PB95-964508
EPA/ROD/R09-95/138
July 1995
EPA Superfund
Record of Decision:
Fort Ord (No Action Plug-In ROD)
Fort Ord, CA
4/13/95
-------
No Action Plug-In Record of Decision
Fort Ord, California
February 1995
United States Department of the Army
Sacramento Corps of Engineers
-------
CONTENTS
1.0 DECLARATION 1
1.1 Site Name and Location 1
1.2 Basis and Purpose , 1
1.3 Description of the Selected Remedy 1
1.4 Declaration Statement 2
2.0 DECISION SUMMARY 3
2.1 Site Description 3
2.2 Site History 3
2.3 Enforcement and Regulatory History 3
2.4 Highlights of Community Participation 4
2.5 Scope and Role of No Action 4
2.6 Characteristics of a Typical No Action Site 4
2.7 Summary of Site Risks 5
2.7.1 Human Health Considerations 5
2.7.2 Protection of Groundwater 6
2.7.3 Ecological Considerations 6
2.8 Approval Process for No Action 6
2.9 Documentation of Significant Changes 7
3.0 RESPONSIVENESS SUMMARY 8
3.1 Overview 8
3.2 Background on Community Involvement 8
3.3 Summary of Comments Received during the Public Comment Period and
Department of the Army Responses 8
3.3.1 Summary and Response to Local Community Concerns 9
3.3.1.1 Public Comments Regarding Community Relations 9
3.3.2 Summary and Response to Written Specific Technical Questions 9
3.3.2.1 Reprint of, and Army Response to, the Letter Received from
the California Coastal Commission 9
TABLE
1 Preliminary Remediation Goals
PLATES
1 NPL Site Map
2 Site Eligibility and Implementation Process Flowchart
D34503-H United States Department of the Army li
Febniary 16. 1995
-------
No Action Plug-In Record of Doclsion
Fort Ord, California
HLA Project No. 23366 04771
This document was prepared by Harding Lawson Associates at the direction of the U.S. Army Corps
of Engineers (COE) for the sole use of the COE and the signatories of the Federal Facilities
Agreement, including the Army, the U.S. Environmental Protection Agency, the California
Environmental Protection Agency, including the Department of Toxic Substances Control (formerly,
the Toxic Substances Control Program of the Department of Health Services), and the Regional Water
Quality Control Board, Central Coast Region, the only intended beneficiaries of this work. No other
party should rely on the information contained herein without prior written consent of the COE and
Army. This report and the interpretation, conclusions, and recommendations contained within are
based on information presented in other documents that are cited in the text and listed in the
references. Therefore, this document is subject to the limitations and qualifications presented in the
referenced documents.
D34S03-H United State* Department of the Army III
February 16.1995
-------
1.0 DECLARATION
1.1
Sit* Nam* and Location
1.3
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 Rey Oaks to the south and
Marina to the north. The Southern Pacific
Railroad and Highway 1 pass through the
western portion of Fort Ord, separating the beach
front from the rest of the base. Laguna Seca
Recreation Area and Toro Regional Park border
Fort Ord to the south and southeast, respectively.
Land use east of Fort Ord is primarily
agricultural.
Description of tho Soloctod
Remedy
1.2
Basis and Purpose
This decision document presents the No Action
Plug-In Record of Decision (ROD) for selected
areas at Fort Ord, California (see Plate 1). The
plug-in ROD describes the process for identifying
a No Action site. Site specific documentation
justifying that the no action criteria has been met
will be provided subsequent to this ROD through
an Approval Process. This process is referred to
as the "plug-in" process, because the Approval
Memoranda plug into the ROD. This plug-in
ROD was prepared in accordance with
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 (USEPA) and the State of California
concur with the No Action site criteria.
A No Action site is a site where remedial action
is not necessary to protect human health and the
environment. No action (i.e., no treatment,
engineering controls, or institutional controls)
would be warranted under the following general
sets of circumstances applicable to sites at
Fort Ord:
• Where the baseline risk assessment or
screening risk evaluation concluded that
conditions at the site pose no unacceptable
risks to human health and the environment
• Where a release involved only substances
exempt from remedial action under CERCLA
Section 101 (investigation and/or remediation
may be undertaken pursuant to other state or
federal authority)
• Where a previous response action
(e.g., interim remedial action or removal
action) eliminated existing and potential risks
to human health and the environment such
that no further action is necessary.
Although the No Action sites at Fort Ord do not
require treatment or controls, groundwater
monitoring may be performed as part of basewide
monitoring activities.
D34503-H
February 16, 1995
United States Department of the Army
-------
Declaration
1.4
Declaration Statement
Because CERCLA hazardous substances will not
remain onsite above health-based levels, the
5-year review will not apply to sites that receive
no action approval.
United States Department of the Army
California Environmental Protection
Agency
ay/? £
Date
Lewis D. Walker
Deputy Assistant Secretary of the
Army (Environment, Safety and
Occupational Health)
Anthony J. Lanffls/P.ET Date
Chief of OperalHons, Office of Military Facilities
California Environmental Protection Agency
Department of Toxic Substances Control
|la Mettee-MfcCutchon
Colonel, U.sNAnny
Garrison Commander
Presidio of Monterey
Rcfee/W. Briggs" // Date
Executive Officer/
California Environmental Protection Agency
Central Coast Regional Water Quality Control
Board
G"ail YoungbodU Date
Acting BRAG Environmental Coordinator
Presidio of Monterey
U.S. Environmental Protection Agency
Anderson Dat&
irector, Federal Facilities Cleanup Office
U.S. Environmental Protection Agency,
Region IX
D34503-H
February 16,1995
United States Department of the Army
-------
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 beach
front from the rest of the base. Laguna Seca
Recreation Area and Toro Regional Park border
Fort Ord to the south and southeast, respectively.
