EPA/ROD/R09-94/118
1994
EPA Superfund
Record of Decision:
FORT ORD
EPA ID: CA7210020676
OU04
MARINA, CA
03/15/1994
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Interim Action Record of Decision
Contaminated Surface Soil Remediation
Fort Ord, California
February 23, 1994
United States Department of the Army
Sacramento Corps of Engineers
February 10, 1994
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CONTENTS
1.0 DECLARATION 1
2.0 DECISION SUMMARY 3
2.1 Site Description 3
2.2 Site History 3
2.3 Enforcement and Regulatory History 3
2.4 Highlights of Community Participation 4
2.5 Scope and Role of Interim Action 4
2.6 Characteristics of a Typical Interim Action Site 4
2.7 Remedial Action Objectives and Summary of Site Risks 5
2.7.1 Human Health Considerations 6
2.7.2 Protection of Groundwater 6
2.8 Description of Alternatives 6
2.9 Alternative 1 - No Action 7
2.10 Alternative 2 - Excavation with Soil Treatment, Recycling, and/or Disposal 7
2.10.1 Screening Process for Recommended IA Areas 9
2.10.2 Approval Process for Interim Actions 10
2.10.3 Public Notice 11
2.10.4 Suitability for Onsite Treatment 11
2.10.5 Confirmation Reports 12
2.11 The Selected Remedy 12
2.12 Statutory Determinations 13
2.12.1 Protection of Human Health and the Environment 13
2.12.2 Compliance With ARARs 13
2.12.2.1 ARAR Development Rationale 14
2.12.3 Cost Effectiveness 14
2.12.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies 14
2.12.5 Preference for Treatment as a Principal Element 15
2.13 Documentation of Significant Changes 15
3.0 RESPONSIVENESS SUMMARY 16
3.1 Overview 16
3.2 Background on Community Involvement 16
3.3 Summary of Comments Received during the Public Comment Period and
Department of the Army Responses 16
3.3.1 Summary and Response to Local Community Concerns 17
3.3.1.1 Public Comments Regarding Community Relations 17
3.3.2 Summary and Response to Written Specific Legal and Technical
Questions 17
3.3.2.1 Summary of, and Army Response to, the Letter Received
from the MBUAPCD 17
3.3.2.2 Reprint of, and Army Response to, the Letter Received from
the California Environmental Protection Agency (Including
the DTSC and RWQCB) 18
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TABLES
1 Preliminary Remediation Goals
2 Summary of Interim Action Alternative Screening Evaluation
3 Applicable or Relevant and Appropriate Requirements for Alternative 2 - Excavation with Soil Treatment,
Recycling, and/or Disposal
4 Application of Waiver
PLATES
1 NPL Site Map
2 Site Eligibility Flowchart
3 Implementation Process Flowchart
4 Soil Treatment Options Flowchart
5 Treatment Options for the POST A
APPENDIX
A COMMUNITY RELATIONS ACTIVITIES CONDUCTED FOR FORT ORD REMEDIAL ACTIVITIES
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February 23, 1994
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Interim Action Record of Decision
Contaminated Surface Soil Remediation
Fort Ord, California
February 23, 1994
HLA Project No. 23366 00773
This document was prepared by Harding Lawson Associates at the direction of the U.S. Army Corps of Engineers
(COE) for the sole use of the COE and the signatories of the Federal Facilities Agreement, including the Army, the
U.S. Environmental Protection Agency, the California Environmental Protection Agency, including the Department of
Toxic Substances Control (formerly, the Toxic Substances Control Program of the Department of Health Services), and
the Regional Water Quality Control Board, Central Coast Region, the only intended beneficiaries of this work. No
other party should rely on the information contained herein without prior written consent of the COE and Army. This
report and the interpretation, conclusions, and recommendations contained within are based on information presented
in other documents that are cited in the text and listed in the references. Therefore, this document is subject to the
limitations and qualifications presented in the referenced documents.
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1.0 DECLARATION
Site Name and Location
Fort Ord is located near Monterey Bay in northwestern
Monterey County, California, approximately 80 miles
south of San Francisco. The base comprises
approximately 28,000 acres adjacent to the cities of
Seaside, Sand City, Monterey, and Del Rey Oaks to the
south and Marina to the north. The Southern Pacific
Railroad and Highway 1 pass through the western
portion of Fort Ord, separating the beach front from the
rest of the base. Laguna Seca Recreation Area and
Toro Regional Park border Fort Ord to the south and
southeast, respectively. Land use east of Fort Ord is
primarily agricultural.
Basis and Purpose
This decision document presents the chosen Interim
Action (IA) for soil remediation of selected areas at 41
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) sites on
Fort Ord, California (see Plate 1). This IA was selected
in accordance with CERCLA, as amended by the
Superfund Amendment and Reauthorization Act
(SARA), and, to the extent practicable, the National
Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This decision is based on the
Administrative Record for Fort Ord.
The United States Environmental Protection Agency
(USEPA) and the state of California concur with the
selected remedy.
Site Assessment
Actual or threatened releases of hazardous substances
from Fort Ord, if not addressed by implementing the
response action selected in this Interim Action Record
of Decision (IAROD), may present an imminent and
substantial endangerment to public health, welfare, or
the environment.
Description of the Remedy
The selected remedial alternative for the Interim Action
described in this IAROD addresses immediate,
imminent, and/or significant risks to human health and
the environment posed by limited areas of shallow
contaminated surface soil at Fort Ord, California. IA at
Fort Ord will likely be implemented before final
remedial alternatives or cleanup levels for given
chemicals have been established, but a conservative
approach will be used in developing soil cleanup levels
for these IA areas to reduce the likelihood of further
remedial actions at an IA area. The selected Interim
Action remedy will involve the following activities:
• Biological and ecological assessment of each IA
area
• Use of site eligibility criteria for screening
potential IA areas
• A regulatory approval process for implementing
lAs
• Excavation of limited quantities of shallow
contaminated surface soil, followed by
confirmation sampling and backfilling with clean
fill
• Soil treatment, recycling and/or disposal.
Whenever possible, the contaminated soil will be
treated or recycled, with landfill disposal used
only as a last resort. Soil treatment/recycling will
be performed at the Fort Ord Soil Treatment Area
(FOSTA) using biotreatment and/or soil vapor
extraction. Whenever feasible, treated soil will be
reused on Fort Ord.
• Preparation of confirmation reports of site
remedial Interim Action activities
Statutory Determination
This Interim Action is protective of human health and
the environment, complies with
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Declaration
federal and state applicable or relevant and appropriate
requirements, with the exception of one waiver, for this
limited-scope action, and is cost-effective. However,
this Interim Action is not intended to address fully the
statutory mandate for permanence and treatment to the
maximum extent practicable. This Interim Action
utilizes soil treatment whenever feasible and
appropriate. The statutory preference for remedies that
employ treatment that reduce toxicity, mobility, or
volume as a principal element, although partially
addressed in this remedy, will be fully addressed the
final basewide Record of Decision (ROD). The
necessity of subsequent actions to address fully the
threats posed by the conditions at these Interim Action
areas will be evaluated in subsequent decision
documents and the final basewide ROD. If hazardous
substances remain on site above health-based levels, a
review will be conducted at 5 year intervals after
remedial action is commenced to ensure that the
remedy continues to provide adequate protection of
human health and the environment. Because this is an
Interim Action ROD, review of this remedy will be
ongoing as final remedial alternatives for Fort Ord are
developed.
J/Mmfrf
: F. Ellzey, Jr.
Colonel, U.S. Army
Commanding
EelTiOrd
Joseph A. Cochran
BRAG Environmental Coordinator
Fort Ord
a v
Anthony J. Landis,~P.E.
Chief of Operations, Office of Military Facilities
California Environmental Protection Agency
Department of Toxic Substances Control
/ /,
illiam R. Leonard
Executive Officer
California Environmental Protection Agency
Central Coast Regional Water Quality Control
Board
John C. Wise
Deputy Regional Administrator
U.S. Environmental Protection Agency,
Region IX
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2.0 DECISION SUMMARY
2.1 Site Description
Fort Ord is located near Monterey Bay in northwestern
Monterey County, California, approximately 80 miles
south of San Francisco. The base comprises
approximately 28,000 acres adjacent to the cities of
Seaside, Sand City, Monterey, and Del Rey Oaks to the
south and Marina to the north. The Southern Pacific
Railroad and Highway 1 pass through the western
portion of Fort Ord, separating the beach front from the
rest of the base. Laguna Seca Recreation Area and
Toro Regional Park border Fort Ord to the south and
southeast, respectively. Land use east of Fort Ord is
primarily agricultural.
