EPA/ROD/R2001041267
2001
EPA Superfund
Record of Decision:
MARINE CORPS LOGISTICS BASE
EPA ID: LA0213820533
OU06
ALBANY, GA
09/19/2001
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CH2M HILL
115 Perimeter Center Place NE
Suite 700
Atlanta, GA
CH2MHILL 3°3461278
Constructors. Inc. Tel 770.604.9095
Fax 770.604.9282
August 14,2001
Captain Brian Ventura
IRP Manager
Environmental Branch - Bldg. 5501
814 Radford Boulevard
Albany, Georgia 31705-1128
RE: Contract No. N62467-98-D-0995
Contract Task Order No. 0059 - Marine Corps Logistics Base (MCLB) Albany -
Albany, Georgia
Record of Decision for Operable Unit 6
Dear Captain Ventura:
CH2M HILL Constructors, Inc. (CCI) is pleased to provide three revised copies of the Record of
Decision for Operable Unit 6 at the Marine Corps Logistics Base (MCLB) Albany, in Albany,
Georgia. This document incorporates your comments provided to us on July 30, 2001. Please
insert the revised copies in the binders previously provided. Following signature by MCLB
Albany at the end of Section 1, please forward all copies to Mr. Robert Pope at the U.S.
Environmental Protection Agency for signature.
Please call me at (770) 604-9182, extension 540 if you have any additional questions or
comments regarding the enclosed document.
bincerely,
CH2M HILL CONSTRUCTORS, INC.
„- .•-£.- W.lV- Uju-_-
Denis W. Ewing /
Senior Project Managerj
Enclosures
cc: Dan Owens - SOUTHDIV (w/o)
Michael Pearson - MCLB Albany (w/o)
Craig Sprinkle - CH2M Hill (w/o)
CCI Project File No. 162880 (w/e)
NAVYRAC\0059\ROD FOR OU6 CVRLTR
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Record of Decision
Operable Unit 6
Marine Corps Logistics Base Albany
Albany, Georgia
Unit Identification Code: M67004
Contract No.: N62467-98-D-0995
Prepared by:
CH2M HILL Constructors, Inc.
115 Perimeter Center Place NE, Suite 700
Atlanta, Georgia 30346
Prepared for:
Department of the Navy, Southern Division
Naval Facilities Engineering Command
2155 Eagle Drive
North Charleston, South Carolina 29406
Dan Owens, Code 1868, Remedial Project Manager
September 2001
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CERTIFICATION OF TECHNICAL
DATA CONFORMITY (July 2001)
The Contractor, CH2M HILL, hereby certifies that, to the best of its knowledge and belief, the
technical data delivered herewith under Contract No. Number N62467-98-D-0995 are
complete and accurate and comply with all requirements of this contract.
DATE: October 5. 2001
NAME AND TITLE OF CERTIFYING OFFICIAL:
Denis Ewing, P.E.
Task Order Manager
NAME AND TITLE OF CERTIFYING OFFICIAL:
Craig Sprinkle, P.G.
Project Technical Lead
(DFAR 252.227-7036)
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Contents
1.0 Declaration of the Record of Decision 1-1
1.1 Site Name and Location 1-1
1.2 Statement of Purpose and Basis 1-1
1.3 Assessment of the Site 1-1
1.4 Description of the Selected Remedy 1-6
1.5 Summary of Site Characteristics 1-11
1.6 Statutory Determinations 1-11
1.7 ROD Data Certification Checklist 1-11
1.8 Signature and Support Agency Acceptance of the Remedy 1-12
2.0 Decision Summary 2-1
2.1 Site Name, Location, and Description 2-1
2.2 Site History And Enforcement Activities 2-4
2.3 Highlights of Community Participation 2-5
2.4 Scope and Role of the Final Response At OU 6 2-6
2.5 Summary of Site Characteristics 2-9
2.6 Current and Potential Future Land and Resource Uses 2-14
2.7 Summary of Site Risks 2-16
2.8 Remedial Action Objectives 2-24
2.9 Description of Remedial Alternatives 2-28
2.10 Comparative Analysis of Alternatives 2-34
2.11 Description of Selected Remedy 2-45
2.12 Statutory Determinations 2-47
2.13 Explanation of Significant Changes 2-48
3.0 Responsiveness Summary 3-1
3.1 Overview 3-1
3.2 Background on Community Involvement 3-1
3.3 Public Comments and Responses 3-2
4.0 References 4-1
Appendices
Appendix A Land-Use Control Implementation Plan for PSC 4
Figures
1-1 Three Geographic Contaminant Source Areas 1-5
1-2 Contingency Remedy Decision Flow Chart 1-8
2-1 Vicinity Map, MCLB Albany, Georgia 2-2
2-2 Hydrostratigraphic Column for MCLB Albany, Georgia 2-10
2-3 Potentiometric Surface of the Upper Floridan Aquifer Lower Water Bearing
Zone in the Albany, Georgia Area (Nov. 1985) 2-11
2-4 Conceptual Model of Groundwater Flow-Northern Plume Area 2-12
2-5 Conceptual Model of Groundwater Flow-DMA Area 2-13
2-6 Upper Water Bearing Aone Plume Map 2-17
2-7 Lower Water Bearing Zone Plume Map 2-18
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Tables
1-1 Comparison of Groundwater COCs in the Upper Water Bearing Zone to
Selected Action Levels 1-2
1-2 Comparison of Groundwater COCs in the Lower Water Bearing Zone to
Selected Action Levels 1-3
1-3 Groundwater Remedial Goals 1-9
2-1 Proposed Remedial Response By Plume Area And Zone 2-7
2-2 Risk Summary for Current and Future Land Use 2-21
2-3 Remedial Action Objectives for Operable Unit 6 2-25
2-4 Action Levels for Chemicals of Concern 2-26
2-5 Synopsis of ARARs and Federal and State Guidance 2-29
2-6 Summary of Evaluation of Source Control Remedial Alternatives 2-31
2-7 Summary of Evaluation of Groundwater Remedial Alternatives 2-35
2-8 Comparative Analysis of Source Control Remedial Alternatives 2-41
2-9 Comparative Analysis of Groundwater Remedial Alternatives 2-43
2-10 Estimated Costs of Selected Remedial Responses 2-45
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Acronyms
ABB-ES
ARAR
bis
BRA
BEHP
CERCLA
CFR
CLP
COC
COPC
cVOC
CT
DCA
DCE
DDT
DMA
DOD
DWTP
EAAGLE
ERA
ET
FFA
GEPD
HHRA
HI
HLA
HQ
IAS
ICP
IWP
IWTP
LDR
LUC
LUCAP
LUCIP
LWBZ
ABB Environmental Services, Inc.
applicable or relevant and appropriate requirement
below land surface
baseline risk assessment
bis(2-ethylhexyl)phthalate
Comprehensive Environmental Response, Compensation, and Liability
Act
Code of Federal Regulations
Contract Laboratory Program
chemical of concern
chemical of potential concern
chlorinated volatile organic compound(s)
central tendency
dichloroethane
dichloroethene
dichlorodiphenyltrichloroethane
Depot Maintenance Activity
Department of Defense
domestic wastewater treatment plant
East Albany Against Garbage Landfill Expansion
ecological risk assessment
evapotranspiration
Federal Facilities Agreement
Georgia Environmental Protection Division
human health risk assessment
hazard index
Harding Lawson Associates
hazard quotient
Initial Assessment Study
institutional control plan
industrial wastewater pipeline
industrial wastewater treatment plant
land disposal restriction
land-use control
land-use control assurance plan
land-use control implementation plan
lower water bearing zone
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MCL
MCLB
Hg/L
mg/kg
MNA
NA
NCP
NPA
NPL
NTU
O&M
OU
PCB
PCE
PSC
RAO
RBC
RCRA
RFI
RI
RI/FS
RI/BRA
RME
ROD
SARA
SC
SOUTHNAV-
FACENGCOM
SSL
SVOC
TAL
TCA
TCE
TCLP
TRC
UFA
USEPA
UST
UWBZ
VOC
maximum contaminant level
Marine Corps Logistics Base
micrograms per liter
milligrams per kilogram
monitored natural attenuation
no action
National Oil and Hazardous Substances Contingency Plan
Northern Plume Area
National Priorities List
nephelometric turbidity unit
operation and maintenance
Operable Unit
polychlorinated biphenyl
tetrachloroethene
potential source of contamination
remedial action objectives
Risk-Based Criteria
Resource Conservation and Recovery Act
RCRA Facility Investigation
remedial investigation
remedial investigation and feasibility study
remedial investigation/baseline risk assessment
reasonable maximum exposure
Record of Decision
Superfund Amendments and Reauthorization Act
source control
Southern Division, Naval Facilities Engineering Command
soil screening level
semivolatile organic compound
target analyte list
trichloroethane
trichloroethene
toxic characteristics leaching procedure
Technical Review Committee
Upper Floridan Aquifer
U.S. Environmental Protection Agency
underground storage tank
upper water bearing zone
volatile organic compound
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Glossary of Terms
Note: Terms in this glossary are italicized in their first text use.
Baseline Risk Assessment (BRA): The BRA uses data on the nature and extent of
contamination at a CERCLA (Superfund) site to estimate current and potential future risks
to human health and the environment from exposure to contaminants. The calculated risk
levels represent: (a) the probability of an individual to develop cancer as a result of exposure
to site-related carcinogenic chemicals during a 70-year period; and (b) the probability of
developing a non-cancer illness from exposure to site-related non-carcinogenic chemicals.
The risk levels are conservatively estimated so that underestimation of the actual risk is
highly unlikely.
Bioremediation: Naturally occurring microorganisms can transform synthetic organic
compounds into simpler inorganic compounds such as carbon dioxide (CCh), and water
(H2O).
bis(2-ethylhexyl)phthalate (BEHP): A semivolatile organic compound. BEHP is used as a
plasticizer.
Central Tendency (CT): Calculations that model a less conservative approximation of risk
than the reasonable maximum exposure. Typically, the CT calculation will use lower values
for ingestion rate and exposure duration.
Chemical of Concern: Chemicals that are: (a) associated with a cancer risk greater than
IxlO6 (1 in 1,000,000), (b) estimate a hazard quotient (HQ) greater than 0.1, and/or (c)
exceed a State or Federal Maximum Contaminant Level.
Chemicals of Potential Concern (COPC): COPCs are chemicals that are potentially site
related, have a maximum detected concentration above risk-based screening concentrations
(where available), and for inorganics are above background concentrations (where
available). Analytes designated as COPCs are quantitatively evaluated in a risk assessment.
Chlorinated volatile organic compound (cVOC): A volatile organic compound that
contains chlorine atoms substituted for hydrogen, such as tetrachloroethene (PCE),
trichloroethene (TCE), and cis- and trans-dichloroethene.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA):
An Act of Congress that established Superfund and the laws that must be followed when
cleaning up certain hazardous waste sites.
Depot Maintenance Activity (DMA): The Depot Maintenance Activity is an industrial
complex involved in the maintenance and refurbishment of military vehicles. The DMA area
is approximately 45 acres and is covered by buildings and/or concrete.
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Dichloroethane (DCA): A chlorinated volatile organic compound. 1,1-DCA is used as an
extraction solvent, insecticide and fumigant, preparation of vinyl chloride, degreasing and
drying metal parts, solvent for plastics, oils, and fats. 1,2-DCA is used as a vinyl chloride
solvent, lead scavenger in antiknock unleaded gasoline, varnish and paint remover, metal
degreasers, soap and scouring compounds. 1,1-DCA can be an anaerobic degradation
product of 1,1,1-trichloroethane.
Dichloroethene (DCE): A chlorinated volatile organic compound. 1,1-DCE is used in
synthetic fibers, adhesives, coating resin, and polymeric food packaging. Cis-and trans-DCE
are formulated as a mixture that is used as a solvent for fats and phenols, ingredient in
perfumes, low temperature solvent for caffeine, a refrigerant, and for synthesis of other
organic compounds. 1,1-DCE and cis- and trans-DCE may occur in groundwater as
anaerobic degradation products of trichloroethene. DCE undergoes reductive
dechlorination to vinyl chloride.
Dichlorodiphenyltrichloroethane (DDT): DDT was formerly used as a pesticide and is now
prohibited under Federal regulation.
Enhanced bioremediation: The introduction of special additives (e.g., lactic acid, molasses, or
vegetable oil) to enhance naturally occurring biological degradation of organics within soil or
groundwater.
Excess lifetime cancer risk (ELCR): ELCR is the likelihood of experiencing an effect owing
to a continuous lifetime exposure to a risk agent(s) (e.g., chemical of concern). The risk is
presented as a probability such as 1 in 1,000,000 or IxlO'6. The ELCR is determined for a
substance by multiplying the potency to the dose that an individual receives.
Federal Facilities Agreement: An agreement among the Department of the Navy,
U.S. Environmental Protection Agency (USEPA), and Georgia Environmental Protection
Division (GEPD) to address investigation, evaluation, and remediation of hazardous-
substance contaminated sites on MCLB Albany.
Hazard Index (HI): The sum of noncancer risk for chemicals in an exposure pathway.
Hazard Quotient (HQ): An expression of noncancer risk for a chemical.
Maximum Contaminant Level (MCL): State and/or Federal enforceable limits on chemical
concentrations in drinking water.
Monitored Natural Attenuation (MNA): A remedial technology that relies on natural
groundwater processes (dilution, dispersion, sorption, volatilization, biotransformation, and
chemical reaction) to reduce (attenuate) contaminant concentrations to acceptable levels.
The monitoring is conducted to assure the desired attenuation occurs before the
contaminants migrate to a potential receptor.
Nephelometric turbidity units (NTU): A unit of measure for turbidity of water. Potable
water should have turbidity less than 5 NTU.
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National Oil and Hazardous Substances Contingency Plan (NCP): The NCP was originally
published under Section 311 of the Federal Water Pollution Control Act. The NCP
establishes Federal procedures and standards for responding to releases of hazardous
substances, pollutants, and contaminants.
Northern Plume Area (NPA): A geographic area associated with MCLB Albany where
former landfills are the most likely source of groundwater contamination. The landfills that
are likely sources of contamination in NPA are Potential Sources of Contamination I, 3, and
26.
National Priorities List (NPL): A national list of sites that, based on a hazard ranking
system, are likely to have contaminated media (e.g., soil, sediment surface water, and/or
groundwater) that pose adverse risk to human health or the environment
Operable Unit (OU): Sites (individually known at MCLB Albany as potential sources of
contamination) that are grouped together because of similarity of contaminant types,
contaminated media, and similarity of remedial actions.
Polychlorinated biphenyls (PCBs): Any of a family of industrial compounds produced by
the chlorination of biphenyl. PCBs are potential environmental pollutants that accumulate
in animal tissue with resultant pathogenic and teratogenic effects.
Potential Source of Contamination (PSC): A site at MCLB Albany with the potential to
have had a release of contaminants to environmental media (soil, sediment, surface water,
and/or groundwater) that may pose adverse risk to human or ecological receptors.
Reasonable Maximum Exposure (RME): Risk calculations that model the highest exposure
that is reasonably expected to occur.
Record of Decision (ROD): A document approved by the USEPA and GEPD, and signed by
MCLB Albany that outlines the response action to be implemented within MCLB Albany,
including responses to public comments on the Proposed Plan.
Reductive dechlorination: Reductive dechlorination occurs when chlorine atoms are
successively stripped from the parent (solvent) molecule to produce degradation products.
Examples of reductive dechlorination sequences are: (a) tetrachloroethene to trichloroethene
to 1,2-dichloroethene to vinyl chloride to ethene; and (b) 1,1,1-trichloroethane to 1,1-
dichloroethane to chloroethane to ethane.
Remedial Investigation (RI): A technical study to determine the nature and extent of
contamination at a CERCLA (Superfund) site.
Resource Conservation and Recovery Act (RCRA): The Federal law that establishes a
regulatory system for the safe and secure storage, transportation, generation, treatment, and
disposal of hazardous waste.
Semivolatile Organic Compounds (SVOCs): Organic analytes that are amenable to analysis
by extraction of the analyte from water using an organic solvent. This group includes
compounds such as phenols, naphthalene, and bis(2-ethylhexyl)phthalate.
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Tetrachloroethene (PCE): A chlorinated volatile organic compound. PCE is a fluid used for
dry cleaning, degreasing and drying metals, a solvent for waxes, greases, fats, oils, and in
the manufacturing of printing inks and paint removers. PCE undergoes reductive
dechlorination under anaerobic conditions and becomes trichloroethene.
Trichloroethene (TCE): A chlorinated volatile organic compound. TCE is a fluid used for
dry cleaning, degreasing and drying metals and electronic parts, a solvent for oils, waxes,
and fats, solvent for cellulose esters, removal of caffeine from coffee, refrigerant and heat
exchange fluid, and a diluent in paints and adhesives. TCE undergoes reductive
dechlorination under anaerobic conditions and becomes 1,1-dichloroethene, trans 1,2-DCE
or cis 1,2-DCE.
Volatile Organic Compounds (VOCs): Organic analytes that are amenable to analysis by
the purge and trap technique, such as benzene, ethylbenzene, toluene, xylenes,
tetrachloroethene, trichloroethene, and cis- and trans-dichloroethene.
Vinyl Chloride: Most of the vinyl chloride produced in the United States is used in the
manufacture of polyvinyl chloride and other vinyl polymers. Because vinyl chloride is a gas,
the only significant route of exposure is inhalation. Vinyl chloride is a product of
biodegradation of PCE and TCE. Vinyl chloride undergoes reductive dechlorination to
ethene and is oxidized under iron reducing conditions.
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1.0 Declaration of the Record of Decision
1.1 Site Name and Location
Marine Corps Logistics Base
Operable Unit 6
Albany, Georgia 31704
1.2 Statement of Purpose and Basis
This Record of Decision (ROD) document presents the final response for Operable Unit (OU) 6
at the Marine Corps Logistics Base (MCLB) Albany, Albany, Georgia. Actual or threatened
releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this ROD, may present a current or potential threat to public
health, welfare, or the environment. The U.S. Environmental Protection Agency (USEPA)
Region IV and Georgia Environmental Protection Division (GEPD) concur with the selected
remedy.
This ROD was developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendments and
Reauthorization Act (SARA), and to the extent practicable, the National Oil and Hazardous
Substances Contingency Plan (NCP). This decision is based on information contained in the
site's Administrative Record file, located at the Environmental Branch Office, Installations
and Logistics Division, Building 5501, MCLB Albany, Georgia, 31704, and at the information
repository in the Dougherty County Public Library, Albany, Georgia.
1.3 Assessment of the Site
OU 6 is an operable unit composed of all groundwater within MCLB Albany. The
boundaries of OU 6 are generally defined by the boundaries of MCLB Albany, except where
extended by the presence of groundwater contaminant plumes originating within
MCLB Albany.
Groundwater within OU 6 occurs in the Upper Floridan Aquifer. This hydrogeologic unit
locally contains an Upper Water Bearing Zone (UWBZ) and a Lower Water Bearing Zone
(LWBZ). OU 6 contains three geographic areas of contamination (plumes) identified by
previous investigations, as described in the OU 6 Remedial Investigation (RI) and Baseline Risk
Assessment (BRA) Report (HLA, 2000a). The three geographic areas (Figure 1-1) are:
1) Northern Plume Area (NPA),
2) Depot Maintenance Activity (DMA) Area, and
3) Potential Source of Contamination (PSQ 4 Area
The plume areas within OU 6 contain chemicals of concern (COCs) in concentrations that
exceed USEPA risk criteria or Federal or State maximum contaminant levels (MCLs)
(Tables 1-1,1-2).
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Table 1-1
Comparison of Groundwater COCs in the Upper Water Bearing Zone
to Selected Action Levels
Analyte
NPA PSC 1 Plume
cis 1,2-Dichloroethene
Methylene chloride
Trichloroethene
Vinyl chloride
Antimony
NPA PSC 3 Plume
cis 1,2-Dichloroethene
Tetrachloroethene
Trichloroethene
Chromium
Thallium
Vanadium
NPA PSC 26 Plume
Carbon tetrachloride
Chloroform
Trichloroethene
DMA Plume
1,1-Dichloroethene
cis 1,2-Dichloroethene
Benzene
Methylene chloride
Trichloroethene
Vinyl chloride
Antimony
Arsenic
Cadmium
Thallium
Frequency
of Detection1
7/7
5/7
6/7
4/7
1/1
3/3
3/3
3/3
1/1
1/1
1/1
4/4
2/4
4/4
5/23
11/23
1/13
2/23
22/23
1/23
2/9
1/9
5/9
1/9
1 Frequency of detection is (number of samples in
2 Asterisk (*) indicates the average of the detected
then 1/2 the laboratory quantitation limit is used.
Minimum
Concentration2
17
12
46
85
2.2
180
43
30
17.6
6
15.9
180
14
33
5.9
4
780
24*
13
120
4.8
2.6
0.22
5.5
Maximum
Concentration2
2,300
450
460
710
2.2
480
120
53
17.6
6
15.9
310
36.5*
74
56
360
780
27.75*
940
120
9.2
2.6
33.6
5.5
Action
Level3
70
5
5
2
6
70
5
5
100
2
13.2
5
100
5
7
70
5
5
5
2
6
50
5
2
Exceedance?
(Yes/No)4
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
which the analyte was detected)/(total number of samples analyzed).
concentrations in a sample and its duplicate. If one value was non-detect,
3 Refer to the action levels in Table 2-4.
4 'Yes' means the maximum detected concentration of the chemical exceeds the action level for groundwater.
Concentrations are in micrograms per liter.
COC = chemical of concern
NPA = Northern Plume Area
DMA = Depot Maintenance Activity
PSC = potential source of contamination
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Table 1-2
Comparison of Groundwater COCs in the Lower Water Bearing Zone
to Selected Action Levels
Frequency
Analyte of Detection1
NPA On Base Plume
cis 1,2-Dichloroethene 1/1
Tetrachloroethene 1/1
Trichloroethene 1/1
NPA Off Base Plume, Current Land Use
1,2-Dichloroethene (total) 1/1
cis 1,2-Dichloroethene 2/2
Carbon tetrachloride 1/2
Chloroform 1/2
Tetrachloroethene 2/2
Trichloroethene 2/2
NPA Off Base Plume, Future Land Use
1,2-Dichloroethene (total) 1/1
cis 1,2-Dichloroethene 5/5
Carbon tetrachloride 2/5
Chloroform 2/5
Tetrachloroethene 4/5
Trichloroethene 5/5
Antimony 1/2
Thallium 1/2
Minimum
Concentration
2
195*
34.5*
195*
29
31
8
2
2
20
29
3.6
6.7
1.5
1.6
3
7.9
6.5
Maximum
Concentration
2
195*
34.5*
195*
29
63
8
2
28
35
29
195*
8
2
34.5*
195*
7.9
6.5
Action
Level3
70
5
5
5.5
70
5
100
5
5
5.5
70
5
100
5
5
6
2
Exceedance?
(Yes/No)4
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
1 Frequency of detection is (number of samples in which the analyte was detected)/(total number of samples analyzed).
2 Asterisk (*) indicates the average of the detected concentrations in a sample and its duplicate. If one value was non-detect,
then 1/2 the laboratory quantitation limit is used.
3 Refer to the action levels in Table 2-4.
4 'Yes' means the maximum detected concentration of the chemical
Concentrations are in micrograms per liter.
COC = chemical of concern
NPA = Northern Plume Area
DMA = Depot Maintenance Activity
PSC = potential source of contamination
exceeds the action level for groundwater.
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The contaminant plumes are associated with past waste handling practices at eight PSCs
identified within MCLB Albany (Figure 1-1). The PSCs considered sources for each plume
include:
• Northern Plume Area
PSC 1, East Disposal Area
- PSC 3, Long-Term Landfill
PSC 26, Containment Berm Area
DMA Plume Area
- PSC 10, Central Repair Division of the DMA
- PSC 12, Industrial Wastewater Treatment Plant (IWTP)
- PSC 13, Industrial Wastewater Pipeline (IWP)
- PSC 22, DMA Storage Area
. PSC 4 Area
PSC 4, Warehouse Disposal Area
The PSCs within the NPA, DMA and at PSC 4 area exhibit a history of varied uses and
contaminants. Detailed discussions of these source areas are in: Sections 4.1 and 4.2 of the
OU 6 Remedial Investigation (RI) and Baseline Risk Assessment (BRA) Report (HLA, 2000a); the
OH 1 and 2 RI/BRA Report (ABB-ES, 1995); the OU 4 RI/BRA Report (HLA, 1998); the PSC
Screening Technical Memorandum (ABB-ES, 1997e); and the PSC 4 Resource Conservation and
Recovery Act (RCRA) Facility Investigation (RFI) (HLA, 1999a). Results of the cited
investigations indicate subsurface soil in the source areas contain chemicals at
concentrations that were, or currently are sources of the COCs detected in OU 6
groundwater.
The UWBZ plumes that are beneath and hydraulically downgradient from PSC 1, PSC 26,
the DMA, and PSC 4 appear to be located entirely within the boundary of MCLB Albany.
The UWBZ plume associated with PSC 3 extends beyond the boundary of MCLB Albany.
Currently, residents on the northern side of MCLB Albany are supplied drinking water by
the City of Albany. However, residential wells in the area have not been abandoned, and
more wells could be drilled in the future. These wells could be adversely affected by the
occurrence of chlorinated volatile organic compounds (cVOCs) above MCLs in the UWBZ.
The nature and extent of the contaminant plume in the LWBZ has been delineated (HLA,
2000a; CH2M HILL, 2001). The analytical results from the 2001 sampling event
(CH2M HILL, 2001) indicate the plume in the LWBZ extends to the northwest of PSC 3. The
extent and orientation of the LWBZ plume may be related to the orientation of secondary
porosity features (e.g., solution fractures, channels, and voids) in the aquifer.
The BRA for OU 6 (HLA, 2000a) was prepared in accordance with the USEPA risk
assessment guidance (USEPA, 1991; USEPA, 1992a; USEPA, 1992b; and USEPA, 1995).
Cancer risk for residential use of groundwater from the off-Base portion of the NPA within
the LWBZ is at the upper limit of the USEPA cancer risk range (IX10'4) for the reasonable
maximum exposure (RME), and is within the USEPA cancer risk range (IX 10~4 to IX 10~6) for
the central tendency (CT). Noncancer risks for this exposure exceed the USEPA hazard index
(HI) threshold of 1 for both adult and child residents. The cancer risk associated with
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DMA Sources
FLEMING ROAD
1500
3000
PSC
NPA
DMA
LEGEND
PSC location
Potential source of contamination
Northern plume area
Depot Maintenance Activity
Contaminant Source Area
SCALE: 1 INCH = 3000 FEET
K:\0252Q\02520-21\RDD\02520B29.DM5. VC-BB 1D/09/OD 10:52:51. R2000
FIGURE 1-1
THREE GEOGRAPHIC CONTAMINANT SOURCE AREAS
RECORD OF DECISION
OPERABLE UNIT 6
MARINE CORPS LOGISTICS BASE
ALBANY, GEORGIA
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current residential use of groundwater is based on the highest recorded offsite contaminant
concentration. This concentration, which was observed in a monitoring well approximately
1/3-mile west of Ramsey Road, is 10 times higher than the highest concentration detected in
any private well by USEPA (HLA, 2000a). This conservative approach for estimating cancer
risk was used because no controls are currently in place to prevent installation or use of
water supply wells in the vicinity of the northern plume area. Cancer risks associated with
future residential use of groundwater within the NPA-UWBZ exceeded the lower limit of
USEPA's cancer risk range (IX1O4) for both RME and CT. Noncancer risks for this exposure
exceed USEPA's HI threshold of 1 for both adult and child residents.
At PSC 4 cancer risks associated with future residential use of UWBZ groundwater are
within the range USEPA considers acceptable (1 X1O4 to 1 X1O6) for the RME. The CT was
estimated to be less than 1 X1O6. Noncancer risks for this exposure are less than USEPA's
HI threshold of 1 for both adult and child residents.
Groundwater within the LWBZ poses cancer risks to MCLB Albany workers that are within
the range USEPA considers acceptable (IX1O4 to IX1O6) and the non-cancer risks are below
the USEPA HI threshold of 1. Cancer risks associated with future residential use of
groundwater from the LWBZ are within the range USEPA considers acceptable (IX1O4 to
IX1O6) for both RME and CT. However, noncancer risks for this exposure are equal to or
exceed the USEPA HI threshold of 1 for both adult and child residents.
Available analytical results indicate that COCs do not exceed MCLs in offsite residential
wells within the NPA. However, MCLB Albany, in cooperation with GEPD and USEPA,
implemented an interim measure in 1999 as a precaution to eliminate the potential for
human exposure to contaminated groundwater associated with the northern plume. The
interim measure consisted of providing access to municipal water for all residents living
within one mile of PSC 3. MCLB Albany also offered to fund all costs associated with
permanently sealing and plugging residential wells that were replaced by municipal water
connections (HLA, 2000b). The Navy continues to encourage those members of the
community that have not already done so to accept this standing offer.
1.4 Description of the Selected Remedy
Based on the findings from the OU 6 RI and BRA (HLA, 2000a), and the RFI for PSC 4 (HLA,
1999a), the following are response actions selected for source areas and the UWBZ and
LWBZ groundwater at the NPA, DMA and PSC 4.
1.4.1 Source Control
The objective of the response actions for the sources at the NPA and DMA is to reduce the
mobility of the contaminants at the source. By reducing the flow of water through the
overburden, contaminants will be isolated above the water table, and should not migrate
downward into groundwater. The primary remedy to achieve this objective at the NPA is an
evapotranspiration (ET) cap. Should the ET cap not meet its performance criteria (as
measured by achieving an infiltration rate of IxlO5 centimeters per second or less), the
contingency remedy is to construct a traditional clay cap. Evaluation of the ET cap will be
conducted during a 3-year review prior to conducting the CERCLA 5-year review. A
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diagram illustrating the process to review the performance of the remedy is provided in
Figure 1-2. The ET cap must be implemented within 3 years of signing the ROD for OU 6.
The source control remedy for the DMA is a cap. Source characterization is part of that
action and will be used to define the area(s) to be maintained as a cap. The source
characterization includes identification of sub-floor pipelines, testing of sub-floor piping for
leaks, and investigating subsurface soil in areas with potentially high levels of
contamination. Leaking pipes or infiltrating surface water in the vicinity of source areas will
be repaired or re-directed to minimize potential for leaching of contaminants to
groundwater. It is possible that F001, F002, F003, F005, F006 or F019 RCRA listed wastes will
occur in environmental media within the DMA Area. However, any environmental media
with chemical test results below health-based levels (i.e., EPA Region IX Risk Based Criteria
[RBCs]) are not considered to contain listed hazardous wastes. If media tested during source
characterization do not exceed RBCs and do not exhibit a hazardous waste characteristic,
they may be disposed offsite without triggering land disposal restrictions (LDRs) or
delisting issues.
The 3-year review of the remedy would consist of evaluating monitoring data and assessing
changes in site conditions (e.g., construction, demolition, receptors, migration pathways,
and qualitative risks). The appropriateness of the capping alternative would be compared to
other potential remedial alternatives for the site as identified in the Feasibility Study (HLA,
2000). After 3 years, if data indicate that capping did not achieve prescribed performance
goals, more aggressive measures may be considered, including sealing floor drains and
replacing industrial wastewater pipelines with above-ground piping.
The primary remedy for source control at PSC 4 is a 12-inch-thick soil cover that prevents
human and ecological receptors from coming into contact with contaminants in surface soil.
The cover would be applied (a) to areas of exposed blast grit, and (b) to areas where wastes
in trenches are insufficiently covered with soil. In addition, MCLB Albany will follow the
Land Use Control Implementation Plan presented in Appendix A. These actions are
consistent with the proposed remedy of MNA for UWBZ groundwater. Should MNA not
reduce the concentration of COCs in the UWBZ, or if COCs are detected in the LWBZ at
concentrations exceeding their MCLs, more active groundwater remedies will be employed
(see Section 1.4.2). If more active groundwater remedies are ineffective, then an ET cap or
traditional clay cap will be constructed at PSC 4. The PSC 4 cap would be required to meet
the same performance criteria as the cap over the NPA source areas.
1.4.2 Groundwater
The goal of remedial measures for groundwater at PSC 4, the NPA, and DMA is to reduce
the chemical concentrations in both the UWBZ and LWBZ of the Upper Floridan aquifer to
MCLs and/or risk-based standards (Table 1-3). COCs were not identified in the LWBZ at
PSC 4 above MCLs during initial characterization studies. Groundwater monitoring will be
conducted in the LWBZ at PSC 4 to assure COCs do not exceed MCLs during and after
remedial actions.
As indicated in Table 1-3, the goal of groundwater remedial measures is to reduce offsite
concentrations of the COCs to below their respective Federal MCL in 10 years, and onsite
COC concentrations to below their respective Federal MCL in 20 years. Prior to conducting
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FIGURE 1-2
CONTINGENCY REMEDY DECISION FLOW CHART
ALBANY, GEORGIA
RECORD Of DECISION
OPERABLE UNIT 6
MARINE CORPS LOGISTICS BASE
ALBANY, GEORGIA
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Analyte
NPA UWBZ at PSC 1
Cis 1 ,2-DCE
Methylene Chloride
TCE
VC
Antimony
NPA UWBZ at PSC 3
Cis 1 ,2-DCE
PCE
TCE
NPA UWBZ at PSC 26
Carbon Tetrachloride
TCE
NPA LWBZ On Base
cis 1 ,2-DCE
PCE
TCE
NPA LWBZ OffBase
1.2DCE
cis 1 ,2-DCE
Carbon Tetrachloride
PCE
TCE
UWBZ at DMA
1,1 DCE
Cis 1 ,2-DCE
Benzene
Methylene Chloride
TCE
VC
Antimony
Cadmium
Thallium
LWBZ at DMA
TCE
Table 1-3
Groundwater Remedial
Maximum Remedial Goal
Detected Level (within 3 years of
(as of June Remedial Action
2001) Start)
2,300 1,150
450 225
460 230
710 355
4.6 6
1500 750
230 165
160 80
310 155
74 37
195 97
35 17
195 97
29 14
195 97
8 5
28 14
35 17
570 285
500 250
780 390
458 239
2100 1050
649 325
9.2 6
33.6 16.8
5.5 2.8
260 130
Goals
Offsite Remedial
Goal = MCL
(within 10 years of
Remedial Action
Start)
70
5
5
1
6
70
5
5
5
5
70
5
5
5
70
5
5
5
7
70
5
5
5
1
6
5
2
5
Onsite Remedial
Goal = MCL (within
20 years of
Remedial Action
Start)
70
5
5
1
6
70
5
5
5
5
70
5
5
5
70
5
5
5
7
70
5
5
5
1
6
5
2
5
Concentration in micrograms per liter.
The overall goal of the remedial measures is to reduce the offsite concentrations of the chemicals of concern
(COCs) to a concentration that is less than their respective Federal maximum contaminant level (MCL) in
10 years, and on-site COC concentrations to less than their respective MCL in 20 years.
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1-9
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the CERCLA 5-year review, a 3-year Review will be conducted to assess the primary
remedies at the NPA, DMA, and PSC 4. The 3-year review will be used to adjust site
monitoring requirements, make a determination as to whether or not the primary remedies
are meeting their Groundwater Remedial Goals and, determining whether or not a
contingency remedy needs to be implemented. The criteria in Table 1-3 will be used to
assess whether or not a contingency remedy should be implemented.
The primary remedy selected for the UWBZ at the NPA and DMA is enhanced bioremediation.
Enhanced bioremediation will be implemented by injecting chemicals into the UWBZ in
source areas to accelerate natural biological reactions that cause reductive dechlorination of
cVOCs. If enhanced bioremediation cannot meet the three-year remedial goals in Table 1-3,
other in situ remedies that rely on abiotic degradation will be implemented in source areas
to supplement the primary remedy. If, the goal of 50 percent reduction in cVOC
concentrations in source areas cannot be achieved after 3 years of implementing additional
in situ technologies, then the contingency remedy (i.e., conventional pumping and ex situ
treatment) will be initiated.
The primary remedy selected for the UWBZ at PSC 4 is MNA. Upon completion of the soil
cover, groundwater will be monitored to determine whether MNA is controlling the
groundwater plume. If MNA has not controlled plume migration after 3 years of
monitoring, then enhanced bioremediation will be implemented in the UWBZ. As
previously stated, if contaminant concentrations still exceed MCLs after 3 years of enhanced
bioremediation, an ET cap or traditional clay cap will be implemented over the source area.
The primary remedy selected for the LWBZ at the NPA and DMA is MNA. The contingency
remedy selected for the LWBZ is conventional pumping and ex situ treatment. A remedial
action is not needed currently for the LWBZ at PSC 4; however, monitoring will be
conducted to confirm that chemical concentrations remain less than MCLs and/or risk-
based standards. If the concentrations of COCs in the LWBZ exceed MCLs at PSC 4, then
enhanced bioremediation will be implemented in the UWBZ within source areas.
Available analytical results indicate COCs do not exceed MCLs in offsite residential wells
within the NPA. However, MCLB Albany, in cooperation with GEPD and USEPA,
implemented an interim measure in 1999 as a precaution to eliminate the potential for
human exposure to contaminated groundwater associated with the NPA. The interim
measure consisted of providing access to municipal water for residents living within 1 mile
of PSC 3. MCLB Albany also offered to fund all costs associated with permanently sealing
and plugging residential wells that were replaced by municipal water connections (HLA,
2000b). The Navy continues to encourage those members of the community who have not
already done so to accept this standing offer.
An Interim Corrective Measure at PSC 3 has been discontinued because the system has not
met the goal of hydraulic containment, and continued operation may interfere with the
pilot-scale technology demonstration being conducted (CH2M HILL, 2000).
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1.5 Summary of Site Characteristics
This section summarizes the regional geology, hydrogeology, and ecology in the vicinity of
MCLB Albany. A more detailed presentation of this information is available in the RI/BRA
report for OU 6 (HLA, 2000a).
1.5.1 Geology
MCLB Albany is located in the Coastal Plain Physiographic Province, which is made up of
layers of sand, clay, sandstone, and limestone. These layers of soil and rock extend to a
depth of at least 5,000 feet below land surface (bis). Each layer has been identified and
named by geologists according to its composition and physical properties.
The soil and rock layers that control the movement of underground water in the first
350 feet bis at MCLB Albany are, in descending order, the overburden, the Ocala Limestone,
and the Lisbon Formation. The overburden is composed of clay with some silt and sand.
The Ocala Limestone is divided into an upper unit and a lower unit. The upper unit is a lime
mud or chalk; the lower unit is hard, dense rock that has been dissolved by the movement of
water along fractures to form underground caves. The Lisbon Formation is a hard, clayey
limestone. Site geology and hydrogeology are discussed more extensively in Section 2 of this
ROD.
1.6 Statutory Determinations
The response actions selected in this ROD are necessary to protect human health and the
environment from actual or threatened release(s) of the COCs from the site. The final
response actions selected for OU 6 are protective of human health and the environment,
comply with Federal and State requirements that are legally applicable or relevant and
appropriate to the remedial actions, apply one or more treatment technologies as a principal
element of the selected remedy(s), and are cost-effective. The selected remedies use
permanent solutions and contingency treatment technologies to the maximum extent
practicable for this site. Because these remedies will result in hazardous substances
remaining onsite above health-based levels, a review will be conducted within 5 years to
ensure that the remedies continue to provide adequate protection of human health and the
environment.
1.7 ROD Data Certification Checklist
The following information is included in the Declaration of the Record of Decision and/or
Decision Summary sections of the ROD.
. Baseline risk represented by the COCs
• COCs and their respective concentrations
• Cleanup levels established for the COCs
• Methods for addressing source materials that constitute principal threats
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. Current and reasonably anticipated future land use assumptions and current and
potential future uses of groundwater in the BRA and ROD
• Potential land and groundwater use thatwill be available at the aite as a result of the
selected remedy
• Estimated capital cost, annual operation and maintenance (Q&M)ci :«t total present worth
cost, and number of years over which Hie remedial costs were estimated
• Key factors that led to selecting me xeznedy
Additional infonnatbn can be found in the Publk Repository located a ttiie Dougherty
County Public Library, 2»i Floor, Reference Section, 300 Pine Street, Albany, Georgia and the
Administrative Record located at MCLB Albany.
1.8 Signature and Support Agency Acceptance of the Remedy
r>
"Charles V. Mugno' '^ Date
Colonel
Commanding Officer, MCLB Albany
V\
Richard D. Green, Director
Waste Management Division
US. Environmental Protection Agency, Region 4
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2.0 Decision Summary
2.1 Site Name, Location, and Description
MCLB Albany is an active facility occupying 3,579 acres east-southeast of the city of Albany,
Georgia (Figure 2-1). Land bordering MCLB Albany, to the south, east, and northeast is
residential, agricultural, and recreational open space. Most of the land to the northwest and
west of the Base is mixed residential and commercial. MCLB Albany currently serves as a
military logistics center, controlling the acquisition, storage, maintenance, and distribution
of combat and support material for the Marine Corps. In addition, the Base is used for
military training and other functions as directed by the Commandant of the Marine Corps.
MCLB Albany holds a Georgia Hazardous Waste Facility Permit (Permit Number HW-009
[S&D]) for storage of hazardous waste and for postclosure care of three surface
impoundments. MCLB Albany was placed on the USEPA's National Priority List (NPL) of
Superfund sites in 1990. In July 1991, the Department of the Navy entered into a Federal
Facilities Agreement (FFA) with GEPD and USEPA Region IV to establish a procedural
framework and schedule for developing, implementing, and monitoring appropriate
response actions at the facility. Any response actions would be in accordance with CERCLA;
RCRA; the National Oil and Hazardous Substances Contingency Plan (NCP); Superfund
guidance and policy; and the Georgia Hazardous Waste Management Act.
Based on results of investigations, three plumes of groundwater contamination are
associated with past waste handling practices at eight PSCs (Figure 1-1). The three plume
areas and their associated PSCs are:
Northern Plume Area (NPA)
PSC 1, East Disposal Area
- PSC 3, Long-Term Landfill
PSC 26, Containment Berm Area
DMA Plume Area
- PSC 10, Central Repair Division of the DMA
- PSC 12, IWTP
- PSC 13, IWP
- PSC 22, DMA Storage Area
. PSC 4 Plume
PSC 4, Warehouse Disposal Area
ATL\\D:\NAVYRAC\NAVYRAC DELIVERABLES\RECORD OF DECISION\0059\ALBANYROD.DOC 2-1
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g
I
b
o
o
AL8AN
EAST ALBANY
HOT TO SCALE
Marine Corps Logistcs Base, Albony
LEGEND
PSC Potential sourci ol contamination
N
FIGURE 2-1
VICiNIIY MAP, UCLB
AIRAN'f. Grf>RCJA
RECORD OF PEC130N
OPERABLE UNIT 6
MARINE CORPS LOGISTICS BASE
ALBANY. GEORGIA
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2.1.1 Northern Plume Area
The sources of contaminants in the northern plume appear to be PSCs I, 3, and 26. The
following text provides a brief description of these source areas.
PSC1, East Disposal Area
PSC 1 is an inactive landfill measuring approximately 100 feet by 300 feet, located adjacent
to the western edge of the Indian Lake Refuge Area and south of North Shaw Road.
Approximately 10,000 tons of paper, cardboard, wood, household refuse, and unknown
volumes of paints, thinners, and solvents were reportedly disposed of and burned in trench-
and-fill operations at this location between 1958 and 1959. The area was subsequently
compacted, covered with soil, and planted with pine trees.
PSC 3, Long-Term Landfill
This landfill, measuring approximately 1,000 feet by 1,400 feet, is located about 2,800 feet
due west of the western edge of the Indian Lake Refuge Area and immediately south of
North Shaw Road. This area was used from 1954 until 1988, reportedly for the disposal of
approximately 175,000 tons of solvents, paints, sludges, sandblast grit, thinner, paper,
cardboard, and wooden pallets. In addition, the area may have received up to 50 gallons of
DDT in the mid-1960s, and possibly transformers containing PCBs during the 1970s. The
landfill was maintained as a trench-and-fill operation, working north to south, with
occasional burning until the early 1970s. This landfill was officially closed in 1988 under
State of Georgia solid waste regulations. Closure certification required the installation of a
soil cover and the planting of natural vegetation.
Three sludge piles were also located on the surface of the landfill cover at the northeast
corner of PSC 3. These sludge piles were removed and disposed off-Base at a permitted
facility under a Time-Critical Removal Action in May 1996 (ABB Environmental Services,
Inc. [ABB-ES], 1997d). Currently, PSC 3 is being used for composting organic debris, such as
trees, branches, and grass cuttings.
PSC 26, Containment Berm Area
PSC 26, measuring approximately 900 feet by 1,400 feet, is located 1,000 feet east of
Walker Avenue and immediately south of North Shaw Road. Interpretation of aerial
photographs suggests that three disturbed areas and a berm in this area were in use from
approximately 1957 to 1964. The exact construction and use of the berm at PSC 26 has not
been determined. Visual inspection of the berm and adjacent site areas suggests that the
area may have been used as a disposal area for an unknown length of time. However, field
investigations of this area disclosed no evidence of waste materials within the berm. The
area has not been used since approximately 1964, and is currently overgrown with
vegetation.
2.1.2 DMA Plume Area
The contaminants in the DMA plume appear to originate from sources of contamination at
PSCs 10,12,13, and 22 (HLA, 1998). These PSCs are briefly described below.
PSC 10, Depot Maintenance Area
PSC 10 is located on the southeastern side of Broom Boulevard. The DMA consists of several
buildings totaling approximately 450,000 square feet. The work within PSC 10 involves
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maintenance and refurbishment of military vehicles. The areas between the buildings are
covered by a concrete slab with a relatively uniform thickness of 8 inches. This area of
concrete is approximately 45 acres. Access to PSC 10 is restricted by fencing.
PSC12, Industrial Wastewater Treatment Plant
PSC 12 is located at the intersection of Broom Boulevard and West Matthews Boulevard. In
1957, a gravity separator and 25,000-gallon holding tank were installed at the present IWTP
site for partial waste treatment prior to discharge to the domestic wastewater treatment
plant (PSC 14).
By 1977, the IWTP was constructed and in operation, treating the waste stream for metals
and pH stabilization. An RCRA corrective action was implemented at the IWTP as required
in MCLB Albany's Hazardous Waste Facility Permit. To comply with the permit, a six-well
pump-and-treat remedial system was installed to address cVOCs detected in the
groundwater. The first recovery well in the system began groundwater extraction in 1990.
This interim remedial system discontinued operations in September 2000.
PSC 13, Industrial Wastewater Pipeline
PSC 13 is a wastewater pipeline that carries industrial wastes from the DMA to the IWTP.
