PB96-963902
EPA/ROD/R03-96/215
June 1996
EPA Superfund
Record of Decision:
Aberdeen Proving Ground (Edgewood),
Soils and Operable Unit, Edgewood, Md
4/1/1996
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Final
April 4, 1995
FINAL
RECORD OF DECISION
INTERIM REMEDIAL ACTION"
BUILDING E5265 (BLDG 503) SMOKE PILOT PLANT BURN SITES
SOILS OPERABLE UNIT
EDGEWOOD AREA-ABERDEEN PROVING GROUND, MD
APRIL 1995
Distribution Restriction Statement:
APPROVED FOR PUBLIC RELEASE; DISTRIBUTION IS UNLIMITED 0689-B-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 (NEPA)
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Final
April 4, 1995
RECORD OF DECISION
for
INTERIM REMEDIAL ACTION
BUILDING ES26S (BLDG 503) SMOKE PILOT PLANT BURN SITES
SOILS OPERABLE UNIT
APRIL 1995
U.S. ARMY, EDGEWOOD AREA-ABERDEEN PROVING GROUND, MARYLAND
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Final
April 4, 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 2
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 503 Area Geology 8
2.1.3 Building 503 Area Surface Water 8
2.1.4 Building 503 Area Ground Water . 9
2.1.5 Building 503 Area Climatology 10
2.1.6 Building 503 Area Land Use 10
2.1.7 Building 503 .\rea Flora and Fauna 11
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 11
2.2.1 History of Site Activities 11
2.2.2 History of Investigations/Remedial Actions 12
2.2.3 Enforcement Activities 12
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 13
2.4 SCOPE AND ROLE OF THE SOILS OPERABLE UNIT 14
2.5 SUMMARY OF SITE CHARACTERISTICS 14
2.5.1 Building 503 Burn Site Soil Information 14
2.6 SUMMARY OF SITE RISKS 20
2.6.1 Human Health Risks 20
2.6.2 Environmental Evaluation 21
2.6.3 Remedial Action Criteria 23
2.7 DESCRIPTION OF ALTERNATIVES 25
2.7.1 General 25
2.7.2 Description of Alternatives 29
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 30
2.8.1 Threshold Criteria 31
2.8.2 Primary Balancing Criteria 32
2.8.3 Modifying Criteria 34
2.9 DESCRIPTION OF THE SELECTED REMEDY 34
2.10 STATUTORY DETERMINATIONS 36
2.11 DOCUMENTATION OF SIGNIFICANT CHANGES 40
RESPONSIVENESS SUMMARY 41
3.1 OVERVIEW 41
3.2 BACKGROUND ON COMMUNITY INVOLVEMENT 42
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April 4, 1995
TABLE OF CONTENTS (CONT.)
Paragraph
3.3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
-COMMENT PERIOD AND AGENCY RESPONSES 43
3.4 PANEL OF EXPERTS 59
3.5 SELECTED NEWSPAPER NOTICES ANNOUNCING DATES OF PUBLIC
COMMENT AND LOCATION AND TIME OF PUBLIC MEETING 59
FIGURES
Figure Page
Figure 1 Aberdeen Proving Ground Regional Location Map 5
Figure 2 Location of Building 503 in the Edgewood Area-Aberdeen Proving Ground .... 6
Figure 3 General Location of the North and South Burn Areas 7
Figure 4 Location of Samples for Analysis in the Northern Burn Site Area 18
Figure 5 Location of Samples for Analysis in the Southern Burn Area 19
Figure 6 Extent of Planned Remediation in the North Burn Area 27
Figure 7 Extent of Planned Remediation in the South Burn Area 28
TABLES
Table Page
Table 1 Highest Contaminant Levels at the North and South Burn Sites from Battelle
Samples 20
Table 2 Oral Toxicity Criteria for Chemicals of Concern at the Building 503 Burn
Sites :' 22
Table 3 Risk Assessment Scenario Results for Chemicals of Concern at Building 503
Burn Sites 24
Table 4 Cost Estimate for the Selected Interim Remedial Action for the Building 503
Burn Sites 36
Table 5 Review of Potential Action-Specific and Locational ARARs for the Building
503 Burns Sites Selected Remedy (See note) . 39
APPENDICES
Appendix Page
APPENDDC A PUBLIC MEETING TRANSCRIPT A-l
APPENDIX B PUBLIC MEETING B-l
APPENDIX C REFERENCES , C-l
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Final
April 4, 1995
RECORD OF DECISION
Building E5265 (Bldg 503) Smoke Pilot Plant Burn Sites Soils Operable Unit
Interim Remedial Action
U.S. Army Edgewood Area-Aberdeen Proving Ground, Maryland
April 1995
SECTION 1
DECLARATION OF THE RECORD OF DECISION
1.1 SITE NAME AND LOCATION
Building H5265 (Bldg 503) Smoke Pilot Plant Bum Sites Soils Operable Unit, U.S. Army Edgewood
Area-Aberdeen Proving Ground, Maryland.
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document presents a determination that an interim remedial action will be taken to
excavate soil and ash from the Soils Operable Unit, Building ES26S (Bldg 503) Smoke Pilot Plant Burn
Sites at the U.S. Army Edgewood Area-Aberdeen Proving Ground (APG-EA), Maryland. The excavated
soil and ash will be moved to the Building 103 dump site where it will provide some of the fill necessary
to form the required base prior to capping and covering of the Building 103 dump.
This determination was developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980, as amended by the Superfund Amend-
ments and Reauthorization Act (SARA) of 1986. Preparation of this Record of Decision (ROD) was
directed by the Directorate of Safety, Health, and Environment (DSHE) for the Army as the owner/
operator. Support was provided by the U.S. Environmental Protection Agency (EPA) Region ffl and by
the Maryland Department of the Environment (MDE).
The MDE concurs that this interim remedial action is protective of both human health and the
environment.
1.3 ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Building 503 burn sites, if not
addressed by implementing the interim remedial action selected in this ROD, may present imminent and
substantial endangerment to public heath, welfare or the environment.
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Final
April 4, 1995
1.4 DESCRIPTION OF THE INTERIM REMEDIAL ACTION
at*
The selected interim remedial alternative is excavation of the contaminated soil and ash in the
Building 503 burn sites followed by disposal of the soil and ash at the Building 103 dump. The soil and
ash from the Building 503 burn sites will form part of the required subbase under the capping and
covering system for the Building 103 dump. Tests performed in 1993 indicate that the soil and ash waste
is not a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA).
1.5 STATUTORY DETERMINATIONS
The selected interim remedy is protective of human health and environment, and is cost effective.
It also 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 and
alternative treatment technologies to the maximum extent practicable for this site.
Selection of the interim remedial action is based on the need to provide a remediation of
contaminated soil and ash located near Building 503. Remediation of the ground water in the Canal
Creek Area is a complex problem, requiring a risk assessment and Remedial Investigation/ Feasibility
Study (RI/FS) which will evaluate remediation alternatives for the entire APG-EA. To reduce risk and
address the immediate hazard posed by the soil and ash, the Army and EPA have resolved to address soil
contamination at the Building 503 burn sites separately from Contamination at other portions of the Canal
Creek Area, by providing for early remediation of contaminated soil and ash in the burn areas. This
interim remedy has a periodic review requirement to determine its effectiveness and whether further
remedial actions are necessary. The risks posed by the Building 503 site will be further evaluated in an
ongoing comprehensive human health and environmental risk assessment. If such evaluation reveals that
no further remedial action of the soils at Building 503 is necessary to protect human health and the
environment, this action may be final.
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Final
April 4, 1995
LEAD AND SUPPORT AGENCY ACCEPTANCE
OF THE RECORD OF DECISION
U.S. ARMY EDGEWOOD AREA-ABERDEEN PROVING GROUND, MARYLAND
FOR INTERIM REMEDIAL ACTION AT
BUILDING E5265 SMOKE PILOT PLANT BURN SITES SOILS OPERABLE UNIT
Signature sheet for the foregoing Record of Decision for die Interim Remedial Action Soils Operable
Unit, Building ES265 (Bldg 503) Smoke Pilot Plant Burn Sites at the U.S. Army Edgewood Area-
Aberdeen Proving Ground between die U.S. Army and me U.S. Environmental Protection Agency
(EPA), Region ID, with concurrence by the State of Maryland Department of Environment (MDE).
J(Jl 1995'
Date
'Richard W. Tra?
Major General,
Commanding
Aberdeen Proving Ground
1 6 NOV 1995
Date
Raymond J. £atz
Acting Deputy Assistant Secretary
of the Army (Environment, Safety
and Occupational Health)
OASA
Date
Director, Hazardous Waste Management Division
U.S. Environmental Protection Agency
Region HI
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Final
April 4, 1995
RECORD OF DECISION
INTERIM REMEDIAL ACTION
BUILDING 503 SMOKE PILOT PLANT BURN SITES SOILS OPERABLE UNIT
EDGEWOOD AREA-ABERDEEN PROVING GROUND, MARYLAND
SECTION 2
DECISION SUMMARY
This Decision Summary provides an overview of the problems posed by the conditions at the Soils
Operable Unit for Building E5265 (Bldg 503) Smoke Pilot Plant Burn Sites, the remedial alternatives,
and the analysis of those alternatives. Following that, it explains the rationale for the remedy selection
and describes how the selected remedy satisfies statutory requirements.
2.1 SITE NAME, LOCATION AND DESCRIPTION
2.1.1 General
As shown in Figure 1, Aberdeen Proving Ground (APG) is located along the Chesapeake Bay
in Harford County and Baltimore County, Maryland, about 15 miles norm of Baltimore. APG is divided
into two main areas by the Bush River. The area norm of the Bush River is referred to as the Aberdeen
Area of APG, and the area south of the Bush River is referred to as the Edgewood Area of APG (APG-
EA).
The Aberdeen Area was established in 1917 as an ordnance proving ground and was used
historically as a testing area for tanks, ordnance hems and other military equipment. 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 n (WWII) the APG-EA was also the location of production-scale chemical agent manufacturing.-
Building 503 is located near the former location of old Filling Plant #2 (now demolished), at the
intersection of Hoadley Road and Noble Road in the Canal Creek Area of APG-EA (see Figure 2). It
was constructed in 1918, and was intended to house a filling plant for large-caliber shells. Construction
was not completed prior to the end of WWI however, and there is no indication mat the plant was ever
completed or used for the filling of munitions with chemical agents. Despite this, Building S03 was
commonly referred to in WWI literature as the large-caliber filling plant Small surrounding buildings
also were used for operations related to filling. During at least a portion of the period between WWI and
WWII, including the early and mid-1930s, Building 503 was used as a garage, gasoline filling station and
carpenter shop.
The Building 503 Burn Sites Soils Operable Unit consists of two ash-covered barren areas located
east of Building 503 (see Figure 3), which were used for the open-air testing of experimental smoke
mixtures and smoke munitions, and for disposing of experimental smoke mixtures and munitions by
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Final
April 4, 1995
LEAD AND SUPPORT AGENCY ACCEPTANCE
OF THE RECORD OF DECISION
U.S. ARMY EDGEWOOD AREA-ABERDEEN PROVING GROUND, MARYLAND
FOR INTERIM REMEDIAL ACTION AT
BUILDING E52« SMOKE PILOT PLANT BURN SITES SOILS OPERABLE UNIT
Signature sheet for die foregoing Record of Decision tor the Interim Remedial Action Soils Operable
Unit, Building ES26S (Bldg 503) Smoke Pilot Plant Burn Sites at the U.S. Army Edgewood Area-
Aberdeen Proving Ground between the U.S. Army and the U.S. Environmental Protection Agency
(EPA), Region in, with concurrence by the State of Maryland Department of Environment (MDE).
Bf7 J/JL 1995'
Date
'Richard W. Tr
Major General,
Commanding
Aberdeen Proving Ground
Army
NOV 1995
Date
Raymond J. f atz ~ ^
Acting Deputy Assistant Secretary
of the Army (Environment, Safety
and Occupational Health)
OASA a,
Date
Thomas C. Voltaggio
Director, Hazardous Waste Management Division
U.S. Environmental Protection Agency
Region m
SYMBOL »
SURNAME »
DATE »
3HUSO
HIRSH
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3RC33
HEKOERSHOT
' A \ ,' V f
3RC33
AJL
3HUSO
SOKOLOUSKI
3HW02
FEROAS
EPA Form 1320-1
Celebrating
of Environmental Progress
OFFICIAL FILE CO
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Final
April 4, 1995
ABERDEEN
PROVING l **
GROUND
n
2$ MILES
10 KILOMETERS.
Figure 1 Aberdeen Proving Ground Regional Location Map
5
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April 4, 1995
Figure 2 Location of Building 503 in the Edgewood Area-Aberdeen Proving Ground
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April 4, 1995
fc*
Figure 3 General Location of the North and South Burn Areas
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April 4, 1995
open burning. The north burn area was used as early as 1943, and the south site was in use starting
about 1951. Use of these sites for testing and disposing of smoke mixtures and munitions ceased in 1975.
