of concern
is a level greater than 10 micrograms per
deciliter (/xg/dL), on the basis of a study by
the Centers of Disease Control and
Prevention (CDC). Children's exposures to
lead that results in blood-lead levels greater
than 10 ug/dL may produce neurotoxicity.
Applying this level to adult receptors such
as construction workers is conservative and
health-protective, because threshold levels
suggested for adult receptors are higher.
Thresholds suggested for workers range
from 25 to 50 ng/dL, for hematological and
cardiovascular endpoints (CDC, 1991;
ATSDH 1993). Therefore, the blood-lead
level of concern of 10 jig/dl is protective of
both children and adults.
The Ecological Risk Assessment for each site
evaluated potential adverse health effects of
chemicals of potential concern on plant and
animal species whose habitats are known to
occur at the sites.
2.7
Remedial Action
Objectives
The remedial action objectives for the sites are
to reduce risks to human health and the
environment and comply with federal and state
applicable or relevant and appropriate
requirements (ARARs). In addition,
remediation of sites containing sensitive,
threatened, or endangered species will be
performed in accordance with the Habitat
Management Plan (HMP) (COE. 1994).
2.8
2.8.1
Sites 2 and 12
Sites 2 and 12: Site
History
Site 2: The Main Garrison Sewage
Treatment Plant (MGSTP) was the primary
sewage treatment facility for Fort Ord,
serving the majority of the housing areas
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Decision Summary
and the main industrial areas from the late
1930s until May 1990 when it was
decommissioned. During operation,
effluent from the MGSTP was discharged
under permit to a storm drain that emptied
onto Indianhead Beach during low tide and
discharged to Monterey Bay during high
tide.
Site 12: Site 12 is comprised of four areas
as described below (Plate 2):
- Lower Meadow. This area was used for
disposal of waste material such as scrap
metal, oil, and batteries generated by
the Department of Logistics (DOL). The
depth of fill material is reportedly up to
30 feet. The area also appears to
contain road construction waste. The
Lower Meadow receives runoff from the
DOL Automotive Yard. Several pipes
appear to discharge runoff to the Lower
Meadow; however, it is uncertain if
these pipes were designed as drainage
lines.
- DOL Automotive Yard. This area
includes several buildings, two wash
racks, and a paint shop at
Building 2726. The former buried
muffler used to contain exhaust from
engine testing at Wash Rack 2723 may
also have been used for liquid waste
storage at Building 2719. Activities at
the DOL Automotive Yard included
transmission repair, degreasing, engine
testing, steam cleaning and washing
vehicles, and petroleum/oil/lubricant
storage.
- Cannibalization Yard. This area was
used from 1964 until 1994 to
disassemble old equipment, primarily
decommissioned military vehicles.
Used motor oil was collected in pans
and transferred to 55-gallon drums for
storage. Other activities included
draining/removing gasoline (leaded and
unleaded), diesel fuel, brake fluid,
asbestos-containing brake shoes and
linings, antifreeze/coolants, lead and
acid from batteries, lubricating greases,
and transmission fluids. One oil/water
separator at the northeast corner of the
yard collects surface runoff from the
area and has been in use since 1988.
- Southern Pacific Railroad fSPRRl Spur.
This area consists of the right-of-way
along a portion of a railroad spur that
extends northward from the SPRR track
west of Highway 1 and curves east
through an industrial complex.
Hydrocarbons may have been sprayed
in this area for dust control.
2.8.2
Sites 2 and 12: Site
Characteristics
No significant continuing source areas were
identified at any of the Site 2 and 12 areas. The
most common contaminants are metals, organic
compounds, and TPH. The results of the
remedial investigation indicate the following:
Soil
At Site 2, the primary chemicals of
potential concern detected in soil were low
concentrations of organic compounds and
metals.
At Site 12, construction debris was
landfilled in the Lower Meadow, and TPH
was detected in the same area. In addition,
TPH was detected in three other areas: the
DOL Maintenance Yard, the
Cannibalization Yard, and the SPRR Spur
in between these two areas.
Groundwater
The Upper 180-foot aquifer and the Lower
180-foot aquifer are present beneath Sites 2
and 12. These 180-foot aquifers are sand
and gravel aquifers present in the Salinas
Valley. The Upper 180-foot aquifer is
unconfined, while the Lower 180-foot
aquifer is confined. Depth to groundwater
in the Upper 180-foot aquifer is
approximately 40 to 80 feet below ground
surface (bgs) and flows to the southwest,
towards the Pacific Ocean. Groundwater in
the Lower 180-foot aquifer flows east
towards the Salinas Valley.
Results of the remedial investigation
indicate that dissolved VOCs have been
detected in the Upper 180-foot aquifer that
exceed their respective maximum
contaminant levels (MCLs). VOCs have not
been detected at concentrations above
MCLs in the Lower 180-foot aquifer. The
primary chemical of concern in
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groundwater is trichloroethene (TCE), a
solvent. Other similar compounds were
also detected. A sandy silt layer dividing
the two aquifers appears to have limited
vertical migration of dissolved VOCs.
2.8.3
Sites 2 and 12: Summary
of Site Ricks
Human Health Risks. Chemicals of potential
concern (COPCs) in soil and groundwater were
identified on the basis of their concentrations,
frequency of detection, and effects on human
health. COPCs for this site include metals in
soil at Sites 2 and 12, organic compounds in
soil at Site 12, and metals and organic
compounds (including TCE) in groundwater at
Site 12. On the basis of the future uses
proposed for the sites, the Human Health Risk
Assessment evaluated risks to future onsite
workers at Site 2 and future residents at Site 12.
The onsite worker scenario for Site 2 is more
conservative than a scenario involving state
park open space use.
Site risks are summarized as follows:
Site 2:
No adverse health effects are anticipated
from exposure to COPCs. The hazard index
calculated was 0.1, and the total cancer risk
was 3 x 10"6, of which 2x10"* was due to
background concentrations of metals such
as arsenic in soil. The incremental cancer
risk associated with site contaminants was
1 x 10"6.
Based on the risk assessment and blood
lead level modelling, no adverse cancer or
blood-lead level effects are anticipated from
exposures to COPCs in soil or groundwater;
however, potential noncancer effects
exceeded the EPA's threshold level of
concern.
The maximum hazard index was 1.9, of
which 1.2 was due to potential exposure to
groundwater; this level exceeds the
threshold level of concern. The total
maximum cancer risk was 6 x 10"*, of
which 3 x 10"s and 1 x 10"s were due to
potential exposure to site contaminants in
groundwater and soil, respectively. The
total risk due to background metals
concentrations was 2 x 10"s; therefore the
incremental cancer risk associated with site
contaminants was 4 x 10"5. Based on blood
lead level modelling, the maximum blood-
lead level calculated was 7.64 mg/dL.
For a future onsite worker at Site 2, no
unacceptable risks are anticipated. The
maximum noncancer hazard index for Site 12
is above the EPA's threshold level of concern.
Cancer risk estimates for a future resident at
Site 12 are within EPA's target risk range, and
modelled blood lead levels are below the EPA's
threshold level of concern.
Ecological Impacts. The Ecological Risk
Assessment identified lead as the only
environmental COPCs for soil at Sites 2 and 12.
The health of two special status species (black
and silvery legless lizards) and the food base
(e.g., mice) for predators such as raptors and
foxes were evaluated.
No unacceptable adverse effects on lizards
are expected because usable habitat at the
two sites is limited. Site 2 consists of large
sewage treatment plant structures, and most
of Site 12 is paved. Ecological impacts
were evaluated by collecting plants and
animals and measuring chemical
concentrations in tissues. Tissue
concentrations in prey were not likely to
produce adverse effects in animal
populations. Tissue concentrations in
plants also did not indicate the surrounding
habitat would be adversely affected.
2.8.4
Sites 2 and 12: Remedial
Action Objectives
Proposed Reuse: The initial proposed reuse
plan for Site 2 includes outdoor and indoor
aquaculture facilities for raising fish and
shellfish, with additional research facilities to
support oceanographic studies. Additional
reuse plans for Site 2 include an open space
area. Reuse planned for Site 12 includes a
central business district, light industrial areas, a
high-tech business park, a transit center, retail
businesses, medium- to high-density residential
areas, and a school.
Remedial Action Objectives:
No unacceptable human health risks are
associated with direct exposure to soil;
however, a remedial action objective for
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protection of groundwater is to remediate
TPH in soil to a concentration of
500 milligrams per kilogram (mg/kg) or less
(HLA. 1994b).
Human health risks are associated with
potential exposure to groundwater;
therefore, the remedial action objective for
groundwater at Sites 2 and 12 is to
remediate the Upper 180-foot aquifer to
MCLs, and for some constituents more
stringent levels, for the detected VOCs (See
Table 1). The analysis used in identifying
these levels was the same as the analysis
used at OU 2 for obtaining aquifer cleanup
levels.
Removal of debris is a remedial action
objective because contaminated soil may be
intermixed with the debris.
To effectively evaluate remedial alternatives,
Sites 2 and 12 were divided into four remedial
units consisting of one groundwater remedial
unit and three soil remedial units (Plate 2). Soil
Remedial Unit 1 is the Lower Meadow Disposal
Area, which contains approximately
16,000 cubic yards of concrete rubble and other
construction debris mixed with limited
volumes of TPH-affected soil. Soil Remedial
Unit 2, the Outfall Area, receives surface runoff
and storm drainage flow from surface water
outfall OF-31 and several other storm drains,
and consists of approximately 2,800 cubic
yards of soil containing unknown diesel-like
chemicals. Soil Remedial Unit 3 is the
Cannibalization Yard Area, and consists of
approximately 1,000 cubic yards of shallow soil
containing TPH.
The remedial action objectives based on the
risk assessments for Sites 2 and 12 are
protective under the proposed reuse, i.e., onsite
workers at Site 2 and residents at Site 12. At
Site 2, since there are no unacceptable risks
associated with soil, no soil remediation is
necessary. At Site 12, the soil and debris that
present unacceptable risks will be remediated
to cleanup levels identified in Table 1. In
addition, a post-remediation human health risk
evaluation for soil at Sites 2 and 12 will be
conducted. If this evaluation shows that the
soils at Sites 2 and 12 are safe for any use, then
deed restrictions will not be necessary. If deed
restrictions are determined to be necessary, the
appropriate restrictions will be attached to the
deed. The restriction will limit reuse and notify
the potential owner of any residual
contamination. Drilling of water wells or use or
access to the groundwater affected by the
contaminants at Sites 2 and 12, however, will
continue to be restricted by deed until the
groundwater cleanup levels are achieved.
2.8.5
Sites 2 and 12:
Description of
Alternatives
The following four remedial alternatives were
evaluated in the Sites 2 and 12 Feasibility
Study. For each alternative, both capital and
annual operations and maintenance (O&M)
costs were estimated. For alternatives requiring
extended long term O&M, the net present value
(NPV) of the money that would be spent over
30 years for O&M was also estimated.
Alternative 1
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
$0
$119,000
$1,838,000
No action other than groundwater and
surface water outfall monitoring. The no
action alternative is required to be
considered under CERCLA to provide a
baseline for comparison to the other
proposed alternatives.
Assumes long-term monitoring program for
existing groundwater wells and two surface
water outfalls.
Alternative 2
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
$1,278,000
$495,000
$8,900,000
Extraction of groundwater containing VOCs
above cleanup goals (See Table 1) and
discharge of untreated groundwater to a
publicly owned treatment works (POTW).
Deed restriction on groundwater use.
Capping and surface water controls for soil
at the Lower Meadow Disposal and Outfall
Areas, which would prevent leaching of
chemicals to groundwater.
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Excavation of approximately 1,000 cubic
yards (cy) of shallow soil containing
concentrations of TPH above the cleanup
level of 500 milligrams per kilogram
(mg/kg) (See Table 1) from the
Cannibalization Yard, and placement at the
OU 2 landfill.
Alternative 3
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
$2,160.000-$2,713,000
$338,000 - $386,000
$7,359,000 - $8,656,00
Groundwater extraction and treatment by
granular activated carbon.
Disposal of treated groundwater by:
(1) reuse aboveground, or (2) injection or
infiltration of treated water back into the
aquifer.
Deed restriction on groundwater use.
