PB96-963911
EPA/ROD/R03-96/228
October 1996
EPA Superfund
Record of Decision:
Aberdeen Proving Ground
(Edgewood Area) J-Field Soil O.U.,
Aberdeen Proving Ground, MD
9/27/1996
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J-FIELD SOIL OPERABLE UNIT
RECORD OF DECISION
FINAL DOCUMENT
DISTRIBUTION RESTRICTION STATEMENT
APPROVED TOR PUBLIC RELEAS&
DISTRIBUTION 19 UNUMITEB
IS3S-A-4
Edgewood Area - Aberdeen Proving Ground, Maryland
September 1996
In accordance with Army Regulation 200-2, this document is inteaded by the Army to comply with the
National Environmental Policy Act of 1969 (NEPA).
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TABLE OF CONTENTS
Section Page
1.0 DECLARATION OF THE RECORD OF DECISION "1-1
1.1 SITE NAME AND LOCATION 1-1
1.2 STATEMENT OF BASIS AND PURPOSE 1-1
1.3 ASSESSMENT OF THE SITE 1-1
1.4 DESCRIPTION OF THE SELECTED REMEDIES 1-1
1.5 STATUTORY DETERMINATIONS 1-2
2.0 DECISION SUMMARY 2-1
2.1 SITE NAME, LOCATION, AND DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
2.2.1 History of J-Field Soil Operable Unit 2-1
2.2.2 Enforcement Activities 2-4
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION ' 2-5
2.4 SCOPE AND ROLE OF THE J-FIELD SOIL OPERABLE UNIT 2-5
2.5 SUMMARY OF SITE CHARACTERISTICS 2-5
2.6 SUMMARY OF SITE RISKS : 2-7
2.6.1 Human Health Risks 2-7
2.6.2 Environmental Risks 2-12
2.7 REMEDIATION OF THE J-FIELD SOIL OPERABLE UNIT 2-19
2.7.1 Description of the Alternatives 2-19
2.7.2 Summary of the Comparative Analysis of Alternatives 2-24
2.7.3 Selected Remedy 2-28
2.7.4 Statutory Determinations 2-30
2.8 DOCUMENTATION OF SIGNIFICANT CHANGES 2-33
2.9 SUMMARY OF PERFORMANCE STANDARDS 2-33
3.0 RESPONSIVENESS SUMMARY 3-1
3.1 OVERVIEW ' , 3-1
3.2 BACKGROUND ON COMMUNITY INVOLVEMENT 3-1
3.3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES 3-2
4.0 REFERENCES • 4-1
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LIST OF FIGURES
Figure Page
Figure 1 Location of J-Field in the Edgewood Area at Aberdeen Proving Ground 2-2
Figure 2 Location o'f Principal Site Features at J-Field 2-3
Figure 3 Locations of the Main Features at the J-Field Soil Operable Unit 2-6
Figure 4 Location of In-Situ Containment Area and Shoreline Containment, Alternative 2 . . 2-31
LIST OF TABLES
Table Page
Table 1 Summary of Chemicals of Potential Concern Detected in Soil Samples Collected
from the Former Toxic Burn Pit 2-8
Table 2 Summary of the Human Health Chemicals of Potential Concern at the Former
Toxic Burn Pits 2-11
Table 3 Summary of Pathway Specific and Cumulative Risks Associated with Human
Health Exposures at the Former Toxic Burn Pits 2-13
Table 4 Summary of the Chemicals of Potential Ecological Concern at the Former Toxic
Burn Pits 2-15
Table 5 Summary of the Ecological Receptors for the Former Toxic Burn Pits 2-16
Table 6 Summary of the Ecological Receptors. Assessment Levels, and Effects
Assessment Method for the Former Toxic Burn Pits 2-18
Table 7 USEPA Evaluation Criteria for Remediation Alternatives 2-25
Table 8 Comparison of Remedial Action Alternatives for the Former Toxic Burn Pits at J-
Field 2-26
Table 9 Cost Estimate for Alternative 2 in April 1996 Dollars 2-29
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1.0 DECLARATION OF THE RECORD OF DECISION
1.1 SITE NAME AND LOCATION
J-Field Soil Operable Unit (SOU), J-Field, Edgewood Area, Aberdeen Proving Ground (APG).
Maryland. This Operable Unit (OU) consists of two main burn pits (the Northern Main Burn Pit and
Southern Main Burn Pit). It also includes the Pushout Area, which consists of the O-ethyl-S-(2-
iisopropylaminoethyl)methyl phosphonothiolate (VX) Burn Pit, the Mustard Burn Pit. and the Liquid Smoke
Disposal Pit.
1.2 STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) document presents the selected remedial actions to reduce the
risks posed by contaminated surface soils from the J-Field SOU located at J-Field, APG, Maryland. The
remedial actions were developed in accordance with the Comprehensive Environmental Response.
Compensation, and Liability Act (CERCLA) of 1980, as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986 and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision is based on the administrative record for
this site. Documents contained in the administrative record are identified in Section 2.2.2.
The U.S. Environmental Protection Agency (USEPA) and the Maryland Department of Environment
(MDE) concur on the selected remedy.
1.3 ASSESSMENT OF THE SITE
Actual or potential releases of hazardous substance from this site, if not addressed by
implementing the response actions selected in this ROD. may present an imminent and substantial
endangerment to public health, welfare, or the environment.
1.4 DESCRIPTION OF THE SELECTED REMEDIES
The remediation of the J-Field SOU is part of a comprehensive environmental investigation, and
clean-up action currently being performed at APG under the CERCLA program. APG is divided into 13
study areas which encompass potential sources of contamination. The J-Field Study Area is comprised
of 2 OUs, one of which is the soil contamination at the J-Field SOU. The remaining areas of concern at
J-Field are included as part of the other OU, which is being addressed as a separate action. This
decision document addresses the actions to be taken toward remediating the principal threats provided
by high levels of arsenic, lead, and PCBs at the J-Field SOU: (1) the removal of isolated hot spots of
contamination from the SOU followed by (2) the construction of a Protective Soil Blanket (PSB) over the
J-Field SOU. The major components of the selected remedy will include:
Unexploded Ordnance (UXO) clearance:
Site preparation and vegetative clearance;
Excavation of isolated areas of arsenic, lead and PCB contamination from the Northern
and Southern Main Burn Pits and lead from the Pushout Area, is described below. The
contaminated soil will be transported off-site for treatment and disposal:
Placement of a layer of permeable geotextile fabric over the entire surface of the J-Field
SOU to separate the unexcavated soil from clean soil:
1-1
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The addition of a minimum two feet thick PSB of clean soil to the J-Field SOU. Where
needed, additional soil will be added to raise topography above the 100 year flood plain
level.
Placement of shoreline protection along the Chesapeake Bay side of J-Field to prevent
erosion of the J-Field SOU;
Repairs of any road damage that may occur during the remediation effort: and
Institution of a long-term performance monitoring program which will be done as part of
the first remediation:
1.5 STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with federal
and state requirements that are legally applicable or relevant and appropriate to the remedial action, and
is cost-effective. The remedy utilizes permanent solutions and currently available technologies to the
maximum extent practicable. The limited excavation, placement of a PSB, and off-site transport and
disposal reduces the risks associated with the contaminants by removing, treating or disposing of them.
as necessary. The statutory preference for treatment or resource recovery is satisfied by using the
selected remedy because the principal element of the remedial technology is to reduce, permanently and
significantly, the toxicity. mobility or volume of hazardous substance 3t the J-Field SOU.
1-2
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Richard W. Tragemartn
Major General (J.S.(0[rmy
Commander, U.S. Army Aberdeen Proving Ground
Date
M
Billy K. fefolomon
Major General, U.S. Army
Chief of Staff, Army Materiel Command
Date
Thomas C. Voltaggio lv _^r- — '
Director, Hazardous Waste Management Division
U.S. Environmental Protection Agency, Region III
Date
1-3
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2.0 DECISION SUMMARY
2.1 SITE NAME..LOCATION, AND DESCRIPTION
APG is a 72,500-acre Army installation located in southeastern Baltimore County and southern
Harford County, Maryland, on the western shore of the upper Chesapeake Bay (Figure 1). The installation
is bordered to the east and south by the Chesapeake Bay; to the west by Gunpowder Falls State Park.
the Crane Power Plant and residential areas: and to the north by the towns of Edgewood, Magnolia.
Perryman, and Aberdeen. APG is divided into two areas by the Bush River: the Edgewood Area lies to
'the west of the river and the Aberdeen Area lies to the east. The Edgewood Area is listed on the National
Priorities List (NPL). The NPL is USEPA's list of hazardous substance sites in the United States that are
priorities for long-term remedial evaluation and response.
The approximately 460-acre J-Field Study Area, in the Eastern coastal plain adjacent to the
Chesapeake Bay, is located at the southern end of the Gunpowder Neck peninsula in the Edgewood Area
(Figure 2). J-Field is bordered to the north by another study area, designated as Other Edgewood Areas,
that includes the other range fields. J-Field is bordered on three sides by tidal estuaries: Gunpowder
River to the west, Chesapeake Bay to the south, and Bush River to the east. Each of the three estuaries
receive surface runoff and groundwater discharge from the J-Field area. Both the Gunpowder River and
the Bush River drain into the Chesapeake Bay.
The site is underlain by more than 100 ft of Quaternary sediments of fluvial and estuarine origins
and other, older geologic formations. The terrain at J-field is nearly flat, with a maximum relief of about
ten feet. Marsh areas are common throughout J-Field. The groundwater table in the surficial aquifer is
shallow, usually less than seven feet below the ground surface. The groundwater is recharged through
precipitation near uplands and is discharged to the surrounding lowlands.
The majority of J-Field is forested. The lowland areas support the development of extensive tidal
marshes and palustrine wetlands. The marshes are dominated by common reed and cattail. Drier upland
areas support occasional stands of yellow poplar or mixed deciduous hardwoods. The western portion
of J-Field along the Gunpowder River consists of old open field areas dominated by upland grasses.
The J-Field Study Area includes the Northern and Southern Main Burn Pit and Pushout Area, the
Riot Control Burn Pit. the Robins Point Demolition Ground, the Robins Point Tower Site, the South Beach
Trench, the South Beach Demolition Ground, the Prototype Building, the White Phosphorous Burn Pits.
and several smaller test areas (designated as site XI, Area A. Area B. Area C, Area D, the Ruins Site, and
several craters). Although all of these areas were included in the Remedial Investigation (Rl). this decision
document focuses solely on the J-Field SOU, which includes the Northern and Southern Main Burn Pits
and Pushout Area.
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.2.1 History of J-Field Soil Operable Unit
During World War II, J-Field was used to test high explosives and chemical munitions. J-Field was
also used for the thermal and chemical decontamination of chemical munitions. Chemical agents.
chemical wastes, and high explosives were burned or "open detonated' in the pits at J-Field. This
Operable Unit consists of two main burn pits (the Northern Main Burn Pit and Southern Main Burn Pit).
It also includes the Pushout Area, which consists of the VX Burn Pit, the Mustard Burn Pit. and the Liquid
Smoke Disposal Pit (Figure 2).
The pits were used extensively between the late 1940s and 1960s and to a lesser extent
throughout the 1970s. The Northern and Southern Main Burn Pits are each approximately 300 feet long
2-1
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PENNSYLVANIA
Gunpowder
Neck
Peninsula
\*r
0
E
SCALE
10000
20000
FEET
DEPARTMENT OF THE ARMY
US Army Corps of Engineers
CONTRACT NO. DACA31-9S-D-0085
____ -. ..
*ICF KAISER
2M3 EMUrtM Pvfc OrtM
nr> csr
L TMBEAU
OAlt: 09/04/96
HO: 667O4
04019290
FIGURE 1
MERMEN PROVMC CROUW)
LOCATION OF
J-FIELD IN THE
EDGEWOOD AREA
AT APG
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Gunp-o-wder
River
SITE XI
WHITE PHOSPHORUS
BURN PITS
FORMER TOXIC
BURN PITS AREA
iE DETAIL)
Fords Point
Chesapeake
Bay
PROTOTYPE BUILDING
RIOT CONTROL
BURN PIT
Rickett's
ROBINS POINT TOWER
SOUTH BEACH TRENCH
SOUTH BEACH
DEMOLITION GROUND
f Robins Point
Chesapeake
Bay
NORTHERN MAIN PIT
SOUTHERN MAIN PIT
VX PIT (FILLED)
MUSTARD PIT (FILLED)
=-PUSHOUT AREA
HIGH EXPLOSIVE
-DEMOLITION GROUND
0
c
SCALE
1250
2500
FEET
LEGEND:
— BOUNDARY BEFORE 1986
MARSH
FORMER TOXIC BURN
PITS AREA DETAIL
0 500 1000
SCALE
FEET
DEPARTMENT OF THE ARMY
US Army Corps of Engineers
CONTRACT MO. OACA31-95-0-0083
*ICF KAISER
PUPMCO Bfi CST
OCOED. |_ 1ME8EAU
O9/04/96
667O4
667O4PSF
FIGURE 2
MBVSN (wane atcw
LOCATION OF
PRINCIPAL
SITE FEATURES
AT J-FIELD
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with a total area of about 4,500 square feet. High explosive-filled munitions, nerve agents, mustard, liquid
smoke, chlorinated solvents, and wastes were disposed in these pits between 1940 and 1980. High
explosive-filled munitions were also 'open burned' or detonated here during this time. Three smaller pits
include the Mustard Burn Pit (approximately 100 feet long), a small Liquid Smoke Disposal Pit
(approximately 24 square feet), and the VX Burn Pit. The three smaller pits, located near the Pushout
Area, have been buried. These pits were used in the same manner to dispose of VX, Mustard
(dichlorodiethyl sulfide), and the primary components of liquid smoke: titanium tetrachloride and sulfur
trioxide/chlorosulfonic acid.