The north burn site is the larger of the two, with an approximate total surface area of 10,540 ft2. The
south site is smaller with a total area of approximately 2,160 ft2. The total area of the two barren sites
is estimated to be-about 12,700 ft2. The barren surface of the two burn areas can be characterized by
visual observation of color and texture of the surface materials as two distinct areas: a central area
covered with a granular ash and a surrounding perimeter or sandy soil with little or no vegetation. The
ground surface is relatively level and flat with minor undulations and changes in elevation.
Buildings and facilities at APG-EA have been assigned numbers using different systems during
various time periods. During the early 1960s the original numbering system, consisting of one- to four-
digit numbers, was changed to a four-digit numbering system. There is no correlation between the old
and the new numbering systems. In the new numbering system, Building 503 was assigned the number
E526S. Historical maps and records use the old numbering system. Development of documents for the
Building 503 interim remedial action drew on existing documents. Therefore, the old numbering system
is used in this ROD.
2.1.2 Building 503 Area Geology
The geology at APG-EA was determined by the U.S. Geological Survey (USGS) in a study con-
ducted in the Canal Creek Area. 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 unit. 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
activities affect the aquifers.
2.1.3 Building 503 Area Surface Water
The Building 503 site is not within the 100-year floodplain, and has a ground surface elevation
from 14 to 25 feet above mean sea level (MSL). The topographic slope is to the southeast. Run-off from
the south burn site is to the south/southeast. Run-off from the north burn site is predominantly to a sewer
on the east boundary of the Building 503 complex, approximately halfway between the two burn sites.
This sewer is part of the old chemical/storm sewer system that once served Filling Plant #1 and
discharged directly into the east branch of Canal Creek.
This sewer is likely to receive contaminants from the Building 503 burn sites. Because the drain
is at the lowest elevation in the vicinity of the north burn site, run-off from the north burn site collects
in and around this drain, where it percolates into the soil or evaporates. It is possible that some run-off
may flow from here to the east branch of Canal Creek. This chemical/storm sewer drainage system is
no longer in use. The system may have been blocked, and it appears that a pipe leading from the drain
has been sheared. The entire drainage system of the Building 503 complex will be addressed as part of
the overall Canal Creek RI/FS.
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April 4, 1995
2.1.4 Building 503 Area Ground Water
The surficiaJ aquifer is unconfined and is defined as the saturated part of the uppermost sand and
gravel layer (0-35 feet) (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 flow system.
The lower confined aquifer is separated from the two overlying aquifers by an overlying confining
unit. The direction of flow in the confined aquifer is also east/southeast.
The USGS has installed four ground-water monitoring wells (wells 36A, 36B, 36C, and 36D) east
of the north burn area. These four wells are part of the 168-well ground-water monitoring system in the
Canal Creek Area. Well 36A is at 14.5 feet MSL and is screened at a depth of 10 to 15 feet in the
surficial aquifer. Well 36B is at 14.3 feet MSL and is screened at 39 to 44 feet in the Canal Creek
Aquifer. Well 36C is at 14.2 feet MSL and is screened at 56 to 61 feet in the Canal Creek Aquifer.
Well 36D is at 14.2 feet MSL and is screened at 88 to 93 feet in the Canal Creek Aquifer. The depth
to ground water is seasonally variable and falls in the range of 5 to 10 feet.
Several residential ground-water wells exist outside of the installation boundary, but they are
located upgradient of the Building 503 site with respect to ground-water flow, and are unlikely to receive
contaminants from the burn areas 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, thiodiglycol, 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.
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April 4, 1995
2.1.5 Building 503 Area 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 in 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).
2.1.6 Building 503 Area 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 in a norm/ northeast direction immediately outside the installation
boundary. State Route 40 runs in a north/northeast direction approximately 3 miles north of the
installation. Interstate 95 runs in a north/northeast direction approximately 5 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) 1 mile west of the
installation, Edgewood (population 23,313) directly adjacent to the installation, and Bel Air (population
approximately 52,000) about 8 miles north of APG-EA on route 24. The total population of Harford
County is approximately 185,000.
Much of the area around Building 503 is developed. Both military and civilian personnel work
in Building 503 and other nearby buildings. In addition, there are several residential areas (barracks and
residential housing-for military personnel and their families), an airfield, and several areas reserved for
military training nearby. Several principal recreational areas are located east/southeast and southwest of
Building 503. Horse stables and a horse grazing area are located directly east and southeast of Building
503. Horses are ridden in the grazing area and along roads around the Building 503 site. Baseball and
softball fields and a swimming pool are located about 1,500 feet southeast of the burn sites. In addition,
playing fields and a picnic area are located approximately 3,500 feet southwest of the burn sites.
The primary source of water for APG-EA has been 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. It 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 503 burn sites because it is located north and upgradient of the site.
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April 4, 1995
2.1.7 Building 503 Area Flora and Fauna
The Building 503 area is grass covered except for the two barren burn sites. Land areas
immediately to the north and east consists of open grass fields. The grassy area to the east and southeast
is used as a grazing area for horses.
The Building 503 burn sites are not located in an area considered to be a wetland. A wetland
area is located west/southwest of the site. Terrestrial wildlife in the area includes songbirds, groundhogs,
field mice, deer, and rabbits. In addition, the bald eagle, an endangered species, is known to be present
at APG. There are no bald eagle nesting or feeding grounds near the Building 503 burn sites. Aquatic
invertebrates, fish and amphibians are not present in the Building 503 area.
23, SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.2.1 History of Site Activities
During WWII, Building 503 was set up as a filling plant for incendiary bombs. Incendiary filling
was performed during the first half of 1942, and then the plant was remodeled as a smoke filling unit.
Approximately 50,000 incendiary ordnance items were filled during this pilot operation, and additional
ordnance items were filled during a brief period of production. The bulk of smoke filling during WWn
was with a smoke formulation containing mainly aluminum, zinc oxide and hexachloroethane (designated
HC smoke). Small amounts of colored smoke filling operations were also performed in Building 503.
Items filled included 105-mm canisters, 155-mm canisters, Ml smoke pots, M77 bombs, 60-mm shells,.
2.36-in rockets, and grenades. Nearly 2.5 million items were filled in Building 503 during WWII. Since
so many of the items being filled were Ml smoke pots, Building 503 became known as the Smoke Pot
Plant.
Open burning at the norm bum area probably started in 1943, primarily for disposal purposes,
with off-specification batches of HC smoke mixture being burned in bulk on the ground surface. Also,
mixing and filling operations inside Building 503 usually generated waste in the form of dust and small
spillage of mixture ingredients. This waste was swept up and taken outside and burned, or flushed with
waste water into a concrete french drain. Solids that remained in the french drain after evaporation of
the water were removed and taken outside and burned. Burning for testing purposes normally would
have been accomplished with either munition items such as grenades, or with test mixtures in open
containers or on small pads. After WWII most open burning was probably conducted as part of the
testing of experimental smoke mixtures and experimental smoke munitions.
Whether for disposal or testing purposes, the burning of smoke mixtures involves the combustion
or chemical reaction of the smoke mixture and oxidizing agent to produce clouds of particulates, which
drift with the wind before they are deposited on the ground some distance from the burn area. Other
smokes are generated by mechanically inducing particulates of the smoke material into the air. The
smoke particles are mostly of aerosol size, and are dissipated into the atmosphere where they move
downwind from the source for a distance before falling to earth. Also, when burning for testing
purposes, the case of the smoke pot or grenade usually was damaged or melted to some degree. Such
hardware residue was disposed of as scrap metal or left at the burn area. This is evidenced by the large
number of grenade spoons and other munition components that have been found at the Building 503 burn
sites. Fuses also have been uncovered at the burn sites.
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April 4, 1995
In the years immediately following WWII, Building 503 facilities continued to be used for the
filling of smoke munitions, including smoke pots, candles and cluster munitions. Open burning and
testing at the south burn site started at this time, probably around 1951. Gradually, however, Building
503 evolved into a research and development (R&D) facility used to blend and test experimental smoke
mixtures and tcrfill experimental munitions. A wide variety of smoke mixtures were burned, with many
different ingredients. Some filling was performed, but the scale of filling activities was much smaller
than during WWII. Much of the filling work was pilot scale, but some production-scale filling was
accomplished. Both HC and colored smoke (CS) munitions were produced. Some incendiary munitions
also were filled in Building 503. Beginning in 1959, Building 503 was used for CS grinding and packing
activities. During recent years much of the work has been with red phosphorous. Use of both the north
and south burn sites for testing and disposing purposes ceased in 1975. The burn sites are not currently
used by the Army.
Building 503 is still used as an R&D facility for pyrotechnic smoke mixtures and smoke
dissemination hardware. These R&D operations in recent years have created little waste. During mixing
and loading operations in bays along the east side of the building, water is used to keep dust and small
spillage of mixture ingredients from accumulating and presenting a safety hazard. This waste water flows
into a concrete french drain. Solids that remain in the french drain, and remain after evaporation of the
water, are periodically removed and drummed for disposal as hazardous waste. Ventilation system dust
collection units also discharge water to the french drain and collect solids for disposal. Spilled mixture
ingredients and material from problem batches are drummed for later disposal.
2.2.2 History of Investigations/Remedial Actions
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 Canal Creek Area. An
initial assessment of the Building 503 burn sites was performed in 1976 as part of this investigation. In
August 1985, APG contracted with the USGS to conduct a hydrogeologic assessment and an investigation
of groundwater contamination in the Canal Creek Area. This investigation showed mat groundwater
beneath the Building 503 site is contaminated in the surficial aquifer and in the Canal Creek Aquifer.
In 1989, the RCRA Facility Assessment (RFA) was performed by the U.S. Army Environmental Hygiene
Agency (AEHA) to document historical activities at APG-EA related to solid-waste management, to
identify potential sources of contaminant release in the Canal Creek Area, and to evaluate environmental
quality at APG-EA with regard to past storage, treatment, and disposal of toxic and hazardous materials.
The RFA recommended that the Building 503 burn sites be treated as an interim action. Additional soil
sampling and analyses were performed by Roy F. Weston in February and March 1991 as part of a
treatability study, and by Battelle in May 1993. Metals and semivolatile organic compounds were found
in the soil during all these sampling events. A description of the soil and groundwater contaminants is
summarized in Section 2.5.1.
2.2.3 Enforcement Activities
APG-EA has been listed by the EPA as a Federal facility meeting the criteria for inclusion on
the National Priorities List (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.
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Final
April 4, 1995
It is currently in the Remedial Investigation/Feasibility Study (RI/FS) stage. To facilitate this ongoing
Canal Creek Rl/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 503 smoke burn sites are considered to be a soils operable unit. 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 Studies 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. Regulatory oversight of the investigation is through the FFA.
23 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Army described the scope and role of this operable unit to the APG Technical Review
Committee (TRC) on July 29, 1993, and on January 27, 1994. The Focused Feasibility Study (FFS)
(Battelle, 1994), Proposed Interim Remedial Action Plan (Battelle, 1994), and background documentation
for the Building 503 Soils Operable Unit 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, an
information repository has also been set up on APG in the TECOM Public Affairs Office. APG issued
a press release announcing the availability of these documents to APG's full media list. APG placed
news-paper advertisements on the availability of these documents and the public comment period/meeting
in the APG News on May 4, 1994, in die Aegis on May 11, 1994, and in the Harford County edition
of the Baltimore Sun newspaper on May 8, 1994 hi the APG News, Aegis and Baltimore Sun. APG
prepared and published a fact sheet on each hem 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. 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, members of the APG Superfund
Citizen's Coalition (APGSCQ, University of Maryland technical advisors to the APGSCC, and Federal,
State and local Government representatives. At mis 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 503 Soils Operable Unit 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. APG also met with representatives of the
APGSCC and their technical advisors on August 24, 1994. 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.
13
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Final
April 4, 1995
2.4 SCOPE AND ROLE OF THE SOILS OPERABLE UNIT
The Army and EPA have resolved to address soil contamination at the Building 503 burn sites
separately from contamination in the ground water. Therefore, the interim remedial action authorized
by this ROD addresses only the contaminated soil and ash at the Building 503 burn sites.
