PB95-963924
EPA/ROD/R03-95/216
June 1996
EPA Superfund
Record of Decision:
Aberdeen Proving Ground (Edgewood),
Operable Unit 1, Edgewood, MD
9/8/1995
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FINAL
RECORD OF DECISION
INTERIM REMEDIAL ACTION
BUILDING 103 DUMP, OPERABLE UNIT 1
EDGEWOOD .AREA-ABERDEEN PROVING GROUND, MARYLAND
FEBRUARY 28, 1995
Distribution Restriction Statement:
APPROVED FOR PUBLIC RELEASE; DISTRIBUTION IS UNLIMITED A 0689-C-2
In accordance with Army Regulation 200-2. this document is intended by the Army to comply with
the National Environmental Policy Act of 1969 CNEPA)
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February 28, 1995
RECORD OF DECISION
for
INTERIM REMEDIAL ACTION
> *
BUILDING 103 DUMP
OPERABLE UNIT 1
FEBRUARY 28, 1995
U.S. ARMY, EDGEWOOD AREA-ABERDEEN PROVING GROUND, MARYLAND
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February 28, 1995
TABLE OF CONTENTS
Paragraph Page
DECLARATION OF THE RECORD OF DECISION 1
1.1 SITE NAME AND LOCATION 1
1.2 STATEMENT OF BASIS AND PURPOSE 1
1.3 ASSESSMENT OF THE SITE : . . . 1
1.4 DESCRIPTION OF THE INTERIM REMEDIAL ACTION 1
1.5 STATUTORY DETERMINATIONS 2
DECISION SUMMARY 4
2.1 SITE NAME, LOCATION, AND DESCRIPTION 4
2.1.1 General , 4
2.1.2 Building 103 Dump Geology 7
2.1.3 Building 103 Dump Surface Water 7
2.1.4 Building 103 Dump Ground Water 8
2.1.5 Building 103 Dump Climatology 8
2.1.6 Building 103 Dump Land Use 9
2.1.7 Building 103 Dump Flora and Fauna 9
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 10
2.2.1 History of Site Activities 10
2.2.2 History of Investigations/Remedial Actions 10
2.2.3 Enforcement Activities 12
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 12
2.4 SCOPE AND ROLE OF OPERABLE UNIT 13
2.5 SUMMARY OF SITE CHARACTERISTICS 13
2.5.1 Building 103 Dump Soil . 13
2.5.2 Building 103 Dump Ground Water , 13
2.5.3 Building 103 Dump Surface Water 14
2.5.4 Building 103 Dump Air 16
2.6 SUMMARY OF SITE RISKS 16
2.7 DESCRIPTION OF ALTERNATIVES 19
2.7.1 General . . : 19
2.7.2 Statutory Preferences 21
2.7.3 Description and Alternatives 23
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 28
2.8.1 Comparative Analysis of Alternatives 28
2.9 DESCRIPTION OF THE SELECTED REMEDY 35
2.10 STATUTORY DETERMINATIONS 37
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES 43
RESPONSIVENESS SUMMARY 44
3.1 OVERVIEW 44
3.2 BACKGROUND ON COMMUNITY INVOLVEMENT 45
3.3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES 46
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TABLE OF CONTENTS (CONT.)
Final
February 28, 1995
Page
3.4 PANEL OF EXPERTS 63
3.5 SELECTED NEWSPAPER NOTICES ANNOUNCING DATES OF PUBLIC
COMMENT AND LOCATION AND TIME OF PUBLIC MEETING 63
FIGURES
Figure Page
Figure 1 Aberdeen Proving Ground Regional Location Map 5
Figure 2 Location of Building 103 Dump, Edgewood Area-Aberdeen Proving Ground .... 6
Figure 3 Typical Cross Section for Alternative 6 (RCRA Cap Using Sodium Bentonite
Geocomposite Mat and Synthetic Membrane) 36
!
TABLES
Table Page
Table 1 Inorganic Constituents with Concentrations that Exceed Federal Drinking-
Water Maximum Contaminant Levels 14
Table 2 Organic Compounds Sampled in Wells 23A and 23B 15
Table 3 Comparative Cost of Alternatives 34
Table 4 Capital Cost Estimate for Alternative 6 38
Table 5 Review of Potential Action-Specific and Locational ARARs for the Building
103 Dump Selected Remedy 40
APPENDICES
Appendix
APPENDIX A. ANNOUNCEMENT OF PUBLIC MEETING A-l
APPENDIX B. TRANSCRIPT OF PUBLIC MEETING B-l
APPENDIX C. REFERENCES C-l
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February 28, 1995
RECORD OF DECISION
Building 103 Dump, Operable Unit 1
Interim Remedial Action
U.S. Army Edgewood Area-Aberdeen Proving Ground, Maryland
February 28, 1995
SECTION 1
DECLARATION OF THE RECORD OF DECISION
1.1 SITE NAME AND LOCATION
Building 103 Dump - Operable Unit 1, U.S. Army, Edgewood Area-Aberdeen Proving Ground (APG-
EA), Maryland
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action for the Building 103 dump.
The selected interim remedial action was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980, as amended by the Superfund
Amendments and Reauthorization Act of 1986, and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the Administrative
Record for this site.
The State of Maryland Department of the Environment concurs that this interim remedial action
is protective of both human health and the environment.
13 ASSESSMENT OF THE SITE
Actual or threatened release of hazardous substances from the Building 103 dump, if not
addressed by implementing the interim response action selected in this Record of Decision (ROD), may
present an imminent and substantial endangerment to public health and welfare, and to the environment.
1.4 DESCRIPTION OF THE INTERIM REMEDIAL ACTION
This interim remedial action involves capping the Building 103 dump to 1) to prevent the
infiltration of water into the dump with subsequent migration of contaminants to ground water and, 2)
to prevent animal intrusion into the dump. The major components of this selected interim remedial action
include constructing a multilayered cap-and-cover system over the Building 103 dump in accordance with
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February 28, 1995
Resource Conservation and Recovery Act (RCRA) requirements for hazardous waste landfill closure using
a geosynthetic membrane and a sodium bentonite geocomposite mat. The design features of this cap and
cover system will include: 1) an earthen material backfill cover (to include contaminated soil from the
Building 503 Soils Operable Unit and non-hazardous drill cuttings from other APG-EA study areas) over
the existing cover; 2) 2 feet of compacted semi-pervious earthen material over the backfill cover; 3) a
sodium bentonite mat over the earthen material; 4) a geosynthetic membrane over the sodium bentonite
mat; 5) a drainage layer over the geosynthetic membrane; 6) a cobble/gravel animal protective barrier
and, 7) a final earthen vegetative cover. Surface water controls will be constructed to accommodate
seasonal precipitation. A gas collection/filtration system will be constructed to filter any emissions from
the dump.
The Army has organized the remedial effort at the Building 103 dump into two operable units:
Operable Unit 1 - the source of contamination, and Operable Unit 2 - ground-water contamination. This
interim remedial action does not address treatment of the contaminated ground water associated with the
Building 103 dump. Groundwater issues are the subject of an additional-investigation by the Army to
more completely determine the nature and overall extent of groundwater contamination at APG-EA. A
separate groundwater operable unit will address remediation of contaminated ground water beneath the
Building 103 dump.
1.5 STATUTORY DETERMINATIONS
The selected interim remedy is protective of human health and the environment in the short term
and is adequate protection until a final ROD is signed for the Canal Creek area, and is cost effective.
It complies with Federal and State of Maryland requirements that are legally applicable, or relevant and
appropriate to the interim remedial action. This interim remedy utilizes permanent solutions to the
maximum extent practicable for this operable unit. However, because excavation of the Building 103
dump with subsequent treatment of the contents was found to be hazardous and not practicable, this
interim remedy does not satisfy statutory preference for removal and treatment as a principal element of
the remedy. The size of the dump, hazards associated with excavation of the dump, and excessive costs
associated with the excavation alternative preclude a remedy in which contaminants can be excavated and
treated effectively. The statutory preference will be addressed by the final response action.
The selected remedy is consistent with the Superfund Program policy regarding waste containment
at landfills (40 CFR § 300.430), where removal and treatment is impracticable. The Building 103 dump
will be further investigated as part of the on-going Canal Creek Remedial Investigation/Feasibility Study
(RI/FS). This investigation will determine if further actions are necessary to fully address the Building
103 dump. If further remediation is required, the selected remedy for Operable Unit 1 of the Building
103 dump will be consistent with those actions. If no further remediation is required, then this action
may be final.
Because the selected interim remedy will result in hazardous substances remaining on-site, a
review under Section 121(c) of CERCLA, 42 U.S.C. §9621(c), will be conducted within five years to
ensure the interim remedy continues to provide adequate protection of human health and the environment.
That review will include consideration of the following elements:
Continued integrity of the cap-and-cover system
Contaminant concentrations in ground water beneath the Building 103 dump
Generation of gas/vapors at the dump
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LEAD AND SUPPORT AGENCY ACCEPTANCE
OF THE RECORD OF DECISION
EDGEWOOD AREA-ABERDEEN PROVING GROUND, MARYLAND
FOR INTERIM REMEDIAL ACTION AT
BUILDING 103 DUMP OPERABLE UNIT 1
Signature sheet for the foregoing Record of Decision for the interim remedial action at the
Building. 103 dump at the Edgewood Area-Aberdeen Proving Ground (APG-EA) between the U.S.
Army and the United States Environmental Protection Agency, Region IE, with concurrence by the
Maryland Department of the Environment.
Date
Army
tichard W. Trage;
Major General,
Commanding
Aberdeen Proving Ground
TuLy9
Date
Raymond J Fatz '
Acting Deputy Assistant Secretary
of the Army (Environment, Safety
and Occupational Health)
OASA a, L&E)
D
omas C. Voltaggio
Director, Hazardous Waste Management Division
U.S. Environmental Protection Agency
Region ffl
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RECORD OF DECISION
INTERIM REMEDIAL ACTION
BUILDING 103 DUMP, OPERABLE UNIT 1
EDGEWOOD AREA-ABERDEEN PROVING GROUND, MARYLAND
SECTION 2
DECISION SUMMARY
This Decision Summary provides an overview of the problems posed by conditions at the Building
103 dump, Operable Unit 1, the remedial alternatives, and the analysis of those options. Following that,
it explains the rationale for the remedy selection and describes how the selected interim remedial action
satisfies statutory requirements.
2.1 SITE NAME, LOCATION, AND DESCRIPTION
2.1.1 General
As shown in Figure 1, Aberdeen Proving Ground is located along the Chesapeake Bay in Harford
County, Maryland, about 15 miles northeast of Baltimore. APG is divided into two main areas separated
by the Bush River. The area north of the Bush River is referred to as the Aberdeen Area, and the area
south of the Bush River is referred to as the Edgewood Area-Aberdeen Proving Ground (APG-EA). The
Edgewood Area was established in 1917 as the primary chemical warfare research and development
center for the Army with activities including laboratory research, field testing of chemical munitions, pilot
scale manufacturing, and filling operations for chemical munitions. During World War I (WWI) and
World War II (WWII), APG-EA was also the location of production-scale chemical agent manufacturing.
Until the early 1970s, the primary methods of waste disposal at APG-EA were through burial, open
detonation, open-air burning, or by discharging untreated liquid wastes through sewer lines to surface
water. Over the years, these operations resulted in contamination of the environment with hazardous
materials, including ground water contamination. The U.S. Army is addressing this situation with a
program for remedial investigation, feasibility study, and corrective action.
The Building 103 dump is located in APG-EA at the intersection of Williams Road and Hoadley.
Road in the old chemical plants area of APG-EA (see Figure 2). The dump is defined as the grassy area
immediately north of Building E5422, which is bordered by Building E5422, the Building E5422/E5427
parking lot, Hoadley Road and Williams Road. The site is referred to as the Building 103 dump because
old Building 103 was located immediately north of the dump. A geophysical survey performed in 1994
determined the size of the dump to be approximately 350 feet from north to south, and 260 feet from east
to west (approximately 1.9 acres). The geophysical work and interpretation of old aerial photographs
suggest the dump extends beneath the parking lot to the west/southwest and extends beneath Building
E5422 to the south. The dump has a ground surface elevation from 20 to 30 feet above mean sea level
(MSL).
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Figure 1 Aberdeen Proving Ground Regional Location Map
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Figure 2 Location of Building 103 Dump, Edgewood Area-Aberdeen Proving Ground
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Presently, the existing dump cover is badly scarred with large animal burrows which permit direct
infiltration of water. There is extensive erosion of the cover soil into the fill material. Also, settling of
the existing cover has resulted in surface depressions.
A hydrogeologic assessment of the Canal Creek Area conducted by the United States Geological
Survey (USGS) from 1986-1989 revealed low levels of contaminants in ground water in two ground-water
monitoring wells at the Building 103 dump. It is not known if the dump is the source of this
contamination, or if the contamination is from another source. However, since the dump is a known
disposal-site, it must be assumed that it is a source contributing to the ground-water contamination.
Based on the findings in the hydrogeologic assessment reports for the Canal Creek Area and the Resource
Conservation and Recovery Act (RCRA) Facility Assessment (RFA) the Army decided to accelerate
remediation of the Canal Creek Area through an interim action at the Building 103 dump for Operable
Unit 1. The Building 103 dump will be investigated further in the Canal Creek RI/FS, and the risks
posed by the Building 103 dump further evaluated in an ongoing comprehensive human health and
environmental risk assessment for the Canal Creek Area. This investigation/risk assessment will
determine if further remedial actions are required to fully address the Building 103 dump. If further
remediation is required, the selected interim remedy for Operable Unit 1 of the Building 103 dump will
be consistent with those actions. If no further remedial actions are required, then this interim remedial
action may be final.
2.1.2 Building 103 Dump Geology
APG-EA is underlain by alluvial and estuarine sands, silts and clays forming alternating sand and
clay layers. The sediments are divided into discrete aquifers and confining units, that from the surface
down are called 1) surficial aquifer; 2) upper confining unit; 3) Canal Creek Aquifer; 4) lower confining
unit and, 5) lower confined aquifer. The surficial and Canal Creek aquifers are connected hydraulically
near the west branch of Canal Creek and in a paleochannel near the east branch of Canal Creek where
the upper confining unit has been eroded. No known pumping stresses affect the aquifers.
The stratigraphy at the Building 103 dump is based on two borings (Wells 23A and 23B). Soil
with roots is present to a depth of approximately 0.4 feet, followed by soils and clayey fill with asphalt
and wood debris to a depth of approximately 7.8 feet below grade. This is followed by thin beds of
varying stratigraphy to a depth of about 14 feet below ground surface. A thick single layer (15.3 ft thick)
of clean sand from 14.0 to 29.3 feet follows. This sand is part of the Canal Creek Aquifer. Underlying
this sand layer is a mixed sand/clay layer with coarse cobbles to a depth of approximately 34 feet.
2.1 J Building 103 Dump Surface Water
The Building 103 dump is not within the 100 year flood plain. Surface water run-on is from the
north/northwest, and through a culvert on the north side of Building ES427 which runs east beneath the
parking lot, where it drains into a shallow gully on the dump. There is direct infiltration of surface water
through holes in the existing cover, and the gully and several smaller depressions on the dump seasonally
contain standing water. Surface water run-off is predominantly to the south/southeast, with drainage
flowing between Building £5422 and Hoadley Road, and then south in a ditch along the west side of
Hoadley Road for a short distance into a storm sewer that discharges into the east branch of Canal Creek.
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2.1.4 Building 103 Dump Ground Water
The surficial aquifer is unconfined and is defined as the saturated pan of the uppermost sand and
gravel layer (0-35 ft) (USGS, 1989). Ground water-flow in the surficial aquifer is characterized mainly
by local recharge and discharge with short flow paths. The surficial aquifer receives recharge from direct
infiltration of precipitation, upward leakage from the Canal Creek Aquifer, and infiltration from leaky
storm drains. Direct infiltration occurs over most of the aquifer surface area. The surficial aquifer
discharges to surface water, leaky sewers and storm drains, and the Canal Creek Aquifer. Discharge to
surface-water bodies occurs through streambanks, bottom sediments and marshes where an upgradient
exists. The surficial aquifer is believed to discharge to the west branch of Canal Creek.
The Canal Creek Aquifer lies beneath the surficial aquifer with a thickness of 30-70 feet. It
subcrops beneath the surficial aquifer where the upper confining unit is absent under the east branch of
Canal Creek, and also near the west branch of Canal Creek. The Canal Creek Aquifer discharges
vertically upward to the surficial aquifer in the paleochannel and near the west branch of Canal Creek
if an upward head gradient exists between the two aquifers. Otherwise it flows to the southeast and down
into a deeper confined fl6w system.
The lower confined aquifer is separated from the two overlying aquifers by an overlying confining
unit. The direction of flow in the lower confined aquifer is also east/southeast.
Several residential ground-water wells exist outside of the installation boundary, but they are
located upgradient of the dump with respect to ground-water flow, and are unlikely to receive
contaminants from the dump under current or probable future use conditions. The aquifer that is tapped
by these wells is the deeper aquifer in the lower confined unit. This unit may not be contaminated, and
is hydraulically independent of the contaminated surficial and Canal Creek aquifers. The Army recently
sampled several residential wells along the northern boundary of the APG-EA for target compound list
(TCL) volatile organic compounds (VOCs), isopropylmethylphosphonic acid, methylphosphonic acid,
thiodyglycol, organosulfur compounds, organophosphorous compounds, explosives, and radiologicals.
The laboratory analysis did not find any APG-related contamination. The Army is currently sampling
and analyzing ground-water from both the Canal Creek Aquifer and the lower confined aquifer in the
Northern Boundary Area to determine the distribution of contaminated ground-water, if any is present,
and to determine whether it has migrated or is likely to migrate northward across the boundary onto off-
post areas. The Army also intends to conduct a ground-water treatability study in the Canal Creek Area.
2.1.5 Building 103 Dump Climatology
Due to the proximity of two large bodies of water (the Chesapeake Bay and the Atlantic Ocean),
the climate at Aberdeen Proving Ground tends to be moderate as compared to the inland areas (ESE,
1981). The average annual temperature is 54.5 degrees Fahrenheit, with an average relative humidity
of 73.8 percent. Precipitation averaged 44.8 inches/year over the past 21 years, with the maximum
rainfall occurring hi the summer and the minimum during the winter (WES, 1990). Snowfall averages
about 12 inches per year (Sisson, 1985). Prevailing winds average 6.8 knots (Sisson, 1985) in a
northwest to north-northwest direction in the winter months, and a south to south-southwest direction in
the summer months (ESE, 1981).
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2.1.6 Building 103 Dump Land Use
The region surrounding APG-EA is primarily residential, with some farming. The Gunpowder
River and the Bush River are used for boating, fishing and other recreational purposes. There is
passenger rail traffic on AMTRAK railroad tracks running in a north/northeast direction immediately
outside the installation boundary. United States Route 40 runs in a north/northeast direction
approximately three miles north of the installation. Interstate 95 runs in a north/northeast direction
approximately five miles north of the installation. State Route 24 terminates at the main gate of APG-
EA. The primary population centers near the APG-EA are the communities of Joppatowne/Magnolia
(population 9,385) one mile west of the installation, Edgewood (population 23,313).directly adjacent to
the installation, and Bel Air (population approximately 52,000) about eight miles north of APG-EA on
Route 24. The total population of Harford County is approximately 185,000.
The Building 103 dump is centrally located in an industrial area of APG-EA with nearby roads,
parking lots, buildings, residential areas, and recreational areas. The dump itself is partially surrounded
by a chain-link fence. Hoadley Road, is located directly east of the dump. Military and civilian DoD
personnel work in buildings immediately adjacent to the Building 103 dump. A residential area (barracks
and housing for military personnel and their families) is located approximately 2,200 feet east and
southwest of the dump. Weide Airfield is located approximately 2,500 feet east of the dump. Horse
stables, and grazing and riding areas are located approximately 1,000 feet east of the dump. Playing
fields, a picnic area, and a swimming pool are located about 1,800 feet south/southeast of the dump. In
addition, playing fields and a picnic area are located about 3,000 feet southwest of the dump. Depending
on wind speed and direction, local communities could be potential receptors in the event of a release of
hazardous substances caused by remediation activities.
The primary source of water for APG-EA has been fronf surface water since the installation was
established. Ground-water has been a secondary.source of water for APG-EA, and wells have been used
to supply water when needs could not be satisfied by surface-water supplies. The primary drinking water
source for APG-EA is Winters Run. The system which has supplied potable water is the Van Bibber
System, which consists of Atkisson Reservoir on Winters Run, the Van Bibber Treatment Plant, a small
dam and reservoir at the treatment plant site, and a piping and tank reservoir system (Hanson Reservoir)
to deliver the water to APG-EA. This system is unlikely to receive any contaminants from the Building
103 dump since it is located north and upgradient of the dump.
2.1.7 Building 103 Dump Flora and Fauna
Diversity of life at the dump is limited. Some wetlands habitat is located to the west/southwest,
however, the dump is not considered to be a wetland. Terrestrial wildlife in the area of the dump
includes song birds, ground hogs, field mice, deer, and rabbits. Several ground hogs inhabit burrows
in the dump. No endangered protected species live at the dump. No aquatic invertebrates and no fish
are present at the dump since water flow to the dump is intermittent and dependent on rainfall. Some
small amphibians may live on the dump during periods of standing water however, a significant
population is probably not present.
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2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.2.1 History of Site Activities
The Building 103 dump is a waste dumping and burial site. It was originally a sand pit from the
time during WWI when the chemical and munition filling plants were constructed. After WWI the sand
pit became a dump site for junk, construction debris, waste chemicals, and possible ordnance items.
Dumping started in the years immediately following WWI and continued until the late 1930s or early
1940s. The dump was probably filled in and covered following a general surface cleanup in April 1937.
While later aerial photographs (as late as 1964) continue to show ground scarring in the area of the dump,
this was probably the result of activity in the area other than burial. Historical records indicate after
dumping ceased, the area was sometimes used to remove insulation from copper wire by open burning.
There are essentially no records as to what was placed into the dump; however, some indication
of the contents can be inferred from wastes typical of the processes used in the manufacture of chemical
agents, incendiary and screening smokes, impregnite (chemical compound used to make military uniforms
chemical agent resistant)^ and other materials. Thus, the contents of the dump are believed to be
chemical agent residues contained in process vessels, possible chemical ordnance and/or conventional
ordnance items, chemical residues, junk and construction debris. Ordnance items are routinely uncovered
during excavation activities in the Canal Creek Area. During a recent voluntary removal action at the
Building 103 dump, approximately SO gallons of organic sludge containing bromobenzylcyanide (BBC)
residue as the major constituent was removed from a process vessel. This vessel had been exposed
because of erosion and settling of the dump cover soil. A fence was constructed around the dump in
1992.
2.2.2 History of Investigations/Remedial Actions
There is little existing documentation which directly addresses waste disposal or the environmental
impact of activities prior to the National Environmental Protection Act (NEPA) in the early 1970s. The
potential environmental impact must be inferred from information concerning chemical processes,
construction records, manufacturing records, reports detailing research and development activities, and
reports concerning worker exposure to chemical materials.
From 1976 through 1979, the U.S. Army Toxic and Hazardous Materials Agency (USATHAMA)
conducted a surface and ground-water investigation at APG-EA, including the area covered by the Canal
Creek Area. In August 1985, APG contracted with the USGS to conduct a hydrogeologic assessment and
an investigation of ground-water contamination in the Canal Creek Area. This investigation is on-going.
The RCRA Facility Assessment (RFA), documented historical activities at APG-EA related to solid-waste
management, and identified potential sources of contaminant release in the Canal Creek Area. The
Building 103 dump was investigated by AEHA as part of the RFA.
Apart from ground-water monitoring wells installed at the dump by the USGS during the
hydrogeologic assessment, relatively little characterization work has been performed to date at the dump.
A limited geophysical investigation was performed by Argonne National Laboratory (ANL) in 1992 to
assess the extent of the Building 103 dump. No soil and/or ground-water samples were collected during
this study instead, non-invasive geophysical techniques including magnetic, resistivity, ground-penetrating
radar, and seismic refraction were used to investigate the dump. Results indicated the dump was probably
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February 28, 1995
an outcrop of the surficial aquifer, and that headward erosion created a surface depression for the
collection of sand, and for the later dumping of waste. Seismic refraction indicated 6 to 12 feet of waste
material in the dump. Magnetic and resistivity anomalies suggested a branching pattern of waste disposal.
A topographic survey of the dump was performed in June 1994. Additional geophysics also was
performed at this time to more fully assess the extent of the dump. A passive soil gas survey was
performed in June 1994 to determine if the dump was generating any gas and/or vapors. The following
conclusions were drawn from all available data:
The average depth of buried waste appears to be from the surface to 6 to 12 feet below
ground surface (8 to 14 feet MSL). The maximum depth of the buried waste is
approximately 19 feet below grade.
The depth to ground water is variable between 5.7 to 9.5 feet MSL.
Ground water beneath the dump is contaminated in the surficial aquifer and in the Canal
Creek Aquifer. Ground-water contamination beneath the dump cannot be directly
correlated with the dump since it is not known if contaminants are the result of waste in
the dump or contamination from other sources. It is likely that the contamination is the
result of a combination of leaking containers in the dump and other past industrial
disposal operations.
The soil gas survey detected the presence of several organic chemicals at the dump,
including trichloroethylene, perchloroethylene (possibly from the passage of surface
runoff), ethyl ether, toluene, xylene, limonene, undecane, tridecanone, acenaphthene,
ethyl methyl phenol, and two hydrocarbons ( C15HM and CIOH16). These emissions
appeared to be randomly distributed across the dump area. No methane was detected at
any of the locations screened.
Debris appears to have been deposited in a branching pattern.
There is extensive erosion of the cover into the fill material, particularly at the northern
part of the dump. The integrity of the existing cover has also been damaged by settling
of the contents of the dump, and by large animal burrows. There may also be lateral
animal incursion underneath Hoadley Road and the parking lot into the dump.
The extent of the dump is larger than the fenced-in area and extends under Building
E5422 and the parking lot.
It needs to be determined if the Building 103 dump is an ongoing source of
contamination.
A recent removal action under Army authority at the dump included a voluntary action in 1992
for the removal of approximately 50 gallons of bromobenzyl cyanide (BBC) residue from a buried process
vessel that had surfaced on its own, and the construction of chain-link fence around the dump.
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2.2.3 Enforcement Activities
APG-EA has been listed by the EPA as a Federal facility meeting the criteria for inclusion on
the NPL established pursuant to CERCLA. APG-EA entered the CERCLA process with Site Notification
in January 1980. A Preliminary Assessment was completed in November 1980, and the Site Investigation
was completed in December 1984. To facilitate the CERCLA process, APG-EA was broken down into
several study areas. The Canal Creek Area is one of these study areas. It is currently in the Remedial
Investigation/Feasibility Study (RI/FS) stage. To facilitate this ongoing Canal Creek RJ/FS, the Canal
Creek Study Area was further subdivided into 50 Installation Restoration Program (IRP) sites, and solid
waste management units (SWMUs) or operable units were identified at each IRP site. The Building 103
dump is an IRP site. The Canal Creek Aquifer beneath the Canal Creek Study Area is also a separate
operable unit. The results of individual IRP site Remedial Investigation/Feasibility Study will be
combined with investigation results from other APG-EA study areas and used to complete an overall ROD
document for APG-EA by 1996. In September 1986 EPA issued a RCRA permit to APG which required
an assessment of SWMUs at APG. In February 1990, APG-EA was placed on the NPL. Pursuant to
Section 120 of CERCLA, 42 U.S.C. §9620, the U.S. Army and EPA signed a Federal Facility
Agreement (FFA) in March 1990 which provides for the oversight and enforcement of environmental
investigations and remedial actions at selected APG-EA study areas. The Building 103 dump is one of
the Edgewood Area study areas specified in the FFA.
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The scope and role of this operable unit was described to the APG Technical Review Committee
(TRC) on July 29, 1993, and on January 27, 1994. The Focused Feasibility Study (FFS), Proposed
Interim Remedial Action Plan, and background documentation for the Building 103 dump were released
to the public for comment in May 1994. These documents were made available to the public in the local
information and administrative record repository at the Aberdeen Public Library, Edgewood Public
Library, Miller College Library, and Essex Community College Library. In accordance with the Federal
Facility Agreement between EPA and APG, APG established an information repository in the TECOM
Public Affairs Office. APG issued a press release also announcing the availability of documents to APG's
full media list. APG placed newspaper advertisements on the availability of these documents and the
public comment period/meeting in the APG News on May 4, 1994, in the Aegis on May 11, 1994, and
in the Harfbrd County edition of the Baltimore Sun newspaper on May 8, 1994. APG prepared and
published a fact sheet on the Proposed Plan and delivered it to on-post buildings close to the site and on-
post libraries; APG also mailed copies to its Installation Restoration Program mailing list. A 45-day
public comment period on the scope and role of the proposed interim remedial action was held from May
4, 1994, to June 24, 1994. A poster session and public meeting were held on May 24, 1994, at the
Chemical and Biological Defense Command conference center (Building E4810) at APG-EA.
Approximately 35 people attended including citizens, advisors and members of the APG Superfund
Citizen's Coalition, and Federal, State and local Government representatives. At this meeting,
representatives of the Army, EPA and the Maryland Department of the Environment (MDE) answered
questions about the proposed interim remedial action at the Building 103 dump and the cap and cover
system remedial alternatives under consideration. Responses to comments received during this period
are included in the Responsiveness Summary which is part of this ROD. The Responsiveness Summary
is based on oral and written comments received during the public comment period.