Open burning initially involved placing three to four feet of wood dunnage in a pit. The materials
to be burned were then placed on top of the dunnage. Fuel oil was added, and the material was ignited.
Scrap metal items were removed and reburned in the same manner. The depths of the pits were
maintained by pushing burned soil and ash out of the burn areas toward the adjacent marsh in an area
that is collectively referred to as the Pushout Area. The Pushout Area occupies about 67,000 square feet
and extends more than 100 feet into the marsh.
2.2.2 Enforcement Activities
The U.S. Army Toxic and Hazardous Materials Agency (renamed the U.S. Army Environmental
Center (USAEC)) reported that contamination at J-Field was first detected during an environmental survey
of the Edgewood Area conducted in 1977 and 1978. Subsequent to this study, 11 groundwater
monitoring wells were installed at J-Field to determine the extent of contamination. Contamination was
also detected during a munitions disposal survey conducted in 1983 (Princeton Aqua Science, 1984).
Princeton Aqua Science installed and sampled nine additional wells and collected and analyzed surface
and subsurface composite soil samples.
In 1986, the USEPA issued a Resource Conservation and Recovery Act (RCRA) Permit (MD3-21-
002-1355) requiring a base-wide RCRA Facility assessment (RFA) and a hydrogeologic assessment at J-
Field. The U.S. Geological Survey (USGS) conducted a two phased hydrogeologic assessment which
included soil gas investigations and the installation of several wells. A groundwater flow model of the J-
Field area was developed based on the hydrogeologic assessment. .Groundwater and surface water
monitoring programs were initiated, and samples continue to be collected as part of that monitoring
program. The results of the USGS study are available in the administrative record.
2.2.2.1 Resource Conservation and Recovery Act Facility Assessment. In 1989. the U.S. Army
Environmental Hygiene Agency (renamed U.S. Army Center for Health Promotion and Preventive Medicine
(USACHPPM)) conducted a RFA that addressed the entire Edgewood Area, including J-Field. The RFA
recommended that a number of sites within the J-Field study be designated as RCRA Solid Waste
Management Units (SWMU) requiring further investigation and possible remediation.
>
The assessment of the J-Field SOU resulted in a recommendation that an additional investigation
be conducted with a primary focus on marsh sediments and surface water adjacent to the J-Field SOU
and a secondary focus on the shallow surficial aquifer.
2.2.2.2 Remedial investigation/Feasibility Study. The entire Edgewood Area was designated
as an NPL Site on February 21, 1990. This resulted in the requirement for a Remedial
Investigation/Feasibility Study (RI/FS) for the entire Edgewood Area, pursuant to Modification 2 of the
RCRA Permit and a March 1990 Federal Facility Agreement (FFA) between USEPA Region III and the U.S.
Department of the Army. The current environmental study at J-Field is being conducted under the FFA,
which incorporates both RCRA and CERCLA requirements.
The J-Field Rl, completed in 1996, entailed the investigation of 15 areas and features of J-Field,
including the J-Field SOU. The conclusion made from the Rl was that the main sources of contamination
at J-Field included former toxic burn pits, the demolition grounds, and the suspect burn areas. The
primary contaminants were identified as heavy metals, petroleum related compounds, and chlorinated
2-4
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methanes, ethanes, and ethenes. Pesticides and PCBs were also present at the J-Field SOU. The
contaminants present are the direct result of disposal, open burning, pushout, and open detonation
activities that occurred at J-Field.
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Focused Feasibility Study (FFS) and Proposed Plan for J-Field were released to the public
on July 10, 1996, initiating a 45-day comment period, which was extended by 14 days. The documents
constituting the administrative record for J-Field were made available to the public at the following
locations:
Harford County Public Library, Aberdeen and Edgewood Branches;
Baltimore County Department of Environmental Protection, Towson, Maryland; and
Miller Library at Washington College, Chestertowne, Maryland;
The notice of availability of the Proposed Plan was published in the several local newspapers in
Harford, Baltimore, Kent, and Cecil Counties. A public meeting was held at the Edgewood Senior Center
in Edgewood, Maryland on August 12, 1996 to inform the public of the preferred alternative and to seek
public comments. At this meeting, representatives from APG, USEPA, and MDE answered questions
about conditions at the site and the remedial alternatives under consideration. Responses to the
comments received during this 45-day period are included in the Responsiveness Summary appended
to this ROD.
2.4 SCOPE AND ROLE OF THE J-FIELD SOIL OPERABLE UNIT
The interim action at the J-Field SOU represents one component of a comprehensive
environmental investigation and clean-up action currently being performed at APG to comply with CERCLA
requirements. This ROD addresses the soil contamination found in the J-Field SOU. This area poses a
potential risk to human health and the environment resulting from elevated levels of metals and PCBs
detected in the soil. The Liquid Smoke Disposal Pit. Southwestern Suspect Burn Area, Storage Area and
the High Explosive Demolition Ground do not pose a risk to human health or the environment. The
purpose of this action is to reduce the risks associated with the J-Field SOU by isolating or removing the
contaminants.
\
2.5 SUMMARY OF SITE CHARACTERISTICS
Contamination detected in the soil at the J-Field SOU is summarized below by main site features
(see Figure 3):
Northern Main Burn Pit: The primary contaminants detected at and underlying the
Northern Main Burn Pit are heavy metals and PCBs. The western portion of the Northern
Main Burn Pit has higher concentrations of lead than the eastern portion. While heavy
metals and petroleum related products as well as low levels of chlorinated solvents.
phthalates, PCBs, and pesticides were detected in the upper ten feet of soil in the
western portion of the Northern Main Burn Pit, the majority of contamination was in the
upper two feet of surface soil. Of the contaminants present, only metals were found in
significant concentrations to pose a potential risk to human health and the environment.
Heavy metals were detected in soils below ten feet, and low levels of metals and PCBs
were detected in the eastern portion of the Northern Main Bum Pit, but neither presents
a measurable risk.
2-5
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PUSHOUT AREA
(ESTIMATED)
VIEWING BUNKER
MAIN PITS
VX PIT (FILLED)
2B JFPM4A T^ J«
MUSTARD PIT (FILLED)
JF203 —
JF2O1
IGH EXPLOSIVE
-DEMOLITION GROUND
Chesapeake
Bay
o
b
SCALE
300
600
FEET
LEGEND:
MONITORING WELL LOCATION
_> BOUNDARIES
Olll'IIIir^ BURIED PITS
PONDS
MARSH
DEPARTMENT OF THE ARMY
US Army Corps of Engineers
CONTRACT NO. OACA31-95-0-0083
. _____ _- _ ,^ ____
^ICF KAISER
210
HKMKD rri car
CMCOD: L. 1MEBCAU
0»tt 09/03/96
WHO: 66704
ICT 0«0 Kb
66704TBP
FIGURE 3
ABERDEEN PROMN6 CRDWO
LOCATIONS OF
MAIN FEATURES AT
THE J-FIELD SOIL
OPERABLE UNIT
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Southern Main Bum Pit: Elevated levels of PCBs and Volatile Organic Compounds
(VOCs) (chlorinated ethanes and ethylenes) were detected in the eastern portion of the
Southern Main Burn Pit. VOC concentrations increased with depth. Semivolatile Organic
Compounds (SVOC) were also found in the upper two feet of soil. The concentration of
heavy metals detected in the Southern Main Burn Pit is lower than that of the Northern
Main Burn Pit; arsenic, cadmium, copper, lead, and zinc were detected in surface soils.
The primary chemical of potential concern (COPC), and the only one for which
remediation is necessary, in the Southern Main Burn Pit are PCBs detected in the upper
four feet of soil in a localized area.
PushoutArea: The upper four feet of soil in the Pushout Area exhibit some heavy metal
contamination, with the highest concentrations in the eastern portion. Contamination type
and level vary throughout the area and are likely related to the amount and content of the
pushout material in any given area. Toxicity Characteristic Leaching Procedure (TCLP)
analyses indicate that the pushout area is considered hazardous with respect to lead.
with levels above 8% in some areas. Chlorinated methanes, ethanes and ethylenes,
petroleurrj related compounds, PCBs, and pesticides were present in surface soils, but
no explosives were detected. Lead is the only contaminant that requires excavation in
the Pushout Area.
VX Burn Pit: The VX Burn Pit within the Pushout Area, now filled, has moderately elevated
levels of heavy metals in »he upper two feet of soil. Low levels of chlorinated ethanes and
ethenes, petroleum-related compounds, pesticides, dioxins and furans, 1,4-dithiane (a
mustard degradation product), and phthalates also were detected. Total Petroleum
Hydrocarbons (TPH) were detected in the deeper soil.
Mustard Burn Pit: The soil borings were drilled adjacent to the Mustard Burn Pit due to
the presence of metallic hits in the pit during the UXO metallic clearance survey. Heavy
metals were found in the upper two feet of soil, including elevated levels of arsenic, lead.
and zinc. Low levels of chlorinated ethanes and ethenes were detected in surface and
subsurface samples. Very low levels of petroleum related compounds also were detected
in surface soil.
Liquid Smoke Disposal Pit: Titanium chloride, a major component of liquid smoke was
detected inside the pit during x-ray fluorescence field measurements. Elevated levels of
heavy metals were found in a soil sample.
i Table 1 provides a listing of COPCs detected in soil collected from the Northern and Southern
Main Burn Pits and Pushout Area with a comparison to human health RBCs and regional background.
For comparison, human health RBCs are shown in Table 1 for each COPC. Ecological COPCs are
indicated with and asterisk. This decision document addresses the remedial actions associated with the
J-Field SOU; however, any associated groundwater, surface water, and sediment contamination will be
addressed in the RI/FS for the remaining J-Field areas.
2.6 SUMMARY OF SITE RISKS
2.6.1 Human Hearth Risks
A Human Hearth Baseline Risk Assessment (RA) was completed as part of the Rl for the J-Field
SOU to characterize the current and potential future risks associated with site-related chemicals in
ground water, soil, sediment, and surface water. As noted above, however, only risks associated with
exposures to chemicals in soil are discussed in this document.
2-7
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TABLE 1
CHEMICALS OF POTENTIAL CONCERN DETECTED iN
SOIL SAMPLES COLLECTED FROM THE J-FIELD SOIL OPERABLE UNIT
Compound
Maximum Detected
Concentration*
(mg/kg)
Risk-Based
/Concentration* . .:
(mg/fcg)
Background (mg/kg)
Volatile organic compounds
Acetone'
Benzene*
Carbon disutfide*
Chlorobenzene
Chloroform
1.1 Dichloroethylene*
trans-1 .2 Dichloroethylene
Methyl ethyl ketone
Methylene chloride
Tetrachloroethane*
Tetraehloro-ethylene
Toluene
Trich loroethy lene *
Xylenes*
Semivotatite organic compounds
Benzo(b)fluoranthene*
Benzo(k)fluoranthene"
Bis(2-chtoroethyl) ether*
Diethyl phthalate*
Fluorene*
Hexachlorobe'nzene*
t
Hexachloroethane"
2-Methylnaphthalene*
2-Methylphenol*
4-Methylphenol*
N-Nrtrosodiphenylamine*
Phenol*
Pyrene
2.4.6-Trichloroaniline*
0.02
0.1
0.040
0.1
0.05
0.10
0.17
0.014
0.10
2.5
1.0
0.05
•2.8
0.05
0.66
0.51
0.05
0.145
0.068
2.17
0.59
0.23
0.69
0.715
O.B
0.43
0.652
7.9
200.000
200
200.000
41 .000
940
9.5
18.000
1.000.000
760
29
110
410.000
520
1 .000.000
7.8
78
5.2
1 .000.000
82.000
3.6
410
NAC
100.000
10.000
1.200
.1 .000.000
61.000
170
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND .
. 0.035 - 0.35
0.036 - 0.140
ND
0.041 - 0.072
0.033 - 3.2
ND
ND
ND
ND
ND
ND
ND
0.038 • 0.620
ND
Explosives
Nrtroglycerin*
15.3
NA
ND
2-8
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TABLE 1 (continued)
CHEMICALS OF POTENTIAL CONCERN DETECTED IN
SOIL SAMPLES COLLECTED FROM THE J-FIELD SOIL OPERABLE UNIT
. .;v.;,V:rA'-:?:>s*'Coi»poHnd
inorganic materials
Aluminum*
Antimony*
Arsenic*
Barium*
Beryllium*
Cadmium*
Calcuim
Chromium*
Cobalt*
Cooper*
Cyanide*
Iron*
Lead*
Magnesium*
Maganese
Mercury*
Molybdenum
Nickel*
Potassium*
Selenium*
Silver*
Sodium
Thallium
Vanadium*
Zinc
Maximum Detected
Concentration*
<*ng/kg)
Risk-Based , - . ..:..,:
Concentration* : '•.. '" :- ::. : ' :
(mg/kg)
.••: "••••' .•••:• ••'•••' . •• •;- ' "
22.600
501
1.440
1.580
0,98
50
• 36.000
878
11
4.320
66
•154.000
94.200
3.880
633
22
6.9
76
1.460
2.8
42
521
7.9
167
84.485
1 .000.000
820
3.8
140.000
1.3
1.000 .
e
10.000
120.000
82.000
41.000
610.000
•
^e
10.000
610
10.000
41.000
e
10.000
10.000
_e
160s
14.000
610.000
Background (rug/kg)
2.630-16.900
ND
1.1 - 3.7
9.8 - 202
0.62 - 1.1
0.86 - 1 .4
71 - 1.980
5.3 - 69
1 .5 - 26
3.0 • 33
ND
3.190 - 23.500C
5.5 - 294
63 - 3.920
4.95-1140
0.07
NO
2.7 - 24
96 - 1700
0.44 - 0.50
ND
366 - 653
ND
1 1 - 59
4.9 - 242
ND
Maximum detected concentrations for surface soil samples (O-2 ft in depth). These values were taken from table C-
13 of the Remedial Investigation.