Land use east of Fort Ord is primarily
agricultural.
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) occupied Fort Ord. Light
infantry troops are those that perform their duties
without heavy tanks, armor, or artillery. Fort Ord
was selected for closure in 1991. The majority of
the soldiers were reassigned to other Army posts
in 1993. Although Army personnel still operate
the base, no active army division is currently
stationed at Fort Ord.
The three major developed areas within Fort Ord
are the Main Garrison, the East Garrison, and
Fritzsche Army Airfield (FAAF). The remaining
undeveloped property (approximately
20,000 acres) was used for training activities.
The Main Garrison contains commercial,
residential, and light industrial facilities. It was
constructed between 1940 and the 1960s, starting
in the northwest corner of the base and
expanding southward and eastward. During the
1940s and 1950s, there was a small airfield in the
central portion of the Main Garrison. This
airfield was decommissioned when FAAF was
completed, and the airfield facilities were
redeveloped as motor pools or for other
operations. FAAF, which serves as the general
airfield for Fort Ord, is in the northern portion of
the base, adjacent to the city of Marina. FAAF
was incorporated into Fort Ord in 1960 and
expanded in 1961. The East Garrison occupies
350 acres on the northeastern edge of the base
and consists of military and industrial support
areas, recreational facilities, and recreational
open space.
Generally, any chemicals present in soil at
potential No Action sites are the result of former
routine maintenance and support activities on
Fort Ord. Such activities include: maintenance
of military vehicles at wash racks, tank storage of
chemicals such as waste oil, the use of oil/water
separators in drainage areas, and pesticide use
and storage.
2.3
Enforcement and
Regulatory History
Environmental investigations began at Fort Ord
in 1984 at 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 Bum Pit (Operable Unit 1 or OU-1).
The subsequent Remedial Investigation/
Feasibility Study (RI/FS) for OU-1 was completed
in 1988, and cleanup of soil and ground-water
began. A plan describing the cleanup process
was presented to the public in June 1987. In
1986, under RWQCB cleanup or abatement
orders 86-87, 86-317, and 88-139, further
investigations began of the landfill areas
(Operable Unit 2 or OU-2), and,the preliminary
site characterization was completed in 1988. In
1990, Fort Ord was placed on the
U.S. Environmental Protection Agency's (USEPA)
National Priorities List (NPL) primarily because
of volatile organic compounds found in
groundwater beneath OU-2, and a Federal
Facility Agreement (FFA) under CERCLA
Section 120 was signed by the Army, USEPA.
DTSC, and RWQCB. The FFA establishes
D34503-H
February 16,1995
United State* Department of the Army
-------
Decision Summary
schedules for commencing remedial
investigations and feasibility studies, and
requires completion of remedial actions as
expeditiously as possible. The basewide RI/FS
began in 1991, and Fort Ord was placed on the
Base Realignment and Closure List (BRAG). The
final Feasibility Study for OU-2 was completed
October 1,1993 and the ROD was signed in
August 1994. An Interim Action Plug-In ROD
was signed in March 1994 which allows for
excavation and treatment of shallow
contaminated soils. The Draft and Draft Final
versions of the Basewide RI/FS were completed
on August 1,1994 and December 5,1994,
respectively.
2.5
Scope and Role of No Action
2.4
Highlights of Community
Participation
On September 15,1994, the United States
Department of the Army (Army) presented the
Proposed Plan for No Action at Fort Ord to the
public for review and comment. The Proposed
Plan summarizes information on the No Action
process and other documents in the
Administrative Record for the base. These
documents are available to the public at the
following locations: Chamberlain Library,
Building 4275 North-South Road, Presidio of
Monterey Annex, California; and Seaside Branch
Library, 550 Harcourt Avenue, Seaside,
California. The entire administration record is
available at 1143 Echo Avenue, Suite F, Seaside,
California.
Comments on the Proposed Plan were accepted
during a 66-day public review and comment
period that began on September 15,1994 and
ended on November 21,1994. A public meeting
was held on September 22,1994, at the
Sherwood Hall, Santa Lucia, in Saunas,
California. At that time, the public had the
opportunity to ask representatives from the
Army, U.S. EPA, and Cal EPA questions and
express its concerns about the plan. In addition,
written comments were accepted during the
public comment period. Responses to comments
received during the public comment period are
included in the Responsiveness Summary
(Section 3.0), which is part of this No Action
Plug-In ROD.
The No Action ROD will document that any
necessary remedial actions under CERCLA have
been taken at sites or that remedial action is not
necessary for the two No Action categories
described below. Additionally, a No Action ROD
would provide a basis for deletion of the property
from the NPL. The scope of the No Action
process is to address categories of sites where
remedial action is not necessary to protect
human health and the environment, or CERCLA
does not provide the appropriate authority to
take any remedial action at the site. Plate 1
identifies 41 areas on Fort Ord where No Action
may be implemented.
