SUPERFUND RECORD OF DECISION ALLEGANY BALLISTICS LABORATORY US NAVY OU 3, MINERAL WV


                                    EPA/ROD/R03-97/174
                                    1997
EPA Superfund
     Record of Decision:
     ALLEGANY BALLISTICS LABORATORY (USNAVY)
     EPA ID:  WV0170023691
     OU03
     MINERAL COUNTY, WV
     05/29/1997

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                                   RECORD OF  DECISION
        SITE  1  OPERABLE UNIT 3,  GROUNDWATER, SURFACE  WATER,  AND  SEDIMENT





                                          at  the





                   ALLEGANY BALLISTICS  LABORATORY,  WEST VIRGINIA
                                       APRIL  1997

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                             TABLE OF CONTENTS

                                                             PAGE
1.0  DECLARATION

     1.1 Site Name and Location 	   1
     1.2 Statement of Basis and Purpose 	   1
     1.3 Description of the Selected Remedy 	   1
     1.4 Statutory Determinations 	   2

2.0  DECISION SUMMARY

     2.1 Site Name, Location,  and Description 	   4
     2.2 Site History and Enforcement Activities 	   5
     2.3 Scope and Role of Operable Unit 	   8
     2.4 Summary of Site Characteristics 	   9
     2.5 Summary of Site Risks 	  15
     2. 6 Description of Alternatives 	  18
     2.7 Summary of Comparative Analysis of Alternatives ....  22
     2.8 The Selected Remedy 	  25
     2.9 Statutory Determinations 	:  	  29

3.0  RESPONSIVENESS SUMMARY

     3.1 Background on Community Involvement 	  33

                          LIST OF FIGURES

     1   Location Map
     2   Plant Features
     3   Site, 1 Waste Disposal Units
     4   Approximate Area of Contaminated Groundwater

                           APPENDICES

A    Toxicological Profiles for COCs at Site 1
B    Applicable or Relevant and Appropriate Requirements
C    Summary of Comments Received During Public Meeting and Responses

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1.0 THE DECLARATION

1.1 SITE NAME AND LOCATION

Site 1 Groundwater, Surface Water and Sediments
Allegany Ballistics Laboratory
Rocket Center, West Virginia

1.2 STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for site 1 (the "site") Groundwater, Surface
Water and Sediments at the Allegany Ballistics Laboratory (ABL), Rocket Center, West Virginia. This
determination has been made in accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980(CERCLA) , as amended by Superfund Amendments and Reauthorization Act of 1986 (SARA), and
to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This
decision is based on the administrative record for this site.

The Department of the Navy (DoN) has obtained concurrence from the State of West Virginia and the United
States Environmental Protection Agency (USEPA) , Region III with the selected remedy.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this Record of Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment.

1.3 DESCRIPTION OF THE SELECTED REMEDY

The Navy will manage the remediation at Site 1 in two phases or operable Units (OUs). The remedial action
selected in this Record of Decision (ROD) addresses contamination associated with groundwater, surface water
and sediments in the North Branch Potomac River near Site 1 and is to be implemented as Operable
Unit Three (OU 3).

Operable Unit Four (OU 4), defined as the contaminated surface and subsurface soils at Site 1, will undergo
further evaluation and separate remediation alternatives will be studied.

The selected remedy for OU 3 is a site-wide groundwater extraction, with Dense Non-Aqueous Phase Liquids
(DNAPLs) targeting and air stripping.

The major components of the selected remedy are:

• Construction of a groundwater treatment plant onsite for treatment of flow in the range of
175 gpm to 540 gpm.

• Extraction of groundwater across Site 1. Groundwater extraction will prevent flow of
contaminated groundwater into the river thereby allowing contaminated surface water and
sediments to undergo processes of volatilization, degradation, dilution, mixing, and sediment
removal or erosion. Extracted groundwater will be treated by the groundwater treatment plant
and discharged to the North Branch Potomac River. A portion of the treated groundwater will
be utilized by-the facility, on an as needed basis, for steam generation. The extraction
well network would be periodically evaluated and modified as necessary in order to enhance
recovery of contaminants and better control the dissolution of DNAPLs into groundwater.

• Establishment of an Operation and Maintenance (O&M) program for the groundwater treatment
plant and extraction system. Deed notations and property use and access restrictions will
be implemented to prevent future groundwater use.

• A sediment, surface water, and aquifer monitoring plan will be undertaken to monitor
contaminant concentrations in the river and across Site 1. Human health risk from ingestion
of fish will be reconsidered during this monitoring. In concurrence with State and EPA,
wells that no longer produce contaminated groundwater concentrations above MCLs would be
shut off, providing residual groundwater contaminant concentrations do not present
unacceptable risk to human and ecological receptors in the river. This process would

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continue until a smaller zone of groundwater contamination is defined in the aquifer, likely
corresponding to DNAPLs.

Implementation of the selected remedy will address the principal threats at the site by reducing the
potential risk to human health and the environment associated with the discharge of groundwater to the North
Branch Potomac River.

1.4 STATUTORY DETERMINATIONS

The selected remedy for OU 3 is protective of human health and the environment, complies with Federal and
State requirements that are legally applicable or relevant and appropriate to this action (a waiver for
cleanup of the DNAPL-zone under the Safe Drinking Water Act may be justified because of technical
impractability from an engineering perspective), and is cost-effective.

This remedy utilizes permanent solutions and alternative treatment (or resource recovery) technologies to the
maximum extent practicable, and satisfies the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.

Because this remedy will result in hazardous substances remaining on-site above health based levels, a review
will be conducted within five years after commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environment.

2.0 DECISION SUMMARY

2.1 SITE NAME, LOCATION, AND DESCRIPTION

Allegany Ballistics Laboratory (ABL) is located at Rocket Center, in the north central panhandle of West
Virginia, about 10 miles south of Cumberland, Maryland. ABL consists of two plants and several additional
sites (Figure 1). Plant 1 occupies approximately 1,572 acres and is owned by the Navy and operated by
Aliiant Techsystems. Plant 2, a 56-acre area adjacent to Plant 1, is owned exclusively by Aliiant
Techsystems, and was not listed on the NPL. Plant 2 is located along the river on a floodplain separate from
Plant 1. Plant 1 lies between the North Branch Potomac River to the north and west, and Knobly Mountain to
the south and east. Several small towns and communities are located near Plant 1, including Pinto,
Maryland, (1,500 feet to the northwest) and the community along McKenzie Road (750 feet north of Site 1) both
located directly across the river from Site 1 (Figure 1). These Maryland communities include a total of
approximately 30-40 residents, 15 of whom obtain all potable water from private residential wells. Other
residents use a public water system. Short Gap, West Virginia, is located on the other side of Knobly
Mountain, 5,000 feet to the southeast of Plant 1.

Site 1, shown in Figure 2, is approximately 11 acres and is situated on the northern edge of Plant 1. Site 1
is located on the alluvial plain above the North Branch Potomac River and has a range in elevation from 648
feet above mean sea level (msl) and 671 feet msl. A portion of Site 1 is located in the 100-year
flood zone. Most of Site 1 is level, however there is lower topography and a man-made drainage in the
western portion of the Site 1. The northern edge of Site 1 is moderately steep, sloping toward a lower-level
terrace and the river.

The land use across the river from Site 1 is primarily agricultural. The land is used for growing corn and
hay, and a dairy farm also exists at the eastern end of McKenzie road. In addition, an aeration basin
treating wastewater from the unincorporated Maryland communities of Pinto, Bel Air, and Glen Oaks is located
just west of Pinto and discharges to the river.

Limestone quarry and treatment works were formerly located to the northeast of Site 1 across the North Branch
Potomac River. The operation has been abandoned for over 50 years.

To the northwest of Site 1, a former industrial operation was located on top of the bedrock terrace.

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There are no ground water production wells currently active on the alluvial plain portion of Plant 1 at ABL.
Several residences utilize ground water wells, within 1,000 feet of Site 1 across the river. Springs have
been identified on Plant 1 approximately 2,000 feet to the south of Site 1.

The North Branch Potomac River is the closest major body of water.

2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES

2.2.1 History of Site Activities

Plant operations at ABL included research, development and the production of solid propellant rocket motors.
The formulation of the rocket fuels included the use of oxidizing and explosive materials. Processing the
propellant and hardware eguipment required the use of organic solvents.

Since 1959, Site 1 has been utilized for various types of waste burning and disposal activities. As shown in
Figure 3, Site 1 contains inert (non-ordnance)open and ordnance burn areas, two landfills, a former drum
storage area, and three solvent disposal pits. Within the fenced portion of Site 1, known as the ordnance
burning ground, eight earthen pads were formerly used to burn ordnance material generated at the facility.
Selected pads are currently used for burning, however all burning is now done on steel pans. Near the
southwest corner of the ordnance burning ground, three unlined pits historically were used to dispose of used
solvents, acids, and bases generated by plant operations.

Near the eastern end of Site 1, inert wastes (i.e., rags, paper, etc.), possibly contaminated as a result of
plant operations, historically were burned and the ash buried. Burning and disposal activities at this area
have ceased.

Waste not classified as ordnance or explosive contaminated, such as sanitary waste, was burned in the open
burn area, located near the western end of Site 1. The ash from the open burning activities was landfilled,
together with building material and other nonflammable debris, in the open burn area landfill along the bank
of the North Branch Potomac River.

Prior to 1981, the former drum storage area was used to store 55-gallon drums containing used solvents
generated during plant operations.

In August 1981, reports of deteriorated drums releasing their contents to the surrounding ground surface
resulted in a cleanup effort in which the spilled material from the drums was removed from the ground surface
and contained in new drums. The drums were then disposed in accordance with RCRA regulations.

2.2.2 Previous Investigations

Five investigations have been conducted at ABL during which Site 1 has been either part or the focus of the
investigation: (1) the Initial Assessment Study (IAS); (2) the Confirmation Study (CS); (3) the Remedial
Investigation (RI); 4) the Focused RI; and (5) the Focused Feasibility Study (FFS). The IAS, completed in
1983 under the Navy Assessment and Control of Installation Pollutants Program (NACIP) , identified nine sites
at ABL for further investigation (Environmental Science and Engineering, January 1983). The IAS concluded
that these sites did not pose an immediate threat. However, the IAS showed the need for a confirmation study
at seven of the nine sites, including Site 1, to assess the potential impacts on human health and the
environment by suspected contaminants.

Following the recommendations of the IAS and in accordance with the NACIP, the CS was initiated in June 1984
and completed in August 1987. The CS focused on identifying the existence, concentration, and extent of
contamination at the sites recommended for further investigation in the IAS. As a result of the Superfund
Amendments and Reauthorization Act (SARA) of October 1986, the Navy changed its NACIP terminology and scope
under the Installation Restoration Program (IRP) to follow the rules, regulations, guidelines, and criteria
established by the EPA for the Superfund program. For this reason, the results of the CS are documented in
the Interim Remedial Investigation (Interim RV Report (Weston, October 1989). The Interim RI Report
recommended further investigation at six of the seven sites, including Site 1.

Following the recommendations of the Interim RI Report and in accordance with the Navy's changed Installation
Restoration Program URP) policy, CH2M HILL was contracted to conduct an RI following EPAs RI/FS format under
CERCLA.
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The RI, initiated in May 1992 and completed in October 1992 (final document dated January 1996), was
conducted to define the nature and extent of contamination at a number of ABL sites, including Site 1. The
RI investigation at Site 1 is discussed in detail in the Remedial Investigation of the Allegany Ballistics
Laboratory, January 1996 (RI).

In order to expedite the RI/FS process at Site 1 by filling data gaps remaining after completion of the RI,
the Atlantic Division of the Navy contracted CH2M HILL to conduct a Focused RI at Site 1 following EPA's
RI/FS format under CERCLA. The Site 1 Focused RI further defined the nature and extent of contamination at
and adjacent to Site 1 and included baseline risk assessments for human health and the environment. The Site
1 Focused RI and the risk assessments are discussed in detail in the Site 1 Focused RI Report.

Based on the results from the previous four investigations a Focused Feasibility Study (FFS) was undertaken
for Site 1. The FFS was conducted to assess several alternatives to address groundwater, surface water and
sediment contamination identified at Site 1.

2.2.3 Enforcement Actions

In August, 1981, the State of West Virginia issued ABL a consent order for the improper storage of hazardous
wastes at the storage facility within Site 1. ABL fully complied with all terms of the order resulting in no
further action.