The pipeline is gravity-drained, and the depth of the pipeline varies from approximately
6 feet bis on the west side of the DMA to 12 feet bis just before entering the IWTP. The
diameter of the pipeline varies from 6 inches (on the west side of DMA) to 12 inches just
before entering the IWTP.
PSC 22, Old RCRA 90-Day Storage Area
PSC 22 is the Old RCRA 90-Day Hazardous Waste Storage Area. PSC 22 is located within
the fenced area of the DMA (PSC 10) along its southwest side. PSC 22 consists of a metal-
fabricated roofed shed approximately 30 feet by 180 feet in dimension. The sides of the shed
are not enclosed; however, access is limited by a chain-link fence fixed to the pillars of the
roof. The floor of the shed is concrete.
PSC 4 Plume
Waste disposal at PSC 4, the Warehouse Disposal Area, appears to be the source of the
PSC 4 plume. PSC 4 was characterized in 1985 (Envirodyne Engineers, 1985) as having
received solid waste and building materials during the 1960's. The 1985 Initial Assessment
Study (IAS) concluded that the innocuous nature of material reportedly disposed at PSC 4
did not pose a potential threat to human health and the environment. In contrast, the IAS
identified neighboring PSC 5, the West Disposal Area, as a trench-and-fill landfill that
between 1950 and 1960 received large quantities of solvent, paint, and other industrial
wastes from the DMA. HLA concluded that the IAS mistakenly identified these two PSCs
(HLS, 2000). The DMA wastes had been disposed at PSC 4 and the innocuous wastes had
been disposed at PSC 5.
2.2 Site History And Enforcement Activities
MCLB Albany has generated various types of solid and liquid wastes over the years,
including hazardous wastes. The hazardous wastes include electroplating wastes containing
heavy metals, organic solvents from stripping and cleaning operations, and waste fuel and
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oil. Beginning in 1985, three investigations were performed at MCLB Albany to assess and
characterize those PSCs identified as having the potential for a release. The three studies
were:
1) Initial Assessment Study (Envirodyne Engineers, Inc., 1985)
2) Confirmation Study (McClelland Engineers, 1987)
3) RCRA Facility Investigation (Applied Engineering & Science, Inc., 1989)
These investigations resulted in placing MCLB Albany on the USEPA NPL in 1990. In
July 1991, the Department of the Navy, USEPA, and GEPD signed an FFA to develop,
implement, and monitor response actions at MCLB Albany. Any response actions would be
in accordance with CERCLA, RCRA, NCP, and the Georgia Hazardous Waste Management
Act.
The Department of the Navy, GEPD, and USEPA agreed to perform additional
investigations over the entire installation. Between 1987 and 1991, the total number of PSCs
at MCLB Albany increased to 24. Investigations made after 1991 added 6 more PSCs,
resulting in a total of 30 PSCs. The 30 PSCs were grouped into six OUs based on their
proximity and similarity of potential contamination. Fourteen of the PSCs were addressed
under the CERCLA process, 14 PSCs were evaluated through screening activities, and 2
PSCs were addressed under RCRA. With the exception of PSC 21, remediation (or
determination of no further action) has been completed at the 16 PSCs undergoing screening
and within the RCRA process. Remedial activities are planned for PSC 21 in 2001.
Significant progress was made under the CERCLA process at MCLB Albany over the last
few years. Final RODs signed for five of the six OUs at the Base are as follows:
. OU 1 ROD (ABB-ES, 1997a), signed in August 1997
. OU 2 ROD (ABB-ES, 1996), signed in September 1996
. OU 3 ROD (ABB-ES, 1997b), signed in August 1997
. OU 4 ROD (HLA, 1999b), signed in February 1999
. OU 5 ROD (ABB-ES, 1997c), signed in December 1997
2.3 Highlights of Community Participation
The Proposed Plan for OU 6 recommended for source control maintaining an existing cap
for the DMA area, constructing a soil cover and land use controls at PSC 4, and constructing
an ET cap over PSC 3. Enhanced bioremediation and MNA were recommended for
groundwater. The Proposed Plan was made available to the public in the Information
Repository located at the Dougherty County Public Library and in the Administrative
Record located at the Environmental Branch Office, Building 5501, MCLB Albany, Georgia,
31704-1128. The public notice of the Proposed Plan was published in the Albany Herald on
May 22, 2000, and meeting notices were mailed to the MCLB Albany Installation Restoration
community mailing list. A public meeting was held on June 1, 2000, to present the results of
the RI and BRA, the preferred remedy, and to solicit comments from the community. At this
meeting, representatives from Southern Division, Naval Facilities Engineering Command
(SOUTHNAVFACENGCOM), MCLB Albany, USEPA Region IV, GEPD, and HLA were
available to discuss findings from the RI and BRA for OU 6 and the response actions under
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consideration. The Community Relations Responsiveness Summary is included in Section 3
of this ROD.
2.4 Scope and Role of the Final Response At OU 6
OU 6 is the Operable Unit for groundwater basewide. Multiple investigations have
identified three contaminant plumes associated with eight PSCs (HLA, 2000). The response
actions selected for controlling leaching from source areas and for remediation of
groundwater within the three plumes are listed in Table 2-1 and described in the following
sections.
2.4.1 Source Control Remedies
The objective of the response actions for the sources at the NPA and DMA is to reduce the
leaching and mobility of the contaminants at the source. By reducing the infiltration of
water, contaminants will be isolated above the water table, and should not be able to
migrate downward into groundwater.
The primary remedy at the NPA is an ET cap. Should the ET cap not meet its performance
criteria (Table 2-1) (measured by achieving an infiltration rate that is less than or equal to
IxlO'5 centimeters per second), the contingency remedy is to construct a traditional clay cap.
Evaluation of the performance of the ET cap for the NPA will be conducted during a 3-year
review, prior to the CERCLA 5-year review.
The primary source control remedy for DMA is a cap to control infiltration through
potential source areas. Leaking pipes and "french drains" for roof runoff in the vicinity of
such source areas could compromise the capability of existing concrete and pavement to
minimize infiltration (Table 2-1). During remedial design, the DMA will be investigated to
identify location of potentially leaking sub-floor pipelines, zones of contaminated
subsurface soil in areas with confirmed pipeline releases, "french drains" and major cracks
or gaps in the pavement that would allow direct infiltration of rainwater. The remedial
design will then use this information to reduce potential infiltration over confirmed sources.
Potential remedial actions could include pavement repairs, repair or replacement of leaking
pipes, plugging of "french drains", and re-routing of roof runoff. The remedial actions may
also include institutional controls on land-use and site monitoring. After 3 years, if data
indicate that the response action did not achieve prescribed performance goals, more
aggressive measures will be considered. More aggressive measures at the DMA may include
sealing floor drains and replacing in-ground wastewater pipelines with above-ground
piping.
The primary remedy for source control at PSC 4 is a 12-inch thick soil cover that prevents
human and ecological receptors from coming into contact with contaminants in surface soil.
The cover would be applied (a) to areas of exposed blast grit, and (b) to areas where wastes
in trenches are insufficiently covered with soil. In addition, MCLB Albany will follow the
Land Use Control Implementation Plan presented in Appendix A.
ATL\\D:\NAVYRAC\NAVYRAC DELIVERABLES\RECORD OF DECISION\0059\ALBANYROD.DOC 2-6
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Table 2-1
Proposed Remedial Response By Plume Area and Zone
Location Remedial Action Objective
Northern Plume Area
Source Reduce chemical mobility, toxicity, or
volume in the overburden
Upper Water Reduce chemical concentrations in
Bearing Zone groundwaterto Maximum Contaminant
(UWBZ) Levels (MCLs) and/or to risk-based
standards
Lower Water Reduce chemical concentrations in
Bearing Zone groundwaterto MCLs and/or to risk-
(LWBZ) based standards
Potential Source of Contamination 4 Area
Source Reduce chemical mobility, toxicity, or
volume in the overburden
UWBZ Reduce chemical concentrations in
groundwaterto MCLs and/or to risk-
based standards
LWBZ Confirm chemical concentrations in
groundwater are less than MCLs
and/or risk-based standards
Depot Maintenance Activity Area
Source Reduce chemical mobility, toxicity, or
volume in the overburden
UWBZ Reduce chemical concentrations in
groundwaterto MCLs and/or to risk-
based standards
LWBZ Reduce chemical concentrations in
groundwaterto MCLs and/or to risk-
based standards
Primary Remedy
Evapotranspiration Cap
Enhanced
Bioremediation
Monitored Natural
Attenuation
Soil Cover
Land Use Controls
Monitored Natural
Attenuation
Monitoring
Inspect and repair floor
drains, and pavement
Enhanced
Bioremediation
Monitored Natural
Attenuation
Performance Criteria
Infiltration rate less than or equal to
average 1x10"5 cm/sec
Reduction of contaminant
concentrations in source area and off-
Base monitoring wells (Table 1-1)
Reduction of contaminant
concentrations in source area and off-
Base monitoring wells (Table 1-1)
Prevent human and ecological
receptors from contacting contaminants
in soil (Table 1-3)
Reduction of contaminant
concentrations in source area
(Table 1-3)
Assure chemicals of concern do not
exceed MCLs
Successful leak test on drains. No
cracking of pavement, no gaps in joints
Reduction of contaminant
concentrations in source area
(Table 1-3)
Reduction of contaminant
concentrations in source area
(Table 1-3)
Contingency Remedy
Traditional clay cap
Other in situ treatment, then
groundwater extraction and ex
situ treatment
Groundwater extraction and ex
situ treatment
Evapotranspiration or traditional
clay cap
Enhanced Bioremediation, then
ET or clay cap on source area
Groundwater extraction and ex
situ treatment
Seal or repair floor drains,
replace pavement, seal joints
Other in situ treatment, then
groundwater extraction and ex
situ treatment
Groundwater extraction and ex
situ treatment
cm/sec = centimeter per second
-------
These actions are consistent with the proposed remedy of MNA for UWBZ groundwater.
Should MNA not reduce the concentration of COCs in the UWBZ, or if COCs are detected in
the LWBZ at concentrations exceeding their MCLs, more active groundwater remedies will
be employed (see Section 2.4.2). If more active groundwater remedial actions are ineffective,
then an ET cap or traditional clay will be constructed at PSC 4. The PSC 4 cap would be
required to meet the same performance criteria as the cap over the NPA source areas.
Evaluation of the primary remedy for PSC 4 will be conducted during a 3-year review, prior
to the CERCLA 5-year review.
The 3-year review would consist of evaluating monitoring data and assessing changes in
site conditions (e.g., construction, demolition, receptors, migration pathways, and
qualitative risks). The appropriateness of the primary remedy would be compared to other
remedial alternatives selected for the site.
2.4.2 Groundwater Remedies
The objective of the response actions for groundwater is to reduce the chemical
concentrations in groundwater to MCLs and/or risk-based standards (Table 2-1). As
indicated in Table 1-3, the remedial measures must reduce the offsite concentrations of the
COCs to a concentration that is less than their respective Federal MCL in 10 years, and
onsite COC concentrations to less than their respective MCL in 20 years. Prior to conducting
the CERCLA 5-year review, a 3-year review will be conducted to assess the primary
remedies at the NPA, DMA, and PSC 4. The 3-year review will be used to adjust site
monitoring requirements, to make a determination as to whether the primary remedies are
meeting their Groundwater Remedial Goals, and to determine whether or not a contingency
remedy needs to be implemented.
The primary remedy selected for the UWBZ at the NPA and DMA is enhanced
bioremediation. Enhanced bioremediation would be implemented by injecting chemicals
into the UWBZ to accelerate natural biological reactions that cause reductive dechlorination
of cVOCs. However, achievement of the 3-year remedial goals in Table 1-3 may not be
achievable by this technology. If enhanced bioremediation cannot meet the 3-year remedial
goals, other in situ remedies would be implemented, as needed. If the goal of 50 percent
reduction in cVOC concentrations in source areas or adequate reduction in trace metals
concentrations cannot be achieved after 3 years of implementing additional in situ
technologies, then the contingency remedy (i.e., conventional pumping and ex situ treatment)
will be initiated.
The primary remedy selected for the UWBZ at PSC 4 is MNA. Groundwater sampling and
chemical analysis (monitoring) will be conducted at PSC 4 to determine whether MNA is
controlling the extent of the groundwater plume and is reducing contaminant
concentrations inside the plume. If MNA has not controlled the plume or reduced the
contaminant concentrations after 3 years of monitoring, then enhanced bioremediation will
be implemented in the UWBZ. As previously stated, if additional groundwater remedies are
not successful, then an ET cap or traditional clay cap will be placed on the source area.
The primary remedy selected for the LWBZ at the NPA and DMA is MNA. The
implementation of enhanced bioremediation in the UWBZ should reduce the concentration
of cVOCs that migrate to the LWBZ, thereby, meeting the remedial action objective. The
ATL\D:\NAVYRAC\NAVYRAC DELIVERABLES\RECORD OF DECISION\0059\ALBANYROD.DOC 2-8
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contingency remedy for the LWBZ in these two plume areas is conventional pumping and
ex situ treatment.
2.5 Summary of Site Characteristics
This section summarizes the regional geology, hydrogeology, and ecology near MCLB
Albany. A more detailed discussion is presented in the RI/BRA report for OU 6 (HLA,
2000a).
2.5.1 Geology
MCLB Albany is located in the Coastal Plain Physiographic Province, which is composed of
layers of sand, clay, sandstone, and limestone. These layers of soil and rock extend to a
depth of at least 5,000 feet bis. Each layer has been identified and named by geologists
according to its composition and physical properties.
The soil and rock layers that occur within the first 350 feet bis at MCLB Albany are, in
descending order, the overburden, the Ocala Limestone, and the Lisbon Formation. The
overburden is composed of clay with some silt and sand. The Ocala Limestone is divided
into an upper unit and a lower unit. The upper unit is a lime mud or chalk; the lower unit is
harder, denser limestone that may be partly dolomitic. The lower unit has been dissolved by
groundwater and has developed extensive secondary permeability (karst). The Lisbon
Formation is a hard, clayey limestone. Figure 2-2 presents a generalized hydrostratigraphic
column of the Albany, Georgia area.
2.5.2 Hydrogeology
The upper Floridan aquifer (UFA) locally occurs within the Ocala Limestone. The Ocala
Limestone ranges from approximately 200 to 275 feet thick in the vicinity of MCLB Albany
(Figure 2-2). The clayey overburden and a low-permeability layer of the Lisbon Formation
are above and below the UFA, respectively. The UFA may be confined, semiconfined, or
unconfirmed by the clayey overburden, depending on local conditions. The Ocala Limestone
is divided into an upper zone with low permeability (UWBZ), middle zone (a semiconfining
unit for the lower zone), and a lower zone with greater permeability due to solution-
enlarged joints, bedding planes, and fractures (LWBZ). The middle zone occurs in the
vicinity of the DMA, but is absent in the vicinity of the Northern Plume Area. The UWBZ
introduced in Section 1.1 is composed of the upper and middle zones of the Ocala
Limestone, while the LWBZ is the lower zone of the Ocala Limestone.
The UFA is recharged by rainfall that slowly percolates down through the confining units
and through sinkholes. Recharge rates are dependent primarily on the local vertical
hydraulic conductivity of the overburden. Movement of water in the UFA is generally west
toward the Flint River, where it discharges to the river through springs (Figupre 2-3) (Hicks,
1987). Conceptual models depicting the interpreted contaminant migration pathways for the
NPA and PSC 4 plumes, and DMA plume are presented in Figures 2-4 and 2-5, respectively.
ATL\\D:\NAVYRAC\NAVYRAC DELIVERABLES\RECORD OF DECISION\0059\ALBANYROD.DOC 2-9
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ATL\\I:\NAVY RAC\ALBANY\ROD\ALBANYROD.DOC 2-
UJ
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Overburden
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Lisbon
Tallahatta
Tuscahoma
Upper Clayton
Clayton Limestone
Providence
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HYDROSTRATIGRAPHIC COLUMN
K:\02520\02520-21\ROD\02520826.DWG, VC-BB 10/W/OO 11:35:37, R2000
AQUIFER
Upper
Floridan
Pearl River
Chattahoochee
River
1 Sandy clay
Limestone
Sand
^| Coquina
Calcareous sand
• Clay
^1 Clayey limestone
From: Hicks and Others, 1981;
Miller, 1990
^sss^^ RECORD OF DECISION
XggffifSifX OPERABLE UNIT 6
\Ss3^S/ MARINE CORPS LOGISTICS BASE
x^gSvp^ ALBANY, GEORGIA
-------
g
I
b
o
o
. .
W 100
s^Tmas
, 190
From: Hk&s and others. 1937
SCALE: 1 INCH = 2.5 MILES
APPROXIMATE /
150 Po'diH&TUT'c Iwplrlh ihovi sIHjdt (rt which
wwl4 tio»i *10»J in 1ijliH|f wj
- Inlerval j 10 febl. Dfllum t« Mo lin
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FIGURE 2-3
POTENT10WE1RIC SURFACE OF THE
UPPER TLORDAN AQUIFCR ,
LOWER WATE^ BEARING ZONE,
IN WE ALBANY, GEORGIA AREA
N (MMBER V385
RECORD Of DECISION
OPERABLE UNIT 6
MARINE CORPS LDGISTICS BASE
ALBANY. GEORGIA
-------
o
p
b
o
UPPER WATER BEARING ZONE jUWBZ
Ctiafiy Lfttfv Mull ti/ujrty L
Middle Unit .'confining layer)
Overburden and
UWBZ Interface
LOWER WATER BEARING ZONE (LABZl
nti \rnrrpftftnt unttttinnpfH
FIGURE 2-4
NORTHERN PLUME AREA CONCEPTUAL
GROUNDWATER FLOW MODEL
RECORD OF DECISION
OPERABLE UNIT 6
MARINE CORPS LOGISTICS BASE
ALBANY, GEORGIA
-------
• '9fe
o
p
b
o
UPPER WATER BEARING ZONE ;UW6Z
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».'*fturd«i and
UVYR" liil.it*.
FIGURE 2-5
DMA AREA CONCEPTUAL GROUNDWATER
FLOW MODEL
RECORD OF DECISION
OPERABLE UNIT 6
MARINE CORPS LOGISTICS BASE
ALBANY, GEORGIA
-------
Most irrigation wells and household water wells near MCLB Albany draw water from the
LWBZ. City of Albany water wells may also draw water from the Floridan aquifer, but most
of the city water is produced from deeper aquifers below the Lisbon formation.
2.5.3 Ecology
The majority of forested land in the vicinity of the Base is vegetated with longleaf pine
flatwoods, the most extensive plant community in the southern coastal plain. Pine flatwoods
grow in Florida, Georgia, South Carolina, and North Carolina. The pine flatwoods habitat
commonly found at MCLB Albany supports diverse plant and animal life, including
invertebrates (e.g., insects and worms), reptiles, and amphibians. Many mammals inhabit
the pine flatwoods community, although no mammal is exclusive to this habitat. Pine
flatwoods also provide habitat for a variety of birds, including seed- and insect-eaters,
flycatchers, and aerial predators (e.g., owls and hawks).
There are two species of concern at MCLB Albany. The American alligator (Alligator
mississippiensis) has been documented living in wetland habitats at the Base; this
semiaquatic species lives throughout the southeastern United States. Bachman's sparrow
(Aimophila aestivalis) is also a possible resident of the dry, open pine forests at MCLB
Albany. This large, secretive sparrow is a year-round resident of southern Georgia.
2.6 Current and Potential Future Land and Resource Uses
2.6.1 Current Land and Resource Uses
MCLB Albany property land-use and land-cover classifications include industrial,
residential, silviculture, orchards (pecan trees), surface water (ponds), and scrub/wetland.
The land adjacent to the MCLB Albany property is predominantly rural and agricultural,
with the exception of a large residential area north of PSC 3 along Ramsey Road, and a large
residential area near the Johnson Road gate on the northwest corner of the Base. A
residential property is also located southwest of the Base along Fleming Road. Land
bordering the Base to the south, east, and northeast is primarily agricultural with some
residential use and recreational open space. The land to the northwest and west of the Base
contains residential and commercial areas of eastern Albany. An industrial park is located
approximately 1 mile north of the Base, and other industrial facilities are located to the west
of the Base.
A former city of Albany public landfill is located approximately 3 miles west of MCLB
Albany on the west bank of the Flint River. This facility was in operation from the early
1950s until the early 1980s. The current Dougherty County landfill is located between
Fleming Road and Gaissert Road (approximately 1 mile south of MCLB Albany housing),
and has been in operation since 1982.
2.6.2 MCLB Albany Water Supply
The water supply for the MCLB Albany facility is obtained from three deep wells (750 to
997 feet bis) that are located on Base and have been operational since 1953. These wells
currently produce approximately 700,000 gallons of water for the Base each day (Byrd,
1998). Each well produces primarily from two aquifers: the sand and shell limestone of the
ATL\\D:\NAVYRAC\NAVYRAC DELIVERABLES\RECORD OF DECISION\0059\ALBANYROD.DOC 2-14
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Tallahatta Formation of the Pearl River Aquifer, and the sandstone of the Lisbon Formation
(Pearl River aquifer) and the Clayton Formation of the Chattahoochee River aquifer.
The US Geological Survey (1999a) reports that two of the three MCLB Albany supply wells
are screened in the lower part of the UFA. Recent review of the original well-construction
logs indicates the casing in each well extends to the bottom of the UFA.
The domestic and industrial water supply for the Albany municipal area is produced by a
system of artesian wells owned and maintained by the city of Albany. An average of
18.5 million gallons of water is currently produced daily from 32 multi-aquifer wells
(Knight, 1998). Approximately half of this total was supplied by the Tallahatta Formation
(Pearl River aquifer), and half was supplied by the Clayton Formation and Providence Sand
(Chattahoochee River aquifer), based on historic information (Hicks, 1981). The Albany
municipal water system has a production capacity of 34 million gallons per day and
includes 10 elevated vessels (Knight, 1998).
2.6.3 Residential Water Supply
As of early 1999, private residences in the vicinity of MCLB Albany had access to municipal
water systems, with the exception of two areas:
1) Residences north of MCLB Albany and east of Ramsey Road (Ramsey Road area)
2) Residences southwest of MCLB Albany and south of Fleming Road (Fleming Road area)
The USGS (1999b) reports approximately 56 households are supplied by water from
domestic wells in the Ramsey Road area. Based on visual observations, approximately
64 households are supplied by wells in the Fleming Road area (HLA, 2000b). Domestic wells
near the MCLB Albany boundary have shown detectable levels of cVOCs. However,
chemical analyses by USEPA and MCLB Albany over multiple sampling events indicate the
water from domestic wells in the Ramsey Road and Fleming Road areas meets State and
Federal drinking water standards.
Available analytical results indicate that COCs do not exceed MCLs in offsite residential
wells within the NPA. However, MCLB Albany, in cooperation with GEPD and USEPA,
implemented an interim measure in 1999 as a precaution to eliminate the potential for
human exposure to contaminated groundwater associated with the northern plume. The
interim measure consisted of providing access to municipal water for all residents living
within 1 mile of PSC 3. MCLB Albany also offered to fund all costs associated with
permanently sealing and plugging residential wells that were replaced by municipal water
connections (HLA, 2000b). The Navy continues to encourage those members of the
community that have not already done so to accept this standing offer.
2.6.4 Potential Future Land and Resource Uses
There are no known community or county development plans to change the land use
surrounding MCLB Albany. According to the Commandant of the Marine Corps, there are
no future plans for MCLB Albany to be converted from government (military) use to private
use.
ATL\\D:\NAVYRAC\NAVYRAC DELIVERABLES\RECORD OF DECISION\0059\ALBANYROD.DOC 2-15
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2.7 Summary of Site Risks
The following summarizes information contained in the RI/BRA report (HLA, 2000a).
2.7.1 Contaminant Plumes
The RI/BRA (HLA, 2000a) identified three contaminant plumes within the UWBZ of OU 6.
Results from groundwater monitoring conducted in March and April 2001 indicate the NPA
may be two separate plumes (Figure 2-6). The 2001 results show a singular plume within the
LWBZ at NPA (Figure 2-7).
Both biological degradation and mechanical processes (advection, dispersion, diffusion, and
adsorption) appear to be the mechanisms affecting the fate and transportation of cVOCs
detected at OU 6 (HLA, 2000a). Natural attenuation data (HLA, 2000a) indicate biological
degradation is occurring, but available data cannot be used to predict the rate(s) of
biodegradation. The best evidence supporting the occurrence of biological degradation is
the detection of PCE breakdown products including TCE, cz'sl,2-DCE, vinyl chloride, and
ethene. Additionally, the ratio of c/'sl,2-DCE to £ransl,2-DCE is greater than 90 percent. Such
a high predominance of cz'sl,2-DCE strongly indicates that biological degradation is
occurring (Wiedemeier, 1999).
There is no direct evidence to support the occurrence of natural biodegradation of cVOCs
within the LWBZ. It is possible that degradation products have migrated from the UWBZ.
The ultimate fate and transport of the organic chemicals in the UWBZ is the natural
biological degradation of the parent chemical to degradation products. Once the parent and
degradation products migrate from the source area, additional biological degradation may
be more limited and physical transport will predominate. Once the chemicals migrate to the
LWBZ, no biological degradation is expected and only physical transport processes are
likely to occur.
Inorganic elements and compounds occur naturally within the UWBZ. It is possible, but not
documented at MCLB Albany, that changes in oxidation reduction (redox) conditions to
more anaerobic conditions could cause desorption of inorganics from sediment to the
UWBZ aquifer. Ferric iron and anionic inorganics (e.g., arsenic, chromium, selenium, and
vanadium) may occur within the UWBZ as a colloidal phase or may be adsorbed to aquifer
sediment under the normally aerobic, slightly acidic to alkaline environments in the aquifer.
However, where reductive biodegradation is occurring, anaerobic conditions occur and
ferric iron may be reduced to ferrous iron. Conversion of ferric iron to ferrous iron dissolves
both the iron and any adsorbed anionic inorganics (USEPA, 1989c). Once the dissolved
ferrous iron and anionic inorganics migrate to a more aerobic zone, they would re-
precipitate as a colloidal phase. Therefore, the redox potential at different locations within
the aquifer is the most probable factor controlling the concentration of anionic inorganics
detected throughout OU 6. Changes in redox conditions along with sample turbidities
greater than 20 NTUs may explain the variations observed in the concentrations of the
inorganic analytes (HLA, 2000a). Because the natural condition of the UWBZ appears to be
aerobic, active remediation of the inorganic chemicals of concern (COCs) is not warranted.
ATL\\D:\NAVYRAC\NAVYRAC DELIVERABLES\RECORD OF DECISION\0059\ALBANYROD.DOC 2-16
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Legend
PCE
TCE
Cis-1,2Dichloroethene
Carbon Tetrachloride
Well Sampied in March/Aprii 2001
A
1000
Note: Contours are based on contaminant MCL's in groundwater
2000 Feet
Figure 2-6
Upper Water Bearing Zone
Plume Map
March/April, 2001
MCLB Albany
CH2MHIU.
August, 2001
File Path: p:\152Q98
rrjing lawson 3_200t\flGmcao4^pi'
-------
i
Legend
PCE
TCE
A/ Cis-1,2Dich1oroethene
Carbon Tetrachloride
Well Sampled in March/April 2001
L
A
Note: Contours are based on contaminant MCL's in groundwater
Cis 1,2-Dichloroethene values are all below the MCL
1000 2000 Feet
Figure 2-7
Lower Water Bearing Zone
Plume Map
March/April, 2001
MCLB Albany
CH2MHILL
August, 2001
Fife PaBv pAI52098 mdb aJbanytoandirug lawful 3_2l
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2.7.2 Human Health Risk Assessment
Analytical data were used to develop a list of COPCs in groundwater (HLA, 2000a). COPCs
are chemicals that need further evaluation to determine whether or not the concentrations
pose a risk to human health or the environment. The COPCs were used to conduct a BRA in
accordance with USEPA Risk Assessment Guidance. The BRA estimates or characterizes the
potential present and future risks of each CO PC to human health and the environment. The
following three factors were considered when evaluating the potential risks associated with
OU6:
• Nature and extent of COPCs at the site and surrounding areas
• Pathways through which people and the environment are or may potentially be exposed
to COPCs
• Potential toxic effects of COPCs on humans and the environment
The primary pathway for people to become potentially exposed to COPCs in groundwater
is through water supply wells. Existing water supplies for MCLB Albany and the
surrounding areas are:
• MCLB Albany - three multi-aquifer wells screened below LWBZ
• Residential and commercial/industrial areas north and northwest of MCLB Albany -
access to municipal water
. Ramsey Road area - access to municipal water, but private wells are available
. Fleming Road area - private wells and access to municipal water west of the Base
. Agricultural areas - private wells
Exposure Pathways
The BRA identified potential health risks associated with the following groundwater uses:
• Current and future use of groundwater associated with the NPA LWBZ plume
including potable use (e.g., tap water and bathing), swimming pool supply, and garden
irrigation. This provides a worst-case evaluation of possible health risks in the event that
a water supply well was installed in the off-Base portion of the NPA LWBZ
groundwater plume. Residents in the Ramsey Road area closest to the edge of the
northern plume were offered access to the Albany municipal water supply in 1995. In
1999, an additional group of nearby residences was connected to municipal water.
• Future use of groundwater associated with the DMA LWBZ plume and NPA LWBZ
plume for potable household use (e.g., tap water and bathing). This evaluation reflects
possible health risks associated with future use of the on-Base LWBZ groundwater for
residential potable use.
• Future use of groundwater associated with the DMA LWBZ plume and NPA LWBZ
plume for non-potable industrial use (e.g., parts cleaning). This evaluation reflects
possible health risks associated with future use of the on-Base LWBZ groundwater for
non-potable use.
ATL\\D:\NAVYRAC\NAVYRAC DELIVERABLES\RECORD OF DECISION\0059\ALBANYROD.DOC 2-19
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• Future use of the groundwater associated with the UWBZ plumes for potable household
use (e.g., tap water and bathing). This evaluation reflects possible health risks associated
with future use of the on-Base UWBZ groundwater for residential potable use.
Although the groundwater from MCLB Albany may eventually discharge to the Flint River
at or near Radium Springs, analytical data indicate the plumes are miles from the potential
discharge point(s) and there are no complete exposure pathways for aquatic or semiaquatic
receptors. Therefore, no ecological risk assessment was conducted for OU 6.
A BRA was prepared for OU 6 in accordance with the USEPA Risk Assessment Guidance
(USEPA, 1989a). This guidance reflects a conservative approach to the BRA to ensure that
subsequent cleanup decisions are protective of human health and the environment. The
BRA estimates or characterizes the potential current and future risks to human health and
the environment. Three factors were considered when evaluating the potential risks
associated with OU 6.
• Extent of contamination present at the site and surrounding areas.
• Pathways through which people and the environment are or may potentially be exposed
to contaminants at the site.
• Potential toxic effects of site contaminants on humans and the environment.
Exposure pathways considered for the human health portion of the BRA include incidental
ingestion, skin contact, and inhalation of fugitive dust generated during excavation
activities. These pathways were then applied to a current land-use scenario in which Base
workers and child trespassers could possibly be exposed to contaminated media. Although
trespassers have not been observed at the site, child trespassers could obtain access to the
site. These pathways were also applied to a future land-use scenario in which a child
transient and a child and adult resident could potentially be exposed to contaminated
media. The human health risk estimates for OU 6 under current and hypothetical future
land-use scenarios are presented in Table 2-2.
Current Residential Use - LWBZ
This exposure assessment included ingestion of groundwater as drinking water, ingestion
and dermal contact during swimming, ingestion of produce from a residential garden,
inhalation of volatiles while showering and while irrigating a lawn or garden.
Cancer risk associated with current residential use of groundwater from the off-Base portion
of the NPA LWBZ is at the upper limit of the USEPA cancer risk range (IX1O4) for the RME,
and is within the USEPA cancer risk range (IX1O4 to IX1O6) for the CT. Noncancer risks for
this exposure exceed the USEPA HI threshold of 1 for the adult and child resident.
It should be noted that the highest recorded offsite contaminant concentration was used to
estimate the cancer risk associated with current residential groundwater. This concentration,
which was observed in a monitoring well approximately 1/3 mile west of Ramsey Road, is
as much as 10 times higher than the highest concentration detected in any private well. This
conservative approach for estimating cancer risk was used because no controls are currently
in place to prevent installation or use of water supply wells in the vicinity of the northern
plume area.
ATL\\D:\NAVYRAC\NAVYRAC DELIVERABLES\RECORD OF DECISION\0059\ALBANYROD.DOC 2-20
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Table 2-2
Risk Summary for Current and Future Land Use
Land Use
Exposure Route
RME
HI * ELCR *
CT
HI*
ELCR*
Lower Water Bearing Zone - Current Land Use
Off-Base NPA Plume
Adult Resident
Ingestion of Groundwater as Drinking Water 0.8
3x10-5
Ingestion During Swimming 0.005 2x10-7
Produce Ingestion Associated with Irrigation 0.2
Dermal Contact During Swimming 0.4
Inhalation of Volatiles while Showering 0.2
4x10-6
4x10-5
3x10-6
Inhalation of Volatiles During Irrigation 0.009 1x10-7
Child Resident
Total Risk to Adult Resident: 2
Ingestion of Groundwater as Drinking Water 2
8x10-5
2x10-5
Ingestion During Swimming 0.02 2x10-7
Produce Ingestion Associated with Irrigation 0.2
Dermal Contact During Swimming 0.7
Total Risk to Child Resident: 3
Total Risk to Resident (Adult and Child) NC
1 X10-6
2x10-5
4x10-5
1x10-4
0.6
0.003
0.06
0.2
0.2
0.009
1
2
0.01
0.06
0.4
2
NC
6x10-6
3x10-8
4x10-7
6x10-6
7x10-7
3x10-8
1 X10-5
5x10-6
3x10-8
1 X10-7
3x10-6
8x10-6
2x10-5
Upper Water Bearing Zone - Future Land Use
PSC 1 Plume
Adult Resident
Incidental ingestion 2
4x10-3
Inhalation of Volatiles while Showering 0.008 2x10-4
Child Resident
PSC 3 Plume:
Adult Resident
Total Adult Resident 2
Incidental ingestion 6
Total Child Resident 6
Total Risk to Resident (Adult and Child) NC
Incidental ingestion 4
4x10-3
2x10-3
2x10-3
6x10-3
5x10-5
Inhalation of Volatiles while Showering 0.003 4x10-6
Child Resident
PSC 26 Plume:
Adult Resident
Child Resident:
Total Adult Resident 4
Incidental ingestion 9
Total Child Resident 9
Total Risk to Resident (Adult and Child) NC
Incidental ingestion 10
Inhalation of Volatiles while Showering 4
Total Adult Resident 14
Incidental ingestion 23
Total Child Resident 23
Total Risk to Resident (Adult and Child) NC
5x10-5
3x10-5
3x10-5
8x10-5
3x10-4
3x10-5
3x10-4
2x10-4
2x10-4
5x10-4
2
0.008
2
5
5
NC
3
0.003
3
7
7
NC
7
4
11
20
20
NC
9x10-4
5x10-5
1x10-3
7x10-4
7x10-4
2x10-3
1 X10-5
1x10-6
1x10-5
8x10-6
8x10-6
2x10-5
6x10-5
8x10-6
7x10-5
5x10-5
5x10-5
1 X10-4
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2-21
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Table 2-2 (Continued)
Risk Summary for Current and Future Land Use
Land Use
Exposure Route
RME
HI*
ELCR*
CT
HI*
ELCR*
Upper Water Bearing Zone - Future Land Use (Cont.)
PSC 4 Plume
Adult Resident
Child Resident
DMA Plume:
Adult Resident
Child Resident
Incidental ingestion
Inhalation of Volatiles while Showering
Total Adult Resident
Ingestion of Groundwater as Drinking Water
Total Child Resident
Total Risk to Resident (Adult and Child):
Ingestion of Groundwater as Drinking Water
Inhalation of Volatiles while Showering
Total Risk to Adult Resident
Ingestion of Groundwater as Drinking Water
Total Risk to Child Resident
Total Risk to Resident (Adult and Child)
0.03
0
0.03
0.1
0.1
NC
5
0.3
5
11
11
NC
8x10-7
1 x 10-7
9x10-7
4x10-7
4x10-7
1 x 10-6
3x10-4
2x10-5
3x10-4
2x10-4
2x10-4
5x10-4
0.02
0
0.02
0.07
0.07
NC
3
0.3
3
9
9
NC
2x10-7
3x10-8
2x10-7
1x10-7
1x10-7
3x10-7
7x10-5
6x10-6
8x10-5
6x10-5
6x10-5
1 X10-4
Lower Water Bearing Zone - Future Land Use
On-Base NPA Plume:
Adult Worker
Adult Resident
Child Resident
Inhalation During Parts Washing
Total Risk to Adult Worker
Ingestion of Groundwater as Drinking Water
Inhalation of Volatiles while Showering
Total Risk to Adult Resident
Ingestion of Groundwater as Drinking Water
Total Risk to Child Resident
Total Risk to Resident (Adult and Child)
0.002
0.002
2
0.001
2
4
4
NC
5x10-6
5x10-6
4x10-5
4x10-6
4x10-5
2x10-5
2x10-5
6x10-5
0.0008
0.0008
1
0.001
1
3
3
NC
7x10-7
7x10-7
8x10-6
1x10-6
9x10-6
6x10-6
6x10-6
2x10-5
Off-Base NPA Plume:
Adult Resident
Child Resident
Ingestion of Groundwater as Drinking Water
Ingestion During Swimming
Produce Ingestion Associated with Irrigation
Dermal Contact During Swimming
Inhalation of Volatiles while Showering
Inhalation of Volatiles During Irrigation
Total Risk to Adult Resident
Ingestion of Groundwater as Drinking Water
Ingestion During Swimming
Produce Ingestion Associated with Irrigation
Dermal Contact During Swimming
Total Risk to Child Resident
Total Risk to Resident (Adult and Child)
3
0.02
0.2
0.4
0.2
0.008
4
8
0.1
0.2
0.7
9
NC
2x10-5
1 x 10-7
3x10-6
2x10-5
2x10-6
9x10-8
5x10-5
1 x 10-5
1 x 10-7
7x10-7
1 x 10-5
2x10-5
6x10-5
2
0.01
0.05
0.2
0.2
0.008
2
7
0.05
0.05
0.4
8
NC
4x10-6
2x10-8
2x10-7
3x10-6
6x10-7
3x10-8
8x10-6
3x10-6
2x10-8
7x10-8
2x10-6
5x10-6
1 X10-5
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2-22
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Table 2-2 (Continued)
Risk Summary for Current and Future Land Use
RME
Land Use Exposure Route HI * ELCR *
Lower Water Bearing Zone - Future Land Use (Continued)
DMA Plume
AdultWorker Inhalation of Volatiles During Parts Washing 0.00001 7x10-7
Total Risk to Adult Worker 0.00001 7x10-7
Adult Resident Ingestion of Groundwater as Drinking Water 0.2 4x10-6
Inhalation of Volatiles while Showering 0.000009 5 x 10-7
Total Risk to Adult Resident 0.2 5x10-6
Child Resident Ingestion of Groundwater as Drinking Water 0.5 2x10-6
Total Risk to Child Resident 0.5 2x10-6
Total Risk to Resident (Adult and Child) NC 7x10-6
CT
HI* ELCR*
0.00000 9x10-8
6
0.00000 9x10-8
6
0.1 8x10-7
0.00000 2x10-7
9
0.1 1x10-6
0.4 7x10-7
0.4 7x10-7
NC 2x10-6
RME = reasonable maximum exposure
CT = central tendency
HI = hazard index
* = receptor totals may vary from RI/BRA calculations (HLA, 2000) due to rounding
ELCR = excess lifetime cancer risk
NC = Not calculated because child and adult His are not additive.
ND = No human health dose-response data for this exposure route were available in this medium.
Future Residential Use - UWBZ
This exposure assessment included ingestion of groundwater as drinking water, and
inhalation of volatiles while showering.
Cancer risks associated with future residential potable use of groundwater from the UWBZ
at the PSC \, PSC 26, and DMA Area plumes exceeded the upper limit of USEPA's cancer
risk range (IX1O4) for the RME and CT. Noncancer risks for this exposure exceed USEPA's
HI threshold of 1 for the adult and child resident.
Cancer risks associated with future residential potable use of groundwater from the UWBZ
at the PSC 3 are within the range USEPA considers acceptable (IX1O4 to IX1O6) for the
RME and CT. Noncancer risks for this exposure exceed the USEPA HI threshold of 1 for the
adult and child resident.
Cancer risks associated with future residential potable use of groundwater from the UWBZ
at the PSC 4 are within the range USEPA considers acceptable (IX1O4 to IX1O6) for the
RME. Also, the CT is acceptable, as the value is lower than the upper limit (IX1O6).
Noncancer risks for this exposure are less than USEPA's HI threshold 1 for the adult and
child resident.
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Future Industrial Use - LWBZ
This exposure assessment included inhalation of volatiles while washing parts.
Cancer and non-cancer risks associated with industrial use of the on-Base portion of the
NPA or DMA LWBZ groundwater do not exceed either the USEPA cancer risk range
(IX10-4 to IX1O6) or the non-cancer HI threshold of 1.
Future Residential Use - LWBZ
This exposure assessment included ingestion of groundwater as drinking water, and
inhalation of volatiles while showering.
Cancer risks associated with future residential potable use of groundwater from the on-Base
portions of LWBZ at the NPA and DMA are within the range USEPA considers acceptable
(IX1O4 to IX1O6) for the RME and CT. Noncancer risks for this exposure are equal to or
exceed the USEPA HI threshold of 1 for the adult and child resident.
Chemicals of Concern
COCs are defined for each chemical associated with a cancer risk greater than IX1O6 and/or
an HQ greater than 0.1 (as determined in the risk assessment), and/or exceed an MCL. The
COCs within each plume are:
• PSC 1 UWBZ: cis 1,2-DCE, methylene chloride, TCE, vinyl chloride, and antimony
. PSC 3 UWBZ: cis-l,2-DCE, PCE, and TCE
• PSC 26 UWBZ: carbon tetrachloride, chloroform, and TCE
. DMA UWBZ: 1,1-DCE, cis-l,2-DCE, benzene, methylene chloride, TCE, vinyl chloride,
antimony; arsenic, cadmium, and thallium
. NPA LWBZ On-Base : cis-l,2-DCE, PCE, and TCE
. NPA LWBZ Off-Base Current: 1,2-DCE (total), cis 1,2-DCE, carbon tetrachloride,
chloroform, PCE, and TCE
. NPA LWBZ Off-Base Future: 1,2-DCE (total), cis 1,2-DCE, carbon tetrachloride,
chloroform, PCE, TCE, antimony, and thallium
. PSC 4 UWBZ: TCE
2.7.3 Ecological Risk Assessment
The groundwater plumes at MCLB Albany do not discharge to any surface water bodies
and there is no completed exposure pathway for aquatic or semiaquatic receptors. Potential
sources of soil contamination are being addressed to eliminate potential exposure pathways
for land animals and plants. Therefore, no ecological risk assessment for OU 6 is needed.
2.8 Remedial Action Objectives
The remedial action objectives for OU 6 are listed in Table 2-3. A summary of cleanup
(action) levels associated with remedial action objective (RAO) 1 is presented in Table 2-4.
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Timeframes for achieving the RAOs were presented in Table 1-1. Off site the COCs must
attain the cleanup goal in 10 years; onsite the COCs must attain the cleanup goal in 20 years.
Table 2-3
Remedial Action Objectives for Operable Unit 6
Medium
Overburden
Groundwater
Groundwater
RAO
RAO 1: Reduce chemical mobility, toxicity, or volume in the overburden that causes
groundwaterto exceed cleanup levels.
RAO 2: Reduce chemical concentrations in groundwaterto MCLs or to risk-based standards for
those chemicals without MCLs.
RAO 3: Reduce human exposure to contaminants of concern in groundwater that exceed
cleanup levels.
RAO = remedial action objective
MCL = maximum contaminant level
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Table 2-4
Action Levels for Chemicals of
Analyte
Residential2
RGOat
ELCR =
1x10-4
(ug/L)
RGOat
ELCR =
1x10-5
(ug/L)
RGOat
ELCR =
1x10-6
(ug/l)
RGOat
HI = 3
(ug/L)
RGO at RGO
Hl = 1 HI = C
(ug/L) (ug/L
Concern1
USEPA Region
at III Risk-Based
1.1 Concentration
-) (ug/L)
Background
Concentrations
(ug/L)3
Federal
MCL
(ug/L)
Action
Level
(Mg/L)4
Volatile Organic Compounds
1,1-DCE
1,2-DCE (total)
cis-1,2-DCE
Benzene
Carbon Tetrachloride
Chloroform
Methylene Chloride
PCE
TCE
Vinyl Chloride
11
NA
NA
NR
50
NR
NR
NR
NR
3.5
1.1
NA
NA
20
4-5
NA
87
3.8-12
27-57
0.35
0.11
NA
NA
2.0
0.4-0.5
4.0
8.7
0.38-1.2
2.7-5.7
0.0354
NA
NR
470
NR
33
NR
NR
NR
NR
NA
NA NA
0.044
NR 14-15 5.5
160 15-16 6.1
48 4.8
11 1.1
15 1.5
NR 94
0.36
0.16
0.15
4.1
NR 8.9-16 1.1
91-95 9.3-9
NA NA
.5 1.6
0.019
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
7
NA
70
5
5
100
5
5
5
2
7
5.5
70
5
5
100
5
5
5
2
Inorganic Analytes - UWBZ
Antimony
Arsenic
Cadmium
Chromium
Thallium
Vanadium
NA
NR
NA
NA
NA
NA
NA
0.45
NA
NA
NA
NA
NA
0.045
NA
NA
NA
NA
NR
NR
NR
NR
3.7-3.8
NR
6.1 0.61-.
63 1.5
NR 0.47 0.045
NR 0.79 1.85
NR 4.6
1.2-1.3 0.12-.