Capping of debris and selective excavation
of approximately 1,600 cubic yards of soil
containing TPH concentrations above the
cleanup goal of 500 mg/kg (See Table 1)
from the Lower Meadow Disposal Area and
placement at the OU 2 landfill.
Excavation of approximately 3,800 cubic
yards of soil containing TPH concentrations
above the cleanup goal of 500 mg/kg (See
Table 1) from the Outfall Area and
Cannibalization Yard, and placement at the
OU 2 landfill.
Alternative 4
Capital Cost: $2.689,000 - $3.242,000
Annual O&M Cost- $326,000 - $375,000
30 Year O&M NPV: $7,711,000 - $9,009,000
Groundwater extraction, treatment, and
disposal as described for Alternative 3.
Deed restriction on groundwater use.
. Excavation of approximately 16,000 cubic
yards of soil and debris containing TPH
concentrations above the cleanup goal of
500 mg/kg (See Table 1) from the Lower
Meadow Disposal Area, and placement at
the OU 2 landfill.
Excavation of approximately 3,800 cubic
yards of soil containing TPH concentrations
above the cleanup goal of 500 mg/kg (See
Table 1) from the Outfall Area and
Cannibalization Yard, and placement at the
OU 2 landfill.
2.9
2.9.1
Sites 16 and 17
Sites 16 and 17: Site
History
Site 16: Site 16 is comprised of three areas
as described below (Plate 3):
- The POL Maintenance Yard. This area
has been used as a heavy equipment
maintenance facility since the 1950s
when the site was originally developed.
Six buildings and structures enclosed
within a fenced area are identified by
number and current or previous use as
follows:
- Building 4900, the main
maintenance yard building, is used
primarily for vehicle repairs.
Operations in Building 4900
included small arms weapons
repair, a weapons bluing process,
spray painting, and general vehicle
repairs. A former 1,500-gallon
diesel underground storage tank
(UST) near Building 4900 was
removed in March 1992.
- Building 4901 is used for storage of
unused motor oil.
- Building 4902 is a wash rack. An
oil/water separator is adjacent to
the wash rack.
- Building 4903 contains a
diesel-powered steam cleaner. A
200-gallon aboveground diesel fuel
tank adjacent to the building
provided fuel to the steam cleaner
by gravity feed.
- Building 4904 was the former paint
shop.
- Building 4905 is used for storage of
nonhazardous materials.
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- Pete's Pond and Pete's Pond Extension.
These areas have remained open space
areas since development of the
surrounding areas. Based on an aerial
photograph review, these areas were
used for refuse dumping sometime
during the late 1940s and early 1950s.
Site 17: Site 17 is comprised of three areas
as described below:
- 1400 Block Motor Pool Complex. This
area, which includes Buildings 1476
through 1495, was constructed in about
1977. Since 1977, the motor pool
operated at this location until the troop
relocation in 1993. The facility was
used to service motor vehicles
including light and heavy trucks and
other army vehicles. Materials that
were stored at the 1400 Block Motor
Pool Complex include lubricating oils,
brake fluid, coolants, cleaning solvents,
diesel, and gasoline. These materials
are stored in fourteen USTs at the
1400 Block Motor Pool Complex and
were removed as part of the UST
program at Fort Ord. Eight other USTs
have been removed from Site 17. The
Site 17 Disposal Area has been used as
a parking area and contains a washrack
and grease rack. Based on aerial
photographs it appears that material
was buried extensively in this area
between the late 1940s and early 1950s.
- Storage Buildings on Fourth Avenue.
These buildings were built in the 1940s
for storage of various materials. For
example, corrosive chemicals were
stored in Buildings 1431 and 1435.
Building 1442 previously housed an
incinerator for waste generated from the
first Fort Ord Hospital constructed in
the 1940s. This building now houses
an autoclave used to sterilize medical
debris from the onbase Hays Hospital
which was constructed in 1969.
- Disposal Area. This area was used
extensively to dispose of debris at
Fort Ord; however, there are no known
sources of information on site history
related to disposal.
2.9.2
Sites 16 and 17: Site
Characteristics
Results of the RI indicate the following:
So/7
POL Maintenance Yard: The primary
chemicals of potential concern detected in
near-surface soil samples were dioxins and
light and heavy TPH, such as diesel
(TPHd).
Pete's Pond Extension: Incinerated debris
and medical debris dating to the 1950s was
landfilled in Pete's Pond Extension. Other
detected debris included ordnance, glass
bottles, metal, and one 55-gallon drum.
Chemicals detected in soil samples
included metals, organic compounds, TPH,
and dioxins.
Pete's Pond: Debris was detected in several
areas of Pete's Pond. Total oil and grease
(TOG), pesticides, metals, and dioxins were
detected in soil samples from Pete's Pond.
Site 17 Disposal Area: Incinerated and
unincinerated debris from as early as 1935
was detected at the Site 17 Disposal Area.
Unknown diesel-like chemicals and motor
oil, metals, and dioxins were detected in
soil samples from the Disposal Area.
Site 17 Other Areas: TPH as diesel, silver.
and copper were detected once each in soil
samples from other areas at Site 17.
Groundwater
Two groundwater aquifers were investigated as
part of the Sites 16 and 17 field investigation:
the uppermost A-aquifer and the underlying
Upper 180-foot aquifer. Organic chemicals
have been detected in groundwater samples
from monitoring wells at Sites 16 and 17.
Chemicals detected include PCE, TCE, and
carbon tetrachloride. The RI concluded that
organic chemicals are related to the migration
of chemicals from the OU 2 landfill, which is
being addressed separately under the OU 2
ROD.
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2.9.3
Sites 16 and 17:
Summary of Site Risks
Human Health Risks. The COPCs identified
for soil at Sites 16 and 17 are metals, dioxins,
and volatile organic compounds (VOCs). The
COPCs for groundwater at the sites are organic
compounds and antimony. On the basis of the
proposed future reuse of the sites, the Human
Health Risk Assessment evaluated risks to:
Student/faculty artist at the Site 17 Disposal
Area, with additional exposure at Pete's
Pond and Pete's Pond Extension.
Utility worker at Pete's Pond and Pete's
Pond Extension.
Construction worker at the Site 17 Disposal
Area and the DOL Maintenance Yard.
Commercial worker at the DOL
Maintenance Yard.
Site risks are summarized as follows:
The maximum hazard index calculated was
1, which is equal to the threshold level of
concern. The maximum total cancer risks
were 9 x 10"7, 7 x 10"8, 1 x 10"6, and 1 x 10'5,
for the student/faculty artist, utility worker,
construction worker at the Site 17 Disposal
Area, and commercial worker, respectively.
Risks due to background concentrations
were 2 x 10"7, 5 x 10'", 6 x 10"7, and 2 x 10"6,
respectively. The incremental cancer risks
associated with site contaminants were
7 x 10"7, 2 x 10"8, 4 x 10'7, and 8 x 10'6,
respectively.
Based on blood lead level modelling,
maximum blood-lead levels calculated were
4.73, 4.50, and 4.31 mg/dL for the
student/faculty resident artist, utility
worker, and construction worker at the
Site 17 Disposal Area, respectively, which
are below the threshold level of concern.
The results of the Human Health Risk
Assessment indicate that no adverse health
effects from exposure to the COPCs at the sites
are anticipated for any of the potential site
users evaluated.
Ecological Impacts. The food base for
predators, the health of the legless lizard,
and the central maritime chaparral habitat
were evaluated in the Ecological Risk
Assessment (ERA). Ecological impacts were
evaluated by collecting plants and animals
and measuring chemical concentrations in
tissues. Tissue concentrations in prey were
not likely to produce adverse effects in
animal populations. Tissue concentrations
in plants also did not indicate the
surrounding habitat would be adversely
affected.
2.9.4
Sites 16 and 17:
Remedial Action
Objectives
Proposed Reuse: Parts of Site 16 are proposed
for public agency corporation yards for the City
of Marina, the County of Monterey, and the
Monterey-Salinas Transit District. Site 17 has
been designated as part of the site for the new
Monterey Bay campus of the California State
University. Existing structures are to be used
for student/faculty artists, lecture/laboratory
spaces, and university administrative offices.
In addition, the parcel will provide sites for
new facilities, including additional residence
halls, a permanent library building, and a
science center.
Remedial Action Objectives:
No unacceptable human health risks are
associated with direct exposure to soil;
however, a remedial action objective for
protection of groundwater is to remediate
TPH in soil to a concentration of 500 mg/kg
or less (HLA. 1994b).
Removal of debris is a remedial action
objective because contamination in soil
may be intermixed with the debris.
To effectively evaluate remedial alternatives,
Sites 16 and 17 were divided into remedial
units. A groundwater remedial unit was not
developed because the chemical compounds
detected in groundwater beneath the sites are
associated with the OU 2 contaminant plume;
therefore, the groundwater will be captured and
treated as part of the OU 2 remediation
program.
Two soil remedial units were identified
(Plate 3). Soil Remedial Unit 1 consists of
approximately 1,100 cubic yards of
TPH-impacted soil at the DOL Maintenance
Yard, and Soil Remedial Unit 2 consists of
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approximately 67,000 cubic yards of medical
and miscellaneous debris and associated
impacted soil from Pete's Pond, Pete's Pond
Extension, and the Site 17 Disposal Area.
Approximately 3,600 cubic yards of soil and
debris is from Pete's Pond and Pete's Pond
Extension. The remaining soil and debris is
from the Site 17 Disposal Area.
The remedial action objectives based on the
risk assessments for Sites 16 and 17 are
protective under the proposed reuse, i.e.,
student/faculty and workers. At Sites 16 and
17, the soil and debris that present
unacceptable risks will be remediated to
cleanup levels identified in Table 1. In
addition, a post-remediation human health risk
evaluation for soil at Sites 16 and 17 will be
conducted. If this evaluation shows that the
soils at Sites 16 and 17 are safe for any use,
then deed restrictions will not be necessary. If
deed restrictions are determined to be
necessary, the. appropriate restriction will be
attached to the deed. The restrictions will limit
reuse and notify the potential owner of any
residual contamination. The groundwater will
be treated as part of the OU 2 plume. Drilling
of water wells or use or access to the
groundwater affected by the contaminants at
Sites 16 and 17 will continue to be restricted by
deed until the groundwater cleanup levels are
achieved.
Alternative 2
2.9.5
Sites 16 and 17:
Description of
Alternatives
The following four remedial alternatives were
evaluated in the FS.
Alternative 1
Capital Cost:
Annual O & M Cost:
30 Year O&M NPV:
$20,600
$49,200
$774,000
No action would be taken at the site except
continued groundwater monitoring. The no
action alternative is required to be
considered under CERCLA as a basis for
comparison to other alternatives.
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
$1,175,200
$53,400
$1,804,000
Construction of a cap over the areas
containing debris and TPH-affected soil to
limit contact and prevent surface water
infiltration. Deed restrictions wciuld be
required.
Alternative 3
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
$1,211,100
$38,200
$1,604,000
Excavation of soil and debris from Pete's
Pond and Pete's Pond Extension.
Consolidation of debris from Pete's Pond
and Pete's Pond Extension into the Site 17
Disposal Area, and placement of an
impermeable cover layer material and
1-foot-thick layer of clean soil.
Placement of TPH-affected soil at the OU 2
landfill, or treatment at the FOSTA, with
onsite reuse.
Alternative 4
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
$5,158,000
$0
$5,158,000
Excavation of soil and debris containing
concentrations of TPH above the cleanup
goal of 500 rag/kg from Pete's Pond, Pete's
Pond Extension, and the Site 17 Disposal
Area (see Table 1).
Placement of soil and debris from these
areas at the OU 2 landfill as part of the
foundation layer material.
Placement of TPH-affected soil at the OU 2
landfill.
2.10 Site 31
2.10.1 Site 31: Site History
Site 31, the Former Dump Site, was used for
debris disposal in the 1940s and 1950s
(Plate 4). A 500-ton incinerator was reportedly
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located at the top of the ravine at Site 31 within
the area now occupied by the Leadership
Reaction Training Compound (LRTC). On the
basis of interviews with Fort Ord personnel and
field observations, most of the refuse observed
on and within the ravine slope appears to date
from the 1940s and 1950s. Refuse was wholly
or partially incinerated and dumped over the
northern slope of the ravine. The incinerator
was removed and dumping ceased, and the
LRTC was constructed and used as an obstacle
training course. The site is currently not in use.