In 1991, Congress mandated a 3-year completion
schedule for RI/FS documents for closing BRAC
sites such as Fort Ord (Public Law 102-190). The
impact of Fort Ord's closure on the local
economy is one reason to undertake a No Action
process in order to facilitate release of property at
Fort Ord for redevelopment. Conversion of
Fort Ord property to civilian uses is a high
priority for the local community, the agencies
involved, and the Army. To meet Fort Ord's
mission of transferring real property as soon as
possible, site identification, remedial
investigations, and cleanup at Fort Ord are being
accelerated. By completing and implementing
the No Action ROD and eliminating these sites
from the basewide RI/FS, the properties would
become available for reuse much earlier than the
previously scheduled date.
2.6
Characteristics of a Typical
No Action Site
This section describes the characteristics of a
no action site but does not identify specific sites.
Site-specific no action decisions will be made
through the approval process described in
Section 2.8.
No Action sites at Fort Ord fall under two
categories:
Category 1 Sites
Category 1 sites are already in a protective state
and pose no current or potential threat to human
health or the environment. Fort Ord contains
D34503-H
February 16, 1995
United States Department of the Army
-------
Decision Summary
areas where storage and/or release or disposal of
hazardous substances has occurred and some
level of contamination may be present; however,
in order to be included as a Category 1 site, the
level of contamination that exists at a site must
be below the levels required for protection of
human health and the environment. Examples of
Category 1 sites could include sites where a
previous response action mitigated the threat;
sites where concentrations are below basewide
background levels, or risk-based cleanup levels'
(e.g., Preliminary Remedial Goals [FRGs]
(Table 1]); and sites at which the threat no longer
exists because of natural environmental
processes.
Category 2 Sites
Category 2 sites are sites where CERCLA does not
provide the appropriate authority to take any
remedial action except to the extent that the FFA
provides for corrective action under the Resource
Conservation and Recovery Act (RCRA). These
sites would include two types (Plate 2):
• Sites that had storage and/or release of
contaminants that are excluded from the
CERCLA process. Investigation and/or
remediation may be undertaken pursuant to
other state or federal authority. For example,
leaking underground petroleum hydrocarbon
storage tanks would fall under the present
underground storage tank (UST) program at
Fort Ord and would be regulated under state
and local agencies (DTSC, RWQCB, County
of Monterey).
• Sites where no release to the environment
has occurred. An example of this type of site
would include sites where compounds, such;
as asbestos in buildings, has not been
released to the environment (outdoors). Such
sites would be handled on a site-by-site basis
in accordance with the intended reuse
scenario, and/or under other state or federal
authorities.
If a site contains both CERCLA and non-CERCLA
regulated contaminants' it could not be included
as a Category 2 site, but may be a Category 1 site
if it satisfies those requirements.
2.7
Summary of Site Risks
The primary rationale for the designation of
Category 1 sites is that they do not contain
concentrations of chemicals above PRGs and are
therefore protective of human health. In
addition, an ecological assessment is conducted
to ensure protection of the environment. For
Category 2 sites, no releases have occurred under
CERCLA authority and they are either protective
of human health and the environment or risks
associated with any non-CERCLA substances
would be addressed under separate authority.
2.7.1
Human Hoalth
Considerations
The overall screening criterion for a No Action
Site is an acceptable level of protection for
human health and the environment. This
acceptable level of protection requires that the
reasonable maximum risk of exposure for a
person to site-related chemicals results in an
estimated additional risk of developing cancer of
less than one-in-one million, and is without
appreciable risk of deleterious noncancer health
effects. This is in accordance with the National
Contingency Plan (NCP) and CERCLA guidance.
Category 1 sites would require documentation
that concentrations of contaminants at the site
are below PRGs (Table 1), as set and agreed to by
the State and Federal regulatory agencies.
Because the screening criteria for Category 2 sites
are: no release occurred, or contaminants found
are excluded from CERCLA jurisdiction, these
sites would automatically qualify for No Action
without further analysis (e.g., comparison to
PRGs).
PRGs were developed in accordance with the
procedures described in the Draft Final Technical
Memorandum, Preliminary Remediation Goals,
Fort Ord, California dated June 24, 1994. hi
general, separate PRGs were developed for
chemicals based on possible cancer and
noncancer health effects. PRGs based on cancer
risk represent chemical concentrations in soil
that might result in estimated human daily
intakes (doses) associated with an estimated
one-in-one million probability that an exposed
individual would develop cancer.
D34503-H
February 16. 1995
United States Department of the Army
-------
Decision Summary
PRGs based on noncancer health effects represent
chemical concentrations considered to result in
estimated human daily doses expected to be
without appreciable risk of adverse
noncarcinogenic effects (hazard quotient of 1 or
less). The lowest PRG for a chemical will be
used to evaluate the need for further action or
investigation at sites containing that chemical in
soil; i.e., if concentrations of chemicals at a site
are below PRGs, no action would need to be
taken to protect human health and the
environment. Chemical specific PRGs and
environmental concentration data for each site
will be used to evaluate that contributions of site
chemicals to cumulative area-related health risks
are acceptable.
The methods used to calculate PRGs generally
employed conservative assumptions consistent
with EPA and Cal/EPA risk-management policies
for sites with future unrestricted use.