NR 11
116
13 0.26
26
NA
NA
0.66
7.6
NA
13.2
6
50
5
100
2
NA
6
50
5
100
2
13.2
Inorganic Analytes - LWBZ
Antimony
Thallium
NA
NA
NA
NA
NA
NA
NR
3.8
6.1 0.61 1.5
1.3 0.13 0.26
NA
NA
6
2
6
2
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Table 2-4 (Continued)
Action Levels for Chemicals of Concern1
''Chemicals of concern are chemicals detected in groundwater (UWBZ and/or LWBZ) that are associated with a cancer risk greater than 1x10-6 and/or a
hazard quotient greater than 0.1 and exceeding its MCL. The chemicals of concern were determined in the Remedial Investigation and Baseline Risk
Assessment report for Operable Unit 6 (HLA, 1999).
were calculated for each plume. The maximum range of RGOs at the stated ELCRs and His over all plumes are shown for organics. For inorganics the
range of RGOs is shown separately for plumes in the UWBZ and plumes in the LWBZ. NA indicates that an RGO is not applicable; for example, if a
substance is toxic but not a cancer-causing agent, then an RGO at a specific ELCR is not computable. NR indicates not reported, because the calculated
RGO exceeded the exposure point concentration for all plumes.
3Background screening concentrations are 2 times the arithmetic mean of detected inorganic analyte concentrations in either the upper water bearing zone
(UWBZ) or lower water bearing zone (LWBZ) background wells. The background screening concentrations for inorganics are presented in Table 6-1 (for the
UWBZ) and Table 6-2 (for the LWBZ) of the Remedial Investigation and Baseline Risk Assessment report for Operable Unite (HLA, 2000a).
^Action levels are assumed to be MCLs, except for inorganics, in which case action levels are assumed to be MCLs unless twice the background screening
concentration can be used. Action levels defined for organics apply to both the UWBZ and LWBZ.
5Value is for cadmium-water.
6Value is for chromium +6.
RGO = remedial goal option
ELCR = excess lifetime cancer risk
ug/L = micrograms per liter
USEPA = U.S. Environmental Protection Agency
MCL = maximum contaminant level
DCE = dichloroethene
UWBZ = upper water bearing zone
NA = not applicable
NR = not reported
PCE = tetrachloroethene
TCE = trichloroethene
ND = non-detect
OU = operable unit
-------
Applicable or Relevant and Appropriate Requirements
The Superfund Amendments and Reauthorization Act (SARA) requires that all remedial
actions meet applicable or relevant and appropriate requirements (ARARs), that data
evaluations and risk assessments be conducted in accordance with guidance documents,
and that remedial decisions comply with the National Oil and Hazardous Substances
Contingency Plan (NCP). Under SARA, preferred remedial actions permanently and
significantly reduce the toxicity, mobility or volume of the hazardous contaminants. In
accordance with SARA, a list of ARARs was prepared to determine the appropriate extent
of cleanup for soil and groundwater at OU 6, and to develop remedial action alternatives.
The ARARs, presented in Table 2-5, include both Federal and State regulations and
guidance criteria.
Based on the results of the BRA (Section 2.7), the cVOCs detected in groundwater samples
collected from the UWBZ and LWBZ at the NPA and DMA, and UWBZ at PSC 4 pose a risk
to adult and child residents who may utilize this resource under current and future use as a
potable source (ingestion and inhalation while showering). Remedial alternatives were
identified (Section 2.4) to reduce the risk posed to residential receptors who may use
groundwater from OU 6 as a potable resource. Below is a description of the USEPA
screening criteria that were used to evaluate the compliance of the remedial response
(Table 2-1) with the ARARs (Table 2-5), and USEPA's threshold criteria, primary balancing
criteria, and modifying criteria.
2.9 Description of Remedial Alternatives
Source Control
The alternatives discussed in this ROD are labeled as follows:
. NPA and PSC 4
- SC-1: Landfill Cap
SC-2: Excavation and Off-Site Management
- SC-3: ET Cap
SC-4: In Situ Treatment - Thermal Desorption
. DMA
SC-5: Source Control
The source control (SC) alternatives SC-1 through SC-4 apply only to PSC 4 and the NPA.
SC-5 is the only alternative that contains source control measures appropriate for the DMA.
Therefore, evaluation of SC-5 in comparison to the other source control alternatives is not
appropriate. Table 2-6 presents a summary of the evaluation of the potential source control
alternatives for OU 6. Detailed discussion of the evaluation is provided in the FS for OU 6
(HLA, 2000c).
The source areas of contamination that were identified in the RI (HLA, 2000A) are
addressed in the FS (HLA, 2000c) strictly as sources for potential groundwater
contamination. These source areas currently pose no unacceptable human health or
ecological risk due to exposure to surface soil and already have RODs (ABB-ES, 1996;
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Table 2-5
Synopsis of Potential Federal and
State ARARs and Guidance
Name and
Citation
Description
Consideration in the
Remedial Action Process
Type
RCRA Regulations,
Releases from SWMUs
(40 CFR Part 264,
Subpart F)
RCRA, Closure and Post-
Closure (40 CFR Part
264, Subpart G)
RCRA Regulations,
Identification and Listing
of Hazardous Wastes (40
CFR Part 261)
Endangered Species Act
Regulations (50 CFR
Parts 81, 225, 402)
Clean Water Act (CWA)
Regulations, Water
Quality Standards (40
CFR Part 131)
Fish and Wildlife
Coordination Act
Regulations (33 CFR
Subsection 320.3)
Establishes the requirements for SWMUs at RCRA
regulated TSD facilities. The scope of the regulation
encompasses groundwater protection standards,
concentration limits, point of compliance, compliance
period, requirements for groundwater monitoring,
detection monitoring, and compliance monitoring, and the
corrective action program.
Details general requirements for closure and post closure
of hazardous waste facilities, including installation of a
groundwater monitoring program.
Defines the listed and characteristic hazardous wastes
subject to RCRA. Appendix II contains the Toxicity
Characteristic Leaching Procedure.
The Act requires Federal agencies to take action to avoid
jeopardizing the continued existence of federally listed
endangered or threatened species.
Establishes ecological and health-based Federal Ambient
Water Quality Criteria (AWQCs) that are non-enforceable
guidelines used by states to set their state-specific water
standards for surface water (USEPA, 1988c).
Requires that the U.S. Fish and Wildlife Service, National
Marine Fisheries Service, and related State agencies be
consulted prior to structural modification of any water
body, including wetlands. If modifications must be
conducted, the regulation requires that adequate
protection be provided for fish and wildlife resources.
This rule is applicable for groundwater remediation
executed under the RCRA Corrective Action Program,
and appropriate and relevant for Comprehensive
Environmental Response, Compensation, and Liability
Act. sites contaminated with RCRA hazardous
constituents.
This requirement is a potential ARAR for remedial
alternatives that involve the closure of a hazardous
waste site.
These regulations would apply when determining
whether a solid waste generated by a source removal
action is hazardous, either by being listed or by
exhibiting a hazardous characteristic, as described in
the regulations.
If a site investigation or remedial activity could
potentially affect an endangered species or endangered
species habitat, these regulations would apply.
These AWQCs may be used as a basis for determining
cleanup levels in the absence of State water quality
standards. Furthermore, these regulations, and possibly
the NPDES permit system, would apply if a remedy
involves discharging to surface water.
If a remedial alternative involves the alteration of a
stream or wetland, these agencies must be consulted.
Chemical-Specific
Action-Specific
Chemical-Specific
Action-Specific
Location-Specific
Chemical-Specific
Location-Specific
-------
Table 2-5 (Continued)
Synopsis of Potential Federal and State ARARs
and Guidance
Name and
Citation
Description
Consideration in the
Remedial Action Process
Type
National Environmental Policy Act
(NEPA) Regulations, Wetlands,
Floodplains, etc. (40 CFR
Subsection 6.302 [a])
CAA, National Ambient Air Quality
Standards (NAAQS) and National
Emissions Standards for Hazardous
Air Pollutants (NESHAPs) (40 CFR
Parts 50 and 61)
Safe Drinking Water Act (SDWA),
National Primary Drinking Water
Standards, Maximum Contaminant
Levels (MCLs) and Maximum
Contaminant Level Goals (MCLGs)
(40 CFR part 141)
These regulations contain the procedures for
complying with Executive Order 11990 on wetland
protection. Appendix A states that no remedial
alternative adversely affect a wetland if another
practicable alternative is available. If no alternative
is available, impacts from implementing the chosen
alternative must be mitigated.
NAAQS establish primary (health based) and
secondary (welfare based) ambient air quality
standards for carbon monoxide, lead, nitrogen
dioxide, particulate matter, ozone, and sulfur
oxides emitted from a major source of air
emissions.
NESHAPs establish emission standards for
specific types of air pollution sources and
pollutants.
Establishes enforceable standards for specific
contaminants determined to adversely effect
human health. MCLs are protective of human
health for individual chemicals and are developed
using MCLGs, available treatment technologies,
and cost data.
ARAR = Applicable or Relevant and Appropriate Requirement
RCRA = Resource Conservation and Recovery Act
SWMU = solid waste management unit
CFR = Code of Federal Regulations
TSD = treatment, storage, and disposal
NPDES = National Pollutant Discharge Elimination System
CAA = Clean Air Act
LDR = land disposal restriction
USEPA = U.S. Environmental Protection Agency
OCGA = Official Code of Georgia
GDNR = Georgia Department of Natural Resources
GAGEPD = Georgia Environmental Protection Division
If remedial action affects a wetland, these regulations
would apply.
Location-Specific
Site remediation activities must comply with NAAQS
and NESHAPs. The principal application of these
standards is during remedial actions or application of
remedial technologies resulting in exposures through
dust and vapors.
MCLs established by the SDWA are relevant and
appropriate standards where the MCLGs are not
determined to be ARARs. MCLs and MCLGs apply to
groundwaters or surface waters that are current or
potential drinking water sources.
Action-Specific
Chemical-Specific
-------
Table 2-6
Summary of Evaluation of Source Control Remedial Alternatives
Plume Area
Criterion
NPA and PSC 4
Alternative SC-1 :
Landfill Cap
Alternative SC-2:
Excavation and Off-
Site
Management
Alternative SC-3:
Evapotranspiration
Cap
Alternative SC-4:
In Situ Thermal Desorption
Overall Protection of Human Health and the Environment
How risks are
eliminated, reduced, or
controlled.
Short-term or cross-
media effects.
Mobility of COCs in source
areas is reduced.
None
Mobility of COCs in source
areas is eliminated.
Cross-media contamination
through volatilization during
excavation may occur.
Mobility of COCs in source
areas is eliminated.
None
Mobility of COCs in source
areas is reduced.
Cross-media contamination
through volatilization during
thermal well installation may
occur.
DMA
SC-5: Source Control
Mobility of COCs in source
area is reduced.
None
Compliance with ARARs
Chemical-action-and-
location-specific
Complies with ARARs
Complies with ARARs
Complies with ARARs
Complies with ARARs
Long-Term Effectiveness and Permanence
Magnitude of residual
risk
Adequacy of controls
Reliability of controls
None
Implementation of SC-1
would provide long-term
source control as long as
the landfill cap is
maintained.
Reliability of cap depends
on maintenance.
Reliability of deed
restrictions depends on
enforcement.
None
Implementation of SC-2
would provide immediate
and long-term source
control at OU 6.
Excavation is reliable at
eliminating the source of
contamination.
None
Implementation of SC-3
would provide long-term
source control as long as
the ET cap is maintained.
Reliability of plants to
uptake water will be
determined from pilot test
information.
None
Implementation of SC-4 would
provide long-term source control
at OU 6.
Reliability of technology will be
determined from other projects
where it has been applied.
Complies with ARARs
None
Implementation of SC-5
would provide long-term
source control at OU 6.
Reliability of source control
will be determined from site
monitoring
-------
Table 2-6 (Continued)
Summary of Evaluation of Source Control Remedial Alternatives
Criterion
Alternative SC-1:
Landfill Cap
Alternative SC-2:
Excavation and Off-
Site
Management
Alternative SC-3:
Evapotranspiration
Cap
Alternative SC-4:
In Situ Thermal
Desorption
SC-5:
Source Control
Reduction of Toxicity, Mobility, or Volume
Treatment process and
remedy
Amount of hazardous
material destroyed or
treated
Reduction of mobility,
toxicity, or volume
through treatment
Containment
None
No treatment of sources.
Mobility of chemicals in soil
greatly reduced by capping.
No reduction in volume;
biodegradable waste will
decrease in toxicity with
time.
Contaminants are removed
and contained in a
permitted facility but not
treated.
None
No treatment of sources.
Soils are disposed in a
RCRA-approved facility.
Reduction in toxicity,
mobility, and volume of site
subsurface soil.
Containment.
None
No treatment of sources.
Mobility of chemicals in soil
reduced by vegetative
cover. No reduction in
volume; biodegradable
waste will decrease in
toxicity with time.
Contaminants are destroyed
through thermal treatment.
All VOC contamination
destroyed.
Reduction in toxicity, mobility,
and volume of contaminants
through thermal destruction.
Containment
None
No treatment of sources.
Mobility of chemicals in soil
greatly reduced by capping.
No reduction in volume;
biodegradable waste will
decrease in toxicity with time.
Short-Term Effectiveness
Protection of
community during
remedial action
Protection of workers
during remedial action
Environmental effects
Time to complete
construction/
implementation
No impacts on community.
Minor risk during installation
of cap. Health and safety
protection likely required
during construction.
Each site would have to be
cleared and grubbed prior
to construction of cap.
1 year
Possible impact from
volatilization of
contaminants during
removal.
Minor risk during
excavation of contaminated
soil. Health and safety
protection required during
excavation.
Each site would have to be
cleared and grubbed prior
to excavation of
contaminated soil.
1 year
No impacts on community.
Minor risk during planting
activities. Health and
safety protection required
during planting.
Some potential ecological
impacts from the addition
of new plant life.
2 years
Minor impacts from noise during
installation of thermal wells.
Minor risk during installation of
thermal wells. Health and safety
plan required during installation
activities.
Significant environmental effects
from site preparation and
construction of thermal wells.
5 years
No impacts on community
Health and safety protection
required during
implementation
None
1 year
-------
Table 2-6 (Continued)
Summary of Evaluation of Source Control Remedial Alternatives
Criterion
Alternative SC-1:
Landfill Cap
Alternative SC-2:
Excavation and Off-Site
Management
Alternative SC-3:
Evapotranspiration
Cap
Alternative SC-4:
In Situ Thermal Desorption
SC-5:
Source Control
Implementability
Availability of technology
Reliability of technology
Availability of treatment,
storage, and disposal
(TSD) services for
contaminated soil
Monitoring
considerations
Readily available and
widely used.
Depends on inspection
and maintenance of soil
cover.
None required.
Minimal O&M costs.
Readily available and widely
used.
Land disposal reliably
reduces migration and
exposure.
Offsite TSD facilities are
needed for contaminated
soil. Local TSDs handle non-
hazardous waste only.
No O&M costs
Not readily available.
Technology is emerging.
Technology is only available
through small number of
vendors.
Reliability has net yet been Technology is reliable, but
proven.
None required.
Minimal O&M costs
dependent on electrical capacity.
None Required.
No O&M costs
Readily available and widely
used.
Technology is reliable, but
integrity of control measures
must be maintained.
None Required.
Minimal O&M costs.
Estimated Cost
Total present worth
(including
contingency)
For additional cost
details see Final Draft
FS (HLA, 2000c)
PSC 1:
PSC3:
PSC 4:
PSC 26:
$621,000
$1,616,000
$537,000
$5,414,000
PSC 1:
PSC 3:
PSC 4:
PSC 26:
$6,200,000 C
$2,770,000 D
$115,988,000 C
$46,597,000 D
$7,255,000 C
$3,172,0000
$76,031,000 C
$32,702,000 D
PSC 1:
PSC 3:
PSC 4:
PSC 26:
$145,000
$488,000
$182,000
$1,437,000
PSC 1:$6,417,000
PSC3:$20,122,000
PSC 4:$6,588,000
PSC26$71,651,000:
DMA: $10,691,000
Detailed itemization of capital cost are provided in the FS for OU 6 (HLA, 2000c).
SC = source control.
COC = chemical of concern.
ARARs = applicable or relevant and appropriate requirements.
OU = operable unit.
ET = evapotranspiration.
VOC = volatile organic compound.
RCRA = Resource Conservation and Recovery Act.
O&M = operations and maintenance.
PSC = potential source of contamination.
C = Subtitle C landfill.
D = Subtitle D landfill.
DMA = Depot Maintenance Activity.
NPA = Northern Plume Area.
-------
ABB-ES, 1997'a; ABB-ES, 1997b; ABB-ES, 1997c; and HLA, 1999b). Because source control
was required by USEPA Region IV and GEPD to prevent the migration of COCs in the
vadose zone to groundwater, the no further action alternative was not evaluated in the FS
(HLA, 2000c).
Groundwater
Groundwater remedial alternatives discussed in this ROD are labeled as follows:
. GW-1: No Action
• GW-2: Limited Action - Groundwater Monitoring and Institutional Controls
• GW-3: Ex Situ Physical Treatment - Air Stripping
• GW-4: In Situ Treatment - Enhanced Bioremediation
• GW-5: In Situ Treatment - Monitored Natural Attenuation
• GW-6: In Situ Treatment - Thermal Desorption
Table 2-7 presents a summary of the evaluation of the potential groundwater remedial
alternatives for OU 6. Detailed discussion of the evaluation is provided in the FS for OU 6
(HLA, 2000c).
2.10 Comparative Analysis of Alternatives
This summary is a synopsis of the comparative analysis of remedial alternatives from the
OU 6 Feasibility Study (HLA, 2000c). The comparative analysis of remedial alternatives
evaluates the relative performance of each alternative against the others. The purpose of the
comparative analysis is to identify the advantages and disadvantages of the alternatives
relative to one another to aid in selecting remedies for OU 6. The comparative analysis
described in this section compares the five source control remedial technologies and the six
groundwater remedial technologies relative to the same evaluation criteria.
Specific CERCLA requirements are considered when comparing alternatives for selection of
a preferred alternative. To the extent practicable, the selected alternative should:
• Be protective of human health and the environment
• Comply with ARARs (or provide grounds for invoking a waiver)
• Use permanent solutions and alternative treatment technologies
• Satisfy the preference for treatment that reduces toxicity, mobility, or volume of
contaminants as a principal element (if this preference is not satisfied, the decision
document must explain why)
• Be cost effective
The NCP outlines the approach for performing the comparative analysis of remedial
alternatives. The selected remedy must reflect the scope and purpose of the actions being
undertaken and show how these actions relate to remedial action objectives (RAOs)
(Table 2-3) and long-term responses at the site. The identification of the preferred alternative
is based on evaluation of the major tradeoffs in terms of the nine evaluation criteria. The
USEPA has categorized the evaluation criteria into three groups: threshold criteria, primary
balancing criteria, and modifying criteria. These criteria are described below.
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Table 2-7
Summary of Evaluation of Groundwater Remedial Alternatives
Alternative
Alternative GW-1
No Action
Alternative GW-2
Monitoring and
Institutional
Controls
Alternative GW-3
Air Sparging
Alternative GW-4
Enhanced
Bioremediation
Alternative GW-5
Monitored
Natural
Attenuation
Alternative GW-6
Thermal
Desorption
Overall Protection of Human Health and the Environment
How risks are
eliminated, reduced,
or controlled.
Short-term or cross-
media effects
No protection to
human health
because risks via
ingestion of
contaminated
groundwater would
not be prevented or
reduced.
None
Institutional controls
would reduce the risk
of exposure to
groundwater via
ingestion.
None
Risks via ingestion of
contaminated
groundwater would be
reduced removing
contaminants through
ground-water
extraction and
treatment, and
through institutional
controls.
None. Contamination
would be adsorbed to
granular activated
carbon.
Risk management is
the same as for
Alternative GW-2.
Risks would be
reduced at a faster
pace as biological
treatment is
enhanced.
None. Contamination
would be biologically
degraded in situ.
Institutional controls
would reduce the risk
of exposure to
groundwater via
ingestion.
None. Contamination
would be naturally
degraded in situ.
Thermal treatment of
source areas
eliminates risk of
exposure to
contaminants.
Cross-media
contamination
through volatilization
during thermal well
installation may occur
Compliance with ARARs
Chemical-action-and-
location-specific
Does not comply with
ARARs.
Would achieve
compliance with
ARARs.
Would achieve
compliance with
ARARs.
Would achieve
compliance with
ARARs.
Would achieve
compliance with
ARARs.
Would achieve
compliance with
ARARs.
Long-Term Effectiveness and Permanence
Magnitude of residual
risk
Natural processes
would eventually
reduce risk to
acceptable levels.
Institutional controls
would reduce risk as
long as they are
enforced. Natural
processes would
eventually reduce risk
to acceptable levels.
The risk would be
controlled and
permanently reduced
to acceptable levels.
The risk would be
controlled. Pilot
testing is required to
verify that
contaminants would
be permanently
reduced to acceptable
levels.
Natural processes
would eventually
reduce risk to
acceptable levels.
Institutional controls
would reduce risk as
long as they are
enforced.
Risk to human and
environmental
receptors reduced
significantly because
contaminants would
be thermally
destroyed.
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2-37
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Table 2-7 (Continued)
Summary of Evaluation of Groundwater Remedial Alternatives
Alternati
Alternative No A
Alternative GW-2
Monitoring and
ve GW-1 Institutional
ction Controls
Adequacy of controls No controls are Institutional controls,
implemented. if enforced, would
adequately prevent
ingestion of
contaminated
groundwater.
Reliability of controls No controls are Institutional controls
implemented. are reliable as long as
they are enforced.
Alternative GW-3
Air Sparging
Groundwater
extraction and
treatment provides
adequate controls to
prevent exposure and
attain objectives.
Groundwater
extraction and
treatment is generally
reliable, but
sometimes fails to
meet target cleanup
levels.
Alternative GW-4
Enhanced
Bioremediation
Enhanced biological
treatment will be used
in conjunction with
groundwater controls
to prevent exposure
and obtain objectives.
Enhanced biological
treatment can be
difficult to manage,
and its success hard
to estimate.
Alternative GW-5
Monitored
Natural
Attenuation
Institutional controls,
if enforced, would
adequately prevent
ingestion of
contaminated
groundwater.
Institutional controls
are reliable as long as
they are enforced.
Alternative GW-6
Thermal
Desorption
Thermal treatment
provides adequate
controls to prevent
exposure and obtain
objectives.
Reliability of
technology will be
determined from other
projects where it has
been applied.
Reduction Mobility, Toxicity, or Volume
Treatment process No treatment occurs. No treatment occurs.
and remedy
Amount of hazardous No contaminants No contaminants
material treated or would be treated. would be treated.
destroyed Natural biological Natural biological
mechanisms may mechanisms may
destroy some destroy some
hazardous
materials. hazardous materials.
Groundwater
contamination would
be captured and
treated by air
stripping followed by
carbon adsorption.
Contaminants would
be destroyed during
vapor treatment or
carbon regeneration.
Approximately 9.5
billion gallons of
contaminated
groundwater would
be treated.
Groundwater
contaminants would
be biologically
degraded in situ
yielding natural by-
products.
Approximately 950
pounds of
contaminants in
groundwater would
be destroyed by
enhanced natural
mechanisms.
Groundwater
contaminants would
be naturally degraded
in situ yielding natural
by-products.
Approximately 950
pounds (Table 2-6) of
contaminants in
groundwater would
be destroyed by
natural mechanisms.
Groundwater
contamination would
be captured and
treated by air
stripping. Residual
COCs sorbed to
aquifer soil would be
thermally treated.
Approximately 13
billion gallons of
contaminated ground-
water would be
treated.
-------
Table 2-7 (Continued)
Summary of Evaluation of Groundwater Remedial Alternatives
Alternative
Reduction oftoxicity,
mobility, or volume
through treatment
Irreversibility of
treatment
Type and quantity of
treatment residuals.
Alternative GW-1
No Action
No reduction through
treatment, relies on
natural processes to
reduce toxicity,
mobility, and volume.
No treatment occurs.
No treatment
residuals would be
generated.
Alternative GW-2
Monitoring and
Institutional
Controls
No reduction through
treatment relics on
natural processes to
reduce toxicity
mobility and volume.
No treatment occurs.
No treatment
residuals would be
generated.
Alternative GW-3
Air Sparging
Toxicity, mobility, and
volume of
contamination would
be reduced through
treatment.
Off-gas treatment by
carbon is irreversible
if thermally
regenerated.
Treatment effluent
would be re-injected
into the aquifer from
which it was
extracted.
Alternative GW-4
Enhanced
Bioremediation
Toxicity, mobility, and
volume of
contamination would
be reduced through
treatment.
Biological treatment is
irreversible.
No treatment
residuals would be
generated.
Alternative GW-5
Monitored
Natural
Attenuation
Toxicity, mobility, and
volume of
contamination would
be reduced by natural
mechanisms.
Biotic treatment is
irreversible.
No treatment
residuals would be
generated.
Alternative GW-6
Thermal
Desorption
Toxicity, mobility, and
volume of
contamination would
be reduced through
treatment.
Thermal desorption is
permanent and
irreversible.
Air residuals would be
destroyed.
Short-Term Effectiveness
Protection of
community during
remedial action
Protection of workers
during remedial action
Environmental effects
No impacts on the
public would be
anticipated.
No construction would
occur.
No environmental
effects expected.
No impacts on the
public would be
anticipated.
Workers would follow
an approved health
and safety plan during
monitoring.
No environmental
effects expected.
No impacts on the
public would be
anticipated.
Potential exposure
during O&M.
Workers would follow
health and safety plan
during construction.
Some disturbance of
existing vegetation
would be necessary
to implement this
alternative.
No impacts on the
public would be
anticipated.
Workers would follow
an approved health
and safety plan during
implementation of
remedial action.
Some disturbance of
existing vegetation
would be necessary
to implement this
alternative.
No impacts on the
public would be
anticipated.
No construction would
occur. Workers would
follow an approved
health and safety plan
during monitoring.
No environmental
effects expected.
Potential minor
impacts on the
community from noise
during installation of
thermal wells.
Minor risk during
installation of thermal
wells. Health and
safety plan required
for installation.
Significant
environmental effects
from site preparation
and construction of
thermal wells.
-------
Table 2-7 (Continued)
Summary of Evaluation of Groundwater Remedial Alternatives
Alternati
Alternative No A
Time needed to Immediate
construct/implement
Time until remedial 30+ years.
action objectives and
action levels are
achieved
Alternative GW-2
Monitoring and
ve GW-1 Institutional
ction Controls
Immediate
30+ years
Alternative GW-3
Air Sparging
2 years to construct/
1 0 years of operation
20 years
Alternative GW-4
Enhanced
Bioremediation
1 year construct/
10+ years of repeat
treatments
10+ years
Alternative GW-5
Monitored
Natural
Attenuation
Immediate
30+ years
Alternative GW-6
Thermal
Desorption
2 years
50 years
Implementability
Availability of No technology No technology
technology required. required.
Reliability of No technology Depends on
technology required. enforcement and
monitoring.
Availability of None required. None required.
treatment, storage,
and disposal services
for groundwater or
treatment materials
Monitoring No monitoring would Sampling and
considerations occur. analysis to monitor
extent of
contamination and
compliance with
ARARs.
Readily available and
widely used.
Technology is highly
reliable, although
extraction sometimes
may not reach
desired remedial
endpoints.
No offsite
groundwater disposal.
Facilities are available
to treat spent carbon
and filter cartridges.
Sampling and
analysis to evaluate
progress of cleanup.
Air monitoring of the
vapor treatment
system.
Readily available, but
not widely used.
Technology is
reliable, however
achieving a uniform
distribution of
nutrients is
sometimes difficult.
No offsite
groundwater disposal.
Facilities are available
for disposal of
residuals.
Sampling and
analysis to evaluate
progress of cleanup.
Readily available and
widely used.
Technology is reliable
if subsurface
conditions are
appropriate.
None required.
Sampling and
analysis to evaluate
progress of natural
degradation.
Technology is only
available through a
select number of
vendors.
Technology is
reliable, but
dependent on
electrical capacity.
None required.
Sampling and
analysis to verify
attainment of RAOs
for groundwater.
-------
Table 2-7 (Continued)
Summary of Evaluation of Groundwater Remedial Alternatives
Alternative
Alternative GW-1
No Action
Alternative GW-2
Monitoring and
Institutional
Controls
Alternative GW-3
Air Sparging
Alternative GW-4
Enhanced
Biore mediation
Alternative GW-5
Monitored
Natural Attenuation
Alternative GW-6
Thermal Desorption
Estimated Cost
Total present worth
(including
contingency)
For additional cost
information see Final
Draft FS (HLA,
2000c).
None
PSC1: $1,828,000
PSC 3: $1,719,000
PSC 4: $1,419,000
PSC 26: $1,865,000
DMA: $5,212,000
PSC 3: $9,515,000
DMA: $6,012,000
PSC 1: $2,445,000
PSC 3:$2,663,000 U
$3,532,000 L
PSC 4: $2,632,000
PSC 26: $3,173,000
DMA: $7,365,000 U
$2,760,000 L
PSC1: $1,931,000
PSC 3:$1, 826,000 U
$1,968,0001
PSC 4: $1,537,000
PSC 26:$1, 968,000
DMA: $5,240,000 U
$1,838,0001
PSC1:$33,050,000
PSC 3: 43,803,000
PSC 26:50,947,000
DMA: 133,203,000
ARARs = applicable or relevant and appropriate requirements
COC = chemical of concern
O&M = operations and maintenance
RAO = remedial action objective
PSC = potential source of contamination
U = upper water bearing zone
L = lower water bearing zone
-------
Threshold Criteria. The USEPA has designated two threshold criteria: 1) overall protection
of human health and the environment and 2) compliance with ARARs.
Primary Balancing Criteria. The five primary balancing criteria are: 1) long-term
effectiveness and permanence; 2) reduction in toxicity, mobility, or volume through
treatment; 3) short-term effectiveness; 4) implementability; and 5) cost. Of the five criteria,
SARA emphasizes the importance of long-term effectiveness and reduction of toxicity,
mobility, or volume through treatment. Balancing provides an assessment of the maximum
extent to which permanent solutions and treatment can be used in a practicable and cost-
effective manner. The alternative that is protective of human health and the environment, is
in compliance with ARARs, and provides the best combination of balancing criteria
evaluations is identified as the preferred alternative.
Modifying Criteria. State and community acceptance are modifying criteria that influence
the remedial technology and the extent of permanent solutions and treatment practicable for
the site. State concerns were factored into selection of the proposed remedy during the
development of the proposed plan. Community concerns were factored into the remedy
selection process during the public comment period on the proposed plan. Section 3
contains a summary and responses to comments from the community on the proposed plan.
Source Control
Table 2-8 presents a summary of the comparative analysis of source control remedial
alternatives.
Overall Protection of Human Health and the Environment. Alternatives SC-1 and SC-3
will prevent leaching of contaminants to the groundwater. Alternative SC-2 is protective of
human health and the environment because all landfill materials are removed and
transferred to a lined and permitted facility. Alternative SC-4 thermally destroys
contaminants in the subsurface soil and reduces any leaching of contaminants contributing
to groundwater contamination, thereby reducing risks posed to human receptors.
Compliance with ARARs. All alternatives are anticipated to achieve compliance with ARARs
identified for OU 6.
Long-Term Effectiveness and Permanence. Alternatives SC-2 and SC-4 provide the best
long-term and permanent solution for meeting RAOs. Excavating the contaminant source
material effectively removes the source of groundwater contamination. Thermal treatment
of the source areas will destroy organic contaminants and permanently eliminate any
leaching in the subsurface soil. Alternatives SC-1 and SC-3 offer a long-term solution so long
as the cap, which requires annual O&M activities, remains intact.
Reduction of Toxicity, Mobility, or Volume. Alternatives SC-2 and SC-4 reduce the
volume, mobility, and toxicity of COCs in each of the source areas at OU 6. Alternatives SC-
1 and SC-3 do not use any treatment technologies that will reduce the volume or toxicity of
COCs in the subsurface, but will limit the mobility of contaminants leaching into the
groundwater.
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Table 2-8
Comparative Analysis of Source Control Alternatives
Plume Area
NPA and PSC 4
SC-1
Landfill Cap
Source Control
Organics No
destroyed?
Inorganics No
destroyed?
Estimated time to 1
implement (years)
Volume reduced? No
Toxicity reduced? No
Mobility reduced? Yes
Remedy Yes
permanent?
Treatment of Residuals
Organics destroyed No
on site?
Organics destroyed No
off site?
SC-2
Excavation
and Off-Site
Management
No
No
1
No
No
Yes
Yes
No
No
SC-3
Evapotranspiration
Cap
No
No
2
No
No
Yes
Yes
No
No
SC-4
In Situ Thermal
Desorption
DMA
SC-5
Source
Control
Yes No
No No
5 1
Yes No
Yes No
Yes Yes
Yes Yes
Yes No
No No
Contaminants Released/Remaining in Environment
Organic Yes
Inorganic Yes
No
No
Yes
Yes
No Yes
Yes Yes
Estimated Cost
Present Worth
PSC 1
$621, 00(
PSC 3
$1,616,00(
PSC 4
$537,00(
PSC 26
$5,414,00(
SC = source control
PSC 1
$6,200,00
$2,770,00
PSC 3
$21,550,00
$9,460,00
PSC 4
$7,255,00
$3,172,00
PSC 26
$76,031,00
$32,702,00
PSC 1
$145,000
PSC 3
$488,000
PSC 4
$182,000
PSC 26
$1,437,000
PSC1
$6,417,000
PSC 3
$20,122,000
PSC 4
$6,588,000
PSC 26
$71,651,000
DMA
$10,691,000
PSC = potential source of contamination
C = Subtitle C landfill
D = Subtitle D landfill
DMA = Depot Maintenance Activity
NPA = Northern Plume Area
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2-41
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Short-Term Effectiveness. Some exposure to on-site workers could occur during
implementation activities of Alternatives SC-2 and SC-4. Risks associated with exposure are
expected to be minimal and are easily addressed with a site health and safety plan. All
alternatives would provide an immediate reduction in contaminant mobility.
Implementability. Alternative SC-2 would be more difficult to implement than Alternatives
SC-1 or SC-3 because of the site preparation tasks required prior to excavation. Alternative
SC-4 also requires extensive site preparation tasks, and installation of thermal wells makes
the technology more difficult to implement than the others. Implementation of SC-3 would
be fairly easy once species of plants suitable for each site are determined. Alternative SC-1
includes only a landfill cap, the components of which are readily available from a variety of
contractors.
Cost. The overall cost of Alternative SC-4 is significantly higher than the other three
alternatives. The thermal desorption technology has extensive site preparation costs and
implementation costs. Alternative SC-2 is more expensive than Alternatives SC-1 and SC-3
due to the costs associated with removal and disposal of hazardous waste. The least
expensive alternative, SC-3, requires less capital and has a lower O&M component than
SC-1.
Institutional controls were selected for PSCs 3 and 26 and the no action response was
selected for PSC 1 in the ROD for OU 1 (ABB-1997a). Land use restrictions were
implemented at PSCs 3 and 26 because the human health and ecological risk assessment for
OU 1 (ABB-ES, 1995) determined that exposure to surface soil, subsurface soil, surface water
and sediment pose an unacceptable risk according to USEPA Region IV for existing or
potential future exposure scenarios. Land use control implementation plans for PSCs 1 and
3 were included in the ROD for OU 1 (ABB-ES, 1997a). Under the no actions response for
PSCs 1 and 2, treatment, containment, and restricted access are not required for PSCs 1 and
2 to protect human health and the environment.
A land use control plan was not selected for the DMA in the ROD for OU 3 (ABB-ES, 1997b),
because the total excess lifetime cancer risk associated with current and future exposure was
within the range specified as acceptable by USEPA. However, for future residential land
use, the estimated noncancer risk was 5 (USEPA limit is 1). An implementation plan to
control future land use was not selected because the DMA is industrial and is expected to
remain industrial in the foreseeable future (ABB-ES, 1997b).
At PSC 4 surface and subsurface soil contain polynuclear aromatic hydrocarbons
(benzo(a)anthracene, dibenzo(a,h)anthracene, benzo(b)fluoranthene, benzo(a)pyrene, and
indeno(l,2,3-cd)pyrene), a pesticide (dieldrin), and a metal (arsenic) at concentrations that
exceed their respective residential CERCLA soil screening levels. This ROD for OU 6
contains a land use control implementation plan for PSC 4 in Appendix A.
Groundwater Remedies
Below a comparison is made between groundwater remedial alternatives with respect to the
two threshold criteria: overall protection of human health and the environment, and
compliance with ARARs. Table 2-9 summarizes the comparative analysis of groundwater
remedial alternatives.
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Table 2-9
Comparative Analysis of Groundwater Remedial Alternatives
Alternative
GW-1
No Action
GW-2
Monitoring and
Institutional Controls
GW-3
Air Sparging
GW-4
Enhanced
Biore mediation
GW-5
Monitored Natural
Attenuation
GW-6
Thermal Desorption
Groundwater Remediation
Organics destroyed?
Inorganics removed?
Estimated time to achieve
action levels (years).
Contaminants contained?
Exposure pathways
eliminated?
Remedy permanent?
Uncertainty of attaining
action levels.
No
No
30+
No
No
No
High
Yes
No
30+
No
Yes
Yes
Moderate
Yes
Yes
20
Yes
Yes
Yes
Low
Yes
No
10
Yes
Yes
Yes
Moderate
Yes
No
30+
Yes
Yes
Yes
Moderate
Yes
Yes
50
Yes
Yes
Yes
Low
Treatment of Residuals
Organics destroyed in situ
Organics destroyed ex situ
Yes
No
Yes
No
No
Yes
Yes
No
Yes
No
Yes
Yes
Contaminants Released/Remaining in Environment
Organic
Inorganic
Yes
Yes
Yes
Yes
No
No
No
Yes
No
Yes
No
No
Estimated Cost
Present Worth
None
PSC1: $1,828,000
PSC 3: $1,719,000
PSC 4: $1,419,000
PSC 26: $1,865,000
DMA: $5,212,000
PSC 3: $9,515,0001
DMA: $6,012,0001
PSC 1: $2,445,000 U
PSC 3: $2,663,000 U
$3,532,000 L
PSC 4: $2,632,000 U
PSC26:$3,173,OOOU
DMA: $7,365,000 U
$2,760,000 L
PSC 1: $1,931, 000 U
PSC 3: $1, 826,000 U
$1,968,0001
PSC 4: $1. 537,000 U
PSC 26: $1, 968,000 U
DMA: $5,240,000 U
$1,838,0001
PSC1: $33,050,000
PSC 3: $43,803,000
PSC 26: $50,947,000
DMA: $133,203,000
PSC = potential source of contamination
DMA = Depot Maintenance Activity
U = upper water bearing zone
L = lower water bearing zone
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Protection of Human Health and the Environment. All alternatives provide at least a
minimum standard of protection to human health and the environment, with the exception
of GW-1, the No-Action alternative, which does not involve any deed restriction or action to
remove or treat COCs at any of the OU 6 plume areas. Alternatives GW-2, GW-4, and GW-5
would prevent exposure to COCs through implementation of deed restrictions to prohibit
installation of groundwater supply wells within the affected areas. Groundwater extraction
and treatment, alternative GW-3 and a component of GW-6, effectively removes and treats
COCs in the groundwater, thereby providing protection of human health and the
environment.
Compliance with ARARs. Alternative GW-1 would not comply with ARARs identified for
OU 6. All other alternatives are anticipated to achieve compliance with ARARs.
Long-Term Effectiveness and Permanence. No active treatment is implemented under
alternatives GW-1, GW-2, and GW-5. Human risks would remain over a period of several
decades until concentrations of COCs were naturally reduced. Alternatives GW-3, GW-4,
and GW-6 offer a long-term and permanent remedy for groundwater contamination. COCs
would be actively treated under all three remedial technologies.
Reduction of Toxicity, Mobility, or Volume. Alternatives GW-1, GW-2, and GW-5 do not
employ any technologies that reduce the toxicity, mobility, or volume of COCs in the
groundwater at OU 6. These alternatives rely on MNA mechanisms to reduce
concentrations of COCs over time. Alternatives GW-3 and GW-6 will reduce the toxicity,
mobility, and volume of COCs in the groundwater through treatment. Alternative GW-4
would accelerate the natural degradation of COCs, which would reduce contaminant
toxicity, mobility, and volume.
Short-Term Effectiveness. Human health risks in the short term would not be reduced
under alternatives GW-1, GW-2, and GW-5. Alternatives GW-2 and GW-5 rely on exposure
control through deed restrictions to comply with RAOs in the short-term. Worker exposure
during installation of the treatment system under alternatives GW-3 and GW-6 is expected
to be minimal and would be addressed in a site health and safety plan. Alternative GW-4
does not pose a threat to workers because remedial activities are limited to well installation,
which would also be addressed with a site health and safety plan.
Implementability. Alternative GW-1 can be readily implemented because no special
concerns would need to be addressed at any of the OU 6 contaminant plume areas.
Alternatives GW-2 and GW-5 use the minor remedial activities of institutional controls, site
monitoring, and five-year site reviews, which are easily implemented; though
administratively tasking. Alternatives GW-3 and GW-4 are easy to implement but take
longer due to well installation activities. Of all the technologies considered, alternative GW-
6 is the most difficult to implement because it is only available through a select number of
vendors, and it involves intensive site preparation and construction activities.
Cost. There is no cost associated with alternative GW-1 because no remedial measures are
conducted. Alternatives GW-2 and GW-5 would be the least expensive alternatives of the
five that have costs associated with them. Alternative GW-3 is expensive due to the number
of extraction wells that would need to be installed to effectively remove the volume of
groundwater required to remediate the LWBZ aquifer. Installation of injection wells raises
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the cost of applying alternative GW-4 to the contaminant plume areas at OU 6. In
comparison with alternative GW-5, alternative GW-4 is considerably more expensive.
Alternative GW-6 is the most expensive alternative of those considered for groundwater
remedies at OU 6. The intensive site preparation and construction activities associated with
the technology, in addition to the installation of large electrical supplies, make it extremely
expensive to apply at OU 6.
2.11 Description of Selected Remedy
The following sections describe the response actions selected for source areas and the
UWBZ and LWBZ groundwater at the NPA, DMA and PSC 4. The estimated costs of the
selected remedies are presented in Table 2-10.
TABLE 2-10
Estimated Costs of Selected Remedial Responses
Northern
Source
UWBZ
LWBZ
Potential
Source
UWBZ
LWBZ
Location Primary Remedy
Plume Area
Evapotranspiration Cap
Enhanced Bioremediation
Monitored Natural Attenuation
Source of Contamination 4 Area
Soil Cover
Land Use Controls
Monitored Natural Attenuation
Monitoring
Cost (M $) Total (M $)
7.0
8.3
3.8
Subtotal $19
0.54
1.5
Subtotal $2
Depot Maintenance Activity Area
Source
UWBZ
LWBZ
Inspect and repair floor drains
and pavement
Enhanced Bioremediation
Monitored Natural Attenuation
10.7
8.1
1.8
Subtotal $21
Total Cost $42 M
UWBZ = Upper Water Bearing Zone
LBBZ = Lower Water Bearing Zone
Source Control
The objective of the response actions for the sources at the NPA and DMA is to reduce the
mobility of the contaminants. By reducing the flow of water through the overburden,
contaminants will be isolated above the water table, and will not migrate to groundwater.
The primary remedy to achieve this objective at the NPA is an ET cap. Should the ET cap
not meet its performance criteria (Table 2-1) (as measured by achieving an infiltration rate
that is less than or equal to IxlO5 centimeters per second), the contingency remedy is to
construct a traditional clay cap. The ET cap must be implemented within 3 years of signing
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the ROD for OU 6. Evaluation of the ET cap will be conducted during the CERCLA 5-year
review.
The primary remedy at DMA consists of characterization of potential source areas within
the DMA and control of these sources with an appropriately designed cap. This remedy
includes identification of sub-floor pipelines, testing of sub-floor piping for leaks, and
investigating subsurface soil in areas with confirmed releases. This will be followed by
remedial design to isolate confirmed sources from infiltration, and remedial response.
Normal institutional controls, site monitoring, and 5-year site reviews will follow
implementation of the remedial design. The 5-year reviews would consist of evaluating
monitoring data and assessing changes in site conditions (e.g., construction, demolition,
receptors, migration pathways, and qualitative risks). The appropriateness of the remedial
approach would be compared to other potential remedial alternatives for the site. After
5 years, if data indicate that the response action did not achieve prescribed performance
goals, more aggressive measures may be considered, including sealing all floor drains, and
replacing sub-grade wastewater pipelines with aboveground piping.
The overall goal of the remedial measures is to reduce the off-site concentrations of the
COCs to a concentration that is less than their respective Federal MCL in 10 years, and on-
site COC concentrations to less than their respective MCL in 20 years. Prior to conducting
the CERCLA 5-year review, a 3-year review will be conducted to assess the primary
remedies at the NPA, DMA, and PSC 4. The Three Year Review will be used to adjust site
monitoring requirements, make a determination as to whether or not the primary remedies
are meeting their Groundwater Remedial Goals and, determining whether or not the
contingency remedy needs to be implemented (Table 1-3).
Groundwater*
The objective of the response action for groundwater at the NPA and DMA is to reduce the
chemical concentrations in groundwater in the UFA to MCLs and/or risk-based standards
(Table 2-1). This same objective was established for the UWBZ at PSC 4. However, a
different objective was established for the LWBZ at PSC 4. The latter objective is to confirm
that chemical concentrations in groundwater remain below MCLs and/or risk-based
standards. This objective was established because of the potential for chemicals in the
UWBZ to migrate to the LWBZ, and because chemicals of concern were not detected in the
LWBZ during characterization studies.
The primary remedy selected for the UWBZ at the NPA and DMA is enhanced
bioremediation. Enhanced bioremediation may be implemented by injecting chemicals into
the UWBZ that accelerate natural biological actions to degrade the cVOCs. The injected
chemicals induce anaerobic conditions and provide nutrients to bacteria so that reductive
dechlorination of the cVOCs proceeds at a faster rate. Because of potentially adverse site
conditions, this technology may not achieve the three-year remedial goals in Table 1-3. If
enhanced bioremediation cannot meet the three-year remedial goals in Table 2-1, other in
situ remedies would be implemented to supplement the primary remedy. In situ
If the concentrations of COCs in the UWBZ groundwater at any PSC do not meet remedial
goals, then enhanced bioremediation will be used as the default remedy.
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technologies that rely on abiotic chemical processes would be used at DMA and/or NPA, as
needed. If, after 3 years of implementing additional in situ technologies, the goal of 50% per
cent reduction in cVOC concentrations in source areas cannot be achieved, then the
contingency remedy (i.e., conventional pumping and ex situ treatment) will be initiated.
The primary remedy selected for the UWBZ at PSC 4 is MNA. Groundwater monitoring will
be done at PSC 4 to determine that MNA is controlling the extent of the groundwater plume
and is reducing contaminant concentrations inside the plume. If, after 3 years of monitoring,
MNA has not controlled the plume or reduced the contaminant concentrations, then
enhanced bioremediation will be implemented. As previously stated, this may also result in
implementation of an ET cap or traditional clay cap over the source area.