EPA (1995). for 'industrial' soil.
NA = not available
Risk-based concentrations for PCB isomers are based on Aroclor mixtures
Risk-based concentrations for these compounds are not available due to low toxity.
This level is considered to be a reasonable level with which to determine whether a potential exists for adverse
effects to industrial workers due to lead exposures.
A risk-based concentration was not available for the class of thallium compounds, so the value for thallium sulfate
was used instead.
Ecological Chemicals of Potential Concern
Not Detected
2-9
-------
The Human Health RA evaluated contaminant concentrations detected in the samples collected
during the Rl, the toxicity of these contaminants, and the possible human exposure to these contaminants.
Based on this information, conservative estimates of risk were determined following USEPA guidance to
ensure that potential health effects were not underestimated. The Human Health RA consisted of
contaminant identification, exposure assessment, toxicity assessment, and risk characterization. These
RA steps are summarized below.
COPCs were selected for soil in the J-Field SOU, and Table 2 summarizes the COPCs selected
for each pit. Contaminant identification consisted of several screening procedures to select COPCs for
quantitative evaluation. COPCs were selected for use in the RA based on an evaluation of the data, a
comparison of maximum site concentrations to USEPA Region III Risk-Based Concentrations (RBCs), and
for inorganics, a statistical comparison of site and reference concentrations. As shown in Table 2, only
inorganic chemicals were selected1 as COPCs in soil at the J-Field SOU.
The objective of the exposure assessment is to estimate the type and magnitude of potential
exposures to the COPCs that are present at or migrating from the site. Under the current land use
scenario,- exposure pathways evaluated include incidental ingestion and dermal absorption of chemicals
•in surface soil by a demolition worker. The future uses of the J-Field SOU that were considered include
military and industrial uses. Exposure pathways evaluated for the future land use scenario include
incidental ingestion and dermal absorption of chemicals in surface soil by an industrial worker and a
trespasser. The RA addressed the exposure pathways from all media although this decision document
focuses on the risks associated with exposures to surface soil at the J-Field SOU. The risks associated
with exposures to surface water and sediment wiH be addressed in the RI/FS for the remaining areas of
concern at J-Field.
The purpose of the toxicity assessment is to assess the toxicological hazards of COPCs .as a
function of the anticipated routes of exposure. Quantitative indices of toxicity include cancer slope factors
(CSFs) for chemicals exhibiting carcinogenic effects and reference doses (RfDs) for chemicals exhibiting
noncarcinogenic effects. USEPA developed CSFs using conservative assumptions for estimating excess
lifetime cancer risks associated with exposure to potentially carcinogenic chemicals. CSFs, which are
expressed in terms of reciprocal dose (milligram per kilogram per day)"1 or ([mg/kg-day]"1), are multiplied
by the estimated intake of a potential carcinogen, in milligrams/kilogram-day (mg/kg-day) to provide an
upper-bound estimate of the excess lifetime cancer risk associated with exposure at that intake level.
The RfDs have been developed by USEPA to indicate the potential for adverse health effects from
exposure to chemicals exhibiting noncarcinogenic effects. RfDs, expressed in units of mg/kg-day. are
estimates of daily exposure levels for humans, including sensitive individuals, that are likely to be without
an appreciable risk of deleterious effects during a lifetime. RfDs incorporate uncertainty factors that help
ensure that the RfDs will not underestimate the potential for adverse noncarcinogenic effects. Estimated
intakes of chemicals from environmental media in units of mg/kg-day can be compared to the RfD. to
determine whether adverse noncarcinogenic effects could occur.
The purpose of the risk characterization is to relate exposure estimates to toxicity data in order
to estimate potential excess lifetime cancer risks for carcinogens or the potential for adverse effects for
noncarcinogens. Excess lifetime cancer risks, which are determined by multiplying the intake level by the
CSF. are probabilities that are generally expressed in scientific notation (e.g., 1 x10"6 or 1E-06). An excess
lifetime cancer risk of 1x10~6 indicates the probability that an individual has a one in 1 million chance of
developing cancer as a result of site-related exposure to a carcinogen over a 70-year lifetime, under the
specified exposure conditions. USEPA's acceptable risk range for cancer is 1x10"* to 1x10"6, meaning
there is one additional chance in 10,000 (IxlO"4) to one additional chance in one million (1x10~6) that a
person will develop cancer.
Noncarcinogenic effects are expressed as the hazard quotient (HQ). which is the ratio of the
estimated intake of the noncarcinogen to its respective RfD. The hazard index (HI) can be generated by
adding the HQs for all contaminants wrthin a medium and provides a useful reference point for gauging
2-10
-------
TABLE 2
SUMMARY OF THE HUMAN HEALTH CHEMICALS OF POTENTIAL CONCERN
AT THE J-FIELD SOIL OPERABLE UNIT
'.•••• Compound
- ;-:.- -• :,::|M:*r- ^-^ ./'^^.P ;': :^:;:
Inorganics: . .
Antimony
Arsenic
Lead
Zinc
"". '" ""•"•' ' ' ' -Surface SoH
• -fterthlBP -
-
X
X
-
••.;«ou*'BP':::
-
X
X
-
:fV*BP;:--
-
X
X
-
Mustard BP
-
X
X
-
PusitOut
X
X
X
X
X:
Selected as a chemical of potential concern.
Chemical was either not detected or was present at concentrations below its respective
RBC.
2-11
-------
the potential for adverse effects associated with noncarcinogenic chemicals within a single medium. An
HI of less than one indicates that the human population is not likely to experience adverse health effects.
Table 3 and the following discussion summarize risks associated with exposures to surface soil
that were presented in the'RA.
2.6.1.1 Current Land Use. The J-Field Study Area is located in the Edgewood restricted area
of APG. Access to the restricted is strictly controlled and a wide variety of physical security measures are
in place to prevent unauthorized personnel from entering the area.
Under current land use conditions, risks due to ingestion and dermal absorption of chemicals in
surface soil were summed for demolition workers. The cumulative risk due to ingestion and dermal
exposures was within the USEPA risk range of 1 x10~6 to 1 x10"4, while the cumulative hazard index was
below one. Therefore the risk, associated with the current land-use scenario falls within the acceptable
range as defined by USEPA, and adverse effects associated with noncarcinogenic chemicals would not
be likely to occur.
2.6.1.2 Future Land Use. Under future land use conditions, risks were calculated for industrial
workers and trespassers. The risks for an industrial worker due to incidental ingestion and dermal
absorption of chemicals in surface soil was 3x10~4(3 in 10,000), which exceeded USEPAs target risk
range of 1x10"6 to Ix10~4, while the total hazard index was slightly greater than one (1.4). The
carcinogenic risk and hazard index were primarily driven by dermal exposures to arsenic in the Northern
Main Burn Pit soil. In order to interpret these risks, several uncertainties should be addressed. There are
uncertainties associated with the arsenic toxicity criterion (as discussed in the Uncertainties Section of
the human health RA), with the dermal pathway model, with the fact that only one sample was collected
from this source area, and with the fact that.this scenario assumes that future workers would work at the
J-Field SOU on a regular basis.
The total excess lifetime cancer risk for a trespasser due to incidental ingestion and derma!
absorption of chemicals in surface soil was 1x10~4, which is at the high end of USEPA's risk range for
health protectiveness at Superfund sites. The total hazard index for trespassers was less than one.
indicating that adverse noncarcinogenic effects would not be likely to occur as a result of exposures via
contact with chemicals in surface soil. The carcinogenic risk was primarily driven by exposures to arsenic
in the Northern Main Burn Pit surface soil. It should be noted that the risks and hazard indices estimated
for the trespasser are associated with the same uncertainties as listed above for worker exposures, and
in assuming that the same trespassers would actually be present at the J-Field SOU on a regular basis
for 30 years.
2.6.1.3 Exposures to Lead. Lead was detected with maximum concentrations exceeding the
industrial soil screening concentration of 1,000 mg/kg in the Northern Main Burn Pit, the Mustard Burn
Pit, and the Pushout Area. The industrial screening concentration of 1,000 mg/kg is a reasonable level
used to determine the potential for adverse effects to industrial workers. The area with the highest lead
concentrations and the greatest frequency of elevated lead detections was the Pushout Area. It is not
likely that workers would actually frequent the J-Field SOU on a regular basis and trespassers are not
.likely to be adversely affected due to their assumed limited frequency of exposure at the J-Field SOU
2.6.2 Environmental Risks
The Ecological RA was conducted in three phases. Phase 1 included: 1) qualitative and
quantitative biotic surveys; 2) toxicity testing of soil, sediment, surface water, and groundwater; and 3)
identification of ecological COPCs based on Rl data. Phase 2 included: 1) additional toxicity testing: 2)
surveys of biologically mediated soil processes; and 3) residue analyses of biological tissue. Contaminant
uptake models, developed in Phase 2 and refined in Phase 3, were used to predict contaminant doses
to high level ecological receptors. The results of Phase 1 and Phase 2 were used in Phase 3 to evaluate
the risk to ecological receptors. Phase 3 integrated the risk estimates derived from the uptake modeling
2-12
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TABLE 3
SUMMARY OF PATHWAY SPECIFIC AND
CUMULATIVE RISKS ASSOCIATED WITH HUMAN HEALTH
EXPOSURES AT THE J-FIELD SOIL OPERABLE UNIT
Receptof/Palfiw^
Cancer Rtek Non-Cancer
Hazard Index
Current Land-Use Conditions
Demolition Worker
Soil Ingestion
Dermal Absorption
Cumulative Risk
2x10~5 1x10"1
3x1(T5 2X1CT1
• 5xlCT5 3x10"1
.,. . .. ..,.,.:,....:.. ... ..-V-.-.' ...'.•- .. " •:•:• . :-:: •• ,..:•. ::,;,. -,.-.,;. . . -,..-::. -. ,.,,..,.:,.,,,•,,. -...-.-•. • .... ..
Future Land-Use Conditions
Industrial Worker
Soil Ingestion
Dermal Absorption
Cumulative Risk
Trespasser
Soil Ingestion
Dermal Absorption
Cumulative Risk
8x10"5 5x10"1
2x1CT4 9x10"1
3x10'4 1.4
4x10'5 2X1CT1
7x10'5 SxlO'1
1x10'4 0.5
2-13
-------
results with the results of the exposure and effects assessments to characterize ecological risk at the J-
FieldSOU.
The first task of the Ecological RA was to summarize the COPCs by comparing media
concentrations with chemical-specific factors, including background concentrations, regulatory standards,
and screening toxicity values. Other factors considered in the screening process were frequency of
detection, ability to bioaccumulate, importance as a nutrient, and known toxicity.
The first step in the evaluation of chemicals was the background comparison for inorganics, which
involved a statistical comparison of site concentrations and background concentrations for each medium
to identify chemicals occurring at concentrations above background. The Ecological RA for J-Field
indicates a statistical procedure consistent with the Human Health Evaluation Manual (USEPA, 1989c) and
USEPA Region III guidance (USEPA, 1993) was used to identify COPCs. Occasionally insufficient data
were available for a statistical comparison. In these cases, the maximum reported concentration was
compared to the maximum background concentration. Chemicals with maximum concentrations
exceeding the maximum background were retained for further analysis.
All chemicals were then compared to available regulatory standards or benchmark values that
represent medium-specific contaminant concentrations considered protective of biota. The benchmark
values were selected from many sources, including USEPA reports, agency, reports, and the scientific
literature-. All chemicals detected at concentrations exceeding either a regulatory standard or benchmark
value were retained as the final ecological COPCs, regardless of whether or not they were detected at
concentrations above background. Tatlo 4 indicates those chemicals selected as ecological COPCs at
the J-Field SOU, identifies the range of concentrations detected at on site and background locations, and
presents screening concentrations used in the Ecological RA in conjunction with statistical analysis to
identify COPCs. The rational for selecting each chemical as a COPC was also presented in Table 4.
The receptors selected for evaluation at the J-Field SOU were: grasses, maple trees, common
reeds, phytoplankton. zooplankton, golden shiners, leopard frogs, great blue herons. American kestrels.
red-tailed hawks, American robins, tree swallows, mallard ducks, white-tailed deer, muskrats. white-footed
mice, eastern cottontails, and red foxes (Table 5). Potential exposure pathways were reviewed and
selected for quantitative evaluation in the ecological RA by using uptake modeling. The following
complete exposure pathways were evaluated: 1) incidental ingestion of soil or sediment: 2) ingestion of
drinking water; 3) food chain transfer and uptake of COPCs; 4) root uptake in vegetation; and 5) dermal
absorption for terrestrial invertebrates and aquatic biota. The primary exposure route for most wildlife was
food chain uptake. The applied daily doses (ADD) of ecological COPCs for individual receptors were
estimated by modeling the selected exposure routes.