Conservative EPA-developed models and EPA
default assumptions were used where
site-specific information was unavailable, and
agency-established toxicity values (reference
doses and slope factors) were used. The PRGs
were designed so that uncertainties would tend
to cause overestimation of actual exposures and
toxicity, and thus provide PRGs protective of
human health.
2.7.2
Protection of Groundwater
In addition, No Action sites will be evaluated for
potential impact to groundwater. The PRGs for
chemicals based on human health discussed
above will be evaluated to determine that State
and Federal Maximum Contaminant Levels in
groundwater will not be exceeded.
As discussed in the Technical Memorandum:
Approach to Evaluating Potential Groundwater
Quality Impacts, dated July 29,1993, organic
compounds in the soil within the unsaturated
zone will be evaluated using an USEPA-
developed partitioning mass transport model
(VLEACH). This model will use groundwater
depth and soil characteristics specific to a
preliminarily identified No Action site to estimate
potential maximum groundwater chemical
concentrations for given chemical soil
concentrations. PRGs for organic chemicals
based on human health exposures discussed
above will be evaluated using this model to
ensure that state and federal primary maximum
contaminant levels (MCLs) in groundwater will
not be exceeded. Pesticide- and
metal-contaminated soil will be assessed
qualitatively to determine potential impacts to
groundwater quality.
Concentrations of chemicals below PRGs, such as
those found at Category 1 sites, are not expected
to have an impact on groundwater quality.
2.7.3
Ecological Considerations
Preliminary Hazard Assessments for ecological
risk indicate that the majority of the
preliminarily identified No Action sites do not
pose ecological risks because the areas are
already disturbed (paved). The results of the
ecological risk assessment will be included in the
Approval Memorandum for each site (Plate 2) to
verify that these sites do not pose a risk to the
environment.
2.8
Approval Process for No
Action
Following this ROD, an Approval Memorandum
will be prepared for each proposed No Action
site to demonstrate that the area meets
appropriate requirements and conditions of
Category 1 or 2. Each Approval Memorandum
will be made available by the Army to the
public, local and county agencies, the Restoration
Advisory Board, U.S. EPA, and the California
Environmental Protection Agency, including
DTSC and RWQCB for review.
For Category 1 sites, the Approval Memorandum
will include:
1) A description of the site and its geologic
conditions with reference to appropriate
completed site characterization, interim
action confirmation, and removal action
reports.
2) A map of the site detailing location and any
posted chemical or other pertinent available
data (e.g., groundwater chemistry). .
3) A table of site-related chemical
concentrations and their respective PRGs..
D34503-H
February 16.1995
United State* Department of the Army
6
-------
Decision Summary
4) An evaluation of potential impacts to
groundwater.
5) Results of the ecological risk assessment.
For Category 2 sites, the Approval Memorandum
will include:
1) A description of site conditions
2) Data related to investigation and/or remedial
actions, if applicable (e.g., asbestos surveys,
UST removal records).
The Approval Memorandum will serve as a
decision document for the transfer of property,
and will be prepared prior to the Base Wide
Record of Decision. Following a 30-day public
review and comment period, the Army will
forward the Approval Memorandum, public
comments, and response to comments to the
agencies for final review and approval. Agency
review of the Approval Memorandum will be
completed within 10 working days of its
submittal unless extended pursuant to the FFA.
Agency approvals will be confirmed in
subsequent written correspondence from the
agencies. Agency denial of a No Action Approval
Memorandum may be disputed pursuant to
Section 12 (Dispute Resolution) of the FFA.
When the Army receives approval of a No Action
site determination, a notice will be placed in a
major local newspaper. Completed and planned
No Action site activities will also be described in
newsletters, prepared for local residents by the
Presidio of Monterey.
2.9
Documentation of
Significant Changes
As described in the Responsiveness Summary,
the No Action Proposed Plan was released for
public comment on September 15,1994, and a
public meeting was held on September 22,1994.
This Proposed Plan identified No Action as the
selected remedy for two categories of sites at
Fort Ord. At the request of the public, the
comment period was extended to November 21,
1994. Comments collected over the 66-day
public review period between September 15,
1994 and November 21,1994 resulted in a
modification to the Approval Memorandum
procedures outlined in the Proposed Plan. The
approval process was amended to allow for a
30-day public review and comment period on
each Approval Memorandum. No new category
of sites beyond those described in the ROD and
Proposed Plan have beer identified at this time.
D34S03-H
February 16.1995
United State* Department of the Army
-------
3.0 RESPONSIVENESS SUMMARY
3.1
Overview
This Responsiveness Summary provides a
summary of the public comments and concerns
regarding the No Action Proposed Plan at
Fort Ord, California.
On the basis of the verbal and written comments
received, the Army's Proposed Plan for No Action
was generally accepted by the public. However,
some citizens and/or organizations expressed
concern regarding the level of public involvement
in the review and approval process for the No
Action sites.
3.2
Background on Community
Involvement
The Army has implemented a progressive public
relations and involvement program for
environmental activities at Fort Ord. The
Advance, published by the Army, is a newsletter,
sent to the public, that highlights the status of
ongoing and planned remedial activities at
Fort Ord. The Army also conducts monthly
Restoration Advisory Board meetings to involve
the public in decisions made regarding remedial
actions. In addition, a toll-free 800 number is
available for concerned citizens to comment and
receive answers regarding the environmental
restoration and transfer of Fort Ord property.