The primary remedy selected for the LWBZ at the NPA and DMA is MNA. The
implementation of enhanced bioremediation in the UWBZ should reduce the concentration
of cVOCs that migrate to the LWBZ, thereby, meeting the remedial action objective. The
contingency remedy selected for the LWBZ is conventional pumping and ex situ treatment.
No remedial response has not been developed for the LWBZ at PSC 4 because contaminants
do not currently exceed MCLs or risk-based standards. Groundwater monitoring will be
conducted in the LWBZ at PSC 4 to confirm that chemical concentrations remain below
MCLs and/or risk-based standards. If the concentration of COCs in the LWBZ exceed
MCLs, then enhanced bioremediation will be implemented in the UWBZ.
The Interim Corrective Measure at PSC 3 has been discontinued because the system has not
met the goal of hydraulic containment, and continued operation may interfere with the
pilot-scale technology demonstration being conducted (CH2M HILL, 2000).
During the preparation of the RI/BRA for OU 6 (HLA, 2000a), several data gaps were
identified that would support a more effective remedial design. The following data gaps
will be completed as part of the response action:
• Delineation of carbon tetrachloride in the UWBZ southwest, west and northwest of
PSC 26
. Delineation of TCE and carbon tetrachloride in the LWBZ northwest of PSC 3 LWBZ
• Continued monitoring of the UWBZ and LWBZ water quality to confirm that the
groundwater plumes are stable and the COCs are naturally attenuating
2.12 Statutory Determinations
The response actions selected in this ROD are necessary to protect human health and the
environment from actual or threatened release(s) of the COCs from the site. The final response
actions selected for OU 6 are protective of human health and the environment, comply with
Federal and State requirements that are legally applicable or relevant and appropriate to the
remedial actions, apply one or more treatment technology as a principal element of the
selected remedy(s), and are cost-effective. The selected remedies use permanent solutions and
contingency treatment technologies to the maximum extent practicable for this site. Because
these remedies will result in hazardous substances remaining onsite above health-based
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levels, a review will be conducted within 5 years to ensure that the remedies continue to
provide adequate protection of human health and the environment.
2.13 Explanation of Significant Changes
As the lead agency, SOUTHNAVFACENGCOM prepared and issued the Proposed Plan for
OU 6 on May 11, 2000 (HLA, 2000). The Proposed Plan (HLA, 2000) described the rationale
for a final remedial response for groundwater at OU 6, and Institutional Controls at PSC 4.
No significant changes were made to the Proposed Plan. The GEPD and USEPA Region IV
concurred with the final remedial response. The public has been offered the opportunity to
comment on the Proposed Plan. All public comments were considered and addressed as
fully as possible in completion of this ROD. The effectiveness of the response actions will be
evaluated at 5-year intervals, and new or additional responses will be implemented if
conditions at OU 6 indicate an unacceptable risk to public health or the environment has
developed.
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3.0 Responsiveness Summary
3.1 Overview
Based on the results of the Remedial Investigation and Baseline Risk Assessment, Southern
Division, Naval Facilities Engineering Command (SOUTHNAVFACENGCOM)
recommended a response action for the groundwater associated with Operable Unit (OU) 6.
SOUTHNAVFACENGCOM's recommended alternatives consisted of Source Control,
Groundwater Remedies, and Land-Use Controls (LUCs) at PSC 4.
Following the 45-day public comment period, the extension of the comment period to
August 30, 2000, and the Public Meeting held on the evening of Thursday, June 1, 2000, on
the OU 6 Proposed Plan, this responsiveness summary was prepared to summarize public
comments and provide written responses. This responsiveness summary includes:
• Background on Community Involvement
• Summary of Comments Received During the Public Comment Period and Agency
Responses
Part I: Summary and Response to Local Community Concerns
Part II: Comprehensive Response to Specific Legal and Technical Questions
3.2 Background on Community Involvement
An active community relations program providing information and soliciting input has
been conducted by MCLB Albany for the entire NPL site. Interviews of citizens on Base and
in the city of Albany were conducted in the Winter of 1990 to identify community concerns.
No significant concerns that required focused response were identified. Most comments
received were concerning the potential for contamination of water resources. However,
those interviewed indicated that they place great trust in MCLB Albany and their efforts to
rectify past waste disposal practice.
In addition, the Base formed a Technical Review Committee (TRC) that included members
representing the city of Albany, Dougherty County, and the local academic and private
community. The TRC community members were contacted in July 1996 to determine their
continued interest in serving in serving on the committee. Each member confirmed his or
her interest in serving on the TRC. In addition, parties on the MCLB Albany Environmental
Branch mailing list were contacted to solicit new community members for the TRC. Since
September 1996, the MCLB Albany Environmental Branch has held several meetings with
the TRC to update them on the status of the investigation, remediation, and closure of the 26
PSCs. The local media have also been kept informed since MCLB Albany was placed on the
NPL. Installation Restoration Program fact sheets have been prepared and made available at
the Environmental Office of MCLB Albany. Documents concerning OU 6 are located in the
Information Repository at Dougherty County Public Library and the Administrative Record
File at the Base Environmental Branch office. The TRC was dissolved in 2000. The
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MCLB Albany Environmental Branch staff continues to respond to inquiries from the
public.
3.3 Public Comments and Responses
The public comment period on the final Proposed Plan for OU 6 was held from May 22 to
July 6, 2000, and extended through August 30, 2000. This includes a Public Meeting that was
held on the evening of Thursday, June I, 2000. Minutes from the June 1 meeting are
provided below. Comments received during the entire comment period are summarized
below. Part I of this section addresses community concerns and comments that are non-
technical in nature. Comprehensive responses to regulatory and technical comments and
questions are provided in Part II. Comments in each Part are categorized by relevant topics.
Responses to public comments are presented following each comment. Responses have not
been prepared for every comment received. Rather, individual public comments have been
organized into subject areas, and responses have been prepared for each subject. This
approach is consistent with USEPA guidance for preparing Responsiveness Summaries as
described in the USEPA's Community Relations in Superfund: A Handbook (1992).
PART I - SUMMARY AND RESPONSE TO LOCAL COMMUNITY CONCERN
Public Meeting Held June 1,2000
Proposed Plan for Operable Unit 6
Major Tony Ference: Good evening, ladies and gentlemen. On behalf of Colonel Cole, the
Commanding Officer, Marine Corps Logistics Base, I want to welcome you to tonight's
public meeting on the Operable Unit 6 Groundwater Proposed Plan. My name is Major
Tony Ference. I am the Installation Restoration Program Manger. I manage the
environmental investigation and cleanup of sites aboard the Base.
A few admin notes before we begin. If you haven't had an opportunity to sign up on the
sign in sheet, I would ask that you please do that when we take a break, and also, if anyone
has not gotten a public comment form to write down your comments, if you want to submit
a written comment. Please raise your hand if you want one. Mr. Joe Daniel will pass it on
across, as well as pencils if you need one.
The primary objectives for tonight's meeting: I'd like to present a project overview of the
Operable Unit 6 groundwater project; then move on and present the proposed actions for
the groundwater cleanup, and then finally, the most important part of this meeting, and
primary purpose of this meeting, receive community concerns and input on the Proposed
Plan. As an agenda, I'll cover the process overview. What process do we follow at MCLB
Albany when we investigate the cleanup site. I'd like to cover that briefly. Once I've covered
that, I'd like to give you an overview of our background, investigation, and risk assessment
into the groundwater beneath the Base, cover feasibility study, the Proposed Plan, and then
again open up for questions and receive your community comments. I'll try to address as
many questions as I can and then once we finish the formal portion of the meeting, we have
a recorder here; we are recording the formal portion of the meeting, which will be the
presentation and question and answer period, so we make sure that we capture the
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comments so they are put into the official record; once we've finished that, I'd like to break
back out and all of us will be available and standing by and we're at your disposal until
you've had an opportunity to walk around, take a look at the posters, and get your
questions answered; and that's how I'd like to end the meeting.
Because the primary focus is to get the community comments, I do want to mention that
besides doing the question and answer period, I'm not the subject matter expert on all of
these different topics. There are different topics around the room and that's where the real
meat and potatoes of tonight's information is. And the subject matter experts, the folks who
have done the investigation, the regulators, the geologists, they'll be back there to answer
your questions. If you don't get an opportunity to state your comment verbally, please feel
free to submit it in writing by mail or drop it here so it gets put into the official record for
the groundwater investigation and groundwater project.
With that said, why don't I cover the process that we cover when we investigate sites
aboard the Base? The first thing we need to do is identify areas of potential concern. We
then go investigate these areas and determine if there are any site-related contaminants
present. That's accomplished in the remedial investigation. If we do have site-related
contaminants present, what type of risks do they pose to human health and the
environment. We estimate these risks with a base-line risk assessment and compare the risk
number to regulatory numbers to determine, do we have real risks here? Do we need to take
action and have a cleanup? If the risks exceed these regulatory thresholds, then we need to
evaluate cleanup options and that's accomplished in the feasibility study. Once we've
evaluated different options, we may select a remedy or a group of remedies for different
sites. We're going to outline the proposed remedy in the Proposed Plan and publish that
plan for public review. And that plan is currently out in the library, I believe on the second
floor in the reference section, for public review. Then the regulatory requirements are to
have a 30-day public comment period. We at Albany have a 45-day period, it started 22 May
and ends 6 July. Hold a public meeting; that's what we're here for tonight. Address the
public comments. Possibly modify the remedy that was outlined in the Proposed Plan. Keep
in mind this is a Proposed Plan and it's important that we get your comments on that.
Address the public comments, sign the record of decision deciding upon a remedy and then
move forward with implementing the cleanup; take the cleanup action that you outlined.
With that said, I'd like to first cover the areas of concern, the investigation, and the risk
assessment for groundwater. Operable Unit 6 was established in 1996 to investigate and
address Base-wide groundwater. Previous to 1996, groundwater was investigated along
with surface and subsurface soil of the different sites around the Base. The regulators and
the project team got together and they said, how can we put false boundaries on
groundwater and say that this groundwater's from this particular site, this one's from this
site; it's all interconnected. We need to treat it as such and come up with an investigation for
all the groundwater, and also remedies for the groundwater for the Base as a whole and
implement those. And so that's when it—Operable Unit 6 was established. 1996. The
investigation into the groundwater across the Base identified three main areas of
groundwater contamination: the Northern Plume area, the Depot Maintenance Activity
area, also referred to as the Maintenance Center, that's our main industrial portion of the
Base, and the Warehouse Disposal Area, which I may also refer to as Potential Source of
Contamination 4.
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The investigation discovered we have three main zones beneath our feet. The line at the
very top represents the surface of MCLB Albany. Beneath our feet when we're standing on
Albany, we have approximately 50 feet of clay, red clay, that we refer to as the overburden.
At the bottom of that begins the water table and the water, the groundwater included in the
aquifer. The groundwater flows in two different zones, an upper water bearing zone and a
lower water bearing zone. The upper zone is a tight, chalky lime mud that holds water, but
water doesn't move through it very readily. Whereas the lower water bearing zone is more
of a solid limestone with tunnels and channels cut through it by flowing water and those
tunnels and caverns allow water to flow through.
The first thing the investigation discovered is we have three main contaminant source areas;
areas within the overburden that I mentioned that hold chemicals that may be going down
through the ground and making it into groundwater. The Northern Plume Area
encompasses three sites, the Depot Maintenance Activity encompasses three in the
Maintenance Center area, and then potential source of contamination 4, that warehouse
disposal area. When we look at the - I need to take just a minute. [A poster was brought to
the front of the room.] Now that we've identified some sources, areas where there are
chemicals in that overburden that could get down into the groundwater, well, where do we
have groundwater contamination? This map represents results of groundwater tests for
both that upper zone and lower zone. My intention of this map is to identify any well,
whether it's upper zone or lower zone that has had detections of the chemicals that are
above the drinking level standards. In those areas, these blue blobs represent areas where
we've had detections, even if it was one time in one well, it became blue and was
incorporated into the blob, for lack of a better word. So we find that we have chemicals in
groundwater in those three areas: the Northern Plume Area, the Warehouse Disposal Area,
and the Maintenance Center or Depot Maintenance Activity Area. So we've investigated
sites and found three different zones beneath our feet. We found there are chemicals in that
overburden area in three different areas, and we found that there are chemical
concentrations in water. Well, as I mentioned earlier, if we found some site-related
contaminants, what type of risks do they pose. Those risks are estimated using a base-line
risk assessment. The primary purpose of the risk assessment is to estimate those risks and
determine whether or not cleanup is required. The results of our groundwater risk
assessment indicate that groundwater cleanup is needed. In summary, these reports, the
investigation and the risk assessment, they are included in one large report, these four
binders here.
The summary of that remedial investigation base-line risk assessment is outlined here. We
have three main source areas, as mentioned here, Northern Plume, the Warehouse Disposal
Area, and Depot Maintenance Activity and beneath those three sources, we have three areas
of groundwater contamination. And the results of the risk assessment indicate that we need
to take action. Clean-up action. If I go back to the overview, since the risk assessment
indicates we need to take clean-up action and we need to move forward and evaluate
different clean up options, and we do that with a feasibility study. The primary purpose of
the groundwater feasibility study is to evaluate cleanup options to make sure we select a
remedy. There are many, many options across the country. Some work in some areas and
some don't work in other areas. And so we want to select an effective remedy for Southwest
Georgia and for MCLB Albany. And that is the primary emphasis of this feasibility study -
evaluate options and select a good remedy.
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How do we do that? First we need to develop remedial action objectives for the remedies.
What exactly do we want these remedies to accomplish? We need to evaluate the
effectiveness of these different remedies at accomplishing these goals and meeting these
objectives. And finally evaluate the technologies using nine remedy selection criteria which
are outlined in the National Oil and Hazardous Substances Contingency Plan. And those
nine criteria are outlined in the back of the room if you want to look at them in detail.
First, we know we have chemicals in that overburden; those are our sources. We also know
we have chemicals in the groundwater. So we need to develop remedial action objectives for
both sources and groundwater. For the soil, we have to reduce the chemical mobility,
toxicity, volume in the overburden that causes groundwater to exceed the standard. What
does that mean to me? Stop the chemicals from being able to move from that overburden
area down into the groundwater. Let's turn off the faucet. The overburden is the source of
chemical contamination that is getting into the groundwater. We need to turn off the faucet
in the overburden. Groundwater—we need to reduce the concentrations to safe drinking
levels and reduce exposure to contaminants of concern that exceed the safe drinking water
standards.
The selection criteria outlined in the National Oil and Hazardous Substances Contingency
Plan are in three main groups. The threshold criteria; the primarily focus is to protect
human health and the environment and address whether or not [there are] remedial
regulatory requirements. The balancing criteria: how practical and cost effective are these
different remedies. And then finally the modifying criteria: what about the state and
community comments on the remedy. And that's the reason we're here tonight. What are
your concerns, what are your comments on the proposed remedies. That's in the modifying
criteria.
We jump back to the overview. We've conducted the investigation, the risk assessment. We
need to take action. We've evaluated different technologies. The feasibility study will point
you toward a set of technologies or a technology. So we now we need to outline the
proposed remedy and the Proposed Plan; that's been done, and conduct our public meeting
and outline for you all tonight our Proposed Plan.
With that we mentioned we have sources and we have groundwater contamination. So the
Proposed Plan must address the sources and the groundwater. Let's move to source control
first. The Northern Plume Area the primary problem is rainwater infiltrating through the
surface of the ground and carrying chemicals down into the upper water-bearing level. That
is that faucet; that is the tap of chemicals that can make it down into the groundwater. The
proposed remedy is construction of an evapotranspiration [FT] cap. An FT cap is a cover
with very rich soil over top of the landfill areas and that rich soil has a very high water
holding capacity. So water gets on to the surface and can soak into the soil and the soil holds
that water. On top of the soil is planted different plants to include high-water uptake—high
water drinking plants and trees. So we've got the soil that can hold a lot of water like a
sponge, and we've got the trees that will pump it out. We've got the holding capacity and
then the trees remove the water; and by doing that, you prevent the water from getting
through and into the landfill areas and carrying chemicals down into the groundwater.
For the DMA, the Maintenance Center. The Maintenance Center is partially covered in
concrete. That makes for a pretty good water barrier. We never did think that the water was
coming down through the DMA and hitting any landfill. The primary source of chemical
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and the primary source of water driving chemicals down are underground piping leaks. So
the proposed remedy is to stop that driver; that force of water carrying chemicals down into
the groundwater is to inspect the piping and repair the leaks beneath the DMA.
Move on to the warehouse disposal area. The primary concern there is human and animal
direct contact with chemicals at the surface soil. So what do we need to do? We need to cut
off the surface soil contact. The proposed remedy there is a soil cover for PSC4, warehouse
disposal area.
So just for source control: I'm talking about the primary proposed remedies just for source
control. We've got the tree cap for the Northern Plume Area, over the top of the landfill
cells. We have the leak repairs' inspection and leak repairs at the Depot Maintenance
Activity. We have the soil cover at the warehouse disposal area.
What about groundwater? That's fine and well, but what about groundwater? The primary
cleanup requirement for the groundwater is to reduce the concentration to safe levels. If
needed, we have identified contingency remedies that can further reduce chemical
concentrations in the event that what we've planned and what we think is going to be super
effective is not as effective as we had hoped. How do we propose to accomplish this
requirement; reduce the concentrations to safe levels? I'm going to take these by area.
In the Northern Plume areas, I mentioned the source control is evapotranspiration cap. We
cut off that faucet and prevent the chemicals from making it out of that overburden area
down into the groundwater. But then, we do have chemicals in the upper water bearing
zone. We are proposing enhanced bioremediation. And what we mean by that is the
injection of a time-release lactic acid compound called hydrogen release compound. That
lactic acid released into that groundwater zone, it induces the conditions necessary so that
the natural micro-organisms, bacteria, nature can eat up these chemicals and destroy them.
And that's what's done with the injection of a lactic acid compound. Now by treating that
upper water bearing zone which is the source to the lower water bearing zone, we're cutting
off that tap. We're destroying and helping nature destroy the chemicals in place in the
upper water bearing zone, and turning off, in turn, that faucet into the lower water bearing
zone. Plus some of that lactic acid can follow along and assist in the natural breakdown, the
natural attenuation within the lower zone. So then for the lower zone, we will start a
monitoring program to ensure the chemical concentrations are coming down, not rising,
and that plumes, areas that are impacted, are shrinking and not growing.
For the DMA, turn off that faucet with the leak repairs. Treat that upper water bearing zone
again with that in-situ, in-place enhanced bioremediation, lactic acid. Help nature destroy
the chemicals. And then monitor and make sure that the chemical concentrations are
coming down and not increasing.
Finally, for the warehouse disposal area, the soil cover is designed to prevent that surface
contact. The upper water bearing zone has very little concentration of chemicals and we are
going to do that monitor natural attenuation that I mentioned for the lower water bearing
zones for the other areas. And then we're proposing monitoring for the lower water bearing
zone to ensure that that lower zone beneath Potential Source of Contamination 4, that
Warehouse Disposal Area, stays safe to drink; that it still meets the Safe Drinking Water Act
standards. Which is what we have now based upon our test results.
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Okay, so what if for some reason the chemical concentrations start to increase, the plume
area starts to grow, or it's not decreasing at a rate that we want it to; and those specific rates
are going to be outlined with the regulators; that's still something that has to be worked out.
How much decrease do you need and in what time frame? If the tree cap is not working for
the Northern Plume Area, we'll go with the conventional—this is the backup plan;
conventional landfill cap, perhaps a compacted clay cover or a synthetic liner that covers [it]
to prevent that rainwater from getting into the soil and carrying chemicals. Then we look at
an ex-situ treatment for the upper zone and lower [zone]; and what I mean is removal of the
groundwater from the aquifer and treatment above ground.
For the DMA, if we have a similar problem, we'll look at sealing up those underground
pipes, instead of repairing them. [If] apparently that's not working, we need to seal the
drains and replace that below ground piping with above ground piping. And then ex-situ
treatment for the upper zone and lower zone.
Now the Warehouse Disposal Area, if for some reason that monitoring of the natural
attenuation in the upper zone and that monitoring of the drinking water standards that the
water's still safe in the lower zone, if that turns out to be where the chemicals are increasing,
then obviously the soil cover, which was not designed to prevent water infiltration, but
designed to prevent surface soil contact, that is obviously not going to be an effective
remedy to treat groundwater. We've identified a problem here, say. Then we will move on
the evapotranspiration cap, the tree cap, provided, of course, it's working in the other areas,
and then the enhanced bioremediation in the upper zone and continued monitoring in the
lower zone.
Before we get to the questions and answers, I'd like to just mention the four poster stations,
and we have all the folks here that have been in the investigation, feasibility study,
Proposed Plan, and risk assessment, and they'll be stationed around the different poster
stations. After the formal question and answer period, the recorded portion, I'll put up a list
here, the one that most of you have seen, where the different topics and the folks you may
want to ask pertaining to your specific question. But the four stations cover the background,
the investigation and risk assessment for the groundwater, feasibility study and remedial
action objectives, and then the Proposed Plan for both source control and for groundwater
cleanup. With that again, written comments [are] accepted through July 6. Feel free to leave
them tonight and mail them in. And what I'd like to do for the question and answer period
is to please keep it focused on the Operable Unit 6 groundwater Proposed Plan. If you have
other questions regarding other issues, I am available and so is everybody else after this. But
during the recorded portion, where we have the court recorder, we'd like to keep it focused
on the Proposed Plan and capturing your comments and trying to address your questions
on the groundwater Proposed Plan. With that said, yes, sir?
Mr. Waldorf: Where on that poster have you got that pond where you have kids fish once a
year, where you stock it. Is that in the middle of all that contamination?
Major Ference: The question was, I'm going to repeat the question, because of the
recording. Okay.
Mr. Waldorf: I wanted to see where it was at, first. Was it part of that blue area where it's
contaminated?
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Major Ference: No, sir. The question was where is the pond? Of course, this Saturday,
we're having the buddy fish tournament for kids and is it included in the blue areas
identified as groundwater areas that have had chemicals above drinking water standards?
You see the blue areas here in the Northern Area, and then we've got the PSC 4, and then
we've got the Maintenance Center area, and the pond is located here. And, of course, these
are 50 feet to 300 feet deep, the blue areas.
Reporter: Major Ference, could you identify whose talking, please?
Major Ference: Oh, I'm sorry. If you don't mind, when you ask a question, please identify
yourself so we can get it captured for the recorder.
Ted Waldorf: Again, that same pond, I was out there four, five, six months ago and I
noticed all the way around that pond just about every tree is dead or dying and it caught
my attention pretty quick there. I just wondered if that water's really been checked. Because
I know kids fish out of there, you have those tournaments in that thing all the time, and I
don't know if it's ever been checked or not.
Major Ference: I will say this, I don't know about the testing. I haven't seen any dead trees;
but if we could, I'd like to discuss that afterwards. We can get with Mr. Kern. He knows a
little bit more.
Ted Waldorf: I thought that was part of it.
Major Ference: That's really considered surface water. Not that they're unconnected, or
disconnected; but I do want to focus on the plan if we can.
Sonya Gooden: You made reference to the overburden and the upper Floridan aquifer, I
think what Mr. Waldorf's main concern is that the findings of the PW1 located at the Base is
located in an entirely different aquifer, yet you found contaminations in it last—1999, so
what he is asking, I think, is something we would all like to know. You have spoken as if
there is a tight confined unit underneath each one of these unlined landfills or potential
sources of concern. How did you find tetrachloroethylene and dichloroethylene in your
PW1 well that is in the center of the Base and not right there where we're looking at right
now, along the northern boundary line.
Major Ference: That really, I would prefer to discuss that one afterwards because that's
not—I have a familiarity with what you're discussing. I know what you're talking about.
There's been a detection in one of our supply wells on Base which is screened in multiple
levels. So, in other words, we have reason to believe that that well has some screening,
further up. Although it is a very deep well, there are some screening areas higher up within
it, so in multiple zones. And we're looking at addressing that now. And we're sampling it.
But I'm not quite sure I follow the remainder of the question.
Sonya Gooden: All right, we're talking about the OU6, groundwater contamination. You
have not delineated how deep that contamination goes and I only use PW1 as an example,
that you are finding contamination on the Base in that deep well. Have you worked at
delineating horizontally and vertically in order to address the remediation process, but yet it
appears to us that you have a wide spread area in order to address and the proposal that
you're bringing to the table tonight is a very tight confined proposal dealing with just
specific concentrated areas. When you have how many billions of gallons of groundwater
out there in that area. My question is, I'm back to Mr. Waldorf's statement, we understand
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that the upper Floridan, the overburden, is contaminated. The lower Floridan is
contaminated and now even lower wells have been compromised. What you are bringing to
the table tonight in the Proposed Plan is putting lactic acid in the water; I mean, correct me
if I'm wrong so we'll all understand this; and you want to treat it in that manner, but yet in
all the reports that you've done on the pilot scale, feasibility studies, and the technical
memorandum, they failed miserably.
Major Ference: Different technology.
Sonya Gooden: Different technology. Do you want to explain that to us a little bit clearer
now?
Major Ference: If I understand your question, you're asking why are we proposing to inject
a lactic acid compound when we've done a pilot study in the past that shows that this is not
effective?
Sonya Gooden: Right.
Major Ference: I can't - Mr. Daniel can cover the pilot study that was done in the past, but it
was a completely different technology. Do you want to take that?
Joe Daniel: My name is Joe Daniel. I'd like to take a crack at that—I heard three different
parts. The first part is, why are we confining the remedies to the areas we show on this map
in blue. When we break out into the separate sessions, you'll be able to see in the monitoring
wells that we have surrounding each of these areas that are identified. Those are wells that
we have surrounding each one of these where the water does meet standards; so that's our
basis for feeling that we do have horizontal delineation on each of these areas. The second
part was pertaining to the supply well. I have seen data on that and there were chemicals
detected, but as far as I know, all of those data show that the water did meet drinking water
standards.
Sonya Gooden: By whose standards?
Joe Daniel: By the federal government's standards.
Sonya Gooden: But we are the people drinking the water.
Joe Daniel: Those are the—
Sonya Gooden: Joe, please. This is a community comment period. Now federal standards,
those who can set those standards and then those who have to live by those standards, they
may not see eye to eye. So when you say you have below MCL's, no MCL's are tolerable.
We want it cleaned up and we want it cleaned up ground zero.
Major Ference: We want it cleaned up, too. And based on our—
Sonya Gooden: Good. But this Proposed Plan is not going to do it. It's not going to do it.
Mr. King: This looks like a 20 or 30 year plan.
Jim Stocker: Probably, you can. The charts you have, they were gone through by the - my
name is Jim Stocker and I was—I wanted to call you and talk to you the other day. What I
want you to do, those charts on the internet, we'll go back there and go step by step and see
what kind of an explanation you are giving here.
Joe Daniel: Excuse me, can we finish with the first question.
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Jim Stocker: Okay, go ahead.
Joe Daniel: Your question, Sonya, was why are we —let me clarify, you disagree with the
standards that we are using?
Sonya Gooden: I'm disagreeing with the tight control that you're looking at and just the
specific areas you're looking at when it is all over the place. I mean contamination has been
found throughout the area. And I understand you have to stop the source in order to dilute
that concentration depending on if we ever have any rain again. But what you are
proposing today, you're not proposing digging it up and carrying it away. You are
proposing leaving this in the ground.
Joe Daniel: Can we go with one question at a time. The first question was how did we —
what is our basis for staying within these areas.
Jim Stocker: With that area, with that specific area.
Joe Daniel: Right, the answer to that is we are going by federal mandated standards for
drinking water. Those standards are for municipal supply systems. Every water system,
municipal water system in the United States has to keep the water to those standards. That's
not standards for groundwater, that's the standards that the Albany water supply has to
meet when they pump water to your house. We are using those same standards for our
cleanup standards. So we defined everywhere that water doesn't meet those standards.
That's what these blue areas represent. So is your question that you disagree with those
standards?
Jim Stocker: What would happen if you go outside?
Joe Daniel: We have gone outside. All these green dots show the monitoring wells we've
installed and the testing that we've done shows that water in those wells meets drinking
water standards that are mandated by the government. That's our basis for drawing these
boundaries.
Sybil Gooden: So what you're saying is the blue spots are really the hot, hot spots.
Joe Daniel: Those are the areas where the groundwater does not meet drinking water
standards.
Sybil Gooden: They're the hot spots.
Joe Daniel: If that's what you want to call it. But around everyone of these blue spots, you
see monitoring wells where we have tested groundwater and it does meet drinking water
standards.
Sybil Gooden: Consistently? Over and over? Every time you test them?
Major Ference: Like I mentioned earlier, I called them and I said, "I want you to identify
anything that has —that you've detected these chemicals in, even once, above drinking
water standard, whether its TCE or DCE's," because we've had some comments that the
community does not like it that mostly we draw maps of the TCE. I said don't just look at
TCE, color it blue if it did not meet the standards so that's what this map represents.
Joe Daniel: And that is all the data that we've collected from 1992 until the present—or until
we did this map.
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Jim Stocker: If you come across the fence, is that the fence?
Joe Daniel: This is the Base boundary right here.
Jim Stocker: Okay, below—below that, below the Maintenance Area, what would happen if
you put a well, have you checked that area?
Joe Daniel: Yes, we have wells here at the boundary of that.
Unidentified Speaker: Is that the Ramsey Road area or the other side?
Joe Daniel: Ramsey Road is right here.
Unidentified Speaker: Where that blue spot is?
Joe Daniel: Right here.
Unidentified Speaker: [What's the] broken line?
Major Ference: There's two wells up here, blue, located off-Base, west of Ramsey Road, that
we've had detections above the drinking water standards.
Jim Stocker: And basically you say you have not seen around that pond or whatever that
was, that fishing area. You have not seen the dead trees around that pond?
Major Ference: No, I haven't seen them. I'd like to talk about that afterwards.
Mr. Waldorf: I've got pictures of them.
Joe Daniel: Have we finished all your questions?
Jim Stocker: That's the same question I believe we were asking.
Mr. Waldorf: I'm concerned about the children that are fishing.
Jim Stocker: That's right. The fish we are eating.
Joe Daniel: You're referring to Covella Pond, our investigation has not included that area.
That was not identified as an area of concern. But we have tested water and fish tissue in
Indian Lake Refuge over here and there was nothing there that indicated a risk.
Robert Jackson: Joe, I think there was a little more depth to Ms. Gooden's question, my
name's Robert Jackson, that you didn't answer and I'd like you to follow up on that if you
would, so we can complete her question. She asked about vertically delineation also. You
addressed the horizontal issue; if you'd speak a little bit to the vertical.
Joe Daniel: Yes, as indicated —as Major Ference indicated in the cross section —does
everybody understand what cross section is; if you just take a slice of cake and you look at
the side of it that's the view that we're looking at in the ground here - land surface - and
then we're looking at a slice through the earth. Fifty feet of clay, then the upper part of the
aquifer, lower part of the aquifer. A lot of our wells are screened in this area; then we have
other wells that are screened in this area. If we sink a well here, we find chemicals there,
then we step out further away from that, from the source area, and typically we go all the
way around it just to make sure, we can't always know which way the groundwater's
flowing, so we go all the way around it. We go further out and we go deeper. And we've
done that in every location here, because once the water goes deeper it has to go further
away from where - so we go out further, we go deeper and that's how we get our vertical
delineation. So this is a clay unit on the bottom of the Floridan aquifer that does not transmit
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water. That's the basement if you will. So if we keep stepping out further, go deeper, and we
don't see contamination, then that's considered delineated.
Robert Jackson: And where is that vertical delineation reported.
Joe Daniel: That's in the report. That's in the RI. Does that answer your question?
Robert Jackson: Partly. I think a number of the questions that we have we'll be submitting
in writing after tonight's meeting. I wonder if it's possible to get a copy of this area
photograph with the blue areas overlaying and also a copy of Major Ference's slides.
Jim Stocker: Yeah, the slides, too, please.
Robert Jackson: Is that possible?
Major Ference: No reason not to. I generally don't bring a copy because it's fluid until I get
here. I may change happy to glad. But I certainly can give anyone that wants a copy of the
slides a copy.
Mr. Waldorf: Since that pond's never been checked, would you please check that thing.
Could you do that. Take a look at the trees around there.
Major Ference: One concern that I want to identify is there is an interest in sampling for the
pond, check the water. Yes, ma'am.
Louann Turnage: Louann Turnage. I would like to make —I'd like to ask a question and
then also make a comment. When we started this, you started in 1985 investigating. In '87
you confirmed things. In '89 you were put on the priorities list. Now we have —y'all have
been studying and studying and studying, now you have a backup contingency plan in case
this doesn't work. My question is, and then I'll make my comment; my question is, how
long do we have to wait for more studies to see if this plan is going to work before you go
into the contingency plan? And my next—and my comment is, this community wants that
dug up and moved off the Base.
Major Ference: I would say that's two comments, so let me address the first one.
Louann Turnage: Okay.
Major Ference: The first one with the contingency remedy, and I think it's also related to
Mr. King's comment of the 30 year remedy that it sounded like to you. First of all, these
remedies that have been proposed have been very effective in other areas. You'll never
know if they're effective here or as effective — and when I say very effective, there are areas
where in a year or two years you see dramatic drops and large shrinkage of plume. And
we're hoping for the same. But the evaluation period, we're discussing that with the
regulators, we're looking at a possible three-year evaluation, a possible five-year. We will
not exceed five years. There is always a five-year review of every record of decision and
there are going to be standards; if this becomes a final remedy, which it's not, it's the
proposed remedy; but if becomes a final remedy, there will be standards such as we must
meet X percentage of reduction in X years; 3 years, 5 years, that's still being discussed. And
this is not a test where we plant a small section—although we have planted a small test
section out there; this is, if it becomes the final remedy, it would go across the whole area —
all of the areas. For example, the tree cap. And then we would be evaluating by measuring
the groundwater concentration with our monitors. So that was the first one; and I'm sorry,
the second comment you mentioned?
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Louann Turnage: We want it dug out and moved out of there.
Major Ference: Right, the digging up. Now we did look at some of those things and Mr.
Daniel and Frank Lesesne, they can discuss it more in depth. We have done a detailed
probing of the landfill area to find out what is there. And there was some discussion about
possibly digging up certain areas. But the primary thing that was discovered are petroleum
products and a chemical that's cis-l,2-dichloroethylene [DCE]. All that is a particular form
of a chemical that is only created by the destruction of trichloroethylene, the natural
destruction of trichloroethylene. And so that interrelationship, you can dig up that
petroleum product area and what you're going to end up —the petroleum products are the
food that help the bacteria to break down the chemicals. And if you removed it, you've
removed let's say 10 feet or 25 feet, there is still that residual chemicals located below, by
now you've removed the food source for the natural breakdown within the overburden and
then you're going to have to end up putting an evapotranspiration or a standard cap,
something to prevent water from infiltrating through anyway. You are not getting rid of all
of the chemicals by just digging up the landfill sites.
Louann Turnage: But we're getting rid of some of it.
Major Ference: That's true; but the concern and the discussion was are we doing more harm
than good by removing the food that is helping to induce the natural destruction of these
chemicals. If you remove this, are you stopping the natural breakdown of the stuff you can't
get to because you can't dig down to 300 feet.
Sonya Gooden: But y'all have left it there all these years for it to naturally attenuate
anyway.
Major Ference: And that's why we are finding that cis-l,2-DCE because it's breaking down.
Sonya Gooden: And how long have we had to wait for it to break down. How much longer
do we have to wait for it to breakdown and be safe?
Major Ference: The primary concern we have to look at with this remedy is that, you know,
the protection, first, of human health and the environment. And what I'm saying is that look
where the groundwater is flowing, look where — do we have any receptors, do we have
anyone that can receive this groundwater currently; which, I'm hoping with the interim
measure of the installation of the municipal water, that would prevent any of that, and then
destroy the chemicals the best way possible. Do you pump and treat? That's not very
effective in the upper zone. We've seen that. Do you excavate? You can't excavate to 200
feet. So how do you destroy it. The best way, we believe based on the evaluation, is destroy
it in place by assisting the natural breakdown that is taking place. But, please, I am sure that
does not answer your question to a satisfactory manner, but we're going to have to go back
and look at some other things and get a more detailed response.
Sonya Gooden: There are still two people still drinking that water out there. I want you all
to know that. Two households.
Major Ference: And I know that we somewhat disagree on whether the groundwater from
the Base and any chemicals from the Base are flowing in that direction, flowing west, south,
east, and that's something—they are located very far away and it is sort of across stream or
upstream from the general flow direction. Can I say where water flows, what direction, in
every particular spot? No. If you put in three wells the size of this room, you can get an
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understanding of what's going on right here, but it doesn't tell you what's going on at the
end of the hall, so—but the best we have is USGS report, how does the groundwater flow,
and then our reports, how is it flowing, to get a feel for whether those chemicals will be
flowing towards those folks or away from those folks, and then I would defer to Rob for the
EPA sampling results of the wells also. Yes, sir?
Billy Ramsey: I'm Billy Ramsey and I live right near several of those blue spots. How long
has contamination been pumped into those areas, or dumped in those areas, or put there or
gotten there. How many years has it been going on?
Major Ference: Some of the landfill cells in this vicinity, which is what you are most
interested in, are from the 50's. The primary ones of concern, based on the detailed probing
of the landfill, are old landfill trenches, and they are dated back into the 50's and possibly
60's. And now I'm getting out on the limit of my knowledge off the top of my head. You can
get with Frank and Joe on some of this.
Billy Ramsey: I understand, but we've been possibly drinking contaminated water for 50
years.
Major Ference: I would tend to disagree with that, sir, because of the amount of time that it
would take for chemicals that tend to like to grab on to soil more than be in water to travel
from that portion, wherever it is put in the landfill cell, down, all the way through and into
the groundwater.
Jim Stocker: Can you give us any kind of time you are talking about now? A billion years?
Major Ference: I'm sorry, sir, can you hold on a minute. Sir, I want to make sure -
Billy Ramsey: That answers it. My wife has a question also. She has a pear tree. Those pears
are mostly water. So Ludie Ramsey.
Ludie Ramsey: We are approximately half mile, maybe, at the most from that area. And you
are planting trees to bring the toxics out of the soil, right?
Major Ference: No, ma'am. The planting of the trees, I'm sorry, if I may just repeat the
question. The [Ramseys] live approximately a half a mile from the area, and she's asking
whether — one comment is whether we are planting trees to remove toxics; and I just want to
clarify, no, that is not the reason for the trees. The trees combined with that soil is to prevent
water from getting through and into the landfill cell areas and carrying any more chemicals.
I know that was just the beginning of your question.
Ludie Ramsey: Okay, well, my pear tree is about a half mile from there and I can like 250
pints off that pear tree in a year's time. What am I doing canning those toxics?
Major Ference: Ma'am, based upon our sampling which indicates that the chemicals have
not flowed further north toward you, I would say that you probably don't have a problem
in the groundwater. But, if you look at those type of things, in the risk assessment, they
evaluated the uptake of chemicals based on concentrations that we have found west of
Ramsey Road, but nevertheless off the Base, looked at the uptake of chemicals into different
food products, such as gardens and such. And Dr. Delaney's in the back of the room. He's
the toxicologist who will be able to address this a little better. But we did evaluate that to see
if there is a possibility of any risks from even irrigating a garden with groundwater
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pumped —that may have concentrations as high as we found far to the west of the Ramsey
Road area.
Ludie Ramsey: I'm just saying we're giving up a lot more than a well of water when we
have to give up our gardens and our fruit trees and the fruit that grows around. We're
giving up a lot more than our well water.
Major Ference: Yes, ma'am, that's what I'm saying. That was evaluated.
Dr. Delaney: I can answer that question right now.
Major Ference: This is Dr. Delaney who is going to speak. He's one of the toxicologists
working with us.
Dr. Delaney: These kinds of chemicals do not accumulate into the plants. They don't
accumulate into fruit, so that won't be a problem. Also they don't accumulate —they don't
bio-accumulate into fish. We are talking about solvents. They may—the highest that they
will do is they would come in the same concentration as the surface water. But remember,
these things evaporate a lot, so it is always coming off the surface water. That's why there
would be very low concentrations in there. It's not going to be in your fruit; it's not going to
be in your vegetables; and it's not going to be in any significant concentrations in your fish.
Unidentified Speaker: Lake Eufala; it's more or less fishing up there, [but] don't eat the
catfish.
Dr. Delaney: That's probably because of other chemicals, such as PCB's and things like that.
Right, there are chemicals that can come and—
Unidentified Speaker: They say don't eat the fish.
Dr. Delaney: But that's a whole lot different.
Unidentified Speaker: How about peanuts? There's a man that grows peanuts out there,
right across from the whole landfill.
Dr. Delaney: Right, they just don't accumulate into that; not these kinds of chemicals. Are
there chemicals that can, yes, but it's not this kind of chemicals.
Sonya Gooden: Are there any on the Base that can? Do you know every chemical that's
been out there. You have made a huge statement.
Dr. Delaney: And you know something, I can defend virtually every statement that I make.
There are chemicals that can be accumulated into fish; there are chemicals that can be
accumulated into food, but we are talking about here, for solvents, it doesn't happen.
Sonya Gooden: Have any of these been found on the Base? Of those chemicals that you are
talking about.
Dr. Delaney: We're talking about groundwater.
Sonya Gooden: We're talking about limited testing.
Dr. Delaney: We're talking about OU6 groundwater.
Sonya Gooden: You're absolutely right. We are talking about it.
Dr. Delaney: About OU6 groundwater.
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Sonya Gooden: Yes, yes.
Dr. Delaney: Okay, the solvents in the OU6 groundwater do not accumulate in the fish, do
not accumulate into food, do not accumulate into fruits, do not accumulate into vegetables.
Jim Stocker: Therefore, we shouldn't clean up them, right?
Dr. Delaney: No, I didn't say that. That's a whole different thing.
Unidentified Speaker: Do PCB's accumulate in it?
Dr. Delaney: Yes, PCB's do accumulate in the fish; that's one of the reasons that you'll find
fishing advisories. But you don't find it for— that's not what we have here.
Unidentified Speaker: What about the fruits and the vegetables for PCB's?
Dr. Delaney: No, PCB's accumulate into fats. That's the reason why catfish which have a lot
of fat, that's a real problem. Also, PCB's tend to accumulate into mud where catfish tend to
feed and they tend to accumulate into that.
Unidentified Speaker: What about the pesticides and all?
Dr. Delaney: Pesticides can do that, too, because they share many of the same
characteristics; they accumulate into fats.
Sonya Gooden: And if you'll notice the word "mud" up there on the upper Floridan
aquifer.
Dr. Delaney: That's not the kind of mud that you're talking about here. I'm talking about
river mud, which is the reason why you normally give fishing advisories.
Jim Stocker: Could you explain for me now why we have to clean up this if it's that simple
that any of the chemicals do not - why do we have to clean up?
Major Ference: The question is why are we going to clean up, based upon what Dr. Delaney
said? We have to clean up because the groundwater does not meet the standards of the Safe
Drinking Water Act.
Jim Stocker: Why?
Major Ference: It's not ingestion through fish, or—we evaluated and estimated risks based
on someone sitting in the middle of this plume and drinking from high concentrations,
located—
Jim Stocker: Of what?
Major Ference: Of these chlorinated solvents. Yes, sir, of these chlorinated solvents.
Jim Stocker: But according to Dr. Delaney's explanation, they aren't harmful.
Major Ference: No, sir, we're talking about something different. Dr. Delaney. If you would,
clarify and make sure we're not talking about apples and oranges.
Dr. Delaney: That's quite an analysis here because we are talking about fruit. Okay, when
we are talking about a risk assessment, we look at the ways people can come into contact
[with solvents]. And for example, we have to look at drinking the groundwater. That is —
that would not be a smart thing to do because we know there are chemicals in groundwater.
They are above the safe drinking water level. That is what the federal government says is
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safe. I've looked at these and I can tell you that the MCL's, the safe drinking water levels are
so conservative that they are safe for children, safe for infants. I have a one-year old. It
wouldn't bother me the least bit to have him drink water that is below the MCL, my own
child.
Tina Knepp: Wait until you're in that situation and say it.
Dr. Delaney: So. What?
Tina Knepp: Wait until you're in that situation and say it.
Dr. Delaney: Oh, okay. Well, we are all in that situation everyday when we drink water
from any drinking water supply. We are in that situation every day. What we do have to
look at is, for example, what would be the risk if you were going to drink the water? If you
were going to bathe in the water? If you were going to shower in the water? These kinds of
things. Normal uses that we use water for. And many of these, the risks are too great so the
water has to be cleaned, [but] other things are safe. For example, using this to irrigate your
garden. This material is not going to come up into the fruit. It is not going to come up into
your vegetables. It is safe to eat; it is safe to eat the fruit. It is safe to eat the vegetables. We
know what these chemicals do and what they don't do. One of the things they don't do,
these types of chemicals do not accumulate into vegetables, they don't accumulate into fruit.
Sonya Gooden: Can you explain, Dr. Delaney, your part in all of this. Do you work for
MCLB, are you a contractor with Harding Lawson? Can you tell us how you came about to
be involved in this.
Dr. Delaney: Even though my name tag says Harding Lawson, I work with a company that
Harding Lawson was before; ABB Environmental, where we had the Navy contract; and I
consulted with them for the Navy. After that, when I left that, I formed my own private
consulting firm. So one of my jobs now is to help communities understand the actual truth
about chemicals. And there is a lot of misunderstanding, throughout the nation. People read
newspapers and they are scared. And there are people —there are a lot of environmental
activists that scare people. And so one of the things that I do is I try to teach people what is
known about chemicals and what is not known about chemicals. And one of the things that
is here is the risk assessment. The Navy wanted someone to explain the risk assessment, a
toxicologist, and they asked me to do it. The way they did this was through their CLEAN
contractor, which is Harding-Lawson. But I'm not Harding-Lawson, I'm my own person. I
head my own company. I carry my own liability insurance. I'm a practicing toxicologist in
Tallahassee, Florida.
Sonya Gooden: Did you write the risk assessment?
Dr. Delaney: No, I did not.
Sonya Gooden: Who did?
Dr. Delaney: There were risk assessors from Harding-Lawson that wrote this. I did review
the risk assessment, but I didn't write it. It is rare that people at my level get to do that.
Sonya Gooden: All right, so Harding-Lawson wrote the risk assessment?
Dr. Delaney: Correct. And it was reviewed by the EPA and the state.
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Sonya Gooden: You know, that does bring us to a very good question at this point. You had
mentioned that the state and the community had a say so. Is Billy Hendricks here tonight?
Major Ference: Yes, ma'am.
Sonya Gooden: I think we want to hear what does the State of Georgia think about this
Proposed Plan?
Major Ference: Billy, if you would, would you come on up?
Billy Hendricks: I'm Billy Hendricks. I'm the state compliance officer that handles the Base
cleanup and compliance activities. When we receive a risk assessment from a facility, any
facility, I read through it. I don't attempt to make heads or tails of it; I send it to our risk
assessor. Our head risk assessor, Dr. Cliff [unintelligible]. He reviewed this. His staff
reviewed it and agreed —they agreed with the findings that the Base has put forth. They
went back and redid the calculations, based on the data that had been given, and in this
case, the numbers came out virtually the same.
Major Ference: And said, cleanup necessary.
Billy Hendricks: Said "you've got to clean it up."
Sonya Gooden: All right, does the state agree with the Proposed Plan?
Billy Hendricks: Yes, we do.
Sonya Gooden: Unequivocally.
Billy Hendricks: We don't agree with anything unequivocally.
Major Ference: You were involved in the development.
Billy Hendricks: I was involved in the development of the plan. We have a stake in it. If it
doesn't work, we're going to try something else.
Sonya Gooden: We're looking at anywhere from 8 million dollars to 300 million dollars
that's talked about. From 8 million to 300 million, how much is the Proposed Plan in cost
going to be involved here? How much money are you going to spend to clean these sites
up? I ask you this, Billy, because I want you to stay here with us. You gave seven
alternatives in the feasibility study. And it ranged from 8 to 300 million —to 300 million just
to get it, as they say, load it and go. So the question that I think Louann was asking, all right,
you make a run at it, that's, you know, 50 million dollars, it doesn't work. So now you have
to pull up another 75 million to make Plan B work. When and at what point are you going to
clean the groundwater up where it is usable for future generations because it's not usable
now?
Major Ference: That's the focus of the proposed remedy.
Sonya Gooden: That's right, and we're here, and right now you've talked in so many circles
- I've read a lot of this material - and you've talked in so many circles at this point, I don't
think any of us are real clear about it. I know I'm not. About what's the deal. How much is it
going to cost you to do what you are proposing to do?
Major Ference: Cost? I don't have that number off the top of my hand.
Sonya Gooden: Why don't you?
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Major Ference: I can get that answer for you.
Sonya Gooden: Why don't you? We came here to talk about this tonight, you should have
that material with you.
Major Ference: To me cost is not as big a factor as a technically sound alternative that will
clean up the water. Isn't that what we want? That's what we want. What's done to destroy
the chemicals and clean it up. That's why I don't focus on the cost. It has to be looked at in
the feasibility study because it's outlined in the National Oil and Hazardous Substances
Contingency Plan. But what is my personal focus: "what is a good alternative to clean up
the water." That's why I don't know it's 8,15 or 300 million off the top of my head. I
apologize about that. But I can get that answer for you.
James Southfolk: Again, my name is James Southfolk. I'm glad Mr. Billy's here representing
the State of Georgia. You agree to the method that we—that is proposed now?
Billy Hendricks: Yes.
James Southfolk: And you think it's going to work?
Billy Hendricks: Yes.
James Southfolk: And that's the only method that you think that has been chosen from all
methods that's out there?
Billy Hendricks: No, it's not the only thing that will work.
James Southfolk: Okay, why do you say that?
Billy Hendricks: It's the first choice of the Base. We agree with that first choice.
James Southfolk: And so the State of Georgia agrees with that?
Billy Hendricks: Yes. And the State of Georgia agrees that there should be contingencies in
case it doesn't work.
Major Ference: Mr. King.
Mr. King: The method that y'all have chosen, is that the fastest method of cleaning it up?
Major Ference: It has been very quick in many locations, but we won't know until we put it
in place at MCLB Albany how quick it's going to be. I'm very optimistic about it.
Mr. King: But do you think that is the fastest method you can do?
Major Ference: I think it's a lot faster than trying to pump and treat.
Mr. King: Well, we know pump and treat doesn't work. That's a known fact.
Major Ference: I truly believe this is the best selection to move forward and destroy the
chemicals and get the water back to Safe Drinking Water Act standards.
Unidentified Speaker: Which method is that you are referring to?
Major Ference: I'm talking about the combination of cutoff the source and be —and I'm
referring specifically to the in-situ treatment that enhance bio-remediation. Let the natural
micro-organisms destroy the chemicals. But give them the material to encourage them to do
so.
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James Southfoik: By pumping the lactic acid into them. To make the process faster.
Major Ference: Yes, sir. It causes the conditions necessary to speed up the breakdown.
James Southf oik: And if it doesn't work, we'll go to what?
Major Ference: That's right, we go on to the next remedy. The contingency remedy.
James Southf oik: Which is the ET, or whatever you call it.
Major Ference: No, sir, when we—when I'm talking about the lactic acid, I'm talking about
that upper water bearing zone. When you're talking about ET, you're talking about cutting
off—turning off that faucet up top. The source; the original source of chemicals and still a
source. There are chemicals, probably, from the bottom of that landfill grabbed onto the soil
all the way down to the groundwater. We need to stop the water from running through that
soil and carrying chemicals into the groundwater. So we've got two different things. If we're
finding that the remedy we're proposing is not working, then we need to shift into another
gear which outlined as our contingency is the standard cap if the infiltration is not being
prevented. And the pump and treat, ex-situ removal of water and cleanup. Does that
answer your question, sir?
James Southf oik: I think it's been answered.
Sonya Gooden: Major Ference, in April of 1997, and I knew I needed to bring this tonight
because I read that material, it says, "Groundwater tracer tests, data and preliminary data
from the US Geological Survey Base-wide groundwater investigation at MCLB, Albany,
found a porosity in the upper zone of the Ocala limestone ranges from 31 to 54 percent.
These results indicate that enhanced in-situ treatment is impractical for PSC 1 based on the
hydrological conditions and aquifer characteristics." Are you not bringing the same thing to
the table that you knew in April 1997 wasn't going to fly and you worked the project for two
years? It says the data - "this data supports the conclusion that an in-situ nutrient delivery
system will require long-term operation to determine the technology's effectiveness. Further
evaluation of the enhanced in-situ biological treatment was not performed during this
treatability study." You have already done pilot studies but yet you are bringing to the table
something that you found out in 1997, [that] it don't work.
Major Ference: Joe, will you address that, since that's probably—
Joe Daniel: I think that's the treatability study for Potential Source of Contamination 1.
Sonya Gooden: Yeah.
Joe Daniel: Okay. That is specific to one cell that consisted of four wells.
Sonya Gooden: Right.
Joe Daniel: What we are proposing is a much larger grid; a full-scale treatment where the
failure of that particular test was based on not finding the tracer in the downgradient wells.
What we are proposing, we are going to have so many wells that the delivery system will
work.
Sonya Gooden: So maybe it will and maybe it won't. You've got a report right here that is at
least 300 pages thick that says it don't work, Joe.
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Joe Daniel: That said adding amendments to —those specific amendments at that point on
Base did not work. We did not have access to the HRC technology at that time. This is a
different technology; it's a different compound.
Sonya Gooden: What is HRC technology?
Joe Daniel: Hydrogen Release Compound, I'm sorry.
Sonya Gooden: So how much is this going to cost?
Joe Daniel: You did ask about the cost. The cost is in your hand. We can't tell you the
bottom line because we haven't been presumptuous and selected the remedy. We have a
proposed remedy. If that is what everyone agrees on, then we will have that bottom line
cost that you're talking about.
Sonya Gooden: Okay, so let's say you move ahead without everybody's agreement. How
much? How much?
Joe Daniel: Do you have that number Bob?
Bob Lunardini: At this point, I'm Bob Lunardini, I prepared the feasibility study. What we
did, cost wise, is we broke it down for each individual area, so since we are doing different
things at different areas, we haven't added that up for the Proposed Plan. But we do have
costs and it's in the handout in the back, for each individual site, for each individual
technology. That information is available. The feasibility study, the guidance, expects you to
get that cost within plus 30 to minus 50 percent. We like to think we get it closer to that; we
try to get within plus or minus 10 percent. The cost information is in that handout.
Sonya Gooden: Are you telling me you cannot tell me tonight how much this Proposed
Plan is going to cost? There was four or five costs and you didn't add these up yourself. This
is a proposal that's on the table, isn't it? Help me. It's a proposal, isn't it?
Bob Lunardini: It is.
Sonya Gooden: This is a solution, it's a remedy. But yet not one of the three of y'all have
been able to tell me how much does this cost, and yet your asking us to agree with you
when you can't even tell us what the bottom line's going to be.
Bob Lunardini: If you give me 10 minutes, I'll get that number for you. I'll add it up right
now.
Sonya Gooden: That's good, that's what we're here for.
Major Ference: As many of you can see, there's a lot of moving parts and there's a lot of
different people with different expert knowledge on different areas. I would like to take a
few more questions and then break up. I'm here until—anyone wants to come ask me
questions, I'm here until the room is empty. The same holds true for everyone else, but
please come get with us. I'd like to tackle a few more questions but also give other people an
opportunity, perhaps folks that would rather speak one on one, to ask their questions. I'll
station myself around. Let me start up here, please.
Louann Turnage: Louann Turnage, again. In the feasibility study in Chapter 1, it mentions
because the groundwater plumes associated with MCLB Albany do not discharge to any
certain water bodies, and that's all I wrote, because that's what I want to address. How does
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Piney Woods Creek fit into this. Because we experience a lot of flooding from Piney Woods
Creek.
Major Ference: The groundwater beneath our sites flows towards Radium Springs, not to
the East, but more to the West. So that's a more technical question to Joe. But my surface
knowledge would be Piney Woods Creek is to the east; the groundwater flows to the West,
to Radium Springs, so I wouldn't expect that that area that's beneath us would discharge to
Piney Woods Creek.
Louann Turnage: I'm talking about surface water.
Major Ference: Right, Piney Woods Creek is surface water.
Louann Turnage: Yeah.
Major Ference: Oh, you're saying no surface water —I'm sorry, can you read that again. It
says, "no surface water?"
Louann Turnage: All right, it says the groundwater plumes—because the groundwater
plumes associated with MCLB Albany do not discharge to any groundwater bodies. So
doesn't Indian Lake empty into Piney Woods Creek at some point.
Major Ferrence: The surface water —the groundwater, the 50 feet down to 300 feet does not
discharge to surface water.
Louann Turnage: Okay.
Major Ferrence: Does the outflow from Indian Lake end up in Piney Woods Creek, my
guess would be yes. It comes under the railroad tracks and hooks a right and goes east
toward Piney Woods Creek.
Louann Turnage: Do any of the contaminants go down Piney Woods Creek?
Joe Daniel: Not that we've found.
Major Ference: And I would answer that similar based on the test results of the surface
water at Indian Lake which is older data; but nonetheless when Indian Lake was sampled.
Joe Daniel: Did you get your question answered about the groundwater discharge to
surface water.
Louann Turnage: Yeah. And you said there's no contaminants going down Piney Woods
Creek?
Joe Daniel: Not based on the data we have. We tested water from Indian Lake and sediment
and fish tissue as part of the remedial investigation of Operable Unit 1. There was nothing—
there was no human health risk based on the data we got there. I've not seen any recent
data.
Mrs. Ramsey: When was that tested?
Joe Daniel: 1992,1 believe.
Major Ference: That was Mrs. Ramsey.
Mrs. Ramsey: And not since then?
Joe Daniel: Not that I'm aware of.
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Robert Jackson: Joe, I have two questions for you quickly; this is Robert Jackson again. The
first one is that you mentioned that the sediment, fish tissue, and water testing, there was no
risk to human health. Were there contaminants found in the soil or the sediment, or fish, or
water?
Joe Daniel: Do you remember those numbers. Dr. Delaney?
Dr. Delaney: No, I don't.
Robert Jackson: Not the amounts. Were contaminants found?
Joe Daniel: I would assume that chemicals were found, of some nature. When you're testing
to the parts per billion level, you will find chemicals. Evidently there was nothing that
posed a human health risk, but there is chemicals in everything we eat and drink everyday.
Robert Jackson: I certainly understand that. A follow up question, you mentioned the HRC,
hydrogen release compound as a potential remedy. I've seen that in some of these
documents. My experience with that process is it produces toxic bi-products that are,
breakdown, [unintelligible] products that are more toxic than the chemicals you are trying
to remediate, is that correct?
Joe Daniel: Specifically?
Robert Jackson: Specifically, tell me. Is that correct? Are more toxic contaminants produced
as a result of HRC?
Joe Daniel: I'll defer to Bob and Dr. Delaney on that.
Robert Jackson: Do you not know, then?
Joe Daniel: I don't know specifically about the chemicals that you're talking about. It was
always my understanding that the chemicals break down into less toxic. Ultimately, yes, sir.
Robert Jackson: But in the interim is it correct they are more toxic —
Major Ference: The main problem is this. I think what you are getting at is vinyl chloride.
Robert Jackson: That's where I'm going.
Major Ference: Say it.
Robert Jackson: I'd like to hear your expert tell me he knows what it is.
Major Ference: I think there was a disconnect there. What we have is trichloroethylene
breaks down to cis-l,2-Dichloroethylene and then to vinyl chloride and then to ethene. And
that's the breakdown chain. The main problem with the trichloroethylene, and the ones with
more chlorine is that you need anaerobic condition, what that means is low oxygen down
there. We typically have high oxygen down there. So we got the hydrogen release
compound down there; it induces the low oxygen and starts the breakdown process to the
DCE. The DCE can breakdown both with aerobic and anaerobic, low oxygen and high
oxygen, and then it migrates on out and vinyl chloride gets destroyed just like that in high
oxygen. So it moves into high oxygen and that's what we feel will take place.
Robert Jackson: Major Ference, I appreciate that.
James Southfoik: That was very good, Major.
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Robert Jackson: But, my question was a lot simpler than that. It was simply are these more
toxic contaminants being created as a result of the use of HRC?
Joe Daniel: I will refer to Dr. Delaney on toxicity.
Robert Jackson: Now, Major Ference has already told us that vinyl chloride is being created
as a result of the use of HRC. And your opinion would be eliminated later.
Major Ference: You can't destroy these chemicals and bypass vinyl chloride.
Robert Jackson: Vinyl chloride is being created. Vinyl chloride, Dr. Delaney, is a known
toxic —carcinogen, is that correct.
Dr. Delaney: You can go down that path if you want to, but—
Robert Jackson: I just want to know if it's a known carcinogen.
Dr. Delaney: Okay, this is one of those situations that I tried to warn you all about, where
people try to scare you.
Robert Jackson: I'm not out to scare anyone.
Dr. Delaney: Fact number one, it is—
Robert Jackson: And I don't appreciate the indication that I'm trying to scare anyone.
Tina Knepp: You're very rude, sir. You're very rude.
Robert Jackson: I have placed a question before you. You have —
Dr. Delaney: Yes, it is a confirmed human carcinogen. Now, here's the actual facts about it.
The only people that ever developed cancer from vinyl chloride were people that worked in
vats, where they cleaned the side of the vats. And there were hundreds and thousands of
workers that did that. Do you know how many—we know how many of them did that.
Only 13 ever developed cancer. Of all those thousands of workers, 13 developed cancer.
Unidentified Speaker: You've never studied us though.
Dr. Delaney: None of you all have angelo psychoma. It is a very, very, very rare form of
cancer.
[Lots of people talking at once.]
Dr. Delaney: What I'm saying is, is it a confirmed human carcinogen? Yes.
Robert Jackson: So why couldn't you give me that answer from back there.
Dr. Delaney: Because I wanted the people to understand that—
Robert Jackson: You're safe, you're not over a vat breathing it.
Dr. Delaney: Yeah, and if it was in your water, you'd be safe, too.
Marie Estes: But you're in a shower, a hot steamy shower, —
Dr. Delaney: And you'd be safe—
Marie Estes: —three times a day because your bones hurt. So you take a shower. And when
you get rid of the damn well water, the bones quit hurting. The aches go away. The
infections go away. The cold symptoms that won't leave your body go away. Your entire
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body itching, go away. Your rashes that turn into infected sores, go away. Just because
you're not drinking that God-damn water anymore.
Dr. Delaney: But you won't develop—
Marie Estes: And that's a fact.
Dr. Delaney: But you won't develop cancer from vinyl chloride.
Marie Estes: I don't care. It won't kill you but it damn sure makes your life miserable.
Dr. Delaney: You're right, it won't.
Major Ference: All right, if we're going to destroy the chemicals, or if we're going to rid of
the chemicals, we could pump and treat and may never remove them all. We can try to
destroy them in place, and we're not going to be able to bypass vinyl chloride. If we're
going to destroy it and get it to ethene, we've got to stop at the vinyl chloride station. And
that's why exposure is the number one thing. The vinyl chloride is an inhalation danger,
primarily; but, of course, if you're taking a shower, that's vapor, inhalation. But that's why
we have to look at exposure. Where do we have chemicals and where do we have municipal
water wells. And that's one of the things; although we don't have any reason to believe that
there is, you know, based upon even EPA sampling, that there is any vinyl chloride up here
or that the chemicals would flow in this direction, let's go for this interim measure and try to
install water to these folks just in case. Let's do it because there is a possibility that, who
knows, it makes a right-hand turn and we don't see where it makes a right-hand turn. So the
big thing is, yes, to destroy it in place, we're going to have to stop at vinyl chloride. Dr.
Delaney mentioned, a confirmed carcinogen. You can't destroy it and bypass that. So we
need to stop exposure. If there is no exposure to that chemical that we're going to have to
stop at, then there shouldn't be any health effects because no one is exposed to it.
Unidentified Speaker: But if you dig it up, do you get rid of the vinyl chloride — I mean,
you bypass that?
Major Ference: The chemicals are in —it's not just in that landfill cell. It's not just in that
landfill. It's beneath it. It's all the way down through. You know, maybe that landfill trench
stretches a third of the way into that overburden area, but water going through there all this
time, over the years, has carried chemicals down. As they come down, they grab onto soil
the whole way down. They get into the upper water bearing zone, very tight - still grabbing
onto soil. So you can dig up that trench, but you still leave all those chemicals in the same
spot. You haven't really —I mean, as I mentioned earlier, I think by removing the petroleum
products, and based upon our discussions, you've probably done more harm than good by
stopping some natural breakdown. But you haven't done anything for the bottom of the
trench all the way down. You still need to turn off the faucet up in the overburden area and
then try to destroy it in place in the upper water bearing zone. And while we stop at the
vinyl chloride station, make sure that no one is; first, with our monitoring, make sure we
know where all those chemicals are and that no one is tapping into those areas where the
chemicals are.
Robert Jackson: That's a very reasonable answer, Major Ference. And I'd like to state for the
record that it's not my intention here to scare anyone, but we have heard discussion of the
HRC as a proposed method. I hadn't heard once vinyl chloride until I raised it. These are the
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types of the issues that the community wants in front of them to help make their decisions
and provide proper comment on the administrative [record].
Major Ference: And that's what we want. We want to address the comments and concerns
so I'm glad you brought it up.
Robert Jackson: So when I asked my question, I really just want answers to my questions,
Dr. Delaney and not an insinuation that I'm attempting to frighten anyone.
Joe Daniel: Let me interject something on the hydrogen release compound. I know some of
you are accessing information on the worldwide web. The vendor for hydrogen release
compound has a website. The URL, the address is www.regenesis.com and you can find
everything that they have; a lot of good information on hydrogen release compound at that
site. Specifically regarding your question, it shows the breakdown process. It shows a very
simple, schematic diagram the configuration of these molecules, how it strips off one carbon
atom at a time, to get breakdown, to the next breakdown. So that's one site you might like to
access.
Major Ference: That site should also give you some examples of how quickly it has worked
in areas where it worked. Of course, we believe it's going to work very well here, but that's
part of the contingency process. But I have gone there and they do give examples. If I could
go to the back, there is a gentleman way in the back that wanted to ask a question.
Armond Milner: The question I wanted to ask is are the micro organisms eat up in diesel
fuel and gasoline and that type of fuel that's being disposed of there?
Major Ference: Actually diesel fuel and petroleum-type products are very easy to break
down for natural micro organisms; that's sort of easy. And as I mentioned earlier, that's sort
of like a food source for them, to help them destroy other chemicals that are more difficult to
destroy, such as these chlorinated chemicals.
Armond Milner: Well, my second question is, then, why is the EPA so hard on private
individuals if they have a fuel spill, fuel tank, they have to have it dug up, all the earth
around it has to be disposed of. What's the difference? That's the question I've got.
Major Ference: Okay, sir, what I'd like to do is get back with and possibly with Mr. Pope
from EPA and we can talk about that after. I'd like to wrap up just a few more questions
while we have the recorded portion. [And] make sure we get them on the groundwater. But
that is an excellent question.
Sandi Byrd: We're in a drought situation. And it's got to lower the aquifer, the wells around
it. I've got a side farm, we've got farms pumping lots of water out of these wells. For some
reason the Marine Base decided I didn't need city water when everybody else off Ramsey
Road did. I am east of 82. Now with the lowering of the aquifer, we already know that you
have found chemicals found in the Ramsey Road. As the water goes down, and the
chemicals get more condensed, how much further can they spread and how often are you
checking your wells with this drought situation to see if there's a problem with the
chemicals getting more dense?
Major Ference: I'm going to defer that question to the geology side. We've got several of
them here.
Joe Daniel: Okay, the last question was how often do you sample the wells.
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Sandi Byrd: Right, Ramsey Road area where you found all those contaminants that are
outside of the Base. How often — I know you have the test wells — how often are you testing
your test wells, checking them for contamination, and end up the [unintelligible] of
contamination?
Joe Daniel: The monitoring wells that the Navy has installed off-Base, at least seven of
them, six of them are tested every six months. We have a crew in the field this week testing
wells. That's part of the PSC-3 interim corrective measure there at the fence line. And what
was the other part of your question?
Sandi Byrd: Since my well's in the first aquifer where the chemicals are, as the water table
goes down, it makes the —you don't have too much to dilute your chemicals in.
Joe Daniel: Right, but on the other hand, with less rainfall there is less water washing
through the soil that would take water down, or take chemicals down into the groundwater,
and thus movement of water, once it gets to the — once chemicals get there. As far as where
your well is located relative to the Base, I'm not sure where you live, but as we indicated
here, this represents the analytical data, summary of the analytical data since 1992. So unless
something really unusual has happened in the last few months, this is pretty representative
of what we can expect here.
Sandi Byrd: And you're not going to increase your testing, even though we're in a drought,
when you've already got the chemicals down there, you're saying they're not going
anyplace because it's not raining; they're not going to just congregate—
Joe Daniel: No, I didn't say they're not going anywhere — I didn't mean to imply that. I
mean with less water there is smaller water movement. The water movement is driven by
pressure differentials. If you have a high water level and a low water level here, the high
water is going to attempt to move to the lower level. If everything is pretty flat, there's not
as much pressure pushing the water along. That's what I was trying to convey.
Sonya Gooden: So are you telling us we have—
Joe Daniel: Excuse me. Did I answer all your questions, ma'am.
Sandi Byrd: Yes.
Joe Daniel: What I was trying to get across is we've been monitoring these wells over
almost 10 years; 8 years, and this represents the data from that amount of time.
Sandi Byrd: Okay, but we're in a drought. I think this is the driest May we've had in like
108 years, or since they've been keeping records.
Joe Daniel: I believe this drought has been going on since last year. And we have been
monitoring—
Sandi Byrd: Right, and the situation we're in right now, they did say it was the driest May
in 108 years or something.
Joe Daniel: Right.
Sandi Byrd: So we are in more of a drought situation now than we have been in many,
many years. And people are pumping their irrigation systems and everything. And it's got
to lower to the aquifer, the first aquifer, because we're not getting the rain to replenish it.
Even though the water originally comes from the north and it trickles down. They're in a
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drought situation as well. So this is going on, I don't water my grass because I'm scared to
death my well's going to give up, and it's 196 inches. And I'm not on city water. And I am in
almost a straight line with your contaminated well.
Joe Daniel: A straight line? With?
Sandi Byrd: With PSC 3, what is it, I don't know. PSC twenty—
Major Ference: Are you saying due north?
Sandi Byrd: Yes, a straight line north.
Major Ference: Well, based on the testing and this is our representation of our arms around
where the chemicals are. And in general, as I mentioned, they move in this direction. I
wouldn't expect that it would somehow head up towards your area.
Sandi Byrd: I thought it was on Ramsey Road, so if it's not in my area, why bother to put
water meters on everything on Ramsey Road.
Major Ference: On Ramsey Road, that was the interim measure to address the potential.
Sandi Byrd: My land parallels Ramsey Road.
Major Ference: We said let's take it out a mile; let's be super conservative. The chemicals we
know are here. We've had a few detections based on EPA sampling in private wells down in
this area, —
Sandi Byrd: But you're only going to sample it every six months. Is that what—even though
we're in a drought situation?
Major Ference: This remedy moves forward into more sampling. I don't know what the
schedule is.
Joe Daniel: Yeah, there will be ongoing monitoring as part of the final remedy. And exactly
which wells and where they're located, how frequently they're sampled, that's part of the
final remedy - the remedy selection. Another point, though, based on the—we have the
monitoring well data, which is what we based this information on. There is also the
residential well sampling that's been done and all that information—we have to based our
interpretation on something. Those are the data we have. All that data indicates that—all of
those data show that water met drinking water standards.
Sonya Gooden: In your opinion.
Joe Daniel: No ma'am, that's according to what's mandated by the government.
Marie Estes: Because it won't kill us.
Major Ference: The one thing, the risk assessment—I would like to mention this. When—we
discussed this at the last meeting, which was in March, and a lot of you folks weren't here,
but I think it's an important point. When we calculated a risk assessment for the off-Base
area, we used the highest concentrations of chemicals that we detected in any off-Base wells.
And these wells, the one well that had the highest concentration, was west of Ramsey Road
and the concentrations of chemicals in that well was at least 10 times the concentration of
any chemical detected in any of the wells that were down here. The only ones that we had
detection of the same chemicals.
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Sonya Gooden: And that's where she is, west of Ramsey Road.
Major Ference: West of Ramsey Road and south of Sylvester Highway?
Sandi Bates: Yes.
Major Ference: But still on Sylvester Highway, is that right?
Sandi Bates: Well, my land is attached to Sylvester Road but it also parallels Ramsey Road.
Major Ference: So right here —if you don't mind, I'd love to get with you afterward so we
can look at what you're talking about and discuss it because —I think it would be better
anyway. Let's get Joe to talk about some geology.
Joe Daniel: There was a comment about the drinking water standards, I understand that
you may not agree with the drinking water standards, but that's what we are tasked to do
our interpretations on and those are our cleanup standards. If you have issues with those
standards, then those —you need to communicate that to the state and federal regulators.
Sonya Gooden: I think the issue that we have at this point is the drinking water standards
that you are using to in order to drink this up. We are trying to tell you that if you are going
to use drinking water standards, based on their standards, we are not in agreement with
that. We want it cleaned up.
Joe Daniel: Those are the standards that every municipal water system in the United States
operates on.
James Southfolk: In other words, if we want to change it, we'd have to go to the
government and ask them to change.
Joe Daniel: That's my understanding.
James Southfolk: What is the limit now?
Joe Daniel: It's different for each chemical.
James Southfolk: Well, what is it?
Major Ference: For one of the main chemicals we talked about a lot is trichloroethylene. The
limit is 5 parts per billion.
James Southfolk: It's five—
Major Ference: That's right. Five parts per million. Yes, sir.
Dave Rowland: Major, could you have Mr. Pope address some of the brief fundamental
concerns about, first of all their oversight of the Proposed Plan; and two, what experience
that had on the proposed methodology and what their independent evaluation is. Along the
same lines as Mr. Hendricks discussed. Would that be helpful?
Major Ference: I'd like to just do that as the final formal portion of the meeting. If, Rob, you
wouldn't mind just making a few comments and then if there are further, more detailed
questions, especially the drinking water standards or how EPA came to where they agree
with this, they were involved in the development. Please get with Rob Pope from EPA or
Billy Hendricks from the Georgia EPD. After this, I'd like to close the formal portion. And I
just wanted to outline this and make sure that everyone knows who everyone is. If you're
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interested in the background and project overview, a good person to talk to is Joe Daniel,
from Harding Lawson. He's been the project manager and working with this site since 1990.
Joe Daniel: 1991.
Major Ference: '91. Sorry, since 1991. Rob Pope from EPA, he's their remedial project
manager. You've met Billy Hendricks. He's remedial project manager for the Georgia
Environmental Protection Division. Mr. Dan Owens - Dan, could you stand up? - in the back
of the room. He's from—he's the project manager from the Navy out in Charleston. Of
course, myself, I'm the IRP Manager. Captain Keith Knutson, where's Keith? There he is.
That's the —I'm leaving 5 July, just as a head's up. The new IRP manager is Keith Knutson.
Remedial Investigation, Frank Lesesne, he's a geologist with Harding Lawson standing in
the back. Risk Assessment, you met Dr. Delaney, he's a toxicologist. And then the feasibility
study and Proposed Plan, although most of us can address any of these, the primary person
for those two topics is Bob Lunardini. And he looks like he's chomping at the bit to give you
some costs. But further just give Rob an opportunity to say a few words and then [I'll] close
the formal portion.
Rob Pope: Dave, could you reiterate what you wanted me to cover.
Dave Rowland: Well, what the EPA's independent—what's your view and participation in
this has been and if you have any other data like Major Ference was referring to where this
methodology has been used and what result the EPA has seen.
Rob Pope: Okay, so you're talking specifically the HRC, hydrogen release compound. Yes,
the EPA has seen hydrogen release compound used by various sites that have these chloride
solvents, trichloroethylene, the cis-l,2-Dichloroethylene, and it some places it has worked
very well. It has decreased concentrations of TCE to the MCL, which is our goal, and have
been very successful. Sometimes it happens very quickly - by quickly, I mean months. But
it's very site specific, depending on the contamination, the amount of contamination, how
the HRC is used, those sorts of things. Other places it has taken multiple uses of HRC to
achieve similar results. And there are some places where HRC has not worked as well as it
was hoped that it would. That is one reason; or that is the major reason why there are
contingency remedies in this Proposed Plan, because we have not used HRC at MCLB so we
want to be sure that it works and if it doesn't work as good as we hoped it will, we want to
have a remedy lined up and ready to go for the Navy and Marine Corps to put in place. So
that's why there are contingency remedies.
Rob Pope: As far as the Proposed Plan itself goes, as Billy said, both EPA and the state get a
chance to look at the Proposed Plan. The Base, you know, involves us very much in what
they propose to do. We looked at it, we made comments on it. It has changed from the very
beginning. I think all the project people will be honest about that. When we get documents
the first time around, they usually do not meet up with what we want them to meet. They
are not quite up to our standards and we make comments on documents and they get
changed. So it has changed a good bit. But as it stands now, the Proposed Plan is an
acceptable document and, as Billy said, the state and EPA concur with these remedies and
think that we should move forward and try them. And that's where we are today. Do you
have a question for me?
James Southf oik: Yeah, the question was everybody is using the word, they have tried
everywhere. Can you name one, two, three, or four that we can do our work—our own
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homework and find out how it is being done. How the community reacted to that particular
technology, and how effective it is for the long term.
Rob Pope: I'm going to briefly restate the question. The first part was, can I name a few
places where HRC was used, how effective was it, and how did the community accept it? Is
that a fair paraphrasing?
James Southfolk:Yeah.
Rob Pope: Off the top of my head, I know that HRC has been used at Hurlburt Air Force
Base, which is in Navarre, Florida, in the panhandle of Florida, near Pensacola. Let's see,
how well did it work. My understanding is that it initially worked very well, but since the
initial testing, concentrations have rebounded. Not to their original—say that they were
100 —these numbers are not exact, but say they were 100, they dropped to 50. Since that time
they have come back up to like 70. And now they are going back and doing another
application of HRC. I haven't heard the results of that. I believe that's actually happening as
we speak or in the works. So it did have some affect, they did rebound a little bit, and they
are hoping with another injection of HRC, they'll continue to go down.
Major Ference: That website is a good place to start.
James Southfolk: I'm kind of skeptical about going to a website because of the technical
information on the website is not as accurate as I would like for it to be.
Rob Pope: Another think about websites, that's the company's website. They are going to
tell you about places that it has worked very well most of the time. If they're —they may be
honest and say it doesn't work everywhere all the time; in fact, they probably are because
there are places that I know that people from Regenesis have said, "No, we don't want to do
HRC here because we don't think it will work due the site specifics." So, but you're right.
That's the company, they're selling their product so that's their website; but they'll have
some examples - I think it's good information with a grain of salt.
Joe Daniel: We can provide some more case history information.
James Southfolk: Are you at a desk where if I call in, I can get you?
Joe Daniel: No, but Major Ference can put you in touch with me.
Major Ference: I'm the contact. Myself or Captain Knutson should be the point of contact.
James Southfolk: Okay.
Rob Pope: Let me finish. The Hurlburt Base, the community acceptance, they are not an
NPL site.
James Southfolk: So, already we have, how do I say, not contradiction, but it's not working
in Hurlburt Air Force Base, right now.
Rob Pope: No, it did work, but not as well as they wanted it to.
James Southfolk: Okay.
Rob Pope: Okay. And so they are trying a second application.
James Southfolk: It was effective enough to warrant another application.
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Rob Pope: They are not an NPL Base, so they don't have these same kind of public meeting
requirements. They do have what's called a restoration advisory board which all the
members of the committee attend and the members of the community have been told about
this remedy, and have said, "Hey that looks like a good idea, let's try it." But they don't
have this kind of response from their community. They don't get 40 or 50 people at their
meetings. They get 5 to 10.
James Southf oik: One more area at least.
Rob Pope: One more area —oh, off the top of my head, I can't think of the name of the place.
There is a dry cleaner site, also in Florida. This site was actually done under the Florida
Environmental Protection Agency for the state environmental agency. And they had
excellent results. But it's a different site than what we have. Their contamination was
shallow. It was a sandy aquifer, that sort of stuff, so it's very different. They had very good
results. I think the numbers I saw were reductions of 70 to 80 percent in about a month
period of time. So those are very good results. But I can't think of the name. It was a dry
cleaner in Florida. Do you know Kyle?
Kyle (unknown last name): I was just going to add that we are applying that technology to
a Dixie Drycleaner in Jacksonville, Florida, right now, under the Florida dry cleaner
program. They've used it at several sites.
James Southf oik: That's—where was that pilot program somewhere?
Kyle: In fact, ABB Environmental Services did some of the early research with Regenesis at
a site in Massachusetts, at a pilot site or test site up there, and I wasn't involved in that. I
don't know the name of the site, but we can get that information for you.
Joe Daniel: That was one of the two case histories I was talking about. I'll get that
information to Major Ference.
James Southfolk: Okay.
Major Ference: I'll field one more.
Sonya Gooden: I think he's back with the answer. Talking about the cost of the Proposed
Plan.
Unidentified Speaker: I've got one question. You said you cut the tap off, right? You are not
dumping any more. I don't believe that. So if you are not dumping, what are you doing
with your chemicals now?
Major Ference: I'm sorry, sir, I didn't follow the question. Could you repeat the question
please?
Unidentified Speaker: You say you cut the tap off, you are not dumping anymore, is that
right?
Major Ference: That's true.
Unidentified Speaker: Okay, if you're not dumping anymore, what are you doing with
your chemicals now?
Major Ference: Okay, the question, and we haven't turned the tap off yet.
Unidentified Speaker: You mean you're still dumping?
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Major Ference: No, sir. When I say turn off the faucet, I mean the stuff that's already there,
the water comes through it, and brings the chemicals to groundwater. I'm calling that a
faucet, okay. We don't dump our chemicals anymore.
Unidentified Speaker: Then what are you doing if you're not dumping them?
Major Ference: It's hazardous waste. Chemicals like this would be considered hazardous
waste and it's containerized in accordance with the law and sent to via permitted
transporter to a permitted disposal facility. And that is a big part of what Billy Hendricks
does. You can ask him about it. He can give you real good specifics about how we manage
our hazardous waste. Let's tackle the last question, if you don't mind: Sonya was asking the
final question of Mr. Lunardini, I guess, about the cost.
Bob Lunardini: The cost for the Proposed Plan, total to the nearest million is $42 million.
The breakdown of that, for the Northern Plume Area, $19 million. PSC 4, $2 million, and for
the Depot Maintenance Area, $21 million.
Sonya Gooden: Let me ask one more question at this point, please. When you propose a
contract with the federal government, aren't you supposed to let out a RFP on a project.
Why are we looking at one proposal from one company with one solution. Why haven't we
been brought three proposals from three different companies? Why?
Major Ference: It's part of the Navy Comprehensive Long Term Environmental Action
Contracting. And Mr. Dan Owens in the back of the room will be able to address that
question more specifically. But they bid for that particular contract and they won that
contract. And that contract was for them to investigate the sites, conduct risk assessments,
and conduct feasibility studies and make recommendations on the appropriate method.
They won that contract years ago based on that bidding process you mentioned. But I
would defer that question to Dan and ask you all to discuss that afterwards.
Sonya Gooden: One more question. So you're saying that Harding Lawson would not
implement the Proposed Plan.
Major Ference: That's correct.
Sonya Gooden: Who would implement the Proposed Plan?
Major Ference: The company that's going to implement the Proposed Plan, it's required, it's
the way it's going to be; the way it has to be because of the requirements. Dan can outline
why it's like this. But there's two contracts. The clean contract, Comprehensive Long Term
Environmental Action Navy, and then when that contract is up, a contractor comes in that is
the remedial action contractor. And that contractor is CH2M Hill and we have a
representative sitting right there, Denis Ewing. Would you raise your hand, Denis? He's
from CH2M HILL and that's the company that would then take these recommendations,
take the decision once we finalize the plan into a record of decision based upon comments,
and start the design of the remedy based on the record of decision.
Sonya Gooden: Does CH2M HILL feel like they can deliver this for $42 million?
Major Ference: That's a question for ...
Denis Ewing: [response masked by laughter from the audience.]
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Major Ference: I would like to please remind everyone that we're here. We have all the
information. This is sort of an idea if you want to talk to someone, I just want to point out
again, Denis is the remedial action contractor if you questions about that. He's not up here.
That's a person —in addition, we have Mr. Jerry Palmer in the back of the room, he's the
Environmental Branch Head for the Environmental Branch. And then, of course, we have
two Marines back there that are not Captain Knutson, and they are from the Public Affairs
Office. Other than that, I want to say thank you very much.
James Southf oik: Are we going to have another meeting after this, or is this the last one.
Major Ference: Sir, we plan on continuing the public availability session program. It will
probably be several months. I'm sorry, we have one final comment from Mr. Pope.
Mr. Pope: I was asked to give one clarification. I alluded to the contingency remedy and the
reasons the regulatory agencies wanted it was to have something in place - ready to go - if
the primary selected remedy didn't work. And the reason for that is if we don't have the
contingency remedies in place and the primary remedies don't work, we have to go through
this whole process again. We have to start from scratch. And we want to avoid that because
we think it's taken long enough and we want to keep it moving forward. That's the
clarification I was asked to make.
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County of Dougherty :
The foregoing transcript consisting of 34 pages is an accurate transcript of the Public
Hearing held by Marine Corps Logistics Base. Albany. Georgia, on the proposed plan for
Operable Unit 6. The hearing was held from 7:00 to 8:55 p.m. on Thursday, June 1, 2000, in
Albanv. Georgia.
-------
Citizen Comments and Questions from July 5,2000
Operable Unit 6 Draft Record of Decision
MCLB Albany, Georgia
1. Comment: Since adequate site specific data has not been compiled to prove the
effectiveness of the proposed remedy, why haven't remedies been proposed which do
not depend so critically on the development of "adequate site specific data". For
example: metal filings barrier walls, sheet pilings, complete excavation and offsite
treatment and removal of waste combined with some of these other remedies that have
been proposed?
Response: Based on the site-specific data collected to date, MCLB Albany believes that
the remedies proposed will work. Other remedies were evaluated in the Feasibility
Study (FS) for OU 6 (HLA, 2000), but were screened out because they were not deemed
applicable to conditions at MCLB Albany. Metal filings barrier walls and sheet piling
were not considered applicable alternatives because of the depth to groundwater
(greater than 50 feet) and the lack of a confining unit to tie into and adequately control
groundwater flow. The remedial alternative to completely excavate the landfilled
materials was evaluated in detail in the FS for OU 6 (HLA, 2000a). Earlier in the
CERCLA (also known as Superfund) program (mid 1980s) millions of dollars were spent
excavating landfills. The lesson learned was that the benefit did not justify the cost. That
is why the USEPA issued guidance on remedial actions for landfills (USEPA, 1996); the
guidance states the presumptive remedy is to cap landfills. That is the selected remedy
for landfills at MCLB Albany.
2. Comment: The proposed remedies are apparently being given "a reasonable time"
within which performance criteria are being evaluated. Please define how long a
reasonable time is before the secondary remedy would be implemented.
Response: The overall goal of the remedial measure is to reduce the offsite
concentrations of the chemicals of concern (COCs) to a concentration that is less than
their Federal maximum contaminant level (MCL) in 10 years and onsite COC
concentrations to less than MCLs in 20 years.
3. Comment: Why were barrier walls, sheet pilings, metal filing barriers not considered as
a possible remedy as these would better protect our properties?
Response: Refer to the response to Question 1.
4. Comment: Why is the performance criteria for the evapotranspiration cap that the
infiltration rate be less than or equal to the average subtitle D performance when we
have hazardous wastes in place here which would need a Subtitle C landfill?
Response: The goal of the cap is to prevent infiltration. The Resource Conservation and
Recovery Act (RCRA) Subtitle D standard accomplishes this and is compliant with
presumptive remedy guidance (USEPA, 1996). Military landfills are similar to municipal
landfills and contain predominantly non-hazardous materials. Hazardous waste is
expected in most municipal landfills due to past disposal practices, but when final
capacity is reached, these landfills are capped, not excavated (USEPA, 1996). MCLB
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Albany acknowledges that if the wastes at PSC 3 were to be excavated, some wastes
might require disposal in a Subtitle C facility. However, the presumptive remedy for
landfills at CERCLA sites is capping, not excavation. The goal of a cap is to minimize
infiltration of precipitation. The proposed remedy will accomplish this goal (HLA,
2000a).
5. Comment: Since we know groundwater extraction and treatment is an effective remedy,
why is it being maintained only as a contingency remedy instead of a primary remedy?
Response: Over the last 15 years, the remediation industry has learned that extraction
and treatment of groundwater contaminated with chlorinated solvents does not work in
an acceptable time frame in the vast majority of cases. There is an abundance of site
specific information presented in the Remedial Investigation (RI) and Baseline Risk
Assessment Report (BRA) for OU 6 (HLA, 2000b) to support the fact that extraction of
groundwater from the upper water bearing zone would not be an effective way to
capture and remediate the chlorinated volatile organic compounds (cVOCs).
6. Comment: If the purpose of treating all the groundwater at the Base in a single Operable
Unit 6 was so that all the contaminated groundwater be addressed at once, why aren't
all the RCRA and other sites that have groundwater contamination included in part of
OU6?
Response: Each of the RCRA and CERCLA sites are included in OU 6. Initially,
characterization of the groundwater at MCLB, Albany was conducted individually for
each Potential Source of Contamination (PSC) or OU. However, after evaluation of data
from several OUs, Southern Division Naval Facilities Engineering Command
(SOUTHNAVFACENGCOM) and MCLB, Albany recommended to the Georgia
Environmental Protection Division (GEPD) and the USEPA Region IV that these
individual groundwater investigations be combined into a single basewide OU.
SOUTHNAVFACENGCOM and MCLB Albany proposed to the regulatory agencies that
the investigation of groundwater at a basewide level would be more technically
appropriate and would also expedite the other ongoing investigations at MCLB Albany.
The initial focus of OU 6 was to encompasses all 26 PSCs that have been identified at the
MCLB Albany and determine specifically which ones were sources of groundwater
contamination. This recommendation was agreed upon in March 1996 by GEPD and
USEPA.
The investigation activities identified three geographic areas that contained sources of
groundwater contamination: the Northern Plume Area (NPA), the depot Maintenance
Activity (DMA) Area, and Potential Source of Contamination (PSC) 4. The PSCs
included in each source area include:
• Northern Area Groundwater Plume
PSC 1, East Disposal Area
PSC 3, Long-Term Landfill
PSC 26, Containment Berm Area
• DMA Area Groundwater Plume
PSC 10, Central Repair Division of the DMA
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PSC12, Industrial Wastewater Treatment Plant (IWTP)
PSC13, Industrial Wastewater Pipeline (IWP)
PSC 22, DMA Storage Area
• PSC 4 Area
PSC 4, Warehouse Disposal Area
Consequently, the OU 6 RI/BRA (HLA, 2000b) has included information collected from
1992 to 1999 to characterize and address potential groundwater contamination as a
basewide effort.
7. Comment: Does the MCLB have any Clean Water Act permits and if so what is
permitted, what is the permit number and why was it not mentioned in the OU 6
documents?
Response: MCLB Albany has pretreatment permits with the City of Albany, they are
number 26 for the Industrial Wastewater Treatment Plant (IWTP), and number 27 for the
Domestic Wastewater Treatment Plant (DWTP). There is a permit (047-0008) for the
three Base water supply wells under the Safe Drinking Water Act.
8. Comment: You have stated that significant progress has been made at MCLB Albany
over the last few years and discuss the final RODs that have been signed for five of the
six Operable Units at the Base. What you don't say is that there has been no action and
institutional controls are the remedy for all of those Operable Units and that no wastes
have been removed or treated or had their toxicity reduced. Please be more specific
about what you mean by significant progress has been made.
Response: No further action is the remedy assigned to sites where no contaminants are
found, or when they are present at concentrations that do not present a threat to human
or ecological receptors. Institutional controls, such as land use controls, are the remedy
that is used where the risk at the site may be inappropriate for residential exposure but
are in the risk range that is acceptable at an industrial site. Additionally, there have been
remedial activities when warranted, such as the removal of the sludge piles from PSC 3.
Significant progress is clarified in the following paragraph of the Proposed Plan, which
states "The signing of these Records of Decision (RODs) signified closure of
investigation and cleanup activities for 14 of the original 26 sites. With the exception of
PSC 9 and PSC 21, the remaining 12 sites have been addressed via screening and RCRA
cleanup activities in 1996 and 1997" (HLA, 2000c).
9. Comment: Please explain in detail what is going on at PSC 9 and PSC 21. It seems that
the community doesn't hear anything about the RCRA probable sources of
contamination and how they are being addressed under the CERCLA cleanup. You
stated that PSC 1 is an inactive landfill. Was it ever permitted under any authority of
state, federal or local government and if so, what authority?
Response: The status of all PSCs was provided in materials provided at the public
availability sessions in October 1999, December 1999, and March 2000. The current status
of PSC 9 is that soil has been excavated, removed, and disposed of at a permitted facility
under the direction of GEPD. PSC 9 remediation is complete pending final regulatory
approval. PSC 21 is scheduled for investigation in FY 2001. PSCs 9 and 21 were
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addressed under RCRA, and were not assessed under the CERCLA processes. PSC 1
was never permitted. At the time PSC 1 was active, there were no State or Federal
regulations requiring permits.
10. Comment: You have identified 26 PSCs. I thought we had heard at one of the public
meetings that there were now more than 26 sources of contamination. If there are more
than 26, please identify what they are, and where they are and how they are being
addressed.
Response: There are only 26 PSCs.
11. Comment: Shouldn't the results of the surface water sediment and fish samples taken
from Indian Lake Wildlife Refuge and Pinewoods Creek also be included in the OU 6
reports?
Response: The focus of the RI/BRA for OU 6 was groundwater. The aforementioned
results were included in previous RIs for OU 1 (ABB Environmental Services, Inc., [ABB-
ES], 1995 and 1997a). The ROD for OU 1 was published in August 1997 (ABB-ES, 1997b).
These reports are available in the Public Repository, located at the Dougherty County
Public Library, 2nd Floor, Reference Section, 300 Pine Street, Albany, Georgia.
12. Comment: What is the Base now doing with the sludge from the industrial wastewater
treatment plant?
Response: MCLB Albany currently hauls the sludge from the IWTP to a RCRA Subtitle
C Landfill (Hazardous Waste Landfill), which may be either in Alabama or Kentucky.
13. Comment: What has the Base historically done with the sludge from the industrial
wastewater treatment plant?
Response: Beginning in the early 1980s it was hauled from the IWTP to a RCRA Subtitle
C Landfill.
14. Comment: What are the sources of waste and streams that comprise the influent the
industrial wastewater treatment plant at PSC 12?
Response: Wastewater that is treated at the IWTP is the water used at the DMA. This
wastewater is routed to the IWTP through a dedicated pipeline.
15. Comment: It appears that waste has been being burned at the Base since the 50s. Have
the waste burning operations been permitted under any authority and what precautions
were taken to insure that people living around the Base were not exposed to fumes from
burning hazardous materials?
Response: Open burning was a standard practice at that time. State and/or Federal
permits were not required at that time.
16. Comment: Is the Base still engaged in the open burning of materials and wastes?
Response: Hazardous material is not burned at the Base, however, as part of Natural
Resource Management (Forestry), there are prescribed burns for the prevention of forest
fires.
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17. Comment: Why were the sludge piles at PSC 3 removed and disposed of off Base in a
time critical removal action in May of 1996?
Response: The inorganics were present at concentrations that did not meet USEPA's
human health risk criteria for residential exposure.
18. Comment: What is a time critical removal action and why was "time" critical?
Response: Under the National Oil and Hazardous Substances Contingency Plan (NCP),
CERCLA defines two different procedures for conducting a removal action that depend
upon whether or not there will be a six month planning period before initiating the
removal, or the removal needs to be initiated sooner than 6 months because of the risk
posed by contaminants. The regulatory agencies requested that the time critical removal
procedure be used for the sludge at PSC 3 to expedite the removal action and allow the
ROD to be completed for OU 1. The time critical action was not implemented because of
the level of risk posed by the sludge.
19. Comment: The term "berm" is used throughout the documents but there is no definition
of what a berm is? Please define that term.
Response: Merriam Webster's Collegiate Dictionary, Tenth Edition, 1993, defines a berm
as "a mound or wall of earth."
20. Comment: Does the industrial waste water treatment plant have a permit to discharge
under the Clean Water Act and if so what is the permit number and for what dates has it
had a permit?
Response: The effluent goes to the City of Albany publicly owned treatment plant. The
City of Albany has an NPDES permit.
21. Comment: How is the eastern boundary of PSC 3 determined and how is it that the
former sludge piles extend west of the eastern boundary of PSC 3?
Response: The boundaries of PSC 3 were interpreted from previous investigations, and
from review of nine aerial photographs taken from 1948 to 1977. The aerial photographs
were used to identify disturbed areas, and subsequent investigations were conducted
within the perimeter to confirm the lateral extent of activities. The sludge piles are
within the defined perimeter.
22. Comment: Has the MCLB ever disposed of waste on the proposed landfill property
north of Seaboard Coastline Railroad and west of Ramsey Road? If so, why is that waste
disposal area not included as part of PSC 26 or PSC 3 or some other PSC?
Response: MCLB Albany has not disposed of waste on the proposed landfill site.
23. Comment: The proposed landfill property north of the MCLB property line and west of
Ramsey Road continues to be contaminated with chemicals migrating from MCLB
which are above MCLs. What agreement, if any, does the Base have with the property
owner of that contaminated property? Has the Base purchased the property or otherwise
paid the owner for contaminating the property? Alternatively, has the Base agreed that
it will support or not object to the placement of a landfill on that property?
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Response: MCLB Albany has an agreement that allows the installation of monitoring
wells and sampling of groundwater from these wells. No purchase of property, or
payment for contamination to the property has been made. MCLB Albany has no official
or unofficial position to make on the proposed landfill.
24. Comment: The proposed remediation system does not appear to have any placement
planned on the proposed landfill property north of the railroad and west of Ramsey
Road nor in the residential properties winch surround the Base. What exactly does the
Base intend to do to clean up those lands?
Response: Source control (landfill capping) will occur only at the landfill sites on the
Base property. Groundwater in the upper water bearing zone (UWBZ) that contains
contaminants above Federal MCLs will be addressed through the proposed insitu
technologies of enhanced biological treatment and or natural attenuation (HLA, 2000a).
The treatment alternative selected for groundwater in the lower water bearing zone
(LWBZ) is monitored natural attenuation. After the ROD is signed, a detailed design will
be prepared to implement these technologies. Some injection and/or monitoring points
may have to be installed on properties that surround the Base. This will be determined
during the detailed design phase.
25. Comment: Does the Base already have permission from the landfill property owner to
conduct pump and treat or other remedial activities or removal activities on the
proposed landfill property north of Seaboard Railroad and west of Ramsey Road just
north of PSC 3 on 26?
Response: No such agreements have been made. If required, this would be initiated
during the detailed design phase.
26. Comment: Please define the term "abrasive blast grit residue' and tell us what
contaminants would be contained in it.
Response: Abrasive blast grit residue is the remains of steel pellets that were used to
remove paint from ground equipment or vehicles. Contaminants detected in PSC 4 soils,
where the abrasive blast grid residue was disposed of, are available in the PSC 4 RCRA
Facility Investigation Report (HLA, 1999a). Contaminants associated with the abrasive
blast grit are not COCs in the OU 6 groundwater. This report is available in the Public
Repository, located at the Dougherty County Public Library, 2nd Floor, Reference
Section, 300 Pine Street, Albany, Georgia.
27. Comment: Shouldn't the investigation of groundwater "Base-wide" level include all
potential sources of groundwater regardless of authority under which they are being
remediated whether it is UST other RCRA or CERCLA?
Response: Please refer to the response to Questions 6 and 9.
28. Comment: It is mentioned in the documents that the 1997-1998 data were also used to
identify potential data gaps that were necessary to complete the OU 6 basewide
groundwater investigation. Please explain with particularity what the data gaps were
and whether they were all answered by the 1997-1998 data that was collected.
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Response: During the preparation of the draft RI/BRA for OU 6, several data gaps were
identified that would support a more thorough understanding of the OU 6 basewide
groundwater and potential human health risks it may pose. These data gaps were as
follows:
• Delineation of carbon tetrachloride in the UWBZ southwest, west and northwest of
PSC 26.
• Delineation of TCE and carbon tetrachloride in the LWBZ northwest of PSC 3.
• Continued monitoring of the UWBZ and LWBZ water quality to confirm that the
groundwater plumes are stable and the COCs are naturally attenuating (HLA,
2000b).
Field activities to fill the above data gaps were completed between May 1999 and
September 1999. The 1999 field activities included installing 11 new wells in the lower
water bearing zone (LWBZ) and five wells in the upper water bearing zone (UWBZ) of
the Upper Floridan Aquifer (UFA), collecting groundwater samples at the 16 newly
installed wells and 216 of the existing wells, and conducting a subsurface geophysical
survey of the 11 new wells in the LWBZ. The data gaps fulfilled the requirements to
sufficiently complete the RI/BRA for OU 6.
29. Comment: Why is the most recent data set the preferred data set for use in assessing the
nature and extent of contamination and for use in the human health risk assessment?
Isn't it true that since natural attenuation and biodegradation has been going on since
disposal of the wastes that the contaminant levels were higher in the past than they are
now in some areas?
Response: The most recent data is more representative of site conditions for the reasons
stated in the comment. Also, sampling technologies have evolved over time and the
methods have changed to protocols that provide results that are considered to be more
representative of the aquifer. The highest concentrations for the cVOCs were detected in
samples collected in sampling events prior to 1999, this could be interpreted that the
concentrations have decreased over time. However, some of the cVOC concentrations
appear to fluctuate with precipitation events and do not conclusively demonstrate either
a decreasing or increasing trend.
30. Comment: When the Base was running metal samples on groundwater, did they check
for molybdenum, arsenic and cyanide in every sample and if not why not?
Response: The samples and analytes selected were in accordance with USEPA protocols
under the Contract Laboratory Program (CLP) Target Analyte List (TAL). The TAL
includes arsenic and cyanide, but not molybdenum.
31. Comment: Does the Base use bis(2)ethylpthalate compounds in its activities. There is a
good deal of comment throughout the documents that pathalate compounds are
common field or laboratory derived contaminants. Does the Base in fact use them in its
processes and if so, in what amounts and how frequently and what is the ultimate
disposition of those compounds?
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Response: Phthalates are common components of plastics, they are the compound that
adds flexibility. The Base does use plastic materials, which may contain phthalates as a
component, as many household products do. The Base tracks and properly disposes of
all hazardous substances in accordance with its Hazardous Waste Permit. Phthalates
could become introduced to an environmental sample in the field or laboratory through
inadvertent contact with the sample container rim, or by a sampler or lab technician
wearing gloves.
32. Comment: The documents seem to ignore pesticides and metals. Does or has the Base
used pesticides in its activities and processes and if so, in what amounts and how
frequently and what is the ultimate disposition of those compounds?
Response: Pesticides and metals were included in laboratory analyses until
investigations determined that they were not COCs. This is addressed in the RI for OU 6
(HLA, 2000b). MCLB Albany does use pesticides, which are applied in accordance with
the application recommendations of the manufacturer. Amounts and frequency vary;
however, if they are no longer to be used they are disposed of in accordance with the
MCLB Hazardous Waste Permit.
33. Comment: Please explain what the advantage to human health and the environment has
been by looking at groundwater on a basewide level (i.e., monitoring) and effectively
doing nothing for 10 years in the way of limiting exposure of the citizens and of the
environment to the leaking wastes.
Response: The decision to treat groundwater as a single OU is discussed in Section 2.2,
Page 2-6, of the RI/BRA for OU 6 (HLA, 2000b). MCLB Albany has provided residents
in the Ramsey Road area access to city water in 1994 and 1999, and in 1999 offered to
abandon residential water supply wells to prevent their future use.
34. Comment: Why was vinyl chloride not used in the baseline risk assessment?
Response: Vinyl chloride was included in the RI/BRA for OU 6 as a Chemical of
Potential Concern (COPC) for the UWBZ but not the LWBZ. Please refer to the RI/BRA
for OU 6 (HLA, 2000b), Tables 6-3 (pages 6-14 through 6-19). Vinyl chloride was a COC
for the UWBZ at PSC 1 and DMA.
35. Comment: You have stated that the BRA (baseline risk assessment) evaluated the
pathways through which people and the environment are/or may potentially be
exposed to contaminants at the site. Please identify specifically what those pathways are.
Response: The following possible uses of tap water and associated exposures were
evaluated:
• Drinking water (ingestion exposures)
• Bathing (volatile inhalation exposures)
• Vegetable garden irrigation (volatile inhalation exposures and ingestion exposures via
consumption of produce that bioaccumulates COPCs during irrigation)
• Swimming pool supply (incidental ingestion and dermal contact exposures during
recreational swimming)
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Health risks were evaluated for long-term (30-year) exposures to child and adult
residents. These pathways are found in the BRA, see Section 6.4, pages 6-5 and 6-77
(HLA, 2000b).
36. Comment: You have also noted that the Ramsey Road area has private wells but
currently has access to municipal water. They haven't always had access to municipal
water. All the private wells are still open and some of the private wells are still being
used for drinking water purposes.
Response: MCLB Albany has and continues to offer to close residential water supply
wells that have been replaced by municipal water, at no cost to the home owner. Well
closure was not required at the time of municipal water hookup.
37. Comment: Many local governments do things like have a gun buy-back-program where
there are instrumentalities that the people own that are deemed hazardous. Will the
Base implement such a program for private well owners living in and around the Base a
sort of private well "buy program" to buy the wells shut?
Response: MCLB Albany maintains a standing offer to pay for the closure of the
residential water supply wells that have been replaced by municipal water, at no cost to
the home owner. At this time there are no plans for a "buy-back" program.
38. Comment: Why is it that the FS and proposed plan do not propose to do anything at all
to the off Base contaminant sources or to reimburse the economic losses of persons
owning property which has been lost as a result of the contaminants?
Response: No off-Base contamination sources have been identified. Also, please refer to
the responses to Questions 24, 36, and 37.
39. Comment: You stated that residences in the Ramsey Road area closest to the edge of the
northern plume were offered access to the Albany municipal water supply in 1995.
Please identify how many residences were offered water and who was offered water.
Response: There were six wells and nine residences offered water in 1995. Two of the
residences declined the offer. The names are available through the MCLB Albany,
Installation Restoration (IR) Office by filing a request under the freedom of information
act.
40. Comment: You have also stated that in 1999 an additional group of nearby residences
were connected to municipal water. Please identify who they were.
Response: Fifty-one additional residences were connected to city water in 1999. The
names are available through the IR Office by filing a request under the freedom of
information act.
41. Comment: Please include a map showing where the Marine Base water supply wells are
identifying the depths of the wells, the depth and thickness of their screens and the
contaminants that have been found in those wells at what ever levels they have been
found.
Response: The well locations are illustrated on Figure 3-2 of the RI/BRA for OU 6
(page 3-4, HLA, 2000b). The well depth is approximately 900 feet, and the wells are
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screened through multiple intervals at various depths. Water quality data is provided in
Appendix G-5 of the RI/BRA for OU 6 (HLA, 2000b).
42. Comment: You stated that no discharges of contaminated water to surface water have
been demonstrated and that was the reason that an ecological risk assessment was not
conducted for OU 6. This makes absolutely no sense. Clearly, the groundwater
discharges to some surface water somewhere. The Base seems to make out that, the
groundwater is not coming from anywhere nor going anywhere.
Response: Groundwater in the Albany, Georgia area discharges to the Flint River
(depending on the river stage). Contaminant concentrations in groundwater decrease
with distance from the source area. The Flint River is so far from the MCLB Albany
source areas that it is very unlikely for groundwater containing measurable amounts of
contaminants would extend to this discharge area.
43. Comment: Please define what you mean by discharges of contaminated water have not
been demonstrated to impact surface water. What is demonstrated exactly?
Response: Please refer to the response to question 42.
44. Comment: Once the contaminants have been released and disposed of they are in the
environment and pose an ecological risk. The fact that they are in the groundwater
creates an ecological risk, particularly in this area of wetlands, sink holes and karst
geology. I don't see how they cannot conduct an ecological risk assessment when we
know the risk to the ecology and environment has been increased significantly.
Response: The ecological risk assessments were completed for the other five OUs, (ABB-
ES, 1992; ABB-ES, 1995; ABB-ES, 1997a; ABB-ES, 1997c; and ABB-ES, 1998). The
ecological risk assessments evaluated contaminants detected in surface soil, and in the
sediment samples collected from the PSCs in OUs 1 through 5. RODs have been signed
for each of these areas (ABB-ES, 1996; ABB-ES, 1997b; ABB-ES, 1997c; ABB-ES, 1997d;
and HLA, 1999b). The surface depressions related to sinkholes are recharge sources for
groundwater, contaminated groundwater does not discharge to these areas.
45. Comment: The Base should include as part of the applicable Unit 6 RIFS the map that
they showed at the public hearing which identifies all the hits that were above the
maximum contaminant levels in the groundwater. They should also tell us what that
map shows exactly. Is it just the chlorinated solvents that were above the MCL or is it
every chemical they ever had that was above the MCL? If it was not every chemical they
ever had above the MCL, then they should produce a new map that shows every
chemical they ever had above the MCL and where that hit was.
Response: The map shown at the meeting was simplified for public display. The map
was provided to Sonya Gooden, a representative of East Albany Against Garbage
Landfill Expansion (EAAGLE), in June of 2000. The map showed only where cVOCs
(PCE, TCE, cis and trans 1,2-dichloroethene (DCE), vinyl chloride, and carbon
tetrachloride), were detected from 1992 to 1999 at concentrations that exceed Federal
MCLs. Chemical analytical results for groundwater samples collected between 1992 to
1999 are provided in the RI/BRA for OU 6 (HLA, 2000b).
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46. Comment: The map showing the hits above MCL is incomplete because it doesn't show
the hits above MCL in the residential wells that were found in 1994 and 1995 that
initially caused the EPD to require the Base to offer city water. It also doesn't identify the
hit of Bis(2)ethylpthalate found in Solomon's well that was well above MCL.
Response: There have been a number of sampling events conducted of residential water
supply wells by USEPA, beginning in November 1993. Out of these events, only one
volatile organic compound, methylene chloride, was detected above its Federal MCL of
5 micrograms per liter (|j,g/L). Methylene chloride was detected at 5.8 (J,g/L. Subsequent
sampling events by USEPA have not confirmed this result. Therefore the result is
believed to be a laboratory artifact. The detection of bis(2-ethylhexyl)phthalate (BEHP) in
the Solomon's well is also a field or laboratory artifact. Bis(2-ethylhexyl)phthalate is not
a COC for groundwater. GEPD required MCLB Albany to provide water to residences in
the Ramsey Road area to prevent the possibility of exposure, not because of these
chemicals exceeded their respective MCLs. MCLB cannot prevent residents from using
their water supply wells.
47. Comment: In just about every case you have stated that the non-cancer risks are equal to
or exceed the hazard index threshold of 1. Please identify specifically what the
non-cancer risks are by telling us exactly what type of illnesses particularly are
associated with the non-cancer risks.
Response: This information is provided in Volume IV, Appendix J-3 of the RI/BRA for
OU 6 (HLA, 2000b).
48. Comment: There has been a great deal of discussion of the "seven" groundwater plumes
and very little discussion of how the seven groundwater plumes are moving, whether
they are expanding, sinking or evaporating into the atmosphere, moving along with the
groundwater or just static. Clearly they didn't just come to have the configuration that
they do instantly. We have no reason to believe that they will stay as they are. You need
to describe more the transport of these contaminants how quickly they are moving, in
what directions and where they are moving.
Response: The groundwater plumes mentioned were identified and interpreted based
on groundwater data collected beginning in 1992 and continuing at present. The
boundaries of the plumes have been updated with each new sampling event with no
apparent significant change in boundaries. Because of this lack of change, it appears that
the plumes are static, however, as proposed, additional monitoring must and will be
conducted to confirm this interpretation.
49. Comment: The hydrogen release compounds in enhanced bioremediation that has been
planned all seem to require that the source areas be removed first. Additionally, you
stated that removal of the, landfill materials and transferring them to an offsite
permitted facility is protecting the human health and environment. It doesn't make any
sense to try injecting hydrogen release compounds and other compounds into
heterogeneous fill material of unknown consistency (paper, crates, trash, containers etc.)
and composition when in fact it was designed for dissolved contaminants in
groundwater and soils.
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Response: The primary remedy for the source areas at the landfill sites is the
Evapotranspiration Cap. The primary remedy for the DMA is to find and eliminate leaks
from pipes. These source control measures are being conducted to minimize/prevent
the COCs from migrating from the unsaturated (vadose) zone to groundwater. The
hydrogen release compounds would be injected into the aquifer and not the source area
(landfill). This treatment would reduce the concentration of the COCs in groundwater.
These remedies do not require that the source area be excavated and removed.
50. Comment: Citizens of the Ramsey Road and Branch Sylvester Road area communities
produced their own community remedial investigation feasibility study but didn't
receive any comments from the Marine Base on that though it was advertised and
available in the public library and advertised for over a month. Why did the Base not
comment?
Response: MCLB Albany has no comments.
51. Comment: The community's RIFS included comparison of costs for various alternatives
that would eliminate their exposure to, contaminants and all of those costs were orders
of magnitude less than the costs estimates that were included in the Marine Base's study.
We are appalled that it has taken 25 - 30 million dollars or more and over ten years to
decide that the best thing that needed to be done is the wells should be closed and the
Base should pay for that well closure and pay the people for the losses associated with
the well closure and that the waste should be dug out and properly treated and
disposed of elsewhere.
Response: Please refer to the responses to Questions \, 5, 36, 37, 38, and 49.
52. Comment: The Base has said that the interim measure in 1999 consisted of providing
access to municipal water to the residents within one mile of PSC 3. Please explain how
that one mile boundary was chosen by MCLB.
Response: The distance was selected by GEPD.
53. Comment: The citizens living in, and around the Marine Base encouraged the EPD and
the EPA to take steps to permanently rid their communities of these horrible
contaminants and not to do what they are planning by making vinyl chloride and take
further risks with their health by the introduction of cleanup methods that will
introduce new contamination and increase the toxicity and mobility of various
contaminants and leave the wastes in place for future generations to have to deal with
when the Marine Base is long gone.
Response: Please refer to the response to Question 1.
54. Comment: I want to ask the Georgia EPD and the EPA to require the Marine Base to
excavate all the pollution sources to treat them and dispose of them offsite in permitted
facilities where they will no longer pose a threat to my community.
Response: Please refer to the response to Question 1.
55. Comment: The Marine Base needs to define vinyl chloride in the definitions section of
the proposed plan.
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Response: It is chloroethylene, a volatile organic compound. The chemical formula is C2
H3d.
56. Comment: The Base makes no discussion of the fact that the proposed enhanced
bioremediation will produce vinyl chloride, a known carcinogen, as this remediation
alternative has not been fully considered. For example, they have estimated the volumes
of various contaminants that exist beneath the MCLB and have proposed a cleanup
method which will require conversion of those volumes to vinyl chloride. The Base must
be required to specify the time period during which vinyl chloride will remain; is it
months, years and at what depth and the volumes of vinyl chloride that will be
produced on a stochiometric basis assuming the remedy completes itself.
Response: It is possible that vinyl chloride will be a temporary product as it is an
intermediate step in the reductive dechlorination process that eventually ends as carbon
dioxide and water. A discussion of biological degradation processes (which included
discussion of vinyl chloride) is provided in the RI/BRA for OU 6 on pages 5-4 through
5-20 in paragraph 5.2.2.1 Volatile Organic Compounds (HLA, 2000b).
57. Comment: The Base needs to explain why, at the public meeting, it tried to hide the fact
that vinyl chloride would be produced until our lawyer brought it up.
Response: There was no intent to hide the fact that vinyl chloride was a break down
product of TCE. Major Ference tried to communicate that vinyl chloride was a necessary
intermediate in the reductive dechlorination process. Also, please refer to the response
to Question 56.
58. Comment: Do low flow sample results produce reduced contaminant concentrations in
groundwater or higher concentrations in groundwater as opposed to bailer collected
samples. Which data was used in the baseline risk assessment, the low flow or the bailer
collected samples?
Response: Low flow purging and sampling is the method by which stagnant water
(water above the well screen interval) in a well casing is purged (removed) to allow
replacement by water that is representative of conditions surrounding the well. When a
bailer is used to purge a well, the repeated raising and lowering may agitate the water
and result in lower concentrations than low flow sampling. However, because of the
small volume required for a volatile organic sample, a bailer may then be lowered into
the well to collect the water sample from the well after purging is complete.
59. Comment: Why has there been no discussion of remediation of pesticides in the
feasibility study or proposed plan?
Response: Pesticides were not detected in groundwater samples at concentrations above
their MCLs and are not COCs (HLA, 2000b).
60. Comment: When you determine the volume of contaminant concentrations and you
assume that the concentrations do not vary with depth but that they do vary laterally
does that not neglect the possibility that contaminant concentrations may increase with
increasing depth? How has that been accounted for, and if it hasn't, the contaminant
concentration volumes are no longer conservative, isn't that correct?
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Response: The highest detected concentrations of the COCs in OU 6 were in the UWBZ
(HLA, 2000b). Typically contaminant concentrations decrease with depth; therefore, a
conservative mass can be estimated by assuming they do not decrease with depth.
61. Comment: I am disgusted that over $28 million and ten years has already expired and
the Base is still debating whether it needs to cap the landfill. Clearly the landfill area
needs to be capped but only after the contaminants have been removed, properly treated
and disposed of offsite.
Response: Please refer to the response to Question 1.
62. Comment: The statement has been made that there were no releases to surface water of
any of the contaminants from MCLB when in fact there was over 400 ton of sludge piles
at PSC 3. The sludge piles were open and exposed to the elements for years and even a
couple of floods (one a 100 year flood and another a 500 year flood). It is ludicrous to
state that there has been no demonstrated release of those contaminants to any surface
waters. Has there been any testing of surface water, and if so, where are the results?
They should be included as part of the water cleanup.
Response: Please refer to the responses to Questions 6, 8,11, 21, and 44.
63. Comment: GEPD has apparently not given any consent for subsurface reinjection. The
reinjection needs to be approved ahead of time before you can state which remedial
technology will be used. The Base should obtain approval, at least in principal, for its
underground injection control plans from the GEPD before bringing them to the public.
Simply identifying the permitting requirements and contacting the program isn't
sufficient to show that you will be able to do what you want to do.
Response: GEPD and USEPA have reviewed and approved the Proposed Plan and are
currently reviewing the draft Record of Decision.
64. Comment: You stated that aerobic conditions should cause vinyl chloride and DCE to
"rapidly oxidize to carbon dioxide". What exactly is rapidly and how do you know the
conditions will remain aerobic (a month or a year or more, also are we talking about
complete oxidation or partial such that we will be left with DCE and vinyl chloride over
time)? We would like to know the total volume and the total time for which vinyl
chloride and DCE would remain.
Response: A pilot scale study is to be conducted to evaluate the technology and obtain
the above information. Also, please refer to the response to Questions 55, 56, and 57.
65. Comment: Why is an additional source area characterization not best accomplished
during the removal of the sources for treatment and disposal offsite rather than during a
pilot study or design phase implementation. By then it appears much too late to being
additional source characterization.
Response: Additional source characterization helps determine more exactly the
conditions under which a remedy would be implemented. This additional detailed site-
specific data information is not required to select or pilot test the remedy. Also, please
refer to the responses to Questions 1 and 29.
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66. Comment: Additional source characterization is needed now because it is impossible to
determine whether the remedy is going to be successful without it. The government has
poked along for 10-15 years doing virtually nothing and now seems hell-bent on
rushing forward with a half-baked remedy without all the information it needs to
determine whether it will be successful.
Response: If you would like additional information regarding the evaluated and selected
remediation technologies, the EPA has a website at http://www.cluein.com. Also,
please refer to the response to Question 65.
67. Comment: None of the remedies proposed address metals or pesticides in groundwater.
The entire document is almost completely devoid of discussion of migration of
contaminants horizontally and vertically. There is almost no discussion of groundwater
flow rates, merely generalized directions and the fate of the plumes hasn't been shown.
Plumes aren't characterized well enough to assess potential remedies.
Response: Inorganics are likely present in the UWBZ at natural concentrations and if
dissolved, will migrate at rates similar to the groundwater velocity. Pesticides were not
detected in groundwater samples at concentrations above their MCLs and are not COCs
(HLA, 2000b). The data collected for the OU 6 RI/BRA was sufficient for characterizing
the nature and extent of contamination, conducting human health risk assessment, and
conducting the feasibility study. Information on groundwater flow rates is provided in
paragraph 5.2.3.2 Groundwater (page 5-25) and illustrations of groundwater flow
directions are found in Figure 3-10 (page 3-21) and Plates A-l, A-2, and 1-3 in
Appendix A of the RI/BRA for OU 6 (HLA, 2000b).
68. Comment: There's been almost no discussion about how offsite plumes are going to be
remediated or cleaned up, and that discussion needs to take place and be included in the
cost of the remedial options that are selected and the public needs a chance to comment
on the offsite proposal.
Response: Please refer to the responses to Questions 1, 24, 38, and 49.
69. Comment: Clearly, the offsite clean-up costs include more than just removal of the
contaminants, but also compensation of property owners who have been damaged by
the contaminants. Those costs need to be included as part of the feasibility study based
on the remedial options selected.
Response: Please refer to the responses to Questions 1, 24, 36, 37, and 38.
70. Comment: Whatever remedy it is that the Base plans to implement absolutely must
consider activities beyond the boundary of the Base. Thus far, none of them do. That
information has to be presented as part of the feasibility study before the citizens can
make any decision regarding which response action is truly appropriate. At this point,
we consider none of them to be appropriate, as none of them address any of the issues
off Base or fully delineate the contamination. This comment applies to off Base plumes
all around the Base.
Response: Please refer to the responses to Questions 1, 22, 24, and 38.
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71. Comment: If the Navy decides that the remedial action objectives on the Base are MCLs
and they're going to prevent their contaminants from continuing to migrate off Base,
and that's the Navy's property, but aOs to the off-Base property beyond the Navy's
boundary the citizens want their properties cleaned to background and don't want to
wait 20 or 30 years for it to happen.
Response: Please refer to the responses to Questions 2, 69 and 70.
72. Comment: I want the government to fund an ecological risk assessment which is
conducted in an independent investigation and not by some arm of the United States. I
want the investigation to also determine the relationship between groundwater and
surface water in the area. In fight of the geology, the numerous springs, wetlands,
surface water bodies, including Piney Woods Creek and Indian Lake Refuge, it just
makes no sense that an ecological risk assessment not be done simply because the Base
does not want to do one.
Response: Please refer to the responses to Questions 11,42, and 44.
73. Comment: Does the groundwater discharge to the Flint River? Does it discharge to or
come from the tributaries of the Flint River? The Base appears to be claiming that the
groundwater doesn't move at all and doesn't go anywhere nor come from anywhere.
Response: Please refer to the responses to Questions 42 and 44.
74. Comment: The document's entirely deficient regarding the mass of contaminants and
concentration of contaminants with depth. As many of these contaminants are sinkers or
heavier than water, has there been any characterization of the groundwater, the bottom
of the groundwater table, i.e., the top of the bedrock, and characterization of the bedrock
itself.
Response: Generally, contaminant concentrations increase with depth when the dense
nonaqueous phase liquid (DNAPL) of a cVOC is present. However, DNAPL has not
been found at the MCLB Albany PSCs (HLA, 2000b). Information characterizing the
lithology and hydrogeology has been provided in the RI/BRA for OU 6.
75. Comment: We don't believe that the Base has accurately estimated the volume of
contaminants in the groundwater. They keep saying the depth of contamination is
assumed constant along the length of the plume, but they don't discuss what happens
along the plume with depth. They mention preferential pathways vertically and
horizontally, presumably this is the reason for not using actual delineation data to
estimate plume volume.
Response: Please refer to the response to Question 60.
76. Comment: If the concentration sources and limits of the plume vertically and
horizontally were determined, more accurate plume volume could be estimated.
Wouldn't that solve the problem of whether linear interpolation or step wise
isoconcentrations had made any big difference in the amount of contaminants?
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Response: The plumes have been sufficiently delineated to proceed to the feasibility
study and remedy selection. Conservative volume and mass calculations (HLA, 2000a)
were made based on the data collected.
77. Comment: The very existence of the plume itself identifies that inorganics have
migrated from the Base's potential sources of contamination. The very existence of the
plumes shows that these other contaminants, chlorinated solvents, pesticides & organics
have migrated from the Base's potential sources of contamination. We do not
understand why the document continues to talk about how things may migrate and
how these are potential sources of contamination and has failed to discuss the
movement of these contaminants laterally and vertically under the ground.
Response: Characterization of chemicals and their distributions in OU 6 was provided in
Chapter 4 of the RI/BRA for OU 6 (HLA, 2000b). A discussion of the fate and transport
of these chemicals was provided in Chapter 5 of the OU 6 RI/BRA (HLA, 2000b).
Specifically, beginning on page 5-27 in paragraph Summary of Contaminant Fate and
Transport is a discussion of the fate and transport of organic and inorganics at the
Northern Plume Area, the DMA and PSC 4.
78. Comment: When the very existence of the plume proves that they have and are
migrating, we want to know where they're going, how fast they're moving there, and
how long they've been moving there and where they've been and it's not in the
documents.
Response: Please refer to the responses to Questions 48 and 77.
79. Comment: None of the risk documents seem to discuss the dermal exposure route as
part of the risk assessments. We want to see that in the document included for vinyl
chloride.
Response: Vinyl chloride exists as a gas. The most significant exposure is through
inhalation. Please refer to Volume IV, Appendix J of the RI/BRA (HLA, 2000b).
80. Comment: I want the Base to consider an iron filing trench for remediation or simply a
sheet barrier containment along the boundary of the Base to prevent the contaminants
from continuing to migrate off Base onto my property. Why hasn't that treatment option
been considered or implemented already?
Response: Please refer to the response to Question 1.
81. Comment: I do not object to the institutional controls and the necessity for an
impermeable cap, but if the Base is going to place an impermeable cap there make it
100% impermeable, make it out of concrete or asphalt, not some clay that's going to dry
out and accept water later; and in any event, I don't agree with any of these remedial
alternatives until the source areas are properly excavated and removed offsite for
treatment and disposal at a proper facility.
Response: Please refer to the response to Question 1.
82. Comment: If the idea on excavating waste is to simply run a TCLP or other analysis to
determine whether the landfill waste should go to a Subtitle C or D facility, then that
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characterization activity has to be done on a much, much smaller grid than they
proposed in order to avoid violating other laws by taking Subtitle C waste to a
Subtitle D.
Response: Please refer to the responses to Questions I, 4, and 24.
83. Comment: Has there been any sampling at all in any of the properties for landfill gas
control? And if so, why has that information and correcting that condition not been
presented in the RIFS or proposed plan?
Response: A description of the sampling of gases generated within the landfill was
provided in paragraph 4.1.7 Remedial Investigation Activities (1991 to 1999) (page 4-3)
of the RI/BRA for OU 6 (HLA, 2000b).
84. Comment: What gases were sampled and what were the concentration results?
Response: Please refer to the response to Question 83.
85. Comment: We know that the Base was conducting open burning activities even while
the sludge piles contaminated with PCBs was right there on top of PSC3. We know that
burning produces dioxin contaminants. Has there been any samplings for dioxin? And if
so, what were the results? If there hasn't been sampling, why not?
Response: Prescribed burns of forested areas were conducted in the PSC 3 vicinity.
Analysis for dioxins has not been conducted. Prescribed burns are not likely to produce
measurable dioxins from PCB-contaminated sludge at MCLB, Albany. No other sources
of dioxins have been identified at MCLB, Albany.
86. Comment: The introductory text needs to state with specificity what it is exactly the
Base is doing with its waste now. Apparently, in the years past, it's just been dumped on
property and buried in the ground. I'd like to know exactly where the hazardous wastes
are being disposed of now and who is overseeing that the disposal is proper.
Response: Please refer to the responses to Questions 12 through 17, and 20.
87. Comment: I believe that the DMA building is in the way of the clean up and should be
demolished and removed so that all the soil areas and leaking pipes and everything
beneath it can be removed and cleaned up and properly disposed of offsite. The Base
should build another DMA area in an uncontaminated portion of the facility, if they can
find one.
Response: Comment acknowledged.
88. Comment: I don't understand why the Base even bothers asking us what we think since
they are just going to continue with business as usual anyway and do whatever they
want.
Response: MCLB Albany is interested in your opinion and likes to keep the public
informed.
89. Comment: I am concerned that the Navy's lack of discussion of vinyl chloride, that
would be produced by their proposed remedy, was intentional and that I did not have
ample opportunity to discuss that issue at the public hearing because the Base didn't
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bring it up and because the toxicologist that the Base provided stood there at the public
meeting and said that vinyl chloride, a known carcinogen, wouldn't cause cancer and
that his baby could drink the water contaminated with it.
Response: Please refer to the responses to Questions 53, 55, 56, 64, and 79.
90. Comment: I think all of the issues from the public meeting need full airing and cannot
be determined such that we can comment on them until the Base has provided all the
information that should be provided to the public on the proposed remedy rather than
hiding that information from the citizens.
Response: MCLB Albany places documents pertaining to the CERCLA activities at a
Public Repository, which located at the Dougherty County Public Library, 2nd Floor,
Reference Section, 300 Pine Street, Albany, Georgia. The RI/BRA for OU 6, the FS for
OU 6 and the Proposed Plan for OU 6 are available at the Public Repository.
91. Comment: The Navy stated that natural attenuation data shows that mechanical and
biological fate and transport processes occur in the upper water-bearing zone and
mechanical state and transport processes occur in the lower water-bearing zone. The
Base needs to explain exactly what those fate and transport processes are; what
contaminants are being moved; where they are being moved from and to.
Response: This information is contained in Chapter 5 of the RI/BRA for OU 6 (HLA,
2000b).
92. Comment: Based on all the proposed remedies which appear not to identify the
timeframe in which they are going to be completed are we to understand that the MCLB
has just selected thirty (30) years without any basis other than EPA policy guidance?
Does that mean that the Base really does not know how long cleanup will take? Does
that mean that folks have to wait thirty (30) years for a remedy that the Base isn't sure
will correct the problems now? People should not have to wait thirty (30) years to find
out whether the remedy is going to be successful and whether the alternatives need to
be implemented- We want to see the Navy take actions now that we know will be
effective since we have already waited fifteen (15) years and they haven't done anything.
Response: Please refer to the response to Question 2.
93. Comment: Dig it up, take it away, treat it offsite site, install some barrier walls and some
impermeable caps. Protect human health and the environment Quit spending money
doing nothing.
Response: Please refer to the responses to Questions 1, 2, 5, 24, and 49.
94. Comment: The Base seems to have mistaken monitoring and drilling over 200 wells and
their sampling activities for reducing health risks to human health and the environment.
They seem to have been confusing that throughout the document and throughout the
past fifteen (15) years. It's warning the public, taking effective steps to limit or eliminate
the movement of contaminants that reduces risk, not simply endless sampling. When
the ship is sinking you can only bail for so long. At some point you have to abandon
ship.
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Response: The monitoring wells were a necessary part of the assessment of
contaminants in groundwater beneath MCLB Albany as a means to collect groundwater
samples that were used to characterize risk to human health. The CERCLA process at
MCLB Albany has been conducted under the oversight of USEPA and GEPD. MCLB has
undertaken actions such as the PSC 3 interim measure in an attempt to control the
migration of groundwater containing contaminants, and has attempted to minimize/
prevent exposure to groundwater by providing residents in the Ramsey Road area
access to city water.
95. Comment: The Base seems to want to select this remedy that they've got - the HRC
compounds or enhanced bioremediation - before it runs a pilot study to determine
whether that is going to work for the contaminants. This does not make sense since the
cost of the proposed remedy can only be within the range required for the FS and can
only be determined within the range required for the FS if there has been some pilot
study to determine effectiveness.
Response: Hydrogen Release Compound® (HRC) has been used successfully at other
sites to enhance the degradation of chlorinated solvents. The pilot study is required to
confirm that it will be successful and determine the spacing required for detailed design
and full-scale implementation at MCLB Albany. Also, please refer to the response to
Question 66.
96. Comment: In Appendix A, page I, the Base keeps talking about the calculation of the
volume of the plume. But all they give us is the area - 6.6 million square feet. I recollect
that volume is computed using 3 parameters. So there needs to be some depth
component. What depth component was used for the 6.6 million square feet; where did
it come from and how is it determined?
Response: Please refer to the response to Question 60. The calculations are provided in
the FS (HLA, 2000a).
97. Comment: Georgia law already requires that unlined landfills, like the ones that the
Base has, have to be capped and have an impervious surface. Please explain why the
government has spent millions to study doing what they already have to do under
Georgia law.
Response: The Base is participating in an Alternative Cover Assessment Program
(ACAP) to assess whether or not planted poplar trees can function as well or better than
a traditional clay cap. If successful, the tree cap will save several millions of dollars in
construction and maintenance costs. Georgia law also has a provision for installing
alternative covers that meet the requirements of a traditional cap. Also, please refer to
the response to Question 4.
98. Comment: The Base has said that the enhanced bio degradation by remediation will
rapidly oxidize DCE and VCE. Please identify how long rapidly is.
Response: Please refer to the responses to Questions 2, and 56.
99. Comment: The soil cleanup that should have already occurred as a result of all the
numerous rods and millions of dollars that has been spent has not sufficiently prevented
further contamination of ground water or air. This is apparent by the continued
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contamination of the ground water. I do not accept the remedy that has been proposed
by MCLB because it does not include removal and offsite treatment and disposal of the
soil sources which should have occurred long ago.
Response: Comment acknowledged. Also, Please refer to the response to Question 1.
100. Comment: I believe that the US MCLB should provide alternative water supplies to all
the populations that have to rely on the ground water around the Base now and in the
future. And that MCLB should pay for it. And that the feasibility study has neglected the
offsite impacts of the ground water and other contaminants released to the environment
by MCLB and is inadequate. I believe that containment at the edge of all the plumes,
preferably at the boundaries of the Base, to contain the contamination within the
boundaries of the Base should be required and should be a part of the feasibility study
and the cost for such containment should have been included.
Response: Comment acknowledged. Also, please refer to the response to Question 1.
101. Comment: I don't believe that the people most affected by MCLB's hazardous chemical
releases have been given an adequate voice in the CERCLA decisions at the Base over
the years that have continued to affect their lives. I believe that my community has been
consulted in only the slightest manner and has had to fight for information regarding
the implementation of all the activities of the Base.
Response: Comment acknowledged.
102. Comment: I think the Base has spent way too much time and money trying to determine
what to do with the site, including all this process we're going through now about
selecting a remedy under the guise of CERCLA when they really just wanted the
problem to go away without having to tell anybody.
Response: Comment acknowledged.
103. Comment: I think common sense could have told anybody fifteen (15) years ago that
they needed to remove the sources of the contamination, take them off site and dispose
of them, pump and treat the ground waters best they could and if they could contain the
hazardous chemicals on their property with some sheet pilings or some other methods
they should have done it already. I think it would be appropriate for the Base to be
considering a combination of treatment technologies rather than alternatives for
treatment technologies that appear to want to rely heavily in every single instance of
leaving the waste in place, having some kind of treatment which leaves the waste in
place and which puts some institutional controls or no action in place.
Response: Comment acknowledged. Also, The CERCLA process at MCLB Albany has
been conducted under the oversight of USEPA and GEPD. Please refer to the responses
to Questions 1 and 5.
104. Comment: I think for most of these to be effective they need to start with removal,
treatment and offsite disposal of the source areas and then look at what additional
treatment technologies including containment, institutional controls, and other things
that they should consider.
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Response: Comment acknowledged. Also, please refer to the responses to Questions I, 2,
5, 6, and 8.
105. Comment: Is it true that all the timelines that we see in the feasibility study for how long
it will take to clean up the property are just estimates and that no one really knows how
long to clean up?
Response: Comment acknowledged. Also, please refer to the responses to Questions I, 2,
5, 6, and 8.
106. Comment: What exactly are the future land uses contemplated for this property here in
the heart of Albany once the Marine Base is finished with it and leaves all their
contamination behind buried underground.
Response: There are no plans to change the land use. According to the Commandant of
the Marine Corps, there are no future plans for MCLB to leave Albany, GA.
107. Comment: There needs to be a definition of hot spot provided in the definitions of the
feasibility study and the proposed plan.
Response: An isolated area where contaminant concentrations are much higher than the
other samples.
108. Comment: Please explain why MCLB has, after fifteen (15) years and many, many
millions of dollars, still not delineated to background the vertical and horizontal extent
of all the plumes emanating from MCLB.
Response: Please refer to the responses to Questions 6, 8, 28, 29, and 48.
109. Comment: The Marine Base intends to put into perpetuity public land use controls on its
property that would then be sold to local residents or state or local government are
concerned that these land use controls in the long term will be ineffective and that the
better option, in addition perhaps, to include in the land use controls is to remove the
contaminants and dispose of the waste offsite.
Response: Comment acknowledged. Also, please refer to the response to Question 8.
110. Comment: Many of us here in the community do not trust that Harding Lawson &
Assoc. has taken steps that are in the interest of the public and the environment who
believe they have done whatever was necessary to hide the full extent of the
contamination and to ensure that their contract will be renewed and that they will
continue to receive work from the MCLB. Who has been checking the work of HLA and
what do they have to say about what the government has got for all its millions that has
been spent?
Response: HLA is subject to General Service Audits (GSAs) by the Federal Government,
and their work has been reviewed by the Navy, USEPA, GEPD, and USGS.
111. Comment: Why has all the written correspondence between the Marine Base and HLA
and other contractors for the Marine Base related to this site remediation not been
included as a part of the Administrative Record for the public to inspect and review?
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Response: The information is maintained in the Administrative Record, not the Public
Repository. The Administrative Record is maintained at MCLB Albany.
112. Comment: Why is it that no government official stepped in to say that Dr. Dulaney, the
Marine Bases toxicology expert or epidemiologist or whatever he was, was lying to us at
the OU 6 public meeting when he said that vinyl chloride doesn't cause cancer unless
you inhale it?
Response: Dr. Dulaney was explaining the amount of chemical it took to develop cancer.
He was not trying to hide the fact that vinyl chloride is a carcinogen. Also, please refer to
the human health toxicity profiles provided in Volume IV, Appendix J-3 of the RI/BRA
for OU 6 (HLA, 2000b).
113. Comment: Why is the Superfund NPL hazard ranking of the Marine Base never been
made available to the community so that they can understand the risks that made this
site a Superfund site all the way back in 1989? Can you provide those documents?
Response: Notice of the Superfund NPL Hazard Ranking was published in the Albany
Herald. Information pertaining to the CERCLA investigation at MCLB Albany is
maintained at the Dougherty County Public Library, 2nd Floor, Reference Section, 300
Pine Street, Albany, Georgia.
114. Comment: What exactly does the Base plan to do offsite where the contamination is
migrating. It's not mentioned anywhere in the feasibility study and apparently no funds
have been allocated for that purpose. Does the Base have an agreement with the Maple
Hill Landfill people that they don't have to clean up the proposed landfill property.
Doesn't the law require them to clean it up whether the landfill people agree or not?
Response: Please refer to the responses to Questions 2, 24, and 49.
115. Comment: Has the Base been involved in any dredging of Piney Woods Creek or
sampling of Piney Woods Creek and if so, why aren't the results included in the
feasibility study?
Response: There has not been any dredging of Piney Woods Creek by MCLB Albany.
Environmental samples (surface water and/or sediment) have not been collected during
the CERCLA investigation activities from Piney Woods Creek.
116. Comment: Where has it been provided as to what the wells were sampled for each time
they were sampled and the dates on which they were sampled? And where are the
analytical lab data sheets and chain of custody forms? They are not in the
Administrative Record anywhere.
Response: This information has been incorporated into Appendix G of the RI/BRA for
OU 6 (HLA, 2000b), and is available at the public repository.
117. Comment: It's apparent that after many millions of dollars and many, many years, the
Base still doesn't have the data necessary to support or defend this regulatory decision
that it's trying to make on this proposed remedial design for OU 6. We don't believe the
site has been properly characterized, we believe that monitoring wells have been placed
in the wrong locations, not in enough locations. We don't believe that the proper
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samples have been taken with enough frequency or that the proper chemicals have been
tested for. In addition, we believe the data interpretation and data use are skewed to the
benefit of the Base.
Response: Comment acknowledged.
118. Comment: The feasibility study and proposed plan just summarize how little is known
about the ground water conditions beneath the Base and how lax the monitoring that
has not been done or that has been done has been done poorly or the data that has not
been collected or if it has been collected has not been reported, or the data that has been
reported hasn't been usable or not acted upon or even lost or hidden from us.
Response: Please refer to the responses to Question 6, 9, 28, 33,48, and 77.
119. Comment: The institutional controls and no action controls that the Base has been
relying on so heavily ever since it's been on the NPL is only supposed to be a
supplement to the engineering controls. Engineering controls are supposed to be the
primary methods, they are supposed to clean it up, treat it, properly dispose of it and
use institutional controls in supplement of that Isn't that correct?
Response: Please refer to the response to Question 8.
120. Comment: Feasibility study nowhere says what the time frame is to return the ground
water to beneficial drinking water use. That time frame needs to be stated specifically in
the document.
Response: The Feasibility Study gives estimates of timeframes for clean up in Chapters 4
and 5 (HLA, 2000a). Also, please refer to the response to Question 2.
121. Comment: I think the Base should conduct an ecological risk assessment because by not
doing so they are just again telling the community that there is no problem. Let's not
forget that this is a Superfund site. If there was no problem it wouldn't be a Superfund
site.
Response: Please refer to the responses to Question 11 and 44.
122. Comment: I don't believe that the Base presented enough remedial alternatives for the
people to consider. And the ones they did present they don't know if they are going to
work. I don't agree with the proposed plan.
Response: Comment acknowledged. Also, please refer to the responses to Questions 1,5,
and 49.
123. Comment: We've heard from all the scientists at the public meetings that none of the
contaminants at MCLB bio-accumulate. Is this true? I thought lead bio-accumulated, and
if it does, why hasn't there been any studies of the wildlife populations or the human
populations around the Base to determine whether lead is bio-accumulating? Also, do
PCB's bio-accumulate? And what other chemicals that MCLB has released are
bio-accumulating and has there been a study to determine whether that's happening in
our communities.
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Response: The COCs, which are chlorinated solvents, do not appreciably bio-
accumulate. Contaminants that are known to bio-accumulate, such as lead in some
organisms and PCBs, were evaluated in RI/BRAs for OUs 1 through 5 ((ABB-ES, 1992;
ABB-ES, 1995; ABB-ES, 1997a; ABB-ES, 1997c; and ABB-ES, 1998).
124. Comment: I don't see how leaving the wastes in place protects the human health and the
environment. I don't care what the Base says. I also don't see how leaving the wastes in
place is effective in the long or the short term, particularly since none of the waste in the
ground is treated and the landfills are unlined I don't understand why the people at
MCLB are debating whether they should put a cap on the landfill when common sense
tells you, you don't want the water running down through the ground. I don't want my
future health and safety to have to rely on plants to pull water up out of the ground. I
want the Base to remove the contamination, treat it and take it away.
Response: Comment acknowledged. Also, please refer to the responses to Questions 1
and 5.
125. Comment: I hope that whatever they plan to do finally, they are going to give us
another opportunity to talk about it, and comment on it because I don't trust anything
they've done so far because they've tried to sneak it by us and then ram it down our
throats.
Response: The Proposed Plan comment period was extended at the request of the
community.
126. Comment: Will there be an additional comment period where we have an opportunity
to ask more questions after you respond to these?
Response: USEPA and GEPD indicate that there will not be any other extension to the
comment period.
127. Comment: I want the Base to explain what the vinyl chloride scare is and why it is they
wouldn't talk about it at the public meeting. They should be able to tell us how much
vinyl chloride will be produced and for how long.
Response: Please refer to the responses to Questions 34, 35, 55, 56, 57, 64, 79, and 89.
128. Comment: There should be a computation based on the amount of PCE and TCE
already present in the ground water as to how much vinyl chloride will be produced.
Response: Calculations for the volume of the contaminant plumes are provided in the FS
(HLA, 2000a). Also, please refer to the responses to Questions 2 and 56.
129. Comment: Is it true that vinyl chloride is more mobile and more toxic than it's parent
products PCE, TCE and DCE?
Response: Vinyl chloride has only been detected in the groundwater samples collected
from the UWBZ at PSC 1 and the DMA. Vinyl chloride has not been detected in the
LWBZ groundwater samples (HLA, 2000b).
130. Comment: Is it true that the use of the hydrogen release compounds or the accelerated
bio-remediation is only really effective if the sources have been removed?
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Response: Please refer to the responses to Questions 4, 5, 24,49, and 56.
131. Comment: If the Base was only going to cleanup the groundwater to MCLs anyway,
why bother with the baseline risk assessment? They spent millions for nothing.
Response: The BRA is required by CERCLA. The BRA is an integral part of the CERCLA
remedial decision process in determining whether or not remediation is required.
132. Comment: Why is it that the feasibility study presents no data and neither does the
administrative record of the results of sampling of the water supply wells on the Base?
Please explain how it is that the controls that the Base is talking about or the proposed
plan is protective of those water wells on the Base that supply the Base?
Response: The FS summarizes the data presented in the RI/BRA for OU 6 (HLA, 2000b).
Also, please refer to the responses to Questions 40, 46, and 48.
133. Comment: Dr. Dulaney said at the public meeting that solvents don't bio-accumulate
but he didn't talk about pesticides and PCB's. Is it true that they do bio-accumulate and
if so, what studies have been done to determine whether MCLB's releases of pesticides
and PCB's are bio-accumulating in our community.
Response: Please refer to the responses to Questions 32, 59, 67, and 123.
134. Comment: Please explain exactly how it is that the Base has gone about horizontal and
vertical delineation of contaminants at MCLB and why it is that the procedure has yet to
result in complete delineation of contaminants.
Response: Please refer to the responses to Questions 6, 48 and 74.
135. Comment: Was a risk assessment performed for VOCs only? Or was it also performed
for all the other contaminants that were found in ground water?
Response: The risk assessment was conducted on VOCs, semivolatile organic
compounds, and inorganics. The list of chemicals evaluated during the BRA is provided
in Tables 6-3 and 6-4 in pages 6-14 through 6-19 (HLA, 2000b).
136. Comment: Was a risk assessment performed for vinyl chloride?
Response: Yes, please refer to the responses to Questions 34 and 135.
137. Comment: Did the baseline risk assessment consider any degradation products of the
cleanup processes that are now being considered in the proposed plan?
Response: Yes, please refer to the responses to Questions 34 and 135.
138. Comment: Why haven't the results of Piney Woods Creek and Man Lake sampling
sediment and surface water been released as a part of any of the documents in the
administrative record? All we hear is that the contaminants were not significant or
didn't pose a risk. Why hasn't that information been released? It is virtually impossible
to comment on the plan they proposed when they haven't released all the information
necessary to tell us where the contamination is.
Response: Please refer to the responses to Questions 11 and 44.
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139. Comment: The documents don't have a total cost in there, which doesn't make any
sense. I thought the point of the feasibility study was to tell us what it could cost. Why is
that information not included. I think the Base needs to consider more alternatives than
they have identified.
Response: Total costs for individual technologies are presented in Chapter 4 and
summarized in Chapter 5. Each PSC may incorporate one or more technologies in the
final remedy. Because of the large number of possible combinations, the FS does not
attempt to cost each possible combination. Total costs for each area are provided in the
Proposed Plan and ROD. The FS has evaluated a broad range of technologies as required
by CERCLA guidance.
140. Comment: How is the Base dealing with the issue of the current drought and how it's
going to continue to crack clay caps? It doesn't make any sense to put down a half-assed
impermeable barrier, such as a clay cap where you have to depend on nature and other
natural conditions to keep it in an impermeable state rather than cracked wide open. If
they are going to put down an impermeable cap, make it asphalt, make it something
where they can really control it. We are not interested in continuing to pay taxpayer
dollars to line Harding Lawson & Associates pockets. We want the contaminants
removed, treated offsite, disposed of offsite.
Response: Please refer to the responses to Questions 1, 4, 24, and 97.
141. Comment: Didn't the OU1 treatability study for Operable Unit 1 that was completed in
April of 1997 already determine that what the proposed plan is planning to do is not
effective? And, if so, how, is it possible that that proposed plan has come out with
injecting these chemicals into the subsurface as the best means of remediating the site?
Response: The treatability study for OU 1 consisted of a single recovery well, and
treatment of the recovered water using a rotating biological contractor. Results from the
treatability study suggest that the low transmissivity and sustainable pumping rates
combined with the results of the tracer test indicate that the low permeability and
preferential flow paths make contaminant recovery and tracer migration difficult to
predict and/or control (HLA, 2000b).
142. Comment: Have MCLB's contaminants moved onto the Firestone Tire and Rubber
Company property? If so, in what amounts? And what contaminants and why has that
not been addressed in the OU 6 documents? Does the Base have any agreements with
Firestone about the contamination? I'm asking about surface water and ground water.
Response: Interpretation of the most recent data collected in 1999 (HLA, 2000b), suggests
that the highest detected concentrations of cVOCs off Base were in groundwater samples
collected from the Cannon property, located to the west of the Ramsey Road residential
area. This is consistent with potentiometric surface maps prepared by the USGS. Based
on the USGS information, the Firestone Tire and Rubber Company (Firestone) property
(now Cooper Tire) is not located hydraulically downgradient from the Base, this
interpretation also applies to the Sylvester and Branch Road areas (US Geological Survey
[USGS], 1999). Also, based on this map, flow paths for the Ramsey Road residential area
appear to be parallel (side gradient) to MCLB Albany, please refer to Figures 12 and 13
on pages 26 and 27 of the USGS report entitled Hydrogeology of the Upper Floridan
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Aquifer in the Vicinity of the Marine Corps Logistics Base Near Albany, Georgia (USGS,
1999a). Based on this information there was no need to address the Firestone site in the
RI/BRA for OU 6. However, information regarding the Firestone site was provided in
paragraph 3.5.3.5 Firestone in the RI/BRA for OU 6 (HLA, 2000b).
MCLB Albany has not made any agreements with either Firestone or Cooper Tire.
143. Comment: Isn't the ground water that gets into the depressions and wetland areas all
over the Base and all over the property north of the Base, isn't that considered discharge
of contaminants to surface water? And isn't that discharge irrespective of the amount of
contaminants that have gotten there? Why haven't we seen the results of the surface
water sampling from all over the Base and from any properties off-Base?
Response: Land surface elevations at MCLB Albany range from approximately 185 to
280 feet above the National Geodetic Vertical Datum (also known as mean sea level
[msl]). Groundwater occurs at approximately 130 feet msl where the land surface is
approximately 185 feet msl and at approximately 245 feet msl where the land surface is
approximately 280 feet msl (HLA, 2000b). Thus, groundwater occurs approximately 35
to 55 feet beneath the land surface at MCLB Albany. The depressions and wetlands are
recharge areas for groundwater not discharge areas. Surface water sampling events were
not part of the investigation of groundwater (OU 6), but were characterized in the
investigations of OUs 1 through 5 (ABB-ES, 1992; ABB-ES, 1995; ABB-ES, 1997a; ABB-ES,
1997c; and ABB-ES, 1998).
144. Comment: Has the Base done any sampling off-Base of properties in the Ramsey Road
area neighborhood without sharing those results with the community? Why haven't we
seen the results of any soil sampling from off Base?
Response: Please refer to the responses to Questions 11, 22, 23, 24, 25,42, and 46.
145. Comment: I believe that the feasibility study and proposed plan have been prepared
prematurely. A proposed plan should only be prepared when the assessment phase has
been adequately completed and that's critical so that the area to be remediated can be
known prior to the design and selection of a remedy. It is difficult to tell but it appears
some of the highest concentrations of contaminants are found at depths perhaps near the
top of bedrock. Please tell us what the depths to bedrock are. And at what depth the
highest contaminants have been found. If there is, in fact, a plume on top of bedrock it
hasn't been complete delineated and assessment is not complete. And the bedrock
aquifer hasn't been assessed. Please comment.
Response: This information was provided in chapters 3, 4, and 5 of the OU 6 RI/BRA
(HLA, 2000b). Also please refer to Plates A-l through A-3 in Appendix A of the RI/BRA
for OU 6 (HLA, 2000b).
146. Comment: I'm concerned that the proposed plan doesn't address the source area in
terms of removing for offsite treatment and disposal of the contaminants. Such removal
action would maximize the effectiveness, of the remediation effort and prevent further
recontamination.
Response: Comment acknowledged. Also, please refer to the response to Question 1.
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147. Comment: The proposed plan puts forward a remediation process which, if successful,
will result in the production of vinyl chloride, a highly toxic chemical and known
carcinogen. This doesn't make any sense when we know that the use of physical and
other processes, engineering controls, would generally avoid producing vinyl chloride
and would result in a safer remediation process with a known time to complete.
Response: Comment acknowledged. Also, please refer to the responses to Questions 34,
35, 56, and 57.
148. Comment: Isn't it true that the chemicals you plan to place in the holes to make the
enhanced bio-remediation work have a very limited radius of influence? I don't believe
that the spacing that you've proposed is going to be tight enough to influence the zone
effectively in the soils, particularly in the soils that the MCLB has and particularly in
light of the fact that the landfill is supposedly full of all types and manner of other trash
and is not simply dissolved contaminants in water and soil. It is my opinion that the
sources of ground water pollution at the MCLB property should be excavated and taken
off site for treatment and proper disposal outside of the community.
Response: Previous pilot scale studies and the PSC 3 Interim Corrective Measure (ICM)
have demonstrated that the low permeability and preferential flow paths make
contaminant recovery and tracer migration difficult to predict and/or control (HLA,
2000b) are reasons this method was selected. The lactic acid produced from the HRC
should take the same flow paths as the contaminants. A pilot study will be conducted to
further characterize and refine the injection spacing for the detailed design phase. The
ET cap is proposed as the method to minimize/prevent the infiltration of surface water
through the landfill and vadose zone above the groundwater (HLA, 2000b).
149. Comment: I disagree with the plan that the MCLB has proposed because I think it is
based on a lack of information and a rush to do something after they have done nothing
for years and years in an attempt to justify the millions of dollars that has been wasted.
Response: Comment acknowledged. Information on the CERCLA activities at MCLB
Albany is maintained at a Public Repository, located at the Dougherty County Public
Library, 2nd Floor, Reference Section, 300 Pine Street, Albany, Georgia.
150. Comment: I believe the MCLB should buy all the water wells belonging to people
around the Base, and then close them.
Response: Please refer to the responses to Questions 36 and 37.
151. Comment: Why have timber management controlled burns continued to be allowed on
locations where landfilling has taken place? Please explain how controlled burns in
those areas are anything other than attempts to reduce the contaminant levels found in
the surface soil under the guise of timber management.
Response: Please refer to the responses to Questions 15 and 16.
152. Comment: Why is it after millions of dollars and all the wells and activity that the Base
has been involved in, the maps that is has produced with the question marks appear to
say that the Base doesn't even know what the depth of the ground water is?
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Response: It is a common practice when identifying contours that have been
interpolated between monitoring well locations to use dashed lines and/or question
marks.
153. Comment: It appears that the results from the top of the ground water, where ever that
might be, have been mixed with the sample results from at depths in the aquifer. This
produces a faulty delineation doesn't it?
Response: The UWBZ and LWBZ have different hydrogeologic characteristics.
Potentiometric surface maps and isoconcentration maps (Plates A-l through A-3 in
Appendix A of the RI/BRA for OU 6 [HLA, 2000b]) were constructed using the
appropriate zone in which the monitoring well was screened. It is common practice to
make such an interpretation.
154. Comment: It does not seem appropriate to mix the results you've gotten from the top of
the groundwater surface and at deeper locations when the objective is to properly
delineate the plume to background horizontally and vertically in all directions.
Response: Please refer to the response to Question 153.
155. Comment: Can you please explain the large photograph that you had at the public
meeting which you said showed all the hits above MCL that the Base had found and any
of its monitoring wells. First, what were the dates of the sampling? Was that all the way
back since 1985 or before or some other dates and is it all the way current up to present
day? Second, is it all contaminants or is it just the chlorinated solvents. Third, hits above
MCL for methyl chloride were found in private wells at the south end of Ramsey Rd.
Why haven't they been included?
Response: Please refer to the response to Question 45.
156. Comment: Why does the Base focus so on the chlorinated solvents and ignore the other
contaminants.
Response: COCs are defined as those chemicals associated with a cancer risk greater than
IxlO6 and/or a hazard quotient greater than 0.1 and exceeding the primary MCL (as
determined in the risk assessment). The COCs within the seven groundwater plumes
typically include cVOCs (e.g., TCE) and inorganics. The specific COCs within each plume
are as follows:
• PSC1 UWBZ: cis 1,2-DCE, methylene chloride, TCE, vinyl chloride, and
antimony;
PSC 3 UWBZ: cis-l,2-DCE, PCE, and TCE;
• PSC 26 UWBZ: carbon tetrachloride, chloroform, and TCE;
• DMA UWBZ: 1,1-DCE, cis-l,2-DCE, benzene, methylene chloride, TCE, vinyl
chloride, antimony; arsenic, cadmium, and thallium;
NPA LWBZ On-Base : cis-l,2-DCE, PCE, and TCE;
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• NPA LWBZ Off-Base Current: 1,2-DCE (total), cis 1,2-DCE, carbon tetrachloride,
chloroform, PCE, and TCE;
• NPA LWBZ Off-Base Future: 1,2-DCE (total), cis 1,2-DCE, carbon tetrachloride,
chloroform, PCE, TCE, antimony, and thallium (HLA, 2000b).
A discussion of the fate and transport of these chemicals was provided in Chapter 5 of
the OU 6 RI/BRA (HLA, 2000b). Specifically, beginning on page 5-27 in paragraph
Summary of Contaminant Fate and Transport is a discussion of the fate and transport of
organic and inorganics at the Northern Plume Area, the DMA and PSC 4.
157. Comment: I don't accept the governments proposed remedy because I believe that they
are just going to waste millions, millions more dollars without really doing anything to
clean up the contamination or protect me and my family.
Response: Comment acknowledged. Also, please refer to the responses to Questions 46,
and 94.
158. Comment: Why haven't the surface water drains leading from MCLB been identified?
Response: The majority of the surface water runoff from the Base exits the facility via the
Marine Corps Canal. Other surface water drainage flow paths exiting the Base are
shown on Figure 3-5, page 3-9 in the RI/BRA for OU 6 (HLA, 2000b).
159. Comment: Please explain the regulatory process by which OU 6 was established and
identify the person who signed off on this establishment and list the documents which
show how, why and when it was established.
Response: The decision to treat groundwater as a single OU is discussed in Section 2.2,
Page 2-6, of the RI/BRA for OU 6 (HLA, 2000b). Information on the CERCLA activities
at MCLB Albany is maintained at a Public Repository, located at the Dougherty County
Public Library, 2nd Floor, Reference Section, 300 Pine Street, Albany, Georgia.
160. Comment: I trust that many efforts have been made to resolve many of the
environmental problems at MCLB but I do not trust that those who have been involved
are sure of what they have been doing! It is apparent that in order to conceal "lack of
ability" it serves MCLB to "deny knowledge, plea of I don't know, or we are working on
that the results will be out soon, we expect any day, the water is safe to drink, and you
must be mistaken!" But the best one I have enjoyed hearing is "the captain is no longer
here, the Lieutenant is gone, the Major is leaving, and the man to take my place has no
environmental training"!
Response: Comment acknowledged.
161. Comment: Did the US EPA Region IV or GA EPD object in writing, to delaying the
groundwater OU 6 to last? Who at MCLB addressed delaying the groundwater OU 6
with US EPA and GA EPD. What year was the decision made to delay the OU
groundwater remediation until last?
Response: The decision to treat groundwater as a single OU is discussed in Section 2.2,
Page 2-6, of the RI/BRA for OU 6 (HLA, 2000b).
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162. Comment: Woodward Clyde Consultants were hired by Bridgestone/Firestone as
contractors for the Bridgestone/Firestone Superfund site, yet data compiled by
Woodward Clyde Consultants has been a part of the RI/BRA. Who did the MCLB
appoint to validate Woodward Clyde's data and was the data current?
Response: Information regarding the Firestone site was provided in paragraph 3.5.3.5
Firestone in the RI/BRA for OU 6 (HLA, 2000b) to support findings at MCLB Albany by
including data that describes a similar hydrogeologic setting at a nearby facility.
Woodward Clyde conducted their assessment and remediation activities under the
oversight of the USEPA and GEPD. Their reports were reviewed and approved of by
USEPA and GEPD.
163. Comment: Who is CH2MHill/ what role did they play?
Response: CH2MHill has been contracted by SOUTHNAVFACENGCOM in North
Charleston, South Carolina, as the Remedial Action Contractor (RAC). They will be
conducting the pilot study, preparing the detailed design and implementing the design.
164. Comment: Where can I find a copy of all of the RFPs, regarding McClellan Engineering,
ABB, Harding Lawson, Bechtel Environmental, Transwaste, Oxford Construction Co,
CH2Mhill, and Rust Environmental?
Response: Information on the CERCLA activities at MCLB Albany is maintained at a
Public Repository, located at the Dougherty County Public Library, 2nd Floor, Reference
Section, 300 Pine Street, Albany, Georgia.
165. Comment: Where are the contracts for MCLB initiated?
Response: Contracting for the Comprehensive Long-term Environmental Response
Navy (CLEAN) and RAC programs is by SOUTHNAVFACENGCOM, North
Charleston, South Carolina.
166. Comment: Harding Lawson has identified four other Military Installations in the RI/Bra
that citizens in other locations have had to resort to hiring "an expert" to serve as a
community liaison. Why did MCLB fail to inform us that in order to communicate
concerns in public availability sessions, the community is required to provide "an
expert" to relay their concerns?
Response: The expert is not hired to communicate your concerns, but is to assist you in
the understanding of information presented in the CERCLA process.
167. Comment: What physical changes to the limestone has been after being exposed to the
hazardous chemicals and acids over the past 20 years?
Response: Changes to the limestone have not been observed.
All public comment sheets are typewritten with the following comment: "My comment is
that the sources of groundwater pollution at the U.S. MCLB property should be excavated
and taken offsite for treatment and proper disposal outside of our communities." A sample
is provided following these responses.
168. Public Comment Sheet: Response: Please refer to the response to Question 1.
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169. Public Comment Sheet: Response: Please refer to the response to Question 1.
170. Public Comment Sheet: Response: Please refer to the response to Question 1.
171. Public Comment Sheet: Response: Please refer to the response to Question 1.
172. Public Comment Sheet: Response: Please refer to the response to Question 1.
173. Public Comment Sheet: Response: Please refer to the response to Question 1.
174. Public Comment Sheet: Response: Please refer to the response to Question 1.
175. Public Comment Sheet: Response: Please refer to the response to Question 1.
176. Public Comment Sheet: Response: Please refer to the response to Question 1.
177. Public Comment Sheet: Response: Please refer to the response to Question 1.
178. Public Comment Sheet: Response: Please refer to the response to Question 1.
179. Public Comment Sheet: Response: Please refer to the response to Question 1.
180. Public Comment Sheet: Response: Please refer to the response to Question 1.
181. Public Comment Sheet: Response: Please refer to the response to Question 1.
182. Public Comment Sheet: Response: Please refer to the response to Question 1.
183. Public Comment Sheet: Response: Please refer to the response to Question 1.
184. Public Comment Sheet: Response: Please refer to the response to Question 1.
185. Public Comment Sheet: Response: Please refer to the response to Question 1.
186. Public Comment Sheet: Response: Please refer to the response to Question 1.
187. Public Comment Sheet: Response: Please refer to the response to Question 1.
188. Public Comment Sheet: Response: Please refer to the response to Question 1.
189. Public Comment Sheet: Response: Please refer to the response to Question 1.
190. Public Comment Sheet: Response: Please refer to the response to Question 1.
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Community Comments on Feasibility Study and
Proposed Plan for Operable Unit 6
MCLB Albany, Georgia
August 30,2000
1. Comment: The RI and the FS have done an incomplete job of characterizing the nature
and extent of groundwater plume resulting from activities at the MCLB.
Response: GEPD and USEPA have provided oversight of the CERCLA process at MCLB
Albany and have reviewed and approved documents prepared for the CERCLA
investigations. Additionally, the USGS has conducted an evaluation of the Upper
Floridan Aquifer in the vicinity of MCLB Albany (USGS, 1999a). Their findings
corroborate the hydrogeological information presented in the RI/BRA for OU 6 (HLA,
2000b). The data collected for the OU 6 RI/BRA was sufficient for characterizing the
nature and extent of contamination, conducting human health risk assessment, and
conducting the feasibility study.
2. Comment: The Northern Plume Area that comprises of PSC 1, PSC 3 and PSC 26 are
immediately adjacent to the Ramsey Road residential neighborhood. In sampling efforts
as recent as 1999, carcinogenic chemicals such as Vinyl chloride, trichloroethylene,
methylene chloride, carbon tetrachloride, toluene, chloroform etc. have been found at
very high concentrations at a very high frequency of detention in the northern plume
area. For example maximum detected concentration of -vinyl chloride, a known human
carcinogen, has been 710 micrograms/ liter and TCE an other known human carcinogen
was detected at a maximum concentration of 460 micrograms/liter and at a frequency of
35 out of 59 samples. It is important to note that all these contaminants were detected in
the upper aquifer. The Base was fully aware that many of the residents of the Ramsey
Road have drinking water wells in the upper aquifer and yet the Base and its contractors
made no effort to warn these residents about the situation.
Response: The UFA has two zones: the UWBZ and the LWBZ. The low permeability of
the UWBZ does not yield sufficient water for a residential water supply well. The
producing zones for the residential water supply wells in the Ramsey Road
neighborhood is the LWBZ (USGS, 1999b). Analytical results for monitoring wells
screened in the UWBZ and LWBZ in the vicinity of the Northern Plume Area are
provided in Tables 4-3 and 4-6 of the RI/BRA for OU 6 (HLA, 2000b). The frequency of
detection and maximum detected concentrations for PCE, TCE, and cis 1,2-DCE are
higher for groundwater samples collected from wells screened in the UWBZ relative to
those screened in the LWBZ. Vinyl chloride has been detected at low frequency of
occurrence in groundwater samples collected from wells screened in the UWBZ relative
to TCE, and cis 1,2-DCE. It is important to note that vinyl chloride has not been detected
in any of the groundwater samples collected from monitoring wells screened in the
LWBZ. MCLB Albany has provided residents in the Ramsey Road area access to city
water in 1994 and 1999, and in 1999 offered to abandon residential water supply wells to
prevent their future use. MCLB Albany has held Public Meetings to inform citizens of
the CERCLA investigation activities at MCLB Albany.
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3. Comment: Many of the same contaminants that were detected in the upper aquifer
under the Northern Plume Area were also detected in the lower aquifer. The
government has known for years that residents around the Base have been drinking
water from the aquifer and yet no effort to warn these residents.
Response: Please refer to the response to Question 2.
4. Comment: The BRA performed as part of the RI did mention the Ramsey Road residents
as potential receptors. But it is noteworthy that basis for evaluating their risk was
sampling data from one well from a location 1/3 mile to the west of Ramsey Road on the
Base. If the Base were truly interested in ascertaining the true risk to the citizens living
around the Base and protecting them it would have identified where the wells are
around the Base and would have data from repeated long-term sampling of all the wells
rather than the giant data gap it now has.
Response: There have been a number of sampling events conducted of residential water
supply wells by USEPA, beginning in November 1993. Out of these events, only one
volatile organic compound, methylene chloride, was detected above its Federal MCL of
5 micrograms per liter (|j,g/L). Methylene chloride was detected at 5.8 (J,g/L. Subsequent
sampling events by USEPA have not confirmed this result. Therefore it is believed to be
a laboratory artifact. The detection of bis(2-ethylhexyl)phthalate in the Solomon's well is
also a field or laboratory artifact. Bis(2-ethylhexyl)phthalate is not a COC for
groundwater. GEPD required MCLB Albany to provide water to residences in the
Ramsey Road area to prevent the possibility of exposure (MCLB cannot prevent
residents from using their water supply wells), not because of these chemicals exceeded
their respective MCLs.
5. Comment: In spite of all the above weaknesses in the data and methodology, the cancer
risk for the Ramsey Road residents is already at the upper limit of the USEPA cancer risk
(1 in 10,000) range of 1/10,000 to 1/1,000,000. It is very likely that if the BRA were
conducted in a more scientific way using site-specific data and realistic information, the
true cancer and noncancer risks would be exposed. But then all would know that the
limits were exceeded and that the risk is unacceptable and indefensible.
Response: Households may use water for many purposes, including water for drinking,
cooking, bathing, dishwashing, cleaning, car washing, clothes washing, swimming pool
supply, and irrigation. The possible exposure routes associated with each of these water
uses include ingestion, dermal contact, and vapor inhalation. However, the exposure
pathways that contribute the majority of potential exposure include:
• ingestion of water as tapwater
• inhalation of vapors released from water during bathing, dishwashing, and
cleaning
• ingestion of water during swimming
• dermal contact with water during swimming
• inhalation of vapors released from water during irrigation, and
• ingestion of COPCs that may bioaccumulate in vegetables following irrigation.
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Of these potential exposure pathways, ingestion of water as tapwater and inhalation of
vapors released during household water use are considered the most substantial exposure
pathways. However, to provide a conservative assessment of possible groundwater uses
and exposures, each of these exposure pathways is evaluated for off-Base use of
groundwater associated with the Northern Plume Area (NPA) LWBZ plume (HLA, 2000b)
The cancer risk for current potable use of groundwater for the off-Base NPA LWBZ
plume, assuming exposure through all pathways described above, is IxlO4 for an
aggregate resident (combined adult and child). This cancer risk is at the lower limit of the
USEPA acceptable risk range of 1x106 to 1x1 CH. The primary risk contributors are PCE
(70%), carbon tetrachloride (20%) and TCE (10%). The noncancer risks associated with the
current potable use of groundwater for the off-Base NPA LWBZ plume are an HI of 2 for
an adult resident and 3 for a child resident. These noncancer risks exceed the USEPA
target HI of 1. However, the majority of non-cancer risk is associated with ingestion of
groundwater as drinking water. For the adult resident, no single exposure pathway is
associated with an HI above 1; the total HI for all exposure pathways other than drinking
water ingestion is less than 1. For the child resident, only the drinking water ingestion
pathway is associated with a HI greater than 1 (HI of 2); the HI for all other exposure
pathways is less than 1. The primary contributors to non-cancer risk are carbon
tetrachloride (30%), cis-l,2-DCE (20%), TCE (20%) and PCE (10%); no individual hazard
quotients exceed 1 (HLA, 200b).
6. Comment: In light of the above mentioned serious shortcomings in the Base's RI and FS
efforts, it is my scientific conclusion that the Base has made every effort not to address
the impact of its activities including the risk it poses to the citizens living on and around
the Base.
Response: Comment acknowledged.
7. Comment: I do not think the proposed response actions of enhanced bioremediation for
the groundwater and the untested methodology of ET cap for source control should be
approved at this time. Even the regulators don't believe that the proposed plan will
work because they have required alternative remedies for when the proposed plan fails.
I think a remedy in which everyone has high confidence in the probability of success is
the remedy that should be selected and that is at a minimum implementation of the
backup plan following removal, treatment and offsite disposal of the waste sources.
Response: Comment acknowledged.
8. Comment: Since the government has done nothing for so long I think they should not
now be allowed to select the proposed groundwater remedy unless they do it after
digging up the waste sources, treating the waste and properly disposing of it elsewhere
in a permitted facility.
Response: Comment acknowledged.
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9. Comment: Why has no soil gas or volitization data been measured, presented or
proposed either for the existing contaminants or in the proposed plan after the vinyl
chloride is produced.
Response: A description of the sampling of gases generated within the landfill was
provided in paragraph 4.1.7 Remedial Investigation Activities (1991 to 1999) (page 4-3) of
the RI/BRA for OU 6 (HLA, 2000b).
10. Comment: Why has the Base not publicly responded to any of the public comments
already?
Response: At the request of the community, USEPA and GEPD agreed to extend the
Public Comment Period, but not to add another comment period. The response to
community comments will be included in the Responsiveness Summary section of the
OU 6 ROD.
11. Comment: How is it that the Base could for years violate the public's rights to comment
on the investigation and cleanup by hiding the problems and not releasing groundwater
data or not taking samples, and now claim to have properly completed the RIFS and
BRA when it still does not know where the contamination is?
Response: Between 1992 and 1995 there was little, if any, public interest expressed by the
community in the CERCLA investigation activities at MCLB Albany. The Public Water
Supply meeting held January 31,1995 sparked some interest by the community. The
public became more involved in 1997 when the Ramsey Road area citizens formed the
East Albany Against Garbage Landfill Expansion (EAAGLE) to contest the landfill
proposed on the Canon Property, which was located to the west of Ramsey Road.
Throughout the program, information on the CERCLA activities at MCLB Albany has
been maintained at a Public Repository, located at the Dougherty County Public Library,
2nd Floor, Reference Section, 300 Pine Street, Albany, Georgia. The RI/BRA for OU 6, the
FS for OU 6 and the Proposed Plan for OU 6 are available at the Public Repository.
12. Comment: How is it that millions of taxpayer dollars have been spent (wasted) and the
groundwater and soil is still just as polluted as it was before the money was spent?
Response: The 26 PSCs were grouped into six OUs based on their proximity, similarity
of contamination, and similarity of investigative techniques. Fourteen of the PSCs were
addressed under the CERCLA process, 10 PSCs were evaluated through screening
activities, and 2 PSCs were addressed under RCRA. Significant progress was made at
MCLB, Albany over the last few years. Below are the final RODs signed for five of the
six OUs at the Base:
OU 1 ROD (ABB-ES, 1997b), signed in August 1997;
• OU 2 ROD (ABB-ES, 1996), signed in September 1996;
OU 3 ROD (ABB-ES, 1997d), signed in August 1997;
• OU 4 ROD (HLA, 1999b), signed in January 1999; and
• OU 5 ROD (ABB-ES, 1997e), signed in December 1997.
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Initially, characterization of the groundwater at MCLB, Albany was conducted on an
individual PSC or OU. However, after evaluation of data from several OUs,
SOUTHNAVFACENGCOM and MCLB, Albany recommended to the Georgia
Environmental Protection Division (GEPD) and the USEPA Region IV that these
individual groundwater investigations be combined into a single basewide OU.
SOUTHNAVFACENGCOM and MCLB, Albany proposed to the regulatory agencies
that the investigation of groundwater at a basewide level would be more technically
appropriate and would also expedite the other ongoing investigations at MCLB, Albany.
This focus of the OU was to encompasses all 26 PSCs that have been identified at the
MCLB, Albany. This recommendation was agreed upon in March 1996 by the GEPD and
USEPA.
13. Comment: Testimony of employees and various records of purchase order acquisitions
identified the description of contents pertaining to activities associated with waste
disposal at U. S. MCLB. The dumpsites contain a collection of military debris saturated
with industrial solvents and other byproducts. The byproducts are a result of activities
such as wood treatment/chrome plating/lead impregnated sand blasting grit, batteries,
transformers containing PCB's and other numerous unidentified substances. The extent
of the contents of these unlined landfills has never been fully discovered.
Response: Invasive explorations into landfill contents are not usually conducted at
landfill sites. Military landfills are similar to municipal landfills and contain
predominantly non-hazardous materials. However, industrial solid waste and even
some household refuse can possess hazardous components such as pesticides, paints, and
solvents. Similar hazardous waste can be expected in most municipal landfills due to
past disposal practices. Therefore, capping is the most frequently chosen remedy
(USEPA, 1996). Additionally, records for purchase orders do not indicate disposal in the
Base's former landfill.
14. Comment: Single compounds are mixed to such a degree and amounts of these
chemicals are not fully known. The injection treatment method would be at best a shot
in the dark, a waste of money, time and effort. The treatment of injecting lactic acids is
known to cause releases of vinyl chloride when mixed with tetrachloroethene.
Response: Lactic Acid has been shown to enhance the degradation of chlorinated solvent
mixtures such as those at MCLB Albany. Vinyl chloride is an intermediate in the
reductive dechlorination of cVOCs. A discussion of biological degradation processes is
provided in the RI/BRA for OU 6 on pages 5-4 through 5-20 in paragraph 5.2.2.1 Volatile
Organic Compounds (HLA, 2000b).
15. Comment: The geology and topography of the PSC's 2, 3, 26 and 4 are located within a
major recharge aquifer system. Seasonal rainfall cause fluctuation of the water table and
produce unpredictable aquifer responses, as noted in all of the existing OU 6 data. The
Karst geological identification further contributes to the continuing spread of toxic
chemicals and human exposure routes.
Response: Comment acknowledged.
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Individual Statements 16 through 184 are typewritten comment sheets made by residents.
Statements 16 through 184 are presented with the July 5,2000, Citizen Comments.
Response to All: Please refer to response to Question 1, Citizen Comments and
Questions dated July 5, 2000.
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Part II: Response to Specific Legal and Technical Questions
Response to Comments from U.S. Environmental Protection Agency
Operable Unit 6 Draft Record of Decision (dated June 21,2000)
MCLB Albany, Georgia
LEGAL COMMENTS
1. Declaration: Assessment of Site - Describe the type of contamination present and
the media in which it is located. If soil contamination is present, indicate the
approximate depth of contamination or the range over which the contamination
occurs.
Response: Comment acknowledged, the text has been revised as requested.
2. Declaration: Section 1.4 states that further source characterization is necessary and is
part of the intended response action. It needs to be stated that the additional source
characterization is necessary to completely and successfully implement the selected
remedy. If this is not made clear, it appears that the facility has not yet delineated the
scope and extent of the contaminant source. It is imperative that it be stated that the
additional source characterization is proposed to ensure that the most effective
remedy is designed. Otherwise, issuance of a ROD seems to be premature if source
characterization is incomplete.
Response: Comment acknowledged, the text has been revised as requested.
3. Declaration: Section 1.4 identifies contingent remedies that will be employed at an
unspecified time based on unspecified changes in constituent concentrations. This is
not a viable contingency remedy because the triggering mechanisms are too vague,
as is the alternate remedy description. Please revise this section to specify the time
period and constituent concentrations which will trigger the contingent remedy or
delete all references to the contingent remedy since five years reviews are required.
(See the table below).
Response: Comment acknowledged, the section has been revised as requested.
4. Declaration: Add a ROD data certification checklist. (Refer to EPA ROD guidance)
Response: Comment acknowledged, a certification checklist has been added as
Section 1.6.
5. Decision Summary: Site History and Enforcement Activities - State whether the
facility was required to obtain a RCRA permit and if so, the date of issuance and
whether it was an operating permit, post closure permit, or both. Identify the date of
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National Priority Listing of MCLB. State that an FFA has been negotiated, and how it
incorporates the requirements of the CERCLA order and RCRA permit.
Response: Comment acknowledged, the text has been revised as requested.
6. Decision Summary: Current and Potential Site and Resource Uses. Describe current
and potential land use. Because groundwater contamination extends beyond the
limits of the facility, please identify the current and potential future uses of the area
delineated by the limits of the plume.
Response: Comment acknowledged, the text has been revised as requested in the
paragraph MCLB Albany and Surrounding Area Land Use, beginning on page 2-5.
7. Table 2-3, Note No. 4.: Description of action levels for inorganics is unclear. Is it
MCLs or is it a calculated number? Clarify the language.
Response: Comment acknowledged, the text has been revised as requested.
8. Table 2-6.: RCRA Closure/Post Closure requirements apply to regulated units only,
not SWMUs. As OU 6 is not a RCRA-regulated unit subject to post closure
requirements, state this here and in the Site History portion of the document. The
reference to RCRA closure/post closure requirements as an ARAR is incorrect and
should be deleted. A possible exception to this is the plume associated with the
IWWTP. The Table should be modified to refer specifically to the portions of OU 6
that might be impacted by RCRA closure requirements.
Response: Comment acknowledged, the Site History portion of the document has
been revised, and the table has been revised to reflect that this requirement is
applicable only for RCRA regulated units.
9. Section 2.7.2.1., Evaluation of Alternatives: Evaluation of alternatives should
include a no action alternative.
Response: The groundwater remedial alternatives contain a no action alternative.
However, the source control alternative does not contain a no action alternative,
because GDNR and USEPA required that source control be implemented at each of
the sites.
10. Section 2.7.2.1., Evaluation of Alternatives: This section should include a more
detailed description of each alternative. References to a "RCRA cap" or
"evapotranspiration cap" are inadequate. Additionally, land use controls are
mentioned as a remedy for the first time for GW-2 on page 2-39 but the document
contains no discussion of what kind of land use controls will be imposed or how
they operate as a remedy. Reference to the appended LUCIP for PSC4 should be
added.
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Response: The text has been amended to include a performance criterion of IxlO5
centimeters per second. Reference to the LUCIP for PSC 4 has been added to the text.
11. Section 2.7.2.1., Comparison of Threshold Criteria: The discussion is conclusory.
The discussion must include a more detailed analysis of how each remedy complies
with the criteria.
Response: Comment acknowledged, text has been added to refer the reader to the
detailed discussion provided in the FS.
12. Table 2-8: A more detailed itemization of capital costs must be included.. If a more
detailed itemization is found in another document, please reference that document at
this location.
Response: Comment acknowledged. Text has been added to the table and to Section
2.7.2.1 to refer the reader to the detailed itemization provided in the FS.
13. Section 2.7.3., Response action: Identify the performance criteria for the
evapotranspiration cap in terms of permeability or hydraulic conductivity, not that
of a "RCRA cap."
Response: Comment acknowledged. The text has been revised as requested, please
refer to the response to comment 10.
14. The ROD does not contain the statutory determinations required by CERCLA
Section 121.
Response: Comment acknowledged. The criteria for statutory determinations have
been added in Table 1-1.
INDEPENDENT REVIEW
This portion of the document review was conducted not so much from a technical
standpoint but from more of an educated layperson's perspective. A layperson's
understanding that the ROD document is the guiding document for cleanup that will follow
may not understand all the technical aspects of the ROD and may require further
clarification of scientific statements or justifications. The educated layperson would be able
to notice and recognize contradictory statements, unclear statements, grammatical or
typographical errors, etc.
GENERAL COMMENTS
1. Remedial Action Objectives (RAOs) and performance criteria are given for source
control remedies and groundwater remedies for each plume area. Contingency
measures are also given in the event that the performance criteria are not met.
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However, timing constraints for meeting these RAOs are not provided. Numerous
references were made regarding the 5 Year reviews as being used to determine if
the response actions have achieved the prescribed performance criteria. This may
not be an appropriate frequency with respect to timing constraints for achieving
RAOs.
Response: Comment acknowledged. Table 1-1, Groundwater Remedial Goals, now
sets the Remedial Goal within 3 years of the Remedial Action Start. A paragraph has
also been added to section 2.7.3. Response Action, in which a 3-year review is
discussed with the purpose of assessing the primary remedies at the NPA, DMA,
and PSC 4. Goals for clean up of contamination off-site and on-site were also
included in Table 1-1.
2. It is reported that enhanced bioremediation may be implemented by such actions
as injecting lactic acid or hydrogen release compound into the UWBZ which
should induce anaerobic conditions. This would result in the complete reductive
dechlorination of the chlorinated volatile organic compounds. The enhanced
bioremediation and reductive dechlorination processes may be difficult for the
layperson to understand. Providing a definition of bioremediation, enhanced
bioremediation and reductive dechlorination in the "Glossary of Terms" section
may be helpful.
Response: Comment acknowledged. The text has been revised as requested.
3. Since the Hazard Index (HI) the Reasonable Maximum Exposure (RME) and the
Central Tendency (CT) definitions are provided in the "Glossary of Terms", the
definition of Excess Lifetime Cancer Risk (ELCR) should be provided as well.
Response: Comment acknowledged. The text has been revised as requested.
Specific Comments:
1. Page 1-2, last full paragraph, 1st sentence. This section discusses that cancer risks
associated with future residential potable users of groundwater from the UWBZ at
the PSC 4 are within the range USEPA considers acceptable (1 x 1O4 to 1 x 1O6) for
the RME. A previous paragraph (page 1-2, 6th complete paragraph) states that PSC1,
PSC4 and DMA area plumes exceeded the lower limit of USEPA's cancer risk range
(1 x 1O4) for the RME and CT. Table 2-2 reports that cancer risks associated with
future residential potable users of groundwater from the UWBZ at the PSC 4 are
within the range USEPA considers acceptable (1 x 1O4 to 1 x 1O6) for the RME.
Clarify this discrepancy.
Response: Comment acknowledged. The 6th paragraph now reads PSC 1, PSC 26 and
DMA.
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2. Page 1-2, last full paragraph, 2nd sentence states "the CT is acceptable as the value is
greater than the upper limit (1 x 1O6)." As reported in Table 2-2, the CT value for
future residential potable users of groundwater from the UWBZ at the PSC 4 are in
the 1 x 1O7 range which is smaller than the upper limit of 1 x 1O6. Clarify/correct.
Response: Comment acknowledged. The text has been corrected to state that the
value is lower than the upper limit.
3. Page 2-5, section 2.2,1st paragraph states MCLB Albany has generated various types
of solid and liquid wastes to include electroplating wastes containing heavy metals,
organic solvents from stripping and cleaning operations, and waste fuel and oil.
Page 2-4,1st paragraph, 1st sentence states that PSC 3 may have received DDT and
possibly transformers containing PCBs. Clarify.
Response: Comment acknowledged. The paragraphs have been changed to
consistently describe waste disposal activities.
4. Page 2-7, Table 2-1. What timing constraints are in place which will trigger the
contingency measure? See general comment 1, above.
Response: Comment acknowledged. Please refer to General Comment 1 above.
5. Page 2-9, section Hydrogeology. This section states that layers that bear water to
wells are called aquifers and layers that cannot bear water are called confining
layers. It also reports that the clayey overburden and the upper unit of the Ocala
Limestone are considered together to be a confining layer. This may be confusing
since the upper unit of the Ocala Limestone at MCLB Albany has been termed the
upper water bearing zone or UWBZ. Additionally, the above statement does not
agree with the hydrostratigraphic column presented as Figure 2-3. Please clarify.
Response: Comment acknowledged. The text has been revised.
6. Page 2-10, Figure 2-3. The figure reference Hicks and others, 1981 and Miller, 1990
could not be found in the reference section. If work completed by others is used in a
report and a reference has been cited in the text, then the appropriate reference
should be provided in the reference section.
Response: Comment acknowledged. The references have been added.
7. Page 2-11, Figure 2-4. The figure reference Hicks and Others, 1987 could not be
found in the reference section. If work completed by others is used in a report and a
reference has been cited in the text, then the appropriate reference should be
provided in the reference section.
Response: Comment acknowledged. The reference has been added.
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8. Page 2-12, Figure 2-4. Figure 2-4 depicts the potentiometric surface of the Upper
Floridan Aquifer in the Albany, Georgia, Area November 1985. With regard to the
aquifer terminology in the report, does Figure 2-4 represent the UWBZ or the LWBZ
at MCLB Albany? Please clarify.
Response: Comment acknowledged. The figure title has been revised to state its
representation of the LWBZ.
9. Page 2-13, Figure 2-5 and Page 2-14, Figure 2-6. Each of these figures depicts a
"middle confining layer" between the UWBZ and the LWBZ. A middle confining
layer was not discussed or made mentioned of in the text. Please explain/clarify.
Response: Comment acknowledged. The text has been revised.
10. Page 2-16,6th complete paragraph, last sentence. This section discusses turbidity
levels and nephelometric turbidity units. It may be helpful if the definitions for
turbidity and nephelometric turbidity units (NTUs) are provided in the "Glossary of
Terms" section.
Response: Comment acknowledged. The text has been revised as requested.
11. Page 2-27, Table 2-4, Page 2-28, Table 2-5. The table reports Fg/R as micrograms per
liter. This unit of measurement is more commonly reported as (ig/L. Please
explain/clarify the significance of Fg/R.
Response: Comment acknowledged. The typographical error has been corrected.
Typographical Errors:
1. Page 1-1, section 1.3,1st paragraph, next to last sentence. The sentence would be
clearer if the word "with" was deleted. The sentence would read ".. .that results from
past waste..." Please/clarify correct.
Response: Comment acknowledged. The text has been revised as requested.
2. Page 1-1, section 1.3, last paragraph, 2nd sentence. The year reported for the USEPA
reference is incorrect. The correct reference is USEPA 1999a. Please correct.
Response: Comment acknowledged. The text has been revised as requested.
TECHNICAL COMMENTS
Of major concern is that there is no calculation of when the remedies will reach the MCL or
any cleanup goal. In the absence of a scientifically calculated cleanup time, the following
cleanup goals are proposed to be used to enforce the response actions. The following
language and table are to be inserted into the ROD.
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LANGUAGE TO BE INSERTED in Section 1.4 and Section 2.7.3:
In order to demonstrate that the ET Cap is operating effectively, a minimum of a 1X10-5
hydraulic conductivity needs to be achieved and maintained as determined by the ACAP
demonstration. In addition, the full ET Cap remedy must be implemented and operating
properly within 3 years of the signing of the ROD.
In order to demonstrate an adequate reduction, all organic COC maximum concentrations
(as of June 2000) must be reduced by a minimum of 50% or to the MCL (whichever is
higher) within 4 years of the signing of the Record of Decision. Refer to the following
table for the specific Remedial Goals. The ultimate goal of the remedy remains to reduce
all organic COC maximum concentrations to the MCL or lower. However, these initial
remedial goals will be used to determine if the enhanced bioremediation is sufficiently
reducing the level of the contamination in the short term. In addition, all inorganic COC
maximum concentrations must show a trend of decreasing concentration and be reduced
to the MCL within 10 years.
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GROUNDWATER VOLATILE COC REMEDIAL GOALS (in H9/L)
Analyte
Maximum Detection (as
of June 2000)
Remedial Goal
(within 3 years of
Remedial Action
Start)
Remedial Goal =
MCL (within 10
years of Remedial
Action Start)
NPA UWBZ PSC 1 Plume
cis1,2-DCE
Methylene Chloride
TCE
VC
2300
450
460
710
1150
225
230
355
70
5
5
1
NPA UWBZ PSC 3 Plume
cis1,2-DCE
PCE
TCE
480
120
53
240
60
26
70
5
5
NPA UWBZ PSC 26 Plume
Carbon Tetrachloride
TCE
310
74
155
37
5
5
DMA Area UWBZ Plume
1,1 DCE
cis1,2-DCE
Benzene
Methylene Chloride
TCE
VC
56
360
780
28
940
120
28
180
390
14
470
60
7
70
5
5
5
1
NPA LWBZ On Base Plume
cis1,2-DCE
PCE
TCE
195
35
195
97
17
97
70
5
5
NPA LWBZ Off Base Plume
1,2 DCE
cis1,2-DCE
Carbon Tetrachloride
PCE
TCE
29
195
8
28
35
14
97
5(MCLis5)
14
17
5
70
5
5
5
DMA Area LWBZ Plume
Any contaminants detected shall be reduced to MCLs or below.
Response: Comment acknowledged. The tables have been added to the document as
requested.
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GROUNDWATER VOLATILE COC REMEDIAL GOALS (in H9/L)
Analyte
Maximum Detection (as
of June 2000)
Remedial Goal
(within 3 years of
Remedial Action
Start)
Remedial Goal =
MCL (within 10
years of Remedial
Action Start)
NPA UWBZ PSC 1 Plume
cis1,2-DCE
Methylene Chloride
TCE
VC
2300
450
460
710
1150
225
230
355
70
5
5
1
NPA UWBZ PSC 3 Plume
cis1,2-DCE
PCE
TCE
480
120
53
240
60
26
70
5
5
NPA UWBZ PSC 26 Plume
Carbon Tetrachloride
TCE
310
74
155
37
5
5
DMA Area UWBZ Plume
1,1 DCE
cis 1,2-DCE
Benzene
Methylene Chloride
TCE
VC
56
360
780
28
940
120
28
180
390
14
470
60
7
70
5
5
5
1
NPA LWBZ On Base Plume
cis 1,2-DCE
PCE
TCE
195
35
195
97
17
97
70
5
5
NPA LWBZ Off Base Plume
1,2 DCE
cis 1,2-DCE
Carbon Tetrachloride
PCE
TCE
29
195
8
28
35
14
97
5(MCLis5)
14
17
5
70
5
5
5
DMA Area LWBZ Plume
Any contaminants detected shall be reduced to MCLs or below.
Response: Comment acknowledged. The tables have been added to the document as
requested.
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3-83
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Response to Comments from
Georgia Department of Natural Resources, Environmental Protection Division
Operable Unit 6 Draft Record of Decision (dated June 21,2000)
MCLB Albany, Georgia
General Comments:
1. The Record of Decision fails to include numeric goals for evaluation of performance of the
remedies selected. Goals should be included for such standards as concentration of
contaminants in the groundwater, efficiency of the evapotranspiration cap, and others.
Please propose goals.
Response: Comment acknowledged. The text has been revised and goals are included
in Table 1-1, Groundwater Remedial Goals.
Specific Comments:
1. The performance criterion, an infiltration rate less than or equal to average Subtitle D
performance, as described in Table 2-1 and in the text is too vague. Although it may be
based on Subtitle D performance criteria, a specific numeric value for the maximum
acceptable infiltration rate should be stated in the ROD.
Response: Comment acknowledged. The text has been revised to include a
performance criterion of IX1O5 centimeters per second.
2. The ROD indicates a 5-year review period for evaluating the source control remedies in
the Northern Plume Area (NPA) and the Depot Maintenance Activity Area (DMA), and
does not indicate a review period for evaluating the performance criteria of the UWBZ
groundwater remedy (monitored natural attenuation) at PSC-4. The effectiveness of
remedies in these areas should be evaluated early in the process. We suggest an initial
evaluation after two years of groundwater monitoring.
Response: Comment acknowledged. A 3-year review will be conducted to determine if
contingency remedies need to be implemented.
3. The ROD outlines the contingency remedy for the DMA source control as sealing or
repairing floor drains that fail the leak test. The ROD does not mention a performance
criterion addressing joints and cracks in the pavement. Please add wording to this effect.
Response: Comment acknowledged. The text has been revised.
4. There is no statement of what is to become of the remediation system currently in place at
PSC-3. If there is a possibility of it being incorporated in a groundwater extraction and
ex-situ treatment system as part of the contingency remedy, the ROD should so indicate.
Response: Comment acknowledged. A recommendation to discontinue the use of the
system has been added.
5. The RI/BRA for OU 6 recommended that data gaps be addressed concurrently with
conducting the detail design for remedial actions. These data gaps include delineation of
carbon tetrachloride in the UWBZ southwest, west, and northwest of PSC 26; delineation
of TCE and carbon tetrachloride in the LWBZ northwest of PSC 3; and continued
monitoring of the UWBZ and LWBZ water quality to confirm that the groundwater
plumes are stable and the COCs are naturally attenuating. A statement to the effect that
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such data gaps will be addressed should be included in the ROD. In addition, a statement
should be included in the ROD committing to addressing data gaps in the geological
characterization of the NPA. In light of recent events at the NPA, karst features such as
buried sinkholes must be characterized and their influence on the fate and transport of
contaminants evaluated.
Response: Comment acknowledged. The text has been revised as requested to address
data gaps in the delineation of contaminants of concern.
6. Figure 2-2 on Page 2-3 inaccurately depicts PSC 12, the Industrial Waste Treatment
Plant; the IWTP itself is excluded from the drawing and should be included.
Response: Comment acknowledged. The figure has been revised.
7. The Lisbon Formation is described on page 2-9 as "hard, clayey limestone". However, the
color shown in the hydrostratigraphic column (Figure 2-3) corresponds to "calcareous
sand" in the explanation for that figure. This mistake should be corrected.
Response: Comment acknowledged. The figure has been revised.
8. Page 2-17, the last paragraph of Section 2.7 repeats a previous wording problem. It is
misleading to state that "the groundwater plumes associated with MCLB do not discharge
to surface water bodies." Current understanding of the hydrogeology of the site indicates
that the groundwater beneath MCLB discharges to the Flint River at or near Radium
Springs. Current analytical data indicate that there is no measurable contamination
attributable to MCLB present in the groundwater thus discharged. The sentence should
be reworded to more clearly support the conclusion that there is no complete exposure
pathway.
Response: Comment acknowledged. The text has been revised.
9. In Table 2-5, the Exceedence? (Yes/No) column is blank for the NPA LWBZ Offbase
Plume Current Land Use category. It should contain a "Yes".
Response: Comment acknowledged. The table has been revised.
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Response to Comments from
EPA Region IV (dated October 2000)
Operable Unit 6 Draft Record of Decision
Marine Corp Logistics Base Albany
1. Comment: Declaration, Assessment of Site - Provide a statement which locates
the unit relative to the boundaries of the Base.
Response: Section 1.3 has been revised to explain the geographical boundaries of
OU6.
2. Comment: Declaration, Assessment of Site - Include a definitive statement that
identifies the existence of a release of hazardous substances into the
environment. Identify the contamination found in both soils and groundwater.
Response: Section 1.3 now includes Tables 1-1 and 1-2 (formerly Tables 2-5 and 2-6)
that list contaminants in groundwater exceeding criteria. Figure 2-2 has been moved
forward to become Figure 1-1, to explain graphically the relation between the OU 6
groundwater plumes and the PSCs. The ROD for OU 6 addresses groundwater and
therefore no soil contaminant levels are provided. Soil contamination was addressed
in the RODs for OUs 1, 2, 3, 4, and 5.
3. Comment: Decision Summary, Site History - Indicate the date and the
instrument which called for the investigation of contamination.
Response: Section 2.2 has been revised to describe the NPL listing and FFA
agreement for MCLB Albany.
4. Comment: Decision Summary - Identify current and future land and
groundwater usages.
Response: Section 2.6 has been revised to describe both land use and resource use.
5. Comment: Decision Summary, Summary of Site Risks - Please include a
ecological risk assessment or justify why one is not needed.
Response: Section 2.7 has been revised. Section 2.7.3 indicates why no ecological
risk assessment was done.
6. Comment: Decision Summary, Description of Alternatives - Provide a more
detailed description of each remedial alternative considered. Indicate time
required for construction. Distinguish between capital costs and operation and
maintenance costs. State whether installation of the remedy will require removal
of contaminated soil or groundwater and whether this material will be disposed
of on or offsite.
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Response: Comment requesting 'more detailed description' and 'distinguish between
. . costs' noted. Detailed descriptions of the alternatives and cost information are
provided in the Feasibility Study for OU 6 (HLA, 2000c). This reference has been
added to Tables 2-6 and 2-7. These tables have also been modified to include
information on time required for construction/implementation, and potential for
onsite/offsite disposal of soil (Table 2-6) or groundwater (Table 2-7).
7. Comment: Decision Summary, Statutory Determinations - Not included. Please
revise.
Response: Section 2.12 has been revised.
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4.0 References
ABB Environmental Services, Inc., (ABB-ES). 1992. Remedial Investigation (RI) and
Feasibility Study Report for Operable Unit 3, MCLB Albany, Georgia. Prepared for Southern
Division Naval Facilities Engineering Command (SOUTHNAVFACENGCOM), North
Charleston, South Carolina.
ABB-ES. 1995. RI and Baseline Risk Assessment (BRA) for Operable Unit 1 and 2, MCLB
Albany, Georgia. Prepared for SOUTHNAVFACENGCOM, North Charleston, South
Carolina.
ABB-ES. 1996. Record of Decision Operable Unit 2, MCLB Albany, Georgia. Prepared for
SOUTHNAVFACENGCOM, North Charleston, South Carolina.
ABB-ES. 1997a. Remedial Investigation and Risk Assessment Addendum for Operable Unit
1 and 2, MCLB Albany, Georgia. Prepared for SOUTHNAVFACENGCOM, North
Charleston, South Carolina.
ABB-ES. 1997b. Final Draft RI/BRA for Operable Unit 5, MCLB Albany, Georgia. Prepared
for SOUTHNAVFACENGCOM, North Charleston, South Carolina.
ABB-ES. 1997c. Record of Decision OU 1, MCLB Albany, Georgia. Prepared for
SOUTHNAVFAC-ENGCOM, North Charleston, South Carolina.
ABB-ES. 1997b. Record of Decision Operable Unit 3, MCLB Albany, Georgia. Prepared for
SOUTHNAVFAC-ENGCOM, North Charleston, South Carolina.
ABB-ES. 1997c. Record of Decision Operable Unit 5, MCLB Albany, Georgia. Prepared for
SOUTHNAVFAC-ENGCOM, North Charleston, South Carolina.
ABB-ES. 1997d. Removal Action Report for PSC 3 Sludge Piles, OU 1, MCLB Albany,
Georgia. Prepared for SOUTHNAVFACENGCOM, North Charleston, South Carolina.
ABB-ES. 1998. Final Draft RI/BRA for Operable Unit 4, MCLB Albany, Georgia. Prepared
SOUTHNAVFACENGCOM, North Charleston, South Carolina.
ABB-ES. 1997e. PSC Screening Technical Memorandum, MCLB Albany, Georgia. Prepared
for SOUTHNAVFACENGCOM, North Charleston, South Carolina.
Applied Engineering & Science, Inc. 1989. RCRA Facility Investigation of Marine Corps
Logistics Base, Albany, Georgia.
Byrd. 1998. Personal communication between J. Daniel of HLA and J. Byrd of MCLB Albany
(October 26).
CH2M HILL, 2000, Work Plan Addendum 01, Pilot Test of Enhanced Biodegradation of
Chlorinated Solvents in Groundwater at PSC 3, MCLB Albany (June, 2000)
Envirodyne Engineers. 1985. Initial Assessment Study of Marine Corps Logistics Base, Albany,
Georgia. NEESA 13-065.
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Harding Lawson Associates (HLA). 1998. RI/BRA Report, OU 4, MCLB Albany, Georgia.
Prepared for SOUTHNAVFACENGCOM, North Charleston, South Carolina.
HLA. 1999a. PSC 4 RCRA Facility Investigation Report, Marine Corps Logistics Base,
Albany, Georgia. Prepared for SOUTHNAVFACENGCOM, North Charleston, South
Carolina.
HLA. 1999b. Record of Decision Operable Unit 4, MCLB Albany, Georgia. Prepared for
SOUTHNAVFACENG-COM, North Charleston, South Carolina.
HLA. 2000a. Final Remedial Investigation and Baseline Risk Assessment Report, Operable
Unit 6, Marine Corps Logistics Base, Albany, Georgia. Prepared for
SOUTHNAVFACENGCOM, North Charleston, South Carolina.
HLA. 2000b. Residential Well Closure Report, OU 6, Marine Corps Logistics Base, Albany,
Georgia. Prepared for SOUTHNAVFACENGCOM, North Charleston, South Carolina.
HLA. 2000c. Feasibility Study, Operable Unit 6, Marine Corps Logistics Base, Albany,
Georgia. Prepared for SOUTHNAVFACENGCOM, North Charleston, South Carolina.
HLA. 2000d. Proposed Plan Operable Unit 6, MCLB Albany, Georgia. Prepared for
SOUTHNAVFACENGCOM, North Charleston, South Carolina.
Hicks, D.W., R.E. Krause, and J.S. Clarke. 1981. "Geohydrology of the Albany Area, Georgia."
Georgia Geologic Survey Information Circular 57.
Hicks, D.W., H.E. Gill, and S.A. Longsworth. 1987. "Hydrogeology, Chemical Quality, and
Availability of Ground Water in the Upper Floridan Aquifer, Albany Area, Georgia." U.S.
Geological Survey Water-Resources Investigations Report 87-4145.
Knight, Jimmy. 1998. Personal communication from Mr. Knight, Water Director of Albany
Water, Gas, and Light, to Joe Daniel of HLA (October 26).
McClelland Engineers. 1987. Final Report, Confirmation Study Verification Step Marine Corps
Logistics Base, Albany, Georgia. Prepared for SOUTHNAVFACENGCOM, North Charleston,
South Carolina.
McSwain, K.B. 1999a. Compiled Information on Residential Wells Located North of
Potential Source of Contamination 3, Marine Corps Logistics Base, Albany, Georgia. USGS
Administrative Data Report (June).
McSwain, K.B. 1999b. Hydrogeology of the Upper Floridan Aquifer in the Vicinity of the
Marine Corps Logistics Base Near Albany Georgia. USGS Water-Resources Investigations
Report 98-4202 . Prepared in cooperation with U.S. Department of the Navy,
SOUTHNAVFACENGCOM.
Miller, J.A. 1990. Groundwater Atlas of the United States, Segment B, Alabama, Florida, Georgia, and
South Carolina. U.S. Geological Hydrologic Investigations Atlas.
U.S. Environmental Protection Agency (USEPA). 1989a. Risk Assessment Guidance for
Superfund, Volume 1, Human Health Evaluation Manual (Part A)"; Office of Emergency
and Remedial Response; EPA-540/1-89/002 (interim final); Washington, D.C. (December).
ATL\\D:\NAVYRAC\NAVYRAC DELIVERABLES\RECORD OF DECISION\0059\ALBANYROD.DOC 4-2
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USEPA. 1989b. Seminar Publication, Transport and Fate of Contaminants in the Subsurface.
USEPA Center for Environmental Research Information, Cincinnati, Ohio, and Robert S.
Kerr Environmental Research Laboratory, EPA/62S/4-89/019 (September).
USEPA. 1990. National Functional Guidelines for Organic Data Review: December 1990
(revised June 1991).
USEPA. 1991. "Risk Assessment Guidance for Superfund, Volume I: Human Health
Evaluation Manual, Supplemental Guidance, Standard Default Exposure Factors"; Office of
Emergency and Remedial Response, Toxics Integration Branch; OSWER Directive 9285.6-03
(interim final); Washington, D.C.
USEPA. 1992. Community Relations in Superfund: Handbook; USEPA Office of Emergency
and Remedial Response, Washington, D.C. EPA/540/R-92/0093.
USEPA. 1992a. "Guidance for Data Usability in Risk Assessment (Parts A and B)"; Office of
Emergency and Remedial Response; Publication 9285.7-09A; Washington, D.C.; April.
USEPA. 1992b. "Supplemental Guidance to RAGS, Calculating the Concentration Term";
Office of Solid Waste and Emergency Response; Intermittent Bulletin, Vol. 1, No. 1;
Washington, D.C.; May.
USEPA. 1995. Supplemental Guidance to RAGS: Region IV Bulletins Numbers 1 through 5. USEPA
Region IV Waste Management Division, Atlanta, Georgia (November).
USEPA. 1996a. Environmental Investigations Standard Operating Procedures and Quality
Assurance Manual, Region IV, USEPA, Athens, Georgia, May.
USEPA. 1996b. Application of the CERCLA Municipal Landfill Presumptive Remedy to
Military landfills (Interim Guidance), USEPA, Office of Solid Waste and Emergency
Response. Directive No. 9355.0-62 FS. EPA/540/F-96/007.
USGS. 1999. Compiled Information on Residential Wells Located North of Potential Source of
Contamination 3, Marine Corps Logistics Base, Albany, Georgia. USGS Administrative Data
Report (June).
Wiedemeier, T.H., H.S. Rifai, C.J. Newell, and J.T. Wilson. 1999. Natural Attenuation of Fuels
and Chlorinated Solvents in the Subsurface. John Wiley & Sons, New York. 617 pp.
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APPENDIX A
LAND-USE CONTROL IMPLEMENTATION PLAN FOR
POTENTIAL SOURCE OF CONTAMINATION 4
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Land Use Control Implementation Plan for PSC 4
Marine Corps Logistics Base Albany,
Albany, Georgia
This attachment identifies Institutional Controls restricting (a) human access to and contact
with surface and subsurface soils contaminated with inorganic constituents through
residential development of the site and (b) certain activities occurring on, around, or under
Potential Source of Contamination (PSC) 4 located at the Marine Corps Logistics Base
(MCLB), Albany. Figure A-l presents the general configuration of PSC 4 within MCLB
Albany.
Introduction
Envirodyne Engineers (1985) concluded in an Initial Assessment Study (IAS) that "due to
the non-hazardous nature of the waste reported disposed of at this site, it is judged not to
pose a potential threat to human health or the environment" (Envirodyne Engineers, 1985).
No sampling activities were conducted at PSC 4 during the IAS, or during the other
previous investigations, conducted in 1987 and 1989 (McClelland Engineers, 1987; and
Applied Engineering & Science, Inc. 1989, respectively).
Based on the results of previous investigations (Envirodyne Engineers, 1985; McClelland
Engineers, 1987; and Applied Engineering & Science, Inc. 1989), MCLB Albany was placed
in Group 7 of the National Priorities List (NPL) for Uncontrolled Hazardous Waste Sites,
according to Title 40, Code of Federal Regulations (CFR), Part 300 (40 CFR 300, July 1991).
In 1991, the Department of the Navy, representing MCLB Albany, entered into a Federal
Facilities Agreement (FFA) with the Georgia Environmental Protection Division (GEPD) and
the U.S. Environmental Protection Agency (USEPA) Region IV to establish a procedural
framework and schedule for developing, implementing, and monitoring appropriate
response actions at the facility in accordance with Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA); Resource Conservation and Recovery Act
(RCRA); the National Oil and Hazardous Substances Contingency Plan (NCP); Superfund
guidance and policy; and the Georgia Hazardous Waste Management Act.
Harding Lawson Associates, Inc (HLA) (formerly ABB Environmental Services, Inc.
[ABB-ES]), was contracted under the Comprehensive Long-Term Environmental Action,
Navy contract (contract number N62467-89-D-0317), to prepare and execute Remedial
Investigation and Feasibility Study Workplans, Site Screening Workplans, and associated
documents for 26 PSCs at MCLB Albany.
To assess whether the past disposal activities had resulted in a release of contaminants to
the land surface at PSC 4, screening level assessments were conducted in 1995 and 1996
(ABB-ES, 1997). Based on the analytical results of the 1995 and 1996 surface soil samples,
additional screening level activities were conducted during a RCRA Facility Investigation in
1999 to evaluate surface and subsurface soil (HLA, 1999a). The characterization of
groundwater beneath PSC 4 was conducted during the basewide Remedial Investigation
and Baseline Risk Assessment for Operable Unit (OU) 6 (HLA, 2000).
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RECCRD OF DECISION
OPERABLE UNIT C
MARINE CORPS LOGISHCS BASE
ALBANY. GEORGIA
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Background
The Warehouse Disposal Area was characterized in an Initial Assessment Study (IAS) in
1985 by Envirodyne Engineers as having received solid waste and building materials from
the early 1960s to 1969. The waste included paper, cardboard, wood pallets, and metal
bindings that were routinely burned, compacted, and covered with local soils. The 1985 IAS
concluded that the innocuous nature of material purportedly disposed of at PSC 4 did not
pose a potential threat to human health and the environment, and a confirmation study was
not recommended.
In contrast, neighboring PSC 5, the West Disposal Area located southwest of PSC 4, was
identified as a 7-acre tract with a landfill (trench and fill). This landfill reportedly received
large quantities of liquid waste including solvents, paints, thinners, and paint strippers, as
well as solid waste including approximately 35,000 tons of paper, cardboard, wooden
pallets, garbage, empty pesticide containers, abrasive blasting grit and other industrial
wastes from the Depot Maintenance Activity (DMA) from the early 1950s to 1960
(Envirodyne, 1985). These wastes were burned periodically prior to compaction and
covering. The 1985 IAS concluded that the nature of material purportedly disposed of at
PSC 5 did pose a potential threat to human health and the environment, and a confirmation
study was recommended.
Over the course of HLA's investigations, a number of facts about PSCs 4 and 5 lead HLA to
conclude that the IAS mistakenly reversed the identification of the two PSCs. First, aerial
photographs of the landfills clearly show trenching activities at PSC 4 by the early to mid
1950s; conversely, photographs from 1953,1957, and 1964 show no such activities at PSC 5.
Second, detailed geophysical surveys conducted during the 1995 PSC screening
investigations identified a distinct "trench-like" anomaly trending northeast to southwest
across PSC 4; no such anomaly was identified at PSC 5 (CEES-Blackhawk Geosciences,
1995). Additionally, the results of the geophysical survey do not indicate the presence of an
anomaly that could be interpreted as an area containing a metallic grit at PSC 5 (CEES-
Blackhawk Geosciences, 1995). Third, despite the large quantities of waste reportedly
disposed of at PSC 5, neither soil nor groundwater contamination was detected during the
1997 Confirmation Study (McClelland Engineers, 1987). Finally, the I AS states that over
1,000 tons of abrasive blast grit residue was disposed of at PSC 5. No such waste has been
found at PSC 5; however, the ground surface in the southeastern portion of PSC 4 is covered
by blast grit. Also, the area where the metallic abrasive blast grit occurs at PSC 4 responds
strongly to the anomaly found during the geophysical survey (CEES Blackhawk
Geosciences, 1995). Based on this evidence, it would appear that the disposal activities
attributed to PSC 5 actually occurred at PSC 4.
Summary of Assessment Activities
The assessment activities conducted in 1996 and 1997 included the evaluation of surface soil
samples (land surface to a depth of 1 foot) and of the evaluation of the abrasive blasting
media.
The assessment activities conducted in 1999 included the collection of subsurface soil
samples to characterize "hot spots" within the PSC 4 trench; and surface and subsurface soil
in the vicinity of the abrasive blast media to characterize the horizontal and vertical extent
of poly chlorinated biphenyls (PCBs).
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Characterization of whether or not the past disposal activities had resulted in a release of
contaminants to groundwater was conducted in 1998 for the upper water bearing zone
(UWBZ) of the Upper Floridan aquifer (UFA), and in 1999 the UWBZ and lower water
bearing zone were assessed.
Below is a summary of these assessment activities.
1996 and 1997 Assessment Activities
The assessment activities conducted in 1996 and 1997 consisted of collecting samples of the
abrasive blasting media and surface soil for analysis of volatile organic compounds (VOCs),
semivolatile organic compounds (SVOCs), pesticides, PCBs, and inorganics; and the
characterization of lead and cadmium in the abrasive blasting media by the toxicity
characteristics leaching procedure (TCLP).
The analytical results for the surface and subsurface soils were compared to soil screening
level (SSL) guidance criteria for sites on the NPL (USEPA, 1996a; and 1996b). SSLs are used
to characterize whether or not no further action is appropriate or additional study or
remediation is required. If the SSL is not exceeded then no further action is warranted, and
if exceeded then additional study or remediation is warranted.
The TCLP test is used to determine whether or not waste would be considered hazardous
by the characteristic of toxicity under 40 Code of Federal Regulation (CFR) part 261.24.
Currently, the abrasive blasting media waste from the DMA is disposed of as hazardous
waste because concentrations of lead and cadmium exceed their TCLP criteria.
VOCs detected in the abrasive blasting media were acetone, 2-butanone, benzene, 2-
hexanone, and toluene. SVOCs, pesticides, and PCBs, if present, were at concentrations less
than their detection limits. Inorganic analytes detected in the abrasive blast media were
aluminum, antimony, arsenic, barium, cadmium, calcium, chromium, cobalt, copper, iron,
lead, magnesium, manganese, nickel, selenium, sodium, vanadium, and zinc.
Lead and cadmium were not detected in the extract of the TCLP sample. Therefore, the
abrasive blasting media at PSC 4 would not be considered to have the characteristic of
toxicity under 40 CFR part 261.24 for lead or cadmium.
VOCs, if present, were at concentrations less than their detection limits in the surface soil
samples. Twenty SVOCs were detected in the surface soil samples. Five of the analytes,
benzo(a)anthracene, dibenz(a,h)anthracene, benzo(b)fluoranthene, benzo(a)pyrene, and
indeno(l,2,3-cd)pyrene were detected at concentrations that exceed their respective
residential SSL.
Seven pesticides were detected in the surface soil samples. One analyte, dieldrin, was
detected at concentrations that exceeded its residential SSL.
One PCB, Aroclor-1260, was detected in 18 of the 31 soil samples, and exceeded its SSL in
one sample.
Twenty inorganic analytes were detected in the surface soil samples. Seven of the analytes
(barium, beryllium, cadmium, mercury, nickel, potassium, and sodium), were statistically
similar to background. Thirteen of the analytes (aluminum, antimony, arsenic, calcium,
chromium, cobalt, copper, iron, lead, magnesium, manganese, vanadium, and zinc) were
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not statistically similar to background. Arsenic was the only inorganic analyte detected at
concentrations that exceeded its SSL.
Three VOCs (acetone, 2-butanone, and TCE) were detected in subsurface soil samples. None
of the VOCs were detected at concentrations that exceed their respective SSL Eleven SVOCs
were detected in subsurface soil samples. Only one analyte, benzo(a)pyrene/ was detected at
concentrations that exceeded its SSL.
One pesticide, 4/4'-dichlorodiphenyldichloro-ethene/ was detected in a subsurface soil
sample as a single occurrence at a concentration less than its SSL.
One PCB, Aroclor-1260, was detected in a subsurface soil sample as a single occurrence at a
concentration less than its SSL.
Nineteen inorganic analytes were detected in the subsurface soil samples. Twelve of the
analytes (aluminum, barium, cadmium, calcium, chromium, copper, iron, lead, magnesium,
nickel, potassium, and vanadium) were statistically similar to background. Seven of the
analytes (arsenic, beryllium, cobalt, manganese, mercury, sodium, and zinc) were not
statistically similar to background. Arsenic and beryllium were detected at concentrations
that exceed their respective SSLs.
1999 Assessment Activities
The purpose of the 1999 Assessment activities was to obtain sufficient information to
characterize chemicals present in surface and subsurface soils and determine the likelihood
of hot spots. The additional soil sampling activities consisted of collecting surface and
subsurface soil samples to characterize PCBs in the vicinity of the abrasive blasting media,
and characterize chemicals present in subsurface at the suspected trench area.
Based on the field screening analysis of PCBs in the surface and subsurface soil samples, it
appears that they are distributed randomly in the vicinity of the abrasive blasting media.
Laboratory analytical results for confirmation samples indicate that the PCBs were below
their USEPA Region III residential risk-based concentration (RBC) (USEPA, 1998). The
USEPA Region III RBCs are used by USEPA Region IV to characterize the potential for
environmental media to contain a chemical(s) at a concentration(s) that could cause adverse
human health risk.
Characterization of the suspected PSC 4 trench, suggest that the trench is approximately
600 feet long, 20 feet wide, and averages twelve feet beneath the land surface.
VOCs, SVOCs, Pesticides, and PCBs were detected in the subsurface soil samples collected
from within the trench area. Only the SVOC, benzo(a)pyrene, and one PCB, Aroclor-1242
were detected at concentrations that exceeded their respective residential USEPA Region III
RBCs.
Twenty-two inorganic target analytes were detected in subsurface soil samples. Antimony,
arsenic, chromium, iron, and manganese were detected at concentrations that exceed their
respective USEPA Region III RBCs.
Groundwater Assessment Activities
Groundwater assessment activities were conducted at PSC 4 during the investigation of
Operable Unit (OU) 6.
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Upper Water Bearing Zone. Volatile organic analytes detected in groundwater samples
collected from the upper water bearing zone (UWBZ) of the Upper Floridan Aquifer (UFA)
during the period from 1997 to 1998 were TCE, 1,2-dichloroethene (1,2-DCE) (total), cis 1,2-
DCE, and 1,2-dichloropropane. Volatile organic analytes detected in UWBZ groundwater
samples collected during 1999 were TCE and chloroform (Table A-l). The maximum
detected concentration and average concentrations for TCE detected in 1999 are lower than
those for the 1997 and 1998 sampling event.
Two semivolatile organic analytes, bis(2-chloro-ethyl)ether and bis(2-ethylhexyl)phthalate
(BEHP), were detected in UWBZ groundwater samples during 1997 and 1998 sampling
event, but not during the 1999 sampling event. BEHP is likely a field or laboratory derived
contaminant.
Inorganic analytes detected in UWBZ groundwater samples collected during 1997 and 1998
were aluminum, arsenic, barium, beryllium, cadmium, calcium, chromium, cobalt, copper,
iron, magnesium, manganese, potassium, sodium, vanadium, and zinc.
Inorganic analytes detected in UWBZ groundwater samples collected during 1999 were
barium, cadmium, calcium, chromium, copper, magnesium, manganese, potassium,
sodium, and vanadium (Table A-l). Maximum detected concentrations and arithmetic
means for inorganic analytes detected in the 1999 groundwater samples were lower than
those for the 1997 and 1998 sampling event.
Lower Water Bearing Zone. Table A-2 summarizes the 1999 analytical results used to
characterize the nature and distribution of organic and inorganic analytes detected in the
LWBZ groundwater samples at PSC 4. The table presents the frequency of detections,
minimum, maximum, and mean detected concentrations, the reporting limits, and action
levels for each analyte detected in the LWBZ groundwater.
Volatile organic analytes detected in groundwater samples collected during 1999 were 1,2-
DCE (total), cis 1,2-DCE, 1,1-dichloroethane, and 2-butanone. TCE, if present, was not
detected at concentrations greater than the detection limit.
Inorganic analytes most frequently detected in groundwater samples collected during 1999
were barium, calcium, chromium, copper, magnesium, potassium, sodium, and vanadium.
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Table A-1
Summary of Analytes Detected in the Upper Water Bearing Zone
at Potential Source of Contamination 4
Frequency Minimum Maxim
Analyte of Detection1 Concentration Concent
Volatile Organic Compounds (|jg/L)
Chloroform 1/5 0.7 0.7
Trichloroethene 2/5 6.2 8.3
Inorganic Analytes (|jg/L)
um Mean Range of Reporting Action Level
ration Concentration2 Limits for Nondetects (ug/L)3
0.7 1-10 100
7.3 1-10 5
Aluminum 1/2 917 917 917 200 450
Barium 2/2 37.4 47.5 42.5 N/A 2,000
Cadmium 2/2 0.2 0.21 0.21 N/A 5
Calcium 2/2 33,800 69,600 51,700 N/A 51,055,398
Chromium 2/2 1.2 1.3
Copper 2/2 1.5 2.6
Total Cyanide 2/2 1.8 2.5
1.3 N/A 100
2.1 N/A 1,000
2.2 N/A 200
Iron 1/2 1,160 1,160 1,160 100 300
Lead 1/2 1.3 1.3
1.3 3 415
Magnesium 2/2 581 1,300 941 N/A 5118,807
Manganese 2/2 25.6 57.5 41.6 N/A 50
Mercury 1/2 0.14 0.14 0.14 0.2 2
Nickel 1/2 1.5 1.5
1.5 40 100
Potassium 2/2 578 1,030 804 N/A 5297,016
Sodium 2/2 10,000 13,300 11,650 N/A 5396,022
Vanadium 2/2 1.3 3.4
2.4 N/A 13.2
Zinc 1/2 17.7 17.7 17.7 20 5,000
Data from RI/BRAfor OU6 (HLA, 2000a).
1 Frequency of detection is the number of samples in which the analyte was detected divided by the total number of samples analyzed (excluding duplicates).
2 The mean concentration is the arithmetic mean of all detected concentrations. For a sample and duplicate, the average of the detected concentrations was used. When a sample or duplicate pair
had a nondetected value, 1/2 the Contract Laboratory Program sample quantitation limit is used as a surrogate.
3 Action levels are primary MCL, except as noted otherwise (40 Code of Federal Regulations [CFR], Part 141).
|jg/L = micrograms per liter.
N/A = not applicable, analyte detected in each sample.
MCL = maximum contaminant level.
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A-7
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The sampling events prior to 1997 used a standard sample collection method which, owing
to the nature of the UWBZ in the Albany area, yielded turbid (muddy) groundwater
samples. A new sample collection method (USEPA, 1996) using very low-flow sampling
pumps, was approved for use during the 1999 sampling event. The 1999 samples, in
addition to being the most recent available data, are less turbid and thus considered to be
more representative of the actual quality of the groundwater in the zone being sampled.
This is the preferred data set for use in assessing the nature and current extent of
contamination and for use in the Human Health Risk Assessment.
Land-Use Restrictions (Institutional Controls). The OU 6 Proposed Plan calls for the initial
implementation and continued application of appropriate restrictions on future usage of the
property encompassing PSC 4 while it is owned by the Federal government. These
restrictions will apply until/unless site remediation is conducted to restore the site for
unrestricted use. Should the Navy later decide to transfer, by deed, ownership in the
property encompassing PSC 4 to any private person or entity, then the provisions of
paragraph Deed Covenants and Conveyance of Title as set forth on page B-ll of this
Institutional Control Plan (ICP) shall apply. Until that time, the following Institutional
Controls will remain in effect:
MCLB Security. Physical access to the property surrounding PSC 4 is controlled by Base
security measures, including fencing, pass and identification procedures, guardhouse, and
periodic security patrols.
Authorized Activities. The following activities are permissible within the confines of PSC 4:
• Land management activities, such as prescribed burns to reduce the potential for forest
fires
• Activities or uses that will not result in the development of the site for residential
purposes or pose a continuous, long-term exposure to child residents located near the
site, and thus will present no greater risk of harm to health, safety, public welfare, or the
environment
• Activities required to ensure adequate protection of human health and the environment
Unauthorized Activities. Those activities and uses that are inconsistent with the objectives
of this ICP, and which, if implemented at PSC 4, could pose an increased risk of harm to
health, safety, public welfare, or the environment may not be conducted at PSC 4. The
following activities are not permissible with the confines of PSC 4:
• Construction of a below ground structure (including but not limited to foundation walls,
wells for drinking water, irrigation, or other domestic purpose)
• Construction of facilities specifically intended for use as residential housing
• Installation and/or storage of chemicals, waste chemical products, or equipment with
the potential for chemical leakage
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Table A.2
Summary of Analytes Detected in Lower Water Bearing Zone
at Potential Source of Contamination 4
Frequency Minimum Maxim
Analyte of Detection1 Concentration2 Concentr
Volatile Organic Compounds (|jg/L)
1,1-Dichloroethane 2/3 1.5* 2
1,2-Dichloroethene (total) 2/3 0.4 0.5*
cis 1,2-Dichloroethene 2/3 0.4 0.5*
2-Butanone 2/3 6 7
Semivolatile Organic Compounds (ug/L)
Phenol 1/3 1.5* 1.5*
Inorganic Analytes (ug/L)
Barium 3/3 30.5 68.3
Cadmium 1/3 1.4 1.4
jm Mean Range of Reporting Action Level
ation2 Concentration3 Limits for Nondetects (|jg/L)4
2 10 5800
0.5 10 70
0.5 10 70
7 10 51,900
2 10 522,000
53.1 N/A 2,000
1.4 5 5
Calcium 3/3 16,400 62,200 46,233 N/A 61,055,398
Chromium 3/3 3.2 4.8
Copper 3/3 1.1 2
Total Cyanide 2/3 1.6 3.3*
4.1 N/A 100
1.5 N/A 1,000
2.5 10 200
Magnesium 3/3 937 1,620 1,356 N/A 6118,807
Potassium 3/3 2,975* 4,460 3,648 N/A 6297,016
Sodium 3/3 6,065* 11,700 9,422 N/A 6396,022
Vanadium 3/3 2.9 5.1*
3.9 N/A 13.2
Data from RI/BRAfor OU6 (HLA, 2000a).
1 Frequency of detection is the number of samples in which the analyte was detected divided by the total number of samples analyzed (excluding duplicates).
2 A value indicated by an asterisk (*) is the average of the detected concentrations in a sample and its duplicate. For nondetected values, 1/2 the Contract Laboratory Program sample
quantitation limit is used as a surrogate.
3 The mean of detected concentrations is the arithmetic mean of all samples in which the analyte was detected. For a sample and duplicate, the average of the detected concentrations was
used. When a sample or duplicate pair had a nondetected value, 1/2 the Contract Laboratory Program sample quantitation limit is used as a surrogate.
4 Action levels are primary MCL, except as noted otherwise (40 Code of Federal Regulations [CFR], Part 141).
5 USEPA Region III Risk-Based Concentration for Tap Water (October 7,1999).
7 Essential nutrient screening concentration (HLA, 2000c).
|jg/L = micrograms per liter.
N/A = not applicable, analyte detected in each sample.
MCL = maximum contaminant level.
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• Activities or uses not specifically stated under "authorized activities" listed above that
will result in the development of the site for residential purposes or pose a continuous,
long-term exposure to child residents located near the site
Proposed Changes in Use. Any proposed changes in permissible uses at PSC 4 that may
result in the development of PSC 4 for residential use shall be evaluated by a licensed
engineering professional and MCLB Albany Environmental Branch Office to determine
whether or not the proposed changes will present a significant risk of harm to health, safety,
public welfare, or the environment. Any such changes in use of the site are subject to
approval by USEPA Region IV and GEPD.
Deed Covenants and Conveyance of Title. Should the decision later be made to transfer
ownership of the property encompassing PSC 4 to any private person or entity, then the
Navy shall either : 1) take all actions necessary to remediate the site to then existing
residential cleanup standards prior to effecting such transfer, or 2) deed record with the
Dougherty County Register of Deeds appropriate restrictive covenants prohibiting future
residential usage of the property or disturbance of the site's surface cap through routine
excavation or building/utility construction, maintenance, or repair activities on or
immediately adjacent to the site. Should the Navy not have the requisite legal authority to
record such deed restrictions, then it shall take all steps necessary to ensure that the
cognizant Federal agency with such authority does so unless the property is remediated to
residential standards prior to such transfer. Should cleanup of the site not be effected to
residential standards, then notification will be given to USEPA Region IV and GEPD at least
30 days prior to any conveyance of title to the site to any third party(ies) and the
purchaser (s) of the site will be advised via the deed documentation as to then existing site
conditions and any/all associated Institutional Controls and long-term monitoring
requirements.
Posting. This ICP will be referenced in all MCLB Albany Utility Maps and in the Master
Plan and Land Use Control Assurance Plan for MCLB Albany. No maintenance or
construction activities are planned without referring to these documents.
References
ABB-Environmental Services. 1997. Potential Source of Contamination (PSC) Screening
Technical Memorandum, Marine Corps Logistics Base (MCLB), Albany, Georgia. Prepared
for Department of the Navy, Southern Division, Naval Facilities Engineering Command
(SOUTHNAVFACENGCOM), North Charleston, South Carolina (June).
Applied Engineering & Science, Inc. 1989. RCRA Facility Investigation of Marine Corps
Logistics Base, Albany, Georgia.
CEES-Blackhawk Geosciences, 1995, Geophysical Surveys PSCs 4, 5, 7,15,19, and 20 Marine
Corps Logistics Base Albany, Georgia. Prepared for ABB-ES, Inc. Tallahassee, Florida.
Envirodyne Engineers. 1985. Initial Assessment Study of Marine Corps Logistics Base,
Albany, Georgia. NEESA 13-065 (September).
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Harding Lawson Associates, Inc. 1999a. PSC 4 Resource Conservation and Recovery Act
Facility Investigation, MCLB Albany, Georgia. Prepared for Department of the Navy,
SOUTHNAVFACENGCOM, North Charleston, South Carolina (May).
HLA. 2000. Final Remedial Investigation and Baseline Risk Assessment Report, OU 6,
Marine Corps Logistics Base, Albany, Georgia. Prepared for SOUTHNAVFACENGCOM,
North Charleston, South Carolina. (December).
McClelland Engineers. 1987. Final Report, Confirmation Study Verification Step Marine
Corps Logistics Base, Albany, Georgia. Prepared for SOUTHNAVFACENGCOM, North
Charleston, South Carolina.
US Environmental Protection Agency (USEPA). 1996a. Soil Screening Guidance: Fact Sheet.
USEPA Publication 9355.4-14FSA. Office of Solid Waste and Emergency response. (July).
USEPA. 1996b. Soil Screening guidance: Technical Background Document. USEPA
publication 9355.4-17A. Office of Solid Waste and Emergency Response. (July).
USEPA. 1998. Risk-Based Concentrations Table (April), USEPA Region III Technical and
program Support Branch, Philadelphia, Pennsylvania.
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