2.2 Site History
Since its opening in 1917, Fort Ord has primarily
served as a training and staging facility for infantry
troops. No permanent improvements were made until
the late 1930s, when administrative buildings,
barracks, mess halls, tent pads, and a sewage treatment
plant were constructed. From 1947 to 1975, Fort Ord
was a basic training center. After 1975, the 7th Infantry
Division (Light) occupied Fort Ord. Light infantry
troops are those that perform their duties without heavy
tanks, armor, or artillery. Fort Ord was selected for
closure in 1991. The majority of the soldiers were
reassigned to other Army posts in 1993. Although
Army personnel still operate the base, no active army
division is currently stationed at Fort Ord.
The three major developed areas within Fort Ord are
the Main Garrison, the East Garrison, and Fritzsche
Army Airfield (FAAF). The remaining undeveloped
property (approximately 20,000 acres) was used for
training activities. The Main Garrison contains
commercial, residential, and light industrial facilities. It
was constructed between 1940 and the 1960s, starting
in the northwest corner of the base and expanding
southward and eastward. During the 1940s and 1950s,
there was a small airfield in the central portion of the
Main Garrison. This airfield was decommissioned
when FAAF was
completed, and the airfield facilities were redeveloped
as motor pools or for other operations. FAAF, which
serves as the general airfield for Fort Ord, is in the
northern portion of the base, adjacent to the city of
Marina. FAAF was incorporated into Fort Ord in 1960
and expanded in 1961. The East Garrison occupies 350
acres on the northeastern edge of the base and consists
of military and industrial support areas, recreational
facilities, and recreational open space.
Generally, chemicals present in soil at Interim Action
sites are the result of former routine maintenance and
support activities on Fort Ord. Such activities include:
maintenance of military vehicles at wash racks, tank
storage of chemicals such as waste oil, the use of
oil/water separators in drainage areas, and pesticide use
and storage.
2.3 Enforcement and Regulatory History
Environmental investigations began at Fort Ord in
1984 at FAAF under RWQCB cleanup or abatement
orders 84-92, 86-86, and 86-315. Investigations
indicated the presence of residual organic compounds
from fire drill burning practices at the Fire Drill Burn
Pit (Operable Unit 1 or OU-1). The subsequent
Remedial Investigation/Feasibility Study (RI/FS) for
OU-1 was completed in 1988, and cleanup of soil and
groundwater began. In 1986, under RWQCB cleanup
or abatement orders 86-87, 86-317, and 88-139, further
investigations began of the landfill areas (Operable
Unit 2 or OU-2), and the preliminary site
characterization was completed in 1988. In 1990, Fort
Ord was placed on the U.S. Environmental Protection
Agency's (USEPA) National Priorities List (NPL)
primarily because of volatile organic compounds found
in groundwater beneath OU-2, and a Federal Facility
Agreement (FFA) under CERCLA Section 120 was
signed by the Army, USEPA, DTSC, and RWQCB.
The FFA establishes schedules for commencing
remedial investigations and feasibility studies, and
requires completion of remedial actions as
expeditiously as possible. The basewide RI/FS
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Decision Summary
began in 1991, and Fort Ord was placed on the Base
Realignment and Closure List (BRAC). The final
Feasibility Study for OU-2 was completed October 1,
1993.
2.4 Highlights of Community Participation
On November 15, 1993, the United States Department
of the Army (Army) presented the Proposed Plan for
this basewide Interim Action at Fort Ord to the public
for review and comment. The Proposed Plan
summarizes information in the Interim Action
Feasibility Study (IAFS) and other documents in the
Administrative Record for the base. These documents
are available to the public at the following locations:
Fort Ord Post Library, Building 4275 North-South
Road, Fort Ord, California; and Seaside Branch
Library, 550 Harcourt Avenue, Seaside, California.
The entire administration record is available at 1143
Echo Avenue, Suite F, Seaside, California.
Comments on the Proposed Plan were accepted during
a 30-day public review and comment period that began
on November 15 and ended on December 15, 1993. A
public meeting was held on November 30, 1993, at the
Doubletree Hotel, Portola Plaza, in Monterey,
California. At that time, the public had the opportunity
to ask the Army questions and express its concerns
about the plan. In addition, written comments were
accepted during the public comment period. Responses
to comments received during the public comment
period are included in the Responsiveness Summary
(Section 3.0), which is part of this Interim Action
Record of Decision (IAROD).
2.5 Scope and Role of Interim Action
The scope of this IA is to address areas of limited
surficial soil contamination on Fort Ord through
excavation of contaminated soil. Excavated
contaminated soil from these IA areas will be treated,
recycled, or disposed of as described in Section 2.12.5.
Plate 1 identifies 41 CERCLA sites on Fort Ord where
these IA excavations may be implemented.
In 1991, Congress mandated a three-year completion
schedule for RI/FS documents for
closing BRAC sites such as Fort Ord (Public Law
102-190). Furthermore, acceleration measures
suggested by the USEPA's draft Superfund
Acceleration Cleanup Model (SACM) Guidance
Manual recommend allocating and expanding
resources to clean up areas that pose the greatest risk to
human health and the environment while expending
resources on sites that can (1) be cleaned up quickly in
keeping with reuse goals and objectives and (2) be
verified as clean and turned over to government
agencies or sold to private entities for use and further
development.
The economic impact of Fort Ord's closure is another
impetus to accelerate the implementation of remedial
actions. Closure of Fort Ord will have significant
repercussions on the local economy, and timely
conversion of Fort Ord property to civilian uses is a
high priority to the local community as well as the
Army. By conducting this IA, a large portion of Fort
Ord property contaminated by chemicals could be
cleaned up and made ready for civilian reuse years
earlier than if remedial measures for these areas were
implemented after the final basewide ROD, which is
anticipated to be completed in 1995. Consequently,
remedial investigations and actions at Fort Ord must be
accelerated.
IA at Fort Ord will be implemented before final
remedial alternatives or cleanup levels for given
chemicals or combinations of chemicals have been
established. Further remedial actions may be required
at IA areas after final cleanup levels are established in
the approved basewide ROD for Fort Ord. A
conservative approach will be used in developing soil
cleanup levels for these IA areas to reduce the
likelihood of further remedial actions at an IA area.
(The development of these cleanup levels is detailed in
Section 2.7 below). Therefore, the IA is consistent with
the anticipated final remedy for these areas.
2.6 Characteristics of a Typical Interim
Action Site
Fort Ord covers approximately 44 square miles. The
majority of soil at Fort Ord consists of sand deposits.
The average depth to water beneath Fort Ord is
typically 60 to 150 feet, and, in
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Decision Summary
many places, the first major clay barrier between
aquifers is located 600 to 700 feet below ground
surface.
The Salinas Basin and the Seaside Basin are the two
main hydrogeologic structures underlying Fort Ord.
The Salinas Basin underlies the northern part of Fort
Ord; the Seaside Basin underlies the southern part
(approximately two-thirds of the base). The location
and characteristics of the boundary are uncertain
between these two basins. Further information on Fort
Ord geology and hydrogeology is presented in the
IAFS and other documents in the Administrative
Record for Fort Ord.
Information gathered to date during ongoing site
characterization activities at Fort Ord has identified
areas within 41 sites that may be potentially suitable
for lAs; of these, nine have been initially recommended
for lAs (Plate 1). Potential IA areas are located
throughout Fort Ord and are not limited to any single
portion of the base. For the purpose of screening,
developing, and selecting an appropriate remedial
action at these IA areas, a "typical" IA remedial unit is
described below. If additional sites (beyond the 41
sites) are identified for which the processes developed
in this document are applicable, then an Explanation of
Significant Differences (ESD) will be prepared, or this
IAROD will be amended to include these additional
sites and issued for public comment.
The following physical characteristics are applicable to
all the preliminarily identified IA areas:
• Contaminated soil, like most surface soil at Fort
Ord, consists of sand and/or silty sand of fine to
medium grain size.