The purpose of this response is to address the current and future inhalation and incidental
ingestion risk to personnel posed by the soil and ash. Although the Building 503 burn sites present little
risk to ground water and surface water, this response will also minimize contaminant migration to ground
water and to surface water bodies.
The Army is addressing ground-water contamination beneath the Building 503 site as a part of
the on-going 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
The Remedial Investigation for the Building 503 burn sites included a review of historical data
and several sampling and analysis events. A description of the burn sites and contaminants based on the
RI results is summarized here.
2.5.1 Building 503 Burn Site Soil Information
Contamination is the result of the testing and disposal of pyrotechnic mixtures and munitions.
Pyrotechnic compositions are low-explosive mixtures designed to produce illumination, heat or smoke.
They contain some ingredients that serve as fuel, and others that function as the oxidizing agent. Smoke
v_ munitions are designed either for signaling, as in the use of colored smokes, or for screening. Incen-
diaries are designed to produce heat for destroying a target either by melting a nonflammable target or
by igniting a flammable target.
Some smoke and incendiary munitions [such as white phosphorus (WP) or petroleum-filled items]
do not contain an oxidizing agent and are not considered pyrotechnic. Incendiary munitions contain
compositions of chemical substances designed to destroy buildings and material by fire. They are of two
types: scatter and intensive. Materials such as WP or petroleum products are used hi scatter munitions,
and materials such as thermite and magnesium are used hi intensive-type munitions. Use of many smokes
involves combustion or chemical reaction of the smoke mixture and oxidizing agent to produce clouds
of particulates. Other smokes are generated by mechanically inducing particulates the obscurant material
into the air.
Because there are almost no records available, it is difficult to estimate the extent of disposal and
testing operations at the Building 503 burn sites. It is known, however, that more field tests have been
conducted at APG-EA with smoke than with other chemicals, and that, although hydrocarbon mixtures
probably comprised the bulk of the chemicals burned at Building 503, a wide variety of organics,
inorganic salts, metals, and dyes have been used in smoke mixtures.
Prior to 1950, the most common smokes hi use with the Army were WP, HC and fog oil. Hexa-
chlorethane (HCE) was an ingredient in HC smoke mixtures. Fog oil is a paraffin-free low-viscosity
14
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Final
April 4, 1995
petroleum product that is heated during dissemination from a smoke pot or mechanical smoke generator
and makes smoke by the condensed droplet scattering light. Other smoke mixture ingredients included
metallic oxides; hexamethyltetramine; chrorayl chloride; sodium metal and nitrates; and, chlorates of
sodium, potassium and ammonium. Sodium metal was used as a standard filling ingredient in bombs.
During WWn,jncendiary mixtures consisted of black powder (potassium nitrate, charcoal, sulfur), flaked
and grained aluminum metal, sulfur, castor oil, barium nitrate, and thermite (aluminum powder and ferric
oxide).
Since 1950, more tests have been performed with colored smokes, fog oil and similar materials,
and with special obscurants. Organics used in colored smokes include anthracene; benzo(a)anthracene;
benzo(a)pyrene; benzo(b)fluoranthene; benzo(k)fluoranthene; chrysene; fluoranmene; indeno (1,2,3-
cd)pyrene; pyrene; 1,2,4-trichlorobenzene; 4,4'-DDT; 4,4'-DDE; 4,4'-DDD; and 7H-naphthalene. The
compound 1-methylamino-anthraquinone is the dye Disperse Red 9, and (benzide) anthracene-7-one and
2-amino-9,10-anthracenedione are dye degradation products. Mirex was used by the Army as a color-
enhancing material hi colored dye mixtures, and was almost certainly introduced into the soil and ash by
testing and/or waste burning of color-enhanced mixtures. Tetrachloroethylene, hexachlorobenzene (HCB),
and hexachlorobutadiene could have been ingredients in smoke mixtures or could be thermal and/or
environmental degradation products of smoke mixture components.
Several investigations have studied the soil and water contamination and potential risks due to
contamination in tfc° Building 503 burn sites. The results of these investigations are described in an
environmental survey of Edgewood Area (Nemeth et al., 1983), the RCRA Facility Assessment (Nemeth,
1989), data by USGS (USGS, 1989), the S/S Treatability Study under die Response Engineering and
Analytical Contract (REAC) (U.S. EPA, 1991c), the preliminary risk assessments (AEHA, 1992 and
ICF/Kaiser Engineers, 1993) and soil sampling data (Battelle, 1993a).
All sampling events indicated elevated levels of heavy metals, and volatile and semivolatile
organics in the soil and ash, with the highest contaminant concentrations being present hi the ash and in
the soil under the ash to a depth of 12 hi. Inspection of the Building 503 burn sites shows that the ash
overlying the soil is roughly 6 to 12 La thick hi the center of the burn sites.
Results of the USGS Study. In 1987 the USGS installed four (4) ground-water monitoring
wells east of the north burn site. These two wells are part of the 168 well ground-water monitoring
system hi the Canal Creek Area. Chemical analysis of ground water from 1987 sampling data indicate
that the surficial aquifer at this location is contaminated with elevated levels of methylene chloride,
trichloroethylene and tetrachloroethylene. Additional sampling and analysis hi 1988 and hi 1989 indicated
that the surficial and Canal Creek aquifers are contaminated with elevated levels of zinc, lead, iron,
arsenic, barium, boron, vinyl chloride, ethyl benzene, and methylene chloride. 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. No surface-water sampling has been performed
at the Building 503 burn sites.
Results of the REAC Treatabifitv Study. Sampling and analysis of the soil and ash at the
Building 503 burn sites were conducted hi 1991 by the U.S. EPA Response Team and the REAC
personnel. From the two burn sites, 5-gallon composite samples were collected. Only the ash material
was collected. The ash was crushed and screened to a particle size of < % inches, placed hi a 5-gallon
15
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Final
April 4, 1995
bucket and homogenized. Various layers could be seen in the ash, and pieces of metal casing also were
scattered on the site.
Raw waste samples were sent for Base, Neutral, Acid Extractables (BNA) analysis; Toxicity
Characteristic Leaching Procedure (TCLP) metals (As, Ba, Cd, Cr, Pb, Hg, Se, and Ag) analyses; total
metals (Al, As, Ba» Cd, Cr, Fe, Pb, Mg, Hg, Se, Ag, and Zn) analyses; and TCLP organics (HCE and
HCB) analyses. In addition, solidification treatability tests were performed.
The analysis results indicated that untreated ash exhibited the toxicity characteristic due to
teachable lead. Samples showed TCLP teachable lead of 7.7 mg/1 and 6.2 mg/1 for ash from the north
and south sites respectively, which is slightly higher than the TCLP limit of 5 mg/1. The ash and
surrounding soil also contained high concentrations of zinc and elevated levels of the following metals:
arsenic, barium, c?dminm^ chromium, iron, mercury, selenium, silver, manganese, and aluminum. -
Elevated levels of the following volatile and semivolatile organics were found: mirex, HCB, HCE,
hexachlorobutadiene, tetrachloroemylene, and tributyi phosphate. HCB and HCE were present in the
highest concentration with total (BNA extractable) HCE and HCB concentrations being 92.6 and 47.5
mg/kg for HCE and HCB, respectively, at the norm burn sites. Leachable concentrations were well
below toxicity characteristic levels at 0.048 and <0.01 mg/1 for HCE and HCB, respectively, in com-
posite samples from the norm and south burn sites. Explosives-related compounds were not detected.
The sampled ash from the two burn sites was composited for a solidification test Ash from the
north and south burn sites was mixed in a 2: 1 proportion and treated with portland cement or a portland
cement/latex admixture. Cement was added at 5%, 10%, 15%, and 20% concentrations based on the
weight of the waste to be solidified. Following a 28-day curing period, the treated waste samples were
analyzed for TCLP lead and cadmium, TCLP semivolatiles, multiple extraction procedure lead and
-------
Final
April 4, 1995
chromium, lead, and stiver were also present in the near surface soil and/or ash in the burn sites. EP
toxicity extracts contained cadmium, lead, and selenium, but not at levels that would classify the soil or
ash as a hazardous waste. Explosives-related compounds were not detected in the soil or ash samples.
A red stain in the steam condensate ditch at the northeast corner of Building 503 is due to iron rather than
to red phosphorus.
Results of Battelle Soil Sampling. A Building 503 site sampling program was completed
to supplement the existing data by studying the soils around and below the ash accumulation. Sampling
and analysis focused on contaminants identified as potential chemicals of concern by the AEHA risk
assessment (AEHA, 1992): HCB, HCE, lead, and zinc.
Prior sampling events quantified contaminant levels in the soil and ash below the ash to a depth
of 6 inches or 1 to 2 feet. The additional sampling examined the perimeter areas and established
contaminant levels at greater depths. The supplemental sampling also included analysis of several
samples of the surface soil and ash to establish a statistical basis for evaluating the lead teachability
toxicity characteristic. Locations of sample points used for analysis of the ash area and surrounding soils
are summarized in Figures 4 and 5 for the north and south burn sites, respectively.
Spatial composite sampling to a depth of 3 inches was used to characterize surface contamination
in the area of visible ash. Sample points were selected and 5 samples taken from the four corners and
center of a 2 foot by 2 foot square around the selected sample point. These 5 subsamples were then
composited, and mixed into a homogeneous sample for analysis. Subsurface samples below the actual
surface sample points were collected by core borings to extract a series of samples at 1-foot-deep intervals
for 1 to 2 feet, and 2 to 3 feet. Sampling in 1-foot intervals was continued for a single core boring at
the north burn site, and for a single core boring at the south burn site until ground water was encountered
(5-feet deep).
Perimeter surface samples in the bare area around the ash were collected using the five-point
technique described, as were samples just below the grass on the outskirts of the barren area and hi the
horse pasture.
Analytical results showed that concentration levels of all contaminants were higher at the north
burn site than at the south burn site. The highest contaminant levels were at the north burn area (see
Table 1). Due to the low contaminant levels found in earlier studies, no organic analyses were performed
on surface samples from the south burn site. At both burn sites, the highest contaminant levels occurred
in the north end of the barren area. In the core samples, contaminant concentrations in the 1- to 2-feet
depth interval were much lower than the concentrations in the surface samples. Contaminant
concentrations continued to decrease in samples taken from deeper levels. Also, contaminant levels
decreased significantly in samples collected in the barren soil and grass surrounding the ash area.
17
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Final
April 4, 1995
Nor th Burn Ar e e
20ieet
-120
150
-95
-70
-20
150
125 h
100 h
Approximate Perimeter
of Barren Area
25h
0
-120
0
East
Distance From Fence (ft)
Figure 4 Location of Samples for Analysis in the Northern Burn Site Area
18
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Final
April 4, 1995
20 leet
South Burn Ar e e
-80 -76 -72 -68 -64 -60 -56 -52 -48 -44 -40 -36 -32
90
i i i i i i i i i i i i i i i i i i i i i i i i
Approximate Perimeter
of Barren Area
iii
48 -44 -40 -36
West
30
-80 -76 -72 -68 -64 -60 -56 -I
Distance From Fence (ft)
30
Figures
Location of Samples for Analysis in the Southern Burn Area
19
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Final
April 4, 1995
Table 1 Highest Contaminant Levels at the North and South Burn Sites from Battelle Samples
Contaminant
North Burn Site
Zinc 176,000.0 rag/kg
Lead 762.0 mg/kg
HCB 1.56 mg/kg
HCE 0.26 mg/kg
South Bum Site
Zinc 23,800.0 mg/kg
Lead 167.0 mg/kg
Location
NA-1
NA-2
NA-1
NA-1
SA-1
SA-1
The highest zinc level outside of the ash area was 11,000 mg/kg in sample NB-1 located to the
northeast of the north burn area. The highest lead level outside of the ash area was 379 mg/kg in sample
SC-5 located southwest of the south burn site.
Soil and ash samples from the north and south bum sites were analyzed for TCLP lead. A total
of 19 samples were analyzed for TCLP leachable lead. None of the results exceeded the regulatory
threshold of 5.0 mg/1 for lead. The highest values for TCLP lead in ash were 1.98 mg/1 and 0.44 mg/1
in the north and south burn sites, respectively. The highest values for TCLP lead in soil were 0.64 mg/1
and 0.56 mg/1 in the north and south burn sites, respectively. Therefore, the material to be managed is
not a RCRA characteristic hazardous waste.
