PB97-964504
                                 EPA/541/R-97/034
                                 November 1997
EPA  Superfund
       Record of Decision:
       Fort Ord (Beach Trainfire Ranges) (Site 3)
       Marina, CA
       1/17/1997

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 Interim Record of Decision
 Site 3
 Beach Trainffire Ranges
 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	1
       1.2 Basis and Purpose	.._.	l
       1.3 Site Assessment	,	1
       1.4 Description of the Remedy	1
       1.5 Statutory Determination	2

2.0 DECISION SUMMARY	3

       2.1 Site Description	3
       2.2 Site History	'.	3
       2.3 Enforcement and Regulatory History	4
       2.4 Highlights of Community Participation	,	4
       2.5 Site Characteristics	5
       2.6 Scope and Role of Operable Unit	5
       2.7 Summary of Site Risks	5
       2.8 Remedial Action Objectives	6
       2.9 Description of Alternatives	7
              2.9.1 Alternative 1 - No Action	7
              2.9.2 Alternative 2 - Final Cleanup for Human Health:  Excavation and Treatment	7
              2.9.3 Alternative 3 - Final Cleanup for Human Health:  Excavation and Placement at the
              OU 2 Landfill CAMU	7
       2.10 Summary of Alternative Comparison	7
       2.11 The Selected Remedy	8
       2.12 Statutory Determinations	8
              2.12.1 Protection of Human Health	8
              2.12.2 Compliance with ARARs	9
              2.12.3 Cost Effectiveness	9
              2.12.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or
              Resource  Recovery Technologies	....9
              2.12.5 Preference for Treatment as a Principal Element	9
       2.13 Documentation of Significant Changes	9

3.0 RESPONSIVENESS SUMMARY	10

       3.1 Overview	10
       3.2 Background on Community Involvement	10
       3.3 Summary of Comments Received During the Public Comment Period and Department of the
       Army's Responses	10
              3.3.1 Remedial Alternative Preferences	10
              3.3.2 Technical Questions/Concerns Regarding Remedial Alternatives	12
              3.3.3 Costs/Funding Issues	13
              3.3.4 Enforcement	13
       3.4 Remaining Concerns	13

4.0 REFERENCES	15
C44877-H                                      United State* Department of the Army      II
January 13. 1997

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 TABLES

 1      Summary of Remedial Alternatives Evaluation


 PLATES


 1      Site Map - Soil Remedial Unit


 APPENDIXES


 A     APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS FOR THE SELECTED
       ALTERNATIVE

 B      COMMUNITY RELATIONS ACTIVITIES AT SITE 3
C44877-H                                  United States Department of the Army     ill
January 13. 1997

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                                      1.0 DECLARATION
1.1
Site Name and Location
1.3
Site Assessment
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.
1.2
Basis and Purpose
This Interim Record of Decision (ROD)
addresses Remedial Investigation (RI) Site 3,
the Beach Trainfire Ranges, which extends
approximately 3.2 miles (780 acres) along the
coastline of Monterey Bay at the western
boundary of Fort Ord.  This Interim ROD does
not address ordnance or explosives (OE), which
will be addressed in a separate process. RI Sites
2 and 12, 16 and 17, 31, and 39 were addressed
in a separate ROD.

This decision document presents the selected
remedial action for Site 3 for protection of
human health. Ecological protection will be
addressed after completion of the Ecological
Risk Assessment. The remedy was selected in
accordance with the Comprehensive
Environmental Response, Compensation, and
Liability Act (CERCLA), as amended by the
Superfund Amendment and Reauthorization
Act (SARA), and, to the extent practicable, the
National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This
decision is based on the Administrative Record
for Fort Ord.

The United States Environmental Protection
Agency (EPA) and the California Environmental
Protection Agency (Cal/EPA), which includes
the California Regional Water Quality Control
Board (RWQCB) and other State agencies,
concur with the selected remedy.
                                   Actual or threatened releases of hazardous
                                   substances at Site 3, if not addressed by
                                   implementing the response action selected in
                                   this Interim ROD, may present a current or
                                   future threat to public health,  welfare, or the
                                   environment.
                                   1.4
              Description of the
              Remedy
The selected remedial alternative described in
this Interim ROD addresses current or potential
significant risks to human health posed by
Site 3 at Fort Ord, California as described in the
Basewide Remedial Investigation/Feasibility
Study (RI/FS) (HLA. 1995a). The remedy's
protectiveness of the environment will be
addressed after an environmental cleanup level
is finalized on the basis of the Ecological Risk
Assessment being performed.

The existing boundaries of the main landfill at
Fort Ord 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. The soil remedy for Site 3 utilizes the
CAMU for placement of excavated soil from
remedial actions at the site. The soil will be
managed at the CAMU, incorporated within the
landfill cover soils (foundation  layer) with
remediation waste from the other RI sites, and
capped as part of the landfill.