• Groundwater is relatively deep, typically more than
60 feet below the ground surface.
• Contaminated soil is of limited extent, often less
than 500 cubic yards (cy), and no more than 5,500
cy of contaminated soil.
• Contaminated soil to be excavated is not more than
25 feet below the ground surface.
• Generally, the chemicals present in contaminated
soil at these potential IA areas are the result of
routine Fort Ord activities. Typically this soil is
located near maintenance or service facilities, such
as wash racks, oil/water separators, drainage areas,
or former storage tanks.
• Chemicals in contaminated soil that are likely to be
the object of an IA are: petroleum hydrocarbons,
solvents, oils, metals and pesticides.
2.7 Remedial Action Objectives and
Summary of Site Risks
The primary rationale for the development of Interim
Remedial Action Objectives (RAOs) is the reduction of
immediate risks to human health and protection of
groundwater at an IA area. RAOs for the protection of
human health from exposure to chemicals in
contaminated soil at an IA area consider the following
exposure routes: ingestion or dermal contact with the
contaminated soil, ingestion of contaminated soil or
groundwater affected by chemicals leaching from
contaminated soil, and the inhalation of dust created
from contaminated soil.
Achievement of the RAOs for the reduction in
long-term human exposure to the contaminated soil
through the above pathways requires the establishment
of allowable chemical concentrations in surface soils.
Soil having such allowable chemical concentrations, if
left in place, will not pose unacceptable risks to future
residents or users of the area. Similarly, achievement of
the RAOs for the protection of groundwater quality, as
well as for the prevention of ingestion of contaminated
groundwater, requires the establishment of allowable
chemical concentrations in the soil that will not
adversely impact groundwater, if present. The
methodology used to establish these allowable
concentrations is presented below.
Risks to the ecosystem from the contaminated soil and
proposed remedial action will be qualitatively assessed
at each IA area. If such a qualitative analysis indicates
that a quantitative analysis is necessary to assess the
ecological
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Decision Summary
risks posed either by contaminated soil or by potential
remedial activities at an area, the appropriateness of
conducting an IA will be re-evaluated. As mentioned
previously, further remedial actions at IA areas may be
specified in the final basewide ROD for Fort Ord;
however, a conservative approach will be used to
minimize the likelihood of future remedial actions.
2.7.1 Human Health Considerations
The RAO for the IA areas is the achievement of an
acceptable aggregate human health risk estimate of: (1)
10~6 excess cancer risk (one-in-one million probability
of an exposed individual developing cancer) or lower
in accordance with USEPA methods (see Table 1) and
(2) a hazard index of 1 or less, to address possible
noncancer health risks. Achievement of the RAO will
be evaluated separately for each of the IA areas and
will apply to soil treated at the Fort Ord Soil Treatment
Area, as described in Section 2.10. Site
Characterization Reports for proposed IA areas will
contain Screening Risk Evaluations (SREs), which
identify Preliminary Remediation Goals (PRGs), also
listed in Table 1 of this document, for individual soil
chemical concentrations at each proposed IA area. The
SREs performed for each site using chemical-specific
PRGs and environmental concentration data will be
used to evaluate contributions of site chemicals to
cumulative area-related health risk estimates.
Chemical-specific PRGs will then be revised as
necessary to develop Target Cleanup Concentrations
(TCCs) that address possible cumulative effects of
exposure to multiple site-related chemicals and meet
the overall interim RAOs. Interim RAOs and potential
remediation requirements were also listed in the IAFS.
These RAOs are in accordance with the National
Contingency Plan (NCP), and CERCLA guidance. The
development of PRGs is described in detail in the Draft
Technical Memorandum, Preliminary Remediation
Goals, dated June 14, 1993; these PRGs were also
presented in the IAFS and are presented in Table 1. If
necessary, additional PRGs will be developed using the
same methodology.
2.7.2 Protection of Groundwater
Chemicals in contaminated soil at each IA area will be
evaluated for their potential impact to groundwater. As
discussed in the Technical Memorandum: Approach to
Evaluating Potential Groundwater Quality Impacts,
dated July 29, 1993, organic compounds in the
contaminated soil within the unsaturated zone will be
evaluated using an USEPA-developed partitioning
mass transport model (VLEACH). This model will use
groundwater depth and soil characteristics specific to
an IA area to estimate potential maximum groundwater
chemical concentrations for given chemical soil
concentrations. TCCs for organic chemicals based an
human health exposures discussed above will be
evaluated using this model to ensure that state and
federal primary maximum contaminant levels (MCLs)
in groundwater will not be exceeded. If state or federal
primary MCLs are predicted to be exceeded in
groundwater, the TCCs for organic chemicals will be
reduced accordingly until this standard of protection is
obtained. Pesticide- and metal-contaminated soil will
be assessed qualitatively to determine potential impacts
to groundwater quality.
2.8 Description of Alternatives
Two alternatives were developed in the IAFS for
detailed analysis: Alternative 1, No Action (as required
by CERCLA guidance); and Alternative 2, Excavation
with Soil Treatment, Recycling, and/or Disposal. Each
of these remedial alternatives were evaluated in the
IAFS in accordance with nine screening criteria as
described in the NCP. These criteria are:
• Overall Protection of Human Health and the
Environment
• Compliance with ARARs
• Long-Term Effectiveness
• Reduction of Toxicity, Mobility, and Volume
Through Treatment
• Short-Term Effectiveness
• Implementability
• Cost
• State Acceptance
• Community Acceptance.
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Table 2 presents a summary of these evaluations.
2.9 Alternative 1 - No Action
Alternative 1, the No Action alternative, provides a
baseline from which to evaluate other alternatives and
is required to be considered under CERCLA guidance.
Some minimal actions were assumed to be necessary
for this alternative, such as securing the area from
public access with fencing, installing monitoring wells,
and placing deed restrictions on the property. Annual
water quality monitoring reports and site assessments
were also assumed to be necessary.
The No Action alternative could be easily implemented
at an IA area; however, gaining community and
regulatory acceptance of this alternative would be
difficult. The estimated cost, primarily O&M, to
implement the No Action alternative when all 41
potential sites are considered, would be approximately
$19 million. This cost is based on the net present value
of annual O&M costs of approximately $1 million per
year, primarily for groundwater monitoring, over 30
years using a 5 percent interest rate.
2.10 Alternative 2 - Excavation with Soil
Treatment, Recycling, and/or
Disposal
Alternative 2 involves excavating contaminated soil
from the IA area and backfilling the excavation with
clean material. Soil will be removed using a backhoe
and either placed in stockpiles (nonhazardous) or
containers (hazardous) at the IA area while waiting for
laboratory analytical results or hauled immediately for
storage, treatment, or disposal.
Excavation is a simple, readily implementable,
remedial alternative for IA areas that will be protective
of the community and site workers. The services and
materials required for treatment of soil will also be
readily available.
Excavation at an IA area could be completed within a
week, because soil to be excavated is shallow and does
not cover a large area. Field screening analyses and
laboratory confirmation
samples will be required to establish that contaminated
soil had been removed before backfilling began.
Analytical results may require up to two weeks to
obtain. One destination for excavated soil will be the
Fort Ord Soil Treatment Area (FOSTA) located at the
519th Motor Pool. The FOSTA will serve several
purposes: (1) as an area to store excavated IA soil
pending waste classification as well as for storage of
soil until sufficient quantities are obtained for treatment
or recycling; and (2) as a treatment area for
nonhazardous soil containing petroleum hydrocarbons
and solvents.
Some excavated soil will be stored in containers at
FOSTA pending results of laboratory analysis. If the
soil is characterized as hazardous, and cannot be
treated at FOSTA, it will be sent off site for treatment,
recycling, and/or disposal.
Soil treatment using bioremediation and soil vapor
extraction (SVE) treatment technologies are considered
"presumptive" remedies because their effectiveness has
already been established by previous successful
implementation at Fort Ord. The effectiveness of
bioremediation was demonstrated at the Operable Unit
1 Fire Drill Area at Fritzsche Army Airfield. Soil vapor
extraction was demonstrated as an effective technology
in a pilot study at a non-NPL petroleum hydrocarbon
cleanup also at Fritzsche Army Airfield. These
technologies are presumed to work successfully for
excavated IA soil at the FOSTA because the
contaminated soil types, as well as the chemicals, are
similar to those in areas where these technologies have
been successfully implemented previously. Application
of these technologies at FOSTA is described below.