The Army held a public comment period on the
No Action Proposed Plan from September 15,
1994 through November 21,1994. Over
700 copies of the Proposed Plan were mailed for
public review and comment to interested parties
and were placed in the Chamberlain Library,
Building 4275, North-South Road, Presidio of
Monterey Annex, California and Seaside Branch
Library, 550 Harcourt Avenue, Seaside,
California. This Proposed Plan also invited
readers to a public meeting to voice their
concerns.
The September 22,1994 public meeting was held
to discuss the screening and approval process for
the No Action sites.
No comments were received from the public
regarding the proposed No Action process prior
to the publication of the Proposed Plan and the
start of the comment period. Comments received
during the comment period are addressed below.
3.3 Summary of Comments
Received during the Public
Comment Period and
Department of the Army
Responses
The public comment period on the No Action
Proposed Plan was held from September 15,1994
to October 15,1994. A thirty-six day extension
of this comment period, to November 21,1994,
was granted to the public at their request.
Concerns from the general public on the
proposed No Action process were raised at the
Public Meeting (held on September 22, 1994)
regarding the level of public involvement in the
development and approval of the No Action sites.
These questions and comments were addressed
during the public meeting.
Four written letters were received from the
general public during the public comment
period. One written letter from California
Coastal Commission (CCC) regarding specific
technical questions was received during the
public comment period. The letter from the CCC
expressed concern with the identification of No
Action sites in the coastal zone, the criteria for
identifying No Action sites and the review and
comment period for a No Action Approval
memorandum.
Comments from the local community that were
not sufficiently addressed during the public
meeting are summarized and addressed according
to their topics in the following sections of this
document. Response to the specific technical
issues raised by the state agencies is also
presented.
D34503-H
February 16,1995
United States Department of the Army
8
-------
Responsiveness Summary
3.3.1
Summary and Response to
Local Community Concerns
Comments from the local community were voiced
at the Public Meeting, and are summarized and
addressed below. Four written comments were
received from the local community during the
public comment period.
3.3.1.1 Public Comments Regarding
Community Relations
Comment: The public meetings aren't adequately
advertised to the general public.
Anny Response: The public meeting was
advertised in the Proposed Plan and in the
Monterey Herald on September 16,17, and 18th
before the scheduled meeting date. -In addition,
the public meeting was advertised in the
Califomian on September 16,17, and 19th.
Comment: The meetings should be held closer to
Fort Ord instead of in Salinas.
Response: In the past, public meetings related to
the cleanup at Fort Ord have been held in
Monterey. At the request of the Restoration
Advisory Board and the regulatory agencies to
involve all potential areas that have an interest in
the cleanup at Fort Ord, the No Action public
meeting was held in Salinas, which is the county
seat lor Monterey County.
3.O2
Summary and Response to
Written Specific Technical
Questions
One written comment letter was received during
the Public Comment period from the California
Coastal Commission concerning the identification
of No Action sites in the coastal zone, the criteria
for identifying No Action sites and the review
and comment period for a No Action Approval
memorandum.
3.3.2.1 Reprint of, and Army
Response to, the Letter
Received from the California
Coastal Commission
Staff of the California Coastal Commission has
reviewed the Superfund Proposed Plan for
preliminarily identified No Action (NOFA) sites,
and offers the following comments.
NOFA Sites In the Coastal Zone
As expressed in previous comment letters dated
May 13,1994, July 7,1994, and October 28,
1994, Commission staff has many concerns
regarding the Army's evaluation of hazardous
waste sites in the coastal zone and their impacts
on coastal resources. We are alarmed at the
proposed plan's preliminary identification of the
Beach Stormwater Outfalls (Site 4) and the Ord
Village Sewage Treatment Plant (Site 1) as sites
which require no further action.
At the September 22,1994 public hearing
regarding the NOFA proposed plan, Commission
staff expressed concerns regarding the
preliminary identification of the storm drains
(Site 4) as a NOFA site. In response, the Army
clarified that Site 4 was no longer being
considered as a NOFA site, and that remedial
action would be undertaken. Written
clarification of the current status of Site 4 should
be provided.
Commission staff remain concerned that
inadequate investigations have been undertaken
at Site 1 in order to quantify and evaluate
contamination which may adversely impact
human health and environmental resources
(please refer to our comments on the draft
Remedial Investigation/Feasibility Study dated
October 28,1994). More thorough investigations
and analyses should be provided prior to
classifying this coastal zone site as requiring No
Further Action.
NOFA Criteria
The NOFA Proposed Plan describes NOFA sites
as sites where remedial action is not necessary to
protect human health or the environment
(Category 1), or where CERCLA does not provide
the appropriate authority to take remedial action
(Category 2). In order to qualify as a Category 1
site, the proposed plan states: "the level of
contamination that exists at a site must be below
the level required for protection of human health
(e.g., Preliminary Remediation Goals [PRGs]) and
the environment" (page 2).
D34S03-H
February 16,1995
United States Department of the Army
-------
Responsiveness Summary
Commission staff is concerned that the criteria
for qualifying as a Category 1 NOFA site has not
been adequately identified. The PRGs listed in
Figure 3 of the Proposed Plan may not be
adequate to identify potential threats to human
health, due to the fact that a PRG has not been
identified for contaminants such as fecal coliform
bacteria, total chromium, total polycyclic
aromatic hydrocarbons (PAHs), 4,4'-DDD,
e.e'-DDE, and polychlorinated biphenyls (PCBs).