Consent Order (CO) #CO-R6,13,25-95-8 was issued on November 10, 1995 by the State of West Virginia. It deals
with open burning of propellant and explosive (P/E) wastes and P/E contaminated wastes. The Co compliance
program reguired cessation of open burning of P/E contaminated wastes by May 31, 1996. It also delineated
three primary reguirements: compliance demonstration; waste minimization and emissions mitigation; and
utilization of an open burning management plan. Compliance demonstration included construction of an
incinerator if open burning of P/E contaminated wastes was not ceased, research on alternative technologies,
determination of impact on human health and the environment, and relocation of the burn site if the impact
were unacceptable.

This order is currently in force and all order reguirements are being met.

No other enforcement actions have occurred at Site 1.

2.2.4 Highlights of Community Participation

In accordance with Sections 113 and 117 of CERCLA, 42 U.S.C. °°9613 and 9617, the Navy held a public comment
period from October 22, 1996 through December 9, 1996 for the proposed remedial action described in the
Focused Feasibility Study for Site 1 and in the Proposed Plan.

These documents were available to the public in the Administrative Record and information repositories
maintained at the Fort Ashby Public Library, Fort Ashby, West Virginia and at the La Vale Public Library, La
Vale, Maryland. Public notice was provided in the Cumberland Times newspaper on October 18, 1996 and a
Public Meeting was held in the Bel Air Elementary School on October 29, 1996. No written comments were
received during the comment period and the comments and responses provided during the Public Meeting are
presented in Appendix C.

2.3 SCOPE AND ROIiE OF OPERABLE UNIT (OR RESPONSE ACTION) WITHIN SITE STRATEGY

The Navy has decided to manage the remediation of Site 1 in two phases or operable Units (OUs). An OU is
defined by the National Oil and Hazardous Substances Pollution Contingency Plan (40 CFR 300.5)(NCP), as a
discrete action which is an incremental step toward comprehensively mitigating site problems. The NCP (40
CFR 300.430 (a)(1)(ii)(A)) states "Sites should generally be remediated in operable units when early actions
are necessary or appropriate to achieve significant risk reduction guickly, when phased analysis and response
is necessary or appropriate given the size or completion of total site cleanup.

The principal threats posed by conditions at Site 1 result from potential exposures to contaminated soils,
groundwater, and surface water and sediments. The remedial action identified in this ROD address
contamination associated with Site 1 groundwater, surface water and sediments, as identified in the RI
Report and the Focused RI Report.

The selected final remedial action (FRA) is to be implemented as Operable Unit Three (OU 3). The FRA
consists of extracting groundwater across Site 1 thereby preventing flow of contaminated groundwater into the
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river. This action will allow contaminated surface water and sediments to undergo processes of
volatilization, degradation, dilution, mixing, and sediment removal or erosion.

In addition, institutional controls will be used to prevent future groundwater use.

The remedial action at OU 3 will help to contain the DNAPLs in the aquifer, reduce contaminant concentration
in the groundwater, reduce the discharge of contaminated groundwater to surface water
thereby reducing the principal threat from groundwater contamination.

The response actions for groundwater, surface-water, and sediment are expected to comply with the remedial
action objectives identified in the FFS for these media which are:

• Prevent or minimize exposure of potential future onsite residents and construction workers to
contaminated groundwater originating from Site 1.

• Prevent or minimize offsite migration of contamination originating from Site 1.

Operable Unit Four (OU 4), defined as the contaminated soils at Site 1, will undergo further evaluation and
remedial cleanup alternatives will be developed. The final remedy or remedies for OU 4 will be for surface
and subsurface soils.

2.4 SUMMARY OF SITE CHARACTERISTICS

Site 1 is underlain by two distinct lithologies: (1) unconsolidated alluvial deposits of clay, silt, sand,
and gravel; and (2) mainly calcareous shale and limestone of Silurian age.

Unconsolidated Aquifer

Drilling activities at Site 1 indicated that the unconsolidated deposits overlying bedrock generally consist
of two distinct layers of material: (1) an upper, or surficial silty clay, considered floodplain deposits and
(2) a deeper sand and gravel layer (alluvium), with variable but typically significant amounts of clay and
silt.

The floodplain deposits have an average depth of approximately 12 feet below ground surface (bgs) and the
alluvial materials have an average thickness of approximately 14.5 feet beneath Site 1.

The sand and gravel alluvium constitutes the shallow aguifer at Site 1. The approximate position of the
water table is based on water-level measurements collected in November 1994 during the Focused RI. The
alluvial deposits are believed to be saturated through their entire thickness except near the river, where
the water table drops below the top of the alluvium. Water-level measurements collected in November 1994
from all Site 1 alluvial wells indicate the direction of groundwater flow in the alluvial aguifer at Site 1
is toward the river. This translates into a north-northeast flow direction in the central and eastern
portions of Site 1 and a northwest flow direction in the western portion of the site. As discussed
previously, the average elevation of the river surface (648 feet msl) is within the 640 to 652 feet msl
elevation range of the alluvial aguifer adjacent to the river at Site 1.

This suggests that the river is the ultimate discharge zone for groundwater flowing laterally through the
alluvium.

Hydraulic conductivities calculated from slug tests conducted in Site 1 alluvial monitoring wells and
horizontal hydraulic gradients were used to approximate the average linear velocity of horizontal groundwater
flow in the alluvial aguifer at Site 1. Assuming an effective alluvium porosity of 20 percent, the average
linear velocity was estimated to be between 5 and 250 feet per year (ft/yr), depending on the amount of clay
in the alluvium and on the relative steepness of the hydraulic gradient.

Bedrock Aquifer

Below the sand and gravel alluvium lies bedrock consisting of mainly calcareous shale and limestone of
Silurian age. The average depth to bedrock at Site 1 is approximately 26.5 feet. Across the North Branch
Potomac River from Site 1, no alluvium was encountered on the hill slopes and the top of the predominantly
shale bedrock lies close to the ground surface.
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During the RI and Focused RI, separate investigations were conducted to identify bedrock fracture sets and
orientations in the vicinity of Plant 1 which may control local bedrock groundwater flow. During the RI,
field measurement of 96 fracture planes identified two predominant orientations: (1) N26IE; and (2) N39IW.
The former measurement was the most common measurement recorded and is approximately parallel to the
structural trend of the Wills Mountain anticlinorium and the Appalachian folds in the region. The latter
orientation is obligue to the Appalachian structural trend.

During the Focused RI, aerial photographs were also studied and it was found that a number of probable
fracture traces adjacent to the plant display orientations that are similar to the predominant fracture
orientations measured during the RI. It is assumed that fracture traces displaying these predominant
orientations also exist beneath Site 1.

Because of the limited bedrock-fracture data, the areal extent of fracture sets or voids at Site 1 is
unclear. The bedrock coring data collected from two monitoring wells (1GW9 and 1GW15) at Site 1 suggest that
there are no voids and that the fracture sets observed are limited in areal extent.

The pattern or direction of groundwater flow in the bedrock aguifer is similar to that of the alluvial
aguifer, with both aguifers locally discharging to the North Branch Potomac River. However, unlike the
alluvial aguifer, lateral groundwater flow in the bedrock aguifer is confined mainly to partings along
bedding planes and fractures.

Bedrock groundwater beneath the central and eastern portion of Site 1 generally flows northeast,
approximately parallel to strike of N30IE, toward the North Branch of the Potomac River; groundwater beneath
the western portion of the site is believed to flow in step-wise fashion northwest, approximately parallel to
the strike of N39IW, toward the river.

Aguifer tests at Plant 1 and water-level data collected from the river and monitoring wells at Site 1 suggest
varying degrees of hydraulic interconnection exist between the river and alluvium, the river and shallow
bedrock, and the alluvium and shallow bedrock. In addition, water-level data collected from monitoring wells
across the river from Site 1 suggest that bedrock groundwater from the western two thirds of the site clearly
discharges to the river and does not flow-beneath the river.

These flow conditions are a result of the higher bedrock topography and related groundwater elevation heads
that occur across the river in comparison to the bedrock on site. However, bedrock groundwater may migrate
beneath the river from the eastern one third of the site. Water-level data from the bedrock wells on both
sides of the river in this section of Site 1 are very similar, however the wells to the north have a slightly
lower groundwater elevation head indicating potential flow in that direction. The wells across the river at
this location have been sampled and no contaminants of concern detected at Site 1 were detected, so if
groundwater does flow under the river Site 1 groundwater contamination has not reached that area. Similar to
the alluvium, the river is most likely a discharge zone for shallow bedrock groundwater in the vicinity of
Site 1.

Data collected from alluvial and shallow bedrock well pairs at Plant 1 indicate that the vertical component
of hydraulic gradient is downward throughout the plant, including Site 1. This is not the case for the
shallow and deep bedrock relationship in the north-central portion of Site 1. Here, the vertical component
of hydraulic gradient was shown to be upward from the deep bedrock to the shallow bedrock.

Because the shallow bedrock was shown to be in hydraulic connection with the river, increases in head in the
shallow bedrock resulting from recharge from the overlying alluvium can be dissipated through movement of
shallow bedrock groundwater into the river. The deeper bedrock, likely recharged in the highlands to the
southwest of the facility, may not be hydraulically connected to the river. Therefore, the heads at
depth tend to increase in response to addition of groundwater in the recharge zone, which results in an
upward vertical component of hydraulic gradient in the deep bedrock relative to shallow bedrock and alluvium
along the rivet.

Sources of Contamination

Three former solvent disposal pits are located in the southwestern portion of the fenced area. These pits
are considered the prime source of the ground water solvent contamination at Site 1. Two additional areas,
identified as potential spill sites are possible sources for solvent contamination. These two area are
located in the northeastern portion and the northwestern portion of the fenced area.
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NATURE AND EXTENT OF CONTAMINATION

Based on site history, previous investigations and Site 1 Focused RI findings, contamination from prior land
use practices at Site 1 has impacted surface soil, subsurface soil, sediment, surface water, and groundwater.
A brief summary of the nature and extent of contamination follows. A complete list of the contaminants of
concern detected in groundwater, surface water and sediment and their toxicological characteristics is
presented in Appendix A. Due to site geology and the probability of dense, non-agueous phase liguids
(DNAPLs) , an accurate estimate of the volume of contaminated groundwater plume cannot be made. However,
Figure 4 provides an approximate areal extent of the contaminant plume. This summary focuses on the primary
constituents associated with groundwater contamination, and is not intended to address all of the sampling,
analytical, and evaluation results contained in previous investigative documents. A detailed discussion of
contaminant nature and extent can be found in the Site 1 Focused RI Report.

Groundwater Contamination

During the course of the RI and Focused RI, groundwater samples were collected from all Site 1 monitoring
wells and monitoring wells across the river from Site 1 for various analyses to determine the nature and
extent of contamination. The analytical results are discussed in detail in the RI and the Focused RI, and
are briefly summarized here.

Volatile Organic Compounds (VoCs)

Thirteen VOCs were detected in Site 1 groundwater during one or both investigations, but the six most
prevalent (detected in six or more samples) VOCs were, in order of detection freguency: trichloroethene ME),
total 1,2-dichloroethene (1,2-DCE), methylene chloride (MC), acetone, 1,1,1-trichloroethane (1,1,1-
TCA), and tetrachloroethene (PCE).

Vinyl chloride (VC) was also detected, but in only one groundwater sample, at a concentration of 41
micrograms per kilogram (ug/kg). Of the VOCs detected in Site 1 groundwater, TCE was the most prevalent and
was detected at the highest concentrations. The highest concentrations of TCE ((up to 240,000 micrograms per
liter(ug/l)] were found in a well cluster located hydraulically downgradient of the solvent disposal pits.
Concentration at this level indicates the presence of DNAPLs. TCE was found in all alluvial wells and most
bedrock wells adjacent to the river at Site 1.

Similar to TCE, MC, 1,2-DCE, and 1,1,1-TCA were detected at the highest concentrations (8,000 ug/1, 4,800
ug/1, and-7,700 ug/1, respectively) in the well cluster located hydraulically downgradient of the solvent
disposal pits. PCE was detected in both alluvial and bedrock monitoring wells at concentrations as high as
800 ug/1 and 12 ug/1, respectively.

Inorganics

The highest total concentrations of inorganics in the alluvial aguifer on Site 1 were detected in a well
considered to be an upgradient or "background" well for the alluvial aguifer at Site 1.

However, the total concentrations of 12 inorganics were found to be higher in one or more Site 1 bedrock
wells than in a well considered to be an upgradient or "background" well for the bedrock aguifer at Site 1.
The 12 inorganics include; aluminum, arsenic, barium, chromium, cobalt, copper, iron, lead, mercury,
nickel, vanadium and zinc.

Surface-Water and Sediment Contamination

Surface-water and sediment samples collected from the North Branch Potomac River upstream, downstream, and
adjacent to Site 1 were analyzed for VOCs, SVOCs, and inorganics. Several of the surface-water and sediment
sampling locations were located along areas with elevated levels of soil contamination detected in Site 1
soil.

The analytical results are discussed in detail in the RI and the Focused RI, and are briefly summarized here.
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Surface-Water VOCs

TCE and 1,2-DCE (total) were the most prevalent VOCs detected in surface-water samples collected adjacent to
and downstream of Site 1.

MC was also detected, but at relatively low concentrations, suggesting that it may have been the result of
laboratory contamination. None of the aforementioned VOCs were detected in the upstream surface-water
sample, suggesting that groundwater discharging to the river from Site 1 is the source of VOCs.

Surface-Water SVOCs

Bis(2-ethylhexyl)phthalate was the only SVOC detected, at an estimated concentration of 1 ug/1.

Surface-Water Inorganics

In general, inorganics concentrations in samples collected adjacent to and downstream of Site 1 were similar
or lower than inorganics concentrations detected in the upstream sample.

Sediment VOCs

With the exception of acetone, which is believed to have been due to laboratory contamination, no VOCs were
found in the upstream sample. The highest VOC concentrations were detected in the sediment samples collected
adjacent to the groundwater well cluster hydraulically downgradient of the solvent disposal pits. In general,
the VOC concentrations decrease in a downstream direction to non-detect within 1.5 miles of the eastern end
of Site 1.

Sediment SVOCs

In general, similar SVOCs at similar concentrations were detected in sediment samples collected upstream,
downstream, and adjacent to Site 1.

Sediment Inorganics

The inorganics data for the sediment samples collected during the RI and the Focused RI indicate that all
inorganics concentrations were slightly higher in the upstream sediment sample than in the sediment samples
collected adjacent to and downstream of Site 1.

Potential Routes of Contaminant Migration

Contaminated groundwater in the alluvial and bedrock aguifers at Site 1 is likely discharging to the North
Branch Potomac River.

Conseguently, contamination (primarily VOCs) has been detected in surface water and sediment samples
collected hydraulically downgradient from the approximate area of the contaminant plume at Site 1 (Figure 4).
VOC-contaminated groundwater in the bedrock aguifer could possibly flow to the north beneath the river at the
eastern end of Site 1 as discussed above, however, no VOC-contamination has been detected in monitoring wells
or residential wells along McKenzie Road.

2.5 SUMMARY OF SITE RISKS

The human health and ecological risks associated with exposure to contaminated media at Site 1 were evaluated
in the Focused RI Report. The human health baseline risk assessment evaluated and assessed the potential
health risks which might result under current and potential future land use scenarios.

Cancer risks are presented as a number indicating the potential for an increased chance of developing cancer
if directly exposed to contaminants. As an example, EPA's acceptable risk range for cancer is 1 x 10 -6 to 1
x 10 -4, which means there might be one additional chance in one million (1 x 10 -6) to one additional chance
in ten thousand (1 x 10 -4) that a person would develop cancer if exposed to the contaminants at the site
using EPA's recommended exposure scenario.

EPA's recommended exposure scenario for ingestion of contaminated groundwater for an adult resident assumes
the individual consumes 1 liter/day for the first six years or their life and 2 liters/day for the following
twenty-four years for 350 days/year. The risks evaluated for developing other health effects (using EPA's
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recommended exposure scenario) are expressed as a hazard index (HI). A hazard index of one or less indicates
a very low potential to experience any adverse health effects based on EPA's recommended exposure scenario.
An ecological evaluation was also performed and addressed the threats to ecological receptors. A summary of
the human health and ecological risks associated with the site are summarized below.

2.5.1 Human Health Risks

Groundwater

There is no current exposure to contaminated groundwater because it is not used as a drinking water source at
Site 1 or on Plant 1 at ABL.

Future exposure to groundwater was evaluated for a future resident obtaining all of their potable water from
the most contaminated groundwater at Site 1. Future adult resident exposure pathways include inhalation of
VOCs while showering and ingestion of groundwater. Future child resident exposure pathways include dermal
contact while bathing and ingestion of groundwater.

Groundwater risks for potential future exposure scenarios were calculated assuming two different water supply
sources: the most likely residential water supply source, and a reasonable maximum residential water supply
source. The definition of these sources is provided in the Focused RI Report, and the associated risks for
each source is described below.

For the reasonable maximum exposure, which includes use of groundwater from the alluvial aguifer and shallow
bedrock, the HI for the child resident is 4,000 and the HI for the adult resident is 3,000. TCE contributed
greater than 90 percent of the total HI. The lifetime exposure age-adjusted cancer risk, which included
dermal exposure while bathing up to age 7 and inhalation of VOCs while showering for 24 years, and ingestion
of groundwater is 1 x 10 -1. The risk from ingestion is 5 x 10 -2, with TCE contributing 65 percent.

The risk from inhalation of VOCs by an adult is 8 x 10 -2, mainly from vinyl chloride. The risk from dermal
exposure to a child, 2 x 10 -3, is mainly caused by TCE.

For the most likely exposure, which includes use of groundwater from the shallow and deep bedrock, the HI for
a child is 1,000, and the HI for an adult is 900. TCE contributed the majority of the hazard associated with
inhalation, dermal contact, and ingestion. The lifetime exposure age-adjusted cancer risk, including dermal
exposure while bathing for a child, inhalation of VOCs while showering for an adult and ingestion of
groundwater is 7 x 10 -2. The lifetime risk from ingestion of groundwater for 30 years is 1 x 10 -2. The
main contributor for the ingestion risk is TCE.

The risk from inhalation of VOCs by an adult is 5 x 10 -2. Vinyl chloride contributes approximately 83
percent of this risk. The risk to a child from dermal contact while bathing is 7 x 10 -3, with TCE
contributing about 99 percent of the risk.

No human health risk assessment was performed for a future construction worker exposed to groundwater,
however the risks would be much lower than the residential risk evaluated above.

Surface Water and Sediment

A guantitative human health risk evaluation of the surface water and sediment was not conducted during the
base-line risk assessment. At the time of the evaluation, all of the contaminants in the surface water and
sediment at Site 1 were eliminated during preliminary screening. However, after additional review several
contaminants including iron, manganese, and antimony were determined to be of potential concern. Iron is an
essential human nutrient. The other two inorganic contaminants will be re-evaluated during the development
of discharge limits and during monitoring of the effectiveness of the preferred action. Human health risk
from ingestion of fish was also not considered. This potential exposure pathway will also be reconsidered
during the monitoring of the remedy performance.

2.5.2 Environmental Evaluation

Analytical data compiled from the Focused RI were analyzed using EPA Region III guidance for determining
environmental effects guotients (EEQs). Data was reviewed for surface water, sediment, and soil. EEQs were
determined by comparison with standard guidelines. EEQs greater than 1 indicate a potential for risk,
greater than 10 represent potential moderate adverse effects, and greater than 100 represent a significant
potential for adverse effects. The exposure assessment for surface water and sediment is presented below.
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Surface Water

EEQs greater than 1.0 occurred for mercury, silver, copper, chromium, and aluminum at a "background" sampling
location. EEQS over 40 were reported for silver in several site samples. EEQs for aluminum, lead, zinc, and
mercury also exceeded a value of 1 for sampling locations potentially receiving site-related contaminants.

Sediment

EEQs for two SVOCs exceeded 1 at a "background" sampling location, but were based on values for non-detects.
Most of the site EEQ values exceeding 1 were the result of using non-detect values (i.e., one half of the
detection limit). Based on the analysis of EEQ values for surface water and sediments, there are relatively
few contaminants of concern (COCs). The COCs include: antimony, cadmium, anthracene, benzo(a)anthracene,
benzo(a)pyrene, chrysene, fluoranthene, TCE, and VC.

2.6 DESCRIPTION OF ALTERNATIVES

A detailed analysis of the possible remedial alternatives for Site 1 groundwater, surface water, and sediment
is included in the Site 1 FFS report.

The detailed analysis was conducted in accordance with the TPA document entitled "Guidance for Conducting
Remedial Investigations and Feasibility Studies under CERCLA" and the National Oil Hazardous Substances
Pollution Contingency Plan (NCP). A summary of the remedial alternatives which were developed to address
contamination associated with Site 1 groundwater, surface water, and sediment is presented below.

GROUNDWATER ALTERNATIVE 1 - NO ACTION

Description: Under this alternative no further effort or resources would be expended at Site 1. Because
contaminated media would be left at the site, a review of the site conditions would be reguired every 5
years. The review is specified in the NCP. Alternative 1 serves as the baseline against which the
effectiveness of the other alternatives is judged.

Cost: There are no costs associated with this alternative.

Time to Implement: Implementation would be immediate.

GROUNDWATER ALTERNATIVE 2 - INSTITUTIONAL CONTROL ACTIONS

Description: The major components of this alternative include:

1. Locking up or abandoning existing wells onsite.

2. Filing of a groundwater use restriction on the site.

3. Deed notations along with property use and limited access restrictions that would prevent residential
development and access to the land overlying groundwater contamination.

4. Groundwater, surface water, and sediment monitoring on a routine basis, guarterly to semi-annually, for
a minimum of 5-years.

Cost: The estimated costs associated with this alternative are as follows:
Capital: $50,000
Annual operation and maintenance: $0
Net present worth (30-year): $50,000

Costs associated with performing the 5-year site reviews are not included.

Time to Implement: Three to four months to implement.

GROUNDWATER ALTERNATIVE 3 - SITEWIDE GROUNDWATER EXTRACTION AND AIR STRIPPING

Description: The major components of this alternative include:
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1. Construction of a groundwater treatment plant onsite. The treatment plant will be located outside the
limits of the 100-year floodplain. The preliminary major process components are flow equalization,
metals precipitation and clarification, gravity filtration, air stripping, and off-gas treatment by
thermal oxidation.

2. Extraction of groundwater across Site 1, treatment by the groundwater treatment plant, and discharge to
the North Branch Potomac River. A portion of the treated groundwater will be utilized by the facility,
on an as needed basis, for steam generation.

3. During implementation of this alternative, an annual operation and maintenance (O&M) program will be
established for the groundwater treatment plant. Deed notations and property use and access
restrictions will be implemented to present future groundwater use.

4. Groundwater, surface water, and sediment monitoring on a timely basis, quarterly to semi-annually, for
inclusion in the 5-year site reviews.

Groundwater extraction will occur across the length of Site 1 with the focus of preventing offsite migration
of contaminants from the site to the river. This will prevent the continued contamination of surface water
and sediment in the North Branch Potomac River.

Because the contaminant source (Site 1 groundwater) will be controlled, surface water and sediment
contamination will be reduced through processes of volatilization, degradation, dilution, mixing, and
sediment removal or erosion in the river.

Based on preliminary groundwater modeling, the extraction flow race is estimated to range from 175 to 540
gpm, depending an the anisotropy exhibited by groundwater flow in the aquifer. The treatment plant flow rate
will be revised based upon pump tests conducted on the extraction wells once they are installed and
tested.

Discharge of treated water to the North Branch Potomac River will comply with ARARs, governed primarily by
the State of West Virginia's National Pollutant Discharge Elimination System (NPDES) program.

The Ambient Water Quality Criteria (AWQC) for water and organisms will be considered further in the
calculation of final discharge limits to be protective of human health and the environment.

The State of Maryland has the right to review the discharge limitations imposed by West Virginia, and may
impose more stringent limitations at their discretion. The treatment plant will be designed to comply with
the final discharge limits once they are established.

Cost: The estimated costs associated with this alternative are listed below. Costs are given over the flow
rate range of 175 gpm to 540 gpm.

Capital: $3,600,00 to $7,500,000
Annual operation and maintenance: $250,000 to $550,000
Net present worth (30-year): $7,400,000 to $16,000,000

Time to Implement: Six to twelve months to implement.

GROUNDWATER ALTERNATIVE 4 - SITEWIDE GROUNDWATER EXTRACTION, TARGETING DNAPLs, AND AIR STRIPPING

Description: This sitewide alternative is very similar to Alternative 3. The major components of this
alternative include:

1. Construction of a groundwater treatment plant onsite for treatment of flow in the range of 175 gpm to 540
gpm. The treatment plant in this alternative is identical to that specified in Alternative 3.

Therefore, the treatment plant will be designed to comply with the final discharge limits once they are
established.

2. Extraction of groundwater across Site 1 preventing flow of contaminated groundwater into the river
allowing contaminated surface water and sediments to undergo processes of volatilization, degradation,
dilution, mixing, and sediment removal or erosion. Extracted groundwater will be treated by the
groundwater treatment plant and discharged to the North Branch Potomac River. A portion of the treated
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groundwater will be utilized by the facility, on an as needed basis, for steam generation.

3. Establishment of an O&M program for the groundwater treatment plant and extraction system. Deed
notations and property use and access restrictions will be implemented to prevent future groundwater use.

4. A sediment, surface water, and aquifer monitoring plan will be undertaken as well to monitor contaminant
concentrations in the river and across Site 1. Human health risk from ingestion of fish will be
reconsidered during this monitoring. In concurrence with State and EPA, wells that no longer produce
contaminated groundwater concentrations above MCLs would be shut off, providing residual groundwater
contaminant concentrations do not present unacceptable risk to human and ecological receptors in the
river. This process would continue until a smaller zone of groundwater contamination is defined in the
aguifer, likely corresponding to DNAPLs.

The extraction well network would be periodically evaluated and modified as necessary in order to enhance
recovery of contaminants and better control the dissolution of DNAPLs into groundwater.

As with Alternative 3, the treatment plant will be designed to comply with the final discharge limits once
they are established.

Cost: The estimated costs associated with this alternative are listed below. Costs are given over the flow
rate range of 175 gpm to 540 gpm.

Capital: $3,700,00 to $7,600,000
Annual operation and maintenance: $250,000 to $550,000
Net present worth (30-year): $7,500,000 to 16,100,000
Time to Implement: Six to twelve months to implement.

2.7 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives presented in Section 2.6 were evaluated in the FFS against nine criteria identified
in the NCP.

2.7.1 THRESHOLD CRITERIA

Overall Protection of Human Health and the Environment

The Site 1 RAOs include:

• Preventing or minimizing exposure of potential onsite residents and construction workers to
contaminated groundwater originating from Site 1.

• Preventing or minimizing migration of contamination from Site 1.

Alternative 1 does not achieve either RAO. Alternative 2 prevents exposure to contaminated groundwater
through groundwater use restrictions, but off-site migration is not prevented and contaminated groundwater
will continue to discharge to surface water and sediments. Alternatives 3 and 4 attain both RAOs.

However, because of the presence of DNAPLs, neither of these alternatives are expected to attain MCLs over
the 30-year project life. Alternative 4 however, does have a containment plan for areas of groundwater that
have DNAPLs.

Compliance with Applicable or Relevant and Appropriate Requirements

Groundwater chemical-specific ARARs (MCLs) would likely not be attained during the 30-year project life by
any alternative. This is due to the probable existence of DNAPLs which may provide a continual source of
contamination.

However, alternatives 3 and 4 are expected to achieve the MCLs in areas where DNAPLs do not exist.
Alternative 4 will enhance contaminant removal by setting up containment of the area of groundwater
contaminated with DNAPLs and better control the possible spread of dissolved DNAPLs. This will likely
increase the volume of groundwater where MCLs are attained at Site 1.
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All alternatives would comply with location-specific ARARs. Applicable ARAR focus on the presence of the
100-year floodplain of the North Branch Potomac River. All alternatives would comply with action-specific
ARARs as well.

2.7.2 PRIMARY BALANCING CRITERIA

Long-term Effectiveness and Permanence

Alternatives 2 through 4 minimize the risk associated with groundwater contaminants remaining at Site 1.
Alternative 2 provides the lowest degree of minimization by the use of deed and groundwater use restrictions.
Alternative 2 does not prevent or minimize off-site migration of groundwater contaminants and conseguently,
surface water and sediment contamination would continue. Alternative 3 prevents off-site migration through
groundwater extraction. Alternative 4 provides the most significant degree of risk minimization. The
performance of the extraction well network in this alternative would be periodically evaluated and modified.

Wells that no longer produce contaminated groundwater concentrations above MCLs would be shut off, providing
residual groundwater contaminant concentrations do not present unacceptable risk to human and ecological
receptors in the river. Areas with sustained high concentrations of VOCs would be targeted enhancing
contaminant removal, containment, and controlling dissolution of DNAPLs. Five year site reviews are reguired
for each alternative.

Reduction of Toxicity, Mobility, or Volume of Contaminants Through Treatment

Alternatives 3 and 4 provide reductions in groundwater toxicity, mobility, and volume using a treatment
plant. However, Alternative 4 enhances contaminant removal, establishes containment of the DNAPLs, and
better controls the dissolution of DNAPLs into groundwater by targeting DNAPLs. These alternatives will
prevent the discharge of contaminated groundwater to surface water and sediments, allowing contaminants in
these media to undergo processes of volatilization, degradation, dilution, mixing, and sediment erosion or
removal, effectively reducing the toxicity, mobility, and volume of contamination associated with surface
water and sediments. Alternatives 1 and 2 provide no reduction in toxicity, mobility, or volume for
groundwater, surface water, or sediments.

Short-Term Effectiveness

Alternatives 1 and 2 can be implemented most guickly, however they do not meet the remedial action
objectives. Alternatives 3 and 4 can both be implemented in about the same amount of time, six to twelve
months.

The no action alternative and alternative 2 involve no construction or site activities, and would therefore
produce no disturbance to the surrounding community and environment. Alternatives 3 and 4, which reguire well
installation and the construction of a groundwater treatment plant and a significant piping network, produce
minimal to moderate disturbance to the community. All construction will take place at Site 1 on ABL
property. The majority of the risk results from fugitive dust emissions which can be controlled.

Implementabili ty

Alternatives 1 and 2 reguire no technical innovation. Alternatives 3 and 4 reguire the design and
construction of an effective extraction well network and the construction of a complex treatment facility.
Groundwater extraction in fractured bedrock is complicated.

Aguifer testing will be necessary to evaluate whether a well network is capable of capturing the contaminant
plume. There are many specialty vendors to provide expertise in sizing the treatment plant components.

Jar testing is reguired to design the metals precipitation, and pH adjustment process, and to select the
optimum polymer dosage for flocculation of the inorganics in the groundwater treatment plant.

Cost

The annual operating and maintenance (O&M) cost is estimated to be the same for alternatives 3 and 4. On a
present worth basis, Alternative 4 is slightly more costly, at $7,500,000 at a proposed flow rate of 175
gallons per minute(gpm) and $16,100,000 at a flow rate of 540 gpm. The present worth of Alternative 3 is
$7,400,000 at a flow rate of 175 gpm and $16,000,000 at a flow rate of 540 gpm. Alternative 2 is the least
expensive alternative (excluding the No Action Alternative), with a present worth of $50,000.
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2.7.3 MODIFYING CRITERIA

State Acceptance

The West Virginia Division of Environmental Protection on behalf of the State of West Virginia, has reviewed
the information available for Site 1 OU 3 and has concurred with the selected remedy.

Community Acceptance

Community Acceptance summarizes the public's general response to the alternatives described in the Proposed
Plan and the Focused Feasibility Study. No written comments were received during the forty-five day comment
period, which began on October 22 and ended on December 9, 1996. The comments recorded at the Proposed Plan
Public Meeting held October 29, 1996 and the responses are referenced in the Responsiveness Summary, Section
3.0 and included in Appendix B of the ROD.

2.8 THE SEIiECTED REMEDY

Alternative 4 - Sitewide Groundwater Extraction/Targeting DNAPLs, and Air Stripping, is the selected remedial
alternative.

Based on available information and the current understanding of Site 1 conditions, Alternative 4 appears to
provide the best balance with respect to the nine NCP evaluation criteria. In addition, the selected
alternative is anticipated to meet the following statutory reguirements:

• Protection of human health and the environment (groundwater, surface water, and sediment).

• Compliance with ARARs. While compliance with chemical-specific ARARs (MCLs) for groundwater
will not likely occur for the entire site during the 30-year project life, it is estimated
that a major portion of the aguifer will be remediated to MCLs in 30 years, with the
remainder of the aguifer (DNAPL-zone) to be hydraulically-contained with continued
groundwater extraction.

• Cost-effectiveness.

• Utilization of permanent solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable.

The major components of the selected remedy include:

• Extraction of contaminated groundwater using an extraction well network to remove
contaminated groundwater from both the alluvial and bedrock aguifers. Groundwater modeling
and aguifer testing shall be used to design the extraction wells and the extraction network.
The number and location of the extraction wells shall be specified during remedial design.
The extraction system will be carefully monitored on a regular basis and its performance
evaluated.

This evaluation may provide further information concerning the extent of the DNAPL-zone.

• An above ground treatment system. One or more of the treatment technologies - air stripping,
granular activated carbon (GAG), chemical /UV oxidation - shall be used for treating agueous
contaminants in the extracted groundwater. Other technologies will also be used as needed in
the treatment system for removal of dissolved inorganics and total suspended solids. The
actual technologies and seguence of technologies used for the treatment system will be
determined during remedial design. Final selection of these technologies will be based on
additional, site information to be collected during remedial design.

• Discharge of the treated groundwater to North Branch Potomac River. Sampling shall be
conducted before and after discharge to ensure that the discharge is not causing an
exceedence of Ambient Water Quality Criteria. A portion of the treated groundwater will be
utilized by the facility, on an as needed basis, for steam generation.

• Long-term groundwater monitoring will be performed, including guarterly sampling for 30
years. The groundwater monitoring plan will be developed during remedial design.
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• Land-use restrictions to prohibit the on-site use of untreated groundwater.

The primary goals for the groundwater portion of this remedial action is for hydraulic containment of the
likely DNAPL-zone and to restore the maximum areal extent of both the alluvial aguifer and the bedrock
aguifer to its beneficial uses. At Site 1, the aguifers are potentially useable as a source of drinking
water and the bedrock aguifer is currently used off-site for this purpose. Based on information obtained
during the remedial investigation and on a careful analysis of all remedial alternatives, the Navy, WVDEP,
and the EPA believe that the selected remedy will achieve these goals.

The selected remedy will include groundwater extraction for an estimated period of 30 years, during which the
system's performance will be carefully monitored, and adjusted as warranted by the performance data collected
during operation.

Refinement of the extraction system may be reguired, if the Navy, WVDEP, and the EPA determines that such
measures will be necessary in order to restore the maximum areal extent of the aguifers in a reasonable
timeframe, to provide a more efficient containment of the DNAPL-zone, or to significantly reduce the
timeframe or long-term cost of attaining this objective.

Refinement of the extraction system may include any or all of following:

1) Adjusting the rate of extraction from some or all wells;

2) Discontinuing pumping at individual wells where cleanup goals have been attained:

3) Pulsed pumping of some or all extraction wells to eliminate flow stagnation areas, allow sorbed
contaminants to partition into groundwater, or otherwise facilitate recovery of contaminants from the
aguifers; and

4) installing additional groundwater extraction wells to facilitate or accelerate cleanup of the
contaminant plume.

The primary goal for the surface water and sediment portion of this remedial action is to stop the migration
and discharge of contaminated groundwater into the North Branch Potomac River and to allow processes of
volatilization, degradation, dilution, mixing, and sediment removal or erosion to clean the river. The
selected remedy will achieve this goal.

The selected remedy addresses all contaminated media at Site 1, except contamination associated with surface
and subsurface soil overlying the groundwater aguifers. As discussed previously, a separate FFS will be
prepared which addresses soil contamination as operable Unit 4 at Site 1.

2.8.1 PERFORMANCE STANDARDS

The performance standards outlined below shall be used to evaluate the overall performance of the selected
remedy.

A sufficient number of extraction wells shall be installed to achieve three remedial objectives for both
aguifers: 1) minimizing further migration of contaminants from suspected subsurface DNAPL source areas to
the surrounding groundwater; 2) minimizing further migration of the leading edge of the contaminant plume;
and 3) capturing the Site 1 groundwater contaminant plume and preventing discharge of contaminated
groundwater into the North Branch Potomac River along Site 1.

All extracted groundwater shall be treated to levels meeting the substantive reguirements of the National
Pollutant Discharge Elimination System (NPDES).

The Ambient Water Quality Criteria (AWQC) for water and organisms shall be considered further in the
calculation of final discharge limits to be protective of human health and the environment.

All emissions from the air stripper shall be in compliance with the Clean Air Act and the reguirements of the
West Virginia Air Pollution Control Act.

Surface water and sediments in the North Branch Potomac River shall be monitored according to the substantive
reguirements outlined in the NPDES permit. Additionally, surface water and sediment will be sampled to
monitor the contaminant concentrations in the river. This data will be used to evaluate the effectiveness of
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the extraction well network in reducing discharge to the river. A surface water and sediment monitoring
plan, including the substantive reguirements of the NPDES permit, will be developed during the remedial
construction (action) phase.

A risk evaluation for fish ingestion shall be undertaken and reported before discharge of the treated
groundwater begins.

Groundwater extraction shall be terminated after groundwater contaminant levels in the dissolved TCE plume at
Site 1 are below the Maximum Contaminant Levels (MCLs) as defined in the Safe Drinking Water Act, providing
residual groundwater contaminant concentrations do not present unacceptable risk to human and ecological
receptors in the river. If the groundwater contaminant concentrations in the dissolved TCE plume at Site 1
reach background level of the contaminant, the wells can be shut off. The target level for total noncancer
risk is represented by the hazard index (HI) of not more than 1 and for a total cancer risk within the range
of 1 x 10 -6 to 1 x 10 -4. To this end, extraction wells and monitoring wells shall be sampled for at least
30-years.

The number and location of these monitoring and extraction wells shall be specified during the remedial
design, and additional monitoring wells shall be installed, if reguired. The 0 & M plan for the groundwater
treatment plant and extraction well network will be developed during the remedial construction (action)
phase. If sampling confirms that MCLs or background levels have been attained at individual wells and remain
at the reguired levels for three consecutive sampling periods, operations at those wells can be suspended.
The sampling periods will be determined during remedial construction (action) phase and may vary during the
life of the project. The sampling periods can not be changed unless the Navy, WVDEP, and the EPA agree on
the change.

If subseguent monitoring shows the groundwater concentrations of any contaminant of concern in these wells to
be above MCLs or background levels, pumping at those wells shall be restarted.

2.9 STATUTORY DETERMINATIONS

Remedial actions must meet the statutory reguirements of Section 121 of CERCLA, 42 U.S.C. °9621 as discussed
below.

Remedial actions undertaken at NPL sites must achieve adeguate protection of human health and the
environment, comply with applicable or relevant and appropriate reguirements of both Federal and State laws
and regulations, be cost effective, and utilize, to the maximum extent practicable, permanent solutions and
alternative treatment or resource recovery technologies. Also, remedial alternatives that reduce the volume,
toxicity, and/or mobility of hazardous waste as the principal element are preferred. The following
discussion summarizes the statutory reguirements that are met by this remedial alternative. Refer to the
attached ARAR table for more information on specific ARARs mentioned below.

2.9.1 Protection of Human Health and the Environment

The selected remedial action will protect human health and the environment. The installation of extraction
wells and the construction of a groundwater treatment plant will prevent continued discharge of contaminated
groundwater to the river and will reduce contaminant concentrations in the aguifer.

However, due to the presence of DNAPLs, contaminant concentrations in the groundwater may not be remediated
at or below MCLs across a portion of Site 1 in a reasonable time frame. The DNAPL-zone shall be
hydraulically-contained with continued groundwater extraction.

A waiver for cleanup of the DNAPL-zone under the Safe Drinking Water Act and a variance for the West Virginia
Groundwater Protection Act may be justified because of technical impractability from an engineering
perspective and may be reguested at a later time after more information about the DNAPL-
zone is collected.

Processes, including volatilization, degradation, dilution, mixing, and sediment removal or erosion will
reduce contaminant concentrations in the river and will eliminate the associated risk of exposure to human
health and the environment.

Deed notations and property use and site access restrictions will prevent future use of untreated
groundwater, therefore eliminating direct contact, ingestion and inhalation threats associated with
groundwater contamination at the site.
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2.9.2 Compliance with ARARs

The selected remedy will be constructed to meet all applicable or relevant and appropriate requirements
(ARARs) whether chemical, action, or location specific with the following exception: Cleanup level MCLs,
within the DNAPL-zone, may be waived and a State required variance secured due to technical impracticability
from an enqineerinq perspective.

Chemical-Specific ARARs - Attainment of ARARs for qroundwater is accomplished throuqh the use of extraction
wells across Site 1 and treatment of extracted qroundwater. In order to comply with chemical-specific ARARs,
aquifer contaminant concentrations must be reduced to or below MCLs. This qoal is complicated by the
possible presence of DNAPLs providinq a lonq-term source of continuinq contamination.

This alternative will focus on remediation of the qroundwater to MCLs and containment of the contaminants in
the DNAPL-zone but, because of their presence, attaininq MCLs for all of the site is unlikely. Complete
aquifer restoration within the DNAPL-zone may be technically impracticable from an enqineerinq perspective,
and for this reason the ARAR in the DNAPL-zone may be waived accordinq to CERCLA °121(d) (4) (c) , 42 U.S.C.
°9621(d)(4)(c) in addition, it may be necessary to secure a variance from the West Virqinia Groundwater
Protection Act accordinq to West Virqinia Code °22-12-5(d), °47 CSR 57.

Under this remedial action, extracted qroundwater will be treated, then used for boiler make-up or discharqed
to the North Branch Potomac River.

Chemical-specific ARARs require contaminant concentrations in treated qroundwater to be less than or equal to
discharqe limits established by the State of West Virqinia and the federal qovernment. The qroundwater
treatment system will be desiqned to meet these criteria.

Location-Specific ARARa - Site 1 is partially located within the 100-year floodplain of the river. Accordinq
to 40 CFR 264.18(b), any facilities constructed in the floodplain of a river must be desiqned and constructed
to avoid washout.

The qroundwater treatment plant will be located an appropriate distance from the river, and outside the
limits of the floodplain so that washout would not occur.

Discharqe pipinq would be located in the floodplain, and therefore, would incorporate concrete collars at
intervals to counteract buoyant forces actinq on the pipe durinq floodinq.

The Navy performed an ecoloqical risk assessment as part of the Focused RI. A site survey was performed, and
information was qathered concerninq the presence of endanqered or threatened species on Site 1.
Correspondence with federal requlatory aqencies indicated that, except for the occasional transient
individuals, no federally listed or proposed endanqered species are known to exist on Site 1. Therefore, the
requirements of the Endanqered Species Act of 1973 (16 USC 1536(a)) will likely not be applicable to
remediation activities occurrinq on Site 1.

The Wild and Scenic Rivers Act (16 USC 1271 et seq.) requires the avoidance of takinq action that will have a
direct adverse effect on a scenic river. Because construction activities alonq the river bank may impact
river water quality, this ARAR is potentially applicable. Erosion and sediment controls will be incorporated
into the remedial desiqn in order to comply with this ARAR.

Action-Specific ARARs - The State of West Virqinia Groundwater Protection Act requlations (47 CSR °58-4.7 to
4.7.4) require that pipelines which convey contaminants shall preferentially be installed above qround.
Further, 47 CSR 58-4.4.1 requires that loadinq and unloadinq stations includinq but not limited to drums,
trucks and railcars shall have spill prevention and control facilities and procedures as well as secondary
containment, if appropriate or otherwise required. Spill containment and cleanup equipment shall be readily
accessible,

All residuals from the qroundwater treatment plant will be properly handled, characterized, and underqo
proper disposal followinq federal and state requlations such as the Resource Conservation and Recovery Act
(RCRA) (40 CFR 262.34, 40 CFR 262.171 to 173, 40 CFR 264.111, 174, 175, 176, and 177).

All emissions from the air stripper shall be in compliance with the Clean Air Act (40 C.F.R. 52 and 61, and
CAA Sections 101 and 112) and the requirements of the West Virqinia Air Pollution Control Act (45 CSR °7-4.2,
45 CSR °25-3.1 to 3.3, 45 CSR °25-4.1 to 4.3, and 45 CSR °30) and Maryland's Air Quality requlation (COMAR
26.11).
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Post-closure use of the property would be restricted during 30-year project life because the aquifers will
most likely remain contaminated. Section 121 of CERCLA, 42 U.S.C. °9621 as amended by SARA, requires a
periodic review of remedial actions at least every five years for as lonq as contaminants which pose a threat
to human health and the environment remain onsite.

2.9.3 Cost-Effectiveness

The selected remedy is the most cost effective alternative in meeting the RAOs. The "no action" and
"institutional control" alternatives are less costly than the selected alternative, however these
alternatives do not meet all of the RAOs. Although Alternatives 3 and 4 are approximately the same cost,
the selected remedy, Alternative 4, provides for better control of DNAPLs.

2.9.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable ("M.E.P.")

The selected remedial action utilizes permanent treatment technologies to the maximum extent practicable for
this operable unit.

The selected remedy will greatly reduce contamination in surface water and sediment and dissolved
contamination in the groundwater, providing a permanent solution in these contaminated areas. In addition,
the groundwater extraction system will be modified as necessary to contain DNAPLs. Finally, a portion of the
treated groundwater will be utilized by the facility for boiler make-up.

2.9.5 Preference for Treatment an a Principal Element

The statutory preference for treatment is satisfied by using aboveground treatment system to treat
contaminated groundwater at Site 1.

2.9.6 Documentation of Significant Changes

The selected remedy is the same alternative identified as the recommended alternative in the Proposed
Remedial Action Plan and that was presented to the public at the public meeting held October 29, 1996.

There were no significant changes to the recommended remedial action alternative presented in the Proposed
Plan.
-------
3.0 RESPONSIVENESS SUMMARY

The selected remedy for Site 1 OU 3 is the sitewide groundwater extraction, targeting DNAPLs, and air
stripping. No written comments, concerns, or guestions were received by the Navy, EPA, or the State of West
Virginia during the public comment period from October 22, 1996 to December 9, 1996. A public meeting was
held on October 29, 1996 to present the Proposed Plan for Site OU 3 and to answer any guestions on the
Proposed Plan and on the documents in the information repositories. Several guestions were answered during
the meeting. Based on the limited comments, the public appears to support the selected remedy. The
transcript of the meeting is part of the administrative record for this Operable Unit. A summary of comments
received during the Public Meeting is attached as Appendix C.

3.1 BACKGROUND ON COMMUNITY INVOLVEMENT

The Navy and ABL has had a comprehensive public involvement program for several years. Starting in 1993, a
Technical Review Committee (TRC) would meet on average twice a year to discuss issues related to
investigative activities at ABL.

The TRC was comprised of mostly governmental personnel, however a few private citizens attended the meetings.

In early 1996, the Navy converted the TRC into a Restoration Advisory Broad (RAB) and 8-10 community
representatives joined. The RAB is co-chaired by a community member and has held meetings approximately every
three months since.

The Focused Feasibility Study for Site 1 and the Proposed Plan were both discussed at the RAB meetings and a
Site 1 tour was undertaken during a special RAB meeting.

Community relations activities for the final selected remedy include:

• The documents concerning the investigation and analysis at Site 1, as well as a copy of the
Proposed Plan was placed in the information repository at Fort Ashby and La Vale Libraries.

• Copies of the documents, including the Proposed Plan were sent to the technical committee of
the RAB.

• Newspaper announcements on the availability of the documents and the public comment
period/meeting date was placed in the Cumberland Times on October 18, 1996.

• The Navy established a 45-day public comment period starting October 22, 1996 and ending
December 9, 1996 to present the Proposed Plan.

• A Public Meeting was held October 29, 1996 to answer any guestions concerning the Site 1 OU 3
Proposed Plan. Approximately 30 people, including Federal, State and local government
representatives attended the meeting. A summary of comments received during the Public
Meeting is attached as Appendix C.
-------
APPENDIX A

TOXICOLOGICAL PROFILES FOR COCs AT SITE 1
(Source: Region III TOX PROFILES)

VOLATIIiE ORGANIC COMPOUNDS VOCs

CHLOROFORM

Chloroform has a molecular weight of 119.38, and exists at room temperature as a clear, colorless liquid with
a boiling point of 61.7 C. It is widely used in industry as a solvent, feedstock, and sterilizing agent, and
is found in all chlorinated public water supplies (because it is a by-product of the chlorination process).
Chloroform is soluble in water, acetone, and non-polar solvents, and volatilizes readily from solution. It
is readily taken into the body by inhalation, ingestion, and dermal or eye contact.

Chloroform is a Class B2 carcinogen, because it causes increases in kidney tumors in rats, and in liver
tumors in mice. There is also suggestive evidence from epidemiological studies that exposure to chloroform
and other trihalomethanes is associated with an increased incidence of bladder tumors in humans. Other toxic
effects of chloroform include central nervous system depression; eye, skin, and gastrointestinal irritation;
and damage to the liver, heart, and kidney.

1,1-DICHLOROETHANE

Dichloroethane (1,1-) is a colorless liguid with a chloroform-like odor. It is used as a solvent and
cleaning and degreasing agent as well as in organic synthesis as an intermediate. Exposure to
1,1-dichloroethane may occur through inhalation, ingestion, eye and skin contact. Direct contact to
1,1-dichloroethane may cause skin irritation. Oral exposure to 1,1-dichloroethane has been shown to cause
mammary gland, liver and kidney tumors in rats and mice. Therefore, the EPA has classified 1,1-dichloroethane
as a Group C possible human carcinogen.

1,2-DICHLOROETHANE

1,2-Dichloroethane (1,2-DCA) is used in synthetics (nylon, rayon, rubber, plastics) industries. It can be
used as a solvent, fumigant, and degreaser. It may be used in the photographic, adhesive, water softening,
cosmetic, and pharmaceutical industries (Sittig, 1985).

Prolonged dermal contact with 1,2-DCA can cause irritation and dermatitis. Symptoms of inhalation exposure
can include CNS effects such as dizziness and depression of respiration, as well as nausea.

EPA has classified 1,2-DCA as a Group 32 probable human carcinogen. 1,2-DCA has also been shown to alkylate
DNA.

1,1-DICHLOROETHENE

1,1-Dichloroethene (1,1-DCE), formerly known as vinylidene chloride, is used in the manufacture of 1,1,1-
trichloroethane and in polymers. Polymer applications include mortars, concretes, and fabrics (Sittig, 1985).

1,1-DCE is an irritant that can also affect the liver. Inhalation of high concentrations of 1,1-DCE has
resulted in CNS depression, as well as liver and kidney damage. 1,1-DCE is highly volatile and is readily
absorbed by the respiratory and GI tracts. EPA has classified 1,1-DCE as a Group C possible human
carcinogen. 1,1-DCE has been shown to alkylate DNA.

1,2-DICLOROETHENE

1,2-Dichloroethene (1,2-DCE) is used as a solvent for waxes, resins, and acetylcellulose. It is also used in
the rubber extraction, refrigeration, and Pharmaceuticals industry (Sittig, 1985).

1,2-DCE can irritate the skin and mucous membranes. Via the inhalation route, dizziness, nausea, and
vomiting and CNS depression may occur (Sittig, 1985). The lungs, liver, and kidneys may be affected.

1,2-DCE is not classified as a carcinogen by EPA.
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METHYLENE CHLORIDE (DICHLOROMETHANE)

Methylene chloride, also known as dichloromethane, is a volatile solvent and common laboratory contaminant.
Like many volatile solvents, methylene chloride can affect the nervous system, especially after inhalation
exposure. Potential effects include dizziness, numbness, eye and skin irritation, and cardiac effects.

Methylene chloride is classified by the EPA as a Group B2 (probable human) carcinogen via the oral and
inhalation routes of exposure.

TETRACHLOROETHENE

Tetrachloroethene (PCE), also known as perchloroethylene, is a commonly used solvent in the dry cleaning,
degreasing, and textile industries. It is also used as an intermediate in the manufacture of organic
chemicals (Sittig, 1985).

Irritation of the skin can occur after dermal exposure. High-level inhalation exposure can cause respiratory
and eye irritation. Other effects include CNS depression and liver damage (Sax, 1989).

EPA ECAO classifies PCE as a Group B2 probable human carcinogen, although this is not considered Agency-wide
consensus at this time.

TOLUENE

Toluene is a clear, colorless, noncorrosive liguid with a sweet, pungent, benzenelike odor. Toluene may be
encountered in the manufactures of benzene. It is used as a chemical feed for toluene diisocyanate, phenol,
benzyl and benzoyl derivatives, benzoic acid, toluene sulfonates, nitrotoluenes, vinyltoluenes, and
saccharin. As a solvent, toluene is used for paints and coatings. It is also used as a component of
automobile and aviation fuels.

Toluene has been shown to be embryotoxic in experimental animals. Chronic inhalation exposures to high
levels of toluene produce central nervous system depression and narcosis in humans. Chronic exposure to
toluene at high concentrations by mammals may produce cerebellar degeneration and an irreversible
encephalopathy. Co-administration of toluene along with benzene or styrene has been shown to suppress the
metabolism of benzene or styrene in rats. In humans toluene may cause irritation to the eyes, respiratory
tract, and skin. Acute exposure to toluene causes central nervous system depression, the symptoms of which
include headache, dizziness, fatigue, muscular weakness, drowsiness, loss of coordination with staggering
gait, skin paresthesia, collapse, and coma.

1.1.1-TRICHLOROETHANE

1,1,1-Trichloroethane is a colorless, nonflammable liguid with an odor similar to chloroform. In recent
years it has been used as a substitute for carbon tetrachloride. In liguid form it is used as a degreaser
and for cold cleaning, dip-cleaning, and bucket cleaning of metals. 1,1,1-trichloroethane is a solvent used
in dry-cleaning, vapor degreasing, and as a propellant.

1,1,1-Trichloroethane is irritating to the eyes on contact with either liguid or vapor phases. This effect
is usually first noted in acute exposures. Mild conjunctivitis may develop but recovery is usually rapid.
The solvent's defatting properties may produce a dry, scaly dermatitis upon repeated contact with the skin.
Acute exposures may lead to dizziness, drowsiness, increased reaction time, loss of coordination,
unconsciousness, and death. Inhalation exposure to high concentrations of 1,1,1-trichloroethane depress the
central nervous system; affect cardiovascular function; and damage the lungs, liver, and kidneys in animals
and humans. Mucous membranes may also be irritated by exposure to this solvent.

TRICHLOROETHENE

Trichloroethene (TCE) has been used as a solvent in degreasing operations associated with both metal-using
industries and dry cleaning. TCE has been used as an intermediate in the production of pesticides, waxes,
gums, resins, paints, varnishes, and trichloroacetic acid (Sittig, 1985).

TCE toxicity can include dermatitis, CNS depression, anesthesia, and effects on the liver, kidneys, and
heart. TCE is a volatile compound, and inhalation exposure may be significant.

The carcinogenicity of TCE is currently under review.
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VINYL CHLORIDE

Vinyl chloride is a volatile organic compound used in the manufacture of polyvinyl chloride and other resins.
It is also used as a chemical intermediate and a solvent (Sittig, 1985). Vinyl chloride can be found
environmentally as a breakdown product of tetrachloroethene, trichloroethene, 1,1-dichloroethene, and
1,2-dichloroethene.

Vinyl chloride can cause skin irritation and CNS depression. Chronic exposure may cause hepatic damage
(Doull, 1986). Vinyl chloride is classified by EPA as a Group A (known) human carcinogen, and has been
specifically associated with hemangiosarcoma of the liver.

INORGANICS

BARIUM

Barium is an extremely reactive silver white metal produced by the reduction of barium oxide. It may ignite
spontaneously in air in the presence of moisture. Barium is insoluble in water but most of the barium
compounds are soluble in water. Barium has many uses. It is used for removal of residual gas in vacuum
tubes and in metal alloys (e.g., nickel and lead). It is used in the manufacture of lithopone (a white
pigment in paints); in synthetic rubber vulcanization; in x-ray diagnostic work; in glassmaking; and
in electronics industries. Long-term oral exposure to soluble barium salts may increased blood pressure.
Short-term exposure may cause prolonged stimulant action on muscle. Occupation-inhalation exposure to barium
may result in Baritosis, a non-cancerous lung disease. There are no reports of carcinogenicity associated
with exposure to barium.

MANGANESE

Manganese is used in the manufacture of dry cell batteries, paints, dyes, and in the chemical and glass and
ceramics industries. Manganese is an essential nutrient in food; the average human intake is reported to be
approximately 10 mg/day (Sittig, 1985).

Previous reports of neurotoxicity from manganese were generally reported from high-level occupational
exposure to dust and fumes. More recent studies have focused on exposures to drinking water, with subtle
neurologic effects being reported after chronic consumption of high concentrations of manganese in water
(Sittig, 1985; USEPA, 1993).

Manganese is not classified as a carcinogen by EPA.

TOXICOLOGICAL PROFILES FOR CONTAMINANTS FOR FUTURE CONSIDERATION

INORGANICS

ANTIMONY

Antimony is a soft metal insoluble in water and organic solvents. It is widely used in the production of
alloys. Short-term oral exposure to antimony has been shown to cause burning stomach pains, colic, nausea and
vomiting in humans. Long-term occupational inhalation exposure is associated with heart disease in both
humans and laboratory animals, and decreased longevity and altered cholesterol levels in rats. Antimony has
not been tested for carcinogenicity.

ARSENIC

Arsenic has been used by the agricultural, pigment, glass, and metal smelting industries. Arsenic is a
ubiguitous metalloid element. Acute ingestion of arsenic can be associated with damage to mucous membranes
including irritation, vesicle formation, and sloughing. Arsenic can also be associated with sensory loss in
the peripheral nervous system and anemia. Liver injury is characteristic of chronic exposure. Effects of
arsenic on the skin can include hyperpigmentation, hyperkeratosis, and skin cancer.
(Casarett & Doull, 1986)

EPA classifies arsenic in drinking water as a Group A known oral human carcinogen.
-------
CHROMIUM

Chromium is a heavy metal that generally exists in either a trivalent or hexavalent oxidation state.
Hexavalent chromium is soluble and mobile in ground water and surface water. Trivalent chromium is in the
reduced form and is generally found absorbed to soil; and therefore, it is less mobile. Hexavalent chromium
is used in chrome plating, copper stripping, aluminum anodizing, as a catalyst, in organic synthesis and
photography. Exposure to chromium compounds can occur through ingestion, inhalation and skin contact.

Hexavalent chromium may have a direct corrosive effect on the skin and may cause upper respiratory tract
irritation. Short term exposure to dust or mist of hexavalent chromium may cause upper respiratory distress,
headache, fever, and loss of weight. Long term occupational inhalation exposure to dust and fumes of
hexavalent chromium has been shown to cause lung cancer in humans, especially those in the chromate-producing
industry. In addition, a number of salts of hexavalent chromium are carcinogenic in rats. The EPA has
classified hexavalent chromium as a Group A human carcinogen. Trivalent chromium is an essential nutrient
and has low toxicity; however, at high levels, it may cause skin irritation.

LEAD

Lead has been used as a gasoline additive (tetraethyl lead) and in paint pigments, batteries, X-ray
shielding, and plumbing, and has been associated with smelting and plating industries.

The target organs for lead exposure include the nervous system, hematopoietic system, kidneys, and
reproductive system. Symptoms of severe toxicity may include anemia, encephalopathy and peripheral
neuropathy. Recently, an association between low-level lead exposure and impaired neurological development
in children has been suggested.

EPA considers lead to be a Group B2 probable human carcinogen via the oral route, but no Agency-wide
consensus has been reached concerning a cancer slope factor.

MERCURY

Mercury is a silver-white, heavy liguid metal that is slightly volatile at ambient temperatures. Mercury can
occur in the environment in either the organic (usually methyl) or inorganic (metallic) form. Mercury
compounds are used as preservatives, disinfectants, fungicides, and germicides. Additionally, mercury is
used in the plating, dyeing, textile and pharmaceutical industries. In humans, prenatal exposure to
methylmercury has been associated with brain damage. Other major target organs for organic mercury compounds
in humans are the central and peripheral nervous systems and the kidney. In animals, toxic effects also
occur in the liver, heart, gonads, pancreas, and gastrointestinal tract.

Experimental studies involving laboratory animals indicate that both organic and inorganic forms of mercury
are toxic to embryos.

NICKEL

Nickel is a white, hard, ferromagnetic metal that is a naturally-occurring element in the earth's crust and
is stable in the atmosphere at ambient temperatures. Nickel forms alloys with a variety of metals, including
copper, manganese, zinc, chromium and iron. Elemental nickel is used in electroplating and casting
operations, magnetic tapes, surgical and dental instruments, nickel-cadmium batteries, and colored ceramics.
Occupational exposure to nickel compounds has been associated with an increased incidence of nasal cavity and
lung cancers. For this reason, nickel refinery dust has been classified by the EPA as a Group A - Human
Carcinogen via the inhalation route of exposure. The most common reaction to nickel exposure is skin
sensitization. Nickel and its compounds also irritate the conjunctiva of the eye and the mucous membranes of
the upper respiratory tract.

SILVER

Silver is a white metal. Alloys of silver (e.g., copper, aluminum, cadmium, lead or antimony) are used in
the manufacture of silverware, jewelry, coins, automobiles bearings and grid in storage batteries, in
photographic films, in mirrors, as a bactericide for sterilizing water, fruit juices, etc. Some silver
compounds are also of medical importance as antiseptics or astringents. Exposure to silver can occur through
inhalation of fumes or dust, ingestion of solutions or dust, eye and skin contact. Eye and skin contact with
metallic silver may produce local permanent discoloration of the skin similar to tattooing. This process is
refer to as argyria. Argyria is characterized by a dark, slate-grey color pigmentation of the skin.
-------
Generalized argyria can also develop through exposure to silver oxides or salts through ingestion and
inhalation of dust. Silver is not classifiable as to carcinogenicity.

THALLIUM

Thallium is a byproduct of iron, cadmium, and zinc refining. It has been used in alloys, optical lenses,
jewelry, semiconductors, and dyes and pigments. Thallium, compounds have been used as pesticides. (Casarett
and Doull, 1986)

Thallium, toxicity can result in hair loss, gastrointestinal irritation, paralysis, nephritis, and liver
necrosis. Thallium, is one of the more toxic metals, with an estimated lethal dose in humans of 8 to 12
mg/kg. (Casarett and Doull, 1986)

ZINC

Zinc is a bluish-white metal that is stable in dry air, but becomes covered with a white coating on exposure
to moist air. Zinc is present in abundance in the earth's crust. Zinc chloride is used as a wood
preservative, in dry battery cells, in oil refining operations, and in the manufacture of dyes, activated
carbon, deodorants and disinfecting solutions. Zinc chromate and zinc oxide are used primarily as pigments.
Exposure to zinc compounds can cause skin sensitization, irritation of the nose and throat, fever, and
fatigue.
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ARAR or TBC
APPENDIX B
Applicable or Relevant and Appropriate Requirements
Site 1 Groundwater, Surface Water, and Sediments
Allegany Ballistics Laboratory, West Virginia
Regulation
Classification
Requirement Synopsis
I LOCATION
SPECIFIC
Endangered
Species Act of
1978

The
Archaeological
and Historical
Preservation Act
of 1974
16 USC 1531
50 C.F.R. Part
402

16 U.S.C
469
Applicable
Potentially
Applicable
Act requires federal agencies to ensure that any action authorized by any
agency is not likely to jeopardize the continued existence of any
endangered or threatened species or adversely affect its critical habitat.

Requires actions to avoid potential loss or destruction of significant
scientific, historical, or archaeological data. Construction on previously
undisturbed land would require an archaeological survey of the area.
Rivers and
Harbors Act of
1890
33 USC 403
Applicable
The North Branch Potomac River is classified as a navigable river.
Permits required for structures or work in or affecting navigable waters.
Migratory Bird
Area
16 USC
Section 703
Applicable
Protects almost all species of native birds in the U.S. from unregulated
"take" which can include poisoning at hazardous waste sites Migratory
birds are encountered near the river at Site 1.
Wild and Scenic
Rivers Act
Fish and Wildlife
Coordination Act,
Section 662
16 USC 1271
et seq. And
section 7(a)

16 USC 662
Potentially
Applicable
Potentially
Applicable
Avoid taking or assisting, in action that will have direct adverse effect on
scenic rivers. Construction activities near the North Branch Potomac
River may have an adverse effect on the river.

Action taken should protect fish of wildlife. Response actions (treated
discharge) will be protective of human health and the environment.
Resource
Conservation and
Recovery Act
40 C.F.R.
264.18(b)
Potentially
Applicable or
Relevant and
Appropriate to
removal and
treatment
activities.
Site 1 is located in a 100-year floodplain. Applicable to hazardous waste
facilities constructed within 100-year floodplain. Relevant to
construction of facilities for management of materials similar to
hazardous waste. Facility must be designed, constructed, operated, and
maintained to avoid washout.
Groundwater
Protection Act
47 CSR 58- Relevant and Facility or activity design must adequately address the issues arising
4.10 Appropriate from locating in karst, wetlands, faults, subsidences, delineated wellhead
protection areas determined vulnerable.
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Executive Order
11988, Protection
of Floodplains
APPENDIX B
Applicable or Relevant and Appropriate Requirements
Site 1 Groundwater, Surface Water, and Sediments
Allegany Ballistics Laboratory, West Virginia
40 C.F.R. 6,
Appendix A,
excluding
sections
6(a) (2) .
6(a) (4) .
6(a) (6); 40
C.F.R. 6.302
Potentially
Applicable
Facilities or activities located within the floodplain must comply with
this order. Actions taken should avoid adverse effects, minimize
potential harm, restore and preserve natural and beneficial values.
Executive Order
11990, Protection
of Wetlands
40 C.F.R. 6,
Appendix A
Applicable
Action to minimize the destruction, loss, or degradation of wetlands
Procedures for
Implementing the
Reguirements of
the Council on
Environmental
Quality on the
National
Environmental
Policy Act

Endangered and
Threatened Fish
Species

Construction on
Nontidal Waters
and Floodplains

Nontidal Wetlands
40 C.F.R.
Part 6
Appendix A
Applicable
COMAR
09.02.12/
08.03.08

COMAR
08.05.03
COMAR
08.05.04/
08.05.07
This is EPA's policy for carrying out the provisions of Executive Order
11990 (Protection of Wetlands). No activity that adversely affects a
wetland shall be permitted if a practicable alternative that has less effect
is available. If there is no other practicable alternative, impacts must be
mitigated.
Applicable
Applicable
To Be
Considered
Actions will be performed to conserve endangered fish species and the
habitats they depend on.
Any remedial action that alters the waterway or floodplain in the State of
Maryland will follow these regulations.
Protect the nontidal wetlands of the State of Maryland.
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II ACTION
SPECIFIC
APPENDIX B
Applicable or Relevant and Appropriate Requirements
Site 1 Groundwater, Surface Water, and Sediments
Allegany Ballistics Laboratory, West Virginia
AIR

Clean Air Act

Clean Air Act
CAA Section
101 and 40
C.F.R. 52

40 C.F.R. 52
40 C.F.R. 60
Subpart
WWW and CC
Relevant and File an Air Pollution Emission Notice (APEN) with the State to include
Appropriate estimation of emission rates for the pollution expected. Design system
to provide an odor-free operation.

Applicable Predict total emission of volatile organic compounds (VOCs) to
demonstrate allowable emission levels from similar sources using
Reasonably Available Control Technology (RACT).

To Be New Source Performance Standard (NSPS): deals with non-methane
Considered organic compounds.
Clean Air Act
Clean Air Act
Clean Air Act
40 C.F.R. 61
CAA Section
112(D)

CAA Section
118
Relevant and
Appropriate
Relevant and
Appropriate

Applicable
Verify that emissions of mercury, vinyl chloride, and benzene do not
exceed levels expected from sources in compliance with hazardous air
pollution regulation.

Emission Standards for new stationary sources.
Control of pollution from Federal Facilities.
Air Pollution
Control Act
M5CSR7-4 2
Applicable
Allowable mineral acids stack gas concentration.
Air Pollution
Control Act

Air Pollution
Control Act and
the Hazardous
Waste
Management Act
M5CSR25-3.2
M5CSR25-4.3
Relevant and
Appropriate

Relevant and
Appropriate
Adopts by reference Table 25-A of the Code of Federal Regulations
Facility design, construction, maintain, and operate in a manner to
minimize hazardous waste constituents to the air.
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Air Pollution
Control Act
APPENDIX B
Applicable or Relevant and Appropriate Requirements
Site 1 Groundwater, Surface Water, and Sediments
Allegany Ballistics Laboratory, West Virginia
°45CSR27-3.1
thru °45-27-
3.5
Applicable
Best Available Technology requirements for the discharge of emissions
of toxic air pollutants.
Air Pollution
Control Act

Air Pollution
Control Act
°45CSR27-4.1
thru 4.2

°45CSR30
Applicable

Applicable
Best Available Technology requirements for Fugitive Emissions of
Toxic Air Pollutants.

Requirements for the air quality permitting system.
Air Quality
WATER
COMAR
26.11
To Be
Considered
Ambient air quality standards, general emissions standards, and
restrictions for air emissions from construction activities, vents, and
treatment technologies.
Criteria for
Classification of
Solid Waste
Disposal Facilities
and Practices
49C.F.R.
257.3-3(a)
Potentially
Applicable
A facility shall not cause a discharge of pollutants into the waters of the
U.S. that is in violation of the substantive requirements of the NPDES
under CWA Section 402, as amended.
Criteria for
Classification of
Solid Waste
Disposal Facilities
and Practices
49 C,F.R
257.3-3(a)
Potentially
Applicable
A facility or practice shall not cause nonpoint source pollution of the
waters of the U.S. that violates applicable legal substantive requirements
implementing an areawide or Statewide water quality management plan
approved by the Administrator under CWA Section 208, as amended
Criteria for 49 C.F.R.
Classification of 257.34 and
Solid Waste Appendix I
Disposal Facilities
and Practices
Potentially
Applicable
A facility or practice shall not contaminate an underground drinking
water source beyond the solid wage boundary or a court- or State-
established alternative.
Clean Water Act
40 C.F.R. 403
Applicable
Pretreatment Standards. Control the introduction of pollutants into
POTWs.
Clean Water Act
40 C.F.R. 121
Relevant and Contaminated groundwater will be cleaned up to MCLs, except in the
Appropriate DNAPL-zone which will be exempt because it is technically
impracticable based on engineering concerns.
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Clean Water Act
Clean Water Act
Clean Water Act
APPENDIX B
Applicable or Relevant and Appropriate Requirements
Site 1 Groundwater, Surface Water, and Sediments
Allegany Ballistics Laboratory, West Virginia
40 C.F.R.
122.44(a)
40 C.F.R.
122.41(1), (j)

40 C. F. R.
125.100
Applicable

Applicable

Applicable
Best Available Technology (BAT). Use BAT to control toxic and
nonconventional pollutants. Use best conventional pollutant control
technology (BCT) to control conventional pollutants.

Monitoring Reguirements. Discharge must be monitored to assure
compliance. Comply with additional substantive reguirements

Best Management Practices. Develop and implement a Best
Management Practice program to prevent the release of toxic
constituents to surface waters.
Groundwater
Protection Act
°46CSR12-3.1
thru 3.3 plus
Appendix A,
°47CSR58-1
to °47CSR58-
12
Relevant and This establishes the minimum standards of water purity and guality for
Appropriate groundwater located in the state.
Groundwater
Protection Act

Groundwater
Protection Act

Groundwater
Protection Act
Groundwater
Protection Act
M6CSR 12-3.3
M7CSR58-4 2
°47CSR58-
43-2

°47CSR58-
4.4.1
°47CSR58-
4.5.2
Applicable Constituents in groundwater shall not cause a violation of the standards
found at 46 CSR in any surface water.

Relevant and Subsurface bores of all types shall be constructed, operated and closed
Appropriate in a manner which protects groundwater.

Relevant and New areas used for storage shall be designed, constructed and operated
Appropriate to prevent release of contaminants.

Relevant and Loading and unloading stations including but not limited to drums,
Appropriate trucks and railcars shall have spill prevention and control facilities and
procedures as well as secondary containment

Relevant and New impoundments shall be designed and operated to prevent
Appropriate contamination of groundwater.
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Groundwater
Protection Act
Groundwater
Protection Act

Groundwater
Protection Act
APPENDIX B
Applicable or Relevant and Appropriate Requirements
Site 1 Groundwater, Surface Water, and Sediments
Allegany Ballistics Laboratory, West Virginia
°47CSR58-4.7
to 4.7.4
M7CSR58-4.8
°47CSR58-
4.9.4 to 4.9.7
Relevant and Pipelines conveying contaminants shall preferentially be installed above
Appropriate ground. Ditches conveying contaminants must have appropriate liners
Pumps and related eguipment must be installed to prevent or contain any
leaks or spills.

Relevant and Requirements for secondary containment for sumps and above ground
Appropriate tanks.