• Bioremediation: Contaminated soil will be
segregated depending on the soil type and the type
of petroleum hydrocarbons present. Treatment may
consist of irrigating, aerating, and mixing the soil
to provide soil conditions conducive to increased
microbial activity. Inorganic nutrients (i.e., bulk
agricultural fertilizers or ammonia, nitrate, and
phosphate of industrial or food-grade quality) will
be dissolved in water and periodically applied to
the soil. The amount and rate of application will be
based on data
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collected from field operations and pretreatment
laboratory studies, if necessary. To maintain
proper soil moisture conditions, the soil will be
irrigated with water as needed. The application of
water will be controlled to minimize the
production of leachate. The amended and irrigated
soil will be mixed periodically or aerated using
perforated plastic pipes within the pile. Air
emissions are not anticipated to present any
significant health risks as a result of
bioremediation activities. This treatment is
intended for use on soils contaminated with heavy,
nonvolatile petroleum hydrocarbons such as jet or
diesel fuels, and/or pesticides.
• Soil Vapor Extraction: Vacuum extraction pipes
consisting of plastic perforated pipes will be
installed beneath or within each pile. Each soil pile
will be covered with polyethylene sheeting.
Concrete blocks or sand bags will be used all
around and on top of each pile to hold down the
plastic cover. An electric blower will draw air
through the soil to remove volatile organic
compounds (VOCs) from the soil. Air leaving the
piles will be treated with vapor phase carbon or
prefabricated abatement units as required. Soil
amenable for this treatment will generally contain
volatile petroleum hydrocarbons or solvents.
Prior to treatment of excavated soil, the FOSTA will be
modified in the following manner:
• A liner system (permeability less than 10~6 cm/sec)
will be constructed beneath the treatment unit(s)
areas that minimizes leachate migration from the
units.
• Perimeter berming will be constructed around the
treatment unit(s) that prevents precipitation runoff
from the unit(s) and prevents runon from outside
the unit(s).
The Army will prepare a groundwater monitoring plan
to perform groundwater monitoring during the
FOSTA's operation, closure, and if necessary, post
closure period. If groundwater monitoring is
technically warranted, existing monitoring wells
around the FOSTA will be used. The location of
monitoring wells and frequency of sampling will
be established during the Remedial Design phase.
At the conclusion of soil treatment, the FOSTA will be
closed. Closure will include decontamination of
treatment components, and removal and proper
disposal of contaminated components and associated
soil at an appropriate waste management facility.
Future IA areas may require treatment technologies in
addition to those described above. An Explanation of
Significant Differences or IAROD Amendment will be
used to address these new IA areas and any new
necessary soil treatment technologies. These
technologies may include: low temperature thermal
desorption, soil stabilization/solidification, or soil
aeration.
Recycling or treatment of excavated soil sent offsite
will be performed at an approved facility whenever this
option is feasible. When appropriate, treated or
untreated soil below health-based standards and
classified as "inert" under Title 23 CCR, Chapter 15,
Article 2, "Waste Classification and Management"
may be used on Fort Ord as part of the OU 2 landfill
cap, as roadbase material, or as clean fill. Soil that can
not be treated at the FOSTA will be transported off
Fort Ord using, where appropriate, a licensed
hazardous waste hauler. Such soil will be sent to a
licensed treatment, storage, or disposal (TSD) facility
designed and approved to accept such wastes.
The cost of Alternative 2, Excavation with Soil
Treatment, Recycling, and/or Disposal, is comparable
to the No Action alternative. The cost, including
capital and O&M, for implementing this alternative at
the nine preliminarily identified IA areas is
approximately $1 million. A total of 6,600 cubic yards
(cy) is anticipated to be excavated for all of these nine
areas. Extrapolating these costs to all 41 sites results in
a total cost of approximately $24 million. A quantity of
2,750 cy of excavated soil from each of the other 32
sites with potential IA areas assumed in this
extrapolated cost estimate. This quantity of excavated
soil is a conservative maximum. This cost assumes that
the soil from the other 32 areas will be treated at
FOSTA, recycled, or
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disposed in the same ratio as the nine preliminary
identified sites (79 percent for the POST A, 19 percent
for offsite disposal, and 2 percent for recycling.).
Furthermore, costs for the construction of FOSTA, two
years of groundwater monitoring, excavation and
backfill, mobilizing, and regulatory interaction are also
included in this estimate.
2.10.1 Screening Process for
Recommended IA Areas
An IA area must meet given site conditions with
respect to the nature and extent of the contaminated
soil and IA location constraints, as described below.
These criteria are included in the IA area eligibility
checklist presented in the IAFS.
• Maximum Depth of Chemicals: IA excavations
will be made with standard construction equipment
to a maximum depth of 25 feet below grade. This
depth limitation is based on the maximum reach of
an extended backhoe. Furthermore, the bottom of
IA excavations win be no deeper than 5 feet above
the groundwater table, including the capillary
fringe, at that area.
The maximum depth of chemicals detected above
their respective TCCs will be estimated from data
presented in the site characterization report. This
estimated depth will be compared with the depth
limitation discussed above. Any site with
contaminated soil that requires excavation below
those depth limitations will not be recommended
for an IA as defined in this document and will be
addressed in the basewide RI/FS.
• Maximum Volume of Excavated Soil: The
maximum volume of contaminated soil to be
removed from a recommended IA area will be
estimated from available data collected during site
characterization activities and presented in the
Approval Memorandum. The maximum quantity
of contaminated soil to be excavated at any single
area considered for IA will be not more than 5,500
cy. This maximum volume is based on a
preliminary review of potential IA site data from
available SCRs and is not a technical or
regulatory restriction. Because an IA is intended to
be limited in scope, this maximum quantity
requirement is presented as a reasonable limit.
Many IA areas will have much smaller quantities
of soil. Agency approval will be required to exceed
quantity limitation of 5,500 cy.
Location Restrictions for IA Areas:
Excavation activities will be restricted in certain
locations. Each recommend IA area will meet the
following criteria:
- No IA will divert modify, or impact an
existing stream, watercourse, or wetland
- No property listed in the National Register of
Historic places will be impacted by IA
excavations
- IA excavations will not impact oak trees
greater than 6 inches in diameter and more
than 2 feet tall
- IA areas in the coastal zone will require a
consistency determination that the proposed
remedial actions are in conformance with
California's Coastal Zone Management Plan.
Biological and Cultural Resource Screening:
Because endangered or threatened plants and
animals are present at some locations at Fort Ord, a
Biological Area Clearance (BAG) will be
completed for each IA area. These species are
generally found at undeveloped regions of the
base. Because preliminarily identified IA areas are
located in developed areas, these species are not
anticipated to be impacted by the proposed lAs.
Documentation of the BAG will be included with
the approval memorandum.
Similarly, a Cultural Resources Clearance (CRC)
will be completed for each IA, either as part of
current site characterization activities or prior to
IA. Documentation of the CRC will also be
included in the Approval Memorandum.
Ecological Assessment: A qualitative Ecological
Assessment (EA) of each IA area will be
performed to determine if a
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quantitative risk assessment is required for an IA area.
A summary of this qualitative ecological risk
assessment will be included with the Approval
Memorandum. If a quantitative risk assessment is
recommended, the appropriateness of an IA at each
area will be re-evaluated.
• Materials Restricted from Interim Action:
lAs are intended only to address shallow
contaminated soil that may contain pesticides,
metals, solvents, and petroleum hydrocarbons. The
remediation of other wastes, such as radioactive
materials, medical wastes, liquids, and sludges, are
not addressed in this document. Agency approval,
such as an Explanation of Significant Differences
(ESD) or ROD amendment, will be required to
perform an IA excavation on such materials.
Flowcharts on Plates 2 and 3 summarize the
methodology used to evaluate and recommend areas
for an IA, and the implementation process for these
recommended IA areas. These flowcharts as well as a
checklist for site eligibility criteria that will be used to
screen a proposed IA area were presented in the IAFS;
this checklist will be completed and included in the
Approval Memorandum as described below in Section
2.10.3.