The NOFA process should include remediation
goals for all chemicals of potential concern
detected at each site and provide comparisons of
detected levels with remediation goals which are
protective of environmental resources as well as
human health. As indicated in our comment
letter of October 28,1994, many of the PRGs
exceed the Probable Effects Levels (PELs) for
sediment impacts on coastal and marine
resources (in some cases by 2 orders of
magnitude), and therefore do not provide an
acceptable basis for evaluating potential sediment
impacts on coastal and marine resources.
NOFA Process
The proposed plan states: "An Approval
Memorandum will be prepared for each proposed
No Action site to demonstrate that the area meets
appropriate requirements and conditions. Each
Approval Memorandum will be submitted by the
Army to the U.S. EPA, and the California
Environmental Protection Agency, including
DTSC and RWQCB for review and
approval... Agency review will be completed
within 10 working days of its submittal" (page 6).
Commission staff is concerned that the proposed
process does not incorporate an acceptable level
of public participation, hi addition to the
governmental agencies involved in the disposal
and reuse of Fort Ord, members of the public and
their representatives at the Restoration Advisory
Board (RAB) should have the opportunity to
review and comment on a draft Approval
Memorandum for each NOFA site. The Army
should formally respond to submitted comments
in a final Approval Memorandum for each NOFA
site. The proposed review period of 10 days is
much too short to allow for thorough public
review, and a minimum 30 day comment period
should be provided.
La addition, the proposed plan states: "When the
Army receives approval of a No Action site
determination, a notice will be placed in a major
local newspaper" (page 6). In order to allow for
public input into the decision making process,
notice that a site is being considered for No
Further Action should be paced in more than one
major local newspaper prior to the final decision.
In summary, Commission staff has concerns
regarding the preliminary identification of coastal
zone Site 1 as requiring No Further Action, and
request written clarification regarding the status
of Site 4. Commission staff is also concerned
that the criteria for qualifying as a Category 1
NOFA site identified by the proposed plan does
not adequately protect human health and the
environment, as Preliminary Remediation Goals
are incomplete and do not adequately protect
coastal zone resources. Furthermore,
Commission staff believe that the NOFA
proposed plan should be revised in a manner
which will maximize public participation and
ensure that public concerns are adequately
addressed.
Army Response to Comments from the
California Coastal Commission
The Army has responded to each of the CCC
comment letters with additional information and
clarification regarding the site characterization of
areas within the Coastal zone. The Army would
like to reiterate that each site considered for No
Action under CERCLA will be evaluated during
the approval memorandum process. If a site is
approved for no action under CERCLA, it does
not preclude the implementation of other actions
that may be required under federal, state, and
local regulations.
At the public meeting on September 22,1994,
the Army indicated that the evaluation of Site 4
(beach stormwater outfalls) is being performed
under the basewide stormwater assessment. The
results of the basevnde evaluation will determine
if any remedial action at the outfalls will be
required. However, it does not indicate that
remedial action will be undertaken as stated by
CCC.
D34503-H
February 16, 1995
United States Department of the Army 10
-------
Responsiveness Summary
The Army has stated in the Proposed Plan that
the overall screening criterion for a No Action
site is an acceptable level of protection for
human health and the environment. The
preliminary remediation goals (PRGs) were
developed on a chemical specific basis for cancer
and non-cancer health effects. All chemicals
detected at a site will be screened against a
chemical specific PRG. The Proposed Plan states
in the footnote to Figure 2 that PRGs not listed
will be established according to the approved
procedures as described in the PRG Technical
Memorandum dated June 15,1993. The CCC
comment letter of October 28,1994 was
providing comment on the Draft Basewide RI/FS
report and not the No Action Proposed Plan.
However, the Army again emphasizes that an
ecological risk evaluation will use appropriate
screening criteria (such as Probable Effects
Levels) where applicable, and be performed for
each No Action site.
The Army has encouraged public involvement
and implemented several progressive public
relations programs for environmental activities at
Fort Ord. To that end, the Army will modify the
approval memorandum process for No Action
sites to provide the public with an opportunity
for review and comment on the each Approval
Memorandum.
The modified memorandum process will consist
of the following:
For each No Action site, the Army will submit an
Approval Memorandum for a 30 day public
review and comment period. Following public
review and comment, the final Approval
Memorandum, public comments, if any, and
response to public comments will be submitted
to the USEPA and the California Environmental
Protection Agency, including DTSC and RWQCB.
Agency review of the Approval Memorandum
will be completed within 10 working days of
submittal unless extended pursuant to the FFA.
Agency approvals will be confirmed in
subsequent written correspondence from the
agencies. Notice of a No Action site
determination will be placed in a major local
newspaper.