, The biological studies were classified as either exposure assessments or effects assessments.
Exposure assessments characterized the co-occurrence of ecological receptors with the distribution of
ecological COPCs by either: 1) directly measuring COPC concentrations in biological tissues; or 2)
modeling COPC uptake and estimating ADDs. The effects assessments used field studies and laboratory
toxicity testing of site media to identify and quantify actual adverse effects at the J-Field SOU. The
following paragraphs discuss the exposure and effects assessments conducted at the J-Field SOU
Terrestrial vegetation (common reed), terrestrial invertebrates (grasshoppers and crickets), fish
(shiners and top minnows), amphibians (frogs), and small mammals (white-footed mice) were collected
and analyzed for metals. SVOCs, pesticides, and PCBs in the first part of the exposure assessment. In
some cases, tissue concentrations in prey items were estimated using uptake modeling for those COPCs
that were not included in the tissue analysis. ADDs were estimated for species more difficult to collect
(mallard, great blue heron, American robin, tree swallow, American kestrel, red-tailed hawk, muskrat, white-
footed mouse, eastern cottontail, white-tailed deer, and red fox) based on modeling by using exposure
point concentrations (95% upper confidence limit (UCL) of the arithmetic mean or maximum detected
concentration) of COPCs in each medium and species-specific exposure factors, such as body weight.
home range, and diet composition. The potential for adverse effects on the receptor species was
2-14
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TABLE 4
SUMMARY OF THE ECOLOGICAL CHEMICALS OF POTENTIAL CONCERN DETECTED IN SOIL
AT THE J-FIELD SOIL OPERABLE UNIT
1 Analyte
Oraanics:
Acetone
Aroclor 1248
Benzene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
2-Butanone
Carbon disulfide
'Chloroform
1,1-Dichloroethene
Diethy! phthalate
2-Methylnaphthalene
2-Methylphenol
4-Methylphenol
N-Nitrosodiphenylamine
Nitroglycerin
1 , 1 ,2,2-Tetrachloroethane
2.4.6-Tnchloroaniiine
m+p-Xylene
Inorganics:
Aluminum
Arsenic
Barium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Mercury
Nickel
Zinc
Range of Concentrations
(ug/kg)
3
. 19.75
. 6
50
42
6
2
6
6
49
71
75
91
170
5.000
2
20
20
4.240.000
0.11
2.110
0.23
6.95
2
7.470.000
6050
765.000
0.03
3.5
20.200
- 20
- 570
- 100
- 1.250
- 1.250
- 37
- 38
- 50
- 100
- 2,000
- 1.250
- 1.250
- 1,250
- 1.250
- 15.300
- 2.500
- 7,900-
- 50
- 22.600.000
- 1,440.000
- 1.580,000
- 35.500
- 878.000
- 4.320.000
- 154.000,000
- 94.200.000
- 3.880.000
- 3.600
- 84.500
- 17.800.000
Regulatory
Range of Reference Standard/Ecological
Concentrations (ug/kg) Benchmark Values* (ug/kg)
-
25.53 -
'
32 -
29 -
-
-
-
-
36 -
120 -
160 -
160 -
80 -
-
-
-
'
2.630.000 -
249 -
. 9.830 -
570 -
5.290 -
3,000 -
3.190.000 -
5490 -
63.000 -
57 -
1.710 -
4.890 -
29.41
350
150
100
150
210
21u
100
16.900.000
3.740
202.000
1.400
70.800
33,200
23.500.000
294.000
3,920,000
145
24.300
242.000
-
-
-
1.000
1.000
-
-
-
-
-
-
1.000
1.000
-
-
-
-
-
50.000
5.200
440.000
970
1.000
12.500
279,235
15 O^""'
-
58
13.000
48.000
* Regulatory standards.ecological benchmark values reflect screening values presented in J-Field ERA
2-15
-------
TABLE 5
SUMMARY OF THE ECOLOGICAL RECEPTORS FOR THE J-FIELD SOIL OPERABLE UNIT
Receptor
Grasses (/(ndropogon
spp.)
Mapie (Acer spp.)
Common reed
Phytoplankton and
zooplankton
Golden shiner
Leopard frog
Great blue heron
American kestrel
Red-tailed hawk
American robin
Tree swallow
Mallard duck
White-tailed deer
i
Muskrat
White-footed mouse
Eastern cottontail
Red fox
^ Habitat Type
Upland
Upland
Wetlands
Quiet surface
waters
Quiet surface
waters
Quiet surface
waters
Surface waters
and wetlands
Semi-open
grasslands •
Wetlands,
grass-lands,
and forests
Wetlands,
grass-lands,
and forests
Grasslands with
wooded edges
or nearby
woodlots
Wetlands with
nearby
grasslands
Old fields.
grass-lands,
and forests
Surface waters
and wetlands
All upland
habitats
Upland habitats
and marsh
edges
Wetlands,
grass-lands.
and forests
Occurrence at
the J-Field
Pushout Area
Main Pits Area
Southern portion
of J-Field
Marsh
Pond and marsh
Pond and marsh
Marsh edges
Marsh and pond
margins
Marsh and pond
margins
Pushout Area
Main Pit Area
Entire Area
Entire Area
. Entire Area
Pond, marsh,
and Pushout
Area
Entire Area
Marsh and pond
Entire Area
Entire Area
Entire Area
Exposure
Point Media
Soil
Soil
Sediment
Surface water
Surface water
Surface water
.
Surface water
Soil and
surface water
Soil ariu
surface water
Soil and
surface water
Soil and
surface water
Soil, surface
water, and
sediment
Soil and
surface water
Surface water
and sediment
Soil and
surface water
Soil and
surface water
Soil and
surface water
Likely to Visit
Other Areas?a
No
No
No
No '
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
•Likelihood to visit other areas based on size of home range or foraging area.
2-16 .
-------
estimated by comparing the ADD to a contaminant-specific benchmark value representing a no effect
ADD. The result is a ratio called the Environmental Effects Quotient (EEQ).
The effects assessment characterized actual effects on vegetation, soil biota, terrestrial
vertebrates, and aquatic biota using several approaches. The effects assessment for the J-Field SOU
included: 1) qualitative and quantitative surveys of terrestrial and aquatic invertebrate and vertebrate biota
and wetland and upland vegetation; 2) quantitative evaluations of soil invertebrate physiological
parameters, such as enzyme activity and respiration rates; 3) quantitative evaluations of biologically
mediated soil processes, such as litter decomposition and nitrogen mineralization; and 4) toxicity tests
of site soils, sediments, and surface water using a variety of invertebrate, vertebrate, and plant test
organisms. The specific receptors, levels of assessment, and the methods of the effects assessment are
presented in Table 6.
2.6.2.1 Results of Exposure Assessment. The results of the tissue residue studies typically
indicated low levels of COPC uptake by biota. Plant tissues were analyzed for metals, SVOCs, pesticides,
and PCBs. The organic chemicals detected were two SVOCs (2-methylphenol and bis(2-
ethylhexyl)phthalate and one pesticide (beta-BHC). Low levels of several inorganic analytes were
detected, including aluminum, arsenic, and lead. Invertebrate tissues were analyzed for metals. SVOCs.
pesticides, and PCBs. The only organic chemical detected was the pesticide dieldrin. Ten inorganic
compounds were detected including seven heavy metals.
Small mammal tissues were sampled for metals, pesticides, and PCBs. Aroclor-1260. arsenic.
barium, cadmium, chromium, and lead were the chemicals primarily detected in small mammal tissues.
However. Aroclor-1260 was detected in only one of ten small mammal tissue samples. Furthermore, the
inorganic compounds were present at low concentrations and none was detected at concentrations
significantly greater than those collected from reference locations.
2.6.2.2 Results of Effects Assessment. More than 100 bird species were identified during the
vertebrate surveys, suggesting a diverse bird community is either inhabiting or using the J-Field SOU.
Mourning doves. American robins, white-throated sparrows, and song sparrows were some of the most
common species. In addition, ospreys have frequently been observed flying over the J-Field SOU. White-
footed mouse, meadow "o!e, short-tailed shrew, and red fox were the mammal species collected or
observed at the J-Field SOU. Four amphibian species were also collected. None of the bird, mammal.
and amphibian specimens exhibited any external abnormalities (such as lesions or tumors).
A comparison between total macroinvertebrate numbers, bacterial and fungal biomass. and
nematode numbers in soils from the J-Field SOU and'on-site and off-site reference locations indicated a
significant reduction at the J-Field SOU. particularly the Pushout Area. In addition, there was a difference
in the trophic structure of the nematode community at the Pushout Area in comparison to the reference
site. Other significant differences between the Pushout Area and the reference site included lower activity
of several bacterial and fungal nutrient-acquiring enzymes (enzyme activity was significantly and negatively
correlated with the total metal content of the soil), and lower substrate-induced respiration and soil
nitrogen dynamics.
Both lethal and sublethal effects were observed in earthworms and vegetation after exposures to
J-Field SOU soils. Exposures to soils from the Southern Main Burn Pit and the Pushout Area resulted in
nearly 100% mortality in earthworms. In addition, significant earthworm weight loss was detected in soil
mixtures containing >25% site soil from these two areas. Seedling emergence rates of less than or equal
to 2.5% from exposures to soils from the Pushout Area and the Southern Main Burn Pit were observed.
In addition, seedling emergence rates were <75% from other areas of J-Field.
2.6.2.3 Environmental Risk Conclusions. The EEQ risk estimates identified several ecological
COPCs as posing potentially high to extreme risks to wildlife. These risks are associated primarily with
soil levels of aluminum, antimony, arsenic, cadmium, chromium, cyanide, lead, mercury, selenium, and
zinc. The EEOs associated with these COPCs were greater than 100 for at least one modeled ecological
2-17
-------
TABLE 6
SUMMARY OF THE ECOLOGICAL RECEPTORS. ASSESSMENT LEVELS, AND EFFECTS
• ASSESSMENT METHOD FOR THE J-FIELD SOIL OPERABLE UNIT
Ecological
Assessment
Effects Assessment Method
Vegetation
Individual
Population and
community
Soil toxicity tests evaluating seedling
germination rates, seedling growth, and
Quantitative surveys to determine species
diversity and quantify total plant biomass
Soil Invertebrates
Individual
Population and
community
Biologically
mediated soil
processes
Soil toxicity tests evaluating earthworm
survival; quantitative surveys to determine
abundance of soil-dwelling and epigeic
Quantitative surveys to determine species
diversity of macroinvertebrates, abundance
and trophic structure of nematode
communities, and abundance of protozoa;
surveys to determine total and active fungal
and bacterial biomass
Evaluations of soil respiration rates, litter
decomposition rates, extracellular nutrient-
acquiring microbial enzyme activity, and
nitrogen mineralization rates
Terrestrial
Vertebrates
Individual
Population and
community
Qualitative surveys of amphibian and avian
abundance
Evaluation of avian reproductive success with
bird nest boxes
2-18
-------
receptor at the J-Field SOU. However, these results were frequently based on uptake results using the
maximum detected concentrations at the J-Field SOU, which can lead to an overestimation of risk.
The ecological RA concluded that extensive adverse ecological effects are evident at the J-Field
SOU, but are limited to soil biota and vegetation and some of the aquatic components. Based on the
results of the EEQ analyses and the effects assessment studies, where 20 of 32 evaluated parameters
were adversely affected at the J-Field SOU, the ecological RA also concluded that the J-Field SOU poses
a high risk to ecological resources.
The results of 12 of the 15 effects assessments evaluating terrestrial media, biota, and habitats
identified adverse ecological effects to ecological receptors at the J-Field SOU. Moderate to extreme risks
from soil contamination were determined for terrestrial vegetation and terrestrial receptors mainly from
exposures to inorganics. The areas of greatest concern appear to be the Pushout Area and the Main
Burn Pits. The contaminated soils in the Pushout Area may also be the source of contamination and high
risk identified in surface water and sediment along the marsh-Pushout Area boundary. The ecological RA
concluded that the overall ecological risk from contaminated soils at the J-Field SOU is high based on the
high EEOs and the number of effects assessment parameters where adverse effects were identified.
In summary, adverse effects that are ecologically significant on a local scale (J-Field) could be
occurring due to current levels of contamination at the J-Field SOU. In addition, these levels of
contamination could pose adverse effects to wide-ranging biota that are not restricted to the -J-Field
boundary, including migratory waterfowl and top-level avian predators (in particular, red-tailed hawk and
American kestrel).
2.7 REMEDIATION OF THE J-FIELD SOIL OPERABLE UNIT
The Army used the conclusions from the Rl. the Remedial Action Objectives (RAO) listed in the
FS, and ARARs to set clean-up objectives for soil contamination at the J-Field SOU. The clean-up
objectives for soil are to reduce exposure of human health and environmental receptors to surface soil
contamination in the three source areas: the Northern Main Burn Pit. the Southern Main Burn Pit. and the
Pushout Area. Part of the reduction of exposure pathways is the reduction or prevention of contaminant
migration through surface runoff and downward leaching through these areas. The Mustard Burn Pit and
the VX Burn Pit. now filled, are located in the Pushout Area. It is anticipated that contaminated surface
soil found in these filled pits will be addressed through remediation of the Pushout Area. Actual or
threatened releases of hazardous substances from the surface soil, if not addressed by implementing the
response action selected in the ROD, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
2.7.1 Description of the Alternatives
2.7.1.1 Alternative 1: No Action. The No Action alternative does not include any remedial
actions to contain, remove, or treat the soil at the J-Field SOU. Evaluation of the No Action alternative
provides a baseline against which to measure other remedial alternatives. Institutional control measures
including access restriction, ownership and use or deed restrictions, and monitoring would remain in effect
as part of this alternative under the assumption of continued land ownership by the U. S. Army.