Applicable Groundwater monitoring stations shall be located and constructed in a
manner that allows accurate determination of groundwater quality and
levels, and prevents contamination of groundwater through the finished
well hole or casing. All groundwater monitoring stations shall be
accurately located utilizing latitude and longitude by surveying, or other
acceptable means, and coordinates shall be included with all data
collected.
Groundwater
Protection Act
M7CSR58-
3.13
Applicable
Adequate groundwater monitoring shall be conducted to demonstrate
control and containment of the substance. The director shall specify
which parameters should be monitored in a remedial operation
Groundwater monitoring must continue until results assure adequate
remedial action was taken.
Groundwater
Protection Act

Groundwater
Protection Act
Groundwater
Protection Act

Groundwater
Protection Act
°47CSR58-
8 1 2 to 8 1 3

°47CSR58-
4.10
°47CSR59-4.1
to 4.7

°47CSR 60-1
to 23
Relevant and
Appropriate

Relevant and
Appropriate
Relevant and
Appropriate

Applicable
Clean up actions shall not rely primarily on dilution and dispersion if
active remedial measures are technically and economically feasible

Facility or activity design must adequately address the issues arising
from locating in Karst, wetlands, faults, subsidence, delineated wellhead
protection areas determined vulnerable.

Monitoring well Drillers certification.
Monitoring well design Standards.
Groundwater
Protection Act
°47CSR60-5 Relevant and Requirements and procedures governing the installation and
to 18 and Appropriate development and/or redevelopment and reconditioning of temporary or
°47CSR60-20 permanent monitoring well(s), piezometer(s), recovery well(s), well(s),
to 22 and boreholes.
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Groundwater
Protection Act
APPENDIX B
Applicable or Relevant and Appropriate Requirements
Site 1 Groundwater, Surface Water, and Sediments
Allegany Ballistics Laboratory, West Virginia

M7CSR60-19 Relevant and Abandonment requirements and procedures for temporary or permanent
Appropriate monitoring well(s), piezometer (s), recovery well(s), well(s), and
boreholes.
Water Pollution
Control Act
Water Pollution
Control Act
°46 CSR 1-1 Relevant and Rules establishing the requirements governing the discharge or deposit
to 9 Appropriate of sewage, industrial wastes and other wastes into the waters of the State
and establishing water quality standards for the waters of the State
standing or flowing over the surface of the State.

°47CSR10 Applicable Requirements for NPDES
Water
Appropriation or
Use
COMAR
08.05.02
Applicable
Report monitoring well data for inclusion in Maryland database
Hearing
Procedures for
Waterway
Obstruction,
Waterway
Construction, and
Water
Appropriation and
Use Permits
COMAR
08.05.06
Applicable
Requirements for public information/notification of the use of State of
Maryland water resources.
Well Construction
Board of Well
Drillers
COMAR
26.04.04

COMAR
26.05 11
Relevant and
Appropriate

Applicable (wells
in Maryland)
Follow specifications for well construction and abandonment for wells in
Maryland.

Licensing requirements for persons drilling and installing wells in
Maryland.
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Water Quality

Discharge Limits
Permits
APPENDIX B
Applicable or Relevant and Appropriate Requirements
Site 1 Groundwater, Surface Water, and Sediments
Allegany Ballistics Laboratory, West Virginia
COMAR
26.08.02/
26.08.03/
26.08.04
Applicable
Discharge of treated groundwater will meet State NPDES limits. There
is an agreement between West Virginia and Maryland that the West
Virginia NPDES limits could apply to discharges from the West Virginia
shore.
Miscellaneous
Public Health
Laws of West
Virginia

Division of
Environmental
Protection
°64CSR42-
4.3.3.20 to
4.3.3 20.2.3

°38CSR11
Relevant and
Appropriate
Relevant and
Appropriate
Abandonment criteria for test wells and groundwater sources.
Requirements for spill prevention
Erosion and
Sediment Control,
Stormwater
Management

Resource
Conservation and
Recovery Act

Resource
Conservation and
Recovery Act
Resource
Conservation and
Recovery Act
Resource
Conservation and
Recovery Act
COMAR
26.09.01/
26.09.02
40 CFR
262.10 (a),
262.11

40 CFR
262.34
40 CFR
262.171, 172,
173
40 CFR
264.111
To Be
Considered
Applicable
Potentially
Applicable
Potentially
Applicable
Potentially
Applicable or
Relevant and
Appropriate
Any land clearing, grading, other earth disturbances require an erosion
and sediment control plan.
Waste generator shall determine if that waste is hazardous waste.
Generator may accumulate hazardous waste onsite for 90 days or less or
must comply with requirements for operating a storage facility.
Accumulation of hazardous waste onsite for longer than 90 days would
subject to the substantive RCRA requirements for storage facilities.

Containers of RCRA hazardous waste must be:
- Maintained in good condition.
- Compatible with hazardous waste to be stored.
- Closed during storage except to add or remove waste.

General performance standard requires elimination of need for further
maintenance and control: elimination of postclosure escape of hazardous
waste, hazardous constituents, leachate, contaminated run-off, or
hazardous waste decomposition products. May be relevant to active
management of wastes which are sufficiently similar to hazardous wastes.
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APPENDIX B
Applicable or Relevant and Appropriate Requirements
Site 1 Groundwater, Surface Water, and Sediments
Allegany Ballistics Laboratory, West Virginia
Resource
Conservation and
Recovery Act

Resource
Conservation and
Recovery Act
Resource
Conservation and
Recovery Act

Resource
Conservation and
Recovery Act

Resource
Conservation and
Recovery Act
Resource
Conservation and
Recovery Act
U.S. Department
of Transportation
40 CFR
264.174
40 CFR
264.175(a) and
(b)
40 C.F.R.
264.176
40 C.F.R.
264.177
40 C.F.R.
264.178
40 C.F.R.
268.40
40 C.F.R.
264.251
(except 251 (j),
251(e) (11))

49 C.F.R.
171.2(f)
Potentially
Applicable
Potentially
Applicable
Potentially
Applicable
Potentially
Applicable
Potentially
Applicable
Potentially
Applicable
Potentially
Applicable
Potentially
Applicable
Inspect Container storage areas weekly for deterioration.
Place containers on a sloped, crackfree base, and protect from contact
with accumulated liquid. Provide containment system with a capacity of
10 percent of the volume of containers of free liquids. Remove spilled or
leaked waste in a timely manner to prevent overflow of the containment system.

Keep containers of iqnitable or reactive waste at least 50 feet from the
facility property line.
Keep incompatible materials separate. Separate incompatible materials
stored near each other by a dike or other barrier.
At closure, remove all hazardous waste and residues from the
containment system, and decontaminate or remove all containers, liners.
Movement and disposal of hazardous waste to new location and
placement in or on land will triqqer land disposal restrictions for the
hazardous waste. Attain land disposal treatment standards before
disposinq of hazardous waste.

Waste put into waste pile subject to land ban requlations.
No person shall represent that a container or packaqe is safe unless it
meets the requirements of 49 USC 1802, et seq. Or represent that a
hazardous material is present in a packaqe or motor vehicle if it is not.
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APPENDIX B
Applicable or Relevant and Appropriate Requirements
Site 1 Groundwater, Surface Water, and Sediments
Allegany Ballistics Laboratory, West Virginia
U.S. Department
of Transportation
U.S. Department
of Transportation
U.S. Department
of Transportation
U.S. Department
of Transportation
U.S. Department
of Transportation
49 C.F.R.
171.2(g)
49 C.F.R.
171.300
49 C.F.R.
171.301
49 C.F.R.
171.302
49 C.F.R.
171.303
Potentially
Applicable
Potentially
Applicable
Potentially
Applicable
Potentially
Applicable
Potentially
Applicable
No person shall unlawfully alter or deface labels, placards, or
descriptions, packages, containers, or motor vehicles used for
transportation of hazardous materials.

Each person who offers hazardous material for transportation or each
carrier that transports it shall mark each package, container, and vehicle
in the manner reguired.

Each person offering non-bulk hazardous materials for transportation
shall mark the proper shipping name and identification number
(technical name) and consignee's name and address.

Hazardous materials for transportation in bulk packages must be labeled
with proper identification (ID) number, specified in 49 CFR 172 101
table, with reguired size of print. Packages must remain marked until
cleaned or refilled with material reguiring other marking.

No package marked with a proper shipping name or ID number may be
offered for transport or transported unless the package contains the
identified hazardous material or its residue.
U.S. Department
of Transportation

U.S. Department
of Transportation

U.S. Department
of Transportation
U.S. Department
of Transportation
49 C.F.R.
171.304

49 C.F.R.
171.400

49 C.F.R.
171.312
49 C.F.R.
171.504
Potentially
Applicable

Potentially
Applicable

Potentially
Applicable
Potentially
Applicable
The marking must be durable, in English, in contrasting colors,
unobscured, and away from other markings.

Labeling of hazardous material packages shall be as specified in the list.
Non-bulk combination packages containing liguid hazardous materials
must be packed with closures upward, and marked with arrows pointing
upward.

Each bulk packaging or transport vehicle containing any guantity of
hazardous material must be placarded on each side and each end with the
type of placards listed in Tables 1 and 2 of 49 CFR 172.504.
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APPENDIX C

SUMMARY OF COMMENTS RECEIVED DURING
PUBLIC MEETING AND RESPONSES

The following represents the Department of the Navy's responses to all the comments received on the subject
Proposed Plan. No written comments were received from any party by the Navy, WVDEP, or the EPA.
Consequently, the following is based on remarks made or guestions posed that were recorded and transcribed
during the public meeting held October 29, 1996 at the Bel Air Elementary School. Because the transcript of
the meeting was made from a recording, some minor editorial liberties were taken for clarification to a
comment or response. A complete copy of the transcript is included in the Administrative Record which can be
found in the information repositories located at:

Fort Ashby Public Library
Box 74, Lincoln Street
Fort Ashby, West Virginia 26719
Contact: Jean Howser
304/298-4493

La Vale Public Library
815 National Highway
La Vale, Maryland 21502
Contact: Sondra Ritchie
301/729-0855

Question 1: Do you (the Navy) ever analyze these materials? You call them DNAPLs (dense, non-agueous phase
liguids)?

Response: Yes. During the investigations, we collected soil and water samples for chemical analysis. The
analyses provide the concentrations of the contaminants. Very high concentrations are strong evidence there
is a contaminant source that will continue to dissolve over time. DNAPL presence is further deduced through
research of the contaminants, their concentrations and their distribution.

Question 2: Are the extraction wells going to be on both the north and south side of the solvent disposal
pits?

Response: The extraction wells will be situated to the north of the solvent disposal pits, between them and
the North Branch Potomac River. Groundwater modeling predicts this is the optimum location to achieve our
remediation goals.

Question 3: This proposed plan now presented is for the Site 1 groundwater. Is there to be a separate plan
for the soil and the surface water?

Response: This Site 1 proposed plan addresses groundwater, surface water and sediment. By containing and
treating the groundwater, we effectively remediate the surface water and sediment by not allowing the
contaminants to move into the River. This will allow any contamination currently present in the sediment and
the surface water to naturally attenuate or degrade. Regarding Site 1 soil, the Navy will develop an
additional Site 1 soil focused Feasibility Study that will lead to a proposed plan.

Question 4: Would the "plan" chosen for the soil affect how the proposed plan for the water will work?
Should they be done at the same time?

Response: The eventual "plan for the soil should not affect the proposed plan for the groundwater. The
"plan" that will address soil contamination, limited to the upper eight to ten feet, will have to take into
consideration the groundwater treatment technology in place.

Question 5: Is there any possibility of the air being contaminated in any of these sites and posing a risk
to the residents?

Response: Volatile organic compounds that are "stripped" from the groundwater will be captured and not
released. Various monitoring stations will be established to ensure our treatment system is effective and the
applicable requirements are being met. The monitoring plan will undergo review from the State of West
Virginia and the EPA.
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Question 6: Who pays for the cost of the clean up?

Response: We do, the taxpayers. The Navy is heading it up but it comes out of our pockets. (Ed: The work
is paid for out of the Navy's budget.)

Question 7: Have soil samples been taken as planned on the Maryland side of the Potomac?

Response: The guestion refers to a reguirement in a consent order for the facility to collect soil samples
in connection with open burning. Although not part of the Navy's Installation Restoration Program, specifics
will be made known to you by Allegany Ballistics Lab.

This constitutes the extent of the comments and responses on the Proposed Remedial Action Plan for Site 1
Groundwater, Surface Water and Sediments at the Allegany Ballistics Laboratory.
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