2.10.2 Approval Process for Interim
Actions
Prior to performing an IA, an Approval Memorandum
will be prepared for each recommended IA area. This
memorandum will demonstrate that the proposed IA
area meets the requirements and site conditions for an
IA as described in the IAFS. This memorandum will
reference completed SCRs and will include, at a
minimum:
• A description of the IA area and its geologic
conditions
• A completed site eligibility checklist for the area
• Results of a biological area clearance for
endangered species that will be impacted by
excavation activities, as well as other potential
ecological impacts
• Results of a cultural resources clearance
• A table of expected chemicals, with their
respective PRGs and TCCs
• A map showing the estimated areal extent of
contaminated soil, and an estimate of the cubic
yards of contaminated soil to be removed
• The anticipated soil waste classification, treatment,
and final disposition of the excavated soil for
excavated soil
• A summary of the qualitative ecological risk
assessment for the IA area.
Each Approval Memorandum will be submitted by the
Army to the USEPA, DTSC, and RWQCB. A verbal
notification of submittal will be performed by the
Army. Before beginning excavations at an IA area,
approval of this memorandum will be obtained from
agency representatives. Agency review of the Approval
Memorandum will be completed within 10 working
days of its submittal. Any agency approvals for the
authorization of the Approval Memorandum or
modifications of IA area eligibility requirements will
be confirmed in subsequent written correspondence
from the USEPA, DTSC, and RWQCB. In the event of
an agency failure to respond to the Army regarding the
Approval Memorandum within the specified review
period, the Army will assume concurrence and
commence with IA activities. If a dispute that cannot
be settled informally arises regarding the Approval
Memorandum, dispute resolution under the FFA could
be invoked. A dispute regarding any particular IA
area(s), however, will not prevent activities at other
approved IA areas.
Generally, modifications to the Approval
Memorandum are not anticipated because of the
restrictive nature of IA area eligibility criteria. Some
modifications of the Approval Memorandum may be
required, however, by the uncertain nature of field
activities and extent of chemicals present at an IA area.
If a dispute that cannot be settled informally arises over
any
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modification to the Approval Memorandum, dispute
resolution under the FFA could be invoked. Such a
modification will be required:
• To exceed the expected volume estimate of
contaminated soil to be removed at the proposed
IA area presented in the Approval Memorandum.
• To remove soil containing unanticipated hazardous
materials or chemicals encountered in an IA
excavation. In such an event, field work will be
postponed until an evaluation is made of the
applicability of an IA. If an IA is not applicable to
chemicals or materials, the site will be
recommended for the RI/FS process and IA
activities will cease.
• If excavated soil requires a different treatment or
class of landfill than proposed in the Approval
Memorandum.
Agency approval (verbal or written) will be required
for any of these modifications by the USEPA, DTSC,
and RWQCB. Written confirmation of such changes
will be sent to the agencies within 10 working days.
2.10.3
Public Notice
Advance notice of an IA will be placed in a major local
newspaper at least two weeks before excavation
activities. Prior, ongoing, or planned future IA
activities will also be described in the quarterly
newsletter, the Advance, prepared by the Army for
local residents. Notification of these proposed IA
activities will also be distributed to other local county
agencies, such as the Monterey County Health
Department and Monterey County Unified Air
Pollution Control District, although site remedial
activities at IA areas are not expected to fall within the
direct jurisdiction of these agencies.
2.10.4 Suitability for Onsite Treatment
Available data for soil at each IA area will be evaluated
to determine its preliminary waste classification. This
waste classification will be used to determine the
anticipated treatment and final disposition of the
contaminated soil. These
preliminary determinations, as well as the estimated
quantity of excavated soil, will be presented in the
Approval Memorandum. If soil from an IA area is not
suitable for treatment on Fort Ord, the Army will
document the rationale for this decision. Cumulative
quantity totals will be recorded for all soil sent off Fort
Ord for disposal and will be available for agency
review. Soil may be stored in rolloff bins pending
confirmation of the waste classification.
Excavated soil taken to the FOSTA as part of these IA
activities will be classified according to Chapter 11 of
Title 22 CCR, "Identification and Listing of Hazardous
Waste." Excavated soil will be assessed for the
presence of pesticides, metals, solvents, and total
petroleum hydrocarbons (TPH). Soil expected to be
characterized as hazardous waste will be containerized
for further characterization and/or storage. As
described in Plates 4 and 5, excavated soil will be
treated and classified at the FOSTA, as appropriate.
Soil containing only petroleum hydrocarbons, without
metal concentrations above background levels or
detectable pesticide concentrations, will be treated to
500 mg/kg. This level was developed based on
conservative site-specific data for Fort Ord, and applies
to the placement or removal of TPH-containing soil
throughout all of Fort Ord. This cleanup level is
demonstrated to be protective both of human health
and groundwater quality and is consistent with the inert
waste as defined in Title 23 CCR, Chapter 15, Article 2
for Fort Ord. A 10"6 excess cancer risk and hazard
index of less than one was used in the Fort Ord Draft
Technical Memorandum: Preliminary Remediation
Goals, dated June 14, 1993 to evaluate health-related
risks of TPH in surface soil. To evaluate potential
groundwater impacts of these PRGs, VLEACH, a
USEPA-developed groundwater modeling program,
was run using conservative assumptions. The specific
modeling techniques used in assessing groundwater
impacts are outlined in the Fort Ord Technical
Memorandum: Approach to Evaluating Potential
Groundwater Quality Impacts, dated July 29, 1993.
Soil containing metals, solvents, and/or pesticides will
be containerized and
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characterized to determine if offsite disposal or onsite
treatment and/or onsite disposal in the OU-2 landfill is
applicable for this waste (see Plate 5). The
characterization data will be qualitatively evaluated to
determine if the soil has the potential to impact
groundwater quality (exceed their respective MCLs). If
the data indicates that no potential for exceeding MCLs
in groundwater exists, then the soil would be classified
as inert waste as defined in 23 CCR Chapter 15 Article
2. Soil that contains a listed RCRA hazardous waste
will be sent off Fort Ord for disposal.
Soil containing chemicals other than metals, pesticides,
solvents, and TPH will be evaluated on a case-by-case
basis for continued storage, treatment, recycling,
and/or disposal. Agency approval will be required for
onsite treatment and/or recycling.
2.10.5 Confirmation Reports
A summary of IA field activities for each will be
presented in a Confirmation Report for each area. The
report will include, at a minimum:
• Copies of waste manifests for the excavated soil, if
applicable
• A site map showing the limits of the excavation
and location of confirmation samples
• A brief documentation of field activities, including
a discussion of any agency-approved deviations or
modifications to the Approval Memorandum
• Records of backfill compaction and density tests
• Chain of custody forms and laboratory analytical
results for soil samples taken from the IA area
• A map showing the vertical and horizontal extent
of excavated soil, and remaining chemical
concentrations in any impacted soil left in place
after the IA
• A determination of whether RAOs have been
achieved at the IA area. This determination
may be used as the basis for subsequent decision
documents that indicate that all necessary remedial
actions have been taken at the area, in accordance
with CERCLA 120 (h) (3), and thus is suitable for
transfer by deed
• Planned future remediation or characterization
activities, if any, that are apparent at the time of the
preparation of the confirmation report.
Each Confirmation Report will evaluate the risks of
residual IA chemical concentrations at IA areas and
document that further remedial actions are or are not
required. Each confirmation report will be sent to the
EPA, DTSC, and RWQCB. These confirmation reports
will support subsequent decision documents that may
allow for the transfer of property, and that may be
prepared prior to the basewide ROD.
2.11
The Selected Remedy
The selected IA alternative must meet the first two of
the nine CERCLA screening criteria described in
Section 2.8 above: protection of human health and the
environment as well as compliance with ARARs. The
next five criteria are primarily balancing criteria used
for comparing alternatives. The final two criteria, state
and community acceptance, are used to address the
concerns of state agencies and surrounding
communities. Table 2 presents a summary of the
alternative screening evaluation. Based on the
assessment in the IAFS, Alternative 2 is the selected
remedial alternative for the following reasons:
• Alternative 1: No Action is not protective of
human health and the environment. In addition,
this alternative will not be timely because it will
delay or prohibit transfer of property from the
Army to civilian use. Thus, Alternative 1 is not a
feasible alternative for IA at Fort Ord.