The selected remedy will involve the following
activities:

•  Excavation and separation (screening) of
   spent ammunition from soil in areas of
   greater than 10 percent surface coverage of
   spent ammunition

•  Recycling of spent ammunition at a metals
   refinery, and

•  Placement of lead-containing soil at the
   OU 2 landfill.
C44877-H
January 13. 1997
                                United States Department off the Army

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                                                                                Declaration
1.5
              Statutory Determination
The selected remedy is protective of human
health, complies with federal and state
applicable or relevant and appropriate
requirements for this action, and is cost
effective. The remedy is intended to fully
address the statutory mandate for permanence
and treatment to the maximum extent
practicable for Site 3. The remedy utilizes
permanent solutions and alternative treatment
(or resource recovery) technologies to the
maximum extent practicable and satisfies the
statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or
volume as a principal element.

•   Soil from Site 3 will be reused as
    foundation layer material beneath the
    barrier layer at  the OU 2 landfill, thereby
    reducing mobility.

•   Spent ammunition from Site 3 will be
    recycled, and the metals reused.

•   Soil from the site 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.

Because this action does not constitute the final
remedy for Site  3, subsequent actions will be
evaluated to address fully the potential
ecological risks  posed by this site.
Ray&6nd 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-McCutchon
                                                 Colonel, U.sNArmy
                                                 Chief, BRAC/Environmental
                                                 Gail Youngtffood
                                                 BRAG Environmental Coordinator
                                                 Presidio of Monterey
                  Date
                                                    ielQpalski     &"           7Bate
                                                        , Federal Facilities Cleanup Branch
                                                 U.S. Environmental Protection Agency
                                                 Region IX
                                                Anthony J. Landis,#E/ "          Date
                                                Chief of Operations
                                                Office of Military Facilities
                                                California Environmental Protection Agency
                                                Department of Toxic Substances Control
/
                                                                                   Date
                                                       W. Briggs
                                                 Executive Officer
                                                 California Environmental Protection Agency
                                                 California Regional Water Quality Control
                                                     Board, Central Coast Region
C44877-H
January IS. 1997
                                             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.

 Srte3
Site 3 extends approximately 3.2 miles (780
acres) along the coastline of Monterey Bay and
forms a portion of the western boundary of Fort
Ord. The site is bordered to the south by Sand
City, to the north by the city of Marina, to the
west by Monterey Bay, and to the east by the
trainfire ranges access road and Highway 1
(Plates 1). Small arms firing ranges, numbered 1
through 17, are scattered along the eastern half
of the site. There are no firing ranges numbered
10 or 13. In general, trainees fired from firing
lines in the eastern portion of the site toward
targets spaced at varying intervals to the west.
Spent bullets accumulated on the east-facing
(leeward) sides of the sand dunes that formed
"backstops" for the targets. A former
ammunition storage area is between Ranges 3
and 4. The area west of the dunes is an
undeveloped beach.

Most of the surface area of Site 3 is unpaved
and vegetated, with dune sand present at the
surface.  The predominant topography (i.e.,
numerous intersecting rolling hills) of Site 3
.reflects a morphology typical of the dune sand
deposits that underlie the  site. The bases of the
dunes begin at an elevation of approximately 40
feet above mean sea level (MSL); the maximum
elevation of the dunes is approximately 150 feet
MSL. The dunes are truncated to the west by
steep cliffs formed as a result of waves and
winter storms. Portions of the cliffs are as high
as 40 feet above the beach.

S til well Hall and two sewage treatment plants
are the main structures onsite. Stilwell Hall, in
the central portion of Site 3, was once used for
recreation purposes but is not currently in use.
The Ord Village Sewage Treatment Plant (STP)
and the Main Garrison STP are within Site 3,
but are not considered part of this site.  Instead,
these STPs were  investigated separately as
Sites 1 and 2, respectively. Sewage is no longer
treated at these plants, but instead is pumped
from Site 1 and gravity fed from Site 2 to the
Monterey Regional Treatment plant in the City
of Marina.

Seven storm drain outfalls, which collect
stormwater from the Main Garrison area of Fort
Ord, discharge to either the dune area or the
intertidal zone of the site. The storm drain
outfalls were investigated separately as part of
the Basewide Surface Water Outfall
Investigation.
                                    2.2
              Site History
                                    Since its opening in 1917, Fort Ord has
                                    primarily served as a training and staging
                                    facility for infantry troops. No permanent
                                    improvements were made until the late 1930s,
                                    when administrative buildings, barracks, mess
                                    halls, tent pads, and a sewage treatment plant
                                    were constructed.  From 1947 to 1975, Fort Ord
                                    was a basic training center.  After 1975, the
                                    7th 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.
                                    Although Army personnel still operate the base,
                                    no active army division is currently stationed
                                    there.
C44877-H
January 13, 1997
                                United States Department off the Army