2.6 SUMMARY OF SITE RISES
2.6.1 Human Health Risks
This section describes the methods and assumptions used to determine the remediation goals for
the Building 503 north and south burn sites. The rationale used in developing these PRGs is outlined in
the preliminary risk assessments (AEHA, 1992; ICF/Kaiser Engineers, 1991, 1993).
The major metal constituents in the Building 503 ash are zinc, iron and aluminum. Low
concentrations of arsenic, barium, cadmium, chromium, lead, manganese, and silver also have been
identified. Some organics, mainly HCB and HCE also have been found. Based on evaluation of total
concentration, leachable concentration, and toxicity, HCB, HCE, lead, and zinc were selected as the
chemicals of concern to be evaluated in the risk assessment.
The preliminary risk assessment concluded: (1) off-site migration of contaminants is possible,
because wind and surface water could transport contaminants to adjacent areas such as the horse stables,
and to the east branch of Canal Creek through the old storm drain; (2) there is no current direct off-site
public contact with contaminants because the Building 503 burn sites are remote from local communities
and located in a secure area; (3) there is limited future potential public exposure via the ingestion and
inhalation pathways due to the distance of off-site receptors; and (4) the possibility of accidental ingestion
20
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Final
April 4, 1995
or inhalation of site contaminants is greatest when personnel are engaged in activity near the burn sites,
for example for those mowing grass.
The preliminary risk assessment concluded that direct contact with incidental ingestion and
inhalation of contaminants are the human exposure pathways most likely to be associated with potential
health risks at the burn sites. Therefore, the exposure pathways used to assess the risks posed by the
burn sites were incidental ingestion and inhalation of particulates. The health-based remediation goals
discussed below are based on these pathways. Based on conservative exposure scenarios, the dermal
pathway was not evaluated. The chemicals of potential concern identified from the preliminary risk
assessment were HCB, HCE, lead, and zinc.
Excess lifetime cancer risks are determined by multiplying the intake level with die cancer
potency factor. These risks are probabilities that are generally expressed in scientific notation (1 x 10~6
or 1E-6). An excess lifetime cancer risk of 1 x 10"* indicates that, as a plausible upper bound, an indi-
vidual has a one in one million chance of developing cancer over a 70-year lifetime as a result of site-
related exposure to a carcinogen under the specific exposure conditions at a site.
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient (HQ) (or the ratio of the estimated intake derived from the contaminant
concentration in a given medium to the contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given population may reasonably be
exposed, the hazard index (HI) can be generated. The HI provides a useful reference point for gauging
the potential significance of multiple contaminant exposures within a single medium or across media.
The preliminary risk assessments concluded that contaminants in the ash and soil could exceed
EPA-recommended (maximum) risk levels for both carcinogenic and noncarcinogenic contaminants, with
a total excess lifetime cancer risk of 1 x 10~5, and a HI of 1 for the inhalation pathway and 4 for the
ingestion pathway (the total HI is 5).
Typically, for sites undergoing remediation the EPA excess lifetime cancer risk point of departure
for determining remediation goals is 1 x 10~* for carcinogens and an HI greater than 1 for
noncarcinogens. Because the potential cancer risk falls within the 1 x 10*6 to 1 x 10~* range, and because
the HI for the Building 503 burn sites exceed EPA's point of departure for noncarcinogenic effects (HI
for receptors at the site exceeds 1), the preliminary risk assessments concluded mat the risk posed by the
soil and ash should be addressed. The toxicity criteria for chemicals of concern related to human
receptors are shown in Table 2.
_/
2.6.2 Environmental Evaluation
A comprehensive ecological risk assessment has not yet been completed for the Building 503 bum
sites. However, in addition to the health risks to human receptors, the preliminary risk assessment briefly
attempted to qualitatively address the risks posed by the burn sites to horses at the stable adjacent to the
site, and attempted to establish remediation goals for non-human receptors.
21
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Final
April 4, 1995
Table 2 Oral Toxicity Criteria for Chemicals of Concern at the Building 503 Burn Sites
Chemical
H«raohlomJ-»»nw.n«>
HftYarhlnrrv.thane.
T«aH
Zinc
Oral Tnvirif
Can7nJW^0r [HI]
i A. T in-2 [r]
N/A [TW]
N/A roi
y rVifpria1*1
Reference Dose
(mg/kg-d)
8 X 10-*
1 x 1O~*
N/A
3 X 10"'
(a) Source: US
(B) Bracketed l
EPA
etters are
weight-of-evidence
Plants in the vicinity of the burn sites will be exposed to the soil throughout their life span. No
data were found for HC8 or HCE toxicity to plants, and only limited data were found for lead and zinc
toxicity. The data were insufficient to establish concentration-based remediation goals for the chemicals
of concern based on impact to plants. The central portions of both burn areas contain little or no
vegetation, which is assumed to be the result of phytotoxic levels of the chemicals of concern.
During several visits to the burn sites, it was apparent that horses seemed to prefer grazing and
standing in the shade of trees immediately next to the eastern boundary fence of the Building 503
compound, and thus could be exposed to contaminants via the ingestion and inhalation pathways. No data
were found for HCB or HCE toxicity to livestock. Eisler (1993) reports that zinc is relatively nontoxic
to mammals, and livestock are particularly resistant to zinc. Adverse effects in adult horses in the
vicinity of a lead-zinc smelter were reported at a zinc dose of greater than 90 mg/kg. This dose was
converted to a toxicity reference value for horses by assuming that soil and/or grass containing zinc
comprises 10% of a horse's dietary intake of 9.6 kilograms and that the horse weighs roughly 500
kilograms. The National Academy of Sciences (MAS) (1980) cited a 1973 study by Knight and Bureau
in which lead poisoning was observed in horses grazing in pastures near a smelter. The reported
concentration of lead in the soil was 325 mg/kg (dry weight).
The preliminary risk assessments identified no endangered or protected species that would be
impacted by not remediating the burn areas. Bald eagles hi APG-EA are unlikely to be disturbed during
the remedial activities at the Building 503 burn sites because they are not known to nest or feed in this
area. The burn sites could potentially pose an ecological risk to aquatic species if contaminants are being
transported to the east branch of Canal Creek through the old chemical/storm sewer system.
The analysis of contaminant fate and migration involves determining how a chemical will behave
when it is released into the environment. This behavior can be described in terms of the following
processes: transformation, transport and transfer. Transformation processes alter the chemical through
physical, chemical, and/or biological reactions or by reaction with another chemical. Fate is the
combination of these transformation processes and controls how long a chemical will persist in the
environment. Transfer processes distribute a chemical between sectors of the environment, whereas trans-
port processes act to redistribute a chemical within a given sector of the environment For purposes of
transport discussions, the environment typically is subdivided into four sectors: air, soil, ground water,
and surface water. Migration is the combination of transport and transfer processes. Migration controls
the spatial and temporal distribution of a chemical with time.
22
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Final
April 4, 1995
Although the soil and ash appear to be relatively stable, some off-site migration in the form of
dust and particulates probably occurs via the aerial pathway from both burn sites to adjacent areas. Some
downward movement of contaminants to ground water would also be expected to occur over time in the
absence of remediation. Also, there is also a limited potential for off-site migration of contaminants via
surface water run-off through the old chemical/storm sewer system. Surface water bodies are unlikely
to be greatly impacted by contaminant run-off, or by aerial dispersion of contaminants from the burn site
soil and ash.
Slow environmental degradation of the organic contaminants is expected to occur at both bum
sites. There would be no environmental degradation of the metal contaminants. The organics are most
likely present dissolved in pore water or sorbed on mineral or soil organic materials. These organics will
undergo slow natural chemical transformation due to biological action and oxidation. The metals are most
probably present as oxides, hydroxides or hydrous oxides. In summary, some environmental degradation
of the organics is expected to occur over time; however, there would be no environmental degradation
of the metals in the absence of remediation.
2.63 Remedial Action Criteria
Actual or threatened releases of hazardous substances from mis site, if not addressed by
implementing the interim remedial action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare or the environment
Remediation goals were considered for the following four potential receptors: 1) Individuals
mowing grass at Building 503; 2) Individuals who work inside and outside Building 503 on a daily basis;
3) plants; and, 4) horses at the adjacent horse stable.
Because a comprehensive ecological risk assessment has not yet been completed for the Building
503 burn sites, the preliminary risk assessment developed remediation goals for the chemicals of concern
using risk criteria for human receptors. A comprehensive human health and ecological risk assessment
for the Canal Creek Area is on-going as part of die RI/FS. This comprehensive risk assessment will also
address the Building 503 burn sites. Based on the results of this risk assessment, additional remedial
measures could be implemented if required.
Health-based remedial action criteria for human receptors were developed using the cancer slope
factor and/or reference dose for HCB and HCE and the reference dose for zinc. Lead concentration
criteria were developed based on a reported limit for a sensitive population, e.g., children up to 6 years
old, and on OSWER Directive #9355.4-12, Revised Interim Soil Lead Guidance for CERCLA Sites and
RCRA Corrective Action Facilities, which recommends a screening level of 400 mg/kg for lead in soil
for residential land use (currently there are no criteria for establishing remediation goals for lead in
industrial soils). Although young children and residential land are not truly applicable to the industrial
scenario, use of a sensitive population gives a conservative remedial action criterion.
Assumptions for exposure conditions for determination of remedial goals based on the above
potential receptors are summarized below. Remediation goals were calculated using standard EPA
guidance (U.S. EPA, 1991a, 1991b, 1993), and were based on the assumed exposure conditions and the
applicable toxichy criteria.
23
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Final
April 4, 1995
Individuals mowing grass were assumed to mow grass in the vicinity of the burn sites for 1 dy/wk
for 28 wk/yr for 25 years. Incidental ingestion of soil and/or ash was assumed to be 480 mg/dy, which
is the default value recommended by the EPA for a construction worker (U.S. EPA, 1991a).
Industrial workers inside the building also could be exposed to chemicals in the soil and ash from
the burn sites. For example, workers might park vehicles in the vicinity of the bum sites. Thus they
potentially could be exposed to airborne paniculate from the burn sites for about 15 minutes prior to
work, 1 hour at lunch, and 15 minutes after work. Additionally, dirt brought inside the building on
clothes or as airborne dust could expose workers in the building. Also, it is possible that future activities
at the plant might involve more work time outdoors. As a conservative estimate, exposure to workers
inside the building could approach that of workers outside. Therefore, the exposure to workers employed
at the plant is estimated based on a work time of 5 dy/wk for 50 wk/yr for 25 years (U.S. EPA, 1991a).
Incidental ingestion of soil and/or ash was assumed to be 480 ing/day.
The use of 480 mg/dy incidental soil ingestion is based on typical outdoor construction. The
work involves vigorous outdoor efforts during the 8-hour period with constant exposure to extensive areas
of barren soil and ash with dust produced by ongoing excavation and earth-moving activities. The
480 mg/dy is an upper bound estimate that is conservative for grass mowing and is extremely
conservative for the building workers.
The risk assessment also recognized the obvious stress to vegetation at the burn sites; however
the requirements for developing standards for non-human receptors are not as well defined. However,
insufficient data were found to support a definition of a concentration-based cleanup level to protect the
vegetation. A requirement to remediate the barren areas was established to account for the damage to
local vegetation due to burn site contaminants. The remediation goals for horses were based on a toxicity
reference value for zinc from a report by Eisler (1993), and on a 1973 study by Knight and Bureau in
which lead poisoning was observed hi horses grazing in pastures near a smelter. The reported
concentration of lead in the soil was 325 mg/kg (dry weight).
Table 3 Risk Assessment Scenario Results for Chemicals of Concern at Building 503 Burn Sites
Chemical
Hexachlorobenzeoe (mg/kg)
Hexachloroethane (mg/kg)
Lead*' (mg/kg)
Zinc (mg/kg)
Health-Based Goals
for Human Receptors
Grass Mowing
Scenario
3.3
380.0
400.0
570,000.0
Industrial
Worker Scenario
0.4
43.0
400.0
64,000.0
Goals for Nonhuman
Receptors*4
Horses
N/A
N/A
325.0
47,000.0
""'Goals based on a 400 mg/kg screening level for lead in soil for residential land use.
Possible remediation goals from the preliminary risk assessment for human and non-human
receptors are summarized in Table 3. Health-based goals for human receptors were developed using
cancer slope factors and/or reference dose. Since there are currently no toxicity criteria (i.e., cancer
slope factor or reference dose) available for lead, lead concentration goals were developed based on
24
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Final
April 4, 1995
reported limits for a sensitive population* e.g., children up to 6 years old. A comprehensive human
health and ecological risk assessment will still be performed for the Building 503 burn areas as pan of
the ongoing comprehensive Canal Creek Area RI/FS. Based on the results of the RI/FS, additional
remedial measures could be implemented depending on the contaminant levels found and future land use
plans.