The following major ARARs are cited as part of Alternative 1:
Contaminated soil is left in place; therefore, RCRA closure and post-closure requirements
specified by Code of Maryland Regulations (COMAR) (COMAR 26.13.05.06 and
26.13.05.07) apply. The No Action alternative does not meet closure requirements which
mandate that measures be taken to prevent the migration of contaminants'.
The costs for Alternative 1 are as follows:
2-19
-------
• Capital costs: $0
Operations and Maintenance (O&M) cost: $10,000/year
Net Present Worth: $153,725 for 30 years
There is no implementation time required for this alternative because the main components of this
alternative are currently in place.
2.7.1.2 Alternative 2: In-Situ Containment and Limited Disposal. This alternative involves the
excavation of approximately 425 cubic yards of soil from the Northern and Southern Main Burn Pits and
1,200 cubic yards of soil from the Pushout Area. This estimate is based on removing the contaminated
soil to below 1,000 mg/kg for lead, 328 mg/kg for arsenic, and less than 25 mg/kg for PCBs. The
excavated soil would be treated and disposed of at an off-site facility. The in-situ containment portion of
this alternative includes the placement of a PSB over the Northern arid Southern Main Burn Pits and
Pushout Area. Erosion control measures would also be implemented at the J-Field SOU and along the
shoreline. While the erosion of the shoreline does not pose an imminent threat from contaminated areas
of J-Field, by combining this action with the J-Field SOU remedial action, the erosion threat is reduced
and the natural resources are preserved. The major components of Alternative 2 are described below
UXO screening and site preparation activities will be conducted prior to the initiation of
any remedial actions. The UXO clearance will entail visually surveying the J-Field SOU
and screening approximately 3,000 feet of shoreline. Site preparation will entail the
clearance of vegetation and the construction of access roads. The UXO screening and
site preparation activities will be conducted in accordance with the Noise Control Act (42
USC 4901 et seq.) and the Occupational Safety and Health Administration (OSHA)
Standards (29 CFR 1910.95(g)).
The soil will be excavated from the Northern and Southern Main Burn Pits and Pushout
Area in accordance with the Toxic Substance Control Act (TSCA) Section 6(e). the
Maryland Nonpoint Source Pollution Control Laws (EN Sections 4-201 et seq. and
COMAR 26.09.05). the Nontidal Wetlands Protection Act, Annotated Code of Maryland
(NR Sections 8-1201 et seq. and COMAR 08.05.04).
The excavated soil will be transported, treated, and disposed of at an off-site facility in
accordance with the Maryland Air Quality Control Act (COMAR 26.11.01, .03 and .06). the
Maryland Landfill Siting Law (COMAR 26.04.07), the Maryland Storage, Treatment, or
Disposal Requirements (COMAR 26.13.05). and the Hazardous Material Transportation
Act (49 CFR Parts 172-179). Lead and arsenic will be stabilized prior to disposal. PCB
levels above 50 mg/kg will be drummed for incineration; below 50 mg/kg will be stabilized
prior to disposal.
A PSB. underlain by a geotextile membrane and including a barrier to burrowing animals.
will be placed over the Northern and Southern Main Burn Pits in accordance with all
applicable regulations including the Maryland Nonpoint Source Pollution Control Laws
(COMAR 26.09.05), and the Nontidal Wetlands Protection Area (COMAR 08.05.04).
• Scrap metal collected during the excavation will be decontaminated and stored for
recycling by the Defense Reutilization and Management Office, or disposed off site at an
appropriate landfill.
Performance monitoring of the PSB would be consistent with the closure and post closure
requirements (COMAR 26.13.05, .06, and .07, and COMAR 26.04.07.21 and .22) to assure
that PSB requirements are maintained and human health and the environment are
protected.
2-20
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This alternative meets clean-up objectives to reduce exposure of human health and environmental
receptors to surface soil contamination in the source areas and minimizes the potential for contaminant
migration through downward leaching and surface runoff through these areas.
The costs for Alternative 2 are as follows:
Capital costs: $2.347,000
O&M costs: $10,000/year
Net Present Worth (30 years): $2.769,000
This alternative is expected to take three months to implement.
2.7.1.3 Alternative 3: Removal and Short Term Storage. This alternative consists of the removal
of approximately 16,000 cubic yards of contaminated soil from the J-Field SOU. The volume of soil to be
excavated is based on the removal of soils to levels that are protective of human health and 'the
environment. A storage facility meeting the design requirements of a RCRA waste pile storage unit would
be constructed adjacent to the J-Field SOU at the Prototype Building. Excavated soil would be
transported by truck from the work area to the storage location and stored for approximately five years.
at which time the soil would be sent off-site for treatment and disposal unless alternate disposal
technology is available at that time. The major components of this alternative are described below.
UXO screening and site preparation activities will be conducted prior to the initiation of
any remedial actions. The UXO clearance will entail screening approximately 218.000
square feet of soil in the work zone to a .depth of four feet. Site preparation activities will
involve the clearance of vegetative areas and construction of access roads in the area of
.the J-Field SOU where remedial actions will occur. The UXO screening and site
preparation activities will be conducted in accordance with the Noise Control Act. as
amended the Noise Pollution and Abatement Act (42 USC 4901 et seq.) and the OSHA
Standards (29 CFR 1910.95(g)).
• The soil will be excavateu from the J-Field SOU in accordance with the TSCA. the
Maryland Nonpoint Source Pollution Control Laws (EN Sections 4-201 et seq. and
COMAR 26.09.05), the .Non-tidal Wetlands Protection Act. Annotated Code of Maryland
(NR Sections 8-1201 et sequence and COMAR 08.05.04). the Noise Control Act. as
amended the Noise Pollution and Abatement Act (42 USC 4901 et seq.). and the OSHA
Standards (29 CFR 1910.95(g)).
A storage facility, located in the vicinity of the Prototype Building would be constructed
using fabric covered steel arch trusses. Design features (e.g.. leachate collections
system, concrete pad. layer of impermeable clay, concrete barriers, and VOC air scrubber
system) would be implemented to meet RCRA regulations pertaining to waste piles. The
storage facility would be constructed and the contaminated soil stored in accordance with
the applicable regulations pertaining to storage of material (COMAR 26.13.02, COMAR
26.13.05, and 40 CFR Part 264).
The excavated soil will be transported to, treated, and disposed of at an off-site facility in
accordance with the Maryland Air Quality Control Act (COMAR 26.11.01. COMAR
26.11.03, and COMAR 26.11.06). the Maryland Landfill Siting Law (COMAR 26.04.07), the
Maryland treatment and disposal requirements (COMAR 26.13.05), and the Hazardous
Material Transportation Act (49 CFR Parts 172-179), unless alternate disposal technology
is available, in which case it will be evaluated in comparison to off-site disposal and
subjected to the same requirements.
2-21
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• Performance monitoring would be conducted to ensure that the excavated soil is being
stored in accordance with all applicable requirements.
This alternative meets clean-up objectives to reduce exposure of human health and environmental
receptors to surficial soil contamination in the source area and minimizes the potential for contaminant
migration and downward leaching through these areas.
The costs for Alternative 3 are as follows:
Capital costs: $4,132,000
O&M costs: $29,000
Net Present Worth (30 years): $4,578,000
• This alternative is expected to take three months to implement.
2.7.1.4 Alternative 4: Removal, On-Site Treatment, and Limited Disposal. This alternative
involves the removal of approximately 16,000 cubic yards of contaminated soils to reduce metals and
organics soil contaminant concentrations to levels that are protective of human health and the
environment. Soil would be removed from the J-Field SOU using standard excavation in construction
equipment. The excavated soil would be temporarily stored near J-Field, treated on-site using a soil
washing/leaching treatment system and returned as clean fill to the source location. Approximately 500
cubic yards of PCB contaminated soil would be excavated from the Southern Main Burn Pit and
transported off-site for treatment and disposal. The major components of this remedial alternative are
described below.
UXO screening and site preparation activities will be conducted prior to the initiation of
any remedial actions. The UXO screening will entail screening approximately 218.000
square feet of soil in the work zone to a depth of four feet. Site preparation activities will
involve the clearance of vegetative areas and construction of access roads in the area of
the J-Field SOU where remedial actions will occur. The UXO screening and site
preparation activities will be conducted in accordance with the Noise Control Act. as
. amended the Noise Pollution and Abatement Act (42 USC 4901 et seq.) and the OSHA
Standards (29 CFR 1910.95(g)).
Excavation of the hot spot areas of lead, arsenic, and PCB contaminated soil from the J-
Field SOU would be accomplished using hand excavation. After excavation, soil would
be transported to the temporary staging area using standard earth moving equipment.
Excavated soil awaiting treatment would be temporarily stockpiled on a bermed and
drained concrete or asphalt pad and covered with plastic laminate to control dust and
vapor emissions. The soil would be excavated, transported for stockpiling, and stockpiled
in accordance with all applicable regulations including the Maryland Nonpoint Source
Pollution Control Laws (COMAR 26.09.05), the Maryland Air Quality Control Act (COMAR
26.11.01). and the Maryland Requirements for Hazardous Waste (COMAR 26.13.02).
A temporary or portable soil washing/leaching treatment system would be constructed on
site to treat the excavated soils, with the exception of approximately 500 cubic yards of
soil containing PCBs at concentrations in excess of the USEPA Region III industrial
carcinogenic RBC of 0.74 mg/kg. The soil washing/leaching treatment system would be
used to treat metals and SVOC contaminated soils by: 1) physically separating metallic
fragments: 2) physically separating soil into various size fractions (course sand and
gravel; fine sand; and silt and clay); 3) chemically removing metals bound to sand. silt.
and clay: and 4) precipitating metals out of the wash for recovery. The contaminated
soils will be treated in accordance with all applicable regulations including the Maryland
2-22
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Requirements for Hazardous Waste (COMAR 26.13.02), the Maryland Requirements for
emissions from a treatment system (COMAR 26.11.06.06), the Maryland Requirements
for waste treatment (COMAR 26.13.05), and the TSCA. Wastewater generated during soil
treatment would be disposed off-site in accordance with all applicable regulations.
The treated soil product would be placed in a pile located adjacent to the treatment plant.
The treated soil would be sampled and analyzed to ensure treatment goals have been
met. Once the excavated and treatment activities were complete, the excavated area
would be backfilled with the treated soil. Additional clean soil would be obtained from an
off site source to be used as backfill as necessary. The excavated area would be
regraded, covered with top soil, and seeded. The backfilling of treated soil will be
conducted in accordance with all applicable regulations including the Maryland
Requirements pertaining to the treatment and disposal of hazardous wastes (COMAR
26.13.03 and COMAR 26.13.05).
• The approximate 500 cubic yards of PCB contaminated soil from the Southern Main Burn
Pit would require off-site treatment or disposal if the PCB concentrations exceed 0.74
mg/kg. The PCB contaminated soil would be disposed of in accordance with all
applicable regulations including the Maryland Air Quality Act (COMAR 26.11.01, COMAR
26.11.03 and COMAR 26.11.06). the Maryland Requirements for treatment and disposal
(COMAR 26.13.05) and the Hazardous Materials Transportation Act (49 CFR Pans 172-
179).
• Performance monitoring would be conducted to ensure that the soil is treated in
accordance with the ARARs.
This alternative meets clean-up objectives to reduce exposure of human health and environmental
receptors to surfidial soil contamination in the source area and minimizes the potential for contaminant
migration and downward leaching through these areas.
The costs for Alternative 4 are as follows:
Capital costs: 511.089.000
O&M costs: $0
Net Present Worth (30 Years): S11.089.000
This alternative is expected to take eight months to implement.
2.7.1.5 Alternative 5: Removal, Off-Site Treatment, and Disposal. This alternative would involve
excavation, staging, and characterization of soils in the same manner as described for Alternative 4:
however, all soil excavated from the J-Field SOU would be shipped off-site for treatment and disposal.
The excavated area would be backfilled with clean soil from an off-site source. Metals contaminated soil
would be shipped to a RCRA Subtitle C landfill for stabilization and disposal. Similar to the procedure in
Alternative 4. PCB contaminated soil would be shipped to a chemical waste landfill or a TSCA approved
incinerator. Metal scrap and remediation derived waste would be disposed of in the same manner
described in Alternative 2. The major components of this remedial alternative are described below.
• UXO screening and site preparation activities will be conducted prior to the initiation of
any remedial actions. The UXO screening will entail screening approximately 218.000
square feet of soil in the work zone to a depth of four feet. Site preparation activities will
involve the clearance of vegetative areas and construction of access roads in the area of
the Northern Main Burn Pits, where remedial actions will occur. The UXO screening and
site preparation activities will be conducted in accordance with the Noise Control Act. as
2-23
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amended the Noise Pollution and Abatement Act (42 USC 4901 et. seq.) and the OSHA
Standards (29 CFR 1910.95(g)).
• Excavation and transport of the soil from the J-Field SOU would be accomplished using
standard earth moving equipment. After excavation, soil would be placed in trucks and
transported to a temporary staging area. The soil would be temporarily stockpiled on a
bermed and drained concrete or asphalt pad. The soil, covered with plastic laminate to
control dust and vapor emissions, would be stored until it would be loaded into trucks
and transported off-site for disposal. The contaminated soil would be excavated and
temporarily stockpiled in accordance with Maryland Nonpoint Source Pollution Control
Laws (COMAR 26.09.05), the Maryland Air Quality Control Act (COMAR 26.11.01). and the
Maryland Requirements for hazardous waste (COMAR 26.13.02).