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                                                                         Decision Summary
SHe3
Site 3 was used for small arms trainfire
beginning in the 1940s. Trainees fired
small-caliber, hand-held weapons at targets
near the leeward dune faces. According to the
director of Fort Ord Range Control, all of the
target ranges were used before 1975, Ranges 1
through 8 have been used since 1975 with
Range 8 receiving the heaviest and most recent
use. During training activities, cartridges were
routinely collected for reuse. No routine efforts
were made to collect the spent ammunition.
Therefore, most of the ranges contain
accumulations of spent bullets.  In 1976 and
1977, several hundred pounds of spent
ammunition were recovered at Ranges 15 and
16 by a Fort Ord contractor, with little
disturbance to the dunes. In addition, a pilot
study was performed at Range 2 to evaluate
excavation, screening, and onsite treatment
options prior to full-scale remedial action at
Site 3 (HLA, 1996a).  Approximately
1,500 cubic yards  of spent ammunition and soil
from Range 2 was excavated, the spent
ammunition was separated and recycled, and
the soil was treated onsite by chemical fixation
in September 1995.
2.3
Enforcement and
Regulatory History
Environmental investigations began at Fort Ord
in 1984 at Fritzsche Army Airfield (FAAF)
under Regional Water Quality Control Board
(RWQCB) cleanup or abatement orders 84-92,
86-86, and 86-315. Investigations indicated the
presence of residual organic compounds from
fire drill burning practices at the Fire Drill Burn
Pit (Operable Unit 1 or OU 1). The subsequent
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,
and 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 VOCs found in
groundwater beneath OU 2.

A Federal Facility Agreement (FFA) was signed
by the Army, EPA, the California
Environmental Protection Agency's Department
                                   of Toxic Substances Control (DTSC; formerly
                                   the Toxic Substances Control Program of
                                   Department of Health Services or DHS), and the
                                   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,
                                   and Fort Ord was placed on the Base
                                   Realignment and Closure (BRAG) list

                                   Site 3
                                   The final draft of the basewide RI/FS was
                                   submitted in October 1996 and addressed Site 3
                                   as well as the other RI sites. Two separate
                                   Proposed Plans were submitted for Site 3 and
                                   the RI sites on May 7,1996 (HLA, 1996b,
                                   1996c}. Site 3 is addressed separately in the
                                   Proposed Plan and this Interim ROD because
                                   the Ecological Risk Assessment at Site 3 is still
                                   being performed and requires separate
                                   scheduling.
                                   2.4
              Highlights off Community
              Participation
On May 7,1996, the Army distributed the
Proposed Plan for Site 3 to the public for review
and comment (HLA, I996b). The Proposed Plan
presented the preferred alternative for
protection of human health, and summarized
information in the Site 3 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
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
C44877-H
January 13. 1997
                                United States Department of the Army      4

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                                                                          Decision Summary
during the public comment period.  Responses
to the comments received during the public
comment period are included in the
Responsiveness Summary presented in
Section 3.0 of this document.
2.5
Site Characteristics
Results of the remedial investigation indicate
that lead, zinc, tin, antimony, chromium,
copper, and iron are the primary waste
components of spent ammunition at the site.
Lead is the main contaminant of potential
concern because of its toxicity and the high
concentrations detected at the site.  The highest
lead concentrations were detected where
surface concentrations of spent ammunition are
greater than 10 percent. In the areas containing
significant amounts of spent ammunition, the
lead concentrations in sieved surface soil
samples ranged from 457 to 46,300 milligrams
per kilogram (nig/kg].  In general, lead is
present above background (naturally occurring)
concentrations to depths of 2 feet below ground
surface.

The following bullet distribution levels were
identified:  (1) light or none: less than
1 percent of surface area covered with spent
ammunition, which occurred at 91 percent of
the site,  (2) moderate:  1 to 10 percent of
surface area covered by spent ammunition,
which occurred at 5 percent of the site, and
(3) heavy: more than 10 percent of surface area
covered, which  occurred at 4 percent of the
site.

The depth to groundwater ranges from 20 to
100 feet at Site 3. Concentrations of metals
detected in groundwater samples were below
regulatory levels and are consistent with
background (naturally occurring) conditions.
Lead was not  detected in wells installed at the
Beach Ranges.
2.6
Scope and Role of
Operable Unit
This Interim ROD addresses planned remedial
actions for Site 3 for the protection of human
health as recommended in the FS. A pilot
study at Range 2 was performed to evaluate
various excavation, soil handling, staging,
screening, and treatment techniques that will
be used to further refine planned remedial
actions (HLA, 1996a). The planned remedial
actions for Site 3 will be final remedies for
protection of human health. The Ecological
Risk Assessment for Site 3 is being performed,
and an environmental cleanup level has not
been finalized. To proceed with cleanup plans
for Site 3, the human health-based cleanup
level for lead will be used as an interim
environmental cleanup level.
                                    2.7
              Summary of Site Risks
Potential human health risks and
environmental impacts at Site 3 were evaluated
in the Human Health Risk Assessment and
Ecological Risk Assessment, respectively.

Human Health Risks. The Human Health Risk
Assessment for Site 3 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 (HI) greater than  1.

•   Potential cancer health risks were evaluated
    using EPA and other toxicity 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  modeling procedures. The
    EPA's threshold  blood-lead level of concern
    is a level greater than 10 micrograms per
    deciliter (^g/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 Mg/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.
C44877-H
January 13. 1997
                                United States Department of the Army

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                                                                          Decision Summary
    Thresholds suggested for workers range
    from 25 to 50 Mg/dL, for hematological and
    cardiovascular endpoints (CDC, 1991;
    ATSDR, 1993). Therefore, the blood-lead
    level of concern of 10 Mg/dL is protective of
    both children and adults.