The above actions satisfy the requirements of Sections 113(k) and 117 of CERCLA, 42 U.S.C.
§§ 9613(k) and 9617. The decision for this operable unit is based on the administrative record.
12
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February 28, 1995
2.4 SCOPE AND ROLE OF OPERABLE UNIT
The Army has organized the remedial effort at the Building 103 dump into two operable units
as follows:
Operable Unit 1: Source of Contamination
Operable Unit 2: Ground-water Contamination.
The interim remedial action authorized by this ROD addresses Operable Unit 1. Typically,
infiltration.of water can result in migration of contaminants to ground water.. The Building 103 dump
poses a potential risk to human health and the environment since infiltration of water can mobilize
contaminants which then migrate to ground water, posing a potential health risk when ground water is
ingested. In addition, with continued erosion of the cover soil into the contents of the dump, the dump
presents a potential dermal hazard, and a potential inhalation hazard from airborne contaminants. The
purpose of this response is to minimize infiltration of water into the dump, and to prevent animal
intrusion into the dump. This will minimize contaminant migration to ground water. This interim action
will also eliminate current and future dermal and inhalation hazards caused by the erosion of the cover
soil into the fill material of the dump.
The Army is addressing ground-water contamination (Operable Unit 2) as a part of the ongoing
Canal Creek RI/FS which includes a plume definition study, an assessment of the APG-EA Northern
Boundary, a ground-water monitoring program and a ground-water treatability study.
2.5 SUMMARY OF SITE CHARACTERISTICS
2.5.1 Building 103 Dump Soil
The extent of soil contamination is unknown, since no comprehensive soil sampling has been
conducted at the Building 103 dump. Potential routes of human exposure to any contaminants which may
be present in surface soil at the dump include dermal exposure and inhalation of airborne dusts. Potential
routes of environmental contamination include the leaching of soil contamination to ground water, and
transport of contamination by run-off to surface water. Currently, the likelihood of dermal and inhalation
exposure is low since the waste is contained in the dump. The likelihood of dermal and inhalation
exposure will increase with continued erosion of the cover soil into the fill material.
2.5.2 Building 103 Dump Ground Water
The USGS installed two ground-water monitoring wells (23 A & 23B) in the southern part of the
dump in 1987. Well 23A is screened from 16-21 ft in the surficial aquifer, with a boring depth of 21
ft. Well 23B is screened in the Canal Creek Aquifer at a depth of 52-57 ft, with a total boring depth of
57 ft. These two wells are part of the 168 well ground-water monitoring system in the Canal Creek
Area.
The USGS reported elevated levels of VOCs, semi-volatile organics (SVOCs), and inorganics in
both the Canal Creek and surficial aquifers. Specifically, the USGS reported elevated levels of cadmium,
methylene chloride, trichloroethylene, 1,2-transdichloroethylene, 1,2Hdichloroethane, and vinyl chloride
in the Canal Creek Aquifer. The USGS reported elevated levels of zinc, methylene chloride and
13
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February 28, 1995
trichloroethylene in the surficial aquifer. Other compounds also were detected. Iron and manganese
exceeded both the primary and secondary MCL values in both wells 23A and 23B (see Table 1). Organic
contaminants are listed in Table 2.
Table 1 Inorganic Constituents with Concentrations that Exceed Federal Drinking Water
Maximum Contaminant Levels
w-
(me/U
Iron
Manganese
Sampling Period
NOT §T? Apr 87
Wen
23A
0.80
0.077
Wefl
23B
30.0
0.29
Sampling Period
. Jnl Sf^Sep 88
Wen
23A
-
-
WeU
23B
24.0
0.26
Sampling Period
Apr 89 -May 89
Wefl
23A
-
-
WeO
23B
24.0
0.32
Sampling Period
Wen
23A
1.40
0.092
Wefl
23B
>0.54
0.41
Well 23A - surficitl aquifer, Well 23B - Canal Creek Aquifer
It is not known if the dump is the source of this contamination, or if the contamination is from
another source. Since there are probably other sources nearby, it is likely the contamination is from
several sources. The spatial distribution of ground-water contamination has not yet been determined;
however, an overall plume definition study is being performed as part of the Canal Creek RI/FS.
Potential routes of human exposure to the contaminants include dermal contact with contaminated ground
water, and ingestion of contaminated ground water. Potential routes of environmental contamination
include discharge of contaminated ground water to surface water bodies. The likelihood of human
exposure to contaminated ground water is low under current use scenarios however, human exposure via
the ingestion and dermal pathways is possible under future use scenarios.
2.5.3 Building 103 Dump Surface Water
No surface water sampling has been performed at the Building 103 dump. Surface water run-on
and run-off is intermittent and dependent on rainfall. Potential routes of environmental contamination
include discharge of contaminated surface water to surface water bodies.
Current potential routes of human exposure for surface water include ingestion of, or dermal
contact with contaminated surface water, or ingestion of wildlife which has ingested contaminated surface
water. Human ingestion of contaminated surface water is considered unlikely. Also, the likelihood of
ingesting wildlife which has ingested contaminated water from the dump surface is minimal since the area
is fenced and not readily accessible to game animals. Dermal contact with contaminated surface water
is considered possible.
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February 28, 1995
nhlf*
Or pan if* {"Y>nmniinHc
in \Vpllc
Sampling Dates
Sunnting. Period
Api W -"May gjl
PnncHfiiMifc (noil \
w»n
MR
WM MA
WellllR
Well MA
Wril MR
WvUMA
Woll 21R
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Final
February 28, 1995
2.5.4 Building 103 Dump Air
Long-term ambient air monitoring has not been performed at the Building 103 dump. Some
short-term ambient air monitoring was performed in 1992 during the removal action for the BBC residue.
No air contaminants were detected during this ambient air monitoring event. Passive soil gas monitoring
conducted in 1994 detected the presence of several organic chemicals which appeared to be randomly
distributed across the dump area. No methane was detected at any of the locations screened.
Some potential routes of exposure to air contaminants include direct inhalation of contaminants,
migration of landfill gases to adjacent buildings with subsequent inhalation, and dispersion of airborne
dusts with deposition of contaminants. Currently the likelihood of inhalation exposure is low since the
waste is contained in the dump. The likelihood of inhalation exposure will increase with continued
erosion of the cover soil into the fill material. Specific monitoring for landfill gases and chemical agent
vapors will be performed during the construction phase of the cap and cover system, and after completion
of the cap and cover system. Air monitoring inside Buildings £5422 and E5427 will be implemented
upon completion of the cap.
2.6 SUMMARY OF SITE RISKS
A Preliminary Risk Assessment was prepared for the Canal Creek Area in January 1991 (ICF,
1991). The Preliminary Risk Assessment was performed in accordance with EPA guidance for human
health and ecological assessments, and addresses NCP requirements for baseline conditions at
uncontrolled hazardous waste sites. This Preliminary Risk Assessment addressed potential impacts on
human health and the environment in the absence of any remediation. It is not site specific to the
Building 103 dump; however, the Building 103 dump is included as one of nine potential sources of
contamination in the Canal Creek Area. A comprehensive Canal Creek Area human-health and
environmental-risk assessment is ongoing. The Building 103 dump will be further evaluated in this
ongoing assessment, which will indicate if further remedial actions are required to fully address the
Building 103 dump. The Preliminary Risk Assessment concluded that:
The principal exposure pathways at the dump under current use scenarios are: 1)
incidental ingestion and dermal absorption of any contaminants in surface soil; 2) chronic
or subchronic exposure by ingesting game that has bioaccumulated contaminants by
feeding at the site; and, 3) the acute inhalation and dermal exposure of workers who
encounter ordnance during excavation and similar activities at the dump. No complete
ground-water exposure pathway exists because nobody consumes the ground water.
The potential complete human exposure pathways under current land use conditions are:
1) ingestion of game that has bioaccumulated contaminants by foraging at the dump; and,
2) exposure of workers digging shrubs or mowing grass at the dump. Exposure from
ingestion of game is unlikely because the fence precludes game from foraging at the site.
Acute inhalation and dermal exposure of the workers is unlikely since the waste is still
contained in the dump. Chronic dermal exposure to the waste and to contaminated
ground water is unlikely.
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February 28, 1995
Under future land use conditions, ingestion of contaminated ground water is a potential
human exposure pathway with a risk-greater than the upperbound excess lifetime cancer
risk in both shallow and deep ground water. The preliminary risk assessment stated that
future use of the ground water beneath the site is unlikely. However, the evaluation of
risks associated with the ingestion was performed because some future pumping scenario
of off-site wells could potentially result in ground water beneath the site being withdrawn
by these wells. Neither the future ingestion of soil particulates from the dump, nor the
future inhalation of dump gases was evaluated for this interim action.
In addition to chronic hazards, grounds keepers or other personnel involved in subsurface
excavation activities could be subjected to acute hazards if ordnance items or chemical
agents are encountered. No data are available since the contents of the dump are
unknown.
In the preliminary risk assessment for the ground-water risk calculation, contaminants were
selected for quantitative evaluation. The preliminary risk assessment then evaluated the potential human
health risks associated with exposure to these contaminants. Excess lifetime cancer risks were determined
by multiplying the intake level with the cancer slope factor. The risks obtained are probabilities that are
typically expressed in scientific notation. For example, an excess lifetime cancer risk of IxlO"6 means
that, as an upper limit, an individual has a one in a million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime under the specific exposure conditions at a
site.
Potential concern for non-carcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient. By adding hazard quotients for all contaminants within a medium or
across all media to which a given population may be exposed, the hazard index can be generated. The
hazard index provides a useful reference point for gaging the potential significance of multiple
contaminant exposures within a single medium or across media. If the hazard index exceeds one (1),
there may be concern for potential non-carcinogenic effects. As a rule, the greater the value of the
hazard index, the greater the level of concern.
The risks from the Building 103 dump come from: 1) dermal exposure to the waste and to
contaminated ground water; 2) burrowing by animals which creates the potential for leaching of soil
contaminants into the ground water; and, 3) the acute inhalation and dermal exposure of workers who
encounter ordnance during excavation and similar activities at the dump. The estimated human health
risks associated with these pathways for current use scenarios are as follows:
The upperbound excess lifetime cancer risk for ingestion of ground water from the
surficial and Canal Creek Aquifers was 4x10"*. This value is greater than the action level
of 1x10"* potential cancer risk. The estimated excess cancer risks are due primarily to
1,1,2,2-tetrachloroethane, carbon tetrachloride, and vinyl chloride. The hazard index for
ingestion of ground water from these two aquifers is greater than 1. These numbers are
not specific to wells at the Building 103 dump.
The hazard index for ingestion of ground water from the lower confined aquifer was less
than 1. These numbers are not specific to wells at the Building 103 dump.
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February 28, 1995
For grounds keepers exposed to contaminants in surface soil in the Canal Creek Area,
- the estimated excess lifetime cancer risk via the ingestion pathway is 3xlO'7. The
estimated excess lifetime cancer risk via the dermal absorption pathway is 2xlOrl°. The
total risk is the sum of the risks for the incidental ingestion and dermal absorption
pathways, which is 3xlO'7. The total hazard index for these pathways is less than 1.
These numbers are not specific to the Building 103 dump surface soil, but are intended
to be representative of the Canal Creek Area as a whole, and have been used here in the
absence of soil data for the Building 103 dump.
The risks presented here for exposure to ground water beneath the Building 103 dump, provide
an upper bound indication of potential future risks that assume the ingestion of untreated ground water.
Capping will eliminate the potential dermal hazard by eliminating dust, and significantly reduce the
infiltration of water into the Building 103 dump and the migration of contaminants from the dump into
ground water. The Canal Creek RI/FS and ongoing Canal Creek Area Risk Assessment will further
address characterization and remediation of the ground water. A Ground-water Treatability Study will
address the actual remediation of the ground water.
i
The cap and cover system will minimize contact with humans and wildlife from being exposed
to any potential hazards from die Building 103 dump's contents.
The risks summarized above are addressed by the goals of this interim remedial action, since they
minimize contact with the contents of the Building 103 dump, while minimizing the infiltration of water
into the dump. Actual or threatened release of contaminants from the Building 103 dump, if not
addressed by the preferred alternative, or one of the other alternatives considered, may present an
imminent and substantial endangerment to public health, welfare or the environment.
Although not a direct health issue, the risk of adverse chemical interaction between the Building
503 soil/ash contaminants and Building 103 dump contents was assessed since contaminated soil/ash from
the Building 503 Soils Operable Unit will be placed under the cap and cover system. The soil/ash at the
Building 503 Soils Operable Unit contains elevated levels of metal compounds and organic compounds
mixed with the soil. Sample analysis indicated that the major metal constituents in the ash/soil are zinc,
lead, iron, and aluminum. Low concentrations of arsenic, barium, cadmium, chromium, manganese, and
silver also are present. Elevated levels of organics, mainly hexachlorobenzene and hexachloroethane were
also found with other organics present at trace levels. *
A number of factors reduce the possibility of increased mobilization of the Building 503 soil/ash
contaminants once under the cap and cover system, and the possibility of adverse interactions between
the Building 503 wastes and the Building 103 dump contents. These factors are: 1) physical isolation of
the wastes under the cap; 2) capping to minimize water intrusion; 3) the generally low concentration and
quantity of contaminants in die Building 503 wastes; and, 4) the stable form of the metals in the Building
503 soil/ash.
When the above factors are considered both individually and collectively, the possibility of an
adverse reaction between the contaminants in the Building 503 soil/ash and the contents of the Building
103 dump is remote.
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February 28, 1995
Non-hazardous drill cuttings from other APG-EA study areas will not adversely react with the
Building 503 soil/ash or the contents of the Building' 103 dump.
2.7 DESCRIPTION OF ALTERNATIVES
2.7.1 General
The general remediation action objectives of the interim remedial action at the Building 103 dump
are to prevent infiltration of water through the dump, to prevent direct contact and inhalation and to
minimize animal intrusion into the dump. This interim remedial action will also promote surface drainage,
minimize erosion, accommodate settling and subsidence, provide for adequate venting for gases/vapors,
and ensure the cap and cover system will function with minimal maintenance.
A range of general response actions was considered which significantly reduce the risk to public
health and the environment. These general response actions were screened for applicability, then those
that appeared to be appropriate for the dump were evaluated in more detail. The Superfund law requires
that each remedy selected to address contamination at a hazardous waste site be protective of human
health and the environment, be cost effective, and be in compliance with statutory requirements.
Based on current site conditions, waste containment technologies were determined to be the most
appropriate interim remedial technology since they minimize the dermal and inhalation risk of the
contaminated soil, and reduce the mobility of contaminants by limiting infiltration. Containment is the
preferred method for preventing infiltration and often is used when it is unrealistic to excavate a site.
The feasibility of excavating the dump also was assessed. This technology wouid involve
excavation and complete or partial removal of waste and contaminated soil from the dump to another
location. While excavation followed by off-site disposal is often a preferred technology when small waste
quantities are involved, it was not retained here as an alternative for the following technical and logistical
reasons:
1) Excavation and removal would not significantly reduce the toxicity, mobility or volume of the
excavated waste.
2) Complete or partial removal would provide a low degree of short-term protection since it could
not be implemented immediately. In the meantime, there would be continued infiltration of water through
the existing cover. Also, even if the dump were excavated and the waste removed, the ongoing ground-
water monitoring program would have to be continued, and ground water beneath the Building 103 dump
may still require remediation.
3) Complete or partial excavation would take a long time to complete since the total volume
requiring excavation is substantial (approximately 16,000-30,400 cubic yards). The total volume may
be greater if surrounding soil is contaminated. Also, soil volume typically increases by up to 30 percent
after excavation due to loss of compaction.
4) On-site disposal of this excavated waste, either by replacement or placement elsewhere on-site,
would require treatment of the excavated waste, short-term containment pending treatment, and possible
long-term containment and management of the waste. While contaminated soil would probably not
19
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February 28, 1995
require any treatment prior to off-site disposal, most other waste and debris would probably require some
treatment prior to off-site disposal. This could present a problem if the volume of debris and waste
overwhelms existing on-site storage and treatment facilities. Also, there is currently no approved
treatment and disposal technology for some of the chemical agent residues which potentially could be
buried in the dump.
5) Off-site disposal without treatment is considered inappropriate for the following reasons: a)
off-site disposal would increase the short-term risk of public exposure due to the removal, handling, and
transportation of the waste and contaminated soil; b) there are no off-site landfills permitted to accept
ordnance items and/or untreated chemical agent residue; and, c) Army regulations require the
decontamination of chemical agent residue and potentially contaminated debris before they are released
to the public sector:
6) Excavation and removal would be difficult to implement since the dump is located adjacent to
occupied buildings and Hoadley Road. While excavation activities should not affect nearby communities,
APG-EA personnel would be.impacted. All personnel working in Buildings E5422, E5427, and E5265
would have to be relocated. Also, Hoadley Road and Williams Road would have to be temporarily closed
and traffic rerouted. While excavation-related impacts would be expected to affect mainly workers at the
dump, it might be necessary from time to time to evacuate other areas as a result of Chemical/Accident
Incident Response Action (CAIRA).
7) In addition to the UXO hazard, other hazardous conditions may be created by disturbing the
contents of the dump. The dump is a confirmed chemical agent residue disposal site (SO gallons of
bromobenzylcyanide residue were pumped from a buried process vessel in 1992). Containers of
hazardous chemicals could be ruptured, or hazardous dusts could be generated. Excavation and removal
increases the risk of contaminating currently unaffected areas. It increases the risk, of worker exposure
through dermal contact with and/or through inhalation of contaminants during excavation and staging,
and increases risk of public exposure through the transport of waste off site.
8) Because of safety considerations, progress would be very slow and take several years to
complete, since the dump would be have to excavated by backhoe, or remote controlled backhoe operated
from a shelter located upwind of the area being excavated, or by hand. Hand excavation or a
combination of hand and mechanical excavation would be required to safely recover suspect debris items
or UXO. Suspect metallic debris in the dump, if identified as conventional UXO, would have to be
rendered safe by EOD personnel and removed. All unearthed suspect storage containers would have to
be drilled, sampled and pumped dry prior to removal from the dump if found to contain liquid. These
container pump and transfer operations would have to be conducted inside specially built temporary
enclosures with carbon filters and under negative pressure to reduce the chance of emissions. All suspect
chemical ordnance items that are unearthed would have to be secured and removed to a safe holding area
and stored pending filial disposition. If EOD personnel determined that ordnance items cannot be safely
moved, they would have to be detonated in place. All excavated debris and ordnance items would have
to be considered potentially contaminated with chemical agent and would require testing. Agent
contaminated items would have to be decontaminated. Staged soil also would have to be screened for
chemical agents, agent degradation products, other contaminants.
9) Building E5422, and part of the parking lot have been constructed on the dump making
excavation of all the buried waste difficult.
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February 28, 1995
10) Large protected staging areas for the transfer of the excavated debris, chemical waste and
contaminated soil would have to be sited and constructed to ensure that wastes can be temporarily stored
with minimal potential for release of contaminants to the environment.
11) Excavation and removal are very expensive. The capital cost for implementation of this
technology was estimated to be at least $9,534,600 when based on a total volume of 30,400 cubic yards.
Treatment costs for ground water were not included, since the ground water is being addressed as a
separate operable unit. If the contents of the dump were removed, the ground water may still require
remediation. This cost estimate did not include soil treatment.
2.7.2 Statutory Preferences
Section 121 (b) of CERCLA mandates that, where possible, EPA select remedies that "utilize
permanent solutions and alternative treatment technologies or resource recovery technologies to the
maximum extent practicable;" Remedial actions in which treatment "permanently and significantly
reduces the volume, toxicity, or mobility of hazardous substances, pollutants, and contaminants as a
principal element" are preferred. Also, current EPA guidance for municipal landfill RI/FS activity
suggests evaluation of waste removal for small (less than 1 acre) landfills, or elimination of known areas
containing containerized liquid wastes. In general, it is not cost effective to excavate landfills with an
area greater than 1 acre.
Removal technologies typically involve the complete or partial excavation and removal of waste
to another location either on-site or off-site for storage, treatment or disposal. Although removal by itself
can disrupt the exposure pathway(s), it has little or no effect on the toxicity or volume of contaminated
material and is therefore often specified only in conjunction with treatment. Excavation can greatly
increase short-term risk to the public and site workers, since excavation typically increases the mobility
of the waste (possible dispersion of contaminated dust during excavation), and since the waste must often
be transported off-site for disposal or treatment.
Capping involves covering a site to reduce direct exposure to contaminants and to minimize water
infiltration and subsequent vertical migration of contaminants. Maryland hazardous waste management
regulations are more stringent than Federal RCRA requirements with respect to the use of capping for
the closure of hazardous waste landfills < Federal RCRA regulations allow closure with waste and
contaminated soils either removed (clean closure) or intentionally left in place. Maryland laws allow
waste or contaminated soil to be left in place only after the owner/operator has made reasonable efforts
to conduct a corrective action program to remove or treat in-place any hazardous constituents that result
in concentration limits in ground water which exceed limits set form in COMAR 26.13.05.06E and K).
The preference for contaminant removal was considered, and complete or partial excavation
screened as a remediation technology. Excavation of the contents of the dump could have been used in
conjunction with ex-situ treatment and disposal technologies. It was anticipated that contaminated soil
would be removed to a depth no greater than ground water using conventional equipment. Since
complete removal and treatment of waste and contaminated soil would not be practicable, the State
requirements for the design and maintenance of landfill caps contained in COMAR 26.13.05.14 and
26.04.07.21 are applicable ARARs. These include the following:
Run-on and run-off must be controlled to prevent erosion of or damage to the cap and
cover system.
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February 28, 1995
The cap and cover system must provide long-term minimization of liquid infiltration and
have a permeability less than that of the natural sub soils.
The cap and cover system must function with minimal maintenance.
The cap and cover system must accommodate settling and subsidence while retaining
integrity.
Postclosure monitoring and maintenance must be provided.
These interim remedial alternatives were developed because they significantly reduce the risk to
public health and the environment from exposure to and/or transport of contaminants that may be
associated with surface-water run-off or surface-water infiltration and subsequent leachate generation.
The Superfund law requires each remedy selected to address contamination at hazardous waste site be
protective of human health and the environment, be cost effective, and be in accordance with ARAR
requirements. The costs for implementing each alternative include preliminary estimates of capital outlay
and estimates for operation and maintenance (O&M), as well as present worth costs.
Taking into consideration the types of waste possibly buried in the dump, the Army felt
containment was the best way to safely achieve the interim remedial action goals by preventing the
infiltration of surface water and precipitation into the dump with a cap and coyer system. The
alternatives evaluated included:
Alternative 1: No Action.
Alternative 2: Install a cap and cover system in accordance with MDE requirements for
industrial landfill closure using off-site clay.
Alternative 3: Install a cap and cover system in accordance with MDE requirements for
industrial landfill closure using a sodium bentonite geocomposite mat.
Alternative 4: Install a cap and cover system in accordance with MDE requirements for
industrial landfill closure using a geosynthetic membrane.
Alternative 5: Install a cap and cover system in accordance with RCRA requirements for
hazardous waste landfill closure using off-site clay and a geosynthetic membrane.
Alternative 6: Install a cap and cover system in accordance with RCRA requirements for
hazardous waste landfill closure using a sodium bentonite geocomposite mat and a
geosynthetic membrane.
These alternatives do not address treatment or monitoring of contaminated ground water
associated with the Building 103 dump. Remediation of the ground water is complex, requiring a
comprehensive risk assessment and long-term RI/FS which will evaluate APG-EA-wide alternatives.
Ground-water issues are the subject of an additional investigation by the Army to more completely
determine the nature and overall extent of ground-water contamination at APG-EA.
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February 28, 1995
2.7.3 Description and Alternatives
Alternative 1: No Action. Under Alternative 1, no remedial actions would be performed at the
dump. Existing institutional controls and maintenance arrangements would be continued. The Army has
documented use restrictions in installation records and on installation maps. Ground-water monitoring
operations at monitoring wells 23A and 23B would continue, and contaminated ground water would be
addressed under the separate Canal Creek Area-wide RI/FS.
The No-Action alternative does nothing to enhance protection of the public health, environment,
or future land and ground-water users. The risks posed by the dump would remain at current levels, or
increase over time. The No-Action alternative does not minimize the infiltration of water into the dump
instead, there would be continued water infiltration and animal intrusion into the dump. There would be
continued erosion of the existing cover into the contents of the dump.
In addition, the No-Action alternative fails to meet RCRA and MDE closure requirements for the
capping of wastes in hazardous waste and sanitary land disposal units.
!
This alternative has no capital costs. Costs associated with future potential liabilities or future
necessary remedial actions at the Building 103 dump would not include maintaining the fence and posted
signs.
Alternative 2: Install a Cap and Cover System in Accordance with MDE Requirements for
Industrial Landfill Closure Using Off-site Clay. Alternative 2 would involve the construction of a
multilayer cap and cover system in accordance with MDE requirements for industrial landfill closure
(COMAR 26.04.07.21). This cap and cover system will cover the full extent of the Building 103 dump
as it is currently known. Based on field work conducted to date, this corresponds to an approximate area
of 1.9 acres, and includes the grassy area adjacent to Building E5422, south of Williams Road, and west
of Hoadley Road. The Building 103 dump would be further investigated as part of the ongoing Canal
Creek RI/FS to fully assess the extent of the dump. This investigation would indicate if further remedial
actions are required in conjunction with the construction of the cap and cover system to fully address the
Building 103 dump. Any additional remedial actions required to fully address the dump would be
undertaken. Since waste would be contained on-site, this alternative has a periodic review requirement
at which time the effectiveness of this alternative will be assessed and further remedial actions taken if
necessary. The design features of this cap and cover system would include:
An earthen material backfill cover (to include contaminated soil from Building 503 Soils
Operable Unit and non-hazardous drill cuttings from other APG-EA study areas) over the
existing cover.
2 feet of semi-permeable earthen material over the backfill cover, graded to achieve a 4
percent topslope.
A low permeability cover consisting of a minimum of 1 foot of clay material with an in-
place permeability less than or equal to 1 x 10'' cm/s placed over the semi-permeable
earthen material.
A drainage layer with an in-place permeability greater than 1 x 10"J cm/sec.
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Final
February 28, 1995
A compacted cobble/gravel animal intrusion barrier.
A final earth cover (up to 2 feet thick) with 4 percent minimum slope and vegetative
cover.
Gas collection/filtration system installed at start of construction to control long-term
emissions.
Long-term storm water management (storm water drainage ditches and/or swales around
the perimeter of the dump).
Warning signs would be placed at the dump, and use restrictions documented on installation
records and maps. The Army would be required to maintain the cap and cover system, which would be
inspected at regular intervals to check for erosion, settlement, or invasion by animals and/or deep rooted
vegetation. Repairs would be implemented as needed.
The capital cost for this alternative is $1,438,531 with annual O&M costs of $4,730. The present
worth is $1,511,243. The time to implement mis alternative is 12 months after having a signed ROD
(costs and times are estimates).
Alternative 3: Install a Cap and Cover System in Accordance with MDE Requirements for
Industrial landfill Closure Using a Sodium Bentonite Geocomposite Mat. This alternative would
involve the construction of a multilayer cap and cover system in accordance with MDE requirements for
industrial landfill closure (COMAR 26.04.07.21). This cap and cover system will cover the full extent
of the Building 103 dump as it is currently known. Based on field work conducted to date, this
corresponds to an approximate area of 1.9 acres, and includes the grassy area adjacent to Building E5422,
south of Williams Road, and west of Hoadley Road. The Building 103 dump would be further
investigated as part of the ongoing Canal Creek RI/FS to fully assess the extent of the dump. This
investigation would indicate if further remedial actions are required in conjunction with the construction
of the cap and cover system to fully address the Building 103 dump. Any further remedial actions
required to fully address the Building 103 dump would be undertaken. Since waste would be contained
on site, this alternative has a periodic review requirement, at which time the effectiveness of this
alternative will be assessed and further remedial actions taken if necessary. The design features of this
cap and cover system would include:
An earthen material backfill cover (to include contaminated soil from Building 503 Soils
Operable Unit and non-hazardous drill cuttings from other APG-EA study areas) over the
existing cover.
Two feet of semi-permeable earthen material over the backfill cover, graded to achieve
a 4 percent topslope.
A low permeability cover consisting of a sodium bentonite geocomposite mat with a
permeability of at least 8 x 10"'° cm/sec.
A drainage layer with an in-place permeability of IxlO"3 cm/sec.
A compacted cobble/gravel anir-ii intrusion barrier.
A final earthen cover (up to 2 f thick) with 4 percent minimum slope and vegetative
cover.
24
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Final
February 2S, 1995
Gas collection/filtration system installed at start of construction to control long-term
emissions.
Long-term storm water management (storm water drainage ditches and/or swales around
the perimeter of the dump).
Warning signs would be placed at the dump, and use restrictions would be documented on
installation records and maps. The Army would be required to maintain the cap and cover system. The
cap and cover system would be inspected at regular intervals to check for erosion, settlement, or invasion
by animals and/or deep rooted vegetation. Repairs would be implemented as needed.
The capital cost of this alternative is $1,388,805 with annual O&M costs of $4,730. The present
worth is $1,461,517. The time to implement this alternative is 12 months after having a signed ROD
(costs and times are estimates).