• Alternative 2: Excavation with Soil Treatment,
Recycling, and/or Disposal will allow timely
transfer of Army property to
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civilian use, will be protective of human health and
the environment through the achievement of
interim RAOs, and will comply with ARARs for
lAs at Fort Ord, except for the waiver as noted
below.
The selected remedy, alternative 2, will meet
Interim RAOs. These RAOs are based on the
reduction of immediate risks to human health and
the environment. The development of these RAOs
is discussed in Section 2.7.
2.12 Statutory Determinations
The selected remedy meets the requirements of Section
121ofCERCLAto:
• Be protective of human health and the
environment
• Comply with ARARs, (except for one waiver as
described in Section 2.12.2 below)
• Utilize permanent solutions and alternative
treatment technologies or resource recovery
technologies to the maximum extent practical
• Satisfy the preference for treatment as a principal
alternative.
2.12.1 Protection of Human Health and the
Environment
The selected remedy for Interim Actions at Fort Ord is
protective of human health and the environment
through the removal of contaminated soil from the IA
areas. Excavated soil will be classified according to its
waste characteristics and handled appropriately. This
excavated soil will be treated to reduce toxicity
mobility and/or the volume of chemicals in the
contaminated soil, whenever feasible.
2.12.2 Compliance With ARARs
ARARs include "applicable" or "relevant and
appropriate" requirements. The categories of ARARS
are: Action-specific, chemical-specific, and location
specific. Action-, chemical-, and location-specific
ARARs for the selected remedy, excavation with soil
treatment, recycling, and/or disposal, are presented in
Table 3.
The selected remedy complies with ARARs, except
that a waiver from the 90-day storage limitation for
hazardous wastes (Title 22 CCR, Chapter 12, Article 3,
Section 66262.34) is invoked. Such storage
requirement under Title 22 would otherwise function to
limit the Army's ability to store both RCRA hazardous
waste and non-RCRA hazardous waste (as defined in
Title 22, Chapter 11, Article 5) at the FOSTA beyond
90 days. However, Section 121 [d] [4] of CERCLA
legislation allows selected ARAR(s) to be waived for a
remedial action under certain circumstances. One such
circumstance is a remedial action that is only part of a
total remedial action, such as an IA, which will attain
or meet such standards when completed. Upon
completion of the final remedy for Fort Ord, the
standard or level of control of Title 22, Chapter 11,
Article 3, Section 662652.34 shall have been met.
The waiver will apply as outlined in Table 4,
Application of Waiver. The purpose of the waiver is
twofold. One, for RCRA hazardous waste, the waiver
is invoked to allow storage until sufficient amounts of
material are accumulated to make offsite treatment or
disposal practical. Currently, the FOSTA is not
designed to treat RCRA hazardous waste, and the
selected remedy in the ROD is limited to treatment of
designated and inert waste as classified by CCR Title
23, Chapter 15. Thus, as stated above, an extended
storage period is required to accumulate the materials
to be shipped offsite. Two, for non-RCRA hazardous
waste, the waiver is similarly invoked to allow storage
until sufficient amounts are accumulated to make
offsite treatment or disposal practical. Additionally,
because the Army may decide to treat non-RCRA
hazardous waste, given the statutory preference for
treatment, the waiver is also required to allow time to
decide whether the ROD should be amended or an
explanation of significant difference obtained in order
to allow such treatment.
Although the waiver will be applied as described
above, in order to be protective of the environment, the
Army will comply with the FOSTA Operation,
Maintenance, Monitoring and Closure Plan, a primary
document under the FFA, which will specify soil
treatment, monitoring and closure, including hazardous
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waste inventory, storage and tracking procedures. For
the interim excavation activities proposed in this
document, no other waivers of ARARs are necessary.
The parties (Army, USEPA, and State of California)
have agreed that, Title 23 CCR, Division 3, Chapter 15
(Chapter 15), Article 2 applies to the discharge of
treated soil. The parties have not agreed as to whether
Chapter 15 is an ARAR for construction and operation
of the POST A soil treatment area. However, the State
has agreed not to dispute the IAROD because the
Army has agreed to design the FOSTA treatment area
as described in Section 2.10 of the IAROD.
No chemical-specific cleanup levels have been
established by federal or state agencies for chemicals in
soil. TCCs for each IA area will be used to define the
minimum limits of excavation. Final cleanup levels for
chemicals in soil will be presented in the basewide
ROD. Because these TCCs will be established prior to
the completion of the basewide ROD, further remedial
actions may be required if final cleanup levels in the
basewide ROD are more stringent than the chemical
concentrations remaining in the soil at the IA area. A
conservative approach, however, will be used in the
development of TCCs to minimize the necessity of
future remedial actions.
Related guidance that was identified as To-be-
considered (TBCs) in the IAFS included "public
nuisance" regulations of the Monterey Bay Unified Air
Pollution Control District (MBUAPCD), as well as the
Monterey County Oak Tree Preservation Ordinance.
The MBUAPCD has not established requirements
regarding dust emissions from excavation activities.
The closest regulation is the Public Nuisance
regulation, which can be invoked in the interest of
protecting public health. In consideration of the oak
tree ordinance, mitigation measures will be taken as
necessary to preserve oak trees that are larger than 6
inches in diameter and greater than 2 feet tall and that
may be detrimentally contaminated by IA excavations.
The Army need not comply with TBCs. These TBCs
were considered as screening criteria, but are not
ARARs or performance standards.
2.12.2.1
ARAR Development Rationale
The purpose of the proposed IA is to address limited
volumes of contaminated soil. Because groundwater
will not be treated or contaminated by the proposed IA
activities, requirements regarding groundwater quality,
protection, and treatment, are not ARARs for these
lAs. Therefore, groundwater requirements, such as
Maximum Contaminant Levels (MCLs), are not
presented in this review of ARARs. Requirements
pertaining to groundwater will be addressed in the
basewide RI/FS and will be established in the final
basewide ROD.
IA will only be performed on selected areas at Fort
Ord. Proposed IA areas must pass site eligibility
criteria which set definitive bounds for any
recommended IA areas. Any areas that do not meet
these criteria will not be the subject of an IA described
in this document. Thus, location-specific ARARs are
based on a specific recommended IA area that meets
these site screening criteria, and not on location
requirements for the entire Fort Ord site.
2.12.3
Cost Effectiveness
The selected alternative is a cost-effective solution for
reducing risks to human health and the environment for
the IA areas, and will also allow for the timely transfer
of property to the public. The estimated net present
value for the No Action alternative is approximately
$19 million. The maximum cost of the selected
alternative is approximately $24 million, and is
comparable to the No Action alternative. This estimate
for the selected alternative includes costs for soil
excavated from all 41 sites. Actual costs for the
selected alternative are likely to be significantly lower
because lAs will most likely not be implemented at all
of the 41 sites.
2.12.4 Utilization of Permanent Solutions
and Alternative Treatment
Technologies or Resource
Recovery Technologies
An IA is a remedial action that can be implemented
quickly and that, although not necessarily intended as a
final-site remedial
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measure, significantly reduces potential immediate,
imminent, and/or significant risks to human health or
the environment. lAs at Fort Ord will likely be
implemented before final remedial alternatives or
cleanup levels for given chemicals or combinations of
chemicals have been firmly established. Further
remedial actions may be required at IA areas after final
cleanup levels are established in the approved
basewide ROD for Fort Ord, but a conservative
approach will be used in developing Target Cleanup
Concentrations for these IA areas to reduce the
likelihood of further remedial actions at an IA area.
The preference for resource recovery (recycling) and
treatment of excavated soil is illustrated in Plate 4.
identified Excavation with Soil Treatment, Recycling,
and/or Disposal as the selected remedial response
action. Comments collected over the 30-day public
review period between November 15 and December
15, 1993 did not necessitate any significant changes to
the conclusions or procedures outlined in the IAFS and
Proposed Plan. In addition, no new IA sites or FOSTA
soil treatment technologies beyond those described in
the IAFS and Proposed Plan have been identified at
this time.
2.12.5 Preference for Treatment as a
Principal Element
The selected remedy satisfies the statutory preference
for treatment as a principal element in addressing the
human health and environmental threats posed by
contaminated soil at the IA areas. Plate 4 is a flowchart
showing soil treatment options, and which illustrates
the selected alternative's preference for soil treatment.