The chemicals of potential concern identified
in the Human Health Risk Assessment for Site 3
are the metals antimony, copper, and lead. On
the basis of the proposed future use of the site,
the Human Health Risk Assessment evaluated
risks to a nearby visitor or resident, and onsite
park rangers. The evaluation assumed an
exposure to contaminants while walking
randomly through any and all portions of the
site. The estimated exposure was based on lead
concentrations within the areas covered by the
three spent ammunition distribution levels.

None of the chemicals of potential concern
evaluated had associated cancer risks; however,
potential noncancer health effects and blood-
lead levels were evaluated and compared to the
EPA's HI threshold levels of concern. The
evaluation indicated that blood-lead levels and
His for the random walking exposure (for
antimony and copper) in areas of light spent
ammunition cover were below levels of
concern. For comparison, human health risk
estimates were also developed by assuming
exposure might occur exclusively at each of the
three bullet distribution areas. If the exposure
is confined to areas with moderate and heavy
spent ammunition cover, blood lead levels and
His are estimated to exceed the EPA's threshold
levels.

Given the conservative assumption that a
nearby resident, visitor, or onsite park ranger
would possibly be exposed to lead only in the
areas with moderate and heavy bullet
distribution, a health-based cleanup level of
1,860 mg/kg of lead in soil was developed. At
this concentration, blood-lead levels are not
expected to exceed the threshold of concern of
10 jxg/dL. Concentrations of lead above the
health-based level of concern occur mainly in
areas where greater than 10 percent of the
surface is covered by spent ammunition.
Although antimony and  copper are present in
some areas at high concentrations, they appear
to be collocated with high levels of lead.  It is
therefore expected that if lead in soil is
remediated to the health-based level of concern,
   this will reduce antimony and copper
   concentrations to levels below which adverse
   health effects on humans might occur.

   Ecological Impacts. On the basis of the
   Ecological Risk Assessment results for Site 3, an
   environmental cleanup level for lead is being
   developed; however, this level has not been
   finalized.  To proceed with cleanup plans for
   Site 3, the human health-based level of concern
   for lead of 1,860 mg/kg will be used as an
   interim environmental cleanup level. The
   Army recognizes the need for additional
   ecological assessment activities and finalization
   of an environmental cleanup level for lead
   2.8
Remedial Action
Objectives
   Proposed Reuse; Site 3 is proposed for reuse as
   a state park consisting mostly of open space.
   The park is intended for public hiking,
   camping, and recreational uses. The Site 2 STP
   within the boundaries of Site 3 is proposed for
   development as an aquaculture and marine
   research center or open space area.

   Remedial Action Objectives:

   The remedial action objectives for the
   protection of human health at Site 3 are to
   reduce potential adverse health effects
   associated with noncarcinogenic, site-related
   chemicals by remediation to health-based levels
   of concern.

   A health-based cleanup level of 1.860 mg/kg
   will be applied to areas of greater than 10
   percent surface coverage and provides the final
   remediation for protection of human health. A
   final determination of the remedy's
   protectiveness of the environment will be made
   when an environmental cleanup level for lead
   is finalized as discussed in Section 3.4.

   Areas in which more than 10 percent of the
   surface is covered with spent ammunition
   comprise the Soil Remedial Unit for Site 3.  The
   Remedial Unit consists of approximately
   63,000 cubic yards (cy) of spent ammunition
   and soil and extends to a depth of
   approximately 2 feet below ground surface.
   Approximately 55,000 cy of the 63,000 cy is
   soil, and 8,000 cy is spent ammunition.
C44877-H
January 13. 1997
United States Department off the Army

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                                                                         Decision Summary
The remedial action objectives based on the
Human Health Risk Assessment for Site 3 are
protective under the proposed reuse. A post
remediation risk assessment evaluating
established chemicals of potential concern for
soil will be conducted. This assessment may
show that the site is safe for any use and deed
restrictions are not necessary. If deed
restrictions are determined to be necessary, the
appropriate restrictions will be attached to the
deed of this property. These restrictions will
limit reuse and notify the potential owner of the
presence of residual contamination.
2.9
Description of
Alternatives
The following three remedial alternatives were
evaluated in the FS. Capital costs were
estimated for each alternative.  There are no
annual operational and maintenance costs
associated with the alternatives.
2.9.1
Alternative 1 - No Action
    Estimated Capital Cost:    $0

    This alternative consists of taking no
    further action to control or remediate
    contamination at the site. The no action
    alternative is required to be considered
    under CERCLA as a baseline against which
    to compare other alternatives. The only
    activity that would continue under the no
    action alternative would be periodic
    groundwater monitoring under the
    basewide program to detect any threat to
    human health or the environment, and
    continuation of access restrictions already
    in place at the site.  Costs for these
    activities are included in existing programs.