• The soil excavated from the Northern and Southern Main Burn Pits that required off-site
treatment or disposal would be loaded into trucks and transported off-site. The soil would
be loaded, transported, and treated or disposed in accordance with all applicable
regulations including the'Maryland Air Quality Control Act (COMAR 26.11.01, COMAR
26.11.03. and COMAR 26.11.06), the Maryland Requirements for treatment and disposal
(COMAR 26.13.05), and the Hazardous Materials Transportation Act (49 CFR Parts 172-
179).
Monitoring would be conducted to ensure that all of the contaminated soil that poses a
risk to human health or the environment would be excavated and treated or disposed off-
site.
This alternative meets clean-up-objectives to reduce exposure of human health and environmental
receptors to surficial soil contamination in the source area and minimizes the potential for contaminant
migration and downward leaching through these areas.
The costs for Alternative 5 are as follows:
. Capitalcosts: $10.542.000
O&M costs: $0
Net Present Worth: $10.542.000
This alternative is expected to take four months to implement.
2.7.2 Summary of the Comparative Analysis of Alternatives
The remedial alternatives presented in Section 2.7.1 were evaluated in accordance with the
regulatory requirements of CERCLA using the nine criterion specified by USEPA (Table 7). This section
and Table 8 summarize the relative performance of each remedial alternative with respect to seven of the
nine CERCLA evaluation criteria. The State concurs with the selected alternative. The public supported
the selected alternative as well, and their input is described in the Responsiveness Summary.
2.7.2.1 Threshold Criteria.
• Overall Protection of Human Health and the Environment. Four of the five treatment
alternatives involve soil excavation and treatment or disposal facility to provide adequate
protection of human health and the environment by reducing contaminant concentrations
or eliminating potential exposure pathways. Alternatives 2. 4, and 5 (In-situ Containment
and Limited Disposal; Removal followed by On-site Treatment and Limited Disposal: and
Removal followed by Off-site Treatment and Disposal) offer long term protection of human
2-24
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TABLE 7
USEPA EVALUATION CRITERIA FOR REMEDIATION ALTERNATIVES
Overall Protection of Human Health and
the Environment addresses whether a
cleanup method provides adequate
protection to human health and the
environment and describes how risks
presented by each pathway are eliminated.
reduced, or controlled through treatment,
engineering controls, or institutional controls.
2. Compliance with ARARs addresses
whether a cleanup method will meet all
applicable or relevant and appropriate
requirements (federal and state
environmental requirements. 7.
3. Long-Term Effectiveness and Performance
is the ability of a cleanup method to
maintain reliable protection of human health 8.
and the environment over time, after the
action is completed.
Short-Term Effectiveness addresses
the period of time needed to complete
the cleanup, and any adverse impacts
on human health and the environment
that may occur during the construction
and operation period.
Implementabilrty is the technical and
administrative feasibility of a cleanup
method, including the availability of
materials and services by the method.
Cost includes the estimated capital
and operation and maintenance costs
of each cleanup method.
State Acceptance indicates whether
the State of Maryland agrees with the
preferred cleanup method.
4. Reduction of Toxicity, Mobility, or Volume
Through Treatment is the anticipated ability
of a cleanup method to reduce the toxicity,
mobility, or volume of the hazardous
substances present a the site through
treatment.
9. Community Acceptance indicates
whether concerns are addressed by
the cleanup method, and whether the
community has a preference for a
cleanup method. Public comment is
an important part of the final decision.
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TABLE. 8
COMPARISON OF REMEDIAL ACTION ALTERNATIVES FOR THE J-FIELD SOIL OPERABLE UNIT
Remedial
Alternative
Overall Protection
of Human Health
and the
Environment
Compliance
with ARARs
Long-Term
Effectiveness and
Performance
Reduction of
Toxicily. Mobility,
and Volume
Short-Term
Effectiveness
Implemenlability
Cost
State
Acceptance
Public
Acceptance
Alternative 2
Alternative 1 In-Silu Containment
No Action and Limited Disposal
O •
O •
O • .
o 9
9 9
• •
$153,725 $2,769,000
O •
o •
Alternative 3
Removal and
Short-Term
Storage
^\
•
^
9
O
•
$4.578,000
•
O
Alternative^
Removal, On-Site
Treatment, and
Limited Disposal
•
•
•
•
O
^\
$11.089.000
•
9
Alternative 5
Removal, Off-Site
Treatment, and
Limited Disposal
9'
•
•
9
O
•
$10,542,000
•
^\
ho
ro
O)
vv - Does nol meet Criteria
- Paitially meets Criteria
- Meets Ciileria
-------
hearth and the environment. This is achieved through removal of the contaminated soil,
in Alternatives 4 and 5, or partial removal and isolation of the remaining soil by means of
the PSB in Alternative 2. Alternative 3 (Removal and Short Term Storage) removes the
soil, but stores it on-site for a period of five years, making it less effective as a long term
remedy. Alternative 1 (No Action) is not protective of human health and the environment.
even though monitoring and institutional controls are included as part of the alternative.
Achievement of ARARs. All of the alternatives will meet ARARs, except Alternative 1 (No
Action). Each of the four remedial alternatives that involve removal and treatment or
disposal of contaminated soil is capable of meeting ARARs and to be considered (TBC)
requirements. The quality of nearby surface water will be protected by proper run -off
control and implementation of erosion control measures in Alternative 2. The emissions
of participates during construction activities will also be minimized with appropriate
engineering controls. Components of Alternatives 2, 4, and 5 will also involve the use of
measures to control the moisture content of earthen materials that are removed and
replaced which minimizes the amount of dust generated during remedial activities. The
RCRA storage permits would be met as part of Alternative 3. For Alternatives 2, 3, 4. and
5. soils deemed hazardous by RCRA standards would be transported and disposed off-
site in accordance with all RCRA, Department of Transportation (DOT) hazardous
materials, and State pre-transport and transportation related requirements. In addition.
PCB-contaminated soils would require management as TSCA waste.
2.7.2.2 Primary Balancing Criteria.
Long Term Effectiveness. Alternative 3 is not considered a long term remedy because
the excavated soil is stored on site for five years. Alternatives 4 and 5 would provide a
permanent solution and long term protection because both alternatives involve removing
and treating all of the soil containing contaminant concentrations above levels that are
protective of human health and the environment. Alternative 2 also provides long term
protection by excavating soil with high concentrations of arsenic, lead, and PCBs and
covering the remaining soil with a PSB. The PSB is constructed to further reduce
potential exposure to environmental receptors, thus providing virtually the same degree
of protection to human health and the environment as Alternatives 4 and 5. Alternative
2 is also consistent with any future anticipated remedial action that may occur at J-Field.
Removal of the PSB can be easily accomplished and it can be used as backfill should
future excavation be deemed necessary.
Performance monitoring would be a component of each of the remedial alternatives to
assure that remedial design parameters are maintained and that risk to human health and
environmental receptors is reduced.
• Reduction in Toxicitv. Mobility, or Volume of Contaminants. Alternatives 2. 4. and 5
reduce the contaminant toxicity and mobility in a relatively similar manner. The volume
of soil required for excavation in Alternative 2 is significantly less than that in Alternatives
4 and 5; however, the in-situ containment component of Alternative 2 reduces risks to
human health and the environment to the same extent as Alternatives 4 and 5.
Alternative 3 does not include a treatment component so contaminant toxicity and volume
would not be reduced. Alternative 1 does not reduce the toxicity. mobility, or volume of
contaminated soil.
Short Term Effectiveness. Alternative 1 has few short term effects because public access
to the J-Field SOU is currently restricted and monitoring activities are currently underway.
Alternative 1 does not remove risks, nor does it introduce new ones. Alternatives 2. 3. 4.
and 5 have the potential for increased short term effects to workers, the community, and
the environment due to construction of the temporary staging areas: dust generation:
2-27
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exposure to potentially contaminated soil during construction, excavation, loading and
transport activities; and potential encounters with UXO. Compared to Alternatives 3. 4.
and 5, which have severe and long-duration adverse effects, Alternative 2 has less
potential for short term effects because the amount of soil requiring excavation and
disposal is significantly less. Alternative 2 would also provide the highest level of
protection quickest because it involves limited removal of contaminated soil followed by
isolation of remaining contaminated soil with a PSB. Alternative 3 would also involve on-
site storage of soil from the J-Field SOU, therefore creating an added increase in the
potential for short term effects. In Alternatives 2-5, the potential for short term effects
would be minimized through the use of protective mitigative measures and engineering
controls, but the additional human health risks associated with the implementation of the
alternatives and ecological damage is measurable in Alternative 2 and significant in
Alternatives 3, 4, and 5. The short term effects associated with the transport of the soil
would be greatest for Alternative 5 due to the increased volume of contaminated soil
requiring transport off-site for treatment and disposal.
Implementabilitv. Each component of the five remedial alternatives can be implemented
with' proven technologies that have been used extensively to remediate soil at similar
facilities across the country. The labor, equipment and procedures required as part of
each of the remedial alternatives are readily available. As with all of the remedial
alternatives, the presence of UXO may delay implementation. The soil washing/leaching
treatment technology, a component of Alternative 4, has been used at several NPL and
RCRA corrective action sites and would not require extensive research and development
to refine the treatment technology. Alternative 4 would, however, require a pilot scale
study to acquire site specific information pertaining to the use of the soil washing/leaching
technology at the J-Field SOU
The implementation of Alternative 2. 3. 4. and 5 would not adversely affect the
performance of any future remedial actions that might be required at the J-Field SOU
Cost. The costs of the different alternatives are given in Table 8. Alternative 2 is the least
costly alternative which meets all ARARs and is protective of human health and the
environment. Therefore, it is the most cost effective remedy. The estimated capital. O&M.
and net present worth costs for the selected remedial alternative are summarized in Table
9.
2.7.2.3 Modifying Criteria.
State Acceptance. The State concurs with the selected alternative.
• Public Acceptance. The public supported the selected alternative as well, and their input
is described in the Responsiveness Summary.
2.7.3 Selected Remedy
The selected remedy to clean up soil contamination at the J-Field SOU is Alternative 2. In-Situ
Containment and Limited Disposal, using soil clean-up objectives of 1000 mg/kg for lead. 328 mg/kg for
arsenic and 25 mg/kg for PCB. Alternative 2 is highly protective of human health and the environment:
complies with all ARARs; has a high level of long term effectiveness and permanence; reduces the toxicity.
mobility, and volume of contamination; has a high level of short term effectiveness; is expected to be
easily implementable: and is relatively cost-effective. Alternative 2 provides the best balance of features
in that a minimal amount of soil is excavated that requires off site disposal, yet the placement of the PSB
reduces risk to human health and the environment to the same extent as Alternatives 4 and 5 The
construction of the PSB reduces the risk to the environment without requiring excavation of an additional
14.000 cubic yards of soil. As part of Alternative 2. erosion control features will be constructed along the
2-28
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TABLE 9
COST ESTIMATE FOR ALTERNATIVE 2 IN APRIL 1996 DOLLARS
Cost (S t.OOOJ
Activity
Subcontract and - '• ' Contractor *
Other Direct Costs ' ':. Unloaded
!i-2c: costs
.-.epair. resurface existing ,-oac iO
UXO screening 70
O'szr and Gr-jb . 15
Excavate.'drurn, stage soil i?C3) !.- 12.5
Exca'/ate-'drum/stage soil (metals) 5.5 ^9.5
Cii-siis disposal, soil (PCS) 30
Off-site disposal, soil (metals) 739.3
Off-site disposal, remediation-derived waste 20
Sampling and analysis • 20 . •
Landscape axcavated area 5 8
Install 2-ri earth cover 332 J7.5
Site stakeout and control 15
Sediment control plans and specs • 5
Perimeter dike with flood protection -6 17
Remedial action professional labor 34
Remedial design _ 50
Shoreline stabilization 73.4 ^5.5
Contractor general conditions" 125
30-year operation and maintenance 50
Contractor unloaded cost* 445
Contractor loaded cost3
Indirect ;ost5
Contractor unloaded and overhead 779
Contractor subtotal cos: . 2173
Fee (3%) 1 7J
Total contractor cost 23-47
Other
Contingencies (10?4) 235
Project management (3%) 138
Total project cost 2759
Loaded costs = subcontract and other direct costs;
unloaded = contractor costs, less overhead.
ror this estimate. \Cr Kaiser Engineers. Inc.. included contractor general conditions under direc
costs.
2-29
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Chesapeake Bay shoreline (Figure 4). While the erosion of the shoreline does not pose an imminent
threat from contaminated areas of J-Field, by combining this action with the J-field SOU remedial action,
the erosion threat is reduced and the natural resources are preserved.
The costs for Alternative 2 are summarized in Table 9.
The goal of this remedial action is to reduce the potential for adverse effects to human health and
the environment. Based on information obtained during the Rl and on a careful analysis of all remedial
alternatives, it is believed that the selected remedy will achieve this goal.
The estimated net present worth of Alternative 2 is S2.769.000. The estimated time to implement
this alternative is three months.
2.7.4 Statutory Determinations
The selected remedy discussed in Section 2.7.3 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 to the maximum extent
practicable.
2.7.4.1 Protection of Human Health and the Environment. The selected remedy. Alternative
2. will reduce potential risks to human health and the environment that are currently being posed resulting
from contaminants in the soil at the J-Field SOU. The remedial alternative .involves the excavation and
off-site treatment or disposal of soil containing elevated levels of lead, arsenic, and PCB followed by
construction of a PSB. Once the PSB has been constructed, no adverse effects are anticipated to
develop in humans, animals, or vegetation as a result of the J-Field SOU. The estimated time required
to implement this alternative is three months, assuming unforeseen delays due to the presence of UXO
do not develop. The adverse short term effects associated with this alternative will be minimized to the
maximum extent practical through the use of protective mitigative measures and engineering controls.
These measures include UXO clearance, sediment and erosion control, control of stormwater runoff, noise
control, dust controls, and spill response plans. Performance monitoring will be conducted to assure that
the remedial measures are conducted and maintained in a manner protective of human health and the
environment.
2.7.4.2 Compliance with ARARs. The selected remedy .will comply with all chemical, location,
and action specific ARARs. The UXO screening, site preparation, excavation, off-site transport and
treatment or disposal, and construction and maintenance of the PSB will be conducted with appropriate
engineering controls to minimize the release of pollutants to air, land, or water. The remedy will be
conducted in accordance with the ARARs presented in Section 2.7.1.2 and below.
Chemical Specific ARARs
The TSCA (15 U.S. Code 2605(e)).
The Federal Regulation 40 CFR, Part 761.125(3)(v).
The Federal and State Requirements pertaining to the use and management of
containers (40 CFR, Part 264. Subpart I. and COMAR 26.13.05.09) (applicable).
2-30
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Gunpo-wder
River
VIEWING BUNKER
PROTOTYPE BUILDING
VX PIT (FILLED)
1L.
PUSHOUT AREA
(ESTIMATED)
MUSTARD PIT (FILLED)
HIGH EXPLOSIVE
DEMOLITION GROUND
C/iesctpeafce
B n. y
LEGEND:
500
1000
I
N
BOUNDARIES
BURIED PITS
EXCAVATED AREA WITH
IN-SITU CONTAINMENT
EROSION CONTROL MEASURE
USING RIPRAP
PONDS
MARSH
SCALE
FEET
DEPARTMENT OF THE ARMY
US Army Corps of Engineers
CONTRACT NO. DACA31-95-0-0063
* ICF KAISER
PKPMXD Oli CST
1MEBEAU
BME: 09/04/98
667O4
66704CON
FIGURE 4
ABERDEEN PROWIG GROUJC
LOCATION OF IM-SITU
CONTAINMENT AREA AND
SHORELINE CONTAINMENT,
ALTERNATIVE 2
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The Solid Waste Disposal Act, as amended (42 USC 6921)
- * The Federal Requirements pertaining to waste characterization (40 CFR, Part 261,
Subparts C and D) (applicable).
Maryland standards concerning defining a hazardous waste (COMAR 26.13.02)
(applicable).
Maryland Air Quality Regulations (COMAR 26.11.01 - 26.11.02) that apply to
general or toxic process emissions and construction activities which generate
particulates (applicable).
Location Specific ARARs
Chesapeake Bay Critical Area Protection Program (NR 8-1801 et. seq. and
COMAR 27) to protect the Bay and criteria for development in the Bay area
(applicable).
Action Specific ARARs
- . Maryland Non-Point Source Pollution Control Laws (Section 4-101) apply for any
construction activities including soil movement, grading, transporting, or otherwise
disturbing land (applicable).
Maryland Nontidal Wetlands Regulations (COMAR 08.05.04) .apply to any
excavation, dredging, or dumping of soil in a nontidal wetland area (applicable).
Maryland Transportation and Disposal Standards (COMAR 26.13.03 and 26.13.04)
which apply to off-site shipment of contaminated material (applicable).
Maryland Landfill Standards (COMAR 26.13.05) which apply to disposal of
material (applicable).
Endangered Species Act (16 USC 1531 -1543, 50 CFR 17.402, 40 CFR 6.302(h))
(applicable).
Bald and Golden Eagle Protection (16 USC 668-668d) which apply if any remedial
activities would disturb the habitat of the Bald Eagle (applicable).
Floodplain Management (EO 11988, 40 CFR, Part 6) would apply because the
site is within the 100 year floodplain (applicable).
Protection of Wetlands (EO 11990, 40 CFR, Part 6) would apply because
wetlands exist in the area (applicable).
Noise Control Act, as amended the Noise Pollution and Abatement Act (42 USC
4909) would apply because heavy equipment will be used (applicable).
OSHA Standards (29 CFR 1910) must be followed during all remedial activities
(applicable).
2.7.4.3 Cost-effectiveness. The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its cost (the net present worth is $2,769,000).
Of the five remedial action alternatives, the selected remedy is more cost-effective than the other
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alternatives. The selected alternative provides the best balance of features that offer overall protection
to human health and the environment.
2.7.4.4 Utilization of Permanent Solutions to the Maximum Extent Practicable. The selected
alternative reduces the toxicity, mobility, and volume of contaminants because contaminated soil would
be excavated and a PSB would be constructed to further minimize the potential risks to human health and
the environment.
2.7.4.5 Preference for Treatment as a Principal Element. The statutory preference for treatment
or resource recovery is satisfied by using the selected alternative because the principal element of the
remedial technology is to permanently and significantly reduce the toxicity. mobility, or volume of
hazardous substances.
2.8. DOCUMENTATION OF SIGNIFICANT CHANGES
The following changes have occurred since the publication of the Proposed Plan. The arsenic
clean-up level of 328 mg/kg is less than the concentration associated with a 1 x 10~4 cancer risk level for
worker exposures (i.e.. 380 mg/kg). The clean-up level is also significantly lower than the noncarcinogenic
protective concentration for worker exposures (i.e., 610 mg/kg). Therefore, it would be appropriate to use
the 328 mg/kg concentration as a clean-up, level, since it is within the acceptable risk range of 1 x 10"6
to 1 x 10 for health protectiveness at Superfund Sites and much lower than the level that could be
associated with adverse noncarcinogenic effects to workers.
The PCS clean-up level has been adjusted to 25 mg/kg. That standard is the clean-up level
designated by 40 CFR 761.125(3)(v) for PCB spills in restricted areas.
The name of the Area addressed by this remedial action has been changed from the Former Toxic
Burn Pits to the J-Field Soil Operable Unit. This was done for clarification. The SOU consists of two main
burn pits (the Northern Main Burn Pit and Southern Main Burn Pit). It also includes the Pushout Area,
which consists of the VX Burn Pit, the Mustard Burn Pit, and the Liquid Smoke Disposal Pit.
The additional excavation of lead in the Pushout Area has been added since the Proposed Plan
was published. This action was added as a further measure to reduce risks to human health and the
environment. Lead will be excavated to levels below 1,000 mg/kg which is generally accepted as the
industrial screening level.
2.9 SUMMARY OF PERFORMANCE STANDARDS
Excavation in the Northern Main Burn Pit and Pushout Area will remove lead to levels
below the industrial screening level of 1000 mg/kg, which is a reasonable level used to
determine the potential for adverse effects to industrial workers.
Excavation in the Northern Main Burn Pits will remove arsenic contamination above 328
mg/kg, which is a level protective of human health risk greater than 1 x 10"4.
The depth of excavation in the Northern and Southern Main Burn Pits will not be less than
2 feet in any area.
PCBs in Southern Main Burn Pit will be excavated to below 25 mg/kg.
The PSB, covering the Northern and Southern Main Burn Pits and the Pushout Area will
be a minimum of 2 feet thick in all places.
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The PSB will be underlain by a geotextHe membrane which separates the unexcavated
soil from the clean backfill of the PSB.
The construction of the P33 will contain a barrier designed to prevent encroachment of
burrowing animals.
Shoreline protection will be constructed along the J-Field. Chesapeake Bay boundary as
part of this interim action.
The PSB will be engineered to include an earthen berm to significantly reduce surface
runoff from the J-Field SOU toward the marsh.
The excavated area will be backfilled with clean soil from an off-site source. Metals
contaminated soil will be shipped to a RCRA Subtitle C landfill for stabilization and
disposal. PCB contaminated soil will be shipped to a chemical waste landfill if under 50
mg/kg or a TSCA approved.incinerator if over 50 mg/kg. Metal scrap and remediation
derived waste will be decontaminated and stored for recycling by the Defense
Reutilization and Management Office, or disposed off site at an appropriate landfill.
The PSB will be monitored in accordance with an approved O&M Plan.
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3.0 RESPONSIVENESS SUMMARY
The final component of the ROD is the Responsiveness Summary. The Responsiveness Summary
provides a summary pf the public's comments, concerns, and questions about the former burn pits at
APG's J-Field Study Area and the Army's responses to these concerns.
During.the public comment period, written comments, concerns and questions were received by
APG.
APG held a public meeting on August 12, 1996, to present the Proposed Plan, to answer
questions, and to receive comments. The transcript of this meeting is part of the administrative record for
the site. All comments and concerns summarized below have been considered by the Army and EPA in
selecting the final clean-up methods for the J-Field Study Area SOU.
This responsiveness summary is divided into the following sections:
3.1 Overview.
3.2 Background on community involvement.
3.3 Summary of comments received during public comment period and APG's responses.
3.4 Sample newspaper notice announcing public comment period and the public meeting.
3.1 OVERVIEW
At the .time of the public comment period, the Army had endorsed a preferred alternative for the
clean up of the J-Field SOU. APG's selected alternative was In-Situ Containment and Limited Disposal
which includes excavation and off-site treatment of the soil, as well as placement of a PSB over the area.
The Maryland Department of the Environment concurred with the selected Alternative.
The community generally agrees with the selected alternative of In-Situ Containment and Limited
Disposal. Several commenters expressed a preference for Alternatives 4 or 5 as they believed Alternative
2 was chosen because of cost. They were concerned that Alternative 2 would not be fully protective of
the community. APG has addressed these concerns in the following section. A community group,
Aberdeen Proving Ground Superfund Citizens Coalition (APGSCC), has stated that it could not support
the Proposed Plan until they received additional information on issues such as the amount of the soil to
be excavated, clean-up levels, and the long-term monitoring plan. These concerns and APG's responses
are further discussed in the following section.
3.2 BACKGROUND ON COMMUNITY INVOLVEMENT
Community participation in the J-Field SOU remedial action has been fairly low. J-Field does not
directly border residential areas, which may account for the relative lack of concern residents have had
with J-Field. Recreational users of the adjacent waterways are interested in potential impacts J-Field might
have on the surface waters of the Bush and Gunpowder Rivers and Chesapeake Bay.
APG has been keeping the community informed about the Remedial Investigation of J-Field and
the Focused Feasibility Study for the J-Field SOU through monthly Restoration Advisory Board meetings,
meetings with APGSCC, fact sheets, newsletters, community meetings, and personal discussions.
APG's community relations activities for the release of the J-Field SOU Proposed Plan included
the following:
APG released the Proposed Plan for the J-Field SOU for public comment on July 10.
1996. Copies were made available to the public at APG's information repositories at the
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Aberdeen and Edgewood Branches -of Harford County Library, Miller Library at
Washington College, and the Baltimore County Department of Environmental Protection
in Towson, MD.
APGT issued a press release announcing the availability of the Proposed Plan, the dates
of the public comment period, and the date and time of the public meeting to APG's full
media list.
A 45-day public comment period on the Proposed Plan ran from July 15 to August 23.
Upon a request from a citizens group, APGSCC. the comment period was extended an
additional 15 days to September 6, 1996.
APG placed newspaper advertisements announcing the public comment period and
meeting in The Aegis, the Cecil Whig, The Avenue, the Kent County News, and the Bay
News.
APG prepared and published a fact sheet on the Proposed Plan. APG mailed copies of
this fact sheet to over 2,500 citizens and elected officials on its Installation Restoration
Program mailing list. The fact sheet included a form which citizens could use to send APG
their comments.
The APG News featured a story on the Proposed Plan in the July 24, 1996 edition and
ran reminder notices about the public meeting in later issues.
On August 12, 1996 APG held a public meeting at the Edgewood Senior Center.
Representatives of the Army, USEPA, and MDE were available to answer questions about
the proposed remedial alternatives under consideration.
3.3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
AGENCY RESPONSES
Comments raised during the J-Field public comment period on the Focused Feasibility Study and
the Proposed Plan are summarized below. The comments are categorized by topic and by source.
As part of its fact sheet on the Proposed Plan, APG included a form that residents could return
with their comments. Of the 2,500 mailed fact sheets and those available at the public meetings and
repositories. APG received 27 completed comment forms.
Responses on the completed returns were:
1 Alternative 1: Take no action
14 Alternative 2: Limited removal, off-site treatment, and in-place containment
1 Alternative 3: Removal and short-term storage
5 Alternative- 4: Removal, on-site treatment, and limited off-site disposal
5 Alternative 5: Removal, off-site treatment, and disposal
1 Have no preference
The following comments were included on the forms returned:
Comment 1: I was wondering if concrete could be used in this procedure around the edges and put
holes (small) in it. I know it would'be impossible to excavate all of the contaminated soil
because some of that stuff has been there for forty years or more.
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Response: It is possible to put some type of physical control measure around the soil. We are
evaluating different possibilities, such as rip rap (large rocks) which would prevent further
erosion of the soil. During the next phase of the clean-up process, the design stage, we
wilhdecide which measure we will use. We will send a fact sheet to the public outlining
the final approved design.
Comment 2: Your fact sheet, July 96, is presented in excellent form-without bureaucratic, confusing
English. Your logical, simple approach to problem solving is outstanding. Thanks for an
excellent job.