2.13 Documentation of Significant
Changes
As described in the Responsiveness Summary (Section
3.0), the Interim Action Proposed Plan for the Interim
Action Feasibility Study (IAFS) was released for
public comment on November 15, 1993, and a public
meeting was held on November 30, 1993. This
Proposed Plan
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3.0 RESPONSIVENESS SUMMARY
3.1
Overview
This Responsiveness Summary provides a summary of
the public comments and concerns regarding the
Proposed Plan and Interim Action Feasibility Study
(IAFS) at Fort Ord, California. At the time of the
public review period, the Army had selected a remedy
for conducting interim Actions for limited areas of
shallow surficial soil contamination at Fort Ord,
California.
On the basis of the written and verbal comments
received, the Army's Proposed Plan for Interim Action
was generally accepted by the public. However, some
citizens expressed concerns regarding the level of
public involvement in the selection of remedial
alternatives at Fort Ord, the location of the FOSTA,
and soil cleanup levels.
3.2 Background on Community
Involvement
The Army has implemented a progressive public
relations and involvement program for environmental
activities at Fort Ord. The Advance, published by the
Army, is a quarterly newsletter, sent to the public, that
highlights the status of ongoing and planned remedial
activities at Fort Ord. The Army also conducts a
quarterly Technical Review Committee to involve the
public in decisions made regarding remedial actions. In
addition, two toll-free 800 numbers are available for
concerned citizens to comment and receive answers
regarding the environmental restoration and transfer of
Fort Ord property. A synopsis of community relations
activities conducted by the Army is presented in
Appendix A.
The Army held a public comment period on these
actions from November 15, 1993, through December
15, 1993. Over 600 copies of the Proposed Plan were
mailed for public review and comment to interested
parties and were placed in the Fort Ord Post Library,
Building 4275 North-South Road, Fort Ord, California,
and Seaside Branch Library,
550 Harcourt Avenue, Seaside, California. This
Proposed Plan also invited readers to a public meeting
to voice their concerns.
This public meeting was held to discuss the selected
remedy and final IAFS with the public. This meeting
was held on November 30, at 7.00 in the Doubletree
Hotel in Monterey, California.
No comments were received from the public regarding
the proposed Interim Action prior to the publication of
the Proposed Plan and the start of the public comment
period. Comments received during this period are
addressed below.
3.3. Summary of Comments Received
during the Public Comment Period
and Department of the Army
Responses
The public comment period on the final IAFS and
Proposed Plan was held from November 15 to
December 15, 1993. A five day extension of this
comment period, to December 20, 1993, was granted to
the California Environmental Protection Agency
(Cal/EPA) at their request. Concerns from the general
public on the proposed IA were raised at the Public
Meeting (held on November 30, 1993) regarding the
location of the FOSTA, soil cleanup levels, as well as
the start of, and local contractor involvement in, IA
activities. Addition comments not related to the
proposed IA were raised regarding the Fort Ord OU2
landfills and the level of public involvement in the
development and selection of remedial activities
(through the Restoration Advisory Board). These
questions and comments were addressed during the
public meeting.
No written comments were received from the general
public during the public comment period. Two written
letters from regulatory agencies regarding specific
technical and legal questions were received during the
public comment period; one from the Monterey Bay
Unified Air Pollution Control District, and the second
from the Cal/EPA, including the DTSC and the
RWQCB. The letter from the MBUAPCD
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concerned air emissions from the FOSTA, and the
letter from the state concerned details on the FOSTA
and TPH soil cleanup levels for Fort Ord.
Comments from the local community that were not
sufficiently addressed during the public meeting are
summarized and addressed according to their topics in
the following sections of this document. Response to
the specific technical and legal issues raised by
regulatory agencies is also presented.
3.3.1 Summary and Response to Local
Community Concerns
Comments from the local community were voiced at
the Public Meeting, and are summarized and addressed
below. No written comments were received from the
local community during the public comment period.
3.3.1.1 Public Comments Regarding
Community Relations
Comment: The public meetings aren't adequately
advertised to the general public.
Army Response: The Public Meeting was
advertised in the Proposed Plan and the Herald two
weeks before of the scheduled meeting date. In
addition, a reminder regarding the scheduled time of
the public meeting was announced on local television
programs on the day of the meeting.
3.3.2 Summary and Response to Written
Specific Legal and Technical
Questions
Two written comments were received during the Public
Comment period, both from regulatory agencies: the
first from the Monterey Bay Unified Air Pollution
Control District (MBUAPCD) regarding air emissions
from soil treatment activities at the FOSTA; and the
second from the Cal/EPA regarding details of the
FOSTA construction.
3.3.2.1 Summary of, and Army Response
to, the Letter Received from the
MBUAPCD
The MBUAPCD had three main concerns regarding
the Proposed Plan and IAFS:
(1) MBUAPCD's Regulation X, Rule 1000, requires
that facilities emitting carcinogenic toxic air
contaminants not cause an excess cancer risk of
greater than one-in-one million. Furthermore, toxic
air contaminants (carcinogenic and
noncarcinogenic) must not result in an exposure of
greater than PEL/420 (where the PEL is the
Permissive Exposure Limit).
(2) Soil vapor extraction, which emits carcinogenic
toxic air contaminants, must have Best Available
Control Technology.
(3) Benzene was not identified in the table of
Preliminary Remediation Goals but is commonly
found in gasoline-contaminated soil.
Army Response to MBUAPCD Letter
Activities performed as part of this Interim Action will
conform to the health-based standards recommended
by the MBUAPCD (the PEL/420 or one-in-one million
excess cancer risk). No toxic air contaminants are
expected to be generated from the bioremediation of
soil, which will be the primary remedial treatment
technology for soil brought to the FOSTA.
Some soil may be treated by soil vapor extraction
(SVE). Any soil treated by SVE will be covered, and
air emissions will be "cleaned" using vapor phase
carbon drums before discharge to the atmosphere. Air
pollution abatement using this carbon treatment will
meet the Best Available Control Technology
requirements.
No benzene is expected to be present in soil collected
as part of these Interim Actions because
gasoline-contaminated soil (where benzene is normally
found) will not be excavated for these Interim Actions.
Thus, benzene is not expected to be present in any
N31264-H
February 23, 1994
United States Department of the Army
17
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Responsiveness Summary
significant quantities for soil collected as part of these
Interim Actions.
3.3.2.2 Reprint of, and Army Response
to, the Letter Received from the
California Environmental
Protection Agency (including
the DISC and RWQCB)
Generally, the State agrees with the Army's planned
Interim Actions; however, the Plan is incomplete in
describing the specific site modifications, treatment
system operation, and site closure of the Fort Ord Soil
Treatment Area (FOSTA). Specific Plan deficiencies
include: a) FOSTA location, b) modifications to the
existing concrete slab to insure containment, c)
groundwater monitoring during FOSTA operations,
closure, and post closure periods, d) soil treatment and
storage areas clean closure, e) decontamination area
modifications to contain wash water and subsequent
wash water disposal. The Plan must specify that:
a) The location of the FOSTA will be the 519th
Motor Pool Area at North-South Roads and Light
Fighter Drive. Non-hazardous soil storage and
treatment will occur on the existing concrete slab
between Buildings S-3897 and S-3898.
b) The concrete slab between Buildings S-3897 and
S-3898 used for soil treatment and storage will be
modified with the application of a concrete sealing
product. A concrete sealing product will be
selected based on the anticipated soil contaminants
and will provide containment of any leachate
during the active life of the unit. The slab area will
be modified to include concrete curbs around the
perimeter. Curbs will be designed to insure that
wastes are contained within the treatment area and
on the modified slab. Curbs will be designed to
prevent precipitation runoff from the treatment unit
and prevent runon from outside the unit
c) The Army will conduct groundwater monitoring
during the FOSTA's operation, closure, and, if
necessary, post closure periods. Groundwater
monitoring will be conducted using existing
groundwater
monitoring wells around the FOSTA. Specified
wells will be monitored quarterly as part of the
basewide monitoring program. Monitoring wells
will be selected during the Remedial design phase
and may be modified during FOSTA operation.
d) The Army intends to "clean close" the FOSTA at
the conclusion of treatment operations. Clean
closure will include removing and properly
disposing all remaining contaminated soils,
washing the concrete surface to remove all
remaining contamination. Where contamination
cannot be removed from the treatment
components, the Army will properly discharge
(dispose) contaminated components at an
appropriate waste management facility.
e) The existing wash area for military vehicles will be
modified to collect and store wash water generated
during equipment decontamination in a properly
designed storage system. The Army will insure that
collect water is properly disposed.