2.9.2         Alternative 2 • Final
              Cleanup for Human
              Health:  Excavation and
              Treatment

    Estimated Capital Cost:    $ 11,480,000

    This alternative consists of mechanical and
    hand excavation of approximately
    63,000 cubic yards of soil and spent
    ammunition in areas of more than
    10 percent surface coverage of spent
    ammunition. Spent ammunition would be
    separated from soil using mechanical
                                       screens or gravity-fed separation
                                       techniques, and transported to a metals
                                       refinery for recycling.  The screened soil
                                       would be treated onsite by chemical
                                       fixation, a stabilization technique that
                                       reduces the teachability of lead in soil.  The
                                       excavated areas within the dunes would be
                                       revegetated with native species of plants
                                       under the Habitat Management Plan (HMP)
                                       (COE, 1994).
                                   2.9.3
          Alternative 3 • Final
          Cleanup for Human
          Health:  Excavation and
          Placement at the OU 2
          Landfill CAMU
                                       Capital Cost:
                        $7,115.000
This alternative consists of mechanical and
hand excavation of approximately
63,000 cubic yards of soil and spent
ammunition in areas of greater than
10 percent surface coverage of spent
ammunition. Spent ammunition would be
separated from soil using mechanical
screens or gravity-fed separation
techniques, and transported to a metals
refinery for recycling. The screened soil
would be transported and placed at the
OU 2 landfill as part of the foundation
layer. The excavated areas within the dunes
would be revegetated with native species of
plants under the HMP (COE, 1994).
                                   2.10
          Summary of Alternative
          Comparison
                                   Nine criteria established by CERCLA were used
                                   to evaluate the alternatives in the detailed
                                   analysis step. The nine criteria encompass
                                   statutory requirements and include other
                                   technical, economic, and practical factors that
                                   assist in comparing the overall feasibility and
                                   acceptability of the cleanup alternatives.  The
                                   nine criteria are summarized as follows:

                                   Overall Protection of Human Health and the
                                   Environment. Addresses whether or not a
                                   remedy provides adequate protection'and
                                   describes how risks posed through each
                                   exposure route are eliminated, reduced, or
                                   controlled through treatment, engineering
                                   controls, or institutional controls.
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January 13. 1997
                                United States Department of the Army

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                                                                         Decision Summary
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.

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.

Implementability. 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. Protection of the environment is not
addressed in this Interim ROD, which considers
protection of human health. 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 action alternatives
   discussed above were evaluated on the basis of
   these criteria in the FS (HLA, 1995}; Table 1
   summarizes this evaluation.
   2.11
The Selected Remedy
   Alternative 3 is the selected alternative based
   on the assessment in the FS and as summarized
   in Table 1. 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

   •   Cost effectiveness.

   The State of California (Cal/EPA, DTSC and
   RWQCB) concurs 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 2.9.
   2.12
Statutory Determinations
   The selected remedy meets the requirements of
   Section 121 of CERCLA to:

   •   Be protective of human health

   •   Comply with ARARs

   •   Utilize permanent solutions and alternative
       treatment technologies or resource recovery
       technologies to the maximum extent
       practicable

   •   Satisfy the preference for treatment that
       reduces toxicity, mobility, and/or volume as
       a principal element

   •   Be cost effective.

   2.12.1       Protection of Human
                 Health

   The selected remedy provides the greatest
   degree of protection for human health.
   Implementation of the selected remedy
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                                                                         Decision Summary
includes removal and recycling of the source of
metals contamination, i.e., spent ammunition,
and removal and placement of soil
contaminated with metals from areas where
concentVations of lead exceed the health-based
level of concern in an engineered landfill.
2.12.2
Compliance with ARARs
The selected remedy complies 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
alternative are presented in Appendix A. In
addition to complying with ARARs, the Army
has the discretion to consider guidance and
health advisories as "to-be-considered" (TBC)
requirements. Those TBCs that the Army
selects become performance standards that
must be complied with.
2.12.3
Cost Effectiveness
The selected remedy is a cost-effective solution
for reducing risks to human health. There are
no costs associated with the no action
alternative. The estimated cost of the selected
remedy is approximately $7,115,000, which is
lower than the treatment alternative and
commensurate with the higher level of
protection of human health provided relative to
the no action alternative.

2.12.4       Utilization of Permanent
              Solutions and Alternative
              Treatment Technologies
              or Resource Recovery
              Technologies

The selected remedy uses permanent solutions,
alternative treatment technologies, and resource
recovery technologies to the maximum extent
practicable.

•  Placement of soil at the OU 2 landfill is an
   innovative, cost-effective waste
   management approach, and significantly
   minimizes 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 at the site.

2.12.5       Preference fo.r Treatment
              as a Principal Element

The selected remedy satisfies the statutory
preference for treatment as a principal element
in addressing the human health threats posed
by Site 3 to the extent possible. The principal
threat to human health identified during the RI
is posed by lead in soil.  The source of the lead
is erosion of spent ammunition deposited at the
site. The selected alternative separates and
recycles the metals in the spent ammunition,
eliminating the source of contamination to the
soil, and reduces the mobility of the metals in
soil through placement under an engineered
landfill cap In addition, the remedy separates
and recycles the metals in spent ammunition,
and reuses soil 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 of the soil at the OU 2
landfill.
                                   2.13
              Documentation of
              Significant Changes
                                   As described in the Responsiveness Summary
                                   (Section 3.0), the Proposed Plan for Site 3 was
                                   released for public comment on May 7, 1996,
                                   and a public meeting was held on
                                   May 18,1996. This Proposed Plan identified
                                   excavation, separation, and recycling of spent
                                   ammunition, and placement of lead-containing
                                   soil at the OU 2 landfill as the selected remedial
                                   response action.