The specific site average concentration remedial clean-up standards were taken from Table 3, and
are as follows:
Hexachlorobenzene 0.4 mg/kg
Hexachloroethane 43.0 mg/kg
Lead 400.0 mg/kg
Zinc 64,000.0 mg/kg
Site averaging will be used in meeting cleanup standards. Confirmatory sampling will be
conducted to ensure that these clean-up criteria are met. Because visual observation clearly indicated
stressed vegetation around the burn sites, a vegetative cover will be established.
It should be pointed out that the remedial-action criteria for zinc and lead based on horses as the
receptor are slightly lower than the goals for the industrial scenario. Soil samples taken east of the burn
sites near the fence indicate that the concentrations of lead and zinc in soils accessible to the horses are
substantially below clean-up standards based on impacts to horses. The horses are separated from the
most concentrated contaminants at the burn sites by a fence; thus, the industrial scenario appears to be
the most applicable.
2.7 DESCRIPTION OF ALTERNATIVES
"" 2.7.1 General
Historical samples indicate the chemicals of concern (HCB, HCE, lead, and zinc) concentrations
in the ash material of the burn sites are above the clean-up standards developed by the risk assessment.
The Battelle sampling program also identified some ash area samples with concentrations of chemicals
of concern above the clean-up standards. One of the north ash site surface samples had a lead con-
centration in excess of the 400 mg/kg standard. Two norm ash site surface samples exceeded the 64,000
mg/kg zinc cleanup standard. These two samples also had HCB levels exceeding the 0.4 mg/kg cleanup
standard.
No chemicals of concern were identified at concentrations exceeding the clean-up standards
beyond the ash area or in the soil below the ash. None of the grass area samples, perimeter area
samples, or archive samples had lead levels exceeding the clean-up standards. None of the grass area
samples or archive samples had zinc levels exceeding the clean-up standards. The Battelle sampling event
did not analyze for HCB or HCE in the grass-covered area. The concentrations of HCB and HCE in the
soil cores taken from below the ash area are all near or below the 0.01 mg/kg detection limit. A sample
taken in 1986 from north of the building showed less than 0.1 mg/kg for bom HCB and HCE. These
data indicate that remediation of the barren areas will adequately treat the chemicals of concern in the
norm and south burn sites.
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Final
April 4, 1995
Removal or treatment of areas with sparse or no vegetation meets the remedial-action objective
to decontaminate areas with stressed vegetation. Setting a remediation area boundary based on the barren
areas will capture all of the ash-covered surface and the surrounding barren perimeter beyond. Figures
6 and 7 illustrate the general configuration of the planned surface area to be remediated. The extent of
the barren area is estimated based on the measured position of sample points used during the 1993
sampling eventr The final delineation will be done at the time of remediation by visual observation of
vegetation at the site.
The expected excavation depth is about 1 foot. Excavation or treatment to about 1 foot is
expected to meet the concentration cleanup standards and provide a volume of clean soil to support new
vegetation. The volume of material requiring remediation is defined by considering the contaminant
concentrations found in soil samples and by visual observation of the location of stressed vegetation at
the site.
The estimated volumes requiring remediation are about 390 yd3 in the north burn site and about
80 yd3 in the south burn site, giving a total volume of 470 yd3 requiring remediation. Based on existing
sampling data, excavation to about 12 inches would reduce the contaminant concentrations to
approximately 31 mg/kg for lead, 2,040 mg/kg for zinc, and to less than 0.01 mg/kg for HCB and HCE
at the north burn site, and to 27 mg/kg for lead, 384 mg/kg for zinc, and to less than 0.01 mg/kg for
HCB and HCE at the south burn site. Confirmatory soil sampling during the excavation process would
ensure removal of the contaminated soil to the risk-based cleanup levels.
Five remedial alternatives were considered for the soil and ash at the Building 503 site:
1. No Action
2. Excavation, screening, dust control, air monitoring, disposal in an off-site industrial landfill,
**** application of clean soil and grass cover to the excavation area
3. Excavation, dry screening, dust control, air monitoring, processing on-site by solidification/
stabilization (S/S), disposal in an off-site industrial landfill, application of clean soil and grass
cover to the excavation area
4. Excavation, dry screening, dust control, air monitoring, disposal in an off-site RCRA
Subpart C permitted facility, application of clean soil and grass cover to the excavation area
5. Excavation, dry screening, dust control, air monitoring, disposal to the Building 103 dump
in the Edgewood Area, application of clean soil and grass cover to the excavation area
Some general site preparation activities will be required as the preparatory phase of Alterna-
tives 2, 3, 4, and, 5. Site preparation will include provision for general access control and allowance
for entry and staging of excavation equipment, storage boxes and trucks. Any needed site services and
utilities, such as water or electricity, also will be arranged for during site preparation. The excavation
will be performed with conventional earth-moving equipment such as backhoes, front-end loaders, dump
trucks, and/or roll-off boxes. The depth of the excavation will be approximately 1 foot, so no sloping
or confined space monitoring will be required. Air monitoring will be conducted during the excavation.
Application of dust control agents or cover sheets will be used for dust control, as needed.
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April 4, 1995
North Bu r n Ar s e
20(eet
-120
-95
-70
-20
150
150
125 -
- 125
100 -
- 100
North Burn Site
Area to be Remediated
S
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April 4, 1995
20
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April 4, 1995
The following general procedures will be provided to minimize short-term risk due to potential
for encountering UXO. Prior to the start of remedial Alternatives 2, 3, 4 or 5, the area to be treated or
excavated will be surveyed for UXO. The contaminated matrix will then be removed in 6-inch layers.
The UXO clearance personnel will repeat the survey before the excavation of each layer.
The excavated soil and ash will be moved to a predetermined location near the screening area and
passed through a screen formed by heavy parallel bars forming open slots 2 to 3 inches wide (grizzly
screen). Material passing through the grizzly screen will drop directly onto a screen with 1-inch square
openings. The screening operation will remove oversize debris. Nonexplosive oversize debris smaller
than 3 inches in diameter will be added to the screened waste material. Any materials screened out of
the contaminated ash and soil that are not suitable for disposal at the Building 103 dump site will be
disposed of in accordance with applicable APG, state and federal regulations. Potentially explosive debris
will be disposed of by the Army.
An excavated depression and surrounding disturbed soil will remain at the Building 503 burn sites
following the soil and ash removal required to implement Alternatives 2, 3, 4, and, 5. The void left after
excavation will be filled and graded to match natural contours using clean soil obtained from off-site.
The backfilled area and surrounding damaged areas will be fertilized, seeded and mulched. Backfilling
and revegetation will be performed using conventional construction equipment.
2.7.2 Description of Alternatives
Alternative 1: No Action. The No Action alternative at this site calls for leaving the site in its
current condition. The No Action alternative is required by U.S. EPA RI/FS Guidance as a baseline
against which other remedial alternatives may be compared. Under this alternative, the remedial goals
will not be met. The No Action alternative has no capital costs.
Alternative 2: Excavation, Disposal at Off-Site Industrial Landfill, Backfill. The screened
material will be transported to an off-site industrial landfill for disposal. The contaminated soil and ash
will be moved in lined dump trucks or roll-off boxes on flatbed trailers. The contaminated soil and ash
will be covered during transportation. The transportation route will use post and public roads. The total
estimated cost of remedial operations for Alternative 2 is $115,820 including excavation; screening;
disposal; and installation of clean soil and application of fertilizer, seed and mulch at the Building 503
sites.
Alternative 3: Excavation, On-Site Treatment by Solidification/Stabilization, Disposal at Off-
Site Industrial Landfill, Backfill. The screened material will be treated on-site by SIS with portland
cement, portland cement/fly ash, or similar inorganic binders. To every 10 pounds of material treated
will be added 1 pound of dry binder. Sufficient water will be added to form a fluid mix. Mixing will
be performed in a rolling drum mixer, pug mill or other mixing device.
After a 24-hour curing period, the S/S-treated materials will be transported to an off-site industrial
landfill for disposal. The treated soil and ash will be moved in lined dump trucks or roll-off boxes on
flatbed trailers. The treated soil and ash will be covered during transportation. The transportation route
will use post and public roads. The total estimated cost of treatment operations for Alternative 3 is
$207,220 including excavation; S/S; screening; disposal; and installation of clean soil and application of
fertilizer, seed and mulch at the Building 503 sites.
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April 4, 1995
Alternative 4: Excavation, Disposal at Off-Site RCRA Subpart C Permitted Landfill,
Backfill. The screened material will be transported to an off-site RCRA Subpart C permitted landfill for
disposal. The contaminated soil and ash will be moved in lined dump trucks or roll-off boxes on flatbed
trailers. The contaminated soil and ash will be covered during transportation. The transportation route
will use post and public roads. The total estimated cost of remedial operations for Alternative 4 is
$278,560 including excavation; screening; disposal; and installation of clean soil and application of
fertilizer, seed and mulch at the Building 503 sites.
Alternative 5: Excavation, Disposal at Building 103 Dump, Backfill. The screened material
will be transported to the Building 103 dump where it will be contained by a cap and cover system to be
constructed over the existing cover of the Building 103 dump. The excavated soil and ash from Building
503 would augment imported backfill required to form a level base for the new cap and cover system.
The contaminated soil and ash will be moved in lined dump trucks or roll-off boxes on flatbed trailers.
The contaminated soil and ash will be covered during transportation. The transportation route for the
contaminated material will use only roads in the Edgewood Area. There will be no movement on public
roads. The total estimated cost of remedial operations for Alternative 5 is $44,900 including excavation;
screening; disposal; and installation of clean soil and application of fertilizer, seed and mulch at the
Building 503 sites.
2.8 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The five interim remedial action alternatives developed for the Building 503 Smoke Pilot Plant
Bum sites 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
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April 4, 1995
The following sections summarize the relative performance of each of the five alternatives with
respect to the nine CERCLA evaluation criteria.
2.8.1 Threshold Criteria
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 ARAR
criteria. As such, it addresses whether or not a remedy will (1) result in any unacceptable impacts;
(2) control the inherent hazards (such as toxicity and contaminant mobility) associated with a site; and,
(3) minimise short-term impacts associated with cleaning up the site. This evaluation provides an overall
assessment of the relative protection of each alternative to human health and the environment.
Alternative 1 provides no overall protection for workers in the vicinity of the site, or for human
health or the environment The risks posed by the site would remain at current levels. Alternatives 2
and 3 give good overall protection, whereas Alternatives 4 and 5 give very good overall protection of
human health and the environment For all cases involving containment or treatment the contaminated
soil and ash material is removed from its exposed position and transferred to a more controlled condition.
Alternative 4 places the contaminated material in a closely monitored hazardous waste disposal site.
Alternative 5 reduces travel distances and avoids transportation on public roads.
All alternatives eliminate the current and future health risks posed by the site since the soil would
be excavated and removed from the she.
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 does not meet the risk-based cleanup standards and would result hi violations of
i *» Federal Ambient Water Quality Criteria (AWQQ guidelines and State water quality standards in ground
water, if movement of contaminants into ground or surface water were to occur.
Alternatives 2, 3, 4 and 5 comply with the ARARs by removing all soil and ash having
contamination levels exceeding the cleanup action level.
with
Alternatives 2 and 4 which require movement of wastes off the installation will be in compliance
U.S. Department of Transportation regulations involving off-site movement of wastes.
Alternative 5 would meet the provisions of the Corrective Action Management Unit (CAMU) rule
set form at 40 CFR Part 264 Subpart S which authorizes on-site consolidation of wastes, and consequently
placement of the contaminated soil/ash at the Building 103 dump. The Army does not need a permit or
waiver from MDE in order to include the contaminated soil/ash as part of the fill material at the Building
103 dump. Land disposal restrictions do not apply to the soil/ash.
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 Maryland Storm Water Management Regulations (COMAR 26.09.02).
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April 4, 1995
National Pollution Discharge Elimination System (NPDES) requirements (40 CFR Parts 122-124)
are not applicable since none of the alternatives under consideration result in discharge to surface water
from a discrete source. Also, AWQC and Maryland Water Pollution Control Regulations (COMAR
26.08.01-04) should not be applicable to this interim remedial action since none of the alternatives under
consideration wilLresult in the discharge of pollutants to surface water or ground water.