D34503-H
February 16,1995
United States Department of the Army 11
-------
TABLE
-------
Table 1. Preliminary Remediation Goals
No Action Record of Decision
Fort Ord, California
Chemical
Lowest
PRG*
Based on Noncancer Health Effects
Child
Resident
Adult
Resident
Construction
Worker
Based on Carcinogenesis
Adult
Resident
Construction
Worker
Acenaphthene
Acetone
Aldrin
Anthracene
Antimony
Arsenic
Barium
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzofk)fluoranthene
Benzo(ghi)perylene
Beryllium
Bis(2-ethylhexyl)phthalate
Bromoform
Butylbenzylphthalate
Cadmium
Carbon disulfide
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloromethane
Chromium m
Chromium VI
Chrysene
Cobalt
Copper
4,4'-DDD
4.4'-DDE
4,4'-DDT
Dibromochloromethane
Di-n-butylphthalate
1,3-Dichlorobenzene
1,2-Dichloroethane
Dieldrin
Diethylphthalate
Endosulfan n (beta)
Endosulfan sulfate
Ethylbenzene
Fluoranthene
Fluorene
gamma-BHC (Lindane)
Heptachlor
Heptachlor epoxide
Indeno(l,2.3-cd)pyrene
Lead (a)
Mercury
Methylene chloride
Methyl ethyl ketone
2-Methylnapthalene
4-Methyl-2-pentanone (MBBK)
960
220
0.011
3300
27
0.87
1000
0.15
0.015
0.15
1.5
640
0.39
13
7.6
3200
8.1
0.96
0.025
0.14
12
0.12
67000
0.23
15
2000
2,500
0.74
0.53 .
0.53
0.13
1600
330
0.074
0.011
13000
96
96
830
640
640
0.14
0.031
0.014
0.15
240
20
0.90
620
640
74
960
220
0.48
3300
27
20
1,000
NA
NA
NA
NA
640
340
320
63
3200
34
0.96
29
0.97
12
NA
67000
7.2
NA
3700
2.500
NA
NA
8.0
22
1600
330
NA
0.80
13000
96
96
830
640
640
4.8
8.0
0.21
NA
240
20
260
620
640
74
4,600
900
2.3
15000
290
220
4,700
NA
NA
NA
NA
3100
3.700
1.500
260
15000
370
3.9
190
4.6
50
NA
720000
30
NA
20000
27,000
NA
NA
38
90
7700
1800
NA
3.8
61000
460
460
3,700
3100
3.100
23
38
1.0
NA
3.900
210
1100
2.900
3.100
400
31.000
8,200
1.6
110000
57
44
4,100
NA
NA
NA
NA
2100
730
1,000
2400
100000
73
3.7
750
3.2
470
NA
/a/
38
NA
2000
5,300
NA
NA
26
840
52000
1200
NA
2.6
420000
310
310
3,900
21000
21,000
160
26
0.68
NA
460
41
950
3.300
2.100
2800
NA
NA
0.011
NA
NA
0.87
NA
0.15
0.015
0.15
1.5
NA
0.39
13
7.6
.NA
8.1
NA
0.025
0.14
NA
0.12
NA
0.23
15
NA
NA
0.74
0.53
0.53
0.13
NA
NA
0.074
0.011
NA
NA
NA
NA
NA
NA
0.14
0.031
0.014
0.15
NA
NA
0.90
NA
NA
NA
NA
NA
2.6
NA
NA
60
NA
37
3.7
37
370
NA
28
3.200
2,300
NA
380
NA
8.6
34
NA
40
NA
11
3700
NA
NA
190
130
130
43
NA
NA
26
2.8
"• NA
NA
NA
NA
NA
NA
34
7.8
3.4
37
NA
NA
310
NA
NA
NA
D34S03-H
February 16,1995
Harding Lawson Associates
1 of 2
-------
Table 1. Preliminary Remediation Goals
No Action Record of Decision
Fort Ord, California
Chemical
Lowest
PRG*
Based on Noncancer Health Effects
Child
Resident
Adult
Resident
Construction
Worker
Based on Carcinogenesis
Adult
Resident
Construction
' Worker
Naphthalene 640 640 3.100 2.1QO NA NA
Nickel 130 1,400 15,000 2.900 130 6.300
PCBs 0.02 NA NA NA 0.02 5.8
Pentachlorophenol 1.5 480 2300 1600 1.5 370
Petroleum Hydrocarbons (b) 500 (c) (c) (c) 500 120,000
Phenanthrene 640 640 3.100 2.100 NA NA
Pyrene 480 480 2.300 16.000 NA NA
Selenium 340 340 3.600 710 NA NA
Silver 340 340 3.600 710 NA NA
2.3.7.8-TCDD 1.20E-06 NA NA NA 1.20E-06 3.00E-04
1,1,2,2-Tetrachloroethane 0.28 NA NA NA 0.28 68
Tetrachloroethylene 0.16 410 2.700 11,000 0.16 54
Thallium (as Thallic oxide) 4.7 : 4.7 50 100 NA NA
Toluene 190 190 770 3.700 NA NA
1.2,4-Trichlorobenzene 49 49 210 710 NA NA
1.1.1-Trichloroethane 200 200 1100 7600 NA NA
Trichloroethene 1.1 NA NA NA 1.1 270
Vanadium 470 470 5,000 1,000 NA NA
Xylenes 130 130 520 500 NA NA
Zinc 20,000 20.000 210.000 42,000 NA NA
* All PRGs are in milligrams per kilogram, and are taken from the: Draft Final Technical Memorandum. Preliminary
Remediation Goals, Fort Ord, California. Dated June 24,1994. Prepared by HLA for the Sacramento COE. These PRGs
were developed according to procedures described in: Risk Assessment Guidelines for Supeifund, Volumes 1 and 2.
Prepared by the Office of Emergency and Remedial Response, EPA documents EPA/540/1-89/006 and EPA/540/1-89/001
(a) Draft Final Basewide Background Soils Investigation. Dated March 15,1993
Prepared by HLA for the Sacramento COE.