                                   Comments collected during 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
                                   Site 3 Feasibility Study and Proposed Plan
                                   (HLA, 1995. 1996b).
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                            3.0 RESPONSIVENESS SUMMARY
3.1
Overview
At the time of the public review period for the
Army's Remedial Investigation/Feasibility Study
and Proposed Plan for Site 3. the Army
identified a preferred remedial alternative. The
preferred remedial alternative consisted of the
excavation, separation and recycling of spent
ammunition, and placement of lead-containing
soil at the CAMU. This remedial alternative
was selected on the basis of an evaluation of
three remedial alternatives, one of which
considered four different treatment methods.

On the basis of the written and verbal
comments received, the Army's Proposed Plan
was generally accepted by the public.
However, several citizens expressed concern
regarding the following issues:

•  The baseline Human Health Risk
   Assessment, development of a lead cleanup
   level, definition of the soil remedial unit,
   and the remedial alternatives considered.

•  The handling of ordnance and explosives
   (OE) at Site 3, as well as the physical
   hazards associated with spent ammunition
   and OE, and implementation of
   institutional controls.

•  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 ROO to address
   the OU 2 landfill's designation as a CAMU
   to receive excavated soil from Site 3.
3.2
Background on
Community Involvement
In 1991, Fort Ord was added to the Department
of Defense BRAC List. The economic impact of
Fort Ord's imminent closure has created much
community interest relative to the potential
economic reuse of portions of Fort Ord.
Specifically, Site 3 is under consideration for
reuse as a park by the California Department of
Parks and Recreation.

Focused community involvement regarding
Site 3 has most recently involved  the public
review of the Army's Remedial
Investigation/Feasibility Study and Proposed
Plan for Site 3 (HLA. 1995, 1996b). The public
comment period began May 7, 1996, and closed
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 site.

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 off the
              Army's Responses

Comments raised during the Site 3 Proposed
Plan public comment period are summarized
below. The comments received from the
comment period are categorized by relevant
topics.
                                  3.3.1
              Remedial Alternative
              Preferences
   Several interested parties were concerned
   about the following issues:

       Consideration of a wide enough range
   of alternatives.

       Discussion of the CAMU at the OU 2
   landfill under the preferred alternative, and

       How institutional controls, long-term
   monitoring, and OE removal and physical
   hazards would be handled.

   Several citizens expressed concern that
   additional remedial alternatives should
   have been considered for soil at Site 3.
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                                                                   Responsiveness Summary
    Department of the Army's Response: The
    remedial alternatives analyzed were
    selected by evaluating the universe of
    applicable technologies.  After considering
    each technology, the following remedial
    alternatives were developed:  1) a no action
    alternative [Alternative 1], 2) four treatment
    and recycling options [Alternative 2], and
    3) two disposal or placement and recycling
    options [Alternative 3].  In addition, four
    treatment options were evaluated in
    bench-scale laboratory studies, and the
    most promising option was further
    evaluated in a pilot study at Range 2 as
    recommended under the treatment
    alternative [Alternative 2].  The Army feels
    these options  represent a broad range of
    alternatives.

•   Several interested parties expressed
    concern that an additional remedial
    alternative should have been developed to
    address areas  of 1 to 10 percent surface
    coverage of spent ammunition. There were
    also questions about how estimated blood
    lead levels were calculated, and concerns
    about residual lead concentrations.

    Department of the Army's Response:  For
    Site 3, the health-based level of concern
    (HBLC) for lead in soil was calculated as
    1,860 mg/kg.  At this concentration blood-
    lead levels are not expected to exceed the
    level of concern,  and correspond to
    concentrations of lead in the areas of
    greater than 10 percent surface coverage.
    The Human Health and Ecological Risk
    Assessments recommended remediation
    only in areas containing greater than
    10 percent surface coverage of spent
    ammunition.  Thus, the soil remedial unit
    for Site 3 was defined by those areas with
    greater than 10 percent surface coverage
    and remedial  alternatives were developed
    for this remedial unit. On the basis of
    CERCLA guidance, remedial alternatives
    are developed for the remedial unit
    identified, i.e., soil with concentrations
    above HBLCs  in areas of greater than 10
    percent surface coverage of spent
    ammunition.

    Under the most conservative reuse
    scenario, no adverse health effects are
    anticipated for the receptors evaluated. A
       post remediation risk assessment evaluating
       established chemicals of potential concern
       for soil will be conducted. This assessment
       may show that the site is safe for any use
       and deed restrictions are not necessary.  If
       deed restrictions are determined to be
       necessary, the appropriate restrictions will
       be attached to the deed of this property.
       These restrictions will limit reuse and
       notify the potential owner of the'presence
       of residual contamination.

       One citizen had concerns that the random
       walk scenario was not an accurate estimate
       of how people would spend time at the site,
       because people would tend to congregate
       and spend time in one area.

       Department of the Army's Response:
       Access throughout the dunes will be
       limited to boardwalks due to the presence
       of habitat supporting sensitive species,
       including the endangered Smith's Blue
       Butterfly. Adequate public education about
       the butterfly habitat and the importance  of
       staying on boardwalks will minimize
       exposures. The random walk exposure was
       used because it is unlikely that an
       individual will spend all of their time in
       one area (of either the 1 to 10 percent or
       greater than 10 percent surface coverage
       areas) that represents less than 5 percent of
       the 780 acres of the beach ranges. In
       addition, institutional controls such as
       boardwalks and posting of signs will
       minimize exposure in these areas.

       One citizen expressed concern that the
       state has a "safety level" for lead of 1,000
       ppm (mg/kg), and the EPA has a
       preliminary remediation goal [PRGJ of 400
       mg/kg, and wondered why the cleanup
       level for Site 3 was above these values.

       Department of the Army's Response: State
       of California law states that 1,000 ppm is
       the total threshold limit concentration
       (TTLC) used for determining handling and
       disposal criteria of hazardous waste; it is
       not  a safety level for lead.  EPA has
       published a preliminary remediation goal
       (PRG) for lead of 400 mg/kg, and Cal EPA
       has published a value of 130 mg/kg, which
       are both intended to be protective under a
       residential scenario. In addition, these are
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                                                                   Responsiveness Summary
    not enforceable, site-specific values, but
    recommended guidelines, to be used when
    evaluating a site. Site-specific information
    and data can, and should, be incorporated
    into the development of a final remedial
    goal as was performed for the Human
    Health Risk assessment for Site 3.

    The PRGs cited are not nationally accepted
    standards, but are guidelines intended for
    use in preliminary evaluations of
    residential sites.  EPA and DTSC support
    the use of site-specific data and information
    in the development of final remedial goals.

•   Several citizens expressed concern that
    Alternative 3 (the disposal or placement
    and recycling option) did not discuss
    placing excavated soil in the CAMU.

    Department of the Army's Response: The
    draft final and final (August and October,
    1995) versions of the RI/FS included a
    discussion of the CAMU and were revised
    from the earlier draft version (June 1995)
    cited in the comment. The earlier draft was
    revised based on agency comments and
    ongoing discussions regarding designation
    of the CAMU.

3.3.2          Technical
               Questions/Concerns
               Regarding Remedial
               Alternatives

•   In general, several citizens expressed
    concern over how institutional controls
    would be implemented.

    Department of the Army's Response:
    Institutional controls described in the
    remedial alternatives  will be implemented
    in conjunction with land use scenarios
    dictated by the FORA Reuse Plan (FORA,
    1996} and the California State Parks  and
    Recreation Reuse Plan (CSPR. 1995).

•   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.

       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,
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                                                                   Responsiveness Summary
    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 waste.
    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
    minimize 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).
3.3.3
Costs/Funding Issues
•   Several citizens expressed concern that the
    cost estimates for remediation of the sites
    did not include costs associated with
    clearing OE or UXO or remediation of areas
    outside the remedial unit (i.e., areas of 1 to
    10 percent bullet distribution) for
    comparison purposes.

    Department of the Army's Response: OE
    and UXO at Fort Ord will be addressed
    under a separate action; therefore, costs
    were included for OE and UXO clearance in
    excavation areas only. The soil remedial
    unit and alternatives did not include the 1
    to 10 percent areas; therefore, there are no
    associated costs.
3.3.4
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.
    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 Interim 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. Since the
    Congress intended that the federal lead
    agency follow all substantive requirements
    that are more stringent than federal
    requirements, it is appropriate to include
    Public Resources Code section 21002 as an
    applicable requirement.

    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.

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 Site 3, as well as
    consolidation of soil from Area A.
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                                                                 Responsiveness Summary
    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 the following documents as
    required under CERCLA: (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.
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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 and Prevention
    (CDC). 1991. Healthy People 2000:
    National Health Promotion and Disease
    Prevention Objectives. DHHS Publication
    No. PHS 921-50212.

    Harding Lawson Associates, 1995.  Final
    Basewide Remedial Investigation/Feasibility
    Study. October.

    	. I996a. Draft Conceptual Remedial
    Design Report and Pilot Study Construction
    Summary Report. Site 3. Fort Ord,
    California. January.
       	. 1996b. U.S. Army Proposes Cleanup
       Plan to Address Human Health at Site 3
       Beach Trainfire Ranges, Fort Ord,
       California. May.

       	, 1996c. U.S. Army Proposes Cleanup
       Plan For Remedial Investigation Sites at Fort
       Ord, California. May.

       U.S. Army Corps of Engineers (COE),
       Sacramento District,  1994.
       Installation-Wide Multispecies Habitat
       Management Plan. February. Technical
       Assistance from Jones & Stokes Associates,
       Inc.
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TABLES

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                                           Table 1. Summary of Remedial Alternatives Evaluation
                                                          Site 3 Record of Decision
                                                             Fort Ord, California