Alternatives 2-5 will involve earthmoving operations which may result in paniculate emissions
to air. Alternatives 2-5 will comply with Maryland State-Adopted National Ambient Air Quality
Standards and Guidelines (COMAR 26.11.03), Maryland General Emission Standards, Prohibitions, and
Restrictions (COMAR 26.11.06), Maryland Toxic Pollutants Regulation (COMAR 26.11.15) and
Maryland Noise Pollution Regulations (COMAR 26.02.03). There will be no air emissions after
completion of this interim remedial action.
Even though portions of APG-EA are considered wetlands, the Building 503 bum sites are not
a wetland and are 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 503 bum sites.
2.8.2 Primary Balancing Criteria
The five criteria below are grouped together because they represent the primary factors upon
which the analysis is based. They take into account technical, cost, institutional, and risk concerns. The
level of detail required to analyze each alternative against these criteria is commensurate with the
m complexity of the site and the alternatives considered.
Long-Tenn 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. With
Alternative 1, the only long-term risk reduction results from slow, natural degradation of organic
contaminants and from dilution and dispersal of metal and organic contaminants by weathering.
Alternatives 2 and 5 provide good long-term effectiveness. In both cases contaminants are removed and
contained by a cap and cover system. This cap and cover system will minimise infiltration of water to
the contaminants, thus minimising vertical migration of the contaminants to ground water, and will
prevent airborne dispersion of the contaminants as particulates. Alternative 3 increases the long-term
effectiveness by additional treatment of the soil and ash with cement to assist in immobilizing the
contaminants. Alternative 4 increases the long-term effectiveness by placing the soil and ash in a RCRA
landfill.
Reduction of Toricity, Mobility, or Volume. This criterion refers to die anticipated
performance of the treatment technologies that may be employed in a remedy.
Alternative 1 provides no reduction of the toxicity, mobility or volume of the contaminants.
Alternatives 2, 3, 4 and 5 all provide excellent reduction of on-site contaminant volume, because the
32
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Final
April 4, 1995
contaminants are removed from the Building 503 burn sites. For Alternatives 2, 4 and 5 the overall
volume of the contaminated material remains the same. The total volume being disposed of in Alterna-
tive 3 may increase due to the addition of the cement binder. The cement addition used as part of
Alternative 3 will increase the leach resistance of the waste, thus lowering the toxicity and mobility.
Alternatives 2,4 and 5 do not reduce the toxicity of the contaminants. Alternatives 2, 3, 4 and 5 greatly
reduce the mobility of the contaminants. In each alternative the contaminated soil and ash material is
removed from an exposed location and placed in a more controlled condition. For each alternative (other
than no action), the contaminated ash and soil is excavated, moved to a landfill or dump site and
immobilized by a cap and cover system. The cap and cover system prevents airborne dispersion of
contaminants as dust or particulates and minimizes infiltration of water, thus, controlling contaminant
migration to ground water.
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. Because no remediation is required to implement the No Action alternative, no dust is
generated, and worker risks from contaminant exposure and accidents during operation of remediation
equipment are eliminated. Alternatives 2, 3, 4 and 5 provide good short-term effectiveness. These
alicmatives would all require approximately the same amount of time to implement after signing of the
ROD. Alternative 3 would probably require the longest period of time to complete. Alternative 5 would
probably require the least amount of time to complete.
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 civilian government employees, military personnel, on-
site workers, and the environment are expected to be minimal under Alternatives 2, 3, 4, and 5.
Personnel could be subjected to construction-related impacts (noise, dust, 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, appropriate
training, and through the use of air monitoring devices. No protected species or sensitive land areas are
expected to be affected during remediation. Due to the nature of the site, there is a potential for
encountering ordnance during excavation of the soil and ash. Transportation of hazardous materials is
not expected to be necessary under any of the alternatives.
Implementability. This criterion describes the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to implement the chosen solution.
There are no technical barriers to implementation of the No Action alternative. However, this
alternative may encounter substantial administrative obstacles because the contaminants will not be
remediated. The technical implementability of Alternatives 2,3,4, and 5 is excellent. These alternatives
use readily available techniques. Excavation, solidification/stabilization with cement-based binders,
transportation, and disposal are all established technologies that have been used at many sites. 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 these alternatives.
Alternative 3 would probably be the most difficult to implement since solidification/stabilization would
have to be performed on site.
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April 4, 1995
Costs. This criterion addresses the capital for materials, equipment, and the O&M costs. The
No Action alternative is the least expensive since it has no associated capital costs. The No Action
alternative involves continued routine maintenance costs (grass mowing), but no expenditures are
specifically required to implement this option. Alternative 5 is the next least expensive to implement with
an estimated cost of $44,900. Alternative 4 is the most expensive to implement with an estimated cost
of $278,560.
2.8.3 Modifying Criteria
In accordance with RI/FS guidance (EPA, 1988), the final two criteria involving State and
community acceptance were evaluated based upon the MDE and public comments to the Focused
Feasibility Study and the Proposed Plan. The criteria are as follows:
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 Ed and MDE both concur that Alternative 5 is protective of human health and the
environment.
Community Acceptance. This criterion assesses public comments received on the Focused
Feasibility Study and Proposed Plan. Community interest in the proposed action at the Building 503 burn
sites soils operable unit 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 Citizens Coalition
(APGSCC). APGSCC agreed that the soil should be excavated but preferred off-site disposal. APGSCC's
comments and APG's response to these comments are contained in the Responsiveness Summary. Other
questions from the community included wanting to know about safety procedures which would be
implemented during excavation to reduce dust and possible exposure of workers or the public to the
soil/ash. APG provided information to the community on health and safety procedures that will be
implemented to protect workers and the general public. This information is also contained in the
Responsiveness Summary.
Public input to the Proposed Plan for this site indicated general community agreement, mat the
soil/ash should be excavated. Therefore, APG does not believe mat Alternative 1, No-Action, would be
acceptable to the community.
APG has received input from the community mat they desire cleanup funds to be spent prudently.
Community members have also inquired about the transportation of wastes over public roads. The
volume of soil is small; therefore, on-site treatment is not cost effective. Since alternative S is cost
effective, and provides a feasible alternative hi this situation to transporting the soil on public roads, APG
believes it is an acceptable interim remedy.
2.8.4 Selection of Remedial Alternative. The selected alternative is Alternative 5.
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 5 (Excavation, Disposal at Building 103 Dump, Backfill) is the most
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April 4, 1995
appropriate alternative for the Building 503 burn sites soils operable unit, and is therefore the selected
remedy. This alternative was selected because it is protective of human health and the environment,
feasible, and cost effective. The time to implement Alternative 5 is 12 months after signing of the ROD.
The Building 503 Smoke Burn Sites Soils Operable Unit will be further investigated as part of
the on-going RI/FS. The investigation will indicated if further remedial actions are required. Alternative
5 has a periodic review requirement to determine the effectiveness of this interim remedy and whether
further remedial actions are necessary.
The clean-up standards to be met by the selected remedial alternative are:
Hexachlorobenzene 0.4 mg/kg
Hexachloroethane 43.0 mg/kg
Lead 400.0 mg/kg
Zinc 64,000.0 mg/kg
In addition, any barren area or areas of stressed vegetation around the burn sites will be
excavated, backfilled with clean soil, fertilized, seeded and mulched to meet the clean-up standards.
The bum sites will be excavated to a depth of approximately 1 foot. The limits of excavation are
approximately 10 feet outside the barren area perimeter at both the North and South sites. The location
of the limits of excavation are based upon all of the soil data and the clean-up criteria presented in this
ROD. UXO clearance will be performed in conjunction with the excavation. Air monitoring and dust
control measures will be provided during remedial operations. Excavated material will pass through a
soil screen to separate out any metallic objects, rocks or debris. The screened soil will then be loaded
into dump trucks. Any metallic objects, rocks or debris will be properly disposed of in accordance with
APG, state and federal regulations. The dump trucks will be loaded as close to the screening area as
possible in an effort to maintain any spilled soil within as small an area as possible.
Once the initial phase of excavation is complete, soil samples will be collected from the excavated
areas for analysis. After the results of the analyses are obtained, additional areas requiring excavation,
if any remain, will be identified. The excavation will continue in 6-inch lifts until sampling and analysis
indicates that all samples are below the required cleanup levels for the constituents of concern.
The soil and ash from the Building 503 burn sites will form part of me required subbase under
the cap and cover system for the Building 103 dump.
The range and expected cost for the major cost elements in Alternative 5 are shown in Table 4.
The total estimated cost of treatment operations for Alternative 5 is $44,900 including excavation,
screening, disposal, and installation of soil and grass cover.
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Table 4 Cost Estimate for the Selected Interim Remedial Action for the Building 503 Burn Sites
Item
Site ~-
Preparation
Excavation
UXO
Clearance
Screening
Air
Monitoring
Hauling
Disposal
Soil for
Backfill
Haul Soil to
Site
Backfill and
Revegetate
Range
$3,000 to $7,000
$5/vd3to$ll/yd3
$2,000 to $8,000
$2/yd3 to $14.50/yd3
$5,000 to $20,000
$3.70/vd3 to $6.90/yd3
$0
$5/yd3 to $25/yd3
SO.lS/yd'/mile to
$0.40/yd/mile
-
Expected
Cost
$5,000
8/yd3
$4,000
$8/yd3
$10,000
$5.85/yd3
$0
$20/yd3
$.28/yd3/mile
$5/yo°
Unit of
Measure
-
470 yd3
-
470 yd3
-
470 yd3
.
470 yd3
470 yd3, 30
miles
470 yd3
Total
$5,000
$3,760
$4,000
*3,760
$10,000
$2,750
$0
$9,400
$3,880
$2,350
Total $48,400
2.10 STATUTORY DETERMINATIONS
The selected remedy satisfies the 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.
As required by Section 121 of CERCLA, use of permanent solutions and alternative treatment
technologies or resource recovery technologies, and a preference for treatment as a principal element were
considered. Resource recovery as a principal element was not found to be cost effective for the Building
503 soil and ash. Also, on-site treatment by solidification/stabilization was not found to provide
additional protection to human health and the environment
The selected interim remedy will reduce risk and address the immediate hazards posed by the
Building 503 Smoke Burn Sites Soils Operable Unit. It is protective of human health and the
environment, and is cost effective. It also complies with Federal and State of Maryland requirements mat
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 site. Alternative 5 has a periodic
review requirement to determine the effectiveness of this interim remedy and whether further remedial
actions are necessary.
The risks posed by the Building 503 Burn Sites Soils Operable Unit will be further evaluated in
the ongoing comprehensive Canal Creek Area human health and environmental risk assessment. If further
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April 4, 1995
remediation is required, then the selected remedy for the Building 503 Burn Sites Soils Operable Unit will
be consistent with those actions. If such evaluation reveals that no further remedial action for the soils
at Building 503 is necessary to protect human health and the environment, this action may be final.
Overall Protection of Human Health and the Environment. The selected remedy will minimize the
human health-risks posed by the Building 503 burn sites through excavation of the contaminated soil and
ash, movement to the Building 103 dump, and placement under a cap and cover system.
No unacceptable short-term risks or cross-media impacts will be caused by implementation of
Alternative 5. During remediation activities, adequate protection will be provided to the community and
the environment by using methods described in a remedial action work plan. This plan will provide for
monitoring and control of dust during excavation and movement of the contaminated soil and ash. In
addition, workers will be provided with personal protective equipment and air monitoring during all
phases of the remediation.
The possibility that UXO items could be detonated by equipment or personnel during the course
of remedial activities makes it necessary to screen the area for UXO prior to the commencement of any
intrusive activities. By screening the area, the potential for accidental detonation of UXO during remedial
activities will be reduced. Prior to any intrusive activities at the Building 503 burn sites, the area will
be cleared for UXO. The clearance of the area, within the limits of disturbance, will be accomplished
by a magnetometer sweep and a visual search for UXO. Any suspect objects detected by this sweep will
be flagged and hand-excavated by UXO-trained personnel. Once exposed, the object will be identified
and properly disposed of in accordance with APG regulations. Upon completion of the initial UXO
clearance, the site will be staked out. The limits of disturbance, limits of excavation, soil screening area
and decontamination area will be clearly delineated. The UXO clearance process will be repeated for
every layer of soil removed.
Compliance with ARAKs. Alternative 5 will meet with all substantive requirements for all ARARs
listed in Table 5. The time to implement Alternative 5 is expected to be approximately 12 months after
signing of mis ROD.