Alternative 4: Install a Cap and Cover System in Accordance with MDE Requirements for
Industrial Landfill Closure Using a Geosynthetic Membrane. This alternative involves the
construction of a new multilayer cap and cover system in accordance with MDE requirements for
industrial waste landfill closure (COMAR 26.04.07.21). This cap and cover system will cover the full
extent of the Building 103 dump as it is currently known. Based on field work conducted to date, this
corresponds to an approximate area of 1.9 acres, and includes the grassy area adjacent to Building E5422,
south of Williams Road, and west of Hoadley Road. The Building 103 dump would be further
investigated as part of the on-going Canal Creek RJ/FS. This investigation would indicate if further
remedial actions are required in conjunction with the construction of the cap and cover system to fully
address the Building 103 dump. Any further remedial actions required to fully address the Building 103
dump would be undertaken. Since waste will be contained on-site, this alternative has a periodic review
requirement, at which time the effectiveness of this alternative will be assessed, and any further remedial
actions taken if necessary. Design features of this cap and cover system would include:
N
An earthen material backfill cover (to include contaminated soil from Building 503 Soils
Operable Unit and non-hazardous drill cuttings from other APG-EA study areas) over the
existing cover.
Two feet of semi-permeable earthen material over the backfill cover, graded to achieve
a 4 percent topslope.
A low permeability cover consisting of a geosynthetic membrane over the compacted
semi-pervious earthen fill material.
A drainage layer with an in-place permeability of 1 x 10~3 cm/sec.
A compacted cobble/gravel animal intrusion barrier.
A final earthen cover (up to 2 feet thick) with 4 percent minimum slope and vegetative
cover.
Gas collection/filtration system installed at start of construction to control long-term
emissions.
Long-term storm water management (storm water drainage ditches and swales around the
perimeter of the dump).
25
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Final
February 28, 1995
Warning signs would be placed at the dump, and use restrictions documented on installation
records and maps. The Army would be required to maintain the cap and cover system. The cover would
be inspected at regular intervals to check for erosion, settlement, or invasion intrusion by animals and/or
deep rooted vegetation. Repairs would be implemented as needed.
The capital cost for this alternative is estimated to be $1,436,417 with annual O&M costs of
$4,730. The present worth is $1,509,129. The time to implement this alternative is 12 months after
having a signed ROD (costs and times are estimates).
Alternative 5: Install a Cap and Cover System in Accordance with RCRA Requirements for
Hazardous Waste Landfill Closure Using Off-site Clay and a Geosynthetic Membrane. This
alternative involves the construction of a new multilayer cap and cover system in accordance with MDE
requirements for hazardous waste landfill closure (COMAR 26.13.05.14) and EPA design
recommendations (USEPA, 1985). This cap and cover system will cover the full extent of the Building
103 dump as it is currently known. Based on field work conducted to date, this corresponds to an
approximate area of 1.9 acres, and includes the grassy area adjacent to Building E5422, south of Williams
Road, and west of Hoadley Road. The Building 103 dump would be further investigated as part of the
ongoing Canal Creek RI/FS, and any further remedial actions required to fully address the dump would
be undertaken. This investigation would indicate if further remedial actions are required in conjunction
with the construction of the cap and cover system to fully address the Building 1Q3 dump. Since waste
would be contained on site, this alternative has a periodic review requirement, at which time the
effectiveness of this alternative will be assessed and any further remedial actions taken if necessary. The
design features of this cap and cover system would include:
An earthen material backfill cover (to include contaminated soil from Building 503 Soils
Operable Unit and non-hazardous drill cuttings from other APG-EA study areas) over the
existing cover.
Two feet of semi-permeable earthen material over the backfill cover, graded to achieve
a 4 percent topslope.
A 2-foot compacted clay layer with an in-place permeability of 10~7 cm/s or less placed
over the backfill material. This cover would utilize off-site clay.
A synthetic geomembrane (minimum thickness 20 mil).
A drainage layer with an in-place permeability greater than 10~3 cm/sec.
A compacted cobble/gravel animal intrusion barrier.
A final earthen cover (up to 2 feet thick), with 4-percent topslope and vegetative cover.
Gas collection/filtration system installed at start of construction to control long-term
emissions.
Long-term storm water management (storm water drainage ditches and swales around the
perimeter of the dump).
Warning signs would be placed at the dump, and use restrictions would be documented on
installation records and maps. The Army would be required to maintain the cap and cover system. The
cover would be inspected at regular intervals to check for erosion, settlement, or invasion by animals or
26
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Final
February 23, 1995
deep rooted vegetation. Repairs would be implemented as needed. This alternative requires from the
Army a long-term commitment to perform maintenance on the cover and to monitor the ground water
beneath the dump.
The capital cost for this alternative is $1,688,520 with annual O&M costs of $4,730. The net
present worth is $1,741,232. The time to implement this alternative is 12 months after having a signed
ROD (costs and times are estimates only).
Alternative 6: Install a Cap and Cover System in Accordance with RCRA Requirements for
Hazardous Waste Landfill Closure Using a Sodium Bentonite Geocomposite Mat and a Geosynthetic
Membrane. Alternative 6 involves the construction of a multilayer cap and cover system in accordance
with MDE requirements for a hazardous waste landfill closure (COMAR 26.13.05.14) and EPA design
recommendations (USEPA, 1985). This cap and cover system will cover the full extent of the Building
103 dump as it is currently known. Based on field work conducted to date, this corresponds to an
approximate area of 1.9 acres, and includes die grassy area adjacent to Building E5422, south of Williams
Road, and west of Hoadley Road. The Building 103 dump will be further investigated as part of the
ongoing Canal Creek RI/FS. This investigation will indicate if further remedial actions are required in
conjunction with the construction of the cap and cover system to fully address the Building 103 dump.
Any further remedial actions required to fully address the dump will be undertaken. Since waste will be
contained on-site, this alternative has a periodic review requirement, at which time the effectiveness of
this alternative will be assessed and further remedial actions taken if necessary. The design features of
this cap and cover system will include:
An earthen material backfill cover (to include contaminated soil from Building 503 Soils
Operable Unit and non-hazardous drill cuttings from other APG-EA study areas) over the
existing cover.
Two feet of semi-permeable earthen material over the backfill cover, graded to achieve
a 4 percent topslope.
A sodium bentonite geocomposite mat with an in-place permeability of at least 10"7
cm/sec or less over the backfill material.
A geosynthetic membrane (minimum thickness 20 mil).
A drainage layer with minimum permeability of 10~3 cm/sec.
A compacted cobble/gravel animal intrusion barrier.
A final earthen cover (up to 2 feet thick), with 4 percent topslope and vegetative cover.
Long-term storm water management (storm water drainage ditches and swales).
Gas collection/filtration system installed at start of construction to control long-term
emissions.
The capital cost for this alternative is $1,507,835 wirn annual O&M costs of $4,730. The net
present worth is $1,580,548. The time to implement this alternative is 12 months after having a signed
ROD (costs and times are estimates only).
27
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Final
February 28, 1995
Appropriate warning signs would be placed at the dump, and use restrictions will be documented
on APG records and maps. The Army would-be required to maintain the cap and cover system. The
cover would be inspected at regular intervals to check for erosion, settlement, or invasion by animals,
or deep rooted vegetation. Repairs would be implemented as needed.
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The six remedial action alternatives developed for the Building 103 dump were evaluated using
nine specific evaluation criteria. These criteria are:
Threshold Criteria
1) Overall protection of human health and the environment
2) Compliance with applicable or relevant and appropriate
requirements
Primary Balancing Criteria
3) Long-term effectiveness and permanence
4) Reduction of toxicity, mobility or volume
5) Short-term effectiveness
6) Implementability
7) Cost
Modifying Criteria
8) EPA/State acceptance
9) Community acceptance
The following section summarizes the relative performance of each of the alternatives with respect
to the nine CERCLA evaluation criteria.
2.8.1 Comparative Analysis of Alternatives
Overall Protection of Human Health and the Environment. The overall protection criterion
is a composite of the short-term effectiveness, long-term effectiveness, and compliance with ARARs
criteria. As such, it addresses whether or not a remedy will: 1) result hi any unacceptable impacts; 2)
control inherent hazards (such as toxicity and contaminant mobility) associated with a site; and, 3)
minimize short term impacts associated with cleaning up site. This evaluation provides an overall
assessment of the relative protection of each alternative of human health and the environment.
The potential complex human exposure pathways under current land use conditions are 1)
ingestion of game that has bie: cumulated contaminants at the site, and 2) possible dermal and inhalation
exposure of on-site workers G :.; ng shrubs or mowing grass at die site. The other current human health
risks associated with the dump
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Final
February 28, 1995
confirmed chemical agent disposal site. Under future land use conditions, ingestion of contaminated
ground water is a potential human exposure pathway. Future health risks could .also result from further
degradation of the existing cover, which would expose buried waste, resulting in possible inhalation and
direct contact hazards.
Alternative 1 does not enhance protection of the public health, environment, or future land and
ground water users. The risks posed by the dump would remain at current levels, and would increase
over time. Alternative 1 does not minimize the infiltration of water into the dump, instead, there would
be continued water infiltration and animal intrusion into the dump. Water infiltration would most likely
increase due to increased failure of the existing cover, as would animal intrusion. Contaminant mobility
would increase due to infiltration of water with increased movement into ground water or into surface
waters. There would be continued erosion of the existing cover into the contents of the dump. Further
degradation of the existing cover system could expose buried waste, resulting in possible inhalation and
direct contact hazards. Therefore, Alternative 1 is not protective of human health and the environment.
Alternatives 2, 3 and 4 provide a moderate to high level of overall protection to human health
and the environment. These alternatives eliminate current health risks associated with the dump, and they
significantly reduce future health risks since they eliminate future inhalation and direct contact hazards.
The cap under each of these alternatives has only a single impermeable layer mat would permit some
water infiltration over tune. Since waste would remain in place, and although the long term risk is
greatly, minimized, there probably would still be some migration of contaminants into ground water.
Alternative 2 would be less protective than Alternatives 3 and 4 in preventing water infiltration, because
clay is more permeable than either a geosynthetic membrane or a bentonite mat hi the long run.
Alternative 3 would be slightly less protective than Alternative 4 since a bentonite mat permits more water
infiltration than a synthetic membrane. Because waste would remain in place, and although the long term
risk is greatly minimized, there probably would still be some migration of contaminants into ground
water.
Alternatives 5 and 6 would provide a high level of overall protection to human health and the
environment. They eliminate the current health risks posed by the eroded cover, and eliminate future
health risks associated with inhalation and dermal contact. Since the cap contains two impermeable layers
Alternatives 5 and 6 provide a higher degree of reliable long- and short-term protection of human health
and the environment than Alternatives 2, 3 and 4. Alternatives 5 and 6 are probably equally protective
of human health and the environment.
Compliance with ARARs. This criterion addresses whether or not a remedy will meet all of the
applicable or relevant and appropriate requirements of other environmental statutes and/or provide
grounds for invoking a waiver.
Alternative 1 would result in violations of Federal Air and Water Quality Controls (AWQC)
guidelines and State water quality standards in ground water, if further degradation of the existing cap
with subsequent leaching of contaminants into ground water were to occur. In addition, Alternative 1
fails to meet RCRA and MDE closure requirements for the capping of wastes in hazardous waste and
industrial land disposal units.
Alternative 2 would meet MDE requirements for industrial landfill closure. Alternative 3 does
not meet RCRA requirements for hazardous waste landfill closure, but meets MDE requirements for
industrial landfill closure. Alternative 4 does not meet RCRA requirements for hazardous waste landfill
closure, but meets MDE requirements for industrial landfill closure. Alternatives 5 and 6 would meet
both RCRA requirements for hazardous waste landfill closure, and exceed MDE requirements for
industrial landfill closure.
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Final
February 28, 1995
In summary, Alternative 1 meets neither MDE closure requirements for an industrial landfill, nor
does it meet closure requirements for a RCRA hazardous waste landfill. Alternatives 2, 3, and 4 would
meet MDE requirements for industrial waste landfill closure, but do not meet RCRA requirements for
hazardous waste landfill closure. Alternatives 5 and 6 meet RCRA requirements for hazardous waste
landfill closure.
Alternatives 2, 3, 4, 5 and 6 meet the provisions of the Corrective Action Management Unit
(CAMU) rule set forth at 58 Fed. Reg. 8679 which authorizes the on-site consolidation of wastes, and
consequently the placement of non-hazardous drill cuttings from other APG-EA study areas, and of
contaminated soil from the Building 503 Soils Operable Unit at the Building 103 dump. The Army does
not need a permit or waiver from MDE under any alternative in order to include the drill cuttings or
contaminated soil as part of the fill material.
There will be increased run-off with alternatives 2, 3, 4, 5, and 6 since the existing drainage will
be upgraded. However, in accordance with Section 121(e)(l) of CERCLA and 40 CFR, Section
300.400(e)(l), no Federal, State, or local permits are necessary for CERCLA response actions conducted
entirely on-site. Consequently, a Maryland discharge permit for storm water systems will not be
required. However, all substantive requirements of such a permit must be met, and all alternatives would
minimize erosion and control sediment run-off as required by Maryland Erosion and Sediment Control
Regulations (COMAR 26.09.01.01) and Storm Water Management Regulations (COMAR 26.09.02).
The gas collection/filtration system to be installed under Alternatives 2,3,4,5, and 6 would meet
U.S. Army regulations (CRDEC Regulation 385-1) for hazardous chemical air emissions, and comply
with the Clean Air Act and Maryland Air Pollution Control Regulations (COMAR 26.11.06 and
26.11.15). There will be no air emissions after completion of the cap and gas collection/filtration system.
Land disposal restrictions under RCRA (40 CFR § 268) do not apply to spent filters.
Maryland Discharge Limitations (COMAR .26.08.03) are not applicable since none of the
alternatives under consideration result in discharge to surface water from a discrete source. Also,
Maryland Water Quality Regulations (COMAR 26.08.02) should not be relevant and appropriate to this
interim remedial action since none of the alternatives under consideration will result in the discharge of
pollutants to surface water or ground water.
Since all alternatives under consideration involve earthmoving operations which may result in
paniculate emissions to air and noise, they will all comply with Maryland State Adopted National
Ambient Air Quality Standards and guidelines (COMAR 26.11.03), Maryland State Ambient Air Quality
Standards (COMAR 26.11.04), Maryland General Emissions Standards, Prohibitions, and Restrictions
(COMAR 26.11.06) and Maryland Noise Pollution Regulations (COMAR 26.02.03). There will be no
air emissions after completion of the cap and gas collection/filtration system.
Even though portions of APG-EA are considered wetlands, the Building 103 dump site is not a
wetland and is not within the 100-year flood plain, therefore 40 CFR Part 6, Appendix A (Response in
a Flood Plain or Wetlands), and Executive Orders 11988 and 11990 do not apply to any of the
alternatives under consideration.
This interim response action will not affect any endangered species at APG-EA, since no
endangered species are present at the Building 103 dump.
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Final
February 28, 1995
Long-Term Effectiveness. This criterion refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time once cleanup goals have been met.
Alternative 1 provides no long term protection to human health and the environment. It would
not minimize the infiltration of water into the dump instead, there would be continued water infiltration
and animal intrusion into the dump. Water infiltration would increase over time due to failure of the
existing cover. The continued erosion of the existing cover into the contents of the dump would expose
buried waste resulting inhalation and direct contact hazards.
Alternative 2 provides a moderate to high degree of reliable long-term protection to human health
and the environment. Alternative 2 reduces the long-term risk of contaminant migration into ground
water, or contaminant run-off into surface water. However, a potential for the leaching of contaminants
into ground water would still exist under this alternative because the waste would remain in place, and
because the clay mat is not totally impervious and would permit some water infiltration. Proper
maintenance and routine inspection of the cap and cover system would minimi?*; the magnitude of water
infiltration due to failure of the clay mat, and animal and plant intrusion. This alternative requires that
the Army make a long-term commitment to maintain the cap and cover system to ensure its future
integrity.
Alternative 3 provides a moderate to high degree of reliable long-term protection to human health
and the environment. Sodium bentonite geocomposite mats are typically assumed to have a useful life
of 25 years, provided they are not physically damaged in some way during installation. Therefore, this
alternative would have a design life of at least 25 years. A potential for leaching of contaminants would
still exist with this alternative because waste material would remain in place, and because the bentonite
mat is not totally impervious and would permit some infiltration of water. However, infiltration of water
would be minimal.
Alternative 4 provides a high degree of reliable, long-term protection to human health and the
environment. Synthetic membranes typically have a useful life of approximately 20 years, meaning that
a synthetic liner would allow virtually no liquid penetration for 20 years. Synthetic liners can be
damaged by soil microbes, rodents and, to a small extent, by vegetation. For example, certain grass
species may penetrate through synthetic membranes, and insects and burrowing rodents can severely
damage plastics. In general, however, roots will not penetrate through geomembranes. Also, the
cobble/gravel barrier would provide protection against roots, insects, and burrowing animals. This cap
and cover system would significantly reduce long-term risks due to the leaching of contaminants into
ground water. Since the waste would remain in place there probably would still be some migration of
contaminants into ground water when the liner begins to fail with age, and prior to this some migration
might occur through puncture holes put into the liner during installation. Proper maintenance and routine
inspection of the cover system would significantly minimize the magnitude of infiltration.
Alternatives 5 and 6 provide the highest degree of reliable long-term protection since there are
two impermeable layers in the cap and cover system. The design life of a cap is generally in excess of
100 years when a synthetic liner is supplemented by a low permeability base, when the underlying waste
is unsaturated, and when proper maintenance procedures are observed. In both alternatives, the
cobble/gravel barrier would protect the synthetic liner from animals and roots, which in turn would
protect the underlying clay layer or bentonite mat. A limited potential for leaching would still exist since
waste materials would remain in place. Infiltration would be minimal, however.
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Final
February 28, 1995
In summary, Alternative 1 offers little or no protection against long-term infiltration of water and
animal intrusion into the dump. Erosion of the existing cover would continue with continued migration
of contaminants to ground water. Alternatives 2, 3, 4, 5, and 6 all significantly reduce the potential for
future migration of contaminants by limiting water infiltration, animal intrusion and cover erosion. Each
of these alternatives contains a drainage layer to ease the flow of water, thus minimizing infiltration
through the low permeability layer(s). Each contains a barrier to prevent animal intrusion, and
subsequent water infiltration through animal burrows. Alternatives 3 and 4 would probably provide more
effective long-term protection than Alternative 2. since a clay liner is more permeable. Alternative 4
would probably provide slightly more protection Against long-term infiltration than Alternative 3, because
a synthetic liner is typically less permeable than a bentonite mat. Alternatives 5 and 6 are expected to
provide the highest degree of long-term protection against water infiltration. Alternative 6 is probably
slightly superior to Alternative 5 and would provide better protection against the.infiltration of water for
the design life of the synthetic liner and bentonite mat. Migration of contaminants could occur under all
alternatives with time since the contents of the dump would be left in place, and because the cap and
cover system would fail over time. However, proper construction and continued maintenance of the cap
and cover system would maintain its integrity.
i .
Reduction of Toxicity, Mobility, and Volume. This criterion refers to the anticipated
performance of the treatment technologies that may be employed in a remedy.
Alternative 1 would not achieve a reduction in toxicity, mobility or volume of the contaminants.
Alternatives 2, 3, 4, 5, and 6 all minimize the infiltration of water into the Building 103 dump, thereby
reducing the mobility of the contents of the dump. None of the alternatives would reduce the toxicity
or volume of the contaminants since the waste would remain hi place. Alternatives 5 and 6 are expected
to reduce contaminant mobility and water infiltration more man Alternatives 2, 3, and 4 because two
impermeable liners are used in the design. Since alternatives 5 and 6 contain two impermeable layers (a
synthetic liner which is essentially impermeable, supplemented by a low permeability base) there would
be almost no infiltration of water through the cap. Alternative 4 is more effective than Alternative 3 in
reducing contaminant mobility, since a synthetic liner is less permeable than a bentonite mat if properly
installed, and consequently would permit less water infiltration. Alternative 3 is more effective than
Alternative 2 in reducing contaminant mobility since the high swelling ability of the bentonite mat
provides for extremely low permeability, and exceptionally uniform permeability. None of these
alternatives should be considered irreversible because waste treatment is not associated with any
alternative.
Short-Term Effectiveness. This criterion refers to the period of time needed to achieve
protection, and any adverse impacts on human health and the environment that may be posed during the
construction and implementation period until clean-up goals have been achieved.
Alternative 1 has no short-term impacts because no remedial actions would be performed under
this alternative. Alternatives 2, 3, 4, S, and 6 would all require approximately the same amount of time
to implement after signing of the ROD. The time to implement depends on factors such as contractor
availability, availability of equipment, and weather conditions. Alternatives 3 and 4 would require the
least time to complete, followed by Alternative 6. Because they have a clay layer, Alternatives 2 and S
would take the longest time to complete.
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Final
February 28, 1995
There would be no short-term impacts to nearby communities under any of the alternatives due
to the location of the site. Short-term impacts to government employees, military personnel, on-site
workers, and the environment are expected to be minimal under Alternatives 2, 3, 4, 5 and 6. Personnel
at or near the site could be subjected to construction-related impacts such as noise, dust, and particulates
under all alternatives. This exposure is expected to be minimal. Exposure of personnel to site
contaminants would be controlled with protective clothing, spraying of work areas with water to minimize
dust generation, appropriate training, and through the use of air monitoring devices. Personnel exposure
through dermal contact and/or inhalation of contaminants is not anticipated since there will be no
excavation of the dump. No protected species or sensitive land areas are expected to be affected during
remediation.
Transportation of hazardous materials is not expected to be necessary under any of the
alternatives.
Personnel working in Buildings E5422, E5427, and ES265 would experience construction-related
impacts (such as noise, dust and particulates) under all alternatives. For these reasons, it will be
necessary to relocate the Technical Escort Unit while construction is taking place. Also, it may be
necessary to close both Hoadley Road and Williams Road at certain times during construction.
Implonentability. This criterion describes the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to implement the chosen solution.
Alternative 1 has no technical feasibility considerations. The technical implementability of
Alternatives 2, 3, 4, 5 and 6 is excellent. Capping is a well developed technique that has been used at
many sites as both a final and as an interim action. The required labor, materials, and equipment
necessary to implement all these alternatives is readily available-. Conventional construction equipment
and techniques would be used to implement all alternatives.
Alternatives 2 and 5 would be more difficult to implement than Alternatives 3,4, and 6 since they
require the construction of a compacted clay layer. Alternatives 3,4 and 6 require either a synthetic liner
and/or bentonite mat, both of which are quicker and easier to install than compacted clay liners under all
weather conditions. Extreme weather conditions might cause delay in implementation of Alternatives 2
and 5, since compacted clay should not be installed during wet and/or freezing weather. This restriction
does not apply to geosynthetic membranes, since they are much more resistant to freeze/thaw and
hydration/desiccation cycles.
An important technical consideration for this site is the final height of the cap with respect to the
surrounding terrain. Height must be minimized due to the close proximity of roads and surrounding
buildings. This is best achieved by using bentonite and/or a synthetic membrane in the cap, since these
materials minimize the infiltration of water and thickness. Alternatives 3, 4, and 6 are superior to
Alternatives 2 and 5 from a design standpoint since they result in a thinner cap than Alternatives 2 and
5. Alternatives 3 and 4 are superior to Alternative 2 since they are somewhat thinner. Alternative 6 is
thinner than Alternative 5. Alternative 6 is superior to Alternatives 3 and 4 since it provides double the
protection for almost no increase in thickness.
With respect to administrative feasibility, Alternative 1 would be the most difficult to implement
because of its unacceptability to regulatory agencies and the public. Alternatives 5, and 6 would probably
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Final
February 28, 1995
be more acceptable than Alternatives 2, 3, and 4, because they provide more protection to human health
and the environment. Therefore, Alternatives 5 and 6 have a slight overall advantage over Alternatives
2, 3, and 4.
Cost. This criterion addresses the capital for materials, equipment, and the O&M costs. Revised
comparative costs are as presented in Table 3.
Table 3
Comparative Cost of Alternatives
Alternative
Alternative 2 (1 foot of clay)
Alternative 3 (bentonite)
Alternative 4 (geosynthetic)
Alternative 5 (2 foot of clay and
geosynthetic) .
Alternative 6 (bentonite and
geosynthetic)
Capital Cost ($)
1,438,531
1,388,805
1,436.417
1,668,520
1,507,836
O& M Costs ($)
4,730
4,730
4.730
4,730
4,730
Present Worth ($)
1,511,243
1,461,517
1.509,129
1,741,232
1,580,548
Regulatory Agency Acceptance. This criterion indicates whether, based on their review of the
Focused Feasibility Study, Proposed Plan, and the Record of Decision, the EPA and Maryland
Department of the Environment concur with, oppose, or have no comments on the Selected Remedy.
EPA, Region in and MDE both concur that Alternative 6 is protective of human health and the
environment.
Community Acceptance. Community interest in this proposed action at Building 103 has been moderate
compared to other actions at APG. Most of the interest and comments were from one community group,
the Aberdeen Proving Ground Superfund Citizen's Coalition (APGSCQ. APGSCC preferred that APG
conduct additional studies and gamer supplemental information before proceeding with an action.
APGSCC proposed APG take limited action with respect to the groundhogs at the site. While not
agreeing with APGSCC's conclusion mat APG should delay action, APG will be addressing APGSCC's
concerns. APGSCC's comments and APG's responses are contained in Section 3, Responsiveness
Summary.
APG's community involvement program has shown that citizens are concerned about ground
water quality and migration of substances from APG into off-post ground water. Therefore, APG does
not believe Alternative 1, No Action, would be acceptable to the community.
In general, comments from the community expressed no preference for one type of cap and cover
system over another (Alternatives 2, 3,4,5 and 6). Again, APG has received input from the community
that they are concerned that cleanup funds be spent prudently. While the cost of Alternative 6 is higher
than other capping alternatives, APG believes the community would accept the higher cost of Alternative
6 because it offers a high level of protection of public health.
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Final
February 28, 1995
The community is concerned about the existence of unexploded ordnance at APG and the handling
of ordnance during cleanup activities. APG believes the community will accept the short -term risks
associated with the capping alternatives as a trade-off for the long-term protection offered by the new cap
and cover system, provided that APG implement adequate safety procedures to protect site workers,
employees and residents.
The community would prefer a permanent solution which removes the buried waste to an off-site
location. They recognize, however, that current limited technology, high cost and human health risks
associated with the excavation of the waste materials and possible buried ordnance currently precludes
implementation of these options.
Selection of Remedial Alternative. The selected alternative is Alternative 6.
2.9 DESCRIPTION OF THE SELECTED REMEDY
Based on the requirements of CERCLA and the detailed evaluation of the alternatives, the Army
has determined that Alternative 6 (Install a Cap and Cover System in Accordance with RCRA
Requirements for Hazardous Waste Landfill Closure Using a Sodium Bentonite Geocomposite Mat and
a Geosynthetic Membrane) is the most appropriate alternative for the Building 103 dump operable unit,
and is therefore the selected remedy (see Figure 3). This alternative was selected because it is protective
of human health and the environment, feasible, and cost effective.
Alternative 6 involves the construction of a new multilayer cap and cover system in accordance
with MDE requirements for hazardous waste landfill closure (COMAR 26.13.05.14) and EPA design
recommendations (USEPA, 1985). The time to implement Alternative 6 is 12 months after having a
signed ROD. This cap and cover system will cover the full extent of the Building 103 dump as it is
currently known. Based on field work performed to date, this corresponds to an approximate area of 1.9
acres, and includes the grassy area adjacent to Building E5422, south of Williams Road, and west of
Hoadley Road, and east of the Building E5427 parking lot. Building £5422 and the parking lot will be
tied into the cap and cover system.
The Building 103 dump will be further investigated as part of the on-going Canal Creek RI/FS
to more fully characterize the risks posed by the dump. This investigation will indicate if further
remedial actions are required to fully address the Building 103 dump. Since waste will be contained on-
site, Alternative 6 has a periodic review requirement, at which time the effectiveness of this alternative
will be assessed and further remedial actions taken if necessary.
The design features of this cap and cover system will include:
An earthen material backfill cover (to include contaminated soil from Building 503 Soils
Operable Unit and non-hazardous drill cuttings from other APG-EA study areas) over the
existing cover.
Two feet of semi-permeable earthen material over the backfill cover, graded to achieve
a 4 percent topslope.
A sodium bentonite geocomposite mat with an in-place permeability of at least 10*7
cm/sec or less over the backfill material.
A geosynthetic membrane (minimum thickness 20 mil).
35
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Final
February 28, 1995
' A drainage layer with minimum permeability of 10"3 cm/sec.
A compacted cobble/gravel animal intrusion barrier.
A final earthen cover (up to 2 feet thick), with 4 percent topslope and vegetative cover.
Gas collection/filtration system installed at start of construction to control long-term
emissions.
Long-term storm water management (storm water drainage ditches and swales).
The earthen fill material used to backfill over the existing cover will include excavated soil/ash
from the Building 503 Soils Operable Unit and non-hazardous drill cuttings from other APG-EA study
areas. Due to the shallow burial depth of the waste and possible ordnance items, there will be no grading
of the existing dump cover. The additional fill material, when placed on the existing cover, will permit
the grading of a suitable slope without disturbing the contents of the dump, and will also dissipate
pressure and vibrations which might otherwise be transmitted to buried ordnance items, thereby reducing
the possibility of explosive detonation.