2.10.2 Site 31: Site
Characteristics
Results of the RI indicate that the main source
of contamination is incinerated debris and ash
from burned refuse. Surface and subsurface
incinerated and unincinerated debris at the site
consists of glass, metal, coal, wood, concrete
and asphalt, brick and clay tile, and ash.
Chemicals detected in soil samples at the site
include TPH as diesel, polynuclear aromatic
hydrocarbon (PAHs), dibenzofuran, pesticides,
dioxins, and some metals including lead. The
chemicals appear to be related to the debris.
Because chemicals detected within soil at the
site are relatively immobile and because
groundwater is deep, groundwater quality was
not investigated at this site. However, potential
impacts to groundwater from COPCs in soil at
this site were evaluated using a leaching model,
and significant impacts were not anticipated.
2.1O.3 Site 31: Summary off Site
Risks
Human Health Risks. Metals, pesticides,
dioxins, and PAHs were identified in the
Human Health Risk Assessment as COPCs. On
the basis of proposed future reuse of the site,
the Human Health Risk Assessment evaluated
risks to a nearby resident trespasser.
Site risks are summarized as follows:
The maximum hazard index calculated was
0.02; and the total maximum cancer risk
was 8 x 10"7 for the nearby resident
trespasser, of which 4 x 10"7 was due to
background concentrations of metals. The
incremental risk associated with site
contaminants was 4 x 10"7. These levels
are below levels of concern.
Based on blood lead level modelling, the
maximum blood-lead level calculated was
16.10 mg/dL for the nearby resident
trespasser, which is above the threshold
level of concern.
The Human Health Risk Assessment calculated
an estimated cancer risk to the child trespasser
to be below EPA's target risk range. The
noncancer hazard index is below the EPA's
threshold level of concern. However, a
maximum blood-lead level of 16.1 Mg/dL was
calculated in the lead exposure evaluation,
which is above the EPA's threshold level of
concern. Adverse health effects from lead
exposure could be associated with the site, and
remediation based on these potential human
health effects may be required. A health-based
level of concern for lead in soil of
1,860 milligrams per kilogram (mg/kg) was
developed. At this concentration, blood-lead
levels would not be expected to exceed the
10 ug/dL threshold level.
Ecological Impacts. The food base (e.g., mice)
for predators and the health of the silvery
legless lizard were evaluated in the Ecological
Risk Assessment. Ecological impacts were
evaluated by collecting plants and animals and
measuring chemical concentrations in tissues.
Tissue concentrations in prey were not likely to
produce adverse effects in animal populations.
Tissue concentrations in plants also did not
indicate the surrounding habitat would be
adversely affected.
Groundwater: The potential impact to
groundwater from detected organic chemicals
was evaluated in the RI using VLEACH
modeling on selected organic chemicals or
groups of chemicals. With the exception of the
TPHd surrogate dodecane, the results of the
modeling indicated that these chemicals would
not leach to groundwater over a 100-year period
if left in place at maximum detected site
concentrations. The modeling indicated that
dodecane might leach to groundwater in
49 years and estimated a maximum
concentration hi groundwater of less than
0.01 ng/l in 100 years; this is not considered to
represent a significant impact to groundwater.
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2.10.4 Site 31: Remedial Action
Objectives
Proposed Reuse: Precise future plans for
Site 31 are unknown. Site 31 has been
included within a 200-acre parcel slated to
become the Monterey Agricultural Center,
which will include facilities for agricultural
production, storage, cooling, packaging, and
distribution and approximately 250 housing
units for families and farm workers. The area
not developed within the parcel is to be set
aside as open space/habitat. The steep nature
of Site 31 and its natural habitats suggest that
part will be set aside as open space.
Remedial Action Objectives:
The remedial action objective for lead in
soil is to remove soil containing lead
intermixed with debris above the health-
based level of concern of 1,860 mg/kg lead
in surface soil developed in the Baseline
Human Health Risk Assessment (HLA,
1995a).
On the basis of the health-based cleanup level
for lead developed in the Human Health Risk
Assessment, a single soil remedial unit was
defined on the north slope of Site 31 (Plate 4).
It consists of approximately 350 cubic yards of
debris and soil. The remainder of the debris
and soil at the site has not been shown to pose
a human health risk or risk to the environment
and would be very difficult to remove because
of steep slopes and overhead powerlines. Also,
there is potential for substantial damage to
natural habitat areas if total debris removal is
performed. The remaining debris is not
proposed for remediation.
The remedial action objectives based on the
risk assessment for Site 31 are protective under
the proposed reuse, i.e., a child trespasser. Soil
and debris associated with unacceptable risks
will be remediated to cleanup levels identified
in Table 1. A post-remediation human health
risk evaluation will be conducted. If this
evaluation shows that the soils at Site 31 are
safe for any use, then deed restrictions will not
be necessary. If deed restrictions are
determined to be necessary, the appropriate
restrictions will be attached to the deed. The
restriction will limit reuse and notify the
potential owner of any residual contamination.
Additionally, a post-remediation ecological
evaluation for Site 31 will be conducted. If this
evaluation indicates that the residual levels of
chemicals of potential concern (COPCs) are
protective of the ecological receptors at Site 31,
the remedial action will be deemed complete.
If not, further actions may be necessary
2.10.5 Site 31: Description of
Alternatives
The following four remedial alternatives were
evaluated in the FS.
Alternative 1
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
$0
$0
$0
No action would be taken at the site. The
no action alternative is required to be
considered under CERCLA as a basis for
comparison to other alternatives.
Alternative 2
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
$320.000
$0
$320,000
Excavation and segregation of
approximately 350 cubic yards of soil and
debris containing lead above the health-
based level of concern of 1,860 mg/kg (see
Table 1).
Placement of soil and debris at the OU 2
landfill as part of the foundation layer.
Deed restrictions.
Alternative 3
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
$410,000
$2,100
$445,000
Excavation of approximately 350 cubic
yards of soil and debris containing lead
above the health-based level of concern of
1,860 mg/kg (see Table 1), and
consolidation onsite. The consolidated soil
and debris would be capped to limit
potential direct human exposure to the
waste materials and water infiltration and
to limit offsite migration of debris and
lead-containing soil. Deed restrictions
would be required.
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Alternative 4
Capital Cost: $335,000
Annual O&M Cost: $0
30 Year O&M NPV: $335,000
Excavation of approximately 350 cubic
yards of soil and debris containing lead
above the health-based level of concern of
1,860 mg/kg.
Offsite transportation and disposal at a
Class I landfill facility.
Deed restriction.
2.11 Site 39
2.11.1 Site 39: Site History
The Inland Ranges were reportedly used since
the early 1900s for ordnance training exercises,
including onshore naval gunfire (Plate 5). Over
the years, various types of ordnance have been
used or found in the Inland Ranges, including
hand grenades, mortars, rockets, mines,
artillery rounds, and small arms rounds. Some
training activities using petroleum
hydrocarbons were also conducted. The
2.36-inch Rocket Range was used as an antitank
rocket (bazooka) range during and shortly after
World War II. Both range areas are inactive
because of the Fort Ord closure.
2.11.2
Soil
Site 39: Site
Characteristics
Results of the RI indicate that explosive
compounds, organic compounds, and the
metals lead and beryllium are present in
shallow soil above background concentrations
in localized areas. Metals and TPH were
detected in shallow soil adjacent to or within
three trenches used for fire and smoke
demonstrations.
Spent ammunition found at the small arms
ranges consists of bullets, black powder rifle
balls, and lead shot. Lead is the primary
chemical of concern in soil. Localized areas
have more than 10 percent of the surface area
covered with spent ammunition. In general,
ordnance used at the site includes small arms
ammunition, grenades, rockets, mortars,
artillery rounds, mines, and bombs. High
densities of ordnance and explosives occur near
targets.
Groundwater
Antimony and nitrate were detected at
concentrations consistent with background
(naturally occurring) concentrations in wells at
Site 39 installed as part of the basewide
ground water monitoring program.
2.11.3 Site 39: Summary of Site
Risks
Human Health Risks. The chemicals of
potential concern identified for soil are
explosive compounds such as
cyclotrimethylene trinitramine (RDX),
semivolatile organic compounds, and metals.
Groundwater chemicals of potential concern
are metals and nitrate. On the basis of the
proposed future reuse of the site, risks to a
habitat management worker and a nearby
resident were evaluated in the Human Health
Risk Assessment.
Site risks are summarized as follows:
The maximum hazard indexes calculated
were 1 and 0.004, and the total maximum
cancer risks were 8 x 10"5 and 3 x 10"6 for
the onsite habitat management worker and
offsite resident, respectively. The risks
associated with background were 6 x 10 6
and 5 x 10"7, and the incremental risks
associated with site contaminants were
7 x 10"s and 3 x 10"* , respectively. The
hazard index of 1 is at the threshold level of
concern.
Based on blood lead level modelling, the
maximum blood-lead levels calculated were
5.13 and 3.93 mg/dL for the onsite habitat
management worker and offsite child
resident, respectively. These levels are
below the threshold level of concern.
The results of the Human Health Risk
Assessment indicate that the hazard index for
noncancer-causing chemicals is not above the
EPA's threshold level of concern. Cancer risks
are within the EPA's target risk range, and
calculated blood-lead levels are below the EPA
threshold blood-lead level of 10 Mg/dL.
However, the health-based level of concern for
lead in soil of 1,860 mg/kg will also be used for
Site 39 in areas in the Small Arms Ranges
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where the surface distribution of spent
ammunition is greater than 10 percent. These
areas are similar to those at Site 3 where the
health-based level of concern roughly correlates
to areas where more than 10 percent of the
surface is covered by spent ammunition.
Ecological Impacts. The silvery legless lizard,
the food base (e.g., mice) for predators such as
foxes and raptors, mourning doves and their
young, and the central maritime chaparral
habitat were in the Ecological Risk Assessment.
Ecological impacts were evaluated by collecting
plants and animals and measuring chemical
concentrations in tissues. Tissue
concentrations in prey were not likely to
produce adverse effects in animal populations.
Tissue concentrations in plants also did not
indicate the surrounding habitat would be
adversely affected.
2.11.4 Site 39: Remedial Action
Objectives
Proposed Reuse: The proposed reuse of most
of the Inland Ranges will be as a Natural
Resource Management Area and public access
will be restricted. The Range 35 area will be
used as a peace officer training area. Areas
along the south boundary of the Inland Ranges
(and Fort Ord) are proposed for several uses,
including city and county parks, a school
expansion and relocation of Highway 68.
Remedial Action Objectives:
No unacceptable human health risks are
associated with direct exposure to soil;
however, a remedial action objective for
protection of groundwater is to remediate
TPH in soil to a concentration of 500 mg/kg
or less.
The remedial action objective for lead,
RDX, and beryllium in soil is to remove soil
containing these chemicals above the
health-based level of concern and
risk-based target cleanup levels (TCLs) of
1.860 mg/kg for lead, 0.5 mg/kg for RDX,
and 2.8 mg/kg for beryllium in surface soil,
respectively (HLA, 1995a).
Removal of spent ammunition is a remedial
action objective because it is a source of
lead in soil.
To effectively evaluate remedial alternatives,
Site 39 was divided into two soil remedial units
(Plate 5). Soil Remedial Unit 1 consists of
approximately 420 cubic yards of soil with
detectable concentrations of the explosive
compound RDX and TPH above the target
cleanup levels in Ranges 40A and 33 and the
Explosive Ordnance Target Area. Soil
Remedial Unit 2 consists of approximately
4,100 cubic yards of soil containing lead and
beryllium above the health based levels of
concern in the Small Arms Ranges and the
Explosive Ordnance Target Area.
The remedial action objectives based on the
risk assessment for Site 39 are protective under
the proposed reuse, i.e., a nearby resident
trespasser. Soil and debris associated with
unacceptable risks will be remediated-to
cleanup levels identified in Table 1. A
post-remediation human health risk evaluation
will be conducted. This evaluation may show
that the soils at Site 39 are safe for any use,
however, deed restrictions will continue to be
necessary because ordnance and explosives
(OE) have not been addressed at the site. The
appropriate restriction will be attached to the
deed which will limit reuse and notify the
potential owner of any residual contamination,
including OE. Additionally, a post-remediation
ecological evaluation for Site 39 will be
conducted. If this evaluation indicates that the
residual levels of the chemicals of potential
concern (COPCs) are protective of the
ecological receptors at Site 39, the remedial
actions will be deemed complete. If not,
further actions will be necessary.
