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.
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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.
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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
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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.
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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.
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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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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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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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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.
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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.
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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
January 13. 1997
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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