^ Final earth cover (2 feet ma-rimum)
^^"Cobble/gravel
Sand or geonet drainage layer (12 inches maximum)
Geosynthetic membrane (20 mil minimum)
ite *"**
'Gas conveyance layer
backfill (2 feet average)
Figure 3 Typical Cross Section for Alternative 6 (RCRA Cap Using Sodium Bentonite
Geocomposite Mat and Synthetic Membrane)
When the initial fill material (to include the soil/ash from the Building 503 soils operable unit)
has been graded, 2 feet of semi-permeable earthen material will be constructed on the backfill. A gas
conveyance layer will be installed on the backfill. A sodium bentonite geocomposite mat will then be
installed over the gas conveyance layer. A synthetic geomembrane (minimum thickness 20 mil) will then
be installed over the sodium bentonite geocomposite mat and anchored, followed by a drainage layer with
minimum perrne.: of 10'3 cm/sec. A compacted cobble/gravel animal intrusion barrier will then be
constructed over: Jrainage layer. Finally, a pervious cover layer of up to 2 feet of loamy top soil will
be constructed o\ the animal intrusion barrier. This top soil layer will be planted with a vegetative
cover to minimize .rosion.
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Final
February 28, 1995
A passive gas collection/filtration system and-lined perimeter trench will be installed .and tied into
the gas conveyance layer. Filtration will consist of whetlerite charcoal filters fitted to vent pipes. Any
chemical agent residue adsorbed onto charcoal filters is not classified as chemical surety material and will
be considered non-recoverable material. Used filters will be disposed of as hazardous waste through an
existing hazardous waste contract. Land ban restrictions do not apply to these filters.
Long-term storm water management includes the construction of storm .water drainage ditches and
swales around the perimeter of the dump. Run-on will be intercepted, and routed around the dump.
Appropriate warning signs will be placed at the dump, and use restrictions will be documented
on APG records and maps. An O&M manual will be developed as part of the 90% design. At a
minimum, the manual shall include provisions for repairs to the cap and cover system as necessary to
correct any settling, subsidence, and erosion effects, the cultivation of natural vegetation on the topsoii
to prevent erosion, the gas system, and five-year reviews under Section 121(c) of CERCLA, 42 U.S.C.
paragraph 9621 (c), because the Selected Remedy will result in contaminants remaining on-site.
i
The estimated capital cost and present worth for this alternative are $1,507,835 and $1,580,548
respectively, with annual O&M costs of $4,730 (see Table 4).
This interim remedial action will attain the following objectives:
Prevent infiltration of water into the Building 103 dump.
Prevent direct contact and inhalation of contaminants.
Prevent animal intrusion into Building 103 dump.
Ensure the cap and cover system will function with minimum maintenance.
Promote drainage of surface water, and minimize erosion of the cap and cover system.
Accommodate settling and subsidence so that cap integrity is maintained.
Provide for adequate collection/filtration of any gases produced by buried wastes.
2.10 STATUTORY DETERMINATIONS
The selected remedy satisfies requirements under Section 121 of CERCLA to protect human
health and the environment, comply with ARARs, be cost effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent practicable.
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Final
February 28, 1995
Table 4
.Capital Cost Estimate for Alternative 6
Item
Site Preparation
Landfill Cap
Perimeter Drainage System and Barrier Wall
Vent System
Perimeter Fence
Sediment/Erosion Controls
Storm Water Management System
Storm Sewer System
Site Restoration '
Construction
Subtotal
Construction Contingencies (20%)
Subtotal
Health and Safety Equipment (2.5%)
Total
Construction Cost
Engineering and Administration (15%)
Total
Capital Cost
Cost 1994 ($)
166,741 -
512,909
222,398
2,471
14,082
2,791
25,650
35.5%
83,347
1,065,988
213,197
1,279,185 -
31,980
1,311,165
196,674
1,507,835
Overall Protection of Human Health and the Environment. Alternative 6 provides an
extremely high degree of reliable long- and short-term protection to human health and the environment,
and meets or exceeds all ARARs. Since Alternative 6 contains both a bentonite mat and a synthetic
membrane, it greatly minimizes infiltration of water into the dump, thereby minimizing the migration of
contaminants out of the dump and into ground water. Alternative 6 also eliminates current and future
dermal and inhalation exposure risks. Currently, extensive settling of the waste and erosion of the cover
soil into the fill material is beginning to expose the contents of the dump. Also, there is considerable
animal intrusion into the dump, which permits direct infiltration of water, and promotes further settling
of the contents. Continued settling of die existing cover, erosion of the cover soil into the contents, and
animal intrusion increase current and future risks. Alternative 6 does not involve excavation of the
Building 103 dump contents; therefore, there will be no risk of human exposure to chemical agent
residues in process vessels or buried chemical ordnance (by leak or detonation). Therefore, this
alternative is considered to offer an extremely high level of overall protection to human health and the
environment.
Compliance with ARARs. Even though disposal activities occurred at the Building 103 dump
long before the enactment of the RCRA Subtitle C requirements, RCRA and MDE requirements are
relevant and appropriate to construction of the cap and cover system. Alternative 6 meets both RCRA
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February 28, 1995
requirements for hazardous waste landfill closure, and MDE requirements for industrial landfill closure.
Placement of non-hazardous drill cuttings from other APG-EA study areas, and of contaminated
soil from the Building 503 Soils Operable Unit at the Building 103 dump is authorized under the
provisions of the CAMU rule set forth at 58 Fed. Reg. 8679, which authorize the on-site consolidation
of wastes. The Army does not need a permit or waiver from MDE in order to include the non-hazardous
drill cuttings or contaminated soil/ash from the Building 503 Soils Operable Unit as part of the fill
material. Continued ground-water monitoring shall be performed at the Building 103 dump in accordance
with Maryland Standards for Owners and Operators of Hazardous Waste Treatment, Storage and Disposal
Facilities (COMAR 26.13.05.06)
There will be increased runoff under Alternative 6. In accordance with Section 121(e)(l) of
CERCLA and 40 CFR, Section 300.400(e)(l), no Federal, State, or local permits are necessary for
CERCLA on-site response actions. Consequently, a Maryland discharge permit for storm water systems
will not be required. However, all substantive requirements of such a permit must be met. Alternative
6 would minimize erosion and control sediment run-off as required by Maryland Erosion and Sediment
Control Regulations (COMAR 26.09.01) and Maryland Storm Water Management Regulations (COMAR
26.09.02). '
The gas collection/filtration system to be installed would meet U.S. Army regulations (CRDEC
Regulation 385-1) for effluent air concentrations for hazardous chemicals, and comply with the Clean Air
Act and Maryland Air Pollution Control Regulations (COMAR 26.11.06 and 26.11.15). There will be
no air emissions after completion of the cap and gas collection/filtration system. LDR restrictions do not
apply to spent gas collection/filtration system filters.
Since alternative 6 may result in paniculate emissions to air and noise, it will comply with
Maryland State Adopted National Ambient Air Quality Standards and guidelines (COMAR 26.11.03),
Maryland State Ambient Air Quality Standards (COMAR 26.11.04), Maryland General Emissions
Standards, Prohibitions, and Restrictions (COMAR 26.11.06), the National Emission Standards for
Hazardous Air Polutants (NESHAPS) (40 CFR Part 61) and Maryland Noise Pollution Regulations
(COMAR 26.02.03). There will be no air emissions after completion of the cap and gas
collection/filtration system.
Alternative 6 will meet with all substantive requirements for all ARARs listed in Table 5. There
are no chemical-specific ARARs relevant to this remedy.
Long-Term Effectiveness. Alternative 6 provides a very high degree of reliable, long-term
protection to human health and the environment. Synthetic liners typically are assumed to have a design
life of approximately 20 yean. Sodium bentonite mats are generally assumed to have a design life of 25
years.
Containment of the waste with alternative 6 significantly reduces long-term risks due to the
leaching of contaminants into ground water. A limited potential for leaching will still exist with this
alternative because the waste material will remain in place. However, proper maintenance and routine
inspections of the cap system will significantly reduce the magnitude of any damage to the cap. The
Army is required to maintain the cap and cover system. Since waste will be contained on-site,
Alternative 6 has a periodic review requirement, at which time the effectiveness of this alternative will
be assessed and further remedial actions taken if.necessary.
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February 28, 1995
Table 5 Review of Potential Action-Specific and Locational ARARs for the Building 103
Dump Selected Remedy
Environmental Laws and Regulations'
ACTION SPECIFIC
I. RCRA
A. Subtitle C Requirements
1. Closure and Postclosure
(40 CFR Part 264, Subpart G)
n. U.S. Army Corps of Engineers
A. Clean Water Act Requirements Section
404 Nationwide Permits
(33 CFR Part 330, Appendix A #38)
m. Clean Air Act
A. National Emission Standard for
Hazardous Air Pollutants (NESHAPS)
(40 CFR Part 61, Subpart WO
IV. U.S. Department of Transportation (DOT)
Regulations (49 CFR Parts 170-179)
Consideration as an ARAR
Waste materials will be contained in place,
requiring a cover.
The Nationwide Permit for NPL Site is
exempt under CERCLA.
The selected remedy involves, earthmoving
equipment operations that may result in
emissions to air.
Contaminated waste materials could be
transported off-post under the selected remedy
V.
State of Maryland
B.
Maryland Noise Pollution Regulations
(COMAR 26.02.03).
Maryland of Water Supply, Sewage
Disposal and Solid Waste Regulations
(COMAR 26.04.04)
Maximum allowable noise levels shall not be
exceeded at the dump property boundaries
during construction ana operation.
Establishes requirements for well construction
and abandonment. Wells at the dump site
will have to be either modified or abandoned.
C. Maryland Sanitary Lmdfill Closure
Regulations
(COMAR 26.04.07.21)
D. Maryland Erosion and Sediment
Control Regulations
(COMAR 26.09.01)
E. Maryland Stormwater Management
Regulations
(COMAR 26.09.02)
F. State Adopted National Ambjent Air
Quality Standards and guidelines
(COMAR26.il. 03)
G. Maryland Air Quality Regulations
(COMAR 26.11.06)
This regulation provides design requirements
for the closure (capping) of sanitary and
industrial landfills.
Excavation and backfilling activities may
cause increased erosi9n and sediment runoff
requiring the application of control measures
during the selected remedy.
Stormwater shall be managed during and after
construction.
The selected remedy involves earthmoving
equipment operations that may result in
emissions to air.
These regulations apply to emissions from the
landfill gas collection/filtration system.
40
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Table 5
Final
February 28, 1995
Review of Potential Action-Specific and Locational ARARs for the Building 103
Dump Selected Remedy
H.
I.
J.
and Regulations'
Maryland Standard for Toxic Air
Pollutants
(COMAR26.il. 15)
Maryland Standard for Owners and
Operators of Hazardous Waste
Treatment, Storage, and Disposal
Facilities.
(COMAR 26.13.05.06)
Maryland Standards for Hazardous
Waste Treatment, Storage, and
Disposal Facilities
(COMAR 26.13.05.14J)
Consideration as an ARAR
The selected remedy involves earthmoving
equipment operations that may result in
emissions to air.
Ground-water monitoring will be performed
at the site.
Design and operating requirements, closure
and post-closure care for hazardous waste
landfills.
LOCATION SPECIFIC
I. RCRA
A.
Subtitle C requirements
1.
Location standards
(40 CFR Part 264, Subpart B)
n.
Statement of Procedures on Flood Plain
Management and Wetlands Protection
(40 CFR Part 6, Appendix A, and
Executive Orders 11988 and 11990)
U.S. Army Regulations (CRDEC Regulation
385-1)
1. Note: Substantive requirements must be met.
Portions of streams downgradient of the site
may be located within the 100-year flood
plain, though none are located in a seismic
area, as denned by the regulations.
Site is not located within 100-year flood
plain.
This regulation applies to emissions from the
landfill gas collection/filtration system.
Reduction of Toxichy, Mobility, and Volume. Alternative 6 will significantly reduce
contaminant mobility by greatly minimizing water infiltration. No reduction in toxicity or volume of
contaminants will be achieved because all wastes will remain in place. Leakage through the bentonite
mat and geosynthetic membrane will be minimal. Sodium bentonite mats typically have a low uniform
permeability, depending on surface pressure, while geosynthetic liners are essentially impermeable.
While there would be holes caused by installation of the liners and the gas vents. Careful installation will
minimize the number of holes. Typically, with stringent quality assurance procedures, it is assumed that
there are five holes/acre as a result of installation. There could also be leakage at the seams where two
synthetic liners are joined. However, Sodium bentonite is high swelling which means any holes or seams
where the bentonite mat is joined would be self-sealing to a great extent resulting in low uniform
permeability.
This alternative would not be considered irreversible because waste treatment is not associated
with it.
Short-Term Effectiveness. Construction activities associated with this alternative are not
expected to affect nearby communities. However, APG-EA employees and military personnel will be
impacted to some extent by construction activities. Personnel working in Buildings E5422, E5427, and
E5265 will be subject to construction-related impacts. It may be necessary to close both Hoadley Road
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February 28, 1995
and Williams Road at certain times during construction and traffic temporarily rerouted. Exposure of
government workers to dusts, noise and particulates is expected to be minimal. Construction related
impacts on human health would be expected to affect mainly workers at the" dump. Worker exposure
through dermal contact and/or inhalation of contaminants is not anticipated since there will be no
excavation of the dump. No protected species or sensitive land areas will be affected during remediation.
Also, transportation of hazardous materials is not expected to be necessary. The time to implement this
alternative is expected to be approximately six months after signing of the ROD.
Cost-effectiveness. The estimated capital cost for implementation of Alternative 6 is $ 1,507,835
with annual O&M costs of $4,730 for the first year. The net present worth of this alternative, evaluated
over a period of 30 years at a discount rate of 5 percent is $ 1,580,548. The total capital cost is shown
in Table 5.
Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)
Technologies to the Maximum Extent Practicable. The Army has determined that the selected remedy
represents the maximum extent to which permanent treatment technologies can be utilized in a cost
effective manner for remediation of the Building 103 dump.
The most permanent solution would be to remove the source of the waste from the Building 103
dump, and place the waste in a secure landfill. The other alternatives do not address the potential for
continued migration of contaminants to ground water. The capping alternatives would reduce the mobility
of contaminants at the Building 103 dump, but would not reduce the toxicity Or volume of the
contaminants because the waste would remain on site. Excavation would remove the waste from the
Building 103 dump, thus providing the greatest reduction of toxicity, mobility and volume. However,
the responsibility for the waste is merely transferred to another location with mis alternative. The size
of the Building 103 dump, hazards associated with excavation of the dump, and excessive costs associated
with the excavation alternative preclude a remedy in which contaminants can be excavated and treated
effectively. The capping alternatives provide a greater level of short term effectiveness than the
excavation alternative because the waste would remain in place and would not pose an increased threat
to human health and the environment. Also, the capping alternatives are much less costly than the
excavation of the Building 103 dump. Of the capping alternatives, alternative 6 is the most cost effective,
implementable, and protective of human health and the environment.
Preference for Treatment as a Principal Element. None of the capping alternatives employ
treatment because no treatment technologies are currently available that would eliminate the risks in a
cost-effective manner. The selected remedy is the most cost effective and technically feasible approach
to eliminate the risks posed by the dump. This remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable for mis site. However, because treatment of
the principal threats for the dump was not found to be practicable, this remedy does not satisfy the
statutory preference for treatment as a principal element of the remedy. The size of the Building 103
dump, and the risk and excessive costs associated with the excavation of the Building 103 dump, preclude
a remedy in which the contaminants could be excavated and treated effectively. The selected remedy is
consistent with the Superfund program policy of containment (40 CFR § 300.430), rather than treatment,
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Final
February 28, 1995
for wastes where removal and treatment is impracticable.
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES
During discussions at the public meeting, the dump was' estimated to have an area of about 1.7
acres. Field work described at the public meeting was performed in 1994 at the Building 103 dump as
pan of the Canal Creek RI/FS. This now completed field work indicates that the Building 103 dump
extends under Building E5422, and has an area of about 1.9 acres. The depth of waste in the Building
103 dump varies, with a maximum depth of about 19 feet below grade. A passive soil gas survey
conducted at the Building 103 dump indicated that the dump may be emitting low levels of organic
vapors. Since the Building 103 dump is larger than previously thought, and since Building £5422 rests
on the dump, the lined perimeter trench and gas collection system will have to be constructed on three
sides of Building ES422, so that the building can be effectively tied into cap and cover system. Building
E5422 will also have to be shored to prevent collapse. This shoring, and the relocation of utility lines
on the east side of the dump will increase the cost of this interim remedial action. The revised costs for
all alternatives based on the new field data are provided in this ROD. The selected remedy is still the
preferred alternative from the Proposed Plan. If during design and construction of the cap and cover
system it becomes necessary to remove Building ES422, this would result in cost savings.
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February 28, 1995
SECTION 3
RESPONSIVENESS SUMMARY
The final component of the Record of Decision is the Responsiveness Summary. The purpose
of the Responsiveness Summary is to provide the public with a summary of citizen comments, concerns,
and questions about the Building 103 dump and the EPA's and the U.S. Army's responses to these
concerns. During the public comment period from May 4 to June 24, 1994, on the Focused Feasibility
Study and Proposed Plan for the Building 103 dump in Edgewood Area of APG, written comments,
concerns, and questions were received by the Army. No comments, concerns, and/or questions were
received by the EPA and/or the MDE. A public meeting was held on May 24, 1994, to present the
Proposed Plan, and to answer questions and to receive comments. Several technical questions were
answered during the public meeting regarding the conduct of the investigation, and written comments and
concerns were received at the meeting and during the Comment Period. The transcript of this meeting
is part of the administrative record for this operable unit. Public comments received by the Army are
discussed below.
i
This responsiveness summary is divided into the following sections:
Overview
Background on Community Involvement
Summary of Comments Received During Public Comment Period and Agency Responses
Panel of experts
Selected newspaper notices announcing dates of public comment period and location/time
of public meeting
This responsiveness summary gives the comments on the Proposed Plan by interested parties, and
provides the Army's responses to the comments. All comments and concerns summarized below have
been considered by the EPA in making a decision regarding the selection of the selected alternative for
the Building 103 dump. Additionally, the Army and EPA are proposing with the issuance of the Record
of Decision to continue investigating the Building 103 dump as part of the on-going Canal Creek RI/FS.
The results of this investigation will be incorporated into the on-going Canal Creek RI/FS and Canal
Creek Area ROD.
3.1 OVERVIEW
At the time of the public comment period, the Army had already endorsed a preferred alternative
for the Building 103 dump. Both the U.S. EPA and the MDE concurred that the preferred alternative
is protective of human health and the environment, since it will minimize infiltration into the dump, and
subsequent leaching of contaminants into ground water. The preferred alternative in this ROD consists
of the following: Install a cap and cover system in accordance with RCRA requirements for hazardous
waste landfill closure using a sodium bentonite geocomposite mat and a geosynthetic membrane, and a
filtration system to collect any vented gas.
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Final
February 28, 1995
3.2 BACKGROUND ON COMMUNITY INVOLVEMENT
APG implemented significant opportunities for public involvement in the Building 103 dump.
Major events are summarized below:
APG briefed the scope and role of this operable unit to the Technical Review Committee
on July 29, 1993, and on January 27, 1994. Representatives were also given a tour of
the dump site.
APG released the Focused Feasibility Study (FFS) (Battelle,. 1994), Proposed Interim
Remedial Action Plan (Battelle, 1994), and background documentation for the Building
103 dump to the public for comment in May 1994. These documents were made
available to the public in the local information and administrative record repository at the
Aberdeen Public library, Edgewood Public library, Miller College library, and Essex
Community College library. APG also established an information repository at the
TECOM Public Affairs Office in accordance with the Federal Facility Agreement
between EPA and APG.
APG issued a news release announcing the availability of these documents to APG's full
media list.
APG placed newspaper advertisements on the availability of these documents and the
public comment period/meeting in the APG News on May 4,1994, in the Aegis on May
11, 1994, and in the Harford County edition of the Baltimore Sun newspaper on May 8,
1994.
APG established a 45-day public comment period from May 4, 1994, to June 24, 1994,
on the scope and role of the proposed interim remedial action.
APG prepared and published a fact sheet on each item in the Proposed Plan and delivered
it to on-post buildings close to the site and on-post libraries; APG mailed copies to its
Installation Restoration Program mailing list.
APG conducted a poster session and public meeting on May 24, 1994 at the Chemical
and Biological Defense Command conference center (Building £4810) at APG-EA.
Approximately 35 people attended including citizens, advisors and members of the APG
Superfund Citizen's Coalition, and Federal, State and local Government representatives.
Representatives of the Army, EPA, and the MDE answered questions about the proposed
interim remedial action at the Building 103 dump, and the cap and cover system remedial
alternatives under consideration.
Responses to comments received during this period are included in the Responsiveness
Summary which is part of this ROD.
- In a letter dated June 24, 1994, community members expressed concern about
the lack of data, and recommended that the groundhogs currently inhabit the
dump be removed, mat existing holes be plugged to prevent infiltration, and that
the dump be investigated further to determine if it is indeed a contaminant
source.
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Final
February 28, 1995
3.3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AM) AGENCY RESPONSES
COMMENT SET 1 received from concerned Joppa, MD citizen.
Note: Comment* pertaining to the Building 503 Soils Operable Unit hive been included because that soil will be used as fill under the cap for
the Building 103 dump.
Ladies and Gentleman, Distinguished Guests, and Concerned Citizens:
Although I agree with the U.S. ARMY'S remedial action at BLDG 503 to remove white
phosphorous contaminated soil,! have several questions concerning the approach to this
decision and the additional hazards that I feel will be created due to these actions.
Comment 1 Will any steps be taken to reduce the dust created during the excavation
process (i.e., watering or dampening)?
Response Yes. Various dust control procedures are being evaluated, including foams
and biodegradable vegetable gums. A Work Plan and Health & Safety Plan will be
written prior to beginning remediation. The Work Plan will detail the procedures which
will be implemented to protect the health and safety of on-site workers and off-site
personnel during the excavation of the soil and ash at the Building 503 burn sites. The
Health & Safety Plan will also specify all measures which will be taken to minimize
adverse health effects to on-site workers. It will require activities such as observation
and monitoring of dust levels and provide for application of dust control procedures as
needed.
Comment 2 Will the contaminated soil be containerized prior to movement to the Bldg.
103 site?
Response The contaminated ash and soil probably will be contained in a roll-off box or
truck bed. The current design concept is to excavate the ash and soil with a backhoe or
front-end loader, and drop it directly into a truck for transport across the road to the
Building 103 dump. The truck will be fitted with spray nozzles to dampen the soil and
ash as it is being dumped to prevent dust generation. The box or bed will be lined with
plastic sheeting. Once the box or bed is filled, the ash/soil will be covered with plastic
sheeting so the truck will be covered while in transit. These provisions will control the
escape of particulates during the short move from Building 503 to the Building 103
dump.
Comment 3 How will construction personnel know if an existing cylinder or UXO
currently buried beneath the surface of Site 103 has been ruptured do to vibration and the
weight of heavy equipment.
Response Continuous air monitoring for volatile organic compounds and chemical agents
will be conducted during the construction activities at the Building 103 dump to warn
personnel of any airborne release.
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Final
February 28, 1995
Comment 4 What safety precautions are being taken to contain any spillage or air
release of hazardous materials due to the rupture or detonation of UXO's at the BLDG
103 site?
Response Both conventional and chemical ordnance items are frequently encountered
during construction activities at APG. Though historical files were researched, the lack
of data make it impossible to determine if ordnance items are present in the building 103
dump, and the possibility of ordnance items being present in the dump cannot therefore
be ruled out. Explosive components in munitions include fuzes, supplementary charges
such as boosters, and bursters. Fuzes contain the primary and most sensitive explosives
that form the explosive train. The fuse may also contain a booster, the second most
sensitive explosive that is usually needed to detonate the main fill in an high explosive
(HE) munition. In chemical, and smoke munitions, the booster charge is replaced with
a burster tube that is used to open the munition casing, scattering the inside fill over a
wide area. Fuzes are the initiating element of the explosive train that detonates either the
booster or the burster charge. A booster charge, as stated above, ignites the main
explosive charge in HE'filled munitions. The burster charge in chemical munitions is
usually shaped like a long cylindrical tube and is found within the longitudinal center of
the munition surrounded by the chemical agent fill. The burster is the main explosive
charge responsible for scattering the munition contents.
No special safety precautions are being taken to contain spillage since the waste contained
in the dump is not being excavated.
A safety precaution being taken to prevent the detonation of possible buried unexploded
ordnance items is the spreading of fill dirt on the dump to dissipate the weight of
personnel and equipment. Buried ordnance is subject to loads, which depend on munition
diameter, depth of burial unit weight, and frictional characteristics of the soil. While
heavy equipment and increased backfill height will produce additional loads on buried
ordnance, the additional vertical pressure dissipates laterally with depth in underlying soil
and is not transmitted directly to ordnance item(s). Thus, only a portion of the additional
pressure is transmitted to buried ordnance. The more fill is put down, the more the load
is dissipated laterally. To further reduce this load, grading equipment equipped with
wide tracks or tires will be used. Since pressure is defined as force per unit area, this
will distribute the weight over a wider area, further reducing the point load. The fill
material will be placed on the dump starting at the dump perimeter, and then will be
graded towards the center.
The additional fill material also has the added benefit of containing detonations which
may occur. The detonation may break the surface of the dump, and may affect other
buried ordnance causing sympathetic detonations. The main factors in determining
whether the explosion will break the surface are the amount of explosive and the depth
of the ordnance item(s). If sufficient soil is present to absorb the energy released, then
the explosion will be contained. This principle is used in in-situ emergency techniques
for the destruction of single munitions. For example, single munitions encased in a
plenum chamber filled with venniculite or some other material can be safely detonated;
the explosion is totally contained since the venniculite absorbs the energy released (shock
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wave, heat, expanding gas). Another in-situ emergency technique is "massive
encapsulation/burial." With this technique, the munition is buried under a mound of soil,
which then absorbs the energy of the explosion.
It is unlikely that the additional load transmitted through soil would initiate a burster
explosion in a non-fuzed munition since the casing is directly subjected to the load, and
not the burster tube. The additional load might crack/deform the casing, however. It
is unlikely that an unfuzed burster will detonate due to additional pressure effects caused
by earth-moving equipment or the added weight of a cap since the burster requires the
fuse to initiate the secondary explosion. Bursters are relatively insensitive to shock.
Considerable corrosion will have occurred in any munitions buried in the dump, which
will reduce wall strength, open seams, reduce threads, and allow water to seep in and the
contents to leak. Chemical reactions will have occurred between the explosives,
surrounding media and metal. Such reactions can form hazardous/sensitive components
which are heat-and-shock sensitive. Fuzes in particular may contain small quantities of
"sensitized" primers and detonators. It is conceivable that low-frequency vibrations of
heavy equipment could be sufficient to detonate such age-sensitized fuzes in shallow
buried munitions. Vibratory compaction equipment could have a similar effect. To
minimize such low-frequency vibrations, non-vibratory compaction equipment will be
used and the use of heavy grading equipment minimized until sufficient backfill has been
put down. Also, since there is waste (such as the BBC tank that was emptied and the
void filled with sand) close to the surface, grading will not take place on the original
cover, and will commence only when sufficient backfill material is present.
Finally, an EOD team will be standing by during construction activities. All work will
be preceded by a magnetometer sweep by EOD personnel of the entire work area. This
will reduce the possibility of running over ordnance buried just beneath the surface, and
uncovering already leaking rounds or rupturing intact rounds during operations.
Comment 5 What are the trade-offs of depositing the white phosphorous contaminated
soil off-post instead of creating or adding to an existing hazard across the street at the
Bldg. 103 site?
Response While some white phosphorous munitions were probably tested and/or
disposed of at the Building 503 burn sites, the main contaminants of concern at the
Building 503 burn sites are lead, zinc, hexachlorobenzene, and hexachloroethane.
Placement of the soil and ash from the Building 503 bum sites under the Building 103
dump cap and cover system will not create an additional hazard since the soil and ash
will be contained under the cap and cover system. Placement of the soil and ash under
the cap will provide a cost-effective way to reduce the potential for adverse effects from
the Building 503 soil and ash without transferring the problem, and it allows the Army
to retain control of its waste. Also, it will reduce the distance over which the
contaminated material must be transported, and will reduce the risk of transportation
accidents and public exposure to the contaminants as a result of transportation accidents
or release during transportation. Finally, the effectiveness of this action will be
monitored as part of the monitoring program of the Building 103 cap and cover system.
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This monitoring program will determine if further remedial actions need to be undertaken
at a later date.
Comment 6 I feel that the Army's role is to cleanup existing hazardous waste, and not
to create or add to others. I also feel that due to the instability of UXO (unexploded
ordnance) and buried canisters of unknown substances at Bldg. 103, a more hazardous
situation exists, not only for the construction workers who are in direct danger, but the
community as a whole.
Response Containing the waste under the cap and cover system at the Building 103
dump is protective of both human health and the environment. The construction of a cap
and cover system over the dump will help contain the waste in the dump and will reduce
migration to ground water. The contaminated ground water .associated with the dump
will be addressed separately. By excavating the soil and ash at the Building 503 burn
sites and then transferring the soil and ash to the Building 103 dump, the Army is
remediating the Building 503 burn sites. The Army is not creating additional waste
through this action. The'Army is attempting to consolidate waste from different areas into
a single waste management unit, at which waste can be more easily contained, and the
effectiveness of the remedial action monitored. Moving the contaminated ash and soil
from the Building 503 sites to the Building 103 dump and covering it will eliminate the
current risks posed by the ash and soil, and will reduce the potential for contaminants to
move from the ash and soil to ground water. Capping will reduce the potential for
contaminant migration from both the ash and soil and from wastes in the dump.
The Army concurs with the comment that a more hazardous situation would exist for on-
site workers and off-site personnel if the dump were to be excavated, since excavation
of the dump would greatly increase the risk of detonation of buried unexploded ordnance
with subsequent chemical release.