The State agrees with and supports the Army's Plan to
expedite remedial activities, particularly sites with
limited soil contamination. However, the State
maintains that the California Code of Regulations,
Title 23, Division 3, Chapter 15 (Chapter 15)
requirements apply to the Fort Ord Soil Treatment
Area (FOSTA). Chapter 15 contains specific
requirements established to regulate construction,
monitoring, and closure of soil storage, treatment, and
disposal areas. Chapter 15 requirements have been
developed to ensure protection of the environment,
specifically water quality.
The Army believes the remedial alternatives proposed
are exempt from Chapter 15 pursuant to Section 2511
(d) and (i). As the State has stated previously, the
Army's belief is not entirely accurate. The Army
appears to be interpreting Section 2511 (d) as a full
exemption from Chapter 15. Section 2511 (d) is a
limited exemption and states that "wastes,. . . removed
from the immediate place of release shall be discharged
according to Article 2 ..." The Army's Plan proposes
to excavate contaminated soil from specific sites ("the
immediate place of release") and transport the
excavated soil to a waste management unit for
treatment. Thus, a
N31264-H
February 23, 1994
United States Department of the Army
18
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Responsiveness Summary
Section 2511 (d) exemption requires compliance with
Article 2 at the treatment unit. According to Article 2,
the contaminated soil must be classified and then
discharged only to waste management units that
comply with other applicable Chapter 15 provisions. In
other words, the waste management unit proposed for
treating the soils must comply with the siting criteria
(Article 3), the construction standards (Article 4), and
the monitoring standards (Article 5). When the unit is
closed, it must close according to Article 8.
Chapter 15, Section 2510 (b) and (c), provides the
Regional Board latitude to consider "specific
engineered alternatives" to Chapter 15's construction
and prescriptive standards. The Army can comply with
the applicable Chapter 15 provisions by constructing a
"specific engineered alternative" as specified in
Section 2510 (b).
Section 2511 (d) requires that, after treatment, the
treated soils must be discharged according to Article 2.
Applicable discharge requirements will depend on the
level of treatment attained.
Chapter 15, Section 2511 (i) provides an exemption
where waste treatment is in fully enclosed facilities.
The Statement of Reasons clarifies the intent to apply
this section to specific types of facilities. An open
concrete slab for contaminated soil treatment does not
fit within the Section 2511 (i) exemptions.
The Plan and the Interim Action Feasibility Study
(IAFS) state the Army intends to modify the proposed
FOSTA location (519th Motor Pool) to store and treat
contaminated soils. At recent Remedial Project
Manager meetings, the Army and its consultant have
described plans to modify the concrete slab at the
FOSTA before treating contaminated soils. The
proposed modifications include sealing the concrete
and providing perimeter curbing to prevent runoff and
runon. The Army has stated it would monitor existing
groundwater wells and "clean close" the FOSTA when
remediation is complete. The specific site
modifications, treatment system operation, and site
closure described by the Army for the FOSTA appear
to comply with Chapter 15 "specific engineered
alternatives." However, specific details discussed have
not been included in either the IAFS or the Plan.
The State contends that all design, operation, and
closure details which qualify as "specific engineered
alternatives" need to be specified in the Plan.
Furthermore, the specific details must also be
incorporated into the Record of Decision. The Plan
must be changed to reflect the specific site
modifications, FOSTA treatment system operations,
and site closure as provided in Attachment 1.
The proposed Plan includes a soil cleanup and soil
treatment level of 500 mg/kg for Total Petroleum
Hydrocarbons (TPH). Although the Regional Board
typically imposes a 100 mg/kg soil cleanup level at
petroleum-contaminated sites, it concurs with the
proposed 500 mg/kg TPH level for the Interim Action
cleanups, based on the following factors:
a. Petroleum contamination at Fort Ord consists
primarily of weathered petroleum product that
contains hydrocarbon chains consisting of 14 or
more carbon atoms (>-C14);
b. The depth to groundwater ranges from 60 to 150
feet below ground surface;
c. A soil partitioning computer model will be used at
each site to determine if groundwater could be
impacted by contaminants remaining in soil at the
500 mg/kg concentration. Soil cleanup level will
be reduced if groundwater could be impacted. If
groundwater is impacted the IA process will not
apply; and
d. The cleanup level seems protective of both human
health and groundwater quality, based on
conservative site-specific data provided.
Army Response to Comments from the
California Environmental Protection Agency
The Army is pleased that the State concurs and
supports the IA Proposed Plan for sites with limited
soil contamination. As the Army has stated previously,
we believe that Section 251 l(d) of Chapter 15 provides
an exemption for "actions taken by or at the direction
of public agencies to cleanup or abate conditions of
pollution or nuisance resulting from unintentional or
unauthorized releases of
N31264-H
February 23, 1994
United States Department of the Army
19
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Responsiveness Summary
waste...". The Army believes that the excavation of
limited amounts of contaminated soil and treatment of
such soil at the FOSTA falls squarely within this
exemption.
The Army agrees with the State that Section 251 l(d) is
not a complete exemption. To the extent that the
exemption further provides that waste "removed from
the immediate place of release shall be discharged
according to Article 2" of Chapter 15, the Army
intends to fully comply with Article 2. Article 2
classifies waste and based upon such classification,
determines where waste may be discharged.
The Army does not agree that soil treatment at the
FOSTA itself constitutes a classified waste
management unit that would be regulated by Chapter
15. Therefore, provisions dealing with siting criteria
(Article 3), construction standards (Article 4),
monitoring standards (Article 5), closure standards
(Article 8), are not triggered. As stated above, the
Army believes that the excavation and treatment of soil
is exempt under Section 251 l(d) as a governmental
action to cleanup or abate waste. The Army is no
longer pursuing exemption 251 l(i) in regard to the
FOSTA as mentioned in previous discussions with the
State.
The Army has stated in the Proposed Plan and IAFS
that design criteria, soil acceptance requirements,
operational and maintenance procedures, target
cleanup concentrations, and closure procedures for the
FOSTA will be provided in a FOSTA Design
Operation, Maintenance, Monitoring, and Closure
Plan.
The Proposed Plan already stated that nonhazardous
soil will be stockpiled at the FOSTA and that
hazardous soil will be stored in containers. Figure 5B
in the Proposed Plan clearly shows that soil will be
placed in a lined facility, and describes the storage of
containers of hazardous waste inside buildings.
Furthermore, the location of the FOSTA was identified
as the 519th Motorpool area in the Proposed Plan and
is clearly shown in the Fort Ord Site Plan (Figure 2 in
the Proposed Plan). The 519th Motorpool area has
historically experienced heavy vehicle traffic and is
expected to have the strength to handle traffic
associated with the placement and treatment of these
materials. The FOSTA will
be designed with the intent of facilitating soil remedial
activities and protecting human health and the
environment, including groundwater.
The specific details requested by the State to be
included in this Record of Decision (ROD), while
important to the operation of the FOSTA, are not
germane in light of the overall CERCLA process and
IAFS. Feasibility Studies and their associated Proposed
Plans are intended to recommend a selected remedy for
a given remedial problem that can attain established
cleanup levels and comply with applicable or relevant
and appropriate requirements (ARARs).
Then, during the Remedial Design (RD) phase,
engineering specifications will be drafted to implement
the selected remedy as directed by the ROD. In
addition to the ARARs listed in the ROD which guide
remedial design, the CERCLA process also provides
for currently accepted construction practices and
techniques to be used to ensure the protection of
human health and the environment, including
groundwater.
Specific details regarding curb specifications or
building numbers had no bearing on the selection of
Alternative 2, Soil Excavation with Treatment, and/or
Disposal, as the selected remedy for Interim Action for
areas on Fort Ord.
The Army again emphasizes that this information will
most likely be similar to information that would be
required under Chapter 15. To that end, the Army is
pleased that the State believes that construction,
operation and closure designs may satisfy the
"engineered alternative" provided by Chapter 15. The
Army believes that these actions would not be driven
by Chapter 15 as an ARAR. In other words, the Army
plans to perform these activities as part of the,
CERCLA process, not as an attