Superfund Record of Decision Aberdeen Proving Ground Edgewood Area Beach Point Test Site Aberdeen Proving Ground MD


                                    EPA/ROD/R03-97/090
                                    1997
EPA Superfund
     Record of Decision:
     ABERDEEN PROVING GROUND (EDGEWOOD AREA)
     EPA ID: MD2210020036
     OU02
     EDGEWOOD, MD
     09/24/1997

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                             BEACH POINT TEST SITE
                       ABERDEEN PROVING GROUND,  MARYLAND
                              RECORD OF DECISION
                  Directorate of Safety, Health and Environment
                Environmental Conservation and Restoration Division
                          Installation Restoration Program
                U.S. Army Garrison Aberdeen Proving Ground, Maryland

                                 SEPTEMBER 1997

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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 REMEDY	1-2
        1.5   STATUTORY DETERMINATIONS 	 1-3

2.0     DECISION SUMMARY	2-1
        2.1   SITE NAME, LOCATION,  AND DESCRIPTION	2-1
        2.2   SITE HISTORY AND ENFORCEMENT ACTIVITIES	2-5
              2.2.1  History of the Beach Point Test Site	2-5
              2.2.2  History of Site Investigations and
                        Enforcement Activities 	 2-6
        2.3   HIGHLIGHTS OF COMMUNITY PARTICIPATION 	  2-8
        2.4   SCOPE AND ROLE OF ACTION	2-8
        2.5   SUMMARY OF SITE CHARACTERISTICS	2-9
              2.5.1  Soil Gas Surveys	2-9
              2.5.2  Surface Soil	2-10
              2.5.3  Subsurface Soil	2-13
              2.5.4  Sediments	2-20
              2.5.5  Surface Water	2-23
              2.5.6  Groundwater	2-23
        2.6   SUMMARY OF SITE RISKS	2-32
              2.6.1  Human Health Risk Assessment	2-32
              2.6.2  Ecological Risk Assessment	2-35
        2.7   REMEDIATION OF THE BEACH POINT TEST SITE	2-37
              2.7.1  Description of the Alternatives	2-38
              2.7.2  Summary of the Comparative Analysis of
                       Alternatives 	  2-40
              2.7.3  The Selected Remedy	2-45
              2.7.4  The Statutory Determinations 	  2-46
        2.8   SUMMARY OF PERFORMANCE STANDARDS 	 2-49

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
        3.4   SAMPLE NEWSPAPER NOTICE	3-5

4.0     REFERENCES	4-1

5.0     LIST OF ACRONYMS	5-1

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                                  LIST OF FIGURES
Figure

Figure 1
Figure 2
Figure 3
Figure 4

Figure 5

Figure 6

Figure 7


Figure 8


Figure 9


Figure 10


Figure 11
                                                          Page

Location of Beach Point Within APG 	2-2
Beach Point Areas of Past Operations 	2-3
Canal Creek Hydrogeological Cross Section 	2-4
Beach Point Surface Soil Sampling;
Concentrations of VOCs and Arsenic (1995)	2-11
Beach Point Subsurface Soil Sampling;
Concentrations of VOCs (1995)  	2-14
Beach Point Sediment Sampling;
Concentrations of VOCs and Arsenic (1995)	2-21
Beach Point Groundwater Sampling;
Distribution of PCA in Groundwater Wells
Screened at 30 ft. (BGS)  	2-24
Beach Point Groundwater Sampling;
Distribution of PCA in Groundwater Wells
Screened at 55 ft. (BGS)  	2-25
Beach Point Groundwater Sampling;
Distribution of TCE in Groundwater Wells
Screened at 30 ft. (BGS)  	2-26
Beach Point Groundwater Sampling;
Distribution of TCE in Groundwater Wells
Screened at 55 ft. (BGS)  	2-27
Beach Point DNAPL Zone and Hypothesized
Release Zone 	2-28
Table

Table 1

Table 2

Table 3

Table 4

Table 5

Table 6

Table 7

Table 8

Table 9

Table 10
Table 11
Table 12
               LIST OF TABLES

                                                           Page

Surface Soil Chemistry—
Detected Inorganics and Organics  (1995)	 2-12
Subsurface Soil Chemistry--
Detected Inorganics (1995) 	2-15
Subsurface Soil Chemistry--
Detected Organics  (1995)  	2-17
Sediment Chemistry--
Detected Inorganics and Organics  (1995)	2-22
Groundwater Quality Summary--
Detected Inorganics (1994-1995) 	2-30
Groundwater Quality Summary--
Detected Organics  (1994-1995)  	2-31
Cumulative Risks to Humans at Beach Point Under
Current and Future Land-Use Conditions 	2-34
Estimated Capital Cost for the Selected Remedial Strategy,
Institutional Controls  	2-41
Estimated Annual O&M Cost for the Selected Remedial
Strategy, Institutional Controls  	2-41
USEPA Evaluation Criteria for Remediation Alternatives ....2-42
Action-Specific ARARs 	2-47
Chemical-Specific ARARs for Surface Water 	2-47

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    1.0  DECLARATION OF THE RECORD OF DECISION  (ROD)

    1.1  SITE NAME AND LOCATION

Beach Point Test Site
Canal Creek Study Area, Edgewood Area (EA)
Aberdeen Proving Ground (APG),  Maryland

    1.2 STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the Beach Point Test Site.  The remedial
action was developed in accordance with the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended by the Superfund Amendments and Reauthorization Act  (SARA) of 1986  (CERCLA), and the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP).  This decision is based on the
administrative record for this site.

The Maryland Department of the Environment  (MDE) has not contested the Technical Impracticability  (TI) Waiver
for this site, and thus has acknowledged the ability of the Army and the U.S. Environmental Protection Agency
(USEPA) to waive Applicable or Relevant and Appropriate Reguirements  (ARARs) for groundwater.  Conseguently,
the MDE has concurred with the selected remedy.

    1.3  ASSESSMENT OF THE SITE

Recent sampling of this site's surface soils, subsurface soils, and offshore sediments have found little
evidence of elevated chemical concentrations when compared to off-site background levels.  One soil boring
indicated an elevated concentration of 1, 1,2,2-tetrachloroethane  (PCA) at 14 feet below the ground surface.
Sampling results also indicated contamination of the surficial aguifer with dense non-agueous phase liguids
(DNAPLs).   This groundwater is toxic to human health and the ecological receptors, and modeling has shown
that groundwater is discharging into the Bush River.  Dilution and other attenuation processes (e.g.,
advection, dispersion, sorption, etc.),  however, appear to result in nontoxic concentrations in the surface
waters.  For example, groundwater discharge from the Beach Point surficial aguifer is likely diffused over a
relatively large area, thus contributing to the dispersion of the contamination prior to discharge into a
large volume of surface water.   The ecological and human health risk assessments at this site found no
adverse effects to human and ecological receptors, however,    uncertainties with respect to the environment
exist for some chemical concentrations in The Bush River.    Implementing the response action selected in
this ROD will provide sufficient future protection to public    health, welfare, and the environment.

    1.4  DESCRIPTION OF THE SELECTED REMEDY

Based on the site assessment, the Army and USEPA developed response actions which primarily focused on the
contaminated groundwater.   However, because of the technical impracticability associated with remediating
and/or containing the DNAPL contamination at this site, the selected remedy for this site does not involve
groundwater treatment or containment.  In addition, the human health and ecological risk assessments found no
unacceptable levels of risk associated with this site.  Thus, the final remediation of the Beach Point Test
Site involves the use of institutional controls.  In order to account for the uncertainties with respect to
the environment associated with some chemical concentrations in the Bush River, a monitoring program
involving the sampling of affected media will be conducted.

Institutional controls, or use restrictions, include:  1) the posting of signs prohibiting unauthorized
excavation and installation of additional groundwater wells; 2) the prohibition of groundwater use in order
to prevent exposure to the contaminated groundwater; 3) inputting these restrictions into APG's Geographical
Information System (GIS)  which is utilized in the development of APG's Real Property Master Plan; and 4)
incorporating these restrictions/prohibitions into any real property documents necessary for transferring
ownership from the Army,  in the unlikely event that the Army sells this property.  The real property
documents would also include a discussion of the National Priorities List (NPL) status of this site, as well
as a description of the groundwater and very limited soil contamination at this site.  The final wording, and
the location and number of posted signs will be determined during the workplan development phase and through
negotiations with USEPA and MDE. Authorization to excavate soil and/or install groundwater wells will reguire
testing and monitoring in order to ensure worker safety.  In addition, the Director of the Directorate of
Safety, Health and Environment  (DSHE) will certify to USEPA on an annual basis that there have been no
violations of these prohibitions.  If a violation has occurred, a description of the violation and corrective
actions to be taken will be provided.

Monitoring of the Bush River will involve the sampling and analysis of affected media (such as sediments and
surface water) at locations within the projected groundwater plume beneath the Bush River.  Chemical analyses
and bioassessments of these samples could be conducted; however, the specifics of the monitoring program
(i.e., media sampled, target analytes, number of samples, location and freguency of samples, and

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deliverables) will be determined through discussions and negotiations with USEPA and MDE during the workplan
deve1opment pha s e.

1.5 STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment and is cost-effective. In addition, a
TI Waiver from some Federal and State ARARs has been justified and has been approved by USEPA (see Appendix
J, Focused Feasibility Study (FFS), Final Beach Point Test Site FFS Technical Impracticability Evaluation).
ARARs to be waived are the Federal Safe Drinking Water Act Maximum Contaminant Levels (MCLs) and Maximum
Contaminant Level Goals (MCLGs) (40 CFR 141.11-12, 141.50-51, and 141.61-62 ), which were adopted by the
State of Maryland in Code of Maryland Regulations (COMAR) 26.04.01 Regulation of Water Supply, Sewage
Disposal, and Solid Waste. Other ARARs to be waived are as follows: Annotated Code of Maryland, Title 9,
Subtitle 3, Water Pollution Control, Sections 9-302 and 9-322; and Annotated Code of Maryland, Title 4,
Subtitle 4, Water Pollution Control and Abatement, Section 4-402.

This remedy utilizes permanent solutions as currently available to the maximum extent practicable for this
site. However, because treatment of the principal threats of the site was not found to be practicable, this
remedy does not satisfy the statutory preference for treatment as a principal element.

Because this remedy will result in some hazardous substances remaining on-site (in the surficial aguifer)
above health-based levels, a review will be conducted within 5 years after commencement of the long-term
monitoring program to ensure that the remedy continues to provide adeguate protection of human health and the
environment.

2.0 DECISION SUMMARY

2.1 SITE NAME, LOCATION, AND DESCRIPTION

APG is a 72,000-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 Bush River. The Edgewood Area of APG (APG-EA) lies to the west of
the Bush River and The Aberdeen Area lies to the east of it. Elevations within APG-EA range from sea level
near large rivers to approximately 40 feet above mean sea level at several of the highest locations. The
APG-EA is listed on the NPL, which is USEPA's list of hazardous substance sites in the United States that are
priorities for long-term remedial evaluation and response.

The Beach Point Test Site is a 6.9-acre peninsula located in APG-EA. It is located approximately 2 miles
south of the APG-EA's northern boundary and nearby populations. As seen in Figure 1, the Beach Point Test
Site lies at the convergence of the Bush River and Kings Creek. The Bush River is one of the major estuarine
channels on the western shore of the Chesapeake Bay. Kings Creek is a major tributary of the Bush River, and
these two surface water bodies drain the majority of the areas at APG-EA. Kings Creek forms the northwestern
boundary of the Beach Point Test Site, while the Bush River borders the Beach Point peninsula to the
northeast and southeast. The Bush River is freguently used for fishing and other recreational purposes,
whereas Kings Creek is closed to the public and used primarily for fisheries and wildlife management support
functions. The area southwest of the Beach Point Test Site is occupied by a wastewater treatment plant and
several vacant structures, all of which are part of the Canal Creek Study Area.

The Beach Point Test Site contains a gravel access road, an office trailer to support restoration activities,
seven concrete building pads, and a steel rocket fuel fire suppression burn pan of approximately 16 sguare
feet (Figure 2). The remainder of the site is grass- and shrub-covered and partially forested with
several species of deciduous hardwoods. Subsurface features at the site include a series of drainage pipes
that discharge to both Kings Creek and the Bush River and to the land surface, evidence of a French drain,
and other subsurface manmade features. A marshy, vegetated area occupies the northernmost portion of the
peninsula and a portion of the Kings Creek shoreline. In addition, a series of drainage swales and erosional
gullies are located along the Kings Creek shoreline. Topographic relief is slight at the site, except for
the Kings Creek and Bush River shorelines, which are characterized by steep (8- to 12- foot high) erosional
slopes. The center of the Beach Point peninsula is approximately 14 feet higher than the shoreline;
therefore, site elevations range from 0 feet to 14 feet above the site datum (National Geodetic Vertical
Datum). Prior to the promulgation of current regulations concerning shoreline erosion control,
construction debris was deposited as rip-rap along the Bush River shoreline.

Sands and silts underlay the Beach Point peninsula to a depth of 65 feet. The groundwater in this surficial
aguifer is slightly brackish and the groundwater flow is highly influenced by both high and low tides. This
surficial aguifer is underlain by a continuous clay confining layer (i.e., the Upper Confining Unit) which is

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estimated to be 80 to 100 feet thick. As seen in Figure 3, this confining layer dips to the southeast
following the regional trend. At Beach Point, low conductivity silts predominate on the northwest side and
neck of the peninsula, thereby mitigating contaminant transfer in those directions. The higher conductivity
sands at Beach Point predominate on the eastern and southeastern side of the
peninsula, but they discontinue in the offshore regions of the Bush River. In summary, the surficial
aguifer at Beach Point eventually discharges into the Bush River. Although this groundwater resource
currently is not used for drinking water, its natural yield and guality render it a potential drinking water
resource. (Thus, this aguifer has been classified as a IIB aguifer by the State of Maryland. However, even
if this groundwater resource were not contaminated with DNAPLs from historical activities at this site, the
brackish nature of this groundwater would necessitate significant amounts of treatment prior to use as
drinking water.)

2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES

2.2.1 History of the Beach Point Test Site

APG was established in 1917 as the Ordnance Proving Ground and was designated a formal military post in 1919.
Testing of ammunition and materiel, and operation of training schools began at APG in 1918. Prior to World
War II, activities at APG were characterized by research and development and large-scale testing of a wide
variety of munitions, weapons, and materiel. Just before and during World War II, the pace of weapons,
munitions, and materiel development increased, and the number of personnel at APG exceeded 30,000. Similar
but smaller-scale increases in munitions and materiel development and testing activities at APG occurred
during the Korean and Vietnam Wars.

Historical documents, aerial photography, and interviews with knowledgeable personnel reveal that several
operations took place at the Beach Point Test Site from the World War II era to the 1970's. The first
recorded operations at the site involved the field testing of one semi-permanent and two mobile process
plants used to develop and test the impregnation of military clothing. (Clothing impregnation was needed to
protect soldiers from the effects of chemical warfare agents.) Each plant operated for a period of
approximately 1,000 hours from March through May 1943. Associated with each plant was a small laboratory.

As seen in Figure 2, the clothing impregnation plants roughly were located in the central portion of the
Beach Point peninsula. Specifically, the semi-permanent impregnation plant was probably located at the site
of the largest concrete pad in the center of the peninsula. The two mobile units, Ml and M2, likely
flanked the semi-permanent plant. The semi-permanent plant utilized either the Ml or M2 process.

The Ml plant used a solvent-based process and the impregnite CC2 (i.e., 2,4,6-trichlorophenyl urea) as the
active protective agent that reacts with and destroys the effectiveness of blister gas vapors and droplets.
PCA was used as a solvent to carry the protective chemicals to the cloth fibers, and was later recovered for
reuse. A chlorinated paraffin binder was added to retain (fix) the CC2 in the fabric.Three thousand pounds
of clothing could be impregnated in a 24-hour period at the Ml plant.

The M2 plant used a water emulsion consisting of the impregnite XXCC3, polyvinyl alcohol (an emulsifier and
dispersing compound), chlorinated paraffin, a dye, and water. XXCC3 is formed by mixing 10 parts CC2 to 1
part zinc oxide. The M2 plant was capable of processing 4,000 pounds of clothes within a 24-hour period.

Monochlorobenzene was used in large guantities in the Ml laboratory for the testing of CC2. PCA was used in
the M2 laboratory in order to test the XXCC3 for CC2.

According to the APG-EA Resource Conservation and Recovery Act (RCRA) Facility Assessment (RFA) (U.S. Army
Environmental Health Agency (USAEHA), 1989), PCA losses at the impregnation plants would have been primarily
due to evaporation. Additional releases could have been due to spillage or leakage as well as from direct
discharge of off-specification batches to surface water. Dirty or spent solvents were also discharged from
laboratory sinks to the ground.

Testing of fire and vapor suppression methods for liguid rocket fuels was conducted in the northern portion
of Beach Point from 1963 to 1964. A typical procedure involved mixing propellants (e.g., hydrazine and red
fuming nitric acid) and an oxidizer (e.g., nitrogen tetroxide) in a steel burn pan, and then attempting to
suppress the resultant flame with a water deluge or mist. During the 1970's, small guantities of explosive
mixtures and compounds also were tested in this part of Beach Point. Examples of explosives that may have
been tested include trinitrotoluene (TNT), tetryl, RDX, and HMX.

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Other operations at the Beach Point Test Site included test firing of 4.2-inch mortars during the 1940's,
storage of small guantities of chemical warfare agents (nerve agents) in Building E3990 at the northern end
of the peninsula, and storage of smoke generator fog oil at a drum/tank storage rack on the southernmost
portion of the site.

2.2.2 History of Site Investigations and Enforcement Activities

Several investigations conducted in the Canal Creek Study Area have included or focused on the Beach Point
Test Site. USAEHA conducted an assessment of surface waters throughout APG-EA during July 1977. This
assessment included four locations in Kings Creek. Major findings of the study included evidence of severe
nutrient overloading to Kings Creek; significant contamination of sediments with mercury, silver, and zinc,
and elevated levels of cadmium, copper, mercury, and zinc in clam, fish, and crab populations.

In 1985, USAEHA conducted a study to investigate the presence and biological effects of priority pollutants
in water, sediment, fish, and macroinvertebrates (i.e., small crustaceans, insect larvae, etc.) in Canal,
Kings, and Watson Creeks. Three sampling stations were established in each creek and a four-phase
sampling program was implemented which encompassed surface water, sediment, fish, and macroinvertebrates.
The program included four rounds of surface water sampling for volatile organic compounds (VOCs),
semi-volatile organic compounds (SVOCs), metals, pesticides, polychlorinated biphenyls (PCBs), and nutrients:
two rounds of sediment sampling for metals, pesticides, and PCBs; one round of fish tissue residue analysis
for metals, pesticides, and PCBs; and one round of macro invertebrate sampling for species diversity.
Analytical results for the Kings Creek sampling events indicated the presence of the following contaminants:
1) SVOCs (i.e., phthalates, dinitrotoluene) and metals (most notably copper, lead, and zinc) in surface
water; 2) metals, pesticides and 2,4,6-trichlorophenyl urea in sediments; and 3) chlordane, DDT, PCBs,
mercury, selenium, and zinc in fish tissues. Macroinvertebrate community diversity was considered
intermediate to poor, however, diversity indices showed downstream improvement from the headwater area of
Kings Creek to the Beach Point Test Site.

USAEHA conducted another study in July 1986 which evaluated the presence of APG-related contaminants in
sediments of receiving water bodies in proximity to APG, and the diversity of the macroinvertebrate community
in these sediments. The sampling included three locations within Kings Creek. Sediment samples were
analyzed for nutrients, metals, pesticides, and PCBs. Macro invertebrate species (i.e., small crustaceans,
insect larvae, worms, clams, pill bugs, etc.) were collected and taxonomically classified at all locations.
The study reported that sediment samples from Kings Creek and other APG-EA sampling locations contained
moderate to high concentrations of arsenic, chromium, and lead. Several chlorinated pesticides were present
at low levels, and PCBs were not detected in samples from Kings Creek. The natural variability in
macroinvertebrate diversity masked any possible minor impacts on the biotic community; therefore, USAEHA was
unable to draw conclusions about macroinvertebrate species diversity in this study.

Also in 1986, the Army contracted with the United States Geological Survey (USGS) to conduct an investigation
of the groundwater, soil, and surface water at Beach Point as a part of the USGS Canal Creek Study (Lorah and
Clark, 1996). During this investigation, the USGS installed six groundwater monitoring wells at the Beach
Point Test Site. Sampling and analysis indicated the presence of VOCs, SVOCs, metals, and inorganics, in the
groundwater. The surficial aguifer was found to contain PCA, trichloroethene (TCE), and other chlorinated
VOCs. Chlorinated VOCs were detected at the highest concentrations in wells CC-33A and CC-33B, with the
deeper well (33B) exhibiting the higher concentration (maximum 9,480 Ig/L of PCA). Zinc, copper, nickel, and
silver concentrations also may have resulted from site operations. Iron and manganese concentrations tended
to be relatively higher in wells CC-33A and CC-33B than in the other wells (e.g., CC-32 and CC-34),
indicating reducing conditions possibly resulting from organic contamination. Analytical results for the
surface soil samples detected the presence of several common soil inorganics (i.e., iron, manganese, calcium,
magnesium, sodium, and arsenic), organic halides, and trichlorofluoromethane. The metals detected in surface
water at concentrations above background included aluminum, cadmium, iron, lead, manganese, mercury, and
zinc. Iron, manganese, and lead were detected at concentrations above background at all surface water
sampling locations. Zinc, mercury, and cadmium were detected at above background levels in surface water
samples from the Kings Creek shoreline of Beach Point. The USGS report also stated that PCA and other
chlorinated VOCs primarily were found in two surface water samples; however, these concentrations were well
below the relevant Ambient Water Quality Criteria (AWQC) (USEPA, 1986). It should be noted that current
standard operating procedures and protocols for collecting surface water data differ from those used by USGS
for this study; therefore, these results should be used for making gualitative rather than guantitative
statements today. These data were not used to make comparisons to existing standards and risk levels.

The USAEHA RFA (1989) contains detailed information on the activities conducted at Beach Point and a summary
of data on solid waste management units (SWMUs) in the Kings Creek drainage area, including waste types and
guantities, contaminant behavior, migration pathways, and recommendations for further study. The RFA does
not contain any Beach Point environmental sampling data.

ICF Kaiser Engineers (a contractor for the Army) conducted a preliminary baseline risk assessment of the

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Canal Creek Study Area between October 1989 and January 1991. This preliminary assessment involved the
review and analysis of existing data, and covered the Beach Point Test Site as well as other areas in this
study area. ICF concluded at that time that it was not possible to fully evaluate potential human health
risks with the available data. In addition, ICF also concluded that acute and chronic toxicity from
contaminants in Canal Creek probably had affected the composition and structure of the resident aquatic
communities, and that terrestrial wildlife feeding in Canal Creek appeared to be at risk from dietary
exposure to heavy metals. It should be noted that the findings from this preliminary analysis were not
definitive, and that additional investigations were warranted in order to determine the actual risk to human
health and environment in the Canal Creek Study Area.

In September 1993, the Army conducted a removal action at the former drum rack area of The Beach Point Test
Site. Activities included the removal of four overpack drums containing fog oil, an empty 500-gallon
aboveground storage tank, a cinder block wall, and miscellaneous debris. Analytical results for the
composite soil sample taken at the site revealed detectable levels of metals (in parts per million (ppm)),
VOCs (in parts per billion or (ppb)), and pesticides (in ppb). One analyte, beryllium, was detected at a
level which exceeded proposed RCRA Corrective Action Standards. Complete results from the analytical program
are tabulated in the FFS prepared for the Beach Point Test Site.

During 1994 and 1995, the Army more fully characterized Beach Point through a series of environmental
sampling events, including soil gas sampling around possible source areas, sediment sampling in areas of
suspected release or discharge near the shorelines, surface soil sampling in the top 6 inches, subsurface
sampling from 6 inches to the top of the water table, and sampling of the surficial aguifer groundwater. In
addition to environmental sampling, aguifer tests were performed on all wells, tidal influence was measured,
and geophysical surveys were conducted.

The Beach Point Test Site has never been the subject of any CERCLA enforcement activities.

2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION

The FFS for the Beach Point Test Site was finalized in June 1996. The Proposed Plan and The TI Waiver were
finalized and released to the public on May 7, 1997, initiating a 45-day comment period. These documents,
which are included in the administrative record for Beach Point, have been made available to the public at
the Harford County Public Library (both the Aberdeen and Edgewood Branches) and the Miller Library at
Washington College in Chestertown, Maryland.

The notice of availability of the Proposed Plan was published in several local newspapers in Harford,
Baltimore, Kent, and Cecil counties. In addition, a story appeared in the APG News. A public meeting was
held at the Edgewood Senior Center in Edgewood, Maryland on May 20, 1997 to inform the public of the
preferred alternative and to seek public comments. At this meeting, representatives from APG, USEPA, and MDE
discussed their position with respect to the preferred alternative. Fact sheets which included a comment
form were sent to approximately 2,590 residents of the aforementioned counties. Responses to the comments
received during this 45-day period are included in the Responsiveness Summary (see Section 3.0 of this
document).

2.4 SCOPE AND ROLE OF ACTION

The final remedial action at the Beach Point Test Site represents one component of a comprehensive
environmental investigation and clean-up action currently being performed at APG to comply with CERCLA
requirements. This ROD primarily addresses the contaminated groundwater of the surficial aquifer at this
site, but also addresses the minimal soil contamination and any possible uncertainties associated with
contamination of the Bush River. According to the Baseline Risk Assessment (BLRA) conducted in 1995, no
unacceptable levels of risks to human health and the environment are posed by the groundwater, sediments,
surface soil, subsurface soil, and surface water at this site. The purpose of this remedial action, however,
is to ensure that future potential exposures to the contaminated groundwater and soil do not occur, and that
any adverse changes in risk to the environment can be detected through the monitoring of the Bush River
(i.e., potentially including but not limited to sampling and analysis of the surface water and sediments).

Because of the technical impracticability associated with remediating the DNAPL contamination in the
surficial aquifer to all clean-up standards and/or containing the DNAPL zone, USEPA has approved a TI Waiver
for this site. Thus, the selected remedy of Institutional Controls utilizes permanent solutions as currently
available to the maximum extent practicable for this site. Because treatment of the principal threats of the
site was not found to be practicable, this remedy does not satisfy the statutory preference for treatment as
a principal element.

2.5 SUMMARY OF SITE CHARACTERISTICS

One objective of the study of the Beach Point Test Site was to evaluate the potential on-site sources and

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whether releases from these sources to the environment have occurred with lasting impact. From existing
records, it was concluded that activities associated with the clothing impregnation operations have impacted
the site soils and groundwater more extensively than the activities associated with the drum rack area or the
rocket fuel fire suppression testing area. Potential source areas also were identified from site
reconnaissance and aerial photography interpretation of historical surface features. Geophysical survey
technigues were used to identify subsurface features such as pipes, trenches, drains, and fill areas as
potential release points. These subsurface conduits could serve as potential migration pathways for
contaminants. Geophysical surveys, soil gas surveys, soil sampling, and excavations were performed in order
to determine whether any underground storage tanks (USTs) at the Beach Point Test Site were present; no USTs
were found.

As previously stated, the nature and extent of contamination at the Beach Point Test Site was investigated
through soil gas surveys and extensive sampling of groundwater, surface soil, subsurface soil, and sediments
in 1994 and 1995. The sampling locations for this investigation were selected by evaluating the locations of
historical activities and likely release points. The following discussions summarize the results of these
investigations.

2.5.1 Soil Gas Surveys

Active soil gas surveys were taken near many of the concrete pads, the suspected location of an UST, and in
the southern-most area of the peninsula near the site of the 1993 removal action. These surveys investigated
the upper 4 feet of the vadose zone. (The vadose, or unsaturated, zone is between the land surface and the
water table. The pore spaces in this zone contain water at less than atmospheric pressure, as well as air
and other gases.) Results indicated that most of the soil gas in the area of the concrete pads and
suspected UST likely was associated with petroleum contamination rather than the variety of chlorinated
solvents that were used in past operations. There was an indication that minor amounts of chlorinated VOCs
were present in soil vapors in the area of former impregnation operations; however, the results did not
indicate the presence of a contaminant source within the soils.

2.5.2 Surface Soil

Fifteen surface soil samples from 13 locations were collected at the Beach Point Test Site in 1995. See
Figure 4 for these locations as well as the analytical results of significant detections in these samples.
For a complete listing of analytical results for both inorganic and organic compounds, refer to. Table 1.
Generally, these samples represent the soil chemistry in the top 6 inches of the soil. In addition,
off-post soil sampling conducted by ICF Kaiser Engineers for the Reference Sampling and Analysis Program
(U.S. Army Environmental Center (USAEC), 1995) provided background soil chemistry data (i.e., inorganics,
polynuclear aromatic hydrocarbons (PAHs), phthalates, pesticides, PCBs, dioxins, furans, and radioactive
isotopes) for comparison. The findings of these soil sampling efforts are summarized as follows.

• Six inorganic constituents exceeded the maximum concentrations of the background
soils. These are calcium, lead, magnesium, mercury, selenium, and nickel.

• The maximum arsenic concentration at Beach Point did not exceed the maximum
concentration of background soils, but it exceeded the carcinogenic level established by
USEPA Region III as the Risk-Based Concentration (RBQ for industrial soils.

VOC detections were found at five surface sample locations; S03N006, 007, 008, 009,
and Oil. The highest VOC concentration was found at sample location S03N008 (e.g.,
124 Ig/kg of styrene). Acetone was found in five surface soil samples taken from four
sampling locations, with concentrations ranging from 3.7 to 20 Ig/kg.

• The following VOCs also were detected in surface soil samples: chloroform, PCA,
toluene, TCE, and methylene chloride. Methylene chloride detections corresponded to
several sampling locations, but these detections always were found in blanks and
therefore likely resulted from laboratory contamination. Detections of chloroform, PCA,
toluene, and TCE were below approximately 5 Ig/kg.

• PCA and TCE were found at sampling location S03N007, near the smaller concrete pad
at the location of the former impregnation operations. TCE was not detected in a
duplicate sample of soil from that same location. PCA detections were below 5 Ig/kg,
and TCE was detected at 3.14 Ig/kg.

• The Reference Sampling and Analysis Program (USAEC, 1995) did not analyze off-post
soils for VOCs; therefore, comparisons between Beach Point and off-post surface soils
could not be made for these types of compounds. None of the Beach Point organic
concentrations exceeded the RBCs.

-------
The surface soil contamination at this site is insignificant when compared to off-site background levels. In
addition, the BLRA found no unacceptable levels of current or future risk to human health and the environment
from exposure to these soils.

2.5.3 Subsurface Soil

Subsurface soil chemistry was investigated using numerous soil borings at The Beach Point Test Site from a
depth of 6 inches to the top of the water table. No background subsurface soil samples were collected as
part of the Reference Sampling and Analysis Program (USAEC. 1995), and there is no other available background
data for subsurface soils that can be used as a basis for comparison to this site. Figure 5 illustrates the
locations of most of the soil borings at the Beach Point Test Site, as well as the analytical results for
VOCs detected in these samples. The analytical results for both inorganic and organic concentrations
included in Tables 2 and 3 are summarized as follows,

• Aluminum, barium, iron, magnesium, manganese, potassium, and zinc were detected in
all samples. Vanadium and arsenic were detected in almost every sample (i.e., 20 out of
21). At least half of the samples contained calcium, chromium, cobalt, lead, copper,
and/or nickel. Arsenic exceeded its carcinogenic industrial soil RBC in only two
samples, and the arithmetic mean concentration was less than the RBC.

Traces of pesticides and related compounds (e.g., 2,4-D, 2,4,5-T, Silvex, DDT, ODD,
DDE, and Endrin) and dioxins (e.g., hexachlorodibenzodioxin (HCDD) and
octochlorodiberizodioxin (OCDD)) were detected in a few subsurface soil samples at
concentrations ranging from 0.0002 to 0.0 166 mg/kg. The OCDD detection very likely
results from laboratory contamination, but the pesticide detections are found at regional
background concentrations and therefore are likely valid.

• Concentrations of bis(2-ethylhexyl) phthalate, butylbenzyl phthalate, and di-n-butyl
phthalate were commonly detected in the subsurface soils at 0.023 to 1.2 mg/kg. Almost
every sample analyzed contained at least one of the above compounds. These detections
may likely result from laboratory contamination.

• PCA and TCE concentrations were detected near the site of the former clothing
impregnation operations. Aside from the aforementioned phthalate concentrations
(which likely result from laboratory contamination), PCA was detected at the highest
concentration for any organic compound (i.e., maximum concentration is 770 Ig/kg at
approximately 14 feet below the ground surface). No detections of organic compounds
exceeded their RBCs.

The subsurface soil contamination at this site is insignificant when compared to the applicable industrial
soil RBCs. In addition, the human health risk assessment screened out this media from analysis because all
contaminant concentrations were below industrial soil RBCs and/or reference screening concentrations.
Regardless, people could be exposed to this subsurface soil contamination through soil excavation activities.
The chosen remedial action for this site (Institutional Controls) will prohibit unauthorized excavation and
groundwater well installation, and will therefore mitigate potential exposures to these contaminants.

-------
TABLE 2. Subsurface Soil Chemistry— Detected Inorganics (1995)
Sample ID
Units
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
SB3N001A
mg/kg
4970 J
2.7
15.9 J
0.22 J

95.2 K
7.2

4.0 J
10200 J
4.0 J
514 K
38.4 J
0.06 J

381 J


12.1
14.2
SB3N002A
mg/kg
6530 J
2.3
17.6 J
0.25 J

41.7 K
10.7
4.2 J
6.4
14200 J
4.4 J
774 K
71.5 J
0.06 J
6.5 J
476 J


11.8
28.0
SB3N003A
mg/kg
4090 J
1.5 J
20.0 J
0.43 J

74.2 K
7.2

3.8 J
10000 J
7.9 J
1150 K
51.9 J

7.6 J
490 J


8.3J
20.9
SB3N004A
mg/kg
3230 J
2.6
11.6 J


53.3 K
4.5


7020 J
5.9 J
737 K
68.2 J

6.9 J
318 J


5.1 J
17.2
SB3N005A
mg/kg
2340 J
1.1
11.0 J


136 K
5.0


3800 J
3.2 J
494 K
17.6 J


318 J



13.3
SB3N006A
mg/kg
10600 J
5.7
33.0 J
0.39 J

226 K
20.5
4.9 J
8.4
21800 J
18.6 J
1570 K
69.5 J

8.3 J
553 J


31.1
34
SB3N007A
mg/kg
4210 J
1.3 J
18.0 J


59.7 K
7.2

4.5 J
9910 J
3.9 J
995 K
33.9 J


343 J


7.1 J
20.7
SB3N008A
mg/kg
3010 J
1.3 J
10.8 J


78.2 K
6.0


5690 J
3.4
760 K
25.9 J

5.5 J
402 J


4.1 J
16.5
SB3N011A
mg/kg
1800 J
1.1 J
5.2 J


59.4 B
3.0 B


3000

268 J
51.7


214 J


3.0 J
6.7
SB3N011D
mg/kg
1850 J
0.44 J
4.6 J


36.4 B
1.9 B


2860

302 J
29.7


204 J


2.5 J
8.8
SB3N012A
mg/kg
3020 J
0.92 J
15.1 J
0.25 J

190 B
4.9


19800
2.8 B
844 J
20.5

5.2 J
669 J

293 J
7.3 J
16.2
SB3N013A
mg/kg
2850 J
2.1 J
13.6 J
0.39 J

81.6 B
6.0
3.2 J
6.1 J
16600
3.6 B
596 J
47.4
0.06 J

295 J

141 J
7.8 J
12.9

-------
                                TABLE 2. Subsurface Soil Chemistry-Detected Inorganics (1995)
                                                         (continued)
Sample ID
Units
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
SB3N014A
mg/kg
4860
2.5
18.0
0.30
0.64
88.5
8.4
2.7
3.9
9690
3.7
936
28.8

6.6
588
0.18

9.4
18.3
J

J
J
J
B

J
J

B
J


J
J
J

J

SB3N015A
mg/kg
4290
2.3
14.9
0.30

118
7.2
3.4
5.0
8010
5.0
992
33

4.9
495

75.7
9.9
18.8
J
J
J
J

B

J
J

B
J


J
J

J
J

SB3N016A
mg/kg
1030
1.4
5.7


99.9
2.8


1790
2.0
265
11.1


180

111
3.4
5.7
J
J
J


B
B



B
J



J

J
J

SB3N017A
mg/kg
722
1.6
6.4


93.4
3.5


2360
1.6
146
8.4


136


3.8
51
J
J
J


B
B



B
J



J


J
J
SB3N029A
mg/kg
6410
2.7
13.2
0.24

629
11.8
3.6
6.1
11300
23.3
1620
115

7.3
762

751
14.3
20.3

B
J
J

J

J
J

K



J
J

J

J
SB3N030A
mg/kg
6220
5.3
17.0
0.50

768
20
4.7
14.3
18000
9.5
1390
106

10.6
730

1150
32.8
29

K
J
J

J

J
J

K
J


J
J

J

J
SBR032BA01
mg/kg
9870
4.4
45.9


839
17.9
3.9
13.4
16300
65.3
2090
147
0.08
16.8
463

368
30.3
79.4

L
L



L
J
L

J

L
B
L
J

J
L
L
SBR032BA02
mg/kg
1070
1.1
5.4


74.3
2.2
2.5
2.1
1570
1.6
224
33.5


154

448
2.4
4.6

JL
JL


J
L
J
JL

J
J
L


J

J
JL
L
SBR033BA01
mg/kg
10600
3 L
36.6


3010
17.5
3.6 J
6.9
19400
7.2
2270
135 K
0.08 B
8.5
321 J

367 JK
29
23.3
SBR033BA02
mg/kg
2400
1.1
11.2


71.6
3.3
1.7
2.6
4340
1.7
603
23

2.9
292

399
3.7
116

JL
J


J

J
J


J
K

J
J

JK
J

Note:  Each sample concentration is followed by EPA Region III data validation gualifiers
EPA Region III Data Qualifiers
B = detected in associated QC blank
J = estimated value
K = biased high
L = biased low
Blank means below detection or analysis not performed.

-------
Sample ID
  SB3N013A
Units
   ug/kg
Benzole Acid
Trichloromethane  (chloroform)
Methylene Chloride
      5 BJ
2-Butanone
Toluene
Styrene
4,4'-DDD
4,4'-DDE
4,4'-DDT
Silvex
  11.32 J
Total Phosphorus
Endrin
OCDD
   0.32
HCDD
butylbenzyl phthalate

bis(2-Ethylhexyl) phthalate
     46 JB
di-n-Butylphthalate
     43 J
                                                174
                                                                           9.74 B
                                                                                                      ug/ Kg
                                                                                                      416.0  B
                                                                                                                                               7.34  B
                                                                                                                                                          SB3N011A

                                                                                                                                                           ug/kg
                                                                                                                                                                                      10  BJ
2 J
6 BJ

2 J


5 BJ
4 J
3 J
4 J

6 B.
3 J
7 J
1 2
                                                                                                                                                                                    130  JB

                                                                                                                                                                         230 JB     210  JB

                                                                                                                                                                          77 JB     110  JB

-------
Sample ID

Units

2,4,5,-T
Methylene Chloride                  4 BJ        7 BJ         7 BJD           7  BJ
Acetone                             1 BJ        2 BJ                                                  5 BJ          5  BJ
Tetrachloroethene                                                                                                                                             2  J

trichloroethene                                 6 J         15 JD            2  J                                                                              3  J
1,1,2-trichloroethane                           1 J
1,1,2,2-tetrachloroethane                     610 J        770 D             30                      13             2  J           9 J          13           440  E
Toluene                                         1 J
Xylene(total)
Chlorethane
4,4'-DDD
4,4'-DDE
4,4'-DDT
Silvex
beta-BHC
alpha-BHC
Endrin
OCDD
butylbenzyl phthalate
bis(2-ethylhexyl)phthalate                     57 JB
di-n-butylphtalate                 45 JB       64 JB

-------
2,4,5,-T
Methylene Chloride
3 JB         8 JB
Acetone
           4 JB
Tetrachloroethene
trichloroethene
1,1,2-trichloroethane
1,1,2,2-tetrachloroethane
Toluene
Xylene(total)
Chlorethane
4,4'-DDD

4,4'-DDE
4,4'-DDT
Silvex
beta-BHC
alpha-BHC
Endrin
OCDD
butylbenzyl phthalate
bis(2-ethylhexyl)phthalate
250 JB      770  B
di-n-butylphtalate

Note:  Each sample concentration is followed by EPA Region III data  validation qualifiers
EPA Region III Data  Qualifiers
B = detected in  associated  QC blank
D = reanalyzed at a  high dilution factor
J = estimated value
K = biased high
P = greater than 25% difference for detected concentrations between  the  two GC columns
Blank means below detection or analysis not performed
1.4 JP
              1200

-------
2.5.4 Sediments

Ten sediment samples-from nine locations in close proximity to Beach Point were collected during this
investigation (see Figure 6). These samples were collected from both Kings Creek and the Bush River. The
results of the sampling and analysis are included in Table 4 and are summarized as follows. Off-post
sediment sampling for the Reference Sampling and Analysis Program (USAEC, 1995) provided background sediment
chemistry data for comparison, although sediments were not analyzed for VOCs in this USAEC study.

• Of the inorganic compounds, only antimony and silver were detected at levels very near
or exceeding maximum background concentrations. Antimony detections ranged from
1.7 to 2.9 mg/kg (at SE3N003, 009, 010, and Oil), and the maximum background
concentration for this compound was 1.6 mg/kg. Silver was detected in one sample
(SE3N011) at 0.54 mg/kg, which approximates the maximum background concentration
of 0.58 mg/kg.

• The maximum lead detection (i.e., 17.8 mg/kg) was found in sample SE3N011, taken at
the farthest western extent of the study area. This concentration did not exceed the mean
background concentration for lead of 27.85 mg/kg.

• Acetone, methylene chloride, toluene, and 1, 1, 1-trichloroethane (TCA) were the only
VOCs detected in the sediments. Acetone was detected in one sample (SE3N010) at 44
Ig/kg. Methylene chloride was detected in three samples (SE3N003, SE3N004, and
SE3N005) at concentrations ranging from 4.38 to 5.10 Ig/kg. Toluene and 1, 1, 1 - TCA
were only detected at sampling location SE3N011 (located at the farthest western extent
of the study area) at 11.1 and 1.90 Ig/kg, respectively.

• No RBCs exist for sediments, but the comparison of sediment concentrations to
industrial soil RBCs resulted in only arsenic exceeding its carcinogenic RBC at two
locations (SE3N008 and SE3N009). The arsenic concentration detected at both of these
locations was 5.7 mg/kg. Arsenic was detected at all sediment sampling locations, and
the concentrations ranged from 0.6 to 5.7 mg/kg. The arithmetic mean arsenic
concentration at Beach Point was 2.3 mg/kg, which is less than the RBC, however.

At the reguest of MDE, additional sediment sampling in the Bush River was conducted in June 1995 to further
evaluate whether groundwater could be detected discharging through the bottom sediments of the Bush River.
Five sediment samples were collected from five locations at 50 foot intervals in a line perpendicular to the
shoreline at well CCJ-158B (see Figure 6). No VOCs were detected in these sediment samples.

The human health risk assessment screened out sediments from analysis because all contaminant concentrations
in this media were less than industrial soil RBCs and/or reference screening concentrations. In addition,
the ecological risk assessment found very little evidence of risk to aguatic receptors from exposure to
contaminants in the sediments. The selected remedy includes a monitoring program of the Bush River in
order to determine whether adverse changes in risk to the environment are occurring at this site. This
monitoring program could include, but is not limited to, the sampling and analysis of Bush River sediments
and surface water.

-------
                               TABLE 4. Sediment Chemistry - Detected Inorganics and Organics
                                                            (1995)
Sample No.
Parameter
Aluminum
Antimony
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Mangenese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
Units
SE3N003A
mg/kg
956


4.0 J

207 J
4.8


3940
6.2 J
170 J
35


214 J

150 B
10.2 J
10.8 J
ug/kg
SE3N003D
mg/kg
841
1.8 J
0.60 J


83.2 J
3.6


1510
3.4 J
103 J
19.2


252 J

124 B

8.6 K
ug/kg
SE3N004A
mg/kg
1800

0.76
6.4

124
3.2


3690
2.3
473
32.7


338

196

9.8



J
J

J




J
J



J

B

K
ug/kg
SE3N005A
mg/kg
2400

1.8 J
11.5 J
0.27 J
671 J
11.9

11.0 L
12300
12.8 J
793 J
54.7
0.07 J
7.5 J
338 J

428 B
16.1
19.5 K
ug/kg
SE3N006A
mg/kg
1710

1.2 J
5.8 J
0.24 J
557 J
5.3


4070
2.0 J
572 J
519


535 J

516 J

10.8 K
ug/kg
SE3N008A
mg/kg
1090

5.7 L
4.2 J

1140 J
3.6


3840
7.8 J
479 J
35.6


161 J

182 B

10.9 K
ug/kg
SE3N009A
mg/kg
2930
1.8 J
5.7 L
5.0 J
0.26 J
148 J
6.6


11500
7.8 J
353 J
22.8


404 J

382 B
13.5 J
14.2 K
ug/kg
SE3N010A
mg/kg
3200
1.7 J
1.8 J
11.9 J
0.24 J
315 J
7.4

7.6 L
7310
9.9 J
817 J
97.6
0.16
9.3 J
581 J

405 B
9.1 J
37.6 K
ug/kg
1,1, 1-Trichloroethane
2,4-D
Silvex
4,4' -DDD
4.4, 4-DDT
Acetone
alpha-BHC
beta-BHC
Endosulfan II
Methylene Chloride
OCDD
Toluene
Total Phosphorus
58 J
4.65 J
0.110 J





4.73 J
0.15

317


0.070 J
0.60 J


0.21 J


0.10

15.3
31.7
2.46






4.38


45.3
J
J






J











5.10 J
0.38

43.1









0.18

154

2.19 J







0.15

171

4.26 J
0.86 J
0. 750 J
44.0 J


0.75 J

0.32

133


0.54 J
5.87



5.87

0.33

103
SE3N011A
mg/kg
4090
2.9 J
2.1 J
24.2 J
0.28 J
732 J
15.7
4.7 J
13.7 L
10900
17.8 J
1160 J
54.9

9.5 J
506 J
0.54 J
183 B
19.5
104
ug/kg
1.90 J
46.6 J
5.03
4.53 J






0.40
11.1
279
SE3N015A
mg/kg
1750

1.1 J
6.9 J
0.15 J
128 J
3.7
2.6 J
3.2 J
3560
5.4
421 J
57

4.4 J
221 J

406 B
3.8
19.3
ug/kg



2.2 J


0.69 JP
1.6 JP





Note:  Each sample concentration and is followed by EPA Region III data validation gualifiers.
EPA Region III Data Qualifiers; B = detected in association QC blank.  J = estimated value.  K = biased high.
L = biased low.  P = greater than 25% difference for detected concentrations between the two GC columns.
Blank means below detection or analysis not performed.

-------
2.5.5 Surface Water

Surface water sampling was not performed for this most recent study (in 1994 and 1995) because sediment
sampling is a more reliable indicator of whether groundwater discharge from the site is impacting the Bush
River. As previously mentioned in Section 2.2.2, surface water sampling was conducted in the Canal Creek
Study Area by USGS in 1988 and 1989 (Lorah and Clark, 1996), and some of these results can be used to provide
an indication of the general water guality of Kings Creek and the Bush River. Specifically, eight surface
water samples from these water bodies were collected by USGS in 1988/89, all during low tide. The results of
this study are as follows.

• Concentrations of inorganic constituents in surface water are highly variable in the Canal
Creek Study Area, including Kings Creek and the Bush River. On each sampling trip,
concentrations varied among the different surface water bodies at different locations.
The variable inorganic chemistry can be largely attributed to the tidal nature of the
creeks and estuaries and to the varying amounts of groundwater input at the different
sampling locations. Refer to Table 4-8 of the FFS for a summary of the detected
inorganics in Kings Creek and the Bush River.

• The September 1988 sampling event revealed 21 common inorganic constituents and 2
VOCs (e.g., methylene chloride and TCE) in unfiltered samples of surface water near the
Beach Point Test Site. Methylene chloride was detected in all samples, pointing to the
possibility that it was introduced as a laboratory contaminant. TCE was detected in two
samples, at 3 and 16 Ig/L. See Tables 4-8 and 4-9 of the FFS for summaries of the data
collected during the 1988 sampling event.

• During the 1989 sampling event, 18 common inorganic constituents and 18 VOCs were
detected in surface water samples near Beach Point. Most of the VOC detections were
from two sample locations: one near well CCJ-159B and another from near the western
shore of Kings Creek. Of the detected VOCs, carbon tetrachloride, 1,1,1 - TCA, 1,1 -
dichloroethane, tetrachloroethene (PCE), and vinyl chloride were detected at the highest
concentrations (i.e., 33.5 - 42.5 Ig/L). See Tables 4-8 and 4-9 of the FFS for summaries
of the 1989 sampling event.

It should be noted that this sampling and analysis was not conducted under the guality assurance/guality
control protocols specified in the Beach Point and Canal Creek Study Area Quality Assurance Project Plan
(Jacobs, 1994). Thus, these data only should be used to gualitatively discuss the surface water in the area
of the Beach Point Test Site.

2.5.6 Groundwater

Ten groundwater monitoring wells at the Beach Point Test Site were sampled from 1994 to 1995. These wells
were spatially distributed over the peninsula as shown in Figures 7 through 11. In addition, these wells
were screened at varying depths in order to collect information on the vertical distribution of the dissolved
contaminants. Some of the compounds used in historical operations at this site are DNAPLs; therefore, it was
anticipated that contaminant concentrations may be found in the lower regions of the aguifer. Moreover, USGS
(Lorah and Clark, 1996) found the highest groundwater VOC concentrations in a deeper well. Wells with an "A"
designation are shallower wells and are screened from approximately 10 to 30 ft. below ground surface (BGS).
Those wells with a "B" designation are deeper wells and are screened from approximately 21 to 60 ft. BGS.

The results of the sampling and analysis of these groundwater wells are summarized in Tables 5 and 6. In
summary, 20 inorganic constituents were detected in the groundwater at this site. Concentrations of antimony
(maximum 0.312 mg/L), beryllium (maximum 0.005 mg/L), cadmium (maximum 0.028 mg/L), lead (maximum 0.015
mg/L), and nickel (maximum 0.443 mg/L) exceeded health-based concentrations. Fifteen VOCs were detected in
the groundwater samples; however, no specific VOC was found in every well. The VOCs that exceeded 10 Ig/L
were methylene chloride, 1,2 dichloroethene (DCE), 2-butanone, TCE, 1,1,2-TCA, PCE, and PCA. Of the detected
VOCS, concentrations of vinyl chloride (maximum 1.0 Ig/L), 1,2-DCE, (maximum 340 Ig/L), chloroform (maximum
10.0 Ig/L), TCE (maximum 2,400 Ig/L), 1,1,2-TCA (maximum 150 Ig/L), PCE (maximum 120 Ig/L), and PCA (maximum
22,000 Ig/L) exceeded RBCs.

PCA and TCE were found at the highest concentrations and in the greatest number of groundwater wells at this
site; therefore, Figures 7 through 10 describe the lateral and vertical extent of these dissolved plumes.

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The highest concentrations of these compounds were found in wells CCJ-158B and CCJ-157B, and both of these
wells are screened in the deeper regions of the surficial aguifer near the confining layer.  Both PCA and TCE
are DNAPLs, and the groundwater data corraborates historical sampling results and the general knowledge of
DNAPL behavior in this type of aguifer.

In addition, evaluation of the percent total solubility data for these organic compounds results in an
estimation that the DNAPL zone exists in the saturated zone in the deeper regions of the aguifer in both the
coarser and finer grained aguifer matrices.  The DNAPL zone is likely to be in the form of residual
concentrations of DNAPL, left behind in vertical masses as the DNAPL migrated downward, and as pools of DNAPL
which have become trapped on low permeability surfaces that are impenetrable to the DNAPL.

Figure 11 presents an approximate delineation of the most likely extent of the DNAPL zone. The DNAPL zone
also includes the most likely DNAPL source area, which is the clothing impregnation area.  This area is
represented on Figure 11 by two pads located just northeast of well nest 33.  Note that the DNAPL zone is
interpreted as existing in the offshore regions of the Bush River, because gravity flow and the prevailing
subsurface geologic interfaces tend to slope in the southeast direction and because the agueous concentration
gradient is increasing in the offshore direction toward the Bush River. (One would expect higher
concentrations in proximity to the DNAPL.)  Ultimately, just how far the DNAPL zone extends depends upon the
amount of mass that was released and where it was released. While there is some evidence that there were
releases on shore near the concrete pads, there is a probability that offshore releases could also have
occurred.

The migration pathways and final distribution of the DNAPL greatly depend on the heterogeneity of the aguifer
materials:  as the degree of heterogeneity in the aguifer increases, the likelihood of accurately locating
DNAPL decreases.  At the Beach Point Test Site, a high degree of stratigraphic and hydrogeologic
discontinuity has been identified.  As such, it is impractical, if not impossible, to locate all
discontinuities (i.e., minor clay lenses, areas of low permeability, thin sand stringers, and depressions in
the lower confining layer) that may affect residual and free-phase DNAPL distribution on a localized scale.
Subseguently, it is also considered impractical, if not impossible, to accurately determine the location of
all of the DNAPL,  and hence accurately define the DNAPL zone.




At heterogeneous sites, Cohen and Mercer  (1993) state that the "subsurface DNAPL distribution may defy
definition."  For all DNAPL sites, Cohen and Mercer (1993) state that "a detailed delineation of the
subsurface DNAPL distribution is difficult and may be impractical using conventional site   characterization
technigues."

Groundwater from the surficial aguifer is toxic to human health and ecological receptors, and  concentrations
of many VOCs exceed human health RBCs.  Because this groundwater is not being extracted for any purpose
(i.e., drinking water), no routes of exposure to humans currently exist. According to groundwater modeling
conducted by Burton et al. (1994), this groundwater discharges into the Bush River, and dilution and other
attenuation processes  (e.g.,  advection, dispersion, sorption, etc.) appear to result in contaminant
concentrations in the surface waters at nondetectable and/or nontoxic levels (i.e., below both acute and
chronic aguatic life criteria).   For example, groundwater discharge from the Beach Point surficial aguifer is
likely diffused over a relatively large area, thus contributing to the dispersion of the contamination prior
to discharge into a large volume of surface water.  The chosen   remedial alternative for this site (e.g.,
institutional controls and monitoring of the Bush River)  mitigates any potential future exposure to this
contaminated groundwater by prohibiting groundwater use and unauthorized installation of additional
groundwater wells.  Environmental monitoring of the Bush River will determine whether significant increases
in risk are occurring at this site.

    2.6  SUMMARY OF SITE RISKS

To assess current and future human health and ecological risks, the Army prepared a BLRA in 1995 which
evaluated the potential for adverse effects on human health and the environment associated with actual or
potential exposure to site-related chemicals at the Beach Point Test Site.  This BLRA was based upon
groundwater, surface soil, subsurface soil, and sediment data collected at Beach Point. The BLRA is comprised
of a Human Health Risk Assessment  (RA) and an Ecological Risk Assessment  (ERA)).

    2.6.1 Human Health Risk Assessment

The Human Health RA evaluated contaminant concentrations detected in the samples collected during the
Remedial Investigation  (RI)  for this site, 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.    These RA steps

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are summarized below.

Chemicals of Potential Concern (COPCs) were selected at this site by evaluating the contaminant
concentrations and exposure routes for groundwater, surface soil, subsurface soil, and sediment. COPC
identification consisted of comparing maximum contaminant concentrations to the USEPA Region III RBCs, and
for inorganics, conducting a statistical comparison of site and reference concentrations.