Thank You
COMMENT SET 2 received May 19, 1994, from technical advisors to the APG Superfund Citizen's
Coalition who are associated with the University of Maryland Program in Toxicology.
Comments on Assessment of the Potential for Interaction Between Building 503
Ash/Soil and Building 103 Dump Contents, April 15,1994.
This brief treatise'concludes that the potential for undesirable interactions between the
chemicals present in the ash/soil of the Building 503 pilot plant burn sites and the
Building 103 dump is remote. Overall, the conclusions reached in this document are
valid, due primarily to the fact that the chemicals in the 503 ash/soil will be present in
low concentrations, particularly after they are mixed with uncontaminated soil. It may
be possible to further insure that interactions do not occur, however, through
consideration of the following comments and questions.
Comment 1 What would be the approximate ratio of the mix of 503 material with
compacted earthen material? What would die overall "dilution" of the chemicals of
concern be?
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February 28, 1995
Response The approximate expected volume of contaminated soil and ash from the
Building 503 burn sites is 470 yd3. The planned thickness for the subbase for the cover
over the Building 103 dump is at least 2 feet. The approximate area to be covered by
the subbase is 55,600 ft2. The total estimated volume of subbase fill is approximately
111,200 ft3 (4,120 yd3). The approximate volume ratio of burn area soil and ash to off-
site fill is 0.129. This does not include the additional material placed over the subbase
to form the cap and cover.
Comment 2 Since the acidity of the soil is an important determinant of the mobility of
the metals, will the pH of the soil mix be determined? Could lime be added to neutralize
the soil if necessary? Would conditions in the dump favor an acidic environment?
Response In general, pH adjustment to neutral or slightly basic conditions will reduce
metal mobility. Most metals form positive ions in solution and tend to be more soluble
and less well sorbed under acidic pH conditions in soils. However, unless carefully
controlled, lime addition could actually increase metal mobility. The minimum solubility
point occurs at a different pH for each metal. The minimum solubility points for typical
metal hydroxides cover a range between 7.5 to 11 (U.S. EPA, 1993). With a mixture
of metals, the pH adjustment point must be carefully selected and controlled to ensure
optimum immobilization. Immobilization by lime addition should not be required and
might prove detrimental for some metals. Primary containment is provided by the cap
and cover system.
Comment 3 The first complete sentence on page 4, paragraph 1 is unclear. What would
the volume of the material influence the reducing conditions?
Response The word "volume" was intended to mean space in general, and not the actual
measured volume. The sentence should have been more clearly phrased such as "The
electrochemical conditions in the material under the cap will not be sufficiently reducing
to favor conversion of zinc, iron, aluminum, or cadmium to metals."
Comment 4 What is the temperature under the cap likely to be? Are there any data
from other caps that would allow a prediction of what temperature one might expect?
Response Because of the low degradation rate in a nibble landfill, and because the dump
has been covered for about 60 years, the temperature within the dump is most likely
similar to inert subsurface environments in this area, or about 55°- 60° F (13°-16° Q.
Also, soil within inches of the surface tends to track seasonal temperature variations.
Typically, the ability of soil to transport heat is sufficiently low that soil acts as an
insulator. Insulation due to the soil causes temperature variations to decrease as depth
increases. For example, a surface variation from 10° C to 30° C is damped to about 15°
C to 25° C at 1 meter depth. At depths below 3 meters, temperature variation is small,
and the soil temperature tends to be close to 20° C (Hillel, 1982). The selection of 25°
C for calculation of the Eh-pH diagrams was based entirely on availability of free energy
data. However, 25 ° C should be a reasonably accurate representation of the temperatures
under the cap.
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Comment 5 Will the concentrations of carbonate and sulfides in the Building 103 dump
soil be determined, so Eh-pH diagrams can be constructed? Perhaps the earthen material
with which the 503 soil/ash material is mixed can be tested for carbonate and sulfide
concentrations and adjusted so as to favor an environment inducive to low mobility and
low reactivity of the metals.
Response Immobilization of the contaminants will be provided by the cap and cover
system. Additional reduction of mobility of some metals may occur due to a variety of
natural precipitation and sorption mechanisms. The carbonate and sulfide levels could
be measured and Eh-pH diagrams generated based on the in-situ composition. However,
adjustment of the soil chemistry with carbonate and/or sulfide is unlikely to add
significant additional immobilization. Therefore, these measures are dot planned.
COMMENT SET 3 received May 19, 1994, from technical advisors to the APG Superfund Citizen's
Coalition who are associated with the University of Maryland Program in Toxicology.
Comments on Proposed Plan Interim Remedial Action for Aberdeen Proving
Ground (APG) Edgewood Area, Maryland, Building 103 Dump (Immediately North
of Building E5422), April, 1994.
Comment 1 Pre-construction tasks include magnetometer sweeps to assess the presence
of ordnance in the Building 103 dump area (Page 8, column 2, para 3). How will the
magnetometer "hits" be verified to determine whether they are ordnance? What action
will be taken if ordnance are detected? To what extent will this entail digging down into
the dump itself? Will items other than ordnance that are uncovered by this digging be
removed from the dump area?
Response The purpose of the geophysical survey is to obtain as much information as
possible about the extent of the dump and the contents of the dump. The results of the
ground penetrating radar survey, when used in conjunction with the magnetometer
results, may make it possible to differentiate between buried objects and will give an idea
of the contents of the dump and .the location of possible ordnance. The location of
anomalies will be retained for future reference since this information could be valuable
if it is necessary to excavate the dump. Another purpose of the magnetometer sweep is
to verify the ground-penetrating radar for delineating the extent.of the dump. No
excavation will be performed as a result of information obtained during these activities,
and no waste will be removed from the dump.
Comment 2 Is there any indication of subsurface/gas/vapor generation at this time. If
so, what type of gas or vapor is present? What type might be expected to be released
in the future as the material in the dump deteriorates?
Response The only gas monitoring done to date at the Building 103 dump was
performed during the removal of bromobenzylcyanide residue from a buried process
vessel in 1992. No background gases/vapors were detected at the dump during that
removal action. A soil gas survey will be performed during the 30 percent design effort
at the Building 103 dump. The types of gases which would be expected to be released
would be minimal levels of methane due to the decomposition of previously
undecomposed organic matter, and possible vapors from leaking buried process vessels.
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February 28, 1995
Anything from solvent vapors to chemical agent vapors could be released, which is why
the soil gas survey is being performed. The soil gas survey will assess the type and
concentration. A gas collection treatment system will be installed to collect any gases or
vapors which could be released at future date under the cap. Any current ongoing
release is venting directly to the atmosphere, which is another reason for constructing the
cap and cover system.
Comment 3 How will the extent of the burrow system be assessed? (Page 8, column 2).
Response The extent of the burrow system will be assessed by a biologist who will
conduct a visual examination of the dump and the surrounding area. A more detailed
assessment is unnecessary since the cap and cover system will be designed to deter rodent
invasion.
Comment 4 What are drill cuttings? What areas of APG will they be from?
Response The term "drill cuttings" refers to the subsurface soil brought to the surface
when drilling holes in the ground, as for example, when installing wells. Drill cuttings
used as fill material will be certified non-hazardous soil from locations in the Edgewood
Area of APG.
Comment 5 The zinc and lead in the soil from the Building 503 site are said to be in
cationic form and thus are non*mobile (Page 9, Column 1, para. 2). Have leaching
experiments with this soil/ash been done? Under acidic conditions?
Response Lead teachability tests were performed on a number of samples as pan of the
Treatability Study performed in 1992, and as part of further characterization in mid 1993.
The leaching test applied in 1992 was the EP Toxicity Extraction test, and the leachability
test applied in 1993 was U.S. EPA SW-846 Method 1311. The commonly used name
for this procedure is the Toxicity Characteristic Leachability Procedure (TCLP). The
leaching fluid was an acetate buffer with an initial pH of 5. The pH after the extraction
period typically ranged from 5 to 6. The TCLP is currently the required method for
determining if a solid waste exhibits the hazardous characteristic of teachable toxicity
under the RCRA regulations (40 CFR 261.24).
Comment 6 Filters on the gas collection system will be retrofitted if necessary (Page
9, column 1, paragraph 3). What would be the cost of retrofitting compared to
installation of an active gas collection system at this time? Perhaps in the future, with
further decay of old drums, etc., the release of gas/vapors would significantly increase.
Are there any plans to analyze the gas vapors released from the dump on a routine basis
after the cap is installed to monitor for the gaseous chemicals not being given off now?
Response A cost benefit analysis of retrofitting the vents versus installing an active
system initially will be performed as part of the 30 percent design phase. No data are
yet available on this comparison. A preferred option of those being considered for the
gas venting system is to install carbon canisters on the vent outlets to adsorb any
gases/vapors released from the dump. The carbon filters will be replaced at regular
intervals. Apart from possible air monitoring, equipment to be installed in Building
E5422, there are currently no plans to actively monitor for gas/vapors.
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Comment 7 Will the perimeter fence be designed to help keep out groundhogs and other
burrowing animals? (Page 9, column 2, paragraph 3).
Response The perimeter fence was originally intended to keep people from walking on
the cap and cover system, and is an option for limiting access to the dump area. It may
or may not be included in the final design. Whether or not a fence is included will
depend on the outcome of further design efforts. If a fence is used, it will not be
constructed to deny groundhogs or other animals access to the dump. The cap and cover
system will be designed to serve that purpose.
Comment 8 In addition to maintaining the gas collection/treatment system, APG should
be responsible for monitoring the gas/vapor released from the dump on a scheduled
(perhaps every 6 months) basis.
Response See response for comment 6.
Comment 9 Since the caps proposed in the alternative action plans (#2-#6) have a finite
life expectancy of about 20-25 years, thought should be given to the "ease of
replacement" of these caps. Is there any significant difference between these caps in
terms of what actions would be required to replace them? Will the cap be replaced
automatically after 20 years, or will the cap be monitored for signs of deterioration? If
so, how?
Response Of the various Alternatives, Alternatives 2-4 are MDE industrial caps with a
single barrier layer. Alternatives 5 and 6 are RCRA caps with dual barrier layers. The
RCRA cap and cover systems are more protective than the industrial cap and cover
systems. Both RCRA cap and cover systems include geosynthetic membranes. A RCRA
cap (Alternative 6) is the selected alternative. Although clay layers would be easier to
replace than geosynthetics because of the anchoring requirements for geosynthetics
membranes, clay alone is not as protective as the dual system with geosynthetic.
Therefore, ease of replacement is secondary to protection of human health and the
environment, and is not the driving force for the design of the cap and cover system.
The cap will not be automatically replaced, but will be monitored on a regular basis for
signs of settlement and failure of the cap layer. Ground water under the dump will also
be monitored for changes in concentration of the contaminants.
COMMENT SET 4 received May 19, 1994, from technical advisors to the APG Superfund Citizen's
Coalition who are associated with the University of Maryland Program in Toxicology.
Comments on Proposed Plan - Interim Remedial Action for Aberdeen Proving Ground (APG),
Edgewood Area, Maryland, Building 503, Smoke Pilot Plant Burn Sites Operable Unit, April, 1994.
Comment 1 The proposed plan for excavating and relocating the contaminated soil/ash
from the 503 burn sites to the 103 dump where it would be placed under a RCRA cap
is both a cost-effective and human health protective remedial action step. The major
drawback to this solution is that its long-term effectiveness is not as great as that of
alternatives #2, 3, and 4 since the contaminated soil/ash remains on site at APG and will
need to be monitored in future years. Because this monitoring will coincide with that
established for the 103 dump site, the additional cost and effort should not be significant.
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It is imperative that not only the on-site workers but also APG employees working in the
area of the 503 burn sites be protected from the contaminated dust and particles that are
dispersed during excavation of this soil and its removal to the 103 dump site. How will
this be accomplished?
Response During excavation of the soil/ash, dust control measures will be used to
minimize dust dispersion. Some options currently being evaluated include spraying of
water, water with a soap-like substance, and water with biodegradable vegetable gum.
In addition, when the soil is dumped into plastic-lined trucks for transport, the trucks will
be fitted with spray nozzles to wet the soil as it is dumped to prevent dust dispersion.
The trucks will also be covered during transport. If the soil is stockpiled (for example
in roll-on roll-off containers), it will be covered with plastic sheeting, dust control foam,
or some other material to minimize dust generation. Also, this interim remedial action
will be conducted under a Health and Safety Plan so as to minimize adverse health effects
to on-site workers and off-site personnel. The plan will require established work areas
to control the spread of contaminants. The work area, which will have the highest
concentrations of'contaminants, is called the exclusion zone. The exclusion zone is
surrounded by a contamination control zone and a support zone. One or more
contamination reduction corridors will pass from the support zone, through the
contamination control zone, and into the exclusion zone. The contamination reduction
corridors allow controlled movement of personnel and equipment to and. from the
exclusion zone. Decontamination procedures will be set up in the corridor to minimize
uncontrolled movement of contamination out of the exclusion zone. Finally, monitoring
will minimize risks to on-site workers and off-site personnel.
Comment 2 What were the conditions used for the TCLP lead analyses? Did they
mimic a "worst case" situation as it might occur in the 103 dump site? This information
could be useful in predicting the teachability/reactivity of this material in its new
environment.
Response Lead teachability tests were performed using both the EPA Toxicity test and
the TCLP test. The TCLP is designed to simulate the disposal of solid waste in an
uncontrolled multiwaste landfill, and should be a reasonable reflection of worst case
conditions in the Building 103 dump. The TCLP analysis method is EPA Solid Waste
Procedure 1311 as described in SW-846, Test Methods for Evaluating Solid Waste. The
requirements of Procedure 1311 were followed for all analyses. Some specific features
of the procedure as applied to the Building 503 ash and soil samples are highlighted
below:
The TCLP includes special provisions for separating liquids and solids in
samples. These were not required since all samples were dry solids.
The TCLP includes special provisions for size reduction and screening. These
were not required since all samples contained particulates smaller than the
maximum allowed size of 9.5 mm.
The TCLP calls for a sample size of at least 100 grams. This is the sample size
used for the analyses.
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The TCLP extraction requires the use of one of two extraction fluids depending
on the alkalinity of the sample. Extraction fluid 1 contains 5.7mL of glacial
acetic acid and 64.3 mL of 1 normal sodium hydroxide mixed with water to
make 1 liter of fluid. The pH of extraction fluid 1 should be 4.93 ± 0.05.
Extraction fluid 2 contains 5.7 mL of glacial acetic acid mixed with water to
make 1 liter of fluid, the pH of extraction fluid 1 should be 2.88 ± 0.05.
Extraction fluid 2 is used for wastes with a pH over 5 and the ability to
neutralize a prescribed quantity of acid. None of the samples tested required the
use of extraction fluid 2.
The TCLP calls for the weight of extraction fluid used to be 20 times' the weight
of the solid material extracted. For all samples this translates to 2,000 grams (or
about 2 liters) of extraction fluid. This amount of extraction fluid was used in
each extraction.
COMMENT SET 5 received June 23, 1994, from the Executive Director, Aberdeen Proving Ground
Superfund Citizens Coalition.
Letter - Proposed Interim Remediation Plans for the 503 Burn Areas and the 103
Dump.
Comment 1 Enclosed please find our comments regarding the Interim Remediation Plans
for the building 503 burn areas and building 103 dump site. As you are aware, Aberdeen
Proving Ground Superfund Citizens Coalition (APGSCC) consists of concerned citizens
who live in close proximity to Aberdeen Proving Ground (APG). As we represent the
effected communities, we do hope that the Army will carefully consider these comments
during this decision process.
On behalf of APGSCC, I would like to take this opportunity to thank you, John Wrobel
and the others involved for the tune and effort spent on these sites. It is our sincere hope
that the Army will continue to make progress hi characterizing the Canal Creek study
area, so the best remedial actions can be initiated in a timely manner.
Response The Army welcomes all comments and will carefully consider all comments
received.
Comment 2 Aberdeen Proving Ground Superfund Citizens Coalition (APGSCC) has
carefully considered the available information regarding the Building 503 burn areas and
the Building 103 landfill. Supported by our technical consultants, Penniman & Browne
and University of Maryland Program in Toxicology, APGSCC has reviewed the Focused
Feasibility Studies pertaining to these areas, as well as the Proposed Interim Remediation
plans. In addition, several of our representatives attended the public meeting held by the
Army on May 24th, and APGSCC convened two additional meetings to discuss our
concerns. It is the strong belief of APGSCC that there are too many data gaps to support
the financial investment of the recommended interim cap at the present time. The issues
behind this conclusion are outlined hi the following paragraphs.
The fact the actual dimensions of the landfill are not fully known is a serious concern to
APGSCC. At the May 24th meeting, John Wrobel said that recent magnetometry
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February 28, 1995
readings confirmed that the dump extends further south than the area to be covered by
the cap. It is our recommendation that the Army perform a more definitive delineation
of this boundary prior to any initiation of cap construction.
Related to the landfill delineation issue is gas migration. At the public meeting, John
Wrobel discussed how the Interim Remedial Action includes the emplacement of
monitoring equipment in the basement of building E-5422. Whether or not the cap is
constructed, this effort is vital to the protection of those individuals working in this
building. Therefore, we believe that the Army should proceed with this initiative without
delay, if these steps have not already been taken.
APGSCC has a variety of concerns regarding cap construction. A major concern for
APGSCC, as well as the Army, is contaminant migration. The Building 103 landfill cap
will have a three-foot gravel and cobble layer, a two-foot compacted soil layer, a one-
foot layer of sand and will be covered by a two-foot layer of compacted soil. This cap
construction will add many tons of weight to the site and will exert a downward pressure.
It is known that the water table aquifer is extremely close to the surface and already
contaminated. APGSCC is concerned that the hydrostatic pressure caused by such a cap
may push the contaminated water downward and radially outward, thereby expanding the
area of contamination and displacing any interstitial gas. Since reducing contaminant
migration is the goal of building a cap, we believe this possibility of increasing
contaminant migration must be addressed before deciding whether placing a cap on the
site is the best action.
A second area of concern regarding cap construction is the ever present concern with
UXO. John Wrobel said the Army planned to place a two-foot layer of soil around the
site to disperse downward pressure and provide a buffer area should an explosion occur.
APGSCC would like to know if the Army has any data available on the effectiveness of
this technique based on previous experience at military installations. Not only would an
explosion be hazardous to personnel at the site, but the potential that highly toxic gases
may be released from containers in the site substantially increases the dangers.
When and if this cap is constructed, it will have to be maintained. We believe the
engineering plans for the cap should contain a very specific Operation and Maintenance
(O & M) Plan that includes a procedure for monitoring and repair. In this plan, such
issues as the possibility of groundhogs burrowing in from across the street, and damaging
the water impermeable layer from underneath, must be addressed. We also feel that the
development of this plan should be included in the CERCLA public participation process.
Overall, the lack of information that exists for this site is troublesome. As stated by the
Army at the public meeting, RI/FS's are currently being conducted at various SWMUs
in the Canal Creek Study Area, including the ground water which is being investigated
as a separate operable unit. Although it is known that the ground water beneath the 103
site is contaminated, it is not known whether this landfill continues to be a source of
contamination to the ground water, and if so, to what extent. The Army's Installation
Restoration Program (IRP) budget is finite. Therefore, we believe that the construction
of this cap should be delayed while information is rapidly collected in order to
characterize the sources of contamination and discern the overall patter- of ground water
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contaminant migration in the Canal Creek area. Technologies such as soil gas surveys
may help delineate the solvent plumes in a timely manner (since VOCs are a co-occurring
contaminant at most of the operable units). A better understanding of this study area
would allow the funding available to be more cost-effectively distributed among the areas
of highest priority.
While this investigation/characterization process continues, APGSCC feels that a few
simple steps can be taken at the 103 landfill to reduce the infiltration of water. The
groundhogs should be removed from the site, and their holes filled with dirt and gravel.
Once these steps are completed, the Army will have to take active measures in keeping
rodents from inhabiting the site in the future.
Lastly, our conclusion to delay cap construction leaves the resultant issue of remediating
the Building 503 burn sites. It is the opinion of APGSCC that the contaminated soil
should be excavated, stabilized, and transported to an appropriate landfill.' Following this
step, the Army should continue with its plan to back-fill with clean dirt and plant
vegetation. '
In closing, we would like to thank the Army for their continued commitment to work
with the citizens toward the common goal of installation restoration.
Response The Army performed geophysical surveys on June 28-29, 1994, to better
determine the extent of the Building 103 dump. This information provided the basis for
delineating the extent of the dump as is currently known. The data from this survey, and
from the soil gas survey will be used in designing the cap and cover system which will
cover the extent of the dump as currently known.
Existing data gaps will be addressed in the Canal Creek RI/FS, in which the Army will
initiate a comprehensive soil, sediment, and ground water sampling event in the Canal
Creek area. Under this work plan, soil, sediment, and ground water samples will be
collected and analyzed. Soil gas surveys and geophysical surveys will also be performed
in an effort to better assess the extent of contamination at APG-EA and to identify
sources. However, it will be take time until the data are analyzed and interpreted, and
even then, due to the many sources in the Canal Creek area (many of which may still be
undiscovered), it may not be possible to determine if the Building 103 dump is an on-
going source of contamination Unfortunately, due to the many possible sources, it is
difficult to "quickly discern the overall pattern of ground water contaminant migration".
Therefore, since the existing cover allows the infiltration of water through the waste, and
since the cover soil is steadily eroding into the contents of the dump, the Army has
determined that the construction of a new cap and cover system is a necessary interim
measure to protect human health and the environment. While it is possible to remove the
animals which currently inhabit the dump and to plug the holes, this action by itself will
not prevent the infiltration of water into the dump since it does not prevent run-on, and
because it does not address the issue of standing water on the dump. Also, it would not
prevent continued erosion of the cover into the fill material, and it would not prevent the
venting of any gases or vapors to the atmosphere. These issues can be addressed only
by plugging the holes in the existing cover, and by grading the cover to a suitable slope.
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Grading can only be accomplished by placing additional fill material on the surface of the
dump. For these reasons, the Army has determined that the construction of a new cap
and cover system is the best interim solution until completion of the Canal Creek RJ/FS
and overall Canal Creek ROD.
Currently, no air monitoring is being performed inside Building E5422 because any
gas/vapor emanating from the dump is venting freely through holes in the existing cap.
It is very unlikely that any gases or vapors are migrating into building E5422 itself
because the building is at the low end of the dump, and because a gas/vapor will take
"the path of least resistance" and vent through holes in the cap rather than through cracks
in the foundation of building E5422. Since Building E5422 has no basement, only leakage
through the foundation need be of concern. The monitoring options available, which will
be addressed in the design phase of the cap and cover system, are the placement of
monitoring equipment beneath th&building E5422 slab or within the building itself. This
will be addressed in the design.
The cap and cover system cross section presented in the Proposed Plan was a preliminary
cross section design concept aimed at minimizing the infiltration of water into the waste.
However, during the 30 percent design phase, the design will be refined with the added
criteria of minimizing the thickness of the cap and cover system. This is necessary
because of the proximity of Williams road and Hoadley road, and adjacent buildings.
The cross section to be presented in the 30 percent design will have all the layers of the
conceptual design presented in the Proposed Plan, but will be thinner and lighter than the
concept presented in the Proposed Plan. The effect of such the cap and cover system on
the hydrostatic pressure has already been investigated. Preliminary settlement
calculations performed show that the total settlement of the existing cover will be
approximately 0.25 inches. Therefore, there is little likelihood that the additional load
of the cap and cover system to be constructed will expand the areal and vertical extent
of contamination and displace any interstitial gas. If the waste compresses 0.25 inches,
there should be a negligible effect on the hydrostatic pressure in the surficial aquifer.
The Army recognizes that the explosive detonation of ordnance of any type is hazardous
to on-site personnel, and possibly to off-site personnel. To this end, data are available
on ways of reducing ground pressure, and on ways of containing the effects of explosive
detonation. The main factors in determining whether an underground detonation will
break surface are the amount of explosive and the depth of the ordnance item(s).
Typically, if sufficient soil is present to absorb the energy released, then the explosion
will be contained. This principle is used in in-situ emergency techniques for the
destruction of single munitions. For example, single munitions encased in a plenum
chamber filled with vermiculite or some other material can be safely detonated; the
explosion is totally contained since the vermiculite absorbs the energy released (shock
wave, heat, expanding gas). Another in-situ emergency technique is "massive
encapsulation/burial". With this technique, the munition is buried under a mound of soil,
which then absorbs the energy of the explosion. The additional fill material to be placed
on the dump will perform this function, and will also dissipate the weight of personnel
and equipment. As stated above, heavy equipment and the cap materials will produce
additional loads on buried ordnance, however, the additional vertical pressure dissipates
laterally with depth is not transmitted directly to buried ordnance. Only a portion of the
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additional pressure is transmitted to buried ordnance. The more fill is put down, the
more the load is dissipated laterally. Standard civil engineering handbooks can be
consulted for the effects of dissipation of pressure with depth. To further reduce this
load, grading equipment equipped with wide tracks or tires will be used. Since pressure
is defined as force per unit area, this will distribute the weight over a wider area, further
reducing the point load. There are many examples of this in everyday life. Snow shoes
are an example of spreading weight so as to be able to walk on snow without breaking
through the crust.
The 100 percent design for the cap and cover system will contain a detailed cap and
cover system Operation & Maintenance plan which will include monitoring and repair
procedures. If necessary, this O&M plan can be included in the 90 percent design for
the cap and cover system. It is unlikely that marmots will damage the cap and cover
system from beneath by tunneling under the cap from the perimeter of the dump. Such
intrusion would be apparent during O&M operations. Also, field studies have shown that
rodents do not appear to be able to penetrate High Density Polyethylene (HOPE). A
study cited by EPA titled Requirements for Hazardous Waste Landfill Design.
Construction, and Closure, dated April 1989, states "In tests done with rats placed in
lined boxes, none of the animals were able to chew their way through the [geosynthetic
liners]".
The Army concurs that a better understanding of the Canal Creek Study Area is
necessary. However, for reasons already stated above, the Army does not believe that
construction of a cap and cover system should be delayed until the RI/FS is completed.
While ground water data has already been collected during four sampling events by the
USGS, additional ground water data needs to be collected during the RI/FS, and new
wells installed in an attempt to better characterize the extent of contamination and to
identify sources. The installation and monitoring of these wells will be a time consuming
process. The collection, analysis, and interpretation of soil and sediment samples during
the RI/FS will also be a lengthy process, and several rounds of data may have to be
collected before the extent of contamination is characterized, and the sources of
contamination identified. It will take time to gather the data and interpret it. The Army
intends to cap a potential source of contamination while the time consuming work data
collection process is being performed.. While the data will be collected and analyzed as
rapidly as possible, it can only benefit die aquifer quality to cap the dump at the present
time, preventing additional water infiltration through the dump with possible further
contamination of the ground water. Soil gas surveys can delineate plumes quickly, but
are limited in their usefulness, particularly in an area with many potential sources, and
with unexploded ordnance. It is more useful to study the scope of contamination in the
study area. Contaminants other man solvents would be missed by a soil gas survey. In
addition, a large area of ground water may be contaminated from several sources. An
area wide study is needed to assess sources and define remedial actions. These questions
must be answered by the remedial investigation currently ongoing. The Army believes
that it is a proactive action to cap a potential source which will provide cost effective
protection to human health and the environment while the investigation is going on.
The Army concurs that an interim action needs to be undertaken at the Building 103
dump. However, for reasons stated above, the Army does not believe that removing the
groundhogs and filling the holes present in the existing cover provides sufficient
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protection to human health and the environment, since this action by itself will not
prevent run-on, and because it does not address the issue of standing water on the dump.
Also, it does not prevent continued erosion of the cover into the fill material, and would
not prevent the venting of any gases or vapors to the atmosphere. This can only be
accomplished by a cap and cover system. The Army will maintain the cap and cover
system in accordance with the O&M plan to be published, and will take active measures
to prevent animals from inhabiting the site in the future.
COMMENT SET 6 Received from Water & Wastewater Superintendent, City of Aberdeen, Maryland,
July 18, 1994.
Comment 1 After reviewing the proposed remediation plans for the Building 103 dump
and the Building 503 smoke pilot plant burn sites, the following is what I believe to be
the best remediation plan.
First you need to combine alternative #3 excavation on-site stabilization using an organic
binder with alternative #5 disposal at Building 103 dump and backfill using alternative
#6 for the installation of a cap and cover system using sodium bentonite geocomposite
mat.
A geosynthetic membrane would guarantee that the pollutants of concern would not
escape the dump site by leaching into the groundwater if the liner were to fail.
Response Properly formulated and controlled treatment of the soil and ash from the
Building 503 burn areas by solidification/stabilization would decrease the mobility of
metals in material. Trace organic contaminants may also be immobilized. Binding
materials used for treatment of hazardous waste fall in two broad classes, inorganic and
organic binders. Commonly used inorganic binders include portland cement, fly ash,
blast furnace slag, and si- -ites. The most commonly used organic binders are
thermoplastics, in particul? _?halt. Application of organic binders is more expensive
than application of inorganic .riders. Organic binders are typically only used in special
applications where the was - s unsuitable for treatment by inorganic binders and/or
where the treated waste cai- r ; ?used as paving asphalt. For example, asphalt binder
is widely used to treat soils -ruminated with petroleum products.
Treatment with either inorganic or organic binders would be implementable and effective
in reducing the mobility of metal contaminants. However, the treatment process is not
cost effective. The fixed cost for on site treatment is high. Equipment to meter the
binding agents and waste and then mix them must be brought to the site, set up, and
tested. Treatability testing must be done to establish the proper mixture of binder and
waste. The high fixed cost makes treatment of a small volume of waste, such as the soil
and ash from the burn areas, very costly for the performance improvement achieved.
Since the soil and ash waste will be effectively protected by a cap and cover system,
additional immobilization by solidification/stabilization will not significantly increase
protection of human health and the environment and will significantly reduce the cost
effecti v: ness of treatment.
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QUESTIONS FROM THE PUBLIC MEETING HELD ON 24 MAY 1994
Question 1 (Page 51) If the Army at some time excavates the contents of the Building
103 dump, will there be additional costs incurred because the Building 503 Burn site
ash/soil has been included in the waste under the Building 103 cap and cover system.
Response Some additional costs would probably be incurred if the Army excavates the
contents of the dump, and if the Building 503 Burn site ash/soil has been included in the
waste under the cap and cover system. However, the additional costs are expected to be
minimal since the volume to be put under the cap and cover system is small compared
to the volume of fill material required and because all of the fill material under the cap
and cover system would most likely have to be removed as hazardous waste.
Question 2 (Page 52) Has the feasibility of covering the Building 503 Burn sites with
a cap and cover system been investigated?
Response The feasibility of constructing a cap and cover system over the Building 503
Burn sites was assessed in a Remediation Feasibility Assessment. This remedial
alternative was not considered further even though it is technically possible to construct
a cap at the Building 503 site. Also, the implementation of such an alternative would
have been considerably more expensive since the cap and cover system would have
construction costs, and maintenance costs.
Question 3 (Pages 54-56) To what extent will the Army attempt to positively identify
items as unexploded ordnance at the Building 103 dump before operating heavy machines
on the Building 103 dump? Will the Army excavate suspect items in order to positively
identify them as ordnance, and/or will the Army attempt to remove ordnance from the
dump?
Response Construction work at the Building 103 dump will be preceded by an
unexploded ordnance sweep, in which an explosive ordnance disposal (EOD) team will
go over the site with a magnetometer and flag all suspect items. If any items are found
on the surface, and if these items are clearly hazardous, they will be rendered safe and
removed by EOD personnel. Positive magnetometer responses very close to the surface
may be excavated if EOD personnel determine that the items are ordnance items which
need to be investigated. No effort will be made to excavate items unless the EOD team
leader determines that this is absolutely necessary. In order to permit heavy vehicles to
drive onto the dump, fill material will be deposited on the edge of the dump and will be
graded to the center so that no heavy equipment will drive onto the dump until sufficient
fill is in place.
Question 4 (Page 57) When will the Army determine the full extent of the Building 103
dump? How and when will the issue of not capping the entire extent of the dump be
addressed?
Response The dump will be further investigated as part of the Canal Creek RI/FS and
during the early stages of the cap design (30% design). The investigation conducted for
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the 30% design will include a geophysical survey which will more fully determine the
extent of the dump. From aerial photographs and work conducted to d.ate, it is likely that
the dump extends under Building E5422 to the south, and under the parking lot to the
west. Building E5422 probably sits on the edge of the dump. The interim cap and cover
system will probably cover the whole dump since Building E5422 will be tied into the
cap. In essence, Building E5422 becomes part of the cap, and in this way the entire
extent of the dump as currently known will be covered. The cap will extend to the
parking lot.
Question 5 (Page 61) After the cap is in place, how will migration of any chemical
gas/vapors from the dump into Building E5422 be averted? What will be done to
safeguard the health of people who work in Building E5422?
Response A soil gas survey will be performed as part of the 30% design to determine
if the dump is generating any gas/vapors. The cap and cover system will incorporate a
gas collection/filtration system which will intercept any gas and prevent it from migrating
into Building E5422. The results of the soil gas survey will help determine the type of
gas collection/treatment system to be installed. Also, a monitoring system will be
installed inside Building ES422 to safeguard the health of people who work in the
building.
Question 6 (Page 62) Is there, a data base which addresses the behavior, particularly
with respect to burrowing habits, of groundhogs? When will Sbe O&M Plan be
completed, and will it address the issue of groundhogs burrowing 'mo fee dump through
the cap and cover system?
Response The O&M Plan will be published as part of the later stages (90% design) of
the cap design effort, and address the issue of ground hogs digging their way into the
dump through the cap and cover system. Information on rodent burrowing behavior has
been addressed in books and biological science journals. In addition, the Department of
Energy has done significant research in this area in their uranium tailings work.
Question 7 (Page 69) What is the useful life of the cap under the selected alternative
(Alternative 6)?
Response Because of the short time geosynthetics have been available, it is not known
what their useful life is. It is conservatively assumed that bentonite geocomposite mats
typically have a useful life of about 25 years, and geosynthetic membranes typically have
a useful life of about 20 years. The cap and cover system under Alternative 6 has a
useful life of approximately 20 years. As required by law (since waste is being contained
on site), the protectiveness of this action will be looked at again in no more than 5 years.
If it is determined at this time that further actions are required to fully address the
Building 103 dump, then those actions will be undertaken.
Question 8 (Page 72) How does this interim action tie into the overall remediation of
the Canal Creek Area, and how do all the individual remedial investigations and
feasibility studies being conducted at APG-EA tie together? Are data generated from one
remedial investigation being used to supplement other remedial investigations?
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Response Currently, in addition to several individual interim remedial actions, the Army
is conducting a Canal Creek Area wide RI/FS and a groundwater investigation. All data
collected as part of an action and/or remedial investigation are being used in other
remedial investigations as much as possible. All data generated are entered into a single
large data base. All individual interim remedial actions in the Canal Creek Area will be
tied together with the Canal Creek RI/FS by a Canal Creek Record of Decision, or by
a Record of Decision for the entire APG-EA. The APG-EA Record of Decision
document will also tie in work being conducted in other areas of APG-EA, such as
Carroll Island and Graces Quarters.
Question 9 (page 80) Is there technology transfer, cooperation, and exchange of ideas
between government agencies, private industry, and foreign countries with respect to the
remediation of contaminated sites?
Response There is significant cooperation, and interchange of ideas and technology
between the various government organizations, and between the government and private
industry. There is some cooperation between foreign countries in this area. Recently,
there has been increased cooperation between the United States and the government of
Russia in the area of chemical demilitarization and restoration of such installations.
Comment 10 (Page 82) A comment was made that the fact sheet for the interim
remedial action at the Building 103 dump did not provide detailed information on the
groundwater at the site.
Response The fact sheet on the proposed interim action at the Building 103 dump did not
go into detail on the groundwater since groundwater is being addressed as a separate
operable unit. APG has available a more detailed fact sheet on the entire Canal Creek
Area, and will be providing additional information on groundwater as the Canal Creek
RI/FS progresses.
3.4 PANEL OF EXPERTS
The following list gives the representatives of the Army, State of Maryland, and U.S EPA who
participated in the poster session and public meeting held on May 24, 1994.
John Wrobel, Deputy Program Manager for Canal Creek Area for APG
Ken Stachiw, Installation Restoration Program Manager for APG
John Fairbank, State of Maryland Program Manager for the Building 103 Dump and Canal Creek
Area
Steven Hirsh, U.S. EPA Region III Remedial Program Manager
3.5 SELECTED NEWSPAPER NOTICES ANNOUNCING DATES OF PUBLIC COMMENT
AND LOCATION AND TIME OF PUBLIC MEETING
The announcement for the public meeting to discuss the interim remedial actions for the Building
503 Soils Operable Unit and the Building 103 dump is attached at Appendix C.
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APPENDIX A. ANNOUNCEMENT OF PUBLIC MEETING
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The U.S. A/my Invftes the public to attend a pubOe meeting on the Proposed Plans for two
environmental actions at the Building 503 Site and the Building 103 Site at Aberdeen Proving Ground:
. DATE- May 34
TIME: 7p.m.
PUCE: APG Btg*»ooJAna Canfmittt Crater, BuiUimg 4*10
Abo. the pubfc can submit written comments durtn0 the 4Vday eommert period which runs from May 4 to June
17. Comments must be postmarked by June 17 and sent to: Directorate of Safety. Health & Environment. U.S. Army
Aberdeen Proving Ground. ATTN: STEAP-SH-CR (J. WrobeO, Aberdeen Proving Ground. Maryland. 21010-5423.
The Army constructed Bukflng 503 dulng World Wbi I and used the Me for a variety of manufacturing, testing
and disposal pwpose*. SampBng shows the1 soil In two aeat bentvt the butding contains elevated levels of metals deed
and zinc) and two substances used In the manufacturing process (hexachlorobenzene and hexachkxoethane). The
Army b proposing to excavate the soil and has evaluated different alternatives. The alternatives the Army evaluated
are:
Alternative I: No Action (required by law to provide a baseUne for comparison).
Alternative 2: Excavate the sol and transport It to an off-post Industrial landfil. backfill the site with
dean topsoi.
Alternative 3: Excavate the sol. orvdte treatment by ttabBtation. dispose of the soil at an off-site
Industrial tondfl. backffl the site with dean topsoL
Alternative * Excavate the sol. transport the sol to an off-tlte hazardous waste landfill, bockfi the site
with dean topsoi.
Alternative 5: Excavate the sol. dispose at APG'* Budding 103 site under the Anal cap and cover
system proposed below, bockfl the site with clean topsoi.
The preferred alternative at thb time b 6. The A/my proposes to excavate the sod to a depth of one foot, removing
about 470 cubic yards of sol, and to place the excavated sol at the Bukflng 103 site. The Army would use dean topsoi
to restore the site to the natural contours of the area:
The BuldJng 103 site b a former waste disposal and burial area. The Army used the site starting In the World War I
era untl the earty 19404. Since dbposal records were not requted during this time, there b Ittle Information about what
was placed at the site. The Army beOeves the site may contain mbcesaneous debris and posstoty chemical agent
residue and ordnance Items. The Army's studies show the site may be contrbuting solvents to the ground water at the
site. There b no afreet pubic exposure to any site cherrtcab. and the water beneath the site b not a source of drinking
water.
The Army evaluated different alternatives to contain the waste and to block rain and surface water from
moving through the site and carrying substances Mo the ground water. The Army abo sought an effective alternative to
prevent animals from burrowing at the sit*. The alternative* the Army evaluated are:
Aftematrve 1: No Action (requred by law to provide a baseline for comparison).
Alternative 2: total a s(ngle4ner cap using off-post day.
Alternative 3: Instal a itngle-iner cap using a higher quality day and sand (bervtonite geocomposte)
met
Alternative 4: Mai a single Iner cap using a rubber-fce material (geosynthetic membrane).
Alternative 5: k-atal a double-liner cap usrg off-post day and geosynthetic membrane.
Alternative 6: Instal a double-aner cap using a bentonfte geocomposite frier and geosynthetic
membrane.
, The preferred alternative at thb time b & The Army propose* to construct a mutlHayer cap and cover system In
! accordance with federal requirements for a hazardous waste tanaJl closure. The cap would cover an area of approxi-
mately 1.7 acres and woutt have a cobble/gravel bonier to Imtt animal access. Two Impermeable layers wood limit
I the movement of water Into the site and substances from the site Into the ground water.
The preferred alternatives may be modified or new aftematrves developed based on pubBc Input. The final
remedies selected wf be documented In Records of Decision that summarize the decision-making process. APG wa
summarize and respond to aM written comments received during the comment period as part of the Records of Decision.
Copies of the Foeuied FeosbBfy Studies and the Proposed Plans are at the APG Information repositories located
at the Edgewood and Aberdeen branches of Harford County library. MOer library at Washington College. Essex Com-
munity College Library, and the TECOM Public Affairs Office at APG.
If you have questions regarding the meeting or proposed action, please coD APG's 24-hour Installation Restora-
tion Program formation ine at (410) 272-8842. *
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APPENDIX B. TRANSCRIPT OF PUBLIC MEETING
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COMMUNITY MEETING U.S. ARMY ABERDEEN PROVING GROUND
INSTALLATION RESTORATION PROGRAM
DATE: TUESDAY, MAY 24. 1994
TIME: 7:30 P.M.
PLACE: APG EDGEWOOD AREA CONFERENCE CENTER
, BUILDING 4810
REPORTER: BARBARA J. RUTH
NOTARY PUBLIC
** BEL AIR REPORTING * 838-3810 **
DISTRIBUTION RESTRICTION STATEMENT
APPROVED FOR PUBLIC RELEASE:
DISTRIBUTION IS UNLIMITED.
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MR. MERCER: Welcome to our public meeting
here this evening. The purpose of this meeting is to
discuss'two proposed actions at the Canal Creek Study
Area, Buildings 503 and 103, in the Edgewood Area of
Aberdeen Proving Ground.
I'm George Mercer from the Aberdeen Proving
Ground Public Affairs Office. My role tonight is to act
as host and moderator. We also have up front with us Mr.
Ken Stachiw. and he is the Chief of the Conservation and
Restoration Division and our Directorate of Safety,
Health and Environment; and Mr. John Wrobel, who is the
Project Officer on the projects we're here to discuss
this evening. We also have Mr. Joe Craten, who is the
Director of the Directorate of Safety, Health and
Environment; Mr. Steve Hirsh of the U.S. Environmental
Protection Agency; Terri White from the Environmental
Protection Agency; and Mike Toreno of the EPA as well.
From the Maryland Department of the
Environment, we have John Fairbank and Fred Keer, and
they're all here to help us this evening.
Did everyone here get an agenda, or are you
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aware of an agenda, do you need one? Okay. We have
okay, everybody's got what they need.
After Mr. Stachiw and Mr. Wrobel make their
presentations, we will open up the activity for
questions. We have index cards, we can take down written
questions, or if you are so moved, you can present your
questions in person we'll just call on you at that
t i me.
I would point out to you that the reason
things are covered up out here is there's conferences
going on in the building tomorrow morning, so please
don't touch any of the covered up items out here in the
hallway.
Also, I would like to remind you that we do
have at Aberdeen Proving Ground an installation
information telephone line, and if you haven't picked one
of our pencils that has our number on it, you can just
pick it up on your way out, and that will get you -- if
you have a question or a problem or any other concern,
you can call that telephone number, and we'll get back
with you with a response.
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We also have cards you can fill .out to get
on our mailing list out there. So any of you that have
any of those things you want to do, you can stop on your
way out or grab me, and I'll help you get whatever you
need on that or Ms. Harris back there, she'll help you
get it.
As this is a formal meeting, we are
required to have a court reporter record all of our
proceedings. This is our court reporter. And the
transcript of what we do tonight will be located in
repositories in the area libraries, so we can tell you
what those are if you want to know. In fact, they are
listed on our fact sheets that you may have picked up in
the other room when you were looking at our exhibits. If
you did not pick up those fact sheets, and you want to
have a written down somewhere the areas of those
repositories, you can go back in at the end of the
meeting and pick them up, rather than me reciting it to
you.
With that taken care of, I think that takes
care of our introductions and logistics, and other
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announcements. And I think we'll just move onto Mr.
Stachiw.
MR. STACHIW: Thank you, George. Thanks
for coming out this evening and your interest in our
project. What I'm going to do is give you an overview of
i
how this fits into everything else that's going on at
Aberdeen Proving Ground. For some of you here, I'm going
to bore you to tears, okay, because you've heard this so
often. Others probably don't know for sure what's
happening or know how this fits in with everything else,
and so we thought it'd be wise to spend five or ten
minutes to go over just'the big picture.
What I'll be speaking about is the
installation and restoration program at APG. As you can
see, we have what we call here at APG the four pillars of
our environmental program. We have prevention,
conservation, compliance, and restoration. What we're
speaking about tonight is restoration. This has to do
with the cleanup of past disposal sites. Sites that were
closed and done with before much of any kind of
environmental regulation existed. We had to do some
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historical searches to find out what we did irr the past,
and to see if there's contamination coming from it. If
there is, to find ways to clean it up.
To separate from that is compliance.
Although we have a compliance program to do restoration,
I
the normal compliance, you deal with it on a day-to-day
basis, that would there's another program at APG run
by another division chief. Okay? That has to do with
water pollution control and air pollution control and the
movement of hazardous wastes from existing operations,
where they're making hazardous waste as we speak, you
know, even now.
So then we ha*- . conservation program
some people that are dedicat .o managing the wildlife
here at APG and making sure the cultural and historical
resources are preserved and taken care of.
And we have a prevention program, and
that's a program where we're trying to prevent the
problems here from occurring again. We're thinking hard
about what we do before we do it. Okay? So things like
an EIS would come under this irena. Okay?
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Now, things such as the project .manager for
Chemical Demilitarization is not part of my realm of
responsibility. Okay? The stockpile falls more under
compliance than it does under, at all, under the
restoration program. Hopefully, whatever we do will be
done right, and there won't be a need for restoration as
far as that's concerned.
So I just want to keep us focused on that.
We're going to be talking about the cleanup of we're
talking primarily about the program we have for cleaning
up the past activities.
As most of. you might be familiar, we have a
map of Aberdeen Proving Ground here. This is the
Aberdeen area, this is the Edgewood area, Grace's
Quarters and Carroll Island, all this area here, part of
Aberdeen Proving Ground. The installation, the Aberdeen
area, was founded 1917, 1918, was devoted to the testing
of military equipment, vehicles, weapons. The Edgewood
area was devoted to the production, research, provides
the chemical warfare agent. As you can imagine, I've
said many times, because of the kind of activity, the
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dealing with lots of hazardous materials, the .oeed to
dispose those materials, the fact there was no science or
too much science involved in the way things took place at
this time, we ended up having a number of different
places where waste may have been disposed of
inappropriately in accordance with modern approaches to
doing things.
We spent three years searching records upon
records looking for past activities, and came out with a
1000-page document, and another one about 500 pages --
the 500-page for the Aberdeen area, the 1000-page
document for the Edgewood area -- and enumerated what we
termed 318 solid waste management units for the total
post. 270 roughly for the Edgewood, another 50 or so
from the Aberdeen area.
Now, the numbers are impressive, but a
solid waste management unit may be something maybe the
half the size of this room where they stored drums. It
may be something as large as the Michaelsville Landfill,
a 31-acre landfill, where we had municipal refuse
disposed.
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Because of the immensity, the size of this,
we worked with the regulators as well as collaborated in
collecting them into 13 study areas for the sake of the
ease of management.
Here's the traditional map we use for this,
although one of the study areas is missing here, the
western boundary. But the color code breaks the whole
post into 13 different study areas-. Of these 13 study
areas, this area here, Grace Court of Carroll Island are
on the national priority list. Also. Michaelsville
Landfill is on the national priority list. There is some
concern, and people are raising the issue, whether the
rest of the Aberdeen area should be on the national
priority list. That's not the subject for tonight's
meeting. Okay? We'll be talking more about this area
here, the Edgewood area.
Now, in concert with confining things to 13
study areas, we worked with the regulators for the State
EPA, and we entered into an interagency agreement with
EPA, which develops the structure for how we are to
manage the study and the cleanup of these sites. The
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fact that we've identified 318 units doesn't mean there
are pollutants. All we're saying is that this is a place
where waste was managed, it was stored, not necessarily
disposed, where there may have been a release of
hazardous materials in the environment. We don't know
for sure there were or not. All we knew is of a record
that something was'done there. Okay?
So what we do is we go back and we research
these areas, monitor them, take samples,- and see if we
can discover anything that may have taken place there --
if there is any release or any evidence of release into
the environment from those sites. Is there any evidence
the material is somehow still there, about to release?
That's part of the study. And the EPA has somewhat
criticized, but I still think a very, very good approach,
to investigating these particular study areas.
Once you've identified, said, here we have
a site -- this is the diagram, the flow diagram for it.
The first thing you would do is a preliminary assessment,
site investigation. You'd go out to the site, take a
look at it, maybe c-ke a soil sample or two, and make a
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determination as to whether this thing doesn't even exist
anymore, or whether or not there's something maybe here,
we'd better look into it. If it gets nominated past
this, okay, it moves into the RI/FS stage.
If we have enough data, there may be enough
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data to rank it. Okay? Say, gee, we can measure a
release. We think it's near a water supply. With this
ranking system, it can be put on a national priority
list. Okay? A national priority list is not done by
someone wanting it to be there because they don't like
it. It's got to do with a ranking system with regards to
the degree of hazard it imposes to health and
environment. Their chance of release in a pathway
contaminants into man or to the ecology.
If there's enough information, it can be
placed on a national priority list. But putting this
aside, whether it's on it or not, this is a nice phase in
terms of where we study this. The next stage would be a
remedial investigation. This is where we would actually
put wells around, maybe take more soil samples, and
determine if there's a release at this site of something
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to the environment either to the groundwater, to the
air, wherever. And then make a determination as to how
far is it going, where will it get to by when, to see if
there's any particular risk associated with it.
A risk assessment is done at this stage as
well. And then we would also do a feasibility study.
And with this information and remedial investigation, we
make determinations as to what we should do with this.
What is the best way to manage this particular site? Do
we do nothing? Do we put a fence around it? Do we dig
it up? Do we suck groundwater out from underneath it?
Or do we put a cap on top of it? What do we do in order
to remediate this site?
Sometimes this process takes a long time to
develop the information that you normally need to stand
up in court and say, this is final. And sometimes it
makes no sense to let something continue to release into
the environment while you're trying to come up with
definitive information to allow you to stand in court
with this piece of information and say this is without a
doubt the final decision, and everyone around agrees with
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it.
Sometimes when you get data, sometimes
instead of getting answers, you get more questions with
more data. It doesn't always provide all the answers as
you need them. Okay? So in the meantime, we do a thing
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called an early action ROD. This normally, once you
complete the RI/FS, you lead to a record of decision.
This record of decision will lead to remedial action, and
then eventual monitoring. We are allowed, under our
interagency agreement, to do what's termed an early
action ROD. An early action ROD is where something makes
common sense to do now and is not likely to be
contradictory to a final solution. And you're allowed to
go in and say, okay, public, we want to do this now.
It's not the last thing we plan to do here, but we will
plan to continue studies some more, but we think we want
to do this now to stop continuing release into the
environment. Okay? We want to stop this release now, so
we have a little more relaxed time to study and come to
the right answer in this particular problem.
Tonight we'll be talking about an early
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action ROD. This ROD, a game plan for a ROD fpr all 13
study areas, early maybe as many as 20 early RODs for
all the study areas totally. But right now we're going"
to be focused in this study area here called the Canal
Creek area. We're right about here, probably no more
than a driver and a three wood from one of the sites
right now. Okay? The 503 and 103 well, maybe a Jack
Nicklaus' drive and a three wood, in the old days.
And we're going to focus on these two
sites, and John is going to talk about that. We're not
going to be talking about 0-Field or various other sites
or Grace's Quarters and Carroll Island. You know, they
each are problems which will have their own day. Okay?
Bur today, today is for the 503, 103. These are two
one's a disposal, where things were burned, disposed of;
the other was a small landfill. And we're trying to
combine an economic solution there that John's going to
describe right now. So before I get him up here, are
there any questions about the overview of what we're
doing? We're here to make a decision about an early
action -- not a final action, but an early action about
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one site in one of the study areas. There are other
sites in the study area besides the 103, 503, but we're
just focusing on one particular segment.of the study
area. Any questions?
(No response from the audience.)
MR. WROBEL: Good evening. As Ken
indicated, my name is John Wrobel. I'm environmental
engineer and Ken Stachiw is my mentor, supervisor for
these projects here. Like he said, we're going to be
talking about two sites, the Building 503 and the
Building 103 sites. I'm using the old building number
system in this program. There is, right now, no Building
503. There hasn't been a Building 103 in many, many
decades here. I'm just using them as because in the
information in the library, identified, many of these
refers to it as the sites. Actually Building 503 is
Building E-5265 right now. As I said, Building 103 was
demolished decades ago. It doesn't even exist anymore.
I'm just those as sort of a context to kind of focus in
with where and when the activities occurred. Building
*
5265 does not do what it had done prior. It's not that
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type of facility anymore.
(Whereupon, slides were presented with
the following narrative.)
Again, I'd like to reiterate, these are
earmarked, these aren't finalized, and these are early
things that we think make sense to do at this point. We
will look at these decisions again based on your input,
based on more information we gather as part of remedial
investigation, to see if these things actually make sense
in the final context of the whole remediation, the whole
cleanup, of the study area we call Canal Creek and
Edgewood Area.
We've got a comprehensive study. It's
going to take several years to do. It's a big site.
It's a complex site. A lot of people say it's one of the
most complex sites in the country. These actions are
very obvious. I think they make sense to do at this
point, but we're here to talk about them with you,
present the information, listen to what you have to say
about them. We may alter our decision based on your
input. Right now, we've discussed things with the
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Environmental Protection Agency and the Maryland
Department of the Environment. They have agreed with,
have a consensus there this thing has been these
projects have been briefed to the technical review
committee, which comprise of a group of citizens that
meet on a quarterly basis to talk about the remediation
projects at APG. We seem to have a consensus from that
particular group, technical assistance grant folks, the
people that represent the Aberdeen Proving Ground
Citizens' Coalition have received these documents, we
provided briefings with them. I've gotten preliminary
response from then all indicating that these things seem
to make sense at these sites at this time.
Where these sites are located when you
came to this meeting today, you probably drove by both of
these sites. We're located here in the'conference
center. The first site I'll be talking about is the
Building 503, Building 5265, it is right here. If you
came down Hoadley Road, it was this building here, the
fenced-in complex on your left-hand side. When you
leave, it's going to be on the right-hand side.
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Building 503 was constructed in World War I
as a chemical agent filling facility. Between the war
years, it was used as a miscellaneous shop, carpentry
facility. Again in World War II, it was set up as a fill
plant for incinerary conditions, things that a bomb
that would cause a fire is what incinerary is. After the
war and during the war periods, it was used to
manufacture and produce experimental smoke material.
What a smoke munition is, it creates a screen that
prevents the enemy from seeing what you are doing. It
provides a big cloud of smoke. So some of the off
specification material may have been burned at this site.
There is no burial on this site based on what we have
seen from the site records and from the sampling that was
done at this particular site. As you can see, it stopped
at about 1975.
And again, what some of these smokes are,
you've seen some of the different documentaries and
whatnot, it could be red smoke, green smoke, used to
signal purposes.
This is what the site looks like currently.
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This is the north burn area, and it's an area_-devoid of
vegetation. It is very clearly defined where these
activities 'took place.
This is a view of the south burn area.
Again you can see, very well defined, the extent of where
those activities occurred.
This is to give you an overview
diagrammatically of the area. This is old Building 503,
current Building 5265. The north burn area comprised of
about 10,000 square feet. The south burn area consists
of about 2,000 square feet. The volume of contaminated
soil based on our soil sampling program is about 470
cubic yards of soil. The extent of contamination seems
to be just in the areas that are devoid of vegetation at
this point, nothing grows there, and it goes about a foot
deep. That seems to be about where most of the
contaminants are.
To give you some kind of perspective what
470 cubic yards of dirt is, a dump truck, a normal dump
truck you see on the highway is about 20 cubic yards. So
this is about 20, maybe. 22, dump truckloads full of
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contaminated soil.
As part of that study that Ken was talking
about where we identified there is 318 solid waste
management units we did some preliminary sampling at
the site back in 1986. And that's what allowed to have
this ranking score and the listing of the whole Edgewood
area as a national .priority list site. In 1989, based
upon the results of that particular study, and the
obvious that this site is a contaminated area, we brought
in the EPA Environmental Response Team out of Edison, New
Jersey. They did a special study for us to see if
there's any way we could stabilize this waste. In other
words, was there anything we could do and what we mean
by stabilization is mix it up with concrete, make it so
that it doesn't release anything, make it into cinder
blocks and maybe dispose it at some other location. We
did that.
Subsequent to that in 1993, we had Battelle
organization, which is a not-for-profit organization,
running the Canal Creek remedial investigation for us,
take additional soil samples, look for the extended
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contamination. In the year '86 was just a small study to
identify areas of concern. This '89 study was just to
see if the waste could be stabilized. In '93, it was
more of a what you would call an investigative kind of
study where you could see what the exact extent of the
burn area was. And as I say, we found most of the
substances, the contaminants, in the top foot.
I'm just going to throw this up, and I
don't want to spend -- but this is not at that site. But
this is what a soil sampling team looks like here in the
Edgewood area. And this is typical of any Superfund
hazardous waste workmen taking soil samples. What you
see here is that typically all the site workers are
wearing white, what we call a Tyvek, it's a trademark,
it's a garment to keep dust off of them so they don't
bring it home. It's disposable. You can see that the
shirt and the boots are taped to prevent primarily
it's to prevent jiggers and ticks from crawling up into
their skin. There's an air monitoring device located
that's sampling air at the worker's breathing zone. And
these workers right now are unprotected and don't have
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any respiratory protection. But what happens,, when this
reaches a certain level that's defined by the
Occupational Safety and Health Administration, OSHA,
reaches a certain level, these workers would back off,
put on appropriate respiratory protection. All this work
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is governed by health and safety plans that talk about
contingencies for these guys and also for people in the
immediate surroundings of the project, what would happen
if this reading went off. And this is how they collect
the soil samples. And he's got gloves on to protect any
germal contact. Very typical. You'll see that more and
more as all the projects get accelerated here. You'll
see these type of people doing these type of activities
on Aberdeen and Edgewood.
Again, these are charts showing north burn
area, the location of some of the soil samples that we
take. And similarly, I have a chart of the south area.
But most importantly is what we found. We
found that these were primarily the contaminants.
Everything else seemed to be below detection levels. In
other words, the instruments did not see any other types
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of contaminants. We found lead, zinc, hexachl.orobenzene,
hexachloroethane, which are components of the different
smoke mixtures that were burned at this particular site^
The highest concentrations in parts per million in dead
areas and also in the grassed areas surrounding the site.