Risk-based cleanup standards were developed for the chemicals of concern in the Building 503
burn sites. Contaminated soil and ash containing concentrations of lead, zinc, HCB, or HCE higher than
the cleanup levels will be removed and moved to the Building 103 dump. Barren areas at the burn sites
also will be excavated. Follow-up confirmatory sampling will ensure that soil and ash containing
contaminant levels greater than the remediation goals have been removed. Excavation and removal of
contaminated soil and ash will ensure mat lead concentrations in the soil are below the 400 mg/kg
screening level for lead in soil for residential land use.
Placement of contaminated soil from the Building 503 Soils Operable Unit at the Building 103
dump is authorized under me provisions of the CAMU rule set forth at 58 Fed. Reg. 8679, which
authorizes on-site consolidation of wastes. The Army does not need a permit or waiver from MDE in
order to include contaminated soil/ash from the Building 503 Soils Operable Unit as part of the fill
material. Land disposal restrictions (LDR) restrictions do not apply to the contaminated soil/ash.
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.
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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 5 shall 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).
Since Alternative 5 may result in paniculate emissions to air, Alternative 5 shall comply with
Maryland State- Adopted National Ambient Air Quality Standards and Guidelines (COMAR 26.11.03),
Maryland General Emissions Standards, Prohibitions, and Restrictions (COMAR 26.11.06), Maryland
Toxic Pollutants Regulation (COMAR 26.11.15) and Maryland Noise Pollution Regulations (COMAR
26.02.03). There will be no air emissions after completion of this interim remedial action.
Alternative 5 is not expected to impact historically significant areas, wetlands, or critical habitats.
No protected species or sensitive land areas will be affected during remediation. Transportation of
hazardous materials could be necessary but is not expected to be necessary under this interim remedial
action.
Cost Effectiveness. The selected alternative is the least expensive of the alternatives that comply with
the ARARs. The estimated capital cost for implementation of Alternative S is $44,900.
Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable. The Army has determined mat the selected interim
remedy represents the maximum extent to which permanent solutions and alternative treatment
technologies or resource recovery technologies can be utilized in a cost effective manner for remediation
of the Building 503 smoke burn sites.
The most permanent solution is to remove the waste source and treat the removed waste. In-situ
treatment of the waste was assessed in the Feasibility Study, however, in-situ treatment could not be
implemented because of the potential for ordnance at the burn sites. Ex-situ treatment can be
accomplished either on-site or off-site. The National Contingency Plan specifies a preference for on-site
treatment. The ex-situ treatment option considered (Alternative 3) was stabilization of the waste followed
by disposal in an off-site landfill. While mis is a permanent solution, stabilization was found to provide
little additional protection due to me nature of the waste. The other alternative (Alternative 4) deemed
practical was to excavate the waste, and place the waste in a RCRA landfill. While Alternatives 2, 3,
and 4 are permanent solutions, they increase the off-site risk since the waste would have to be transported
over public highways. Also, off-she movement would merely transfer responsibility for the soil and ash
to another location. Therefore, Alternative 5 was judged to be the most protective of human health and
the environment, implementable, and cost effective.
Resource recovery was also evaluated in the feasibility study. Recovery of metals value or reuse
allows minimization of the waste. The innovative resource recovery technology of high-temperature
metal recovery (HTMR) was considered for possible resource recovery. However, due to die relatively
low concentration of zinc and the small volume of material, HTMR was not found to be practicable.
Preference for Treatment as a Principal Element. While organic contaminants can be destroyed, metal
cnntaminant$ such as lead and zinc cannot be destroyed by treatment. On-site treatment by stabilization
with cement binders was evaluated as an alternative. This evaluation showed that stabilization would
probably not be effective due to the diverse types of contaminants, and consequently would not provide
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April 4, 1995
much additional protection. Also, since treatment operations entail a high fixed cost for equipment setup,
treatment of small volumes of waste is expensive per unit of waste treated. Due to the low concentration
and volume of contaminants present, additional treatment would not be cost effective.
The selected interim remedy is the most cost effective and technically feasible approach to
minimize the risks posed by the Building 503 bum sites. It does not satisfy the statutory preference for
treatment as a principal element of the remedy because treatment of the principal site contaminants was
found to be not practicable. However, the selected interim remedy reduces the mobility of contaminants.
Excavation removes the waste from the Building 503 sites and provides the greatest reduction in toxicity,
mobility, and volume of the site contaminants. By placing the waste in the Building 103 dump, the
selected interim remedy is consistent with the Superfund program policy of containment, rather than
treatment, for wastes that do not represent a principal threat if they are not highly mobile in the
environment (40 CFR Section 300.430).
Table 5 Review of Potential Action-Specific and Locational ARARs for the Building 503
Burns Sites Selected Remedy (See note 1)
Environmental Taws and Regulations
ACTION SPECIFIC
I. U.S. Department of Transportation (DOT)
Regulations (49 CFR Parts 170-179)
II. State of Maryland
A. Maryland Noise Pollution Regulations
(COMAR 26.02.03)
B. Maryland Erosion and Sediment Control
Regulations
(COMAR 26.09.01)
C. Maryland Stonnwater Management
Regulations
(COMAR 26.09.02)
D. Maryland Air Pollution Control Regulations
(COMAR 26.11,03, 06, and .15)
LOCATION SPECIFIC
I. APG Disaster Control Plan, Annex C, Annex S
(see note 2)
Consideration as an ARAR
Contaminated waste materials could be
transported off-post under the selected
remedy.
Maximum allowable noise levels shall not be
exceeded at die burn site property boundaries
during the selected remedy.
Excavation and backfilling activities may
cause increased erosion and sediment runoff
requiring the application of control measures
during the selected remedy.
Stonnwater shall be managed before and after
the selected remedy.
The selected remedy involves earthmoving
equipment operations that may result in
emmissions to air.
Ordnance could be uncovered during
implementation of the selected remedy.
1. Note: All substantive requirements shall be met.
2. Note: Though not an ARAR, this APG plan would be followed in case of an incident/emergency.
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2.11 DOCUMENTATION OF SIGNIFICANT CHANGES
The selected remedy was the preferred alternative presented in the Proposed Plan. No changes
were made.
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SECTION 3
RESPONSIVENESS SUMMARY
The fmaJ component of the ROD is the Responsiveness Summary. The purpose of the
Responsiveness Summary is to provide the public with a summary ofjcitizen comments, concerns and
questions about the Building 503 burn site interim remedial action and the EPA's and 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 503 bum site in APG-EA, several written
comments, concerns and questions were received by the Army. No comments, concerns, and/or
questions were received by the EPA and/or the Maryland Department of the Environment. 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. The transcript of this meeting
is part of the administrative record for this Operable Unit. The transcript and public comments received
by the Army are attached at Appendix A.
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
Public meeting attendance roster
Panel of experts
Selected newspaper notices announcing dates of public comment period and loca-
tion/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 gnmmarirAH below have
been considered by the EPA in making a decision regarding me choice of the selected alternative for the
Building 503 bum sites. Additionally, the Army and EPA are proposing with the issuance of the ROD
to continue investigating the Building 503 burn sites and the related Building 103 dump area as part of
the ongoing Canal Creek RI/FS. The results of mis investigation will be incorporated into the ongoing
Canal Creek RI/FS and Canal Creek Area ROD.
f
3.1 OVERVIEW
Both the U.S. EPA and the MDE concur that the preferred alternative is protective of human
health and the environment. The selected interim remedy is excavation and transfer of the contaminated
soil and ash to the Building 103 dump where it will form part of the required fill prior to installing a cap
and cover system over the dump. The selected remedy will protect human health and the environment
by reducing the mobility of the contaminants in the soil and ash.
APG has implemented a comprehensive public involvement program. The program includes
public involvement activities for the review and selection of the interim remedial alternative for the
Building 503 burn sites. The community has shown interest in the interim actions. In addition to APG
placing project documents in several repositories and distributing fact sheets, APG has briefed the
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Technical Review Committee on two occasions, and a public meeting was held describing the interim
action and soliciting public input on the plans. The Aberdeen Proving Ground Superfund Citizen's
Coalition prefers a permanent solution which removes the soil and ash to an off-site location.
3.2 BACKGRpUND ON COMMUNITY INVOLVEMENT
Community interest in the interim action has been strong, and APG has implemented a com-
prehensive public involvement program. In addition to placing project documents in several repositories
and distributing fact sheets, the Technical Review Committee has been briefed on two occasions, and a
public meeting was held describing the interim action and soliciting public input on the plans.
Community relations activities for the proposed Building 503 interim action include:
APG briefed the scope and role of this operable unit the Technical Review Committee on July
29, 1993, and on January 27, 1994. Representatives were also given a tour of the burn sites.
APG released the Focused Feasibility Study (FFS) (Battelle, 1994), Proposed Interim
Remedial Action Plan (Battelle, 1994), and background documentation for the Building S03
burn sites 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,
an information repository has also been set up on APG in the TECOM Public Affairs Office.
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 me 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 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 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.
Representatives of the Army, EPA, and the MDE answered questions about the proposed
interim remedial action at the Building 503 burn sites operable unit and remedial alternatives
under consideration.
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Responses to comments received during this period are included in the Responsiveness
Summary which is part of this ROD.
3.3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND AGENCY: HESPONSES
COMMENT SET 1 received from concerned Joppa, MD citizen.
(NOTE: Comments pertaining to (he Building 103 dump are included because the Building 503 Soili Operable Unit toil will be used as fill under
the Building 103 dump cap and cover system.
Ladies and Gentleman, Distinguished Guests, and Concerned Citizens:
Although I agree with the U.S. Army's remedial action at Building 503 to remove white
phosphorous contaminated soil, I 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
operable unit. 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 h 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 She 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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Comment 4 What safety precautions are being taken to contain any spillage or air
release of hazardous materials do to the rupture or detonation of UXO's at the Building
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. In addition to the munition fill, explosive components of the munition also
present a potential hazard. 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 die 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 hi 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 vermiculite or some other material can be safely detonated;
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April 4, 1995
the explosion is totally contained since the vermicuiite 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.
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
minimi 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 depositing of the white phosphorous contaminated
soil off-post instead of creating or adding to an existing hazard across the street at die.
Building 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 burn 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 h 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
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monitored as part of the monitoring program of the Building 103 cap and cover system.
This monitoring program will determine if further remedial actions need to be undertaken
at a later date.
Comment 6 I feei that the Army's role is to clean up existing hazardous waste, and not
to create or add others. I also feel that due to the instability of UXO 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 die Building 103 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 bum 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 bom the ash and soil and from wastes in the
Building 103 dump.
The Army concurs with the comment that a more hazardous situation would exist for on-
site workers and off-site personnel if the Building 103 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.
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 IS, 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 ensure mat 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 the overall "dilution" of the chemicals of
concern be?
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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 site 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 mat 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 hi 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 (HUlel, 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 and 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 not planned.
COMMENT SET 3 received May 19, 1994, from technical advisors to the APG Superrand 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 mis 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 mis 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
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would be minimal levels of methane due to the decomposition of previously
undecomposed organic matter, and possible vapors from leaking buried process vessels.
The Army says 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 OF- 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 part 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 Toxichy Extraction test, and the teachability
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 mis 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. The current plan for the gas venting system is to install
49
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Final
April 4? 1995
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.
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 i>e 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.
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Final
April 4, 1995
COMMENT SET 4 received May 19, 1994, from technical advisors to the APG Superftind Citizen's
Coalition who are associated with the University of Maryland Program in Toxicology.
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 bum 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.
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 mis 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 sou* 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 minimise, dust generation. Also, this interim remedial action
will be conducted under a Health and Safety Plan so as to minimi 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 will be set up in the corridor to
minimi- uncontrolled movement of contamination out of the exclusion zone. Finally,
monitoring will minimize risks to on-she workers and off-she 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 hi its new
environment.
Response Lead teachability tests were performed using bom 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
51
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April 4, 1995
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 man 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.
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 mis 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 (APGSCQ 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 time and effort spent on these sites. It is our sincere hope
that the Army will continue to make progress in characterizing the Canal Creek study
area, so the best remedial actions can be initiated in a timely manner.
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April 4, 1995
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 in 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
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-S422. Whether or not the cap is
constructed, mis effort is vital to the protection of those individuals working in mis
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
unexploded ordnance (UXOs). 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 mis 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.
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FinaJ
April 4, 1995
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 mat 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 pattern of ground water
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 mis 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 wfll 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 mat 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 is currently performing a more definitive delineation of the
Building 103 dump in order to determine the true extent of the dump. Geophysical
surveys were performed June 28-29, 1994, to better delineate the extent of the dump.
The data from mis survey, and from the soil gas survey will be used in designing the cap
and cover system at the Building 103 dump.
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
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April 4, 1995
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 is 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.
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 RI/FS
and overall Canal Creek ROD.