2.11.5 Site 39: Description of
Alternatives
The following four remedial alternatives were
evaluated in the FS.
Alternative 1
Capital Cost: $0
O&M Cost: $0
30YearO&MNPV: $0
No action would be taken at the site except
continued groundwater monitoring. The no
action alternative is required to be
considered under CERCLA as a basis for
comparison to other alternatives.
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Alternative 2
Capital Cost: $92,000
Annual O&M Cost: $2,000
30 Year O&M NPV: $122,000
Institutional controls including:
(1) construction of a perimeter fence to
restrict and completely enclose the
remedial units at Site 39, (2) posting of
warning placards at appropriate intervals
along the fence, and (3) land use (deed)
restrictions placed on the property for
future development.
Alternative 3
Capital Cost: $1,184,000
O&M Cost: $0
30 Year O&M NPV: $1.184,000
Excavation of approximately 4,520 cubic
yards of soil.
Soil containing TPH and ROX above the
cleanup goal and health-based level of
concern of 500 and 0.5 mg/kg, respectively
(see Table 1), would be placed at the OU 2
landfill.
Soil containing lead and beryllium
concentrations above the health-based
levels of concern of 1,860 and 2.8 mg/kg,
respectively (see Table 1), would be placed
in the OU 2 landfill.
Deed restrictions until remaining OE is
removed.
Alternative 4
Capital Cost:
O&M Cost:
30 Year O&M NPV:
$1,293,000
$0
$1,293,000
Excavation of approximately 4,520 cubic
yards of soil.
Soil containing TPH and RDX above the
cleanup goal and health-based level of
concern of 500 and 0.5 mg/kg, respectively,
would be placed at the OU 2 landfill.
Soil containing lead and beryllium above
the health-based levels of concern of 1,860
and 2.8 mg/kg, respectively, would be
transported offsite and disposed at a Class I
landfill facility, and spent ammunition
would be screened and recycled.
Deed restrictions until remaining OE is
removed.
2.12 Surface Water Outfalls
2.12.1 Surface Water Outfalls:
Site History " .
The Basewide Surface Water Outfall
Investigation (SWOI) evaluated contamination
within and adjacent to thirty five outfalls and
manholes. The outfalls at Fort Ord are part of a
surface water drainage system made up of
aboveground natural and engineered drainages
that discharge to or receive discharge from the
subsurface storm drain system. Water in the
drainage system may have come in contact with
areas of known historical chemical usage. The
surface water outfalls OF-l through -14, -16
through -30, -32, and -33 are included in this
ROD because they were investigated as part of
the Basewide RI/FS.
2.12.2 Surface Water Outfalls:
Site Characteristics
Results of the SWOI indicated soil and
sediment near or in the surface water outfalls
contained the following contaminants: TPH,
organic chemicals, pesticides, lead, cadmium,
and polychlorinated biphenyls (PCBs).
2.12.3 Surface Water Outfalls:
Summary of Site Risks
COPCs in soil and sediment from the surface
water outfalls were evaluated in a Human
Health Screening Risk Assessment (SRE).
Based on the SRE, soil and sediment from
OF-l5, -34, and -35 should be removed for the
protection of human health. These areas will
be excavated and handled under the Interim
Action Program (HLA. 1993). No further action
is required for the other outfalls investigated.
2.12.4 Surface Water Outfalls:
Remedial Action
Objectives
There are no remedial action objectives for the
surface water outfalls OF-l through -14, -16
through -30, -32, and -33 because the SREs
indicated there are no unacceptable risks to
human health and the environment associated
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with the presence of chemicals at most of the
outfalls. Surface water outfalls OF-15, -34,
and -35 are not addressed in this ROD, but will
be addressed separately under the Interim
Action (IA) ROD (HIA, I994a).
2.13 Sites 25 and 33
2.13.1 Sites 25 and 33:
History
Site
Site 25: This is an 11-acre, unpaved field in the
Main Garrison used from 1950 to 1972 to store
decommissioned equipment, including
transformers containing PCBs. It was later used
for military training and vehicle parking.
Site 33: This is the golf course maintenance
area consisting of a pesticide mixing area, an
unpaved surface drainage area, and a former
pesticide storage area. The golf course was
established in the early 1950s, and pesticides
and herbicides were used regularly since
operations began.
2.13.2 Sites 25 and 33: Site
Characteristics
Site 25: PCBs and pesticides were detected at
Site 25 in shallow soil. The metals cadmium,
mercury, and zinc were detected at
concentrations above background (naturally
occurring) concentrations.
Site 33: Pesticides, herbicides, and metals were
detected in soil at concentrations below
preliminary remediation goals (PRGs) set for
reuse of this site.
2.13.3 Sites 25 and 33:
Summary of SHe Risks
Site 25: The Human Health Risk Assessment
for soil at Site 25 evaluated exposure of a
construction worker and resident to COPCs.
Based on the assessment, adverse health effects
are not expected, and no further action is
required at the site. A quantitative Ecological
Risk Assessment was performed. Ecological
impacts were evaluated by collecting plants and
animals and measuring chemical
concentrations in tissues. Tissue
concentrations in prey were not likely to
produce adverse effects in the animal
populations. Tissue concentrations in plants
also did not indicate the surrounding habitat
would be adversely affected.
Site 33: The Human Health Risk Assessment
for soil at Site 33 evaluated exposure of a golf
course maintenance worker to COPCs. Based
on the assessment, adverse health effects are
not expected for the proposed reuse. A
quantitative Ecological Risk Assessment was
performed. Ecological impacts were evaluated
by collecting plants and animals and measuring
chemical concentrations in tissues. Tissue
concentrations in prey were not likely to
produce adverse effects in animal populations.
Tissue concentrations in plants also did not
indicate the surrounding habitat would be
adversely affected.
2.13.4 Sites 25 and 33:
Remedial Action
Objectives
There are no remedial action objectives for
Site 25 because the risk assessment indicated
there are no unacceptable risks to human
health and the environment associated with the
presence of chemicals at this site. The remedial
action objective for Site 33 is to maintain
restrictions on the deed to the property for
other than residential type use.
2.14
Summary of Alternatives
Comparison
Nine criteria established by CERCLA were used
to evaluate the alternatives in the detailed
analysis step for each of the RI sites. The nine
criteria encompass statutory requirements and
include other technical, economic, and
practical factors that assist in comparing the
overall feasibility and acceptability of the
cleanup alternatives. The nine criteria are
summarized as follows:
Overall Protection of Human Health and the
Environment. Addresses whether or not a
remedy provides adequate protection and
describes how risks posed through each
exposure route are eliminated, reduced, or
controlled through treatment, engineering
controls, or institutional controls.
Compliance with Applicable or Relevant and
Appropriate Requirements fARARsl. Addresses
whether or not a remedy will meet all of the
ARARs or provide grounds for invoking a
waiver of the requirements.
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Lone-Term Effectiveness and Permanence.
Refers to the magnitude of residual risk and the
ability of a remedy to maintain reliable
protection of human health and the
environment after cleanup goals have been met.
Reduction of Toxicitv. Mobility, or Volume
Through Treatment. Evaluates the anticipated
performance of the treatment technologies that
may be employed in a remedy.
Short-Term Effectiveness. Refers to the speed
with which the remedy achieves protection, as
well as the remedy's potential to create adverse
impacts on human health and the environment
that may result during the construction and
implementation period.
Implementabih'tv. Refers to the technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement the selected solution.
Cost. Evaluates capital and operating and
maintenance costs for each alternative by
performing present-worth cost analyses.
State Acceptance. Indicates whether, based on
its review of the RI/FS reports and Proposed
Plan, the state concurs with, opposes, or has no
comment on each alternative.
Community Acceptance. Assesses general
public response to the Proposed Plan following
a review of the public comments received on
the RI/FS reports and the Proposed Plan during
the public comment period and open
community meeting(s).
The selected remedy must meet the first two of
the nine CERCLA screening criteria described
above: protection of human health and the
environment as well as compliance with
ARARs. The next five criteria are primarily
balancing criteria used for comparison with
other remedial action alternatives. The final
two criteria, state and community acceptance,
are used to address the concerns of state
agencies and surrounding communities.
The remedial alternatives discussed above were
evaluated on the basis of these criteria in the FS
(HLA, 1995a). Tables 2 through 5 present
summaries of these evaluations for each of the
sites.
2.15
The Selected Remedies
Each alternative for the RI sites was assessed
against the nine EPA evaluation criteria
described in Tables 2 through 5. Using the
results of this assessment, the Army compared
the alternatives and selected a preferred
alternative for each site. The SREs for surface
water outfalls OF-1 through -14, -16
through -30, -32, and -33 indicated no further
action is required for these areas. The risk
evaluation for Site 25 indicated no further
action was required at this site. The remedy for
Site 33 will be a deed restriction on the
property for nonresidential use.
2.15.1 Sites 2 and 12:
Remedy
Selected
Alternative 4 was selected as the remedy in
accordance with the EPA's nine evaluation
criteria described in Table 2, because it
provides the greatest degree of protection for
the environment, removes any potential
unknown risks associated with debris, complies
with ARARs, is effective in the short and long
term, is cost effective, and is readily
implementable.
Alternative 4 met the first two screening criteria
and was judged to be superior in the following
three balancing criteria:
Long-term effectiveness and permanence
Reduction of toxicity, mobility, and volume
of chemicals
Short-term effectiveness
The U.S. EPA and the State of California
(Cal/EPA or DTSC and RWQCB) concur with
the selection of Alternative 4. Community
acceptance is discussed in the responsiveness
summary (Section 3.0). Details regarding soil
and groundwater remedial actions under the
selected alternative are presented in
Section 2.8.
2.15.2 Sites 16 and 17:
Selected Remedy
Alternative 4 is the selected remedy based on
the assessment in the FS and as summarized in
Table 3. Alternative 4 met the first two
screening criteria and was judged to be superior
in the following balancing criteria:
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Long-term effectiveness and permanence
Reduction of toxicity, mobility, and volume
of chemicals
Short-term effectiveness
In addition, this alternative eliminates any
potential unknown risk associated with the
debris at the sites, and provides foundation
layer material for the OU 2 landfill. The
increased cost associated with complete
removal of the debris will be partly offset by
reuse of the material at the OU 2 landfill.
Reuse will result in a cost savings on the
material needed for the foundation layer.
The State of California (Cal/EPA, DTSC and
RWQCB) concurs with the selection of
Alternative 4. Community acceptance is
discussed in the responsiveness summary
(Section 3.0). Details regarding soil remedial
actions under the selected alternative are
presented in Section 2.9.
2.15.3 Site 31: Selected
Remedy
Alternative 2 is the selected remedy based on
the assessment in the FS and as summarized in
Table 4. Alternative 2 met the first two
screening criteria and was judged to be superior
in the following balancing criteria:
Long-term effectiveness and permanence
Reduction of toxicity, mobility, and volume
of chemicals
Short-term effectiveness
In addition, this alternative eliminates any
potential unknown risk associated with the
debris at the site, and provides foundation layer
material for the OU 2 landfill.
The U.S. EPA and the State of California
(Cal/EPA or DTSC and RWQCB) concur with
the selection of Alternative 2. Community
acceptance is discussed in the responsiveness
summary (Section 3.0). Details regarding soil
remedial actions under the selected alternative
are presented in Section 2.10.
2.15.4 Site 39: Selected
Remedy
Alternative 3 is the selected remedy based on
the assessment in the FS and as summarized in
Table 5. Alternative 3 met the first two
screening criteria and was judged to be superior
in the following balancing criteria:
Long-term effectiveness and permanence
Reduction of toxicity, mobility, and volume
of chemicals
Short-term effectiveness
In addition, this alternative eliminates any
potential unknown risk associated with spent
ammunition and explosive compounds at the
site and provides foundation layer material for
the OU 2 landfill.
The U.S. EPA and the State of California
(Cal/EPA or DTSC and RWQCB) concur with
the selection of Alternative 3. Community
acceptance is discussed in the responsiveness
summary (Section 3.0). Details regarding soil
remedial actions under the selected alternative
are presented in Section 2.11.
2.15.5 Surface Water Outfalls:
Selected Remedy
No further action is required for surface water
outfalls OF-1 through -14, -16 through -30, -32,
and -33.
2.15.6 Sites 25 and 33:
Selected Remedy
The selected remedy for Site 25 based on the
risk assessment is no action. The selected
remedy for Site 33 is a deed restriction with
reuse restricted to other than residential type
use.
2.16 Statutory Determinations
2.16.1 Protection of Human
Health and the
Environment
The selected remedies provide the greatest
degree of protection for human health and the
environment. Implementation of the selected
remedies include:
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Removal of contaminated soil from areas
where concentrations of chemicals exceed
the health-based levels of concern or
cleanup levels and placement in an
engineered landfill.
Removal of debris from several different
areas of potential contact and consolidation
in one location in a closed landfill with an
engineered landfill cap.
Recycling of the source of metals
contamination, i.e., spent ammunition.
2.16.2
Compliance with ARARs
The selected remedies comply with ARARs.
ARARs are "applicable" or "relevant and
appropriate" requirements that the Army is
required to comply with. The categories of
ARARs are: action-specific, chemical-specific,
and location-specific. Action-, chemical-, and
location-specific ARARs for the selected
alternatives for each site are presented in
Appendix A. In addition to complying with
ARARs, the Army has the discretion to consider
guidance and health advisories as
"to-be-considered" (TEC) requirements. Those
TBCs that the Army selects become
performance standards that must be complied
with.
2.16.3
Cost Effectiveness
The selected remedies are cost-effective
solutions for reducing risks to human health
and the environment. Costs associated with the
surface water outfalls are addressed under the
Interim Action Program (HLA, 1994b). The
estimated costs of the selected remedies are as
follows:
Sites 2 and 12:
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
Sites 16 and 17:
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
$2,689,000 - 3,242,000
$326,000 - $375,000
$7,711.000-9.009,000
$5,158,000
$0
$5,158,000
Site 31:
Capital Cost:
Annual O&M Cost:
30 Year O&M NPV:
Capital Cost:
O&M Cost:
30 Year O&M NPV:
$320,000
$0
$320,000
$1,184,000
$0 .
$1,184,000
Costs for these alternatives are generally lower
than the treatment alternatives and
commensurate with the higher level of
protection of human health and the
environment provided relative to the no action
alternative.
2.16.4 Utilization of Permanent
Solutions and Alternative
Treatment Technologies
or Resource Recovery
Technologies
The selected remedies use permanent solutions,
alternative treatment technologies, and resource
recovery technologies to the maximum extent
practicable.
Placement of soil and debris at the OU 2
landfill is an innovative, cost-effective
waste management approach, and
significantly reduces the need for additional
resources such as backfill material for
construction of the foundation layer for
capping and closure of the existing landfill.
Recycling of spent ammunition is a
permanent solution and resource recovery
technology that provides beneficial reuse of
the metals present in spent ammunition.
2.16.5 Preference for Treatment
as a Principal Element
The selected remedies satisfy the statutory
preference for treatment as a principal element
in addressing the human health and
environmental threats posed by the RI sites to
the extent possible. The selected remedies
eliminate the sources of contamination to soil
and ground water, and reduce the mobility of
the chemicals in soil through placement under
an engineered landfill cap. In addition, the
remedies separate and recycle the metals in
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spent ammunition, and reuse soil and debris as
foundation layer material for the cap at the
OU 2 landfill.
Treatment of soil will not be performed because
an equally protective alternative is available
through placement at the OU 2 landfill.
2.17 Documentation of
Significant Changes
As described in the Responsiveness Summary
(Section 3.0), the Proposed Plan for the RI Sites
was released for public comment on May 7,
1996, and a public meeting was held on
May 18, 1996. This Proposed Plan identified
preferred remedial alternatives for Sites 2
and 12, 16 and 17, 31, 39, the surface water
outfalls, and Sites 25 and 33. A change to the
preferred alternative for Site 33 described in the
Proposed Plan (no further action) was made.
This change includes the institutional control
of a deed restriction for other than residential
type use of the property at the Site 33 Golf
Course.
Comments collected over the 60-day public
review period between May 7 and July 8,1996
did not necessitate any significant changes to
the conclusions or procedures outlined in the
Basewide RI /FS and RI Sites Proposed Plan.
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3.1
Overview
At the time of the public review period for the
Army's Remedial Investigation/Feasibility Study
and Proposed Plan for the RI and other sites,
the Army identified preferred remedial
alternatives for each site. The preferred
remedial alternative consist of the following:
Sites 2 and 12
Excavation of soil containing TPH and
construction debris. Placement of debris
and soil at the OU 2 landfill.
Extraction and treatment of groundwater
containing VOCs by granular activated
carbon and disposal of treated water by one
of the following methods: (1) aboveground
reuse, or (2) injection or infiltration of
treated water back into the aquifer.
Deed restrictions on groundwater and a
post remediation risk assessment to assess
the need for institutional controls.
Sites 16 and 17
Excavation of soil containing TPH and
construction debris. Placement of debris
and soil at the OU 2 landfill.
Deed restrictions on groundwater and a
post remediation risk assessment to assess
the need for institutional controls.
Site 31
Excavation of soil containing lead and
incinerator debris. Placement of debris and
soil at the OU 2 landfill.
A post remediation risk assessment to
assess the need for institutional controls.
Site 39
Excavation of soil containing TPH and
explosive residue compounds, and
placement at the OU 2 landfill.
Excavation and segregation of spent
ammunition from soil containing residual
lead. Recycling of spent ammunition and
fragments and placement of lead-containing
soil at the OU 2 landfill.
A post remediation risk assessment to
assess the need for institutional controls.
Sites 25 and 33
No further action for Site 25 based on a
site-specific risk assessment. A deed
restriction on Site 33 based on a screening
risk evaluation.
Surface Water Outfalls
No further action at surface water outfalls
OF-1 through -14, -16 through -30, -32,
and -33.
Summary of Public Comments
On the basis of the written and verbal
comments received, the Army's Proposed Plan
was generally accepted by the public.
However, several citizens expressed concerns
regarding the following issues:
The handling of OE at the RI sites, as well
as the physical hazards associated with
spent ammunition and OE and
implementation of institutional controls.
Long-term monitoring to evaluate the
effectiveness of planned remedial actions.
Concerns regarding the capacity and design
of the CAMU at the OU 2 landfill.
The role of the state in officially
commenting on the RI/FS and Proposed
Plan regarding the California
Environmental Quality Act (CEQA) and
other state ARARs.
Amendment of the OU 2 ROD to address
the OU 2 landfill's designation as a CAMU
to receive excavated soil from the RI sites.
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3.2
Background on
Community Involvement
In 1991, Fort Ord was added to the BRAG List.
The economic impact of Fort Ord's imminent
closure has created much community interest
relative to the potential economic reuse of
portions of Fort Ord. Specifically, the RI and
other sites are under consideration for reuse for
residential, commercial, and business
development by the Fort Ord Reuse Authority
(FORA).
Focused community involvement regarding the
RI and other sites has most recently involved
the public review of the Army's Remedial
Investigation/Feasibility Study and Proposed
Plan for the RI sites (HLA, 1995a. 1996a). A
30-day public comment period began May 7,
1996 and was extended to 60 days at the
request of the public, closing on July 8,1996.
A public meeting was held on May 18,1996 to
present the Army's Proposed Plan to the public
describing the CAMU and planned remedial
actions at the RI and other sites.
This responsiveness summary responds to
written comments received during the public
comment period as well as oral comments
expressed during the public meeting.
3.3 Summary of Comments
Received During the
Public Comment Period
and Department of the
Army Responses
Comments raised during the RI Sites Proposed
Plan public comment period are summarized
below. The comments received from the
comment period are categorized by relevant
topics.
3.3.1 Technical
Questions/Concerns
Regarding Remedial
Alternatives
In general, the public accepted the
proposed remedial alternatives. Several
interested parties were concerned about
how institutional controls, removal of OE,
and physical hazards associated with spent
ammunition and OE would be handled
under the remedial alternatives.
Department of the Army's Response:
Institutional controls such as access
restrictions described in the remedial
alternatives for each of the sites will be
implemented in conjunction with land use
scenarios dictated by the FORA Reuse Plan
(FORA, 1994). OE, spent ammunition and
any associated potential physical hazards
are not regulated under CERCLA and will
be addressed under a separate action. A
post-remediation risk assessment will be
conducted to evaluate the degree of cleanup
and develop specific deed restrictions, if
necessary. The post-remediation risk
assessment may show that the sites are safe
for any use and deed restrictions are not
necessary.
In general, several citizens expressed
concern over how long-term monitoring for
groundwater treatment effectiveness and
saltwater intrusion at Sites 2 and 12 would
be implemented.
Department of the Army's Response: In
order to evaluate the long-term
effectiveness and potential for saltwater
intrusion at Sites 2 and 12, up to 30 years
of groundwater monitoring with a five year
review period is part of the selected
cleanup alternative. In addition, treated
water may be injected into the aquifer to
control saltwater intrusion.
Interested parties expressed concern about
the CAMU; specific concerns were as
follows:
A citizen stated "I have concerns that
the OU 2 landfill CAMU may not be
able to accommodate all the soil
planned for disposal at the OU 2 site.
How accurate are the projections about
the amount of soil needed as the
foundation layer for the cap, and the
amount of soil planned for removal to
the OU 2 landfill CAMU?"
Department of the Army Response: If
excess materials are generated, the landfill
cover grades can be modified in the field to
accommodate all the soil and documented
as as-built conditions. The Design Analysis
(HLA. 1995) allows for flexibility in the
final waste volume without affecting the
efficiency or effectiveness of the design.
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A citizen expressed concern about the
design of the landfill, including the liner,
the prevention of leakage to the
surrounding soil, and the integrity of the
landfill "structure."
Department of the Army Response: The
OU 2 landfill cover system was developed
in the OU 2 feasibility study [Remedial
Investigations/Feasibility Study, Site 2
Landfills, Fort Ord, California. Dames &
Moore, December 18, 1992) and
recommended in the ROD (Final Record of
Decision, Operable Unit 2. Fort Ord
Landfills, Fort Ord, California. U.S. Army,
June 22. 1994). Design details are
presented in the Design Analysis (Draft
Final Design Analysis, Fort Ord OU 2
Landfill Final Closure, Harding Lawson
Associates, December 5,1995),
Specifications (Specification No. 9705, Fort
Ord OU 2 Landfill Final Closure, Fort Ord,
California, Harding Lawson Associates,
July 5, 1995), the Closure Plan (Final
Closure and Postclosure Maintenance Plan,
Fort Ord OU 2 Landfill Final Closure, Fort
Ord, California, Harding Lawson
Associates, December 5,1995), and the
Design Drawings (Fort Ord OU 2 Landfill
Final Closure, October 20, 1995).
The landfill cover will consist of a
foundation layer to support the upper
layers of the cover, a liner, and a vegetative
layer to protect the liner and support the
growth of native vegetation. The purpose
of the liner is to minimize the infiltration of
stormwater into the refuse. The cover will
be constructed in accordance with
California Code of Regulations Title 23,
Division 3, Chapter 15, which contains
landfill closure requirements.
A citizen expressed concern about the
mixing of wastes in the CAMU, specifically:
interactions of organic and inorganic
chemistries, shifting earth, water
encroachments, solubilities, pH of the soil
and the CAMU contents, and their reactions
with the liner and UXO. The citizen also
expressed concern about the composition of
"source excavations."
Department of the Army's Response: The
liner will not be in contact with the wastes.
A technical memorandum addressing these
issues is in preparation and will become
part of the public record. The landfill cover
design has taken into account seismicity in
the Monterey area and the potential for
both short-term and long-term settlement of
the waste mass. The cover system will
reduce infiltration of water into the wastes.
Available information on the composition
of materials to be excavated and placed in
the CAMU is presented in the Final RI/FS
(HLA, 1995).
3.3.2
Costs/Funding Issues
Several citizens expressed concern that the
cost estimates for remediation of the sites
did not include costs associated with
removal of OE.
Department of the Army's Response: OE
will be addressed under a separate action;
therefore, costs were included for OE
clearance in excavation areas only.
3.3.3
Enforcement
Several citizens expressed concern that the
DTSC's official comments had not
addressed CEQA, and the list of ARARs
should include California Civil Code d3479
regarding residual contamination creating a
public nuisance. Another citizen said they
would accept the remedial alternatives
outlined in the Proposed Plan if: (1) the
DTSC and California Fish and Game
officially concurred, and (2) the RAB Water
Committee's concerns regarding the Surface
Water Outfall Investigation were addressed.
Department of the Army's Response: The
California Environmental Quality Act
(CEQA) is a set of procedures to be
followed by the State in its exercise of
discretionary approval authority. With the
exception of Public Resources Code section
21002, CEQA is comprised of procedural,
as opposed to substantive, requirements.
Although the State is not exercising its
discretionary approval authority in the
context of this ROD, it would be required to
follow Public Resources Code section
21002, which sets out the State's policy in
selecting between or among alternative
remedies, in any case where it does
exercise such authority. The Congress
intended that the federal lead agency follow
all State substantive requirements that are
N44798-H
January 13. 1997
United States Department of the Army
25
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Responsiveness Summary
more stringent than federal requirements.
The Army and EPA conclude that Public
Resources Code section 21002 is not an
applicable requirement. The parties to the
ROD believe that Public Resources Code
section 21002 has been complied with.
The State's alleged failure to comply with
Public Resources Code section 21101 does
not affect the validity of the Army's actions,
since it is the State, and not the federal
government, that is obligated to undertake a
certain action under this State law. The
intent of section 21101 is to ensure that the
State give the same kind of consideration to
a federal project that it would give to a State
project. To the extent that the information
contemplated by section 21101 has already
been provided by the State to the Army in
the course of this cleanup, there is no need
for the State to repeat it in its official
comments.
The OTSC and California Fish and Game
concur with the Ecological Risk Assessment
(ERA) for Sites 16 and 17. The DTSC agrees
with the Army that Site 25 requires no
further action as stated in the Proposed
Plan, and Site 33 will be deed restricted for
other than residential type uses. Comments
from the regulatory agencies on these sites
are being addressed in the draft final
versions of the Site Characterization
reports.
3.3.4
Remaining Concerns
Several citizens expressed concern that the
Proposed Plan could not be approved until
the OU 2 ROD was amended to address
designation of the landfill as a CAMU for
soil excavated from the RI sites, as well as
consolidation of soil from Area A.
Department of the Army's Response: A
ROD amendment is required when the
scope, performance, or cost of a remedy
fundamentally changes. Use of excavated
soil from the RI sites and Area A as
foundation layer material in the OU 2
landfill and its designation as a CAMU does
not fundamentally change the remedy
selected in the OU 2 ROD; therefore, a ROD
amendment is not necessary. These
modifications to the OU 2 ROD were
addressed in: (1) an Explanation of
Significant Differences, Area A, Operable
Unit 2 Landfill (August, 1996). (2) a
Remediation Waste Consolidation Fact Sheet
(October, 1996), and (3) an Explanation of
Significant Differences (BSD) Consolidation
of Remediation Waste at a Corrective Action
Management Unit (CAMU), Operable Unit 2
Landfill (November, 1996).
In addition, a public meeting was held on
October 29,1996 regarding waste
consolidation in the CAMU, and public
comments were accepted from October 8
through November 8,1996.
One citizen suggested it would be useful to
overlay the RI sites on a land use or reuse
plan map for the FORA jurisdiction.
Department of the Army's Response: FORA
has this type of map available for public
review. Reuse plans have been finalized
and were considered in the Proposed Plan
and ROD.
N44798-H
January 13. 1997
United States Department of the Army
26
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4.0 REFERENCES
Agency for Toxic Substances and Disease
Registry (ATSDR), 1993. Toxicological Profile
for Lead. U.S. Department of Health and
Human Services. April.
Centers for Disease Control (CDC), 1991.
Healthy People 2000: National Health
Promotion and Disease Prevention Objectives.
DHHS Publication No. PHS 921-50212.
Harding Lawson Associates (HLA), 1993.
Interim Action Excavations are Proposed for the
Cleanup of Selected Areas at Fort Ord,
California. November.
, 1994a. Interim Action Record of Decision,
Contaminated Surface Soil Remediation,
Fort Ord, California. February.
, I994b. Draft Final Technical
Memorandum, Preliminary Remediation Goals,
Fort Ord. California. June.
_, 1994c. No Action Proposed Plan for
Selected Areas at Fort Ord, California. August.
, 1995a. Final Basewide Remedial
Investigation/Feasibility Study, Fort Ord,
California. October.
, 1995b. Site Analytical Report, Sites 2
and 12 Groundwater, Fort Ord, California.
December.
, 1996a. U.S. Army Proposes Cleanup Plan
For Remedial Investigation Sites at Fort Ord,
California. May.
, 1996b. U.S. Army Proposes Cleanup Plan
to Address Human Health at Site 3 Beach
Trainfire Ranges, Fort Ord, California. May.
U.S. Army Corps of Engineers (COE),
Sacramento District, 1994. Installation-Wide
Multispecies Habitat Management Plan.
Technical Assistance from Jones & Stokes
Associates. Inc. February.
N44798-H
January 13. 1997
United States Department of the Army
27
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TABLES
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Table 1. Chemicals of Concern and Remediation Goals
Record of Decision
Remedial Investigation Sites
Fort Ord, California
Chemical of Concern
Site 2/1 2
TPH
1 ,2-Dichloroethane
1 ,3-Dichloropropene*
cis-l,2-Dichloroethene
Chloroform
Tetrachloroethene
Trichloroethene
1 , 1 -Dichloroethene
Vinyl Chloride
Site 16/17
TPH
Site 31
Lead
Site 39
TPH
Lead
RDX
Beryllium
Media
Soil
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Groundwater
Soil
Soil
Soil
Soil
Soil
Soil
Soil Cleanup
Level
(mg/kg)
5001
«
--
-
-
--
«
5001
1.8602
5001
1.8602
0.52
2.82
Aquifer
Cleanup Level
(MR/1)
-.
0.5
0.5
6.0
2.0
3.0
5.0
6.0
0.1
-
..
..
..
-
Federal MCL
(MR/1)
5.0
-
70
100
5.0
5.0
7.0
2.0
--
-
..
..
..
--
State MCL
(MR/1)
..
0.5
0.5
6.0
100
5.0
5.0
6.0
0.5
-
--
._
..
-
Discharge
Limit for
Treated Water
(MS/1)3
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.1
-
--
..
..
--
a (total).
1 (HLA, 1994b).
2 (HLA. 1995a).
3 Discharge to areas overlying the contaminated groundwaler plume need only meet aquifer cleanup levels. All limits are laboratory detection limits.
rug/kg milligrams per kilogram.
MCL Maximum Contaminant Level.
ng/1 micrograms per liter.
TPH Total Petroleum Hydrocarbons.
RDX Cyclotrimethylenetrinitramine.
N44798-H
January 13.1997
United States Department of the Army
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Table 2. Summary of Remedial Alternatives Evaluation - Sites 2 and 12
Rl Sites Record of Decision
Fort Ord, California
Alternative
Alternative 1
No Action
Alternative 2
Ground water: Extraction
and POTW Discharge
Soil: Capping and Deed
Restrictions for SRUs 1
and 2. Excavation.
Placement at OU2 Landfill
for SRU3
Short-Term
Effectiveness
Not effective
Effective
Long-Term
Effectiveness
Not effective
Effective
Reduction of Toxicity,
Mobility, and
Volume (T. M. V)
Through Treatment
No active reduction of
T, M. or V for
groundwater or soil
Groundwater:
Reduction of T. M, and
V
Soil: Reduction of M
through capping.
EPA Evaluation Criteria
Implementability
Easy to
implement
Implementable
Capping requires
deed restrictions
and maintenance
Compliance
with
ARARs
No
Yes
Overall Protection of
Human Health and the
Environment
Not protective
Protective
Regulatory Agency and
Community
Acceptance
Likely not acceptable
To be determined
NPV
Cost
$1,838.00
0
$8,900.00
0
C44882-H
January 13. ion?
and 12
e 1 of 3
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Table 2. Summary of Remedial Alternatives Evaluation - Sites 2 and 12
Rl Sites Record of Decision
Fort Ord, California
Alternative
Alternative 3
Groundwaler:
Extraction,
Treatment.
Reuse, or
Injection
Soil: Capping,
Deed Restrictions
forSRUl.
Excavation and
Placement at
OUZ Landfill for
SRUs 2 and 3.
EPA Evaluation Criteria
Short-Term
Effectiveness
Effective
Long-Term Effectiveness
Effective
Reduction of
Toxicity. Mobility,
and Volume (T, M, V)
Through Treatment
Groundwater:
Reduction of T, M,
andV
Soil: Reduction of M
and placement at
OUZ landfill for
SRUs 2 and 3.
Implementability
Implementable
Compliance
with ARARs
Yes
Overall Protection of
Human Health and
the Environment
Protective
Regulatory Agency
and Community
Acceptance
To be determined
NPV
Cost
$7,359.000 -
$8,656,000
C44882-H
January 13, 1997
Sites 2 and 12
Page 2 of 3
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Table 2. Summary of Remedial Alternatives Evaluation Sites 2 and 12
Rl Sites Record of Decision
Fort Ord, California
Alternative
Alternative 4
Groundwater:
Extraction.
Treatment,
Reuse, or
Injection
Soil: Excavation
and Placement at
OU 2 Landfill for
SRUs 1. 2. and 3.
EPA Evaluation Criteria
Short-Term
Effectiveness
Effective
Long-Term Effectiveness
Effective
Reduction of
Toxicity, Mobility,
and Volume (T. M, V)
Through Treatment
Groundwater:
Reduction of T, M.
and V
Soil: Reduction of
M.
Implementability
Implementable
Compliance
with ARARs
Yes
Overall Protection of
Human Health and
the Environment
Protective
Regulatory Agency
and Community
Acceptance
To be determined
NI'V
Cost
$7.711,000-
$9.009.000
ARARs
NPV
SRU
Applicable of relevant and appropriate requirements
Net Present Value
Soil Remedial Unit
C44882-H
January 13.19JIL
Site:
P
id 12
of 3
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Table 3. Summary of Remedial AHematlves Evaluation Sites 16 and 17
Rl Sites Record of Decision
Fort Ord, California
Alternative
Alternative 1
No Action
(Groundwater
Monitoring)
Alternative 2
Capping of SRUs
Alternative 3
Excavation.
Onsite Treatment
at FOSTA. and
Reuse or
Placement at
OU 2 Landfill for
SRUs 1 and 2.
Consolidation of
Debris into
Site 17 Disposal
Area.
Alternative 4
Excavations and
Placement at
OU 2 Landfill for
SRUs.
EPA Evaluation Criteria
Short-Term
Effectiveness
Effective
Effective
Effective
Effective
Long-Term Effectiveness
Not effective
Effective
Effective
Effective
Reduction of
Toxicity, Mobility,
and Volume (T. M,
V) Through
Treatment
No active reduction
ofT. M.andV
Reduces M, but not T
orV
Reduces T, M. and V
of soil.
Reduces M. but not T
orV.
Implementability
Easy to
implement
Implementable
Implementable
Implementable
Compliance
with ARARs
No
Yes
Yes
Yes
Overall Protection
of Human Health
and the
Environment
Not protective
Protective of
groundwater and
human health
Protective of
groundwater and
human health
Protective of
groundwater and
human health
Regulatory Agency
and Community
Acceptance
Likely not
acceptable
To be determined
To be determined
To be determined
NPV
Cost
$774.000
$1.804,000
$1.604,000
$5.158.000
ARARs
NPV
SRU
Applicable or relevant and appropriate requirements
Net Present Value
Soil Remedial Unit
C44882-H
January 13,1997
Sites 16 and 17
Page 1 of 1
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Table 4. Summary of Remedial Alternatives Evaluation Site 31
Rl Sites Record of Decision
Fort Ord, California
Alternative
Alternative 1
No Action
Alternative ;
Excavation and
Placement at the
OU2 Landfill
Altornniiv03
Kicavalion and
Consolidation In
an Onslte Waste
Management
Unit, Deed
Restrictions
Alternative 4.
Excavation and
Uflsilo Disposal
at a Landfill
EPA Evaluation Criteria
Short-Term
L'ffcclivenoss
Not effective
Effective
Effective
Effective
Long-Term Effectiveness
Not effective
Effective
Effective: however,
contaminants above
TCU would remain
onsite
Effective
Reduction of Tox icily,
Mobility, and Volume (T.