No routes of exposure to groundwater are possible under current or anticipated future land-use conditions;
therefore, COPCs for the surficial aquifer were not selected for quantitative evaluation in the RA. (Rather,
a qualitative Human Health RA for the groundwater was conducted which discusses the fact that Beach Point
groundwater currently is not used for any purpose, including drinking water, and that future industrial
workers probably would not utilize this brackish groundwater.) Subsurface soil and sediment chemical
concentrations were compared to industrial soil RBCs and/or reference screening concentrations. All
chemicals in both subsurface soil and sediments were below these screening levels; therefore, no COPCs were
selected for these media. In the surface soil, the only chemical that exceeded its screening concentrations
was arsenic, which was retained as a COPC. The maximum concentration of arsenic in surface soil is 5.1
mg/kg.

The objective of the exposure assessment is to estimate the type and magnitude of potential exposures to the
COPC that is 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 the surface soil by a caretaker
and by a trespasser. Under the future land-use scenario, incidental ingestion and dermal absorption of
chemicals in surface soils by an industrial worker were evaluated. The future risk to trespassers is
identical to those for trespassers under current land-use conditions; therefore, the risk calculations for
trespassers were only conducted once but apply to both scenarios.

The purpose of the toxicity assessment is to assess the toxicological hazards of the COPC 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., 1x10 -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 specific exposure conditions. USEPA's acceptable risk range for cancer is 1x10 -6 to 1x10 -4, meaning
that there is one additional chance in one million (1x10 -6) to one additional chance in 10,000 (1x10 -4)
that a person will develop cancer.

Non-carcinogenic 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 (M) can be generated by adding the HQs
for all contaminants within a medium and provides a useful reference point for gauging 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.

Note that only one COPC, arsenic in surface soils, exists for the Beach Point Test Site Human Health RA;
therefore, the HQ is equivalent to the HI in this analysis.

Table 7 and the following discussion summarize both the carcinogenic and noncarcinogenic risks associated
with exposures to the surface soils at the Beach Point Test Site.

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               TABLE 7.  Cumulative Risks to Humans at Beach Point
                  Under Current and Future Land-Use Conditions
Total Cancer Risk

Incidental Ingestion of Soil
Dermal Contact with Soil
TOTAL CANCER RISK
Current Land-Use Conditions

       CARETAKERS           TRESPASSERS
          8E-08                1E-07
          2E-07                2E-07
          3E-07                3E-07
Noncancer Hazard Index

Incidental Ingestion of Soil
Dermal Contact with Soil
TOTAL HAZARD INDEX

Total Cancer Risk

Incidental Ingestion of Soil
Dermal Contact with Soil
TOTAL CANCER RISK
Noncancer Hazard Index

Incidental Ingestion of Soil
Dermal Contact with Soil
TOTAL HAZARD INDEX
       CARETAKERS
       <1 (4E-04)
       <1 (9E-04)
       <1 (IE-OS)
Future Land-Use Conditions
         WORKERS
         (1E-06)
         (3E-06)
         (4E-06)

         WORKERS
        1 (6E-03)
        1 (1E-02)
        1 (2E-02)
TRESPASSERS
<1 (6E-04)
<1 (9E-04)
<1 (2E-03)

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2.6.1.1 Current Land Use.

Under the current land-use scenario, exposure pathways evaluated include incidental ingestion and dermal
absorption of chemicals in the surface soil by a caretaker and by a trespasser.

The cancer risks for both the dermal and ingestion exposure pathways under assumed current land-use
conditions were well under the lower bound (i.e., 1 x 10 -6) of USEPA's acceptable risk range. In
addition, His were less than one, indicating that adverse noncarcinogenic effects are not likely to result
from exposures through either pathway.

Cumulative risks were calculated for combinations of pathways when it was considered likely that the same
receptor could be exposed via different pathways. Under current land-use conditions, the cumulative risks
for both caretakers and trespassers were below the lower bound of USEPA's acceptable risk range for health
protectiveness at Superfund sites. The cumulative His for caretakers and trespassers were less than one,
indicating that noncarcinogenic effects are not likely to occur as a result of combined exposures.

2.6.1.2. Future Land Use.

Under the future land-use scenario, incidental Ingestion and dermal absorption of chemicals in surface soils
by an industrial worker were evaluated. The future risk to trespassers is identical to those for trespassers
under current land-use conditions; therefore. The risk calculations for trespassers were only conducted once
but apply to both scenarios.

Under future land-use conditions, pathway risks were calculated for an industrial worker. The individual
pathway and cumulative cancer risks to an industrial worker through ingestion and dermal absorption of
chemicals in the surface soil were at the lower end of USEPA's acceptable risk range for health
protectiveness at Superfund sites. Both the individual pathway and cumulative His were less than one,
indicating that noncarcinogenic effects associated with arsenic would not be expected to occur.

2.6.2 Ecological Risk Assessment

COPCs for the ERA were selected at this site by evaluating the contaminant concentrations and exposure routes
for groundwater, surface soil, subsurface soil, and sediment. COPC identification for inorganic compounds
primarily consisted of statistical comparison of site and reference concentrations. All detected organic
compounds were evaluated as possible COPCs. Both organic and inorganic compounds could be eliminated as
COPCs if the chemicals exhibited very low toxicities (unless present at extremely high concentrations) or if
the chemicals were detected in less than 10% of the samples. Essential nutrients were not selected as COPCs
if it was deemed that these compounds were unlikely to adversely affect potential ecological receptors at
detected concentrations.

There are a number of uncertainties associated with the ERA, and they should be kept in mind while
considering the results of this study. The most apparent uncertainty is associated with extrapolating the
potential for adverse effects from individual organisms to populations or communities. The ERA includes
assumptions about individual organisms for the determination of adverse effects on terrestrial species that
are higher up the food chain. There are also some guestions concerning the relevance of the toxicity values
utilized in this ERA to the conditions and potential receptors at Beach Point. Many of the toxicity values
were derived to be protective of sensitive ecological receptors; however, sensitive species are unlikely to
be found in some of the Beach Point habitats.

Based on an analysis of the wildlife species occurring on Beach Point and the COPCs in the environmental
media, the following endpoints were selected for evaluation: 1) the potential for adverse effects to
terrestrial plant communities from direct contact with surface soil; 2) the potential for adverse effects to
terrestrial invertebrate communities (represented by earthworms) from direct contact with chemicals in
surface soil; 3) the potential for adverse effects to small mammals (represented by shrews) from ingestion of
chemicals that have accumulated in terrestrial invertebrates (represented by earthworms) and from direct
ingestion of chemicals in surface soil; 4) the potential for adverse effects to carnivorous birds
(represented by robins) from ingestion of chemicals that have accumulated in terrestrial invertebrates
(represented by earthworms) and from direct ingestion of chemicals in surface soil; 5) the potential for
adverse effects to aguatic life from exposure to chemicals discharging from groundwater to surface water;
and, 6) the potential for adverse effects to aguatic life from direct contact with chemicals in sediment.

Terrestrial plant communities were selected for evaluation based on their potential to be exposed to
chemicals in surface soil. Results of the ERA indicate that the overall viability of terrestrial plant
communities at Beach Point is not being adversely affected by the chemicals in the soil.

Earthworms were selected as the soil invertebrate or terrestrial species most likely to be affected by
chemicals in the soil. Toxicity values were not available for any of the organic COPCs and there is

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uncertainty associated with the potential for these chemicals to adversely affect soil invertebrates. Of the
inorganic COPCs identified for evaluation in the ERA, only mercury has the potential to affect earthworms.
The Reasonable Maximum Exposure (RME) concentration of mercury exceeded its Toxicity Reference Value (TRV),
giving an Environmental Effects Quotient (EEQ) of 5.3. It was concluded that the potential for adverse
effects is localized since the exceedance was highly influenced by one sample having an elevated level of
mercury.

Terrestrial vertebrates may also be exposed to chemicals via several exposure pathways on Beach Point. The
ERA evaluated the potential for adverse affects to shrews and robins from the ingestion of earthworms and
surface soil containing DDT and the metabolites, ODD and DDE. DDTr (i.e., DDT, ODD, and DDE) was selected
because of its potential to accumulate to elevated levels in terrestrial food webs. Based on the analysis in
the ERA, it was concluded that shrews will not be affected by ingestion of earthworms and surface soil.

The Beach Point ERA indicated that robins could be adversely affected by the ingestion of DDTr in earthworms
and surface soil; however, it must be considered that the average DDT and DDE concentrations in the reference
samples (collected as part of the Reference Sampling and Analysis Program (USAEC, 1995)) also exceeded
concentrations that would result in a risk to robins under the exposure scenario evaluated in the Beach Point
ERA. Thus, remediation of Beach Point surface soils is unwarranted because it would not result in a risk
reduction to robins (i.e., robins exposed at Beach Point also would be exposed to DDTr at many other
locations as well). In addition, the risk to robins at Beach Point may have been overestimated by the use of
conservative assumptions in the Beach Point ERA. For example, it was assumed that robins would obtain all
earthworms for food from locations at Beach Point that corresponded to the highest expected chemical
concentrations at this site (based on locations of historical Army activities).

Based on a gualitative evaluation of the pathways by which aquatic life could be exposed to chemicals in
surface water and on the results of a Groundwater Hazard Assessment conducted by Burton et al. (1994), it was
concluded that only very limited effects, if any, are likely to occur to aguatic life in Kings Creek or the
Bush River from the presence of chemicals in the groundwater discharging into the surface water. If
occurring, these adverse effects likely would be localized to the areas around the point of groundwater
discharge. Sediment sampling conducted in 1995 at likely areas of groundwater discharge (see Section 2.5.4
and Figure 6) showed no evidence of chemicals being released through sediments.

With respect to potential adverse effects to aguatic receptors from the presence of chemicals in sediment,
available TRVs were exceeded by RME concentrations of DDTr, 2-methylnaphthalene, and antimony, indicating the
potential for these compounds to cause adverse affects to benthic organisms. However, with the exception of
DDT, which just exceeded the Effects Range-Median (ER-M), the RME concentrations of these chemicals remained
below the ER-M values. TRVs were not available for several organic chemicals detected in sediment and there
is uncertainty associated with the potential for these chemicals to adversely affect benthic organisms.

For the Beach Point Test Site, no endangered or threatened species were identified during the ERA. In
addition, no critical habitats have been identified at APG.

2.7 REMEDIATION OF THE BEACH POINT TEST SITE

The site characterization discussed in the FFS indicated the extreme unlikelihood of surface water
contamination at concentrations toxic to human health and ecological receptors. In addition, there is little
evidence of elevated concentrations of chemicals of concern in sediments, surface soil, and subsurface
soil when compared to off-site background levels. The surficial aguifer, however, is contaminated with
DNAPLs. With respect to remediating this site, the Army focused on the risk of human exposure at Beach
Point, especially through groundwater from the surficial aguifer. The human health risk assessment clarified
that there are no routes of exposure to groundwater under current or likely future land-use conditions, and
therefore, there is no human health risk associated with this contaminated groundwater. Contaminant transfer
from the Beach Point surficial aguifer is mitigated on the northwest side and the neck of the peninsula by
low conductivity silts, but groundwater discharges on the eastern and southeastern side at considerably
reduced concentrations into the Bush River. That is, dilution and other attenuation processes (e.g.,
advection, dispersion, sorption, etc.) appear to result in nontoxic concentrations in the surface waters.
For example, groundwater discharge from the Beach Point surficial aguifer is likely diffused over a
relatively large area, thus contributing to the dispersion of the contamination prior to discharge into a
large volume of surface water. Finally, the U.S. Army Center for Health Promotion and Preventive Medicine
(on behalf of the Office of the Army Surgeon General) stated that there is little environmental exposure at
Beach Point and they believe that human health is protected without any remedial action.

Although no exposure routes to groundwater exist at Beach Point, some groundwater treatment technologies and
containment options were evaluated in the FFS. For example, innovative groundwater treatment technologies
such as Ultraviolet (UV) Oxidation and Air Stripping were considered but were screened out because of the
technical infeasibility of their applications at this site. That is, using current technology, it is not
technically feasible to restore the aguifer to Federal and State drinking water standards (i.e., MCLs) by the

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extraction and subsequent treatment of groundwater because the pooled and residual DNAPL present in the
aquifer will continue to dissolve and release contamination. Further, it is technically infeasible to
sufficiently remove the DNAPL zone at this site. The Beach Point FFS also screened out In-Situ
Dehaloqenation which combines the use of an impermeable barrier such as sheet pilinq to divert the
qroundwater to a permeable barrier containing iron filings. This process treats chlorinated organic
compounds in the groundwater; however, PCA has been shown to be difficult to treat with iron filings. Also,
the iron dechlorinates PCA to cis-l,2-DCE, which is also toxic (albeit less toxic than PCA). Moreover, the
use of containment through emplacement of vertical barriers by themselves or combined with In-Situ
Dehalogenation gives rise to several concerns. The potential exists for leakage resulting from the
deformation and separation of the sheet piling as it is installed to a depth of 70 feet. Improper placement
of the barrier may result in the movement of contaminated groundwater around or under the wall, as well as in
the inadvertent disruption and mobilization of the DNAPL mass resting on the confining layer.

Although the FFS detailed the extreme technical difficulty associated with some containment options, the TI
Waiver expands on this discussion (as requested by MDE) and includes evaluation of more containment options.
The TI Waiver was prepared according to USEPA guidelines, and is applicable to Beach Point because of the
technical impracticability associated with remediating this DNAPL-contaminated aquifer to Federal or State
drinking water quality criteria or standards, which are ARARs. In addition, it was deemed technically
infeasible to contain this DNAPL contamination. The finalization of this document results in the waiving of
the requirement to comply with Federal and State MCLs and the State groundwater policies that provide, among
other things, that no waste is discharged into any State water without treatment or corrective action, and
that existing water pollution be abated or controlled.

Like the FFS, the TI Waiver concludes that pumping and treating would not provide long-term restoration of
the groundwater due to the presence of the DNAPL zone. Therefore, clean-up to MCLs cannot be feasibly
accomplished and the State groundwater policies will not be satisfied. Passive containment (e.g., a slurry
wall and cap structure) of the DNAPL zone that acts as a source of the dissolved contaminant plume is not
feasible due to the presence of unexploded ordnance (UXO) and the inability to clear such ordnance in the
offshore regions of the DNAPL zone that underlay the Bush River. Active hydraulic containment of the DNAPL
zone is infeasible due to the presence of multiple preferential flow paths within the aquifer and the
cyclical tidal effects on the groundwater flow patterns. Furthermore, requisite hydraulic gradients necessary
to initiate movement (for containment or removal) of residual pooled DNAPL cannot be created at this site.
Restoration of the dissolved plume in the aquifer is not technically practicable if the DNAPL zone cannot be
99% removed or contained because the DNAPL zone will provide a continuous source of contaminants to the
plume.

Based on the aforementioned information, the Army and USEPA developed remedial action objectives which
primarily focus on the contaminated groundwater from the surficial aquifer and which do not involve
groundwater treatment or containment. These objectives define a realistic management of risk and are
protective of human health and the environment.

2.7.1 Description of the Alternatives

2.7.1.1 Alternative 1: No Action.

Under the No Action Alternative, no remedial action is undertaken to remedy the contaminated groundwater from
this Class IIB aquifer. The No Action Alternative excludes all activities, including institutional controls
such as monitoring and prohibitions on groundwater use. The timeframe for natural restoration is expected to
be well over 100 years due to the DNAPL contamination.

The No Action Alternative has no capital costs associated with it, since it does not require any
activities to be initiated. The site evaluation report, which summarizes the results of the 5-year review,
will cost approximately $40,000 per each review.

2.7.1.2 Alternative 2: Institutional Controls.

Under the Institutional Controls Alternative, the general response actions to be implemented include the
following.

• Access Restrictions. Access restrictions to the Beach Point Test Site for ground surface
usage do not appear to be necessary. The RI showed no surface soil contamination at
levels of concern. In a few locations, very low levels of contaminants were found in the
deeper soil. This alternative would include the posting of signs prohibiting unauthorized
excavation, digging, and groundwater well installation. Authorization would then
require testing and monitoring to ensure worker safety. The prohibition against
unauthorized groundwater well installation is important in order to mitigate the potential
risks of remobilizing any pooled DNAPL as well as exposing people to contaminated

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groundwater.

• Prohibition of Groundwater Use. Groundwater from the surficial (Class IIB) aquifer
beneath the Beach Point Test Site is significantly contaminated with DNAPLs. The use
of this groundwater would be prohibited for all purposes. Groundwater on the APG-EA
site (which includes the Beach Point Test Site) currently is not used for drinking water,
and there are no plans for future use of the Beach Point surficial aguifer for this purpose
either. As previously described, the hydrogeological conditions at Beach Point result in
a general lack of continuity of the surficial aguifer with any other aguifers; therefore,
contaminant transfer from this aguifer to another is naturally mitigated. All site
restrictions, including the prohibition of groundwater use, would be inputted into APG's
GIS, which is utilized in the development of APG's Real Property Master Plan. These
use restrictions/prohibitions would be incorporated into any real property documents
necessary for transferring ownership from the Army, in the unlikely event that the Army
sells this property. The real property documents would also include a discussion of the
NPL status of this site, as well as a description of the groundwater and very limited soil
contamination at this site. In addition, the Director of DSHE will certify to USEPA on
an annual basis that there have been no violations of the prohibitions. If a violation has
occurred, a description of the violation and corrective actions to be taken will be
provided.

• Monitoring. Environmental monitoring of the Bush River would be initiated in order to
ascertain whether increases in risk are occurring at this site. This program could include
chemical analyses and bioassessments of surface water and sediment samples; however,
the exact monitoring program (including media sampled, target analytes, number of
samples, freguency and location of sampling, and deliverables) will be determined
during the workplan development phase and will be approved by USEPA and MDE prior
to implementation.

Assuming an annual monitoring program involving both surface water and sediment sampling, the estimated costs
for Alternative 2 are as follows:

Capital Costs: $2,025

O&M Costs: $68,640

Estimated Present Worth (5% Discount Rate for 30 years): $1,055,165.

Tables 8 and 9 detail the assumptions and methodology for estimating the construction and O&M costs
associated with the Institutional Controls Alternative. This cost estimate assumes that the monitoring
program will continue for 30 years; however, the duration of the monitoring program will be dictated by the
results of each reguired 5-year review.

2.7.2 Summary of Comparative Analysis of Alternatives

The remedial alternatives presented in Section 2.7.1 were evaluated in accordance with the regulatory
reguirements of CERCLA using the nine criteria specified by USEPA as set forth in the NCP (see Table 10).
This section summarizes the relative performance of each remedial alternative with respect to these criteria.

2.7.2.1 Threshold Criteria.

• Overall Protection of Human Health and the Environment. Alternative 2, Institutional
Controls, offers mitigation of risks to humans associated with any potential future use of
the Beach Point Test Site. Specifically, the implementation of Alternative 2 involves the
prohibition of: groundwater use; unauthorized installation of groundwater wells; and
unauthorized soil excavation. Although the risk assessment results do not indicate a risk
posed to human health and the environment, uncertainties with respect to the
environment exist for some chemical concentrations in the surface water. These
potential risks to the environment will be addressed in Alternative 2 through a
monitoring program for the Bush River. In addition, implementation of Alternative 2
does not result in the creation of any pathways leading to exposure to humans.
Alternative 1 (No Action) does not provide complete long-term protection to public
health because it does not prohibit/restrict potential future excavation, groundwater well
installation, and use of the groundwater from the surficial aguifer.

• Compliance with ARARs. Section 121(d) of CERCLA reguires that remedial actions at
CERCLA sites at least attain legally applicable or relevant and appropriate Federal and

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State standards, requirements, criteria, and limitations which are collectively referred to
as "ARARs," unless such ARARs are waived under CERCLA Section 121(d)(4).

Applicable requirements are those clean-up standards, standards of control, or other
substantive requirements, criteria, or limitations promulqated under Federal
environmental or State environmental law or facility sitinq laws that specifically address
hazardous substances, pollutants, contaminants, remedial actions, locations, or other
circumstances at a CERCLA site.  Relevant and appropriate requirements are those same
requirements that, while not directly applicable at a CERCLA site, address problems or
situations sufficiently similar to those encountered that their use is well suited to the
particular site.  Only those State standards that are identified in a timely manner and are
more strinqent than Federal requirements may be relevant and appropriate.  On-site
actions must comply with ARARs, but need comply only with the substantive parts of
those requirements.  By contrast, off-site actions must comply with legally applicable
requirements, includinq both the substantive and the administrative parts of those
requirements.

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                                   TABLE 8.  Estimated Capital Cost for the Selected Remedial

                                      Strategy, Institutional Controls
Item No.           Description            Quantity       Unit of Measure     Unit Cost $         Item Cost $                      Reference
   1      Posting of signs                    1              lump sum                    1,500               1,500       Engineer's estimate
Subtotal estimated construction cost                                                     1,500
Bid contingency (15%)                                                                       225
Scope contingency (20%)                                                                     300
Total capital cost                                                                       2,025
Permitting and legal (0%)                                                                     0
Servicing during construction (0%)                                                            0
Design cost  (0%)                                                                              0
Total estimated capital cost                                                             2,025

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                       TABLE 9.  Estimated Annual O&M Cost for the Selected Remedial
                                Strategy, Institutional Controls
Item No.      Description                         Quantity
   1          Annual sampling and analysis of
              surface water
   2          Annual sampling and analysis of
              sediments
Subtotal of Items 1 and 2 (Total Analytical Cost)
   3          QC samples associated with all
              sampling
   4          Annual reports to regulatory agencies
   5          5-year evaluation reguired by EPA.
              Assume 1/5 of report charged each year
Subtotal estimated annual O&M cost
Scope contingency (20%)
Total estimated annual O&M cost
                                     Item Costs $
           10
           10
40% of the total analytical cost

            1
          0.2
12,000

16,000

28,000
11,200

10,000
 8,000

57,200
11,440
68,640

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    TABLE 10:  USEPA EVALUATION CRITERIA FOR REMEDIATION ALTERNATIVES
Overall Protection of Human Health
and the Environment addresses
whether a clean-up 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.

Compliance with ARARs addresses
whether a clean-up method will meet all
applicable or relevant and appropriate
requirements (Federal and State
environmental requirements).

Long-Term Effectiveness and
Permanence is the ability of a clean-up
method to maintain reliable protection of
human health and the environment over
time, after the action is completed.

Reduction of Toxicity, Mobility, or
Volume Through Treatment is the
anticipated ability of a clean-up method
to reduce the toxicity, mobility, or
volume of the hazardous substances
present at the site through treatment.
Short-Term Effectiveness addresses the
period of time needed to complete the
clean-up, and any adverse impacts on
human health and the environment that
may occur during the construction and
operation period.

Implementability is the technical and
administrative feasibility of a clean-up
method, including the availability of
materials and services required by the
method.

Cost includes the estimated capital and
operation and maintenance costs of each
clean-up method.

State Acceptance indicates whether the
State of Maryland agrees with the
preferred clean-up method.

Community Acceptance indicates
whether public concerns are addressed
by the clean-up method, and whether the
community has a preference for a clean-
up method.  Public comment is an
important part of the final decision.

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Chemical-Specific ARARS. Because USEPA has determined that it is technically
impracticable to remediate and/or contain the DNAPL contamination of the surficial
aquifer, a TI Waiver has been issued for ARARs applicable to groundwater at this site.
Neither of the two alternatives will result in compliance with all groundwater ARARs.
The groundwater ARARs to be waived are the Federal Safe Drinking Water Act MCLs
and MCLGs at 40 CFR 141.11-12, 141.50-51, and 141.61-62, which are adopted by the
State of Maryland in COMAR 26.04.01 Regulation of Water Supply, Sewage Disposal,
and Solid Waste. Other ARARs to be waived are State groundwater policies at
Annotated Code of Maryland, Title 9, Subtitle 3, Water Pollution Control, Sections 9-
302 and 9-322; and Annotated Code of Maryland, Title 4, Subtitle 4, Water Pollution
Control and Abatement, Section 4-402. These groundwater policies: 1) prohibit waste
discharge into any State waters without treatment or corrective action and 2) require the
abatement and control of existing pollution.

Contaminants in the groundwater being discharged into the Bush River, as modeled, do
not cause exceedances of surface water quality criteria for both Alternatives 1 and 2;
therefore, compliance with chemical-specific ARARs for the surface water would likely
be achieved for both alternatives. These ARARs are the water quality standards adopted
by the State of Maryland and approved by USEPA pursuant to 40 CFR Part 131 (Water
Quality Standards) and promulgated at COMAR 26.08.02.03-2. In addition, the AWQC
publication from USEPA (1986) includes recommended numerical water quality criteria
for some substances that are not included in the above-mentioned State regulations. The
AWQC are also likely to be met at this site. These standards are To Be Considered
(TBC) requirements and not ARARs.

Location-Specific ARARS. There are no location-specific ARARs for this site.

Action-Specific ARARs. Alternative 2 would have to comply with the following
regulations to ensure worker safety and the proper handling and disposal of any
hazardous waste generated during the implementation of the monitoring program:
Occupational Safety and Health Administration (OSHA) regulations at 29 CFR Part
1910 (Occupational Safety and Health Standards) and 29 CFR Part 1926 (Safety and
Health Regulations for Construction); and State of Maryland regulations at Title 26
(Environment), Subtitle 13 (Disposal of Controlled Hazardous Substances), including:
COMAR 26.13.02 (Identification and Listing of Hazardous Wastes); COMAR 26.13.03
(Standards Applicable to Generators of Hazardous Wastes); and COMAR 26.13.04
(Standards Applicable to Transporters of Hazardous Wastes). All hazardous wastes
generated must be disposed of at a Hazardous Waste Disposal Facility that meets the
requirements of COMAR 26.13.05 (Standards for Owners and Operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities).

2.7.2.2 Primary Balancing Criteria.

• Long-Term Effectiveness. In the long-term, with both alternatives, permanent
restoration would be achieved through natural degradation and flushing of contaminants.
The timeframe for natural restoration is expected to be well over 100 years due to the
DNAPL contamination.

The magnitude of the residual risk remaining from the untreated groundwater is expected
to be of the same order for the two alternatives. The adequacy and reliability of
institutional controls, which primarily are imposed to protect against exposure to the
risks posed by untreated chemicals in groundwater, is considered high since the
managing authority is the Army and the site is expected to remain a part of APG-EA.

• Reduction of Toxicity, Mobility, and Volume. Neither Alternative 1 nor 2 reduces
toxicity, mobility, and volume because there is no treatment associated with these
alternatives.

• Short-Term Effectiveness. Alternative 1 does not require any activity; therefore, there
are no short-term adverse impacts that may be posed during the implementation period.
Any adverse short-term effects associated with the implementation of Alternative 2 will
be minimized to the maximum extent practicable through the use of protective measures.
For example, site workers tasked with installing signs and collecting surface water
and/or sediment samples will utilize all appropriate safety clothing and employ safe
work practices.

• Implementability. Alternative 1 takes no time to implement because no action is

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required. Alternative 2 could be set for implementation within several weeks notice, and
could be completed within a month after initiation of the required activities.
Implementability is hiqh because the treatment of the qroundwater is not required and
use restrictions/prohibitions would be coordinated with personnel workinq at APG-EA.
Time will be needed for the coordination of the use restrictions/prohibitions and the
development of the Bush River monitorinq proqram.

Cost. The costs associated with Alternative 1 would be approximately $40,000 for the
preparation of a each required 5-year review report. Alternative 2 has an estimated
construction cost of $2,025, estimated annual O&M costs of $68,640, and estimated
present-worth costs over 30 years (at a 5% discount rate) of $1,055,165. These
estimated O&M and present-worth costs are based on an assumed monitorinq proqram
includinq 30 years of annual samplinq of sediments and surface water.
2.7.2.3. Modifyinq Criteria.

• State/Support Aqency Acceptance, MDE has not contested the TI Waiver, and thus has
acknowledqed the ability of the Army and USEPA to waive ARARs for qroundwater.
Consequently, the MDE has concurred with the selected remedy.

• Community Acceptance. Public input on the Institutional Controls Alternative has been
favorable and supportive. The public's comments are summarized and discussed in the
Responsiveness Summary (see Section 3.0 of this document).

2.7.3 The Selected Remedy

The selected remedy for the Beach Point Test Site is Alternative 2, Institutional Controls, because it best
satisfies the threshold criteria of Overall Protectiveness of Human Health and the Environment. Compliance
with qroundwater ARARs is beinq waived due to the technical impracticability of restorinq this qroundwater.
Other criteria are also well satisfied by this Alternative.

Implementation of Institutional Controls would involve prohibition of qroundwater use, the postinq of siqns
prohibitinq unauthorized qroundwater well installation and soil excavation, and inputtinq these
restrictions/prohibitions into APG's GIS which is utilized in the development of APG's Real Property Master
Plan. In addition, these restrictions/prohibitions would also be incorporated into any real property
documents necessary for transferrinq ownership from the Army, in the unlikely event that the Army sells this
property. The real property documents would also include a discussion of the NPL status of this site, as
well as a description of the qroundwater and very limited soil contamination at this site. The Director of
DSHE will certify to USEPA on an annual basis that there have been no violations of the prohibitions. If a
violation has occurred, a description of the violation and corrective actions to be taken will be provided.
These safequards are necessary in order to prevent exposure risks associated with contaminated qroundwater
and subsurface soils. This alternative also will include monitorinq of the Bush River to determine whether
siqnificant increases in risk to the environment are occurrinq at this site.

Alternative 2 provides a hiqh level of overall lonq- and short-term protection to human health and the
environment.

Althouqh Alternative 2 does not remove chemicals from the qroundwater or soil, implementation of this
alternative achieves substantial risk reduction for potential human exposure by prohibitinq qroundwater use,
unauthorized qroundwater well installation, and unauthorized soil excavation.

For Alternative 2, as is the case with Alternative 1, protection of the environment is not an issue since
naturally discharqinq qroundwater, as modelinq has shown, is not likely to cause water quality standards to
be exceeded or be toxic to benthic biota in the Bush River. Alternative 2 includes a monitorinq proqram in
order to ensure that risks to the environment are not increasinq at this site.

Alternative 2 can be implemented quickly even thouqh some time will be needed for coordination of the use
restrictions/prohibitions and the development of a monitorinq proqram. The environmental proqram for
monitorinq the Bush River could be established in a reasonable period of time.

The costs associated with the implementation of Alternative 2 are estimated to be $1,055,165. These costs
exceed those associated with Alternative 1; however, Alternative 2 will result in the mitiqation of any
potential risks associated with future exposures to qroundwater and/or soil. MDE concurs with the selection
of Alternative 2 as the remedy for this site. In addition, public input has been favorable and supportive.

2.7.4 The Statutory Determinations

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The selected remedy discussed in Section 2.7.3 satisfies the requirements under Section 121 of CERCLA for
protecting human health and the environment, utilizing permanent solutions, and cost-effectiveness. The
other statutory requirements for: 1) complying with ARARs; 2) utilizing alternate treatment/resource
recovery technologies to the maximum extent practicable; and 3) using treatment to address the principal
threats at the site, could not be satisfied because of the technical impractibility associated with
remediating and/or containing the DNAPL contamination at this site.

2.7.4.1 Protection of Human Health and the Environment.

The selected remedy, Alternative 2, offers mitigation of risks to humans associated with any potential future
use of the Beach Point Test Site. Although the risk assessment results do not indicate an unacceptable
level of risk to human health and the environment, some uncertainties with respect to the environment exist
for some chemical concentrations in the Bush River. These potential risks to the environment will be
addressed in Alternative 2 through a monitoring program of the Bush River. In addition, implementation of
Alternative 2 does not result in the creation of any pathways leading to human exposure. Any adverse
short-term effects associated with the implementation of this alternative will be minimized to the maximum
extent practicable through the use of protective measures. For example, site workers tasked with installing
signs and/or collecting samples for the monitoring program will utilize all appropriate safety clothing and
employ safe work practices.

2.7.4.2 Compliance with ARARs.

There are no location-specific ARARs for the selected remedy at this site because no site disturbances (of,
for example, the wetlands) will result from implementation of this remedy. The action-specific ARARs apply
because workers involved in the sign installation and the monitoring program will need to comply with OSHA
standards as appropriate. In addition, any samples collected as part of the monitoring program will need to
be disposed of according to State RCRA requirements in the event that these samples are deemed hazardous
waste. The action-specific ARARs that apply are listed and described in Table 11.

As previously discussed, Burton et al. (1994) found that surface water quality criteria likely will not be
exceeded in the Bush River as a result of groundwater from the surficial aquifer discharging into the Bush
River. Thus, the chemical-specific ARARs listed in Table 12 for surface water will be met at this site. In
addition, these ARARs may have limited application in that they may be used as the standard against which
analytical results from the monitoring program will be compared in order to assess compliance.

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           ARARs

OSHA-Occupational Safety and Health
Standards
(29 CFR 1910)
TABLE 11: Action-Specific ARARs

                 Status

        Applicable
OSHA-Safety and Health Regulations for      Applicable
Construction
(29 CFR 1926)

COMAR 26.13.02-05                           Applicable
             Requirement

These regulations specify general worker
safety requirements.   Among other things,
these regulations specify the 8-hr time-
weighted average concentration for various
organic compounds.  Training requirements
for workers at hazardous waste operations
are specified in 29 CFR 1910.120.

This regulation specifics the type of safety
equipment and procedures to be followed
during site remediation.

The State RCRA regulations apply to the
generation, transport, storage, treatment,
and disposal of hazardous waste.  CERCLA
specifically requires (in Section
104(c)(3)(B))  that hazardous substances
from remedial actions be disposed at
facilities in compliance with Subtitle C of
RCRA; COMAR 26.13.05 stipulates the
requirements for a Hazardous Waste
Disposal Facility in Maryland.

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                        TABLE 12:   Chemical-Specific ARARs for Surface Water

           ARARs                                     Status                         Requirement

COMAR 26-08.02.03-2                         Applicable                 This State regulation specifies
                                                                       the numerical criteria for toxic
                                                                       substances in surface waters.

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In addition to the above-mentioned ARARs, the numerical water quality criteria listed in the AWQC publication
(1986) also likely will be met for the surface waters at this site. The AWQC publication presents
recommended numerical water quality criteria for some substances that are not listed in the above-mentioned
State requlations. These criteria have not been promulqated, so they are not ARARs but rather TBCs.

With respect to qroundwater, not all of the chemical-specific ARARs will be met within a reasonable
timeframe; therefore, compliance with qroundwater ARARs is waived due to the technical impracticability
associated with remediatinq and/or containinq the DNAPL contamination at this site. That is, usinq current
technoloqy, it is not technically feasible to restore the surficial aquifer at this site to MCLs by
extraction and treatment because the DNAPL zone present in this aquifer cannot be 99% removed. Unremoved
DNAPL pools, qlobules, and residual droplets serve as a continuinq source for the dissolved phase. In
addition, containment options, includinq both active and passive containment, were found to be technically
impracticable for a number of reasons (see Section 2.7 for a detailed discussion). Federal and State
qroundwater ARARs to be waived are as follows:

• Federal Safe Drinkinq Water Act requlations applicable to drinkinq water supplies and
systems establishinq MCLs and MCLGs (40 CFR 141.11-12, 141.50-51, and 141.61-62);

• Title 26, Subtitle 04, Requlation of Water Supply, Sewaqe Disposal, and Solid Waste
(COMAR 26.04.01) - these State requlations are based on the above-mentioned Federal
drinkinq water standards;

Annotated Code of Maryland, Title 9, Subtitle 3, Water Pollution Control, Section 9-302;

Annotated Code of Maryland, Title 9, Subtitle 3, Water Pollution Control, Section 9-322; and,

• Annotated Code of Maryland, Title 4, Subtitle 4, Water Pollution Control and
Abatement, Section 4-402.

These aforementioned citations of the Annotated Code of Maryland comprise the State's qroundwater policies
of: 1) prohibitinq discharqe of waste into any State waters without treatment or corrective action and 2)
abatinq and controllinq existinq pollution.

2.7.4.3 Cost-effectiveness.

The selected remedy is cost-effective because it has been determined to provide overall effectiveness
proportional to its costs (the estimated present-worth cost is $1,055,165). The selected remedy is more
cost-effective than Alternative 1 (No Action) because the implementation of Alternative 2 results in the
mitiqation of any potential risks associated with future human exposures to qroundwater and/or soil. In
addition, implementation of Alternative 2 ensures the determination of any increases in risks to the
environment at this site. Thus, the selected remedy provides the best balance of features that offer overall
protection to human health and the environment.

2.7.4.4 Utilization of Permanent Solutions and Alternative Treatment Technoloqies to the
Maximum Extent Practicable.

This remedy utilizes permanent solutions as currently available to the maximum extent practicable for this
site. However, because treatment of the DNAPL contamination was not found to be technically practicable,
this remedy does not satisfy the statutory preference for utilizinq alternative treatment or resource
recovery technoloqies to the maximum extent practicable. Specifically, innovative qroundwater treatment
technoloqies such as UV Oxidation and Air Strippinq were considered in the FFS but were screened out because
MCLs cannot be met if the DNAPL zone cannot be 99% removed. Further, it is technically infeasible to remove
the DNAPL source at this site. The Beach Point FFS also screened out In-Situ Dehaloqenation which combines
the use of an impermeable barrier such as sheet pilinq to divert the qroundwater to a permeable barrier
containinq iron filinqs. This process treats chlorinated orqanic compounds in the qroundwater; however, PCA
has been shown to be difficult to treat with iron filinqs. Also, the iron dechlorinates PCA to cis-l,2-DCE,
which is also toxic (albeit less toxic than PCA). Moreover, the potential exists for leakaqe which results
from the deformation and separation of the sheet pilinq as it is installed to a depth of 70 feet. Improper
placement of the barrier may result in the movement of contaminated qroundwater around or under the wall, as
well as in the inadvertent disruption and mobilization of the DNAPL mass restinq on the confininq layer.

2.7.4.5 Preference for Treatment as a Principal Element.

The selected remedy for this site does not satisfy the CERCLA requirement for utilizinq treatment as a
principal element. The aforementioned justification for technical impracticability as discussed in Section
2.7.4.4 clarifies why this preference is not met at this site.

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    2.8  SUMMARY OF PERFORMANCE STANDARDS

       •      At least one sign will be posted at the Beach Point Test Site which will state the
              prohibition of unauthorized excavation and unauthorized groundwater well installation.
              The exact number of,  location of, and wording for the signs will be determined during
              the workplan development phase and will be approved by USEPA and MDE prior to
              implementation.

       •      A prohibition on all  groundwater uses will be imposed.   All site restrictions will be
              inputted into APG's GIS, which is utilized in the development of APG's Real Property
              Master Plan.  All use restrictions/prohibitions will be incorporated into any real property
              documents necessary for transferring ownership from the Army, in the unlikely event
              that the Army sells this property.  The real property documents would also include a
              discussion of the NPL status of this site, as well as a description of the groundwater and
              very limited soil contamination at this site.  In addition, the Director of DSHE will
              certify to USEPA on an annual basis that there have been no violations of the
              prohibitions.  If a violation has occurred, a description of the violation and corrective
              actions to be taken will be provided.

       •      A monitoring plan for the Bush River will be developed and implemented,  and will
              include the sampling and analyses of affected media, such as sediments and surface
              water.  Analyses could include both chemical analyses as well as bioassessments;
              however, the specifies of the monitoring program (i.e., media sampled, target analytes,
              number of samples, freguency and location of sampling,  and deliverables) will be
              determined during the workplan development phase and will be approved by USEPA
              and MDE prior to implementation.

       •      A 5-year review will  be conducted in order to evaluate continuing protectiveness of
              human health and the environment.  Each reguired 5-year review will culminate in the
              preparation of a report.  Specifically, the effectiveness of the selected remedy will be
              reviewed, and a determination will be made as to whether adverse changes in risk have
              occurred at this site.  Determination of increases in risk will involve an in-depth
              evaluation of the monitoring data.  At that point in time, the 5-year review report may
              recommend the continuation of the monitoring program for another 5 years (until the
              next review), a continuation of the monitoring program with changes in the protocol, or a
              cessation of the monitoring program.  In addition,  the effectiveness of the signs and use
              restrictions will be evaluated and changes may be recommended at that time.


    3.0  THE RESPONSIVENESS SUMMARY

The final component of the ROD is the Responsiveness Summary.  The purpose of the Responsiveness Summary is
to provide a summary of the public's comments, concerns, and guestions about the groundwater at APG's Beach
Point Test Site and the Army's responses to these concerns.

During the public comment period, written comments were received by APG.

APG held a public meeting on May 20, 1997 to formally present the Proposed Plan and to answer guestions and
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 USEPA in selecting the final
clean-up remedy for the Beach Point Test Site.

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 the public comment period and APG's responses.
    3.4  Sample newspaper notice announcing the 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 groundwater at the Beach Point Site.  APG proposed:  1) prohibitions on groundwater use and unauthorized
excavation and 2) monitoring of the Bush River surface water and sediments. USEPA concurred with the
preferred alternative, and MDE stated that it would finalize its position after reviewing public comments.
The State's final position is as follows:  MDE has not contested the TI Waiver, and thus has acknowledged the

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ability of the Army and USEPA to waive ARARs for groundwater.   Consequently, the MDE has concurred with the
selected remedy.  With the exception of one comment, public input on the preferred alternative has been
favorable and supportive.

    3.2  BACKGROUND ON COMMUNITY INVOLVEMENT

Citizens' involvement in the Beach Point Site has encompassed numerous discussions at Restoration Advisory
Board  (RAB)  meetings  (formerly Technical Review Committee  (TRC) meetings) and comments by the APG Superfund
Citizens Coalition  (APGSCC).   APGSCC is the recipient of two Technical Assistance Grants from USEPA.  In a
recent RAB meeting, a citizen questioned whether APG had thoroughly investigated all available technologies
for remediating this site.  He was assured that a thorough evaluation was conducted, and that this site is
technically infeasible to clean- up.

APGSCC raised several concerns prior to the finalization of the Proposed Plan.  These issues primarily
focused on the overall readability of the Proposed Plan, MDE's nonconcurrence at that time on the preferred
alternative, and the BLRA.  These concerns either were addressed in a written response to    APGSCC and/or
through editorial changes to the Proposed Plan.

APG has maintained an active public involvement and informatiom program.  Highlights of the community's
involvement with respect to this site and APG's activities during the last two years are as follows:

•      APG began discussing possible clean-up methods for the  Beach Point Test Site at TRC
       meetings in January 1993.  Dates of other TRC/RAB meetings where APG presented
       information on the Beach Point Site are May 1995, November 1995, April 1996, and February 1997.

•      APG released the Proposed Plan for the Beach Point Site for public comment on May 7.
       Copies were available to the public at APG's information repositories at the Aberdeen and
       Edgewood Branches of the Harford County Library, and the Miller Library at Washington
       College in Chestertown, Maryland.

•      A 45-day public comment period on the Proposed Plan ran from May 7 to June 20.

•      APG issued a press release to APG's media list which announced the availability of the
       Proposed Plan, the dates of the public comment period,  and the date and time of the public
       meeting.  In addition, a story appeared in the APG News.

•      APG placed newspaper advertisements announcing the public comment period and meeting
       in The Aegis, the Cecil Whig, The Avenue, and the Kent County News.

•      APG prepared and published a fact sheet on the Proposed Plan.  APG mailed copies of this
       fact sheet to over 2,590 citizens and the elected officials on its Installation Restoration
       Program mailing list.   The fact sheet included a form which citizens could use to send APG
       their comments.

•      On May 20,  APG held a public meeting at the Edgewood Senior Center in Edgewood,
       Maryland.  Representatives of the Army, USEPA, and the MDE presented information on
       the site and their respective positions on the proposed clean-up alternatives.

    3.3  SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND AGENCY RESPONSES

Comments raised during the Beach Point public comment period on the FFS and the Proposed Plan are summarized
below.  The comments are categorized by source.

    COMMENTS FROM QUESTIONNAIRE INCLUDED WITH FACT SHEET

As part of its fact sheet on the Proposed Plan, APG included a questionnaire that residents could return with
their comments.  APG received 7 completed returns, and copies of them have been placed in APG's
administrative record.  Responses on the completed returns were:

            6    Agree with Proposed Plan - No Written Comment Provided
            1    Disagrees with Proposed Plan
            0    Have no preference.

The commenter who disagreed with the Proposed Plan is an Edgewood resident, and this comment is summarized
and discussed as follows.

Comment 1:  Both Alternatives 1 and 2 seem quite similar.  Selecting Alternative 2  (institutional Controls)

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for this site results in ignoring the problem and trying to prevent the use of contaminated resources.

Response: APG understands this citizen's concern with respect to not selecting a remedy that incorporates
pump and treat and/or containment technologies at this site. APG conducted a thorough evaluation of
treatment and containment technologies for the FFS. The TI Waiver summarizes additional investigations
into containment options (see Appendix J of the FFS). The specific conditions of this site result in the
technical impracticability of remediating this site to all groundwater standards, as well as effectively
containing the DNAPL zone. That is, current technology does not offer a solution for remediating this site
and/or containing the DNAPL zone because a significant amount of pooled DNAPL contamination exists 70 feet
from the ground surface and most likely underneath the Bush River. Technical problems posed include:
removing the DNAPL zone to a 99% level; clearing UXO from the Bush River in an attempt to institute
containment measures; multiple preferential flow paths within the aguifer; and cyclical tidal effects on
groundwater flow patterns. After finalization of the ROD, a 5-year review will be conducted which will
evaluate continuing protectiveness of human health and the environment. Specifically, the effectiveness of
the selected remedy will be reviewed, and a determination will be made as to whether adverse changes in risk
have occurred at this site.

COMMENTS FROM RAB MEMBERS

As part of its efforts to involve the public in decisions as early as possible, APG provided RAB members with
drafts of the Proposed Plan. One member provided comment to APG and concurred with the preferred alternative
of Institutional Controls. Another member commented on the Final FFS and stated that he concurred with the
selection of Institutional Controls as the "most appropriate measure to implement until further technological
advances" would allow for compliance with MCLs. Following review of the Final Proposed Plan, the RAB
representative from the Baltimore County Department of Environmental Protection and Resource Management
stated that he agreed with "the proposed alternative to prohibit excavations and impose groundwater use
restrictions in the Canal Creek Study Area." These comments have been placed in APG's administrative record.

COMMENTS AT MAY 20,1997 PUBLIC MEETING
No oral or written comments were presented at the May 20 public meeting on the Proposed Plan. A full
transcript of the meeting is part of APG's administrative record.

COMMENTS FROM APGSCC

In August 1996, APGSCC submitted comments on a working draft of the Beach Point Proposed Plan. As previously
stated, APGSCC's comments primarily focused on the overall readability of the Proposed Plan, MDE's
nonconcurrence at that time on the preferred alternative, and various clarifications on technigues and
methodologies employed in the development of the BLRA. These comments, as well as APG's written response to
them, have been placed in the administrative record.

COMMENTS FROM MARYLAND DEPARTMENT OF THE ENVIRONMENT

During the public comment period, MDE submitted one minor editorial comment on the Proposed Plan. MDE also
submitted two comments on the TI Waiver. These comments have been placed in APG's administrative record.

Comment 1: On page 16, first column, and first line of the Proposed Plan, MDE reguested a change to the
title of Subtitle 4. The title of Subtitle 4 is "Water Pollution Control and Abatement" rather than "Water
Pollution Control and Containment" as stated in the Proposed Plan.

Response: APG will provide an errata to the Beach Point Test Site Final Proposed Plan which reflects this
change.

Comment 2: MDE noted that the surficial aguifer at the Beach Point Test Site was assigned a Class IIB
designation, and therefore is a potential source of usable groundwater. Page J-88, Section 3.4 of the TI
Waiver should be amended to reflect this information.

Response: APG recognizes that the following statement in Section 3.4 of the TI Waiver is not correct: "The
aguifer unit at the site is not a potential source of drinking water..." APG acknowledges MDE's position on
classifying this groundwater resource as a Class IIB potential drinking water source; however, the TI Waiver
correctly states that this groundwater resource would reguire significant amounts of treatment prior to use
as drinking water (even if it were not contaminated with DNAPLs). In addition, the amount of water that can
be obtained from the aguifer is low. Corrected language will be included in an errata to the Final Beach
Point Test Site FFS Technical Impracticability Evaluation.

Comment 3: MDE reguests that Title 9, Subtitle 3, Section 9-322 be added to the list of Annotated Code
of Maryland citations presented in Section 4-1 on page J-109 of the TI Waiver. This citation, along with
Title 4, Subtitle 4, Section 4-402 and Title 9, Subtitle 3, Section 9-302 comprise the State's groundwater

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policy.

Response:  APG included Title 9, Subtitle 3, Section 9-322 as an ARAR to be waived in the Final Proposed
Plan for this site, but the TI Waiver was finalized prior to the decision to waive this ARAR.  An effata to
the Final Beach Point Test Site FFS Technical Impracticability Evaluation will reflect the addition of this
citation (Title 9, Subtitle 3, Section 9-322) to the list of citations which the comprise State's groundwater
policy.

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4.0 REFERENCES

Annotated Code of Maryland. 1996. Title 4, Subtitle 4. Maryland Department of the Environment.

Annotated Code of Maryland. 1996. Title 9, Subtitle 3. Maryland Department of the Environment.

Burton, D.T., R.S. Herriott, S.D. Turley, T.R. Shedd, H.S. Gardner, and R.A. Finch. 1994. Toxicity and
initial hazard assessment of the Beach Point peninsula surficial aquifer at Aberdeen Proving Ground,
Edgewood Area. U.S. Army Biomedical Research and Development Laboratory, Fort Detrick, Frederick,
Maryland.

Code of Federal Regulations (CFR). 1995. Protection of Environment, 29 (various parts).

Code of Federal Regulations (CFR). 1995. Protection of Environment, 40 (various parts).

Code of Maryland Regulation (COMAR). 1996. COMAR 26.04.01, Maryland Department of the Environment.

Code of Maryland Regulation (COMAR). 1996.COMAR 26.08.02.03-2, Maryland Department of the Environment.

Code of Maryland Regulation (COMAR). 1996.COMAR 26.13.02-.05, Maryland Department of the Environment.

Cohen, R.M. and J.W. Mercer. 1993. DNAPL site evaluation. C.K. Smoley, CRC Press.

Jacobs (Jacobs Engineering Group Inc.). 1994. Remedial investigation/feasibility study final quality
assurance project plan, Canal Creek Study Area, Aberdeen Proving Ground-Edgewood Area, Maryland.

Jacobs (Jacobs Engineering Group Inc.). 1996. Final Beach Point Test Site Focused Feasibility Study,
Canal Creek Study Area, Aberdeen Proving Ground - Edgewood Area, Maryland. Document Control No. EMO-
35E35600-B9-06839.

Jacobs (Jacobs Engineering Group Inc.). 1997. Final Beach Point Test Site Focused Feasibility Study
Technical Impracticability Evaluation. Document Control No.: EMO-35E35600-B9-06908.

Lorah, M.M. and J.S. Clark. 1996. Contamination of ground water, surface water, and soil, and
evaluation of selected ground-water pumping scenarios in the Canal Creek Area of Aberdeen Proving
Ground, Maryland. Open-File Report 95-282.

Lorah, M.M. and D.A. Vroblesky. 1989. Inorganic and organic groundwater chemistry in the Canal Creek
Area of Aberdeen Proving Ground, Maryland. U.S. Geological Survey Water Resources Investigations
Report 89-4022.

Roy F. Weston, Inc. 1993. Technical Report. Removal of Four Overpacked Drums, Storage Tank and
Drum Rack at Beach Point, Edgewood Area, Aberdeen Proving Ground, Maryland. Contract No. DACA87-
90-D-0031.

USAEC (U.S. Army Environmental Center). 1995. Reference sampling and analysis program, soil,
sediment, and surface water reference data report. Final. DAAA15-91-D-0014.

USAEHA (U.S. Army Environmental Hygiene Agency). 1977. An assessment of surface water,Edgewood
Area, Aberdeen Proving Ground, Maryland. Water quality biological study. No.24-0043-78.

USAEHA (U.S. Army Environmental Hygiene Agency). 1985. Biological survey for Canal, Kings, and
Watson Creeks, U.S. Army Aberdeen Proving Ground Installation Support Activity, Edgewood Area,
Aberdeen Proving Ground, Maryland: Final Report. Water quality biological study. No. 32-24-0700-87.

USAEHA (U.S. Army Environmental Hygiene Agency). 1986. Phase I groundwater consultation No. 38-
26-0490-86 remedial investigation scoping action interim report, Edgewood Area, Aberdeen Proving
Ground, Maryland.

USAEHA (U.S. Army Environmental Hygiene Agency). 1987. Water quality engineering study. No. 32-
24-0700-87.

USAEHA (U.S. Army Environmental Hygiene Agency). 1989. RCRA facility assessment report Edgewood
Area, Aberdeen Proving Ground, Maryland. Waste Disposal Engineering Division. Project No. 38-26-
0490-90.

USAGAPG, Directorate of Safety, Health, and Environment. 1997. Final Proposed Plan, Beach Point Test

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Site, Aberdeen Proving Ground. Maryland.

USEPA (U.S. Environmental Protection Agency). 1986. Ambient Water Quality Criteria.

USEPA (U.S. Environmental Protection Agency). 1990. National oil and hazardous substances pollution
contingency plan. Final Rule  (40 CFR,300), Federal Register, vol. 55, no. 46, March 8.

USGS (U.S. Geological Survey). 1989. Hydrology of the Canal Creek Area, Aberdeen Proving Ground,
Maryland. Open File Report 894021 and 89-387.

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5.0  LIST OF ACRONYMS
APG - Aberdeen Proving Ground
APGSCC - Aberdeen Proving Ground
     Superfund Citizen's Coalition
ARAR - Applicable or Relevant and
     Appropriate Reguirement
AWQC - Ambient Water Quality Criteria
BGS - Below Ground Surface
BLRA - Baseline Risk Assessment
CERCLA - Comprehensive Environmental
     Response, Compensation, and Liability
     Act
CFR - Code of Federal Regulations
COMAR - Code of Maryland Regulation
COPC - Chemical of Potential Concern
CSF - Cancer Slope Factor
DCE - Dichloroethene
DERP - Defense Environmental Restoration
     Program
DNAPL - Dense Non-agueous Phase Liguid
DSHE - Directorate of Safety, Health and
     Environment
EA - Edgewood Area
EEQ - Environmental Effects Quotient
ERA - Ecological Risk Assessment
ER-M - Effects Range-Median
FFS - Focused Feasibility Study
GIS - Geographical Information System
HCDD - Hexachlorodibenzodioxin
HI - Hazard Index
HQ - Hazard Quotient
MCL - Maximum Contaminant Level
MCLG - Maximum Contaminant Level Goal
MDE - Maryland Department of the
     Environment
NCP - National Oil and Hazardous Substances
     Pollution Contingency Plan
NEPA - National Environmental Policy Act
NPL - National Priorities List
O&M - Operation and Maintenance
OCDD - Octochlorodibenzodioxin
OSHA - Occupational Safety and Health
     Administration
PAH - Polynuclear Aromatic Hydrocarbon
PCA - Tetrachloroethane
PCB - Polychlorinated biphenyl
PCE - Tetrachloroethene
ppb - parts per billion
ppm - parts per million
RA - Risk Assessment
RAB - Restoration Advisory Board
RBC - Risk-Based Concentration
RCRA - Resource Conservation and Recovery
       Act
RFA - RCRA Facility Assessment
RfD - Reference Dose
RI - Remedial Investigation
RME - Reasonable Maximum Exposure
ROD - Record of Decision
SARA - Superfund Amendments and
     Reauthorization Act
SVOC - Semi-volatile Organic Compound
SWMU - Solid Waste Management Unit
TBC - To Be Considered
TCA - Trichloroethane
TCE - Trichloroethene
TI - Technical Impracticability
TNT - Trinitrotoluene
TRC - Technical Review Committee
TRV - Toxicity Reference Value
USAEC - U.S. Army Environmental Center
USAEHA - U.S. Army Environmental Health
       Agency
USEPA - U.S. Environmental Protection
       Agency
USGS - U.S. Geological Survey
UST - Underground Storage Tank
UV - Ultraviolet
UXO - Unexploded Ordnance
VOC - Volatile Organic Compound

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