Alternative
Alternative 1
No Action
Alternative 2
Excavation,
Separation,
Recycling, and
Treatment
Alternative 3
Excavation,
Separation,
Recycling, and
Placement at OU 2
Landfill
EPA Evaluation Criteria
Sbort-Tenn
Effectiveness
Not effective
Effective
SCT - 8-12 mo.
Effective
SCT • 6-8 mo.
Long-Term
Effectiveness
Not effective
Effective
Will achieve
TCLs
Effective
Will achieve
TO*
Reduction of Toxicity,
Mobility, and
Volume (T. M. V)
Through Treatment
No reduction of T. M, or
V
Soil: Reduction of T.
M.andV
Spent Ammunition:
Reduction of T and M,
no reduction of V
Soil: Reduction of M
and V, no reduction
ofT
Spent Ammunition;
Reduction of M, no
reductionofTorV
Implementablllty
Buy to
implement
Implementable
Requires some
specialized
equipment
Easy to
Implement
Compliance
wlthARARs
No
Yes
Yes
Overall
Protection of
Human Health
and the
Environment
Not protective
Protective
Protective
Regulatory
Agency and
Community
Acceptance
Ukely not
acceptable
To be
determined
To be
determined
NPV
Cost
SO
$11,480.000
$7,115,000
ARARs   Applicable of relevant and appropriate requirements
NPV     Net Present Value
SCT     Soil Cleanup Time
TCL     Target Cleanup Level
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Pag* 1 of 1

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PLATES

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         APPENDIX A

 APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS FOR
   THE SELECTED ALTERNATIVE

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                                  APPENDIX A

                                   CONTENTS



Al.O SOIL CHEMICAL-SPECIFIC ARARS	1

A2.0 LOCATION-SPECIFIC ARARS	1

A3.0 ACTION-SPECIFIC ARARS	2
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                                        APPENDIX A
            APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
                            FOR THE SELECTED ALTERNATIVE
The promulgated standards described below are
chemical-, location-, and action-specific ARARS
for the selected alternative: excavation,
separation and recycling of spent ammunition,
and placement of soil in the OU 2 landfill. The
standards described below are "applicable," or
"relevant and appropriate" for soil 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.
                                    A2.0
              LOCATION-SPECIFIC
              ARARS
A1.O
SOIL 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 3.  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-containing soil at Site 3
   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 3, 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 3 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
   3, 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.
Environmentally or historically sensitive
locations have been identified within Site 3 by
investigations performed during the RI and
Ecological Risk Assessment. Certain
endangered plant and animal species are
present at the site and the site is within a
coastal zone.  The following ARARs are
applicable to implementation of the soil remedy
at Site 3:

•   Endangered Species Act, TitlelG, United
    States Code (U.S.C.), Section 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 requires
    action to conserve endangered species and
    critical habitats upon which endangered
    species depend. The Habitat Management
    Plan (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.

    This Act protects certain migratory birds
    and their nests or eggs. The HMP for Fort
    Ord addresses these concerns 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 excavation 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.
C44877-H
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                                United States Department of the Army
                                        A1

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    These Acts require 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 3 is within this zone; therefore, the
    Ecological Risk Assessment will address
    these concerns as they relate to
    implementation of the soil remedy.
A3.0
ACTION-SPECIFIC ARARS
Action-specific requirements apply to
implementation of soil remedy activities such
as excavation, screening, and soil handling.
The following action-specific requirements are
applicable to the soil remedy at Site 3:

•   Monterey Bay Unified Air Pollution Control
    District (MBUAPCD), Regulations II and X,
    and National Primary and Secondary Air
    Quality Standards, 40 CFR Part 150
.	       Appendix A


 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 design
 would need to meet the substantive
 requirements of these regulations.  During
 excavation, screening, and spil handling
 activities, appropriate measures such as
 dust suppression would be implemented to
 meet these requirements.
C44877-H
January 13, 1997
                                United States Department of the Army
                                                                                          A2

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                     APPENDIX B




COMMUNITY RELATIONS ACTIVITIES CONDUCTED FOR SITE 3

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                                       APPENDIX B

             COMMUNITY RELATIONS ACTIVITIES CONDUCTED FOR SITE 3
The following activities have been conducted as
part of the Army's public relations and
information transfer efforts regarding
environmental restoration activities at Site 3,
Fort Ord. Presentations, briefings, and/or tours
were given to the following groups or
organizations, or at the following meetings.

Activity

1996

January 19. Tour of clean-up activities for
Congressman Sam Farr and staff

January 20. Orientation and tour for new
Restoration Advisory Board (RAB) members

March 28. RAB meeting: RI sites

April 25. RAB meeting:  RI sites

May 1. Superfund Roundtable for RAB members
and general public

May 6. Presentation to Cal. State Univ. at
Monterey Bay Environmental Chemistry class

May 8, 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 site's

    February 23. RAB meeting: RI sites

    February 24. Presentation to National
    Oceanographic and Atmospheric Association

    March 23. RAB meeting:  RI sites

    April 2 7. 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

    September 28.  RAB meeting: Site 3

   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
C44877-H
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United States Department of the Army
B1

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                                                                             Appendix B
October 28. Community Outreach Committee of      November 30. RAB meeting
the RAB public meeting in Marina
                                               1994
November 9. Presentation to League of Women
Voters                                          February 7. RAB/Technical Review Committee
                                               (TRC) meeting:  RI/FS
November 27. Seaside Community Forum with
Congressman Fair                                May 11. RAB/TRC meeting: RI/FS

                                               October 20. RAB/TRC meeting: RI/FS

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