M. V) Through Treatment
No active reduction of T,
M.orV
Reduction of M, but not T
- orV
Reduction »f M, but not T
orV
Reduction of M, but not T
orV
Implemenlabilily
Eaiy to implement
Implemenlabls
ImplemenUble
Implementable
Compliance
with ARARs
No
Ye*
Requires
designation of
onslta waite
management
unit
Yes
Overall Protection
of Human Health
and the
Environment
Not protective
Protective
Protective
Protective
Regulatory Agency
and Community
Acceptance
Likely not
acceptable
To be determined
To be determined
To be determined
NI'V
Cost
SO
$320.000
$445.000
$335.000
ARARs
NI'V
Applicable or relevant and appropriate requirements
Net Present Value
C44
Ap
si
Pagel
-------
Table 5. Summary of Remedial Alternatives Evaluation - Site 39
Rl Sites Record of Decision
Fort Ord, California
Alternative
Alternative 1
No Action
Alternative 2
Institutional
Controls
Alternative 3
Excavation and
Placement at the
OU 2 Landfill
Alternative 4
Excavation and
Offsite Disposal
at a Landfill
EPA Evaluation Criteria
Short-Term
Effectiveness
Not effective
Effective
Effective
Effective
Long-Term
Effectiveness
Not effective
Not effective
Effective
Effective
Reduction of Toxicity.
Mobility, and
Volume (T, M. V)
. Through Treatment
No active reduction of
T.M.orV
No active reduction of
T, M. or V
Reduction of M. but
not T or V
Reduction of M, but
not T or V
Implementability
Easy to
implement
Easy to
implement
Easy to
implement
Easy to
implement
Compliance
with ARARs
No
No
Yes
Yes
Overall Protection of
Human Health and the
Environment
Not protective
Protective
Protective
Protective
Regulatory Agency and
Community
Acceptance
Likely not acceptable
Likely not acceptable
Likely acceptable
Likely acceptable
NPV
Cost
$0
$122,000
$1,184,000
$1.293.000
ARARs
NPV
Applicable or relevant and appropriate requirements
Net Present Value
C44882-H
January 13, 1997
Site 39
Page 1 of 1
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PLATES
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SoN *«m«dlei Unlit t on
-------
APPENDIX A
APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS FOR
THE SELECTED ALTERNATIVES
-------
APPENDIX A
CONTENTS
Al.O ARARS FOR SITES 2 AND 12 1
Al.l Chemical-Specific ARARs 1
Al.2 Location-Specific ARARs :_ 2
A1.3 Action-Specific ARARs 2
A2.0 ARARS FOR SITES 16 AND 17 3
A2.1 Chemical-Specific ARARs 3
A2.2 Location-Specific ARARs 3
A2.3 Action-Specific ARARs 3
A3.0 ARARS FOR SITE 31 4
A3.1 Chemical-Specific ARARs 4
A3.2 Location-Specific ARARs 4
A3.3 Action-Specific ARARs 5
A4.0 ARARS FOR SITE 39 5
A4.1 Chemical-Specific ARARs 5
A4.2 Location-Specific ARARs 5
A4.3 Action-Specific ARARs 6
N44798-H United States Department of the Army All
January 13. 1997
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APPENDIX A
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
FOR THE SELECTED ALTERNATIVES
The promulgated standards described below are
chemical-, location-, and action-specific ARARs
for the selected alternatives at Sites 2 and 12, 16
and 17, 31, and 39. ARARs are not presented for
the surface water outfalls or Sites 25 and 33,
because they are designated Interim Action and
No Action Sites, respectively, for which criteria
and ARARs were presented in previous
documents (HLA, 1993, 1994).
The standards described below are "applicable"
or "relevant and appropriate" for soil and
groundwater remediation. These standards are
designed to be protective of human health and
the environment and to be technically achievable
with existing analytical and treatment
technologies.
A1.O
A1.1
ARARS FOR SITES 2 AND 12
Chemical-Specific ARARs
VOCs regulated by the state and federal
government are known to be present in soil and
groundwater at Sites 2 and 12. The following
chemical-specific ARARs for soil and
groundwater remediation have been promulgated
for chemicals of concern at this site.
Waste Classification and Management,
Title 23 CCR, Division 3, Chapter 15,
Article 2
Excavated soil at Sites 2 and 12 would be
classified as a designated waste if samples
indicate the soil contains nonhazardous
levels of chemicals that may potentially
degrade waters of the State. Excavated soil
from Sites 2 and 12. which is exempt from
these requirements, will be placed at the
OU 2 landfill. Chapter 15 will apply to waste
placed at the OU 2 landfill.
Water Quality Control Plan, Central Coast
Region, 1994
Portions of the Central Coast Region Water
Quality Control Plan are ARARs. The Water
Quality Control Plan classifies groundwater
based on beneficial uses. Groundwater at
Sites 2 and 12 is considered a potential
drinking water source. The Water Quality
Control Plan establishes water quality
standards including beneficial use
designations, water quality objectives to
protect these uses, and implementation
programs to meet the objectives.
National Primary Drinking Water Standards,
Title 40 Code of Federal Regulations (CFR),
Part 141,
Chemical-specific drinking water
standards which contain maximum
contaminant levels (MCLs), have been
promulgated under the Safe Drinking
Water Act (SDWA). Drinking water goals
(MCLGs) also have been promulgated
under the SDWA. MCLGs above zero are
considered chemical-specific ARARs
under the NCP
(40 CFR 300.430(e][2j[i][B]). When
MCLGs are equal to zero, the MCL is
considered to be a chemical-specific
ARAR, instead of the MCLG (40 CFR
300.430[e][2][i][C]). Table 1 lists national
primary drinking water standards (MCL)
for chemicals detected in groundwater
during the RI. With the exceptions of
chloroform, tetrachloroethene, and vinyl
chloride, MCLs are the cleanup levels for
chemicals of concern in the groundwater
at Sites 2 and 12.
State Primary Drinking Water Standards,
California Code of Regulations (CCR) Title 22,
Chapter 15.
California primary drinking water standards
establish enforceable limits for chemicals that
may affect public health or the aesthetic
qualities of drinking water; however, only
those state requirements that are more
stringent than federal standards are ARARs
and in this case relevant and appropriate.
These requirements (state MCLs) are
summarized in Table 1.
N44798-H
January 13. 1997
United States Department of the Army
A1
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Appendix A
Land Disposal Restrictions (LDRs), Title 22
CCR, Chapter 16
LDRs prohibit land disposal of specified
untreated hazardous wastes and provides
special requirements for handling such
wastes. If listed or characteristic hazardous
waste exists in carbon treatment vessels used
for groundwater treatment. LDRs will apply to
their disposition. However, carbon vessels
will be regenerated offsite as part of a
commercial process that is an industry
standard for carbon vessel disposition.
There are no promulgated chemical-specific
requirements applicable to soil at Sites 2 and 12.
A1.2
Location-Specific ARARs
Environmentally sensitive locations have been
identified within Site 2 by investigations
performed during the RI and Ecological Risk
Assessment. Certain endangered plant and
animal species are present at the site. The
following ARARs are potentially applicable to
implementation of the groundwater remedy at
Site 2.
Endangered Species Act, Title 16, United
States Code 1531 et seq., as promulgated by
Title 50, CFR, Part 402, Section 7
The Endangered Species Act requires that
any action authorized, funded, or carried out
by a Federal agency must ensure that it is not
likely to jeopardize the continued existence of
any endangered species, or result in the
destruction or adverse modification of habitat
of such species which is determined to be
critical. Fort Ord has consulted with the Fish
and Wildlife Service in accordance with the
Endangered Species Act. The Habitat
Management Plan (HMP) addresses the
management during base closure and
cleanup.
Migratory Bird Treaty Act, 16 U.S.C.,
Section 703, et seq.
The Migratory Bird Treaty Act protects
certain migratory birds and their nests or
eggs. The HMP for Fort Ord addresses
actions to be taken and will be implemented
in conjunction with groundwater
remediation.
National Archaeological and Historic
Preservation Act, 16, U.S.C., Section 469 et
seq., and 36 CFR Part 65
This Act provides for protection of any
historically significant artifacts that may be
unearthed during remediation activities.
Appropriate actions will be taken if any
artifacts are unearthed.
Coastal Zone Management Act, 16 U.S.C.
Section 1456 et seq., and California Coastal
Act of 1976
These Acts require that activities conducted
in the coastal zone (west of Highway 1) be
completed in a manner consistent with the
state's coastal zone management plan. Site 2
is within this zone, therefore the
requirements of that plan apply to
implementation of the groundwater remedy.
A1.3
Action-Specific ARAB*
Action-specific requirements apply to
implementation of remedial activities such as
excavation and soil handling, groundwater
treatment, and discharge.
Monterey Bay Unified Air Pollution Control
District (MBUAPCD), Regulations II and X,
and National Primary and Secondary Air
Quality Standards, 40 CFR Part 150.
These regulations and standards establish
requirements for sources of air pollution, and
the appropriate level of air abatement
technology to be applied for specific
chemicals that may be generated as toxic air
contaminants. The remedial action must
meet the substantive requirements of these
regulations. During excavation and soil
handling, appropriate measures such as dust
suppression must be implemented to meet
these requirements.
Standards Applicable to Generators of
Hazardous Waste, Title 22 California Code of
Regulations (CCR) Chapter 12.
These standards are applicable if hazardous
waste is generated at the Site. The
substantive portions of this regulation will
apply and be complied with.
N44798-H
January 13. 1997
United States Department of the Army
A2
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Appendix A
State Water Resources Control Board,
Resolution No. 88-63
Resolution No. 88-63 specifies that all ground
and surface water is an existing or potential
source of drinking water unless total
dissolved solids (TDS) are greater than
3,000 parts per million (ppm), the well yield
is less than 200 gallons per day from a single
well, or the groundwater is unreasonable to
treat using best management practices or best
economically achievable treatment practices.
Under this resolution, the upper aquifer at
Sites 2 and 12 is a potential drinking source.
State Water Resources Control Board,
Resolution No. 92-49
Resolution 92-49 establishes policies and
procedures for the investigation, cleanup, and
abatement of waste. In accordance with these
requirements, cleanup levels must be set at
background levels, or if background levels are
not technologically or economically feasible,
then at the lowest levels that are achievable.
The Army completed an economic and
technical feasibility analysis pursuant to
92-49 and has determined that cleanup to the
MCLs is reasonable and satisfies this
requirement. The soil cleanup levels
identified in this ROD are protective of
groundwater quality and comply with
Resolution 92-49.
State Water Resources Control Board,
Resolution No. 68-16
Resolution No. 68-16 establishes goals for the
maintenance of existing groundwater quality.
It also requires best practical control
technology for discharges to high quality
water. Discharge levels were chosen for
Sites 2 and 12 considering site-specific
conditions, including the contaminants to be
discharged and the designated beneficial uses
of the receiving water, available treatment
technologies, and cost.
Federal Safe Drinking Water Act, 40 CFR, and
California Toxic Injection Well Act,
California Health and Safety Code
Section 25159.24
40 CFR Part 144 and the California Toxic
Injection Well Act prohibit injection of
contaminated water into or above a drinking
water formation. Injection of treated
groundwater into the source aquifer for the
purpose of aquifer cleanup is exempted. For
Sites 2 and 12, treated groundwater may be
injected to the aquifer provided injected
groundwater does not contain chemical
concentrations above at or below cleanup
levels (Table 1).
A2.0
A2.1
ARABS FOR SITES 16
AND 17
Chemical-Specific ARARs
The following chemical-specific ARARs for soil
cleanup have been promulgated for chemicals of
concern at these sites.
Waste Classification and Management,
Title 23 CCR, Division 3, Chapter 15,
Article 2
Excavated soil at Sites 16 and 17 would be
classified as a designated waste if samples
indicate the soil contains nonhazardous
levels of chemicals that may potentially
degrade waters of the State. Excavated soil
from Sites 16 and 17, which is exempt from
these requirements, will be placed at the
OU 2 landfill. Chapter 15 will apply to waste
placed at the OU 2 landfill.
A2.2
Location-Specific ARARs
No location-specific ARARs have been identified
for these sites.
A2.3
Action-Specific ARARs
Action-specific requirements apply to
implementation of soil remedial activities such as
excavation and soil handling.
Monterey Bay Unified Air Pollution Control
District, Regulations II and X, and National
Primary and Secondary Air Quality
Standards, 40 CFR Part 150.
These regulations and standards establish
requirements for sources of air pollution, and
the appropriate level of air abatement
technology to be applied for specific
chemicals that may be generated as toxic air
N44798-H
January 13. 1997
United States Department of the Army
A3
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Appendix A
contaminants. During excavation and soil
handling, appropriate measures such as dust
suppression must be implemented to meet
these requirements.
State Water Resources Control Board,
Resolution No. 92-49
Resolution 92-49 establishes policies and
procedures for the investigation, cleanup, and
abatement of waste. In accordance with these
requirements, cleanup levels must be set at
background levels, or if background levels are
not technologically or economically feasible,
then at the lowest levels that are achievable.
The Army completed an economic and
technical feasibility analysis pursuant to
Resolution No. 92-49 and has determined that
cleanup to the MCLs is reasonable and
satisfies this requirement. The soil cleanup
levels identified in this ROD are protective of
groundwater quality and comply with
Resolution No. 92-49
Medical Waste Management Act, California
Health and Safety Code, Division 4, Chapter 6
and Infectious Waste, Title 22 CCR,
Article 13.
These regulations cover the handling,
treatment, and disposal of medical and
infectious wastes. Medical waste was found
at Site 16 and 17 during the RI. Medical
wastes and infectious wastes encountered
during excavation activities must be handled
in accordance with these regulations.
A3.0
A3.1
ARARS FOR SITE 31
Chemical-Specific ARARs
Chemicals such as lead that are regulated by the
state and federal government at hazardous levels
are known to be present at Site 31. The following
chemical-specific ARARs for soil cleanup have
been promulgated for chemicals of concern at this
site.
Identification and Listing of Hazardous
Waste, Title 22, California Code of
Regulations (CCR), Division 4.5, Chapter 11.
Excavated lead and DDE/DDT-containing soil
at Site 31 would be classified as a
characteristic hazardous waste under the
Resource Conservation and Recovery Act
(RCRA) if samples indicate the soil contains
hazardous levels of these chemicals.
Excavated soil from Site 31. which is exempt
from these requirements, will be placed at the
OU 2 landfill.
Waste Classification and Management,
Title 23 CCR, Division 3, Chapter 15,
Article 2
Excavated soil at Site 31 would be classified
as a designated waste if samples indicate the
soil contains nonhazardous levels of
chemicals that may potentially degrade
waters of the State. Excavated soil from
Site 31, which is exempt from these
requirements, will be placed at the OU 2
landfill. Chapter 15 will apply to waste
placed at the OU 2 landfill.
A3.2
Location-Specific ARARs
Site 31 contains species categorized as California
Species of Special Concern, or as rare in
California and elsewhere by the California Native
Plant Society. The following ARARs are
potentially applicable to soil remediation at
Site 31.
Endangered Species Act, Title 16, United
States Code 1531 et seq., as promulgated by
Title 50, CFR, Part 402, and the California
Endangered Species Act, California Fish and
Game Code, Section 2050 et seq.
The Endangered Species Acts require action
to conserve endangered species and critical
habitats upon which endangered species
depend. The HMP for Fort Ord addresses
actions to be taken and will be implemented
in conjunction with soil remediation.
Migratory Bird Treaty Act, 16 U.S.C.,
Section 703, et seq.
The Migratory Bird Treaty Act protects
certain migratory birds and their nests or
eggs. The HMP for Fort Ord addresses
actions to be taken and will be implemented
in conjunction with soil remediation.
National Archaeological and Historic
Preservation Act, 16. U.S.C., Section 469 et
seq., and 36 CFR Part 65
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United State* Department of the Army
A4
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Appendix A
This Act provides for protection of any
historically significant artifacts that may be
unearthed during remediation activities.
Appropriate actions will be taken if any
artifacts are unearthed.
The parties to this ROD do not agree whether
California Fish and Game Code
Section 3005(a) is an ARAR for Site 31. The
State's position is that Fish and Game Code
Section 3005(a) is an applicable requirement
for the protection of birds and mammals at
Site 31. The Army does not agree that Fish
and Game Code Section 3005(a) is an
applicable requirement for the protection of
birds and mammals at Site 31. The State,
however, has decided not to dispute this
decision because the Army will conduct a
post-remediation ecological evaluation for
Site 31. If the Parties to this ROD agree that
the post-remediation ecological evaluation
indicate that the residual levels of chemicals
of potential concern (COPCs) are protective of
the ecological receptors at Site 31, the
remedial actions at Site 31 will be deemed
complete. If the post-remediation ecological
evaluation indicates that residual levels are
not protective of ecological receptors at
Site 31, further actions may be necessary.
A4.0
A4.1
ARABS FOR SITE 39
ChemicahSpecific ARARs
A3.3
Action-Specific ARARs
Action-specific requirements apply to
implementation of soil remedial activities such as
excavation and soil handling. The following
action-specific requirements are potentially
applicable to the soil remedy at Site 31:
Monterey Bay Unified Air Pollution Control
District, Regulations II and X, and National
Primary and Secondary Air Quality
Standards, 40 CFR Part 150
These regulations and standards establish
requirements for sources of air pollution, and
the appropriate level of air abatement
technology to be applied for specific
chemicals that may be generated as toxic air
contaminants. During excavation and soil
handling, appropriate measures such as dust
suppression must be implemented to meet
these requirements.
Chemicals such as lead that are regulated by the
state and federal government at hazardous levels
are known to be present at Site 39. The following
chemical-specific ARARs for soil cleanup have
been promulgated for chemicals of concern at this
site.
Identification and Listing of Hazardous
Waste. Title 22 CCR, Division 4.5, Chapter 11
Excavated soil containing lead, RJDX, and
beryllium at Site 39 would be classified as a
characteristic hazardous waste under RCRA if
samples indicate the soil contains hazardous
levels of these chemicals. Excavated soil from
Site 39, which is exempt from these treatment
requirements, will be placed at the OU 2
landfill.
Waste Classification and Management,
Title 23 CCR, Division 3. Chapter 15;
Article 2
Excavated soil at Site 39 would be classified
as a designated waste if samples indicate the
soil contains nonhazardous levels of
chemicals that may potentially degrade
waters of the State. Excavated soil from
Site 39, which is exempt from these
requirements, will be placed at the OU 2
landfill. Chapter 15 will apply to waste
placed at the OU 2 landfill.
A4.2
Location-Specific ARARs
Site 39 is a critical habitat for endangered species
and contains endangered plant and animal
species. The following ARARs are potentially
applicable to soil remediation at Site 39.
Endangered Species Act, Title 16, United
States Code 1531 et seq., as promulgated by
Title 50, CFR, Part 402 and the California
Endangered Species Act, California Fish and
Game Code, Section 2050 et seq.
The Endangered Species Acts require action
to conserve endangered species and critical
habitats upon which endangered species
depend. The HMP for Fort Ord addresses
actions to be taken and will be implemented
in conjunction with soil remediation.
N44798-H
January 13. 1997
United States Department off the Army
AS
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Appendix A
Migratory Bird Treaty Act, 16 U.S.C.,
Section 703, et seq.
The Migratory Bird Treaty Act protects
certain migratory birds and their nests or
eggs. The HMP for Fort Ord addresses
actions to be taken and will be implemented
in conjunction with soil remediation.
National Archaeological and Historic
Preservation Act, 16, U.S.C., Section 469 et
seq., and 36 CFR Part 65
This Act provides for protection of any
historically significant artifacts that may be
unearthed during remediation activities.
Appropriate actions will be taken if any
artifacts are unearthed.
The parties to this ROD do not agree whether
California Fish and Game Code Section
3005(a) is an ARAR for Site 39. The State's
position is that Fish and Game Code Section
3005(a) is an applicable requirement for the
protection of birds and mammals at Site 39.
The Army does not agree that Fish and Game
Code Section 3005(a) is an applicable
requirement for the protection of birds and
mammals at Site 39. The State, however, has
decided not to dispute this decision because
the Army will conduct a post-remediation
ecological evaluation for Site 39. If the
Parties to this ROD agree that the
post-remediation ecological evaluation
indicates that the residual levels of chemicals
of potential concern (COPCs) are protective of
the ecological receptors at Site 39, the
remedial actions at Site 39 will be deemed
complete. If the post-remediation ecological
evaluation indicates that residual levels are
not protective of ecological receptors at
Site 39, further actions may be necessary.
A4.3
Action-Specific ARARs
Action-specific requirements apply to
implementation of soil remedial activities such as
excavation and soil handling. The following
action-specific requirements are potentially
applicable to the soil remedy at Site 39:
Monterey Bay Unified Air Pollution Control
District, Regulations II and X, and National
Primary and Secondary Air Quality
Standards, 40 CFR Part 150
These regulations and standards establish
requirements for sources of air pollution, and the
appropriate level of air abatement technology to
be applied for specific chemicals that may be
generated as toxic air contaminants. During
excavation and soil handling, appropriate
measures such as dust suppression must be
implemented to meet these requirements.
N44798-H
January 13. 1997
United States Department of the Army
A6
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APPENDIX B
COMMUNITY RELATIONS ACTIVITIES
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APPENDIX B
COMMUNITY RELATIONS ACTIVITIES
The following activities have been conducted as
part of the Army's public relations and
information transfer efforts regarding
environmental restoration activities at Fort Ord.
Presentations, briefings, and/or tours were
given to the following groups or organizations,
or the following meetings.
Activity
1996
January 19. Tour of clean-up activities for
Congressman Sam Fair and staff
January 20. Orientation and tour for new
Restoration Advisory Board (RAB) members
January 25. RAB meeting: Sites 16 and 17
February 22. RAB meeting: Site 31
March 28. RAB meeting: RI sites
April 25. RAB meeting: RJ sites
May 1. Superfund Roundtable for RAB members
and general public
May 6. Presentation to Cal. State Univ. at
Monterey Bay Environmental Chemistry class
MayS, 12, 17. Monterey County Herald Notice:
Fort Ord public meeting
May 18. Proposed Plan public meeting
May 23. Tour of clean-up activities for members
of Fort Ord Reuse Authority
May 23. RAB meeting: RI sites
June 3 -5. Monterey County Herald Notice:
Extension of Comment Period for the Fort Ord
Proposed Plans
June 10. Training on DOD/EPA Guidance for
RAB members
June 11. Presentation to Kiwanis Club on
Ordnance and Explosive Waste Issues
1995
January 26. RAB meeting: RI sites
February 23. RAB meeting: RI sites
February 24. Presentation to National
Oceanographic and Atmospheric Association
March 23. RAB meeting: RI sites
April 27. RAB meeting: RI sites
May 9. Presentation ofOUl and Superfund to
Univ. of Calif, at Santa Cruz extension class
May 24. Superfund briefing to Fort Ord Reuse
Authority staff
May 25. RAB meeting: RI sites
May 30. Community Outreach Committee of the
RAB public workshop
June 13. Beach walk with "Coastwalk"
June 22. RAB meeting: RI sites
July 13. Presentation to Univ. of Calif, at
Santa Cruz "Career Seminar"
July 26. RAB meeting: RI/FS report
August 22-27. Information Booth at Monterey
County Fair
August 24. RAB meeting: RI sites
September 7. Community Outreach Committee
of the RAB public meeting in Seaside
October 3. Public meeting on OUl
October 14. Information Booth at Marina
Birthday Celebration
October 21. Community Outreach Committee of
the RAB public meeting in Salinas
October 26. RAB meeting: Sites 2 and 12
October 28. Community Outreach Committee of
the RAB public meeting in Marina
N44798-H
January 13. 1997
United States Department of the Army
B1
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Appendix B
November 9. Presentation to League of Women 1994
Voters
Mnupm.op9_ c .. _ . _ .L February?. RAB/Technica] Review Committee
November 27. Seaside Community Forum with (TRC) meeting: RI/FS
Congressman Farr
NT u May 11. RAB/TRC meeting: RI/FS
November 30. RAB meeting: RI Sites
October 20. RAB/TRC meeting: RI/FS
N44798-H United States Department of the Army B2
January 13. 1997
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