Response: APG acknowledges and appreciates the feedback.
Comment 3: Several commenters stated that Alternative 2 seemed like a good choice financially but
wanted to be sure it was fully protective of the public. Several commenters preferred
Alternatives 4 and 5 because they felt cost was being given a higher priority than
community welfare in Alternative 2.
Response: The USEPA mandates that Overall Protection of Human Health and the Environment be
the top priority in evaluating remedial action alternatives. Cost, the seventh criterion
designated by the USEPA, is considered only after the previous six, which include
protectiveness of human health and the environment, long and short term effectiveness.
and reduction of toxicity, mobility, and volume of contaminants. Alternative 2 is fully
protective of human health and the environment.
Comment 4: Is there a possibility of placing collection stations on telephone poles that would collect
air samples in the community over set intervals? This way the community could see a
monitoring system in effect. There seems to be a lot of respiratory ailments recently in '
our community.
Response: The Risk Assessment did not indicate a need for any action due to chemical releases to
the air at J-Field. APG conducts air monitoring at locations where there are known
sources. In addition, during sampling and field work as part of the clean-up program.
APG conducts monitoring at the work site. If there were any unsafe level of substances
in the air which could move into the community, they would be detected first at the work
site. Air monitoring technology is constantly being improved. APG plans to continue to
review developing technology and improve its air monitoring capabilities wherever
possible.
Comment 5: In alternatives four and five the same amount of soil (16,000 cu. yds.) are removed and
yet by your analysis alternative five is less effective in overall protection and reduction of
toxicity, mobility and volume-why?
Response: Alternative 4 is more protective of human health and the environment than Alternative 5
because it treats the contamination on-site. Alternative 5 introduces new potential
exposure pathways in that it requires the transportation of large amounts of contaminated
soil off-site. In our analysis of reduction in contaminant toxicity, mobility, and volume, we
rated Alternative 4 higher because the soil is actually cleaned, thereby reducing the
overall volume of contamination. In Alternative 5, the soil is just moved to an off-site
facility, and there is no reduction in the volume of contamination.
Comment 6: I prefer #3. Treatment technology in five years should be more cost-effective and this
approach seems to be more thorough in totally cleaning the area.
Response: Alternative 3 is less protective of human health and the environment than Alternatives 2
and 4. In addition, it is not competitive with Alternatives 2, 4, or 5 in its long-term
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effectiveness. Finally, there is no guarantee that alternate methods of treatment will be
available or more cost effective in 5 years.
Comment 7: One_ commenter expressed a preference for Alternative 4 and included the following
comment. Become a leader in waste treatment. An on-site facility provides capability for
past, present and future use as a treatment for APG as well as other areas around the
country which need to be cleaned up. The on-site facility would generate job
opportunities for the area.
Response: The soil washing facility referred to in Alternative 4 would be designed specifically to treat
the soil from the J-Field SOU. To construct a facility that could treat soil from areas
outside of APG is beyond the scope of APG's clean-up program and would require ah
extensive regulatory and public review process to include the obtaining of various permits.
APG is using innovative technology and sharing information wherever and whenever
possible.
Comment 8: Only choice #2 includes erosion control. Why was this not included w/choices 3 thru 5.
Erosion control in that area would be required no matter what choice was made as you
are stripping the topsoil and soil-retaining vegetation.
Response: Under. Alternatives 3, 4, and 5, all the contaminated soil would be excavated. The area
would then be backfilled and vegetation restored, thus eliminating the need for erosion
control to prevent any contaminated soil from leaving the site. Clean-up funds could not
be used to prevent naturally occurring erosion unless the erosion presented a possible
threat to human health or the environment. Under Alternative 2,. some soil containing
metals would remain at the site, therefore making erosion protection necessary.
Comment 9: Is any work being done on on-site decontamination through chemical or bacteriological
methods?
Response: APG is investigating several of these technologies. In addition. APG uses information
provided by USEPA, by consultants who perform work throughout the United States and
internationally, and through technical symposiums where information is exchanged.
Comment 10: Please let us know date of removal.
Response: APG will continue to keep the public informed as work continues on this project through
meetings and newsletters.
Comment 11: A commenter expressed a preference for alternative 1 (take no action) and included the
following comment. I believe in taking action where action is warranted. However, based
on the health RA. potential exposure to humans and the environment is limited. Do a
cost/benefit analysis on this site, and tell me how you can spend S2 million cleaning up
a site that has an extremely low chance of making people and animals sick. Doing
nothing is at least 15 times cheaper than any clean-up option. And that is based on a
30 year cost to maintain the area. The real (annual) cost is more than 55,000 a year if
I understand the information correctly. Let's use some common sense here. Is it a
problem? Probably not. Why clean it up? The decision matrix is nice to help
demonstrate alternatives, but it should take into account the degree of the problem, if
you look at the impact of the alternatives, I believe you will see very little benefit.
Response: APG agrees that the RA showed only a very low potential for risk to human health. This
potential risk of exposure to the soils was to demolition workers, and the' risk could be
controlled by limiting access and by wearing protective clothing. Taking action would
have a beneficial ecological impact, as the Ecological RA highlighted environmental
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Comment 12:
ramifications of the existing soil contamination at J-Field. In addition, preventing
contaminants from future migration is a concern of APG. APG agrees with the need to
use taxpayers' money wisely and effectively and attempts to propose solutions which are
protective of human health and the environment and are the most cost-effective solutions
among equal methods.
Alternative 2 seems the obvious solution--both from the view of practicality and cost
containment. I appreciate your efforts in the restoration program and in keeping the
public informed.
Response: APG acknowledges and appreciates the feedback.
APG received the following verbal and written comments from the Aberdeen Proving Ground
Superfund Citizens Coalition (APGSCC) at the public meeting on August 12.
Comment 13: APGSCC would like further information about the arsenic and PCS clean-up levels and
about whether the soil containing high levels of lead will be removed.
Response: The final clean-up levels agreed upon by APG, MDE, and the USEPA are as follows:
1,000 mg/kg for lead - the generally accepted industrial screening level
328 mg/kg for arsenic - This level is protective of human health risk greater than 1 x 10"4.
25 mg/kg for PCBs - the restricted access clean-up standard designated in TSCA
Comment 14: APGSCC stated they had submitted comments on the two drafts of the Focused
Feasibility Study for J-Field, Volume I of the Remedial Investigation, the Ecological RA,
and the draft proposed plan. APGSCC stated that concerns raised in their comments
•have not been addressed.
Response: APG believes it is important to involve the community throughout the clean-up process
not just at the decision stage. Therefore. APG. makes drafts of documents available, to
APGSCC, other members of the Restoration Advisory Board, and to the public at its
information repositories. APG reviews and considers all comments its receives. If
appropriate. APG incorporates changes into the final version of the document. .Other
comments may relate to future documents and plans, and APG retains these comments
for use at that time. APG has prepared specific responses to APGSCC's comments and
has sent them to APGSCC: copies will be placed in APG's information repositories. With
regard to the draft Proposed Plan. APG did receive and address APGSCC's comments.
Comment 15: APGSCC stated that it had not been presented with information regarding long-term
monitoring plans.
Response: The development of long-term monitoring plans are part of the next phase of the clean-up
process as mandated by environmental laws. After the ROD is signed, APG will develop
the remedial design plans which include the long-term monitoring plan. APG will make
copies of the draft design plans, available for public review.
Comment 16: APGSCC asked about the remediation of the burn pits while another section of J-Field is
still an active emergency demolition area.
Response: APG conducts emergency detonations at a portion of J-Field under a RCRA interim status
permit from the USEPA. The detonations are not conducted close enough to the burn
pits to have an impact on any remediation actions at the Former Toxic Burn Pits (FTBP)
Area.
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Comment 17: APGSCC asked about whether any action is being taken at the marsh as part of this
proposed plan or if action will be taken in the future.
Response: As part of Alternative 2, APG will take action to prevent further erosion of the marsh area.
Geologists who have studied the marsh advised APG that the substances found in the
sediment marsh pose no risk to humans and only a very minor ecological risk. Attempts
at cleaning up and restoring marshes in different parts of the country have not been very
• successful. Scientists believe that disturbing the marsh with any type of clean-up effort
now may do more harm than good. APG plans to continue to monitor the marsh and
evaluate the need for action in the future.
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4.0 REFERENCES
Code of Federal Regulations (CFR), 1995. Labor, 29 (various parts)
Code of Federal Regulations (CFR). 1995. Protection of Environment. 40 (various parts)
Code of Maryland Regulations (COMAR), 1995. Title 26, Department of the Environment (various
subtitles).
U.S. Army Corps of Engineers (USAGE), 1989. RCRA Facility Assessment Report. Edgewood Area.
Aberdeen Proving Ground, Maryland.
U.S. Army Corps of Engineers (USAGE). 1996a. Remedial Investigation Report for J-Field. Aberdeen
Proving Ground. Maryland. Volume I: Remedial Investigation Results.
U.S. Army Corps of Engineers (USAGE), 1996b. Volume II: Human Health Risk Assessment for J-Field
Edgewood Area, Aberdeen Proving Ground.
U.S. Army Corps of Engineers (USAGE), 1996c. Remedial Investigation report for J-Field, Aberdeen Proving
Ground. Maryland. Volume 2: Ecological.
U.S. Army Corps of Engineers (USAGE). 1996d. Focused Feasibility Study for Surface Soil at the Main
Burn Pits and Pushout Area. J-Field Toxic Burning Pits Area, Aberdeen Proving Ground. Maryland.
U.S. Army Corps of Engineers (USAGE). 1996e. Proposed Plan for Interim Action Aberdeen Proving
Ground. Formerly used Toxic Burning Pits (Soil Operable Unit) at J-Field.
U.S. Environmental Protecion Agency (USEPA), 1989a. Risk Assessment Guidance for Supertund. Volume
I: Human Hearth Evaluation Manual. Part A. Interim Final. USEPA/540/1-89/002.
U.S. Environmental Protection Agency (USEPA). 1989b. Exposure Factors Handbook. Office of Health and
Evnironmental Assessment. Washington D.C.
U.S. Environmental Protection Agency (USEPA). 1989c. Risk Assessment Guidance for Superfund. Volume
I. Human Health Evaluation Manual (Part A). Interim Final. Office of Emergency and Remedial
Response. Washington D.C. 20460 EPA/540/1-89/002
U.S. Environmental Protiction Agency (USEPA). 1991. Risk Assessment Guidance for Superfund. Volume
I: Human Health Evaluation Manual Supplemental Guidance. Standard Defaoult Exposure Factors.
Interim Final, OSWER Directive 9285.6-03, Washington D.C.
U.S. Environmental Protiction Agency (USEPA). 1992. Guidelines for Exposure arsenicsessment. Fed.
Register. 57:22888-22938.
U.S. Environmental Protiction Agency (USEPA). 1993. Region III Interim Ecological Risk arsenicsessment
Guidelines. Technical Support Section.' Superfund Program Branch. Hazardous ' Waste
Management Division. Philadelphia. PA.
U.S. Environmental Protiction Agency (USEPA), 1994. Selecting Exposure Routes and Contaminants of
' Concern by Risk-Based Screening. Region III Technical Guidance Manual. Risk arsenicsessment.
ERA/903/R-93-001. Hazardous Waste Management Division, Office of Superfund Programs. Region
III. Philadelphia. PA.
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LIST OF ACRONYMS
ADD—Applied Daily Doses
APG—Aberdeen Proving Ground
APGSCC—Aberdeen Proving Ground Superfund Citizen's Coalition
ARAR—Applicable or Relevant and Appropriate Requirements
CERCLA—-Comprehensive Environmental Response, Compensation, and Liability Act
COMAR Code of Maryland Regulations
COPC—Chemical of Potential Concern
CPF—Cancer Potency Factors
CSF—Cancer Slope Factors
DOT—Department of Transportation
EEQ—Environmental Effects Quotient
FFA—Federal Facility Agreement
FFS—Focused Feasibility Study
,FTBP—Former Toxic Bum Pits
HI—Hazard Index
HO—Hazard Quotient
MDE—Maryland Department of Environment
NCP—National Oil and Hazardous Substances Pollution Contingency Plan
NEPA—National Environmental Policy Act
NPL—National Priorities List
O&M—Operations and Maintenance
OSHA—Occupational Safety and Health Administration
OU—Operable Unit
PCB—Polychlorinated biphenyl
PSB Protective Soil Blanket
RAO—Remedial Action Objectives
RA—Risk Assessment
RBC—Risk Based Concentration
RCRA—Resource Conservation and Recovery Act
RFA—RCRA Facility Assessment
RfD—Reference Doses
RI/FS Remedial Investigation/Feasibility Study
RME—Reasonable Maximum Exposure
ROD—Record of Decision
SARA—Superfund Amendments and Reauthorization Act
SOU—Soil Operable Unit
SVOC Semivolatile Organic Compounds
SWMU Solid Waste Management Units
TBC—to be considered
TCLP—Toxicity Characteristic Leaching Procedure
TECOM—Test and Evaluation Command
TPH—Total Petroleum Hydrocarbon
TSCA—Toxic Substances Control Act
UCL—Upper Confidence Limit
USACHPPM—U.S. Army Center for Health Promotion and Preventive Medicine
USAEC U.S. Army Environmental Center
USEPA—U.S. Environmental Protection Agency
USGS—U.S. Geological Survey
UXO—Unexploded Ordnance
VOC—Volatile Organic Compound
VX—O-ethyl-S-(2-iisopropylaminoethyl) methyl phosphonothiolate
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