(b) This PRG is based on maximum concentrations of individual carcinogenic and non-carcinogenic constituents in used
motor oil and was developed for use at petroleum hydrocarbon sites where SOC analyses were not available.
(c) Calculated value exceeds 100 percent of soil, indicating noncancer health effects would not be expected at any soil
concentration.
PRG = Preliminary Remediation Goal.
mg/kg = Milligrams per kilogram
NA = Not available.
D34503-H
February 16. 1995
Harding Lawson Associates
2 of 2
-------
PLATES
-------
EXPLANATION
Operable Units
OU-1 FORMER FHEORU.AREA
OU-J FORTORDLAMOFILS
I OHO VtLAOE SEWAGE TREATMENT PLANT
MAM GARRISON SEWAGE TREATMENT PLANT
BEACH nRMQRANOE
BEACH STORUWATER QUIT ALLS MCORPOHATED
WTO BASEWDE SEWER PROGRAM
RANGE MA (EXPLOSIVE ORDNANCE OtSPOSAL)
RANGE »(ABANDONED CAR OUW|
fWNO£S40»«l (FKEOEMOAREA)
RANGE «• (UOLOTOV COCKTAIL RANGE)
RANGE Jt (FLAMED FUEL EXMBTflOM)
HRE ORU BURN PIT
II AAFESFUELMQSTATIOH
13 OOL AUTOMOTIVE YARD. CANMBAUZATION
YARD. LOWER MEADOW AREA
It RAILROAD RIGHT-OF-WAY
14 W7TM MAMTENAHCE FAOUTY
15 DnECTORATEOFENOMEERWOANO
MOUSMO(DEH)YARD
1* CnLMAHT£MAHCEtM».PETESPONOAREA
17 1400 BLOCK MOTORPOOL
It . MOOBLOCK MOTORPOOL
H 2200 BLOCK FAOUTt
20 8OUTH PARADE GROUNO.m>0 BLOCK
MOTORPOOL, 51»TM MOTOflPOOl
«l 4400MSOO BLOCKS MOTORPOOL FAST)
a 4400MMO BLOCKS UOTORPOOt. (NEST)
a nooeiocKMoronpooL
» OLDDEHYARD
M FORMER OnnSTTE
» SEWAGE PUMP STATKJKS«LDOSS«71«I«3
37 ARMT RESERVE MOTORPOOL
» BARRACKS AND MAM GARRISON AREA
» ORMO
M ORnERTRAMMGAREA
II FORMER DUMP SITE
12 EAST OAHnOOH SEWAGE TREATMENT PLANT
M OOLF COURSE
M FnmSCMEAAFFUELJNO FACILITY
M ARCRAFTCANMBALIZATIOHYARD
M FHTZSCMEAAF SEWAGE TREATMENT PLANT
•7 TRAJLEB PARK MAMTENAHCE SHOP
M AAFES DRY CLEANERS
» MLANDRANGESIMWCTAREA
»A EAST GARRISOH RANGES
MB MTER^ARnSOHTRAIKMSAREA
<0 FnrrZSCHEAAFOEFUELMG AREAS
41 CRESCENT BLUFF BURN PITS
NPL SIUM
No Action Record ol Dedstoo
Fort Ord. Calttomia
DRAWN
LFDC
PROJECT NUMBER
2336604771
APPROVED
DATE
10/93
REVISED DATE
12/94
-------
41277
SITE ELIGIBILITY
IMPLEMENTATION PROCESS
Review Site Characterization or
Remedial Investigation reports to
Identify potential No Action sites
Are
chemical
concentrations at the •
site below PRGs because:
(1) no release occured, or
(2) a previous response action
mitigated the threat?
Has a release of petroleum
occured that is exempt
from remedial action
under CERCLA?
Has a release
occcured from buildings
(e.g., asbestos, lead
based paints)?
Do results
of the ecological
assessment indicate
a threat to the
environment?
Reevaluate
site under Rl/FS
process
Abbreviations
CERCLA Comprehensive Environmental Response,
Compensation and Liability Act
PRGs Preliminary Remediation Goals
Rl/FS Remedial Investigation/Feasibility Study
ROD ' Record of Decision
Prepare a Proposed Plan that
identifies the No Action process
and specific categories of sites
•legible for No Action (e.g.. site
characterization chemical data
below PRGs)
i.
Distribute for public review a No
Action Proposed Plan which
summarizes the No Action process
Collect public comments on
the Proposed Plan during a
public meeting and a thirty day
review period
Outline the final agency-approved
action in a No Action ROD
Submit Approval Memorandum and
supporting documentation (e.g.,
. chemical data below PRGs or
asbestos surveys) to the public
and the appropriate regulatory
agencies for each site where
No Action is suitable
Forward memorandum, public
comment, and response to
comment to agencies for
final approval
Receive agency approval of the No
Action Memorandum
Provide Public Notification of
the Proposed No Action In a
major local newspaper
021395LFDL
Harding Lawson Associates
Engineering and
Environmental Services
Site Eligibility and Implementation
Process Flow Chart
No Record of Decision
Fort Ord, California
DRAWN
LFDc
JOB NUMBER
23366 04771
APPROVED
DATE
1/95
FlGUF
2
REVISED DATE
------- |