Currently, no air monitoring is being performed inside Building ES422 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. Hie monitoring options available, which will
be addressed in the design phase of the cap and cover system, are the placement of
monitoring equipment beneath the building ES422 slab or within the building itself. This
will be addressed in the design.
The cap and cover system cross section presented hi 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 hi 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 mat the additional load
of the cap and cover system to be constructed will expand the area! and vertical extent
of contamination and displace any interstitial gas. If the waste compresses 0.2S inches,
there should be a negligible effect on the hydrostatic pressure in the surficial aquifer.
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Final
April 4, 1995
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 die 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 and is not transmitted directly to buried ordnance. 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. 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, for example
snow shoes is 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, mis 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 are do not appear to be able to penetrate High Density Polyethylene (HDPE).
A study cited by EPA tided 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 men: 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 tmd 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
56
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Final
April 4, 1995
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 the 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 than 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
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 hi 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
liner.
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 die
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,
57
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Final
April 4, 1995
blast furnace slag, and silicates. The most commonly used organic binders are
thermoplastics, in particular asphalt. Application of organic binders is more expensive
than application of inorganic binders. Organic binders are typically only used in special
applications where the waste is unsuitable for treatment by inorganic binders and/or
where the treated waste can be reused as paving asphalt. For example, asphalt binder
is widely used to treat soils contaminated 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 die 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
effectiveness of treatment.
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 Bum sites with
the 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 since it is not practical to construct a cap at the
Building 503 site and at the Building 103 dump. Also, this would have been
considerably more expensive since the cap and cover system would have construction
costs, and maintenance costs.
Question 3 (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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Final
April 4, 1995
Response Currently, in addition to several individual interim remedial actions, die Army
is conducting a Canal Creek Area wide RI/FS and a ground-water investigation. All data
collected as part of an action and/or remedial investigation are being used in odier
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, e.g., Carroll
Island and Graces Quarters.
Question 4 (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.
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 503 Dump and Canal Creek
Area
Steven Hirsh, U.S. EPA Region ffl Remedial Program Manager'
3.5 SELECTED NEWSPAPER NOTICES ANNOUNCING DATES OF PUBLIC COMMENT AND
LOCATION AND TIME OF PUBLIC MEETING
The announcement for die public meeting to discuss the interim remedial actions for the Building
503 Burn Soils Operable Unit and the Building 103 dump is attached at Appendix A.
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Final
April 4, 1995
APPENDIX A PUBLIC MEETING ANNOUNCEMENT
A-l
-------
,
-.;, ,;r, -K : ..«. ON PROPOSED REMEDIALfACTION PLANS-.
FOR THE BUILDING 503 SITE-ANDTUEZUILDING103 SITE AT
..-{^ABERDEEN PROVING GROUND*EDGEWQ(}D:AREA ~~ '-
The U.S. A/rny Invites the public to attend a public meeting on the Proposed Plans (or two
environmental actions at the Building 503 Slle and the Building 103 Site at Aberdeen Proving Groun
. OA7E May 34
T7M£ 7pm
PMCfc AfC - £4fe»«xf Area Caafmaa Ctmltr. BuU£mg 4110
Abo. the pubic can submit written comments during the 45-day comment period which runs from May 4 to Ju
17. Comments murt be postmarked by June 17 and sert to: Dkedorata of Safety. Heatm & Environment. Ui Army
Aberdeen Proving Ground. ATTN: SIEAKH-BJ tt WrobeO. Aberdeen Proving Ground. Maryland. 21010-5423.
The Atmy constructed Buying 503 during World War I and used tha die (or a variety ol manufacturing, testing
and disposal purpose*. Sampling ihowi the sol In two area behind the butdtng contains elevated levels or metah flee
and line) and two substance* utod In ma monufocturtng proeea (hexrxhlorooenzene and hexachloroethana). The
Army b proposing to excavate the sod and hat evaluated different aftemattves. the altemat)ves the Army evaluated
are:
Altemativ* 1: No Action (required by law to provide a baseOna for comparison).
AltematlvaZ: Excavate the tol end transport tt to on off-port !r.Astrial tandfl. backfB the site with
deantopsoL
ARecnatrv* 3: Excavate the sot art-site treatment by stabOballon. dbpoie of the to* at an off-jtte
(ndurtrlot tandfi. bockfa the site wrlh dean topsoL
Alteinatlv* 4: Excavate the sol. transport the sol to an off-die hazardous waste landfl. boctcfl the sir
with dean topsoL
Altwnatlve & Excavate the sol. dispose at APG'i BuScfng 103 site under the final cap and caver
system proposed below. baddB the stte with clean topsoL
The preferred ottemertrw at this time b & The Am^ propo»« to eaaovate the «oB to a depth of one foot, removtr
cboul 470 ci** yards of »otarKl to pkx» the excavated sal at the Bufcflng Idlstte. The Arniy would use dean lopn
to restore the site to the natural contours of the area
TheBuldlng 103 site b a former waste dbposal and burial area. The Army used the site starting In the Mbrtd Wn
era untl Ihe earty 1940s. Since dbposal records were not required during thb lime, there b title Information about what
was placed at the site. The Army believe* the site may contain mbcetaneous debits and possfcry chemical agent
residue and ordnance Items. The Army** studies show the trie may be contrtxrting solvents to Ihe ground water at the
site. There b no direct pubic exposure to any die ehemlcab. and the water beneath the site b not a source of drinking
want . _
The Army evaluated different cttemallves to certain the waste and to block rain and surface water from
moving through the site and carrying substances Ho the ground watet The Army abo sought an effective artafnoHve
prevent onfenob from burrowing at the sfte. The alternatives the Army evaluated are:
ADemalMel: No Aetlan (requked by law to provide a basePne for comporbon).
Attemotlve 2: (ratal a stnale-iner cap uskng off -post day.
Alternative 3: Instal a sinale4ner cap udng a higher quoflty day and sand (bentonlte geocomposito
Enet
AltemalrveA: Instal a slngle4ner cap using a rubber-Bee material (aeosynthofic membrane).
Aflernalive & tnstal a double-Oner cap uing off-post day and geosynihetlc membrane.
Alternative tr. Instal a double-tnef cap using a bentontte aeocomposite iner and geosynthetic
The preferred alternative at Ihb time b & The Army propotei to construct a multHayer cap and covet system In
accordance with federal requirements for a hazardous waste landfl doue. The cap would cover an oreo of appro*
matety 1.7 acres and woUd have a oobbte/gravel barrier to Srrtt animal Occam. Two Impermeable layers woJd Emit
he movement of water Into the srle and substances from the site Into the ground watet
The preferred alternatives may be modified or new anemattves developed based on pubic input. The final
emedtat selected w« be documented In Records of Oedslon that summarize Ihe decision-making process. APG w9
summarize and respond to d written comments received during Ihe comment period as port of the Records of Deco*
Copies of the Focused FeasasMy Studies and the Proposed Plans ore at the AP6 Wormalton repositories local.
at the Edgewood and Aberdeen branches of Harfoid County Ubrary. M*» library at Washington College. Essex Com-
munity College Ubrary. and the TECOM Public Affairs Office at AP6.
B you have questions regarding the meeting or proposed action, please cat APG's 24-hour InstaOotion Restoro
lion Program Information Gne at (410) 272-8842.
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Final
April 4, 1995
APPENDIX B PUBLIC MEETING TRANSCRIPT
B-l
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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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COMMUNITY MEETING - MAY 24, 1994 2
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
time.
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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COMMUNITY MEETING - MAY 24, 1994 4
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 oato 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
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 in 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,
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 have a conservation program
some people that are dedicated to 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 arena. 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 .need 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 -tudy
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 take a soil sample or two, and make a
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determination as to whether this thing doesn't even exist
anymoref 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
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
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 for 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?
But 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. WR08EL: 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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contaminated soil.
As part of that study that Ken was talking
about where we identifi - there is 318 solid waste
management units we i some preliminary sampling at
the site back in 1986. < that's :"hat allowed to have
this ranking score ami 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 anythir; ve could do and what we mean
by stabilization is mix t up with concrete, make it so
that it doesn't release ything, make it into cinder
blocks and maybe dispos - ..t 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 samr -s, look for the rinded
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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
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 t.-; - projects get accelerated here. You'll
see these ty~ >f people doing these type of activities
on Aberdeen Edgewood.
4ain, 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, hexachlorobenzene,
hexachloroethane, which are components of the different
smoke mixtures that were burned at this particular sitel
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.
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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, has. d 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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1 facility. I can't give a lot of details. I don't know a
2 lot of details what they're doing. But it's industrial
3 work. They work with chemicals. They work with vehicles
4 and maintain things in that area. So it's an
5 industrial-type of scenario. So what we based our risk
6 assessment for, is based on cleanup goals for that type
7 of industrial activity occurring at the site, which is
8 what people would use for a site in Baltimore or people
9 would use in Harford County for an industrial site.
10 . These are the types of cleanup goals they would have in
11 that particular site. If this was a residential use, the
12 levels would obviously, you know, be lower. And this is
13 comparing the cleanup goals versus the concentrations.
14 You can see that we exceed our goals just in the
15 burn area, but not outside that burn area. Keep in mind,
16 this is an interim action. We haven't fully defined I
17 don't know if Congress has fully defined what the
18 ultimate use of the Edgewood Arsenal is going to be,
19 whether it's going to be converted to a residential use,
20 or whether it's going to continue to be a military you
21 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
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 t. 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?
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 Ctate 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 you 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
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. I-'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,
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
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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 animals from
coming back in and eroding the current, the cap 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
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
loo'ked 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
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 using 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
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 AP6 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. 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
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 Cutting 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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COMMUNITY MEETING - MAY 24, 1994
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this big six foot, it's going to be to grade to the
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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 t-hem.
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. TAYLOR: 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 SCO.
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 your
magnetometer readings and try to determine where you have
pits and things like that. It talks about that in your
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 Creek 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 off, 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 come 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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sidesi 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 cculd 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 definitely will have to be revisited. It's
going 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
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
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.
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
Penniman & 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: "11 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 dq 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 yo.u
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 e^e 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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MR. STACHIW: In the design phase.
MR. WROBEL: Somewhere in the design- phase.
In fact, I had a meeting with the stake holders today --
people that actually occupy that particular building, and
we discussed that particular issue today. We talked
about what the final cover is going to look like, what
kind of vegetation we're going to put it. Obviously,
they have to look at it every day, outside their windows,
so we had a meeting with those particular stake holders
to talk about that type of concerns. Obviously, we want
to have something that is maintainable, has a little bit
of esthetics to it, that kind of thing. We've got a
landscape architect as part of the team, we could bring
in as part of the team, to develop a cap that would do
relatively low maintenance. But that would be addressed
in the design process.
I think Dr. Montgomery here he's with
the Battelle organization, done a lot work in capping
landfills maybe can give us a little bit on this
animal intrusion thing.
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
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 C. »ek'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
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, become 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 AP6 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 that 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
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 the'ir point of contact in
Kentucky the kinds of things we had that they were
interested in. So, however, they didn't make known to us
anything that they had that 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 demil 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 a1.: the remediations. I
will send you copies of everything -.hat 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 it.
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 my 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 dar t,
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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
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), Aberdeen Proving 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 arid 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 )
j CERTIFICATE
COUNTY OF HARFORD, SS: j
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.
Hf} ,(^Kl
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
April 4, 1995
APPENDIX C REFERENCES
AEHA. 1992^ See U.S. Army Environmental Hygiene Agency.
Battelle. 1993aT Focused Feasibility Study, Soils Operable Unit, Building E5265 (BLDG 503) Smoke
Pilot Plant Burn Areas, Edgewood Area, Aberdeen Proving Ground, MD. Battelle Edgewood
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Eisler, R. 1993. Zinc Hazards to Fish, Wildlife, and Invertebrates: A Synoptic Review.
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Federal Facilities Agreement 1990. Agreement between the U.S Department of the Army, Aberdeen
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ICF/Kaiser Engineers. 1993. Memorandum on Risk Assessment, June.
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National Academy of Sciences (NAS). 1980. Mineral Tolerance of Domestic Animals. National
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Nemeth, G. 1989. RCRA Facility Assessment, Edgewood Area, Aberdeen Proving Ground, MD.
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Final
April 4, 1995
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U.S. Environmental Protection Agency (U.S. EPA). 1992. Ground Water Issue: Behavior of Metals
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U.S. Environmental Protection Agency (U.S. EPA). 1993a. Integrated Risk Information System
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Personal communication with Ms. L. Miller, Dames and Moore, Lintnicum, MD.
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