As part of our decision-making process here
where we came up with the rationale for why this made
sense to do at this time, we did a risk assessment. And
a couple things to remember about a risk assessment, is
just because you have chemicals, doesn't necessarily you
have risk on site. You have to have it's like that
triad the fire departments talk about. In order to have
a fire, you need to have an ignition source, you need to
have something that will burn, you need to have oxygen.
If you break one of those legs of that triad, you're not
going to have fire. The same thing with risk assessment.
You have to have chemicals present. They have to be in a
significant concentration. You have to have an exposure.
In other words, it has to get either to a person or to
the environment. If you don't have any of those things,
you really don't have risk as such. You may have
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something you have to deal with, but you don't
necessarily have a risk until you have one of those three
legs in that particular.
What we found is, because the site is
fenced, the only people on that site are the people that
work in that particular building, so there's no public
exposure to the site. There's very limited exposure to
water. It doesn't the site has been inactive since
1975. It has basically looked the same since 1975, so
it's not really migrating off that site that well. But
there is a small air pathway. In other words, when dust
blows off the site, you can get some contaminated soil
moving off that site.
What we found is the greatest, based on our
assessment we did, that people working on that site are
at the greatest risk. And the goal is to eliminate this
particular risk to the workers on this particular site.
And what we found when we did the risk
assessment, we identified, okay, it's the workers on this
site. Well, what are the workers doing? Well, they are
still working on smoke mixtures in that particular
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facility. I can't give a lot of details. I don't know a
lot of details what they're doing. But it's industrial
work. They work with chemicals. They work with vehicles
and maintain things in that area. So it's an
industrial-type of scenario. So what we based our risk
assessment for, is based on cleanup goals for that type'
of industrial activity occurring at the site, which is
what people would use for a site in Baltimore or people
would use in Harford County for an industrial site.
These are the types of cleanup goals they would have in
that particular site. If this was a residential use, the
levels would obviously, you know, be lower. And this is
comparing the cleanup goals versus the concentrations.
You can see that we exceed our goals just in the
burn area, but not outside that burn area. Keep in mind,
this is an interim action. We haven't fully defined -- I
don't know if Congress has fully defined what the
ultimate use of the Edgewood Arsenal is going to be,
whether it's going to be converted to a residential use,
.or whether it's going to continue to be a military -- you
know, part of a military industrial complex. I have no
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idea, but again, this is an interim action. -This would
be reevaluated if the scenario, the use, of this
particular area or all of Edgewood Arsenal would be
determined. And as we would go back in and cleanup or
remediate those acceptable levels. At this point, this
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is what makes sense.
Now any when we're at this stage, we are
ready to make a decision or non-criteria. We evaluate
all the alternatives that we have'to evaluate for. All
the alternatives we go through go through the screening
process. We look to see, and number one is protection.
Are we proposing something that's going to be protective?
Is it going to meet laws that exist today? Does it have
any long-term effect? Is it going to be long-term
permanent? Those are the type of criteria. There's a
few more. There's six more actually.
Does it reduce the toxicity of the waste?
Does it reduce the volume of the waste? What does it do
to reduce hazards? Can it be done short-term, or is it
something that needs a lot of work to implement? In
other words, it's just a pilot scale project or something
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that may need some technology development to implement.
You know, how quick can you do the fix? How technically
feasible the fix is? Is it something that can work now,
or something that we have to develop something to do
something with?
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And the last three we look at, and the
reason why you're here," you know, we look at the cost.
We look at, you know, if the State agrees with what the
particular alternative we select. And number nine, and
this is why you're here, we're here to solicit your input
from the community to see if we have selected an
alternative that's feasible to ypu all. And this is why
we're here, and I really appreciate you all coming out
here. This is very good. There's a lot of competing
interests not to be here tonight, and. I really appreciate
that.
As part of this, we looked at five
alternatives. Now, the focus feasibility study, which is
in the Edgewood Area Library we also have copies of it
in the poster section. You can look at it. If anybody's
interested in receiving a copy of it, we'll gladly
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provide a copy if you like. Leave a card with.Katrina
Harris down there, and we'll attempt to get you that
particular study.
But what we have here in the focus
feasibility study is we looked at, not only these
alternatives, but other alternatives. And we screened
those out earlier on before we applied the nine criteria
I just talked to you about. So there are some other
types of technologies that we looked at, but were
screened out for one reason or another. It may have been
too experimental. It had never proved itself in an
actual field condition or that type of thing. So we
looked at those. So there are other ones that aren't
here, and I'd be glad to talk to anybody about those.
But we looked at these. No action
alternative. The law requires us to carry that through
with the nine-step criteria evaluation. We looked at
excavating the soil, bringing it to an industrial
landfill, sampling results seemed to indicate this is
non-hazardous, so it could go to an industrial landfill
that was permitted to accept it.
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We looked at on-site treatment and
solidification, remembering that the environmental
response team proved that this waste material could be
stabilized with Portland cement and fly ash, and it could
be, you know, landfilled in an industrial landfill.
' Another alternative, we could bring it to a
hazardous waste landfill and bring it there. It's
perfectly acceptable.
And the fifth alternative is bring it and
consolidate our waste at another site that I'll be
talking about in a few moments, this Building 103
landfill.
To diagrammatically depict this, I have
what I call the measles chart. What the measles chart
does, the black circles means it meets the criteria. The
gray is partially meets.. And zeroes, it doesn't meet the
criteria evaluation factors. No Action 1, you see is a
big zero. It's not protecting us, so it's not carried
through the rest of the analysis. It's not protective.
Leaving the site as it is, is not protective. To a
degree, we can all see that.
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And these are the other alternatives, and
the costs associated with implementing those
alternatives.
This Alternative 3 where we have a partial
gray here with short-term effectiveness, yes, the
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Environmental Response Team study did show it could be
stabilized, but there would be some additional work
actually stretching out the time frame. It wouldn't be a
short-term thing. It is feasible. It can be done. It's
proven technology, but it would not be as quickly
implemented as some of these strictly excavate and move
type of options.
Based on our analysis, we chose Alternative
No. 5. It's protective, It can be done fairly quickly.
Twenty to twenty-five, dump trucks would move this
particular waste out. It wouldn't have to be moved over
any public highways. And any continued releases into the
environment would be stopped.
And in summary, it's 470 cubic yards that
we propose to move and incorporate in the next part
I'm going to talk about the 103 Landfill to
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incorporate in the 103 Landfill.
I'd like to go into the 103 Building.
Again, you drove past it on your way in. There's the 503
site; The burn area is located in this area. The 103
was this brick building here on your right-hand side
where you were coming on post. It's this fenced area
here, the 103. The old Building 103 is actually located
here. It's a fenced area. It's got some vehicles parked
on it. That was the old Building 103 which was a, what
was termed, a miscellaneous fill plant that filled
different types of ordnance, bombs, with chemical warfare
agents, high explosives, that type of thing. And for
lack of a better term, it's called the 103 site, because
some of the process equipment, some of the waste from
that 103 facility could have been placed in this
particular landfill.
The site was a sand pit when they were
building Edgewood, building up Edgewood Arsenal. They
used it as a burial pit. They took the sand and used it
to make concrete. They used it as construction material.
So that excavation that resulted was filled in from
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miscellaneous junk and possibly ordnance items,. This
probably was one of the first landfills here at Edgewood
Arsenal; Probably till about the late 1930s, early
1940s, this area was used for disposal.'
We believe, based on some records of 1937,
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some type of cleanup occurred at the site. And the
present cap, which has eroded away significantly, was
placed on the site. And the site was used sometimes as
an early recycling effort to remove insulation off of
copper wire. But.we don't know, there were no records
kept, there were no requirements to keep records of what
was placed in this particular dump.
Again, when you came on post, this is what
you saw as you came down Hoadley Road. This is the
current building occupied by the Technical Escort Unit.
It's their headquarters. As you're looking at the site,
you can see there are some holes and some bare areas here
where the existing cap, cover system, is widely eroded
away. The site has a chain-link fence around it.
This is what it will look like when you
leave tonight. It will be on your left-hand side. There
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are two monitoring wells located what might be..down
gradient. Building 103 was located up in this area.
Again, you can see it's a depressed area. The lot has
subsided and is settling in this particular dump.
As part of our remedial investigation,
hydrogeologic assessment, the U.S. Geologic Surveyor came
in and installed those wells I showed in the previous
slide. We detected some contaminants in the groundwater
that were sampled in 1987, 1989. As part of the whole
remedial investigation, additional wells are being
planned to be put in here to better define the
contaminated aquifers associated with this.' We don't
know at this point whether contaminants we're seeing
right now at these wells are from the dump or they're
from another source, because there are over 45, maybe 50,
different sites some may be large, some may be very
small -- in this whole Canal Creek Study Area.
I want to spend a few minutes on showing
how the groundwater monitoring was conducted here at APG.
You see two workers at the 103 site. What they're doing
is they're sampling a well. The well is right here.
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This is the protective casing. They're drawing up
through a pump. And what you'll see is a lot of these
drums here. And what these drums are doing are
collecting the purged water. In other words, the water
that's standing in the well is not really representative
of what's in the aquifer. We purge up that water, the
water that's been standing there, to get a better
representative sample of what's in that aquifer that we
want to sample. And that water that we don't analyze for
is placed in a drum and is analyzed for proper disposal.
So the water drums, you'll see around a lot of our wells.
We are containerizing this type of material.
What this gentleman is doing, he's
monitoring the water coming up from the well to see if it
meets certain parameters that were established with the
Environmental Protection Agency and Maryland Department
of the Environment that say that is a representative
sample. At that point, the sample is collected, sent to
an off-site lab for chemical analysis.
Again, we did a risk assessment for this
103 site. We found that there was no exposure to the
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public from the contaminated groundwater at the site.
The contaminated groundwater is not a drinking water
supply either on-site or off-site. Current monitoring
that has been completed by the U.S. Geological Survey
seems to indicate that the groundwater is flowing away
from the installation boundary in a southeasterly
direction flowing towards the Bush River. Complete
extent of contamination, we don't mind. That's part of
the remedial investigation of the site. But that's what
the current mottling and monitoring that were conducted
to date. We haven't stopped, though. We haven't got
all the answers. But we're investigating that further.
What are goals were on this site are a
little bit different than the 503 site. We want to
continue to contain the wastes, and apparently the waste
is not being contained very well, because that cap, the
current cover system, is eroding. It's deteriorating.
We want to minimize precipitation on the site. Like,
right now what we have on this particular site is -- if
you can best relate it to is a coffee filter. Rain
water, surface water, is allowed to percolate right
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through the cap, right through these big holes., that the
animals, groundhogs, have created in the current system,
and react possibly with the material, junk and debris
buried in the dump. So our goal is to minimize, to stop
that from occurring, and also to prevent the -nimals from
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coming back in and eroding the current, the c^;j as it is
today.
So those are our goals. They are very
limited in scope for this site, because it's early
action; it's not final.
We looked at six alternatives that are
depicted in the focus feasibility study. Again, No
Action, has to be carried through that nine criteria that
we described like I described earlier. All these
essentially are variations on theme, putting a cap on the
site. There are different types of caps. Some will meet
State requirements, some don't meet State requirements.
Because we don't have a real good idea of what type of
contaminants, the debris and junk that were buried in
this particular landfill, some of these may not be
applicable. Because some of these, like the industrial
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landfill, we have a handle on what was disposed of and
it's protective enough for that.
So these five alternatives that we looked
at are essentially variations on the same theme. I can
go into a lot of detail about these in our focus
feasibility study, but essentially it's different layers
of protection to prevent surface water and rain water
from infiltrating through the debris in the landfill.
And again, we evaluated these against the
nine criteria, to see which ones they meet. Again, the
same scheme, black being meets, gray is partial, zero
doesn't meet. Again, No Action, does not meet any of the
alternatives.
You see that the first three do not meet
either a federal or a state law for landfill capping, and
this was determined with discussions with Maryland
Department of the Environment.
As part of the focus feasibility study, we
looked at all kinds of alternatives. We selected those
five that carried on to the nine-point analysis. As part
of the focus feasibility study, we had to look at
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excavation. These are some of the points to consider
when considering excavation. Because we don't know the
extent of what could be buried there, we'd have to err on
the safe side, 150 percent safe, and we have a lot of
safety precautions. It's been done in the past. It can
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be done in the future. It can be done today with the
existing technology. It would be slow and time
consuming. We'd have to relocate the people around the
vicinity, possibly regroup the traffic and stuff like
that, because we didn't want to exposure anybody to any
possible accidents that could happen during the
construction or excavations.
And then one of the bigger problems we
have, and if you've been around EPG for a while and
discussions about the mustard incinerator, if there are
any types of wastes that have been identified that when
we pull up don't have a location that they would go to,
an off-site location, there would have to be stockpiles
here at APG or stockpiles someplace. We couldn't just
take them out of the ground and put them back in, and
say, we don't have any place to go with them.
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So that was one of the things that we
looked at. We don't know but it's something that in the
excavation you have to plan for, that some type of
storage that we'd come across, a chemical warfare item or
agent that would have to be stored long-term until the
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nation gets ahold of what to do with all these chemical
warfare agents.
More on the feasibility, I would like to
add that in the alternative versus excavation, that we
looked at the particular cost and rough order of
magnitude you can see it could range as high or even
higher than $9 million to do an excavation. This does
not count disposal. This is just taking the stuff, the
debris and junk out of the landfill and characterizing it
for disposal. Disposal would depend on what you found
and the cost varies greatly in what you find.
So based on that, we decided to elect for
Alternative No. 6, where it is installing a hazardous
waste landfill cap system over the current exposed 103
dump. It will prevent the water filtration, which is one
of our goals. The animal intrusion, it will prevent.
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This is us,ing well developed technology. This^ is not
something that has to be developed. Hazardous waste
landfills are being enclosed, several a year probably in
this country. And a little bit higher cost than the
industrial cap system that we talked about, but that low
cost is not it's more protective. We ought to go
with it.
And very conceptually, this is what it
would look like. And as I was talking about previously,
the 503 ash, that contaminated soil, would probably go in
this not probably, it would go in this layer of cover
soil which would bring the site up to grade and provide a
good stable platform to build these other layers on. If
this meets, acceptance from the public, we've got the
regulatory concurrence on these particular actions. The
next stages are to design, bring this thing beyond
concept into actual design and develop the specification
that actually how this thing is going to be put together.
And everyone here, your neighbors, everyone
is welcomed to get involved in this design process. We
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make the documents, the design documents publicly
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available. We can have subsequent meetings on., a design
to see if there are any other concerns, things we've
missed on this. We've got a very competent design
engineer working on this project, but sometimes our focus
is a little narrow. Your input is really important and
critical for us to do these things the right way.
For both of these actions, the public
comment period, we'll receive your comments in, public
comment period ends on June 24. We will review those,
and what .we have, come up with a Record of Decision,
which is a legal document signed by representatives from
the Army, Environmental Protection Agency. It becomes
how we conduct ourselves in this site. It's up for
review in five years. It's an automatic five-year review
on all of these projects when you have a Record of
Decision. I also, if anything occurs during the design
of this project or if anything happens while we're
constructing the cap, if that's the chosen alternative,
obviously the Record of Decision gets reopened, maybe
another public hearing is held, but it doesn't end right
here. It could go on. The design step, which I want to
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encourage you to participate in, would be a fall/winter
project with hopefully getting the project going sometime
in the early spring of next year.
As part of this project,'and these actually
supplement and complement the remedial investigation, is
that we prepare a health and safety plan, a plan to
ensure that the workers and the community and the people
that work in that building are safe based on our
activities. We do topographical surveys to define the
topography so we can engineer the cap and pick up the
elevations. A soil gas survey to see if there are any
gases. Old landfills tend to produce methane. We do a
survey to determine whether there was any methane
generation and design into the design features to
eliminate any methane accumulations in the building.
Develop vents, maybe charcoal filter the gases that may
be coming up out of the landfill. We have to collect
some data and design that in the process.
We'd borrow sources, this would be off-site
clean fill. We would have to test it to make sure it
meets certain parameters so we wouldn't have this
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subsidence problem that we see today.
Thirty percent design. I said the concept,
it's got a lot of elements in it. It has these type of'
things listed in it. We talked about storm water
management and erosion control. We talk about possibly
designing in a gas methane system. Cost estimate,
schedules, that type of thing, and all these roll up
into a 30 percent design package. A big sheet of
documents.
And after that, the 60/90/100 percent
designs obviously incorporate any comments received on
the previous design submissions which may involve any
other inputs that we receive. In the schedule, it would
have an engineer report. These are all standard. When
you build a building, this is typically the type of thing
that goes on in a 30/60/90/100 percent design. It's not
atypical.
And in the Edgewood Public Library, the
Aberdeen Public Library, Washington College Library,
these are the documents that are available on the 503.
They're available for your inspection there. They're
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available in the poster section so you can see what these
documents look like. If anybody needs a copy of these
documents, we can try to get those to you.
Building 103 consists of these documents
here.
And common documents that relate to both
projects and relate to the whole Canal Creek area are
listed here. Again, they're available. I'll just go
through them rather quickly, just listing them. I'm not
going to read them to you, but they're available. We can
talk about those if anybody is concerned how to find
them, how to get access to them.
At this point, I'm done my presentation on
the particular proposed actions at 503, 103. I guess we
open it up to comments and questions.
MR. MERCER: Do we have any questions or
comments? Okay, if you would please say who you are and
where you're from, so our court reporter
MS. RICE: I'm Sue Rice, and probably most
people here know I'm the president of the APG Superfund
Citizens' Coalition. We have a few. people who have
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written comments prepared, and I think they'd -like to
present them. And for anyone here that doesn't know who
we are,' we're a nonprofit group that's been monitoring
and studying all the activities, environmental
activities, at APG. We have two TAG grants that allow us
to hire technical advisors to help us understand all
these documents that you keep sending for us.
But first, I'd like our vice president,
John Taylor, to give his comments. He's probably, even
more important than anything we can say, one of the
citizens directly in the affected area, and I think he
would like to present his. And he has them in written
form as well.
MR. TAYLOR: My name's John Taylor.
Although I agree with the Army's restoration action at
Building 503, to remove these residual white phosphorous
contaminated soil, I have several questions concerning
the approach to this decision and the additional hazards
that I feel would be created due to these actions.
Number one, will any steps be taken to
reduce the airborne dust created due to the excavation at
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Building 503, such as watering it down or using some
substance that would keep the dust down from going off
into the atmosphere?
Number two, will the contaminated soil be
containerized prior to moving it to Building 103 site?
Or is it just going to be dumped into this site just like
dirt into a pit?
My third question is, how will construction
personnel know an existing cylinder or UXO currently
buried beneath the surface of the 103 site has been
ruptured due to vibration and the weight of all this
heavy equipment vehicles running back and forth on the
site? This has to do with their safety also. You could
have a small explosion under the surface and heavy
equipment operating, you wouldn't, you may not realize it
happened. But then the substance could come up through
the surface, and be very hazardous to them or anyone else
in the area.
Number four, what safety precautions are
being taken to contain any spillage or air release of
hazardous materials due to rupture or detonation of UXOs
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at the Building 103 site? And there is some, .-possibly
there are some UXOs there, and some canisters of perhaps
unknown substances 4 So I think we have to take some
steps to protect, not only the workers, but the community
also within the area, not knowing what this stuff is.
Number five, what are the tradeoffs the
disposing of the contaminated soil off post instead of
creating or adding to an existing hazard across the
street, at the Building 103 site? In other words, you
know, if we know there is a hazardous condition exists at
the 103 site, so by moving this material across the
street, we're just adding to it. So I go along with your
capping idea I think the action was Action 6 except
for the material from 103 going into that.
And the final comment, I feel that the
Army's role is to clean up the existing hazards and
hazardous wastes and not to create or add others, which I
think we would be doing by moving the material across the
street. I also feel that due to the instability that
UXOs in buried canisters of unknown substance at 103, a
more hazardous situation exists, not only for the
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construction .workers who are in direct danger, but the
community as a whole, not just the Aberdeen/Edgewood
area, but perhaps the civilian population within the
area, not knowing what's buried under that site and what
could happen when they start disturbing it or running
heavy material over top of it, heavy equipment. That's
all I have right now.
MR. WROBEL: I can say a few things about
those. I can address your comments in a lot more detail,
you know, as a response of this paragraph. I can send
you a letter. I can send it to
MR. TAYLOR: Certainly.
MR, WROBEL: your group. But let me
just draw a few points. Okay? I wrestled with these
same issues. I have the same concerns of, do you want
this hazard on this site. Okay? We did a calculation,
which has been sort of proven out on other sites here at
Edgewood that when you place two feet of that first
initial cover, that will reduce any pressure of heavy
vehicles running on the site. In other words, you're not
going to have a point. It's going to be spread out, so
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we do not feel that we're going to create a detonation or
a spontaneous detonation once we place that first
two-foot cover just to kind of bring it to grade so we
can provide a stable platform. And the reason why we're
putting that stable is so we won't have subsidence of
this layers on top of it to move that force, that weight
out. It would move out as an aerial type of thing.
We've looked at it. I wrestled with that
for a long time, because I had the same concern. I
talked to our design people and said, you know, go find
the experts and have them calculate this. And we do have
some calculations where* we looked at that in one of the
studies, and I could share that with you at the poster
section. I could bring that out and show you where it
is. But we'll address your comment in writing at the end
of the comment period. So I did wrestle that, and I
agree that that is one of the big concerns here about any
kind of landfill capping here. But based on looking at
the information that we've developed our people are in
Columbus, Ohio out at the Battelle organization. They've
done explosives work across the country. They're
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considered experts by the Army. They feel that this two
foot of cover will spread out the force not to cause a
spontaneous detonation, and it will prevent that.
MR. TAYLOR: Well, this two foot of cover,
I'm sure you're going to do regardless, you know, whether
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you use that two foot of material coming from the 503
site or if you bring in external materials to provide
that cover..
MR. WROBEL: Well, this 470 cubic yards
that I'm talking about is just a small fraction of the
total number of yardage associated with that two-foot
cover, just a small portion of it. We plan on just
putting it we're not putting it in a container we
plan on just putting on the site. We feel, you know,
based on looking at the different costs and the
implementability, all those things are implementable. We
take that, it's feasible, it's 20, 25 dump trucks or a
couple roll-off those large, you know, cubic-large
containers, we could handle this, move it off the site.
We looked at the cost figures. You know, basically we
looked at, we could do this particular action at a
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significant cost savings and still be protective.
MR. TAYLOR: That's today.
MR. WROBEL: That's today.
MR. TAYLOR: But tomorrow when the site,
when the 103 site has to be when there comes a time
when the 103 site has to be cleaned, up, you're going to
have additional cost now of removing that additional
waste material other than what's already there.
MR. WROBEL: But the law requires, the
Resource Conservation Recovery Act, requires us -- we own
that waste whether it's here or-whether it's in another
landfill in Alabama, we -own that waste. That is not
someone else's problem. It's still the Army's problem.
That waste is still ours, whether we remediate it as part
of that cover, if we ever excavate that particular
landfill, or whether we go down to Alabama where that big
landfill is down there and remediate it there, we still
own it. Whether we put it as part of a bigger problem in
Alabama, or we leave it here, try to manage it here on
our site. My call is that, you know, we're still
responsible for it. We have it significant cost savings
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to do it this way. But that's how I balanced .it. The
EPA looked at it, too. We don't lose custody of this
particular waste. It's still ours.
MR. TAYLOR: Has anything been looked into,
the possibility of perhaps covering the 503 site, putting
a cap on that area over there?
MR. WROBEL: That was one of the very early
things.
MR. TAYLOR: Rather than moving the soil.
MR. WROBEL: What I talked about earlier,
one of the very early things we looked at when we were
screening out technologies, you do like a big
brainstorming session. Here's the problem. You get all
the guys around -- engineers, scientists they all sit
down and they brainstorm the ideas. This sort of stuff
you'd do on any other project. And you throw out ideas,
and you don't throw .out anyone's until everyone's got
their ideas listed. Then we look at them to see, you
know, which ones make sense. We do some, a little bit of
analysis, some calculations. And we did look at that.
We looked at stabilization and leaving it on-site,
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putting a cap on it. It seemed to be more feasible since
we're building one cap, doesn't it make sense, why not
just put it all in one cap instead of building two cap
systems. Because it would have to be the same type of
cap. It would have to be this six-foot, what looks like
be a four to six-foot cover system. So we would have a
cover system here, and two cover systems across the
street. I'm not saying that that's not feasible to do;
it's very feasible to do.
But going with a cap system goes the
maintenance cost. You can't just let it go. It has to
be maintained. Whatever vegetative cover you put on
that, it has to be mowed, so you're increasing your
maintenance cost down the road.
We looked at that, and in short order,
that's kind of why it was not screened further as part of
our alternatives.
MR. TAYLOR: Along with that, when you
removed the material from 503, then that's going to be
restored, so it's going to have maintenance cost --
MR. WROBEL: Yeah, but it's not going to be
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this big six foot, it's going to be to grade to the
natural contours of the area. Clean backfill will be put
on, vegetative to the natural contours. Okay. This is a
flat area. It's not compressed. It's relatively at
grade for that particular area. So that's what we would
do to site restore that particular area. We wrestled
with all of those things, and I think we kind of see a
light on those things when we evaluate them.
But like I say, your comments, we have a
reporter if you want to hand those to us, so we're
sure we don't make a mistake"on them, and we'll get back
to you personally and to the president of the committee.
We really appreciate you coming out.
MR. T. 'LOR: And if you'll see that Sue
here gets the comments; she's our president.
MR. WROBEL: Yes, we'll do that. Thank you.
Thanks for coming out.
MR. MERCER: Any other comments, questions?
MS. SQUIBB: {Catherine Squibb, University
of Maryland, and I'm working as an advisor with APG SCC.
Just to follow-up on your action at 103, if you when
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you first go in, you're going to take all yourr
magnetometer readings and try to determine where you have
pits and things like that. It talks about that in your
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reports.
Obviously, you'll probably come up with
some just because there's metal and everything else in
there. To what extent will you perhaps just start
getting in and opening that Pandora's box, when you start
going after to determine whether or not, you know, they
are surface things that you need to take care of before
you start running over it with heavy equipment, or are
you really going to try -to identify them?
MR. WROBEL: We don't really plan at this
point to do any excavations at all, period. The
magnetometry which is you see the people on the beach
with metal detectors -- that's essentially what
magnetometry is looking for, metal objects. There's a
couple other techniques, we call them geophysical
techniques that evaluate what could be in the subsurface.
Those type of things we're going to do that's going to
supplement the remedial investigation. In other words,
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see if we can map out the extent of this thing, so that
when we get to the final answer to this particular site
site closure the whole Canal Greek area and this
particular site we'll have kind of an idea of what
we're dealing with, what we have there. There are no
plans.
MS. SQUIBB: So you're not going to worry
about trying to take off surface munitions or
MR. WROBEL: There are no plans. Now in.
the 503 site, previously we have found fuses laying on
the surface. Those obviously would be recovered and you
know properly disposed. They would not be put you
know, there would be some sort of screening prior to
moving. Get out any hazardous ordnance that may remain
on that 503 site.
MS. SQUIBB: Put you'll be digging?
MR. WROBEL: Yeah, there will be actually
digging. So there will be some we don't envision
finding any UXOs there, but we have in the past found
fuses which are about the size of this pencil that can
take your hand 'f, is about what happens.
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MR. SQUIBB: Well, as you define- this site,
and I know you said before something about, you know,
this dump actually going perhaps under the building or
under the parking lot, is that going to be studied later?
Or in other words, when is that going to cone up and be
an issue, the extent of, you know, what you're not
covering?
MR. WROBEL: Well, as part of the design
effort, we're going to try to define using these
different geophysical tools, magnetometry, metal
detecting, to define the extent of it. Obviously, where
the building is, you can-'t do .a whole lot, because
there's a building there. We're going to try to go
around the area.
We've got a.couple of aerial photographs
that were taken in the late 1930s when the landfill may
have been -- as a dump, may have been inactive. It
doesn't show the Technical Escort building that's there.
You can looked at the planned view of this particular
map, and kind of see that there's a depression. It's
deepest in the middle and it kind of goes out to the
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sides. What appears is that the building may .exist on a
portion of the excavation. Whether there was any waste
placed on these fringes, we don't know. There may be a
little shelf here. It's hard to look, you know, based on
this. You can look at the small picture, and you can
kind of make it out.
You look at some of the planned views, you
can see a little shelf and they went down deeper to make
the burrow, to get the soil, and then to place the debris
and waste in this particular unit.
It seems to be, you know, there's another
road down here I can't recall its name, but it seems
like it's limited to that area, but it may extend a
little bit under the Technical Escort Unit and maybe
under the parking lot. But that would be investigated as
part of a remedial investigation. We do the first step
as part of the design process and carry that through.
You know, the final solution, you know, I
don't have a crystal ball. It might be to demolish this
and extend it to where we can better define it. The
final solution may be an excavation. I don't know. I
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don't have that crystal ball. But right now, .from this
short term, early act interim, seems like this area here,
the cap doesn't exist. We have rain water, surface
water, protruding into it. Put something 'in place, put a
cork on it essentially, and try to look at the whole
picture, see what we're going to do for the whole site.
MR. STACHIW: Just to add to what John's
saying, the final solution could all involve in situ type
treatment as well. That's something we're looking at so
we're not transporting like Mr. Taylor was saying,
just moving the problem here. Even if it wasn't moving
it off post to someplace else, we'd like to eventually as
we get into final solutions to be doing stuff on site,
fixing it right there so it doesn't bother anyone again.
That's what we'd like to do. That's in the final phase.
Right now, we're just trying to make sure it doesn't,
while we're developing the solutions, that we can prevent
any further contamination.
. MR. WROBEL: I had always hoped in my heart
or hearts that the landfill is just this area in here.
As more evidence is accumulating, it does not appear that
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way. Like I said, this is an interim action, _it seems
like it is going to take care of some immediate potential
problems we have right now. But I feel that down the
road, this definitel7 will have to be revisited. It's
gcing to take a lot of real smart engineers and
scientists, and also you folks here that came to this
meeting, and anybody else, neighbors, friends, that need
to be involved with this process, that need to be here,
so we can figure out what is the best thing to do here
for the Army, for the nation, that type of thing, for
this particular site.
The evidence seems to be mounting, it
probably does extend a little bit more than southward
than what I had really hoped to believe it had. But
we'll address them as. the data comes in, more information
comes in.: But we'll try to do an action now that seems
to make sense, knowing that we're going to get to other
things in the future. We shouldn't just wait for all the
cards to come in and all the cards on the table. Let's
see what we can do early on to resolve some potential
problems.
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MS. SQUIBB: We were talking earlier about
how you were going to assure that the people in the
building may not be exposed to gas that is released after
it is capped and forced out. If you know, if you have
just a minute to go through that, and I think that's an
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important issue.
MR. WROBEL: That is an important issue,
very important. I mean, the people that work here, it is
very important. The Directorate of Safety, Health and
Environment would not allow us to do anything unsafe.
What we plan doing, we have in the chart, a soil gas
survey. In other words,-we would put probes, things
about this size, that have some kind of gas collection
absorbent material, within the landfill, to existing
animal burrows. We leave them in there for a time
period, let them accumulate the gases. Then we'll take
these particular tubes that have absorbent material in
it, run it through a chemistry lab, and determine what
determine what types of compounds may be present in the
gases. And then based on that, we can get an estimate,
yes, it's a problem, no, it's a problem, and then design
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accordingly.
There are a couple of alternatives that we
can look at and get involved in the design process. We
can install instrumentation within that building, when a
certain concentration is detected this is stuff that
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exists, it's off the shelf an alarm goes off, everyone
leaves. We could do that.
It could be, I think we're really leaning
right now conceptually, into putting some kind of
gravelly type of gas collection. You know, gas would
collect in the gravel, and a lot of it would vent off,
and then maybe do an active, pull it and run it through
some charcoal filters.
That's all, you know, we recognize it as a
problem. We're going to do some investigative work to
see what the extent of the problem is, and we're going to
design something to deal with it. But it is important to
us, and we definitely don't want anybody to
unnecessarily. And on the flip side of it, if we do have
a gas generation problem, it's going up into the air
right now as we speak. So this cap will prevent that.
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But we'll have to watch where the gas is --
MS. SQUIBB: And then filter it out.
MR. WROBEL: make sure it filters out
before it comes out. So if we're getting presence of the
chemicals does not necessarily mean there's a problem.
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You've got to have those three elements you have to
have chemicals, the concentration, and also personal.
MR. FEENEY: I'm Brian Feeney. I'm with
Penniraan & Browne. And as I-never tire of saying, I'm
not only a technical advisor, but I live within two miles
of APG. And I have several questions.
One of my questions is about whether or not
the sheer weight of the cap is likely to cause
hydrostatic pressure, a downward pressure. The water
table is quite high, as the US Geo Study indicates, and
it's known to be contaminated. Is there any data
available on the fact of hydrostatic pressure, a downward
pushing, onto that groundwater so that it would be
contaminated, the water table would be spread out?
MR. WROBEL: I exactly know what I
picture in my head is that I might say right now we
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have a coffee filter. What you're talking about is we
have like a tea bag that the groundwater reacts to
pressure squeezing out contaminants? Is that what you're
talking about?
MR. FEENEY: If you put a weight on top of
your tea bag or on top of a filter, would it push out and
say that you had a water table leading up to the bottom
of your filter, would the weight on top of it push
downward, the fluid grading push downward and then push
out laterally in all directions, radial expansion? You
don't have to answer it right now. It's a
hydrogeologist's question. It's not an engineer's
question.
MR. WROBEL: I'll tell you right now, I'm
an engineer. I really don't have an answer. We have a
couple of hydro people that would talk to you about that,
will definitely respond to that in our records. I don't
have a feel for it. I mean, the geologists are brought
here, but we will definitely address that.
MR. FEENEY: We'll put the question on the
record.
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MR. STACHIW: Right. We will dp-the
calculations.
MR. WROBEL: We'll do the calculations.
We'll look at that. That's a good point.
MR. FEENEY: Okay. Another question I
have, as I was reviewing the documents, I didn't see any
specific information on the O&M Plan, Operations and
Maintenance Plan, for the cap at Building 103. And my
concerns are with failure in the cap, failure due to
groundhogs, because while a cobble gravel barrier is
pretty good, it.isn't state of the art in caps. I know
from cruel experience how pernicious and persistent
groundhogs can be, and I'd like to know if there is a
data base out there, there is data available on the
tenacity of these buggers and what you might what you
could be expected to anticipate. And should you have
failures, either due to groundhogs or some other cause,
I'd like to know how specific your O&M Plan is for
addressing these failures.
MR. WROBEL: Well, the reason that the
Operations and Maintenance, O&M in the engineering world,
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wasn't addressed) was because these are proposed, you
know, I think it is appropriate to mention those.
Obviously, there would be some maintenance to insure that
the cap's integrity would be there. The Department of
Energy, who we've got as part of the design team on this
particular project, has had experience of putting
long-range planning and thinking on their sites as to how
prevent animal intrusion. They've got sites that are all
over the country, have all kinds of critters, and they've
done that, and I rely on their expertise that, you know,
we can definitely get together and talk about those
specific references.-
MR. FEENEY: In essence, I'm interested in
the scope.
MR. STACHIW: It would have to be in
operation. This goes to the solution, there's going to
be operation and maintenance with any cap we put here.
MR. FEENEY: At which stage will it appear,
the 30%, 60%?
MR. WROBEL: No. Probably later like
around 60, 90%.
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1 MR. STACHIW: In the design phase.
2 MR. WROBEL: Somewhere in the design phase.
3 In fact, I had a meeting with the stake holders today
4 people that actually occupy that particular building, and
5 we discussed that particular issue today. We talked
6 about what the final cover is going to look like, what
7 kind of vegetation we're going to put it. Obviously,
8 they have to look at it every day, outside their windows,
9 so we had a meeting with those particular stake holders
10 to talk about that type of concerns. Obviously, we want
11 to have something that is maintainable, has a little bit
12 of esthetics to it, that/ kind, of thing. We've got a
13 landscape architect as part of the team, we could bring
14 in as part of the team, to develop a cap that would do
15 relatively low maintenance. But that would be addressed .
16 in the design process.
17 I think Dr. Montgomery here he's with
18 the Battelle organization, done a lot work in capping
19 landfills maybe can give us a little bit on this
20 . animal intrusion thing.
21 DR. MONTGOMERY: On the question dealing
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with is this a proven technology. We work, I .work for
Battelle, Pacific Northwest Laboratory. We are run under
the auspices of the Department of Energy, Richland
Operations, in Hanford, Washington. One of the tasks
that we have is to try to identify repositories that will
last for the lifetime of radioactive materials. So we
were looking for natural materials, manmade materials,
plastic liners, things like that.
We don't really have an experience with how
long do they last. Are they going to last 20 years? Are
they going to last 50? Are they going to last 100 years?
So that's why'we went looking for technologies that
utilized natural materials.
So this program was started approximately
in the mid-'80s. And one of the documents that we have
next door relates the experiences from that program. And
we found that a layer of a gravel material does not
maintain its stability when the animals dig down into it,
and it keeps collapsing around. So the they go move off
and find some other place. So for these caps, we're
looking at trying to maintain these things for 10,000
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years. And so that's why they went to the natural
materials.
And part of my job is to take that
technology and then to distribute it out to the general
public and to other government agencies. And so that's
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one of the reasons that we looked at it, because for this
project, I think it's applicable.
MR. FEENEY: That leads me into my next
question about the length of the cap. The cap has about
a 20-year life?
MR. WROBEL: I don't have any kind of
MR. FEENEY: But at any rate
MR. WROBEL: It's probably at least 20
years.
MR. FEENEY: At any rate
MR. WROBEL: 50 or 100.
MR. FEENEY: The point I'm trying to make
is that these measures are interim by definition. And
what you said earlier that it will be revisited, it will
certainly be revisited. And I guess what my question
comes down to, does the Army acknowledge that all options
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are on the table for the final remedial action. That it
may be that removal, drastic and complicated as it is,
it certainly is a very real possibility.
MR. HIRSH: I'm Steve Hirsh for the EPA.
Back to the question on, do we have a reference. Terry
Grim back there from Battelle gave me a book, because I
was interested what are these animals doing. And you
might want to get ahold of this. It's called Deserts and
Dump Sites. And it gives a lot of information about
burrows, and they track these burrows, and filled with
the foam, what the animals do. That's a good reference
for that.
MR. FEENEY: That's the University of New
Mexico perhaps or someplace?
MR. HIRSH: One of those that's the best
resource I found about what the animals actually do, and
what can they get through and can't they get through.
This is a containment remedy, because the
waste remains in place. Any time one of those, there's a.
ROD for containment remedy, there's a five-year review.
It's required, absolutely required, whether it's a final
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action, interim action; it doesn't matter. You leave
waste in place, five years later, you come back and you
take a look at it. You look at all the technologies that
are currently available at that time, five years from
your decision, and you reevaluate the decision. It's
necessary. It's part of the law. You have to do it.
Since it is interim, there needs to be a
follow-up ROD, and of course, you know, anything
everything's fair game in terms of a final ROD. This --
you know, what you need for an interim action is to do
your best and insure that it will not be incompatible
with a final option.
It's not likely I guess John brought up
the point, that yeah, we may have an additional cost down
the road because we're bringing in additional material,
and that's true. The entire cap may become a waste. I
don't know. We don't know about that. That could be. .
But it's not incompatible with the final remedy. If
we're hauling waste out of there, and we have an
increased volume in the future, then so be it.
But review is required by law.
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MR. FEENEY: I only have one question
remaining then. And that is, I'm a little fussy on how
the various RI/FS fit together. There's the groundwater
under Canal Creek, which is if I have my nomenclature
correct -- it's a mini study area.
And then eventually the Canal Creek's 49
operable units will be divided into clusters; is that
correct?
MR. WROBEL: Yeah, it's how you're going to
study different packets of sites. Now, whether we use
the term "sites," "operable units," "areas of concern."
MR. FEENEY: Well, going back to your
analogy, there may be data generated from one remedial
investigation on the contents of the filter, and another
remedial investigation dealing with the operable unit of
the water at the site. And how would the two remedial
investigations fit together? Would it be like at
Westwood, where you have a large generic RI/FS, and then
clusters or some other subdivision being formed under
that umbrella?
MR. WROBEL: It's fairly confusing, but how
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I envision it is that the whole Canal Creek area is going
to have a remedial investigation, feasibility study, what
to do with the whole site soil, the groundwater,
sediments in the creek. It's all going to be studied in
detail in the feasibility study.
To get to that point, we may have a few
more meetings like this, where we've said, well, we've
got enough information on this, we ought to propose an
interim action.
But as part of the final solution, we will
have a record of decision quite possibly for the Canal
Creek area, and most definitely for the whole APG area.
That would all tie all those things in and be probably a
two-day public meeting to do all of that.
MR. FEENEY: And obviously, the point I'm
driving at is that I wouldn't like to see different
aspects of one larger phenomenon being disjointed by
different RI/FS.
MR. STACHIW: That's a good point.
Eventually, the whole thing's got to come together. And
to make it even more precise, it's got to come together
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at Grace's Quarters and Carroll Island as well. The
whole thing has got to be one nice seamless garment is
what it comes down to.
And in the process now, these study areas
were put together for the sake of geographical
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convenience more than anything else. But we're trying to
break them down into hydrogeological reality as to what
influences what. Because decisions made for Canal Creek
are going to influence basically what's going to be done
at Gun Powder River, and it's going to impact on what
kind of decisions you make for Grace's Court. So the
decisions eventually all have to gel together so that
risks in the entire area is mitigated.
So eventually, in the very beginning stages
of trying to put together the big complicated situation,
which you can see our work plan is a huge series of
curved diagrams like trying to land someone on Mars
and then eventually having the whole thing come together
into one ROD of the entire base. So that's the process.
We're not trying to separate them independently of one
another.
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But sometimes you can go and see-something
that makes sense to do now, instead of just letting it go
until you come up with a solution that might take ten
years to come up with. There's things you can do now,
and that's what we're trying to do. Does that help?
MR. FEENEY: That's very helpful.
MR. WROBEL: Another question?
MS. RICE: I think a good bit of ours are
written, and we'll submit them. But I think Dr. Squibb,
did you want to go over some of your other written ones?
DR. SQUIBB: No, I'think a lot of my others
are actually ones to be addressed during the design
phase, the way I'm hearing you. Actually the specifics
on how you do things, like what filters and --
MR. WROBEL: Right, that all comes out in
the design. That's correct.
MS. RICE: I think we have one set of
written remarks to give you tonight, though, right, that
they don't previously have.
DR. SQUIBB: Yeah, I can hand them in, with
sort of detailed questions, and you can decide --
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MR. STACHIW: All these questions will be
included in the transcripts. A transcript of this
meeting will be in the library. It won't be part of the
record of decision, but will be part of administrative
record. Everything that you heard today will be
that's why we have a court reporter.
MR. HIRSH: This is Steve Hirsh again. The
other thing that happens is, you know, these kind of
comments that we gave you, too, be'come part of the record
of decision, so the decision makers that actually sign
these documents get that. It is actually three pieces
the declaration gets signed by Deputy Assistant
Secretary of the Army, the APG Commander, and my Regional
Administrator. So there's that not the signature page
there's essentially a "what's going on" section and it
describes the alternatives, what's being done, what it
alleviates, what the future is, and then the third part
is called "response and summary," and all the questions
are written down in there along with the written
responses. So the decision makers get that as well.
DR. SQUIBB: Just one more question. You
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said that eventually it would be nice to do this
remediation in situ and clean this all up, and that's
what we're looking for. Who's funding some of the work .
that will actually make that possible? Who's looking
into bioremediation of, you know, chemical agents and
MR. STACHIW: That would be part of the
feasibility studies that we'll do, which will include
pilot studies and things of that nature, when we start
getting to the point of that like Brian was talking
about, you know, for Canal Creek you may have two
problems. You have the stuff that's buried and in the
soil in this landfill, or other stuff that may be in
sewer lines or whatever throughout the whole area, which
would be problematic to dig up,'and you have the
groundwater.
So we're looking upon those things, it's
the source and groundwater is two separate problems.
Okay? Groundwater is something we're pursuing a
solution to, and then and for the most part,
groundwater is the vector that's causing contamination to
leave. Whereas the stuff that's in the ground is either
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going to the groundwater or venting into the Atmosphere,
one or the other or maybe not one, maybe the other.
Then we would look at, what do we do with
that stuff? Do we dig up the entire base, or do we find
ways to treat it right in the ground itself, so it
doesn't release into the groundwater anymore, it doesn't
release into the atmosphere. Those are the kinds of
things we would at least look at as one of the
alternatives to digging up, or not doing anything, or
something else. And part of what we need to do is pilot
studies as part of the feasibility.
Survey existing technologies, see what's
working, and then try it here and see if it works, and
then with that, proposing that to the group.
MR. HIRSH: There, are also other
organizations. The entire issue of how you dispose of
chemical weapons doesn't fall on Aberdeen's shoulders.
There are other Army organizations and DoD organizations
that are working on things, such as, how do you get the
liquid fills out of the munitions? There are other
agencies out there thar. are working on parts of the
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problem. It's not just an Aberdeen issue. These things
are in other places.
MR. WROBEL: And part of the resources that
we've used is Department of Energy resources. They've
got problems! in some ways dissimilar but some ways
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similar to us, so by establishing linkages with the
Department of Energy National Labs, we get access to a
lot of the information as it is learned. I've learned a
lot from Dr. Montgomery about, you know, well, we tried
that ten years ago, or three years ago, and it didn't
work then. The technology hasn't improved. So that kind
of information sharing between two big organizations
the Department of Defense, the Department of Energy
we've tried to do here at APG to kind of work together.
Why should the taxpayers pay twice for the same type of
research done someplace else?
So we're trying -- I'm trying to do that
here, because I, you know, I acknowledge that there's a
lot of information. Like Steve said, there are other
Department of Defense activities looking at us, so we try
to keep abreast by going to conferences and whatnot, try
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to see what's out there, trying to bring in the best
people we can find to work on these particular
situations.
MR. FEENEY: That brings to mind another
question. Not long ago, we had our counterparts in
Russia come to the Joppa Library, and they live
they're neighbors of APG's counterpart in Russia whose
name I forget. Has there been any communication, maybe
you both inventing the wheel in isolation?
MR. STACHIW: They spent the day with us
here at APG. And they've asked for numbers of documents,
which we've sent over to 'heir point of contact in
Kentucky the kinds c lings we had that they were
interested in. So, how. r, they didn't make known to us
anything that they had tiiac was of interest to us.
MR. FEENEY: Technology transfers.
MR. HIRSH: And we have sent delegations
over there, and there's work, but in general, the
technology transfer is that way.
MR. STACHIW: I think Battelle just
announced last week, it was successful in receiving a
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contract to support the Russian derail effort. -They've
been working this for.several years, and we're one of the
many organizations that is going to help them to clean up
their problems over there. So this is a global thing and
technology sharing, and what's going on throughout the
states and throughout the world today. Battelle is
involved in Canal Creek, and so therefore, we will
continue
MR. WROBEL: Because it's such a complex
site, we're trying to find well, I tried to find for
the Army an organization that had that kind of reach.
Battelle is a very large-organization. It's a not-for-
profit organization. It has access to a lot of
information. They've been in this business of chemical
warfare, and so there's going to be some kind of
information exchange on that particular aspect.
So what I've tried to do is assemble a team
of people. And why I'm here today to talk you all, is to
bring you guys into the team also, have some sessions
like this, technical meetings, look at the design, so we
can come to grip with this kind of complex problem that
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needs some kind of resolution in the future. ;And I'm
hoping to establish that with the Department of Energy
through Battelle. I have access to their incredible
amount of information, lessons learned', and bring you all
folks in to design projects, look at the remediations. I
will send you copies of everything that Steve and John
receives, you receive copies of all the work plans, the
schedules, time frames, and that type of thing, for all
the types of things that we're doing. That information
is voluminous, but that's what we have to wade through,
too, to get to the bottom of this.
MR. MERCER: Any other questions or
comments? Yes, sir.
MR. HESSELTON: Ken Hesselton from Harford
County. Anyone that's concerned that their public
representatives aren't here tonight, there happens to be
a County Council meeting. Your council representative of
District 8 and the Edgewood Area, Mrs. Hesselton is at
the council meeting and regretfully not here. Also Mr.
Barker who represents the Edgewood Arsenal is also there.
Now, if I can associate myself from that,
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because there's one thing about this report that has
disturbed me just looking at it. I haven't been getting
involved here for several years. John and a few others
will tell you I have been trying to be with the Citizens
Coalition, citizens committees on this. I have a lot of
respect for the people who work with the Army. But I am
bothered by this for a couple of reasons.
You've described the site at 503 Building.
You identified materials, lead, zinc, 'hexachlorobenzene,
hexachloroethane. Then we come over to the site 103,
which is obviously much larger. There's no statement as
to the number of yards it involves. And there's
statements like simply "there were groundwater samples
found several solvents in the groundwater below the
site." Nothing else describes the extent of materials on
this particular site.
You conducted a study to determine that
there's no direct public exposure to any site chemicals.
And the water beneath the site is not a source of
drinking water.
Well, I can go out in the woods and say,
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that big old rotten land isn't going to hurt anybody,
because there's no one standing under it. I'm somewhat
concerned there's nothing that defines the speed of
movement of the groundwater off that site, any
indications as to what you're undertaking to determine
exactly how far the contamination has been transported,
and there's no indication you did any study to determine
if compressing the water table at that point would tend
to retain the materials in the vicinity.
It's just my impression that the toxins and
the chemicals in the drinking water has been treated
just looking at this-document, nothing else very
casually. That's all I'm going to say. I'm not saying
you didn't treat it properly, but I read this, I get that
impression. And that's a comment. It doesn't deserve an
answer.
MR. STACHIW: You're right, okay, this
doesn't attempt to address itself to groundwater
problems, although i think Brian raised an interesting
issue as to with this hastening in the ground. We know
there's groundwater problems underneath, and we're
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studying the groundwater overall in this area,-with
hopefully an interim solution be proposed for at least to
start get feelings for what we think is a good solution'
and what you think is a good solution maybe about a year
from now.
It's not moving that fast that you've got
to be concerned about it in a year's time. We know that
much. We have computer models of the groundwater below
all of Canal Creek. But we're moving toward a solution.
This is not attempting to address the groundwater as a
problem per se. We will be that doesn't mean we're
not trying to address groundwater. We are, and that's
one of our that's our next highest priority in the
Canal Creek area. So we'll be heading toward that one in
about a year's time or so.
DR. MONTGOMERY: Another response to that,
Mark Montgomery, with the compounds at 503, there are
known health effects, there are standards, OSHA
standards, for lead and zinc, and compounds like that.
And so we have a good handle on, how do we protect
ourselves if we're going to go on and sample it? So that
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allows us to get in and get information on itr
In 103, because things could have been
dumped there, chemical agents, could be munitions. At '
503, you could go in and we can protect ourselves and do
our sampling. At 103, how do you protect yourself
against that one bomb that is six inches underneath the
surface? You hit it, and it pops. And so what we're
doing in our design is using remote non-invasive
technologies to try to determine what's coming, what's
being emitted out of it, as opposed to going in and
physically taking the samples out of it.
So that's why there's a lot of information
on 503, but there is not a lot on 103. And through the
monitoring that we're doing with the groundwater there
and through the vapors coming off, we're going to
determine what's in there.
MR. WROBEL: I probably breezed by this
too .quickly when I did ray presentation, but there are
common documents within the administrative record that
deal with the types of things that you're talking about
-- groundwater chemistry report, hydrological data,
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hydrodology of the Canal Creek area, talks about where's
it going, how it's going. I'm sorry, I breezed through
that very quickly.
MR. HESSELTON: All I'm saying is, this
document glosses over it. I'm not saying you didn't do
something. This thing makes it sound like you didn't.
That's what I'm saying. You don't have to explain all
this to me. I'm saying, this document makes it sound
like, there's no problem there, nobody's going to drink
it, and that's not a good clear concise comment that you
should use when you've got toxic chemicals in water.
When you found them there, and then you just say, well,
it's no problem, because nobody's drinking it, is not
is a poor comment to put in a document. You should say,
it's contained, it hasn't, migrated beyond this point, and
we're studying it further. That, I could have bought.
But this seemed to be a very careless statement in the
document. That's all I'm trying to point out.
I'm not telling you what's there and you're
not doing these things. I'm saying that this is what
this thing says.
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MR. WROBEL: I just threw this up, that we
did look at, based on operations that may have occurred
at Building 103, these are the type of things that could
be expected to be found possibly in the dump. We did do
a search based on particular processes that would have
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occurred. They're in the '20s and '30s, when that
building would have been operated as a fill area -- the
types of things that could possibly be there.
MR. PAUL: I just want to say that we can
address that comment by making a revision to the package,
putting out another revision.
MR. MERCER: Any other comments,
questions? I would like to remind people that the public
comment period for these projects runs to June 24th.
They can call the information line, and that number is
272-8842. Or you can write, you can send written
comments to John Wrobel. That address is in the fact
sheets, however I will read it to you. That's
Directorate of Safety, Health and Environment, U.S. Army-
Aberdeen Proving Ground, Attention: STEAP-SH-ER (J.
Wrobel), Aberdeer, ~ roving Ground, Maryland 21010-5423.
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That's is on the fact sheets. We will be going for a
period of time, we can go back into the room where the
displays are, and you can pick up a fact sheet or ask
questions there as is necessary. But the public comment
period does run to June 24th.
We also want to ask you on your way out,
there are evaluation forms on the table out there.. If
you would please do us a favor and fill out an evaluation
form and make any comments or whatever concerning this
particular meeting and its conduct, and what changes,
suggestions, whatever you might have; we would appreciate
it. You can leave them,- there's a box on the table out
there.
In the meantime, if there are no other
comments or questions, thank you very, very much for
coming and participating. It makes everybody's job a lot
easier by having your participation. Please feel free to
go into the other room, now that we've gone over things,
and look and see what we have. Thank you.
(Meeting concluded at 9:10 p.m.)
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COMMUNITY MEETING - MAY 24, 1994 90
STATE OF MARYLAND )
) CERTIFICATE
COUNTY OF HARFORD, SS: )
I, BARBARA J. RUTH, Notary Public, do hereby certify
that the foregoing public meeting held May 24, 1994 at
the APG Edgewood Area Conference Center, Building 4810,
Edgewood, Maryland, was taken and transcribed by me; and
that the foregoing pages constitute a true and accurate
transcript of the said public meeting.
I do further certify that I am not of counsel for or
in the employment of any of the parties.
In Witness Whereof, I have hereonto subscribed my
name this the 8th day of June 1994.
n BARBARA J. RUTH
' NOTARY PUBLIC
MY COMMISSION EXPIRES: 04/07/96
(RECORDED TAPES ARE RETAINED FOR 30 DAYS FROM DATE OF
CERTIFICATE.)
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Final
February 28, 1995
APPENDIX C. REFERENCES
IGF Kaiser Engineers, January 1991. Baseline Risk Assessment for Eight Selected Study Areas at
Aberdeen Proving Ground, Maryland. Draft Report, Vol I, Chap 1-7, prepared for U.S. Army Corps
of Engineers Toxic and Hazardous Materials Agency, Task Order No. 11, Contract No. DAAA15-88-D-
0009, January 1991.
Oliveros, J.P.; Gernhardt, P.; 1989. Hydrogeologic Data for the Canal Creek Area, Aberdeen
Proving Ground, Maryland, April 1996 - March 1988. Open-file Report 89-387, U.S. Geological
Survey, Towson, Maryland, 1989.
Oliveros, J.P.; Vroblesky, D.A.; 1989. Hydrogeology of the Canal Creek Area, Aberdeen Proving
Ground, Maryland. Water-Resources Investigations Report 89-4021, Towson, Maryland, 1989.
Lorah, M.M.; Vroblesky, D.A.; 1989. Inorganic and Organic Ground-Water Chemistry in the Canal
Creek Area of Aberdeen Proving Ground, Maryland. Water Resources Investigations Report 89-4022,
U.S. Geological Survey, Towson, Maryland.
Nemeth, G. et al; 1989. RCRA Facility Assessment, Edgewood Area, Aberdeen Proving Ground,
Maryland, report No. 39-26-0490-90, U.S. Army Environmental Hygiene Agency, Aberdeen Proving
Ground, Maryland.
Nemeth, G., J.M. Murphy Jr., and Zarzycki, J.M., 1983. Environmental Survey of the Edgewood
Area of Aberdeen Proving Ground. Report No. DRXTH-AS-FR-82185, U.S. Army Toxic and
Hazardous Materials Agency, Aberdeen Proving Ground, Maryland.
Jacobs Engineering Group, January 1992. Program Development Report, Canal Creek Area IRP
Sites, prepared for Battelle Environmental Management
Operations, January 1992. »
U.S. Army Toxic and Hazardous Materials Agency, 1976. Installation Assessment of Aberdeen
Proving Ground. Volume I and JJ, Report No. 101, Aberdeen Proving Ground, Maryland.
Federal Facility Agreement, March 1990, between the U.S Department of the Army, Aberdeen Proving
Ground and die U.S. Environmental Protection Agency, Region III.
Personal communication with Dr. L. McGinnis, Argonne National Laboratories, Argonne, IL.
USEPA, 1989. Technical Guidance Document: Final Covers on Hazardous Waste Landfills and
Surface Impoundments, Report No. EPA 530-SW-89-047, Office of Emergency and Remedial
Response, Washington D.C.
USEPA, 1988. Draft Guidance for Conducting Remedial Investigations and Feasibility Studies Under
CERCLA, OSWER Directive 9355.3-01, Office of Emergency and Remedial Response, Washington
D.C.
v
USEPA, Handbook: Remedial Action at Waste Disposal Sites, Report No. EPA/625/6-85/006, Office
C-l
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February 28, 1995
of Emergency and Remedial Response, Washington D.C.
USEPA, 1982. Draft RCRA Guidance Document - Landfill Designs, Liner Systems, and Final
Cover, Report No. PB87-157657, USEPA Office of Solid Waste, Washington D.C.
Dames and Moore, 1992. Focused Feasibility Study for the Mfchaebville Landfill Cap and Cover
System, Final Report, prepared for U.S. Army Corps of Engineers, Baltimore District, Contract #
DACA31-91-D-0031, Baltimore, MD.
Dames and Moore, 1994. Building 103 Dump and Building 503 Burn Sites, Final Work Plan,
Supporting Activities prepared for Battelle
Personal communication with Ms. L. Miller, Dames and Moore, Linthicum, MD.
Reith, C.C., Caldwell, J.A., 1990. Vegetative Covers for Uranium Mill Tailings, Jacobs Engineering
Group, Inc. Albuquerque, NM.
Personal communication with Dr. C. Reith Jacobs Engineering Group, Inc. Albuquerque, NM.
McGinnis* L.D. et al, 1992. Geophysical Study of the Building 103 Dump, Aberdeen Proving
Ground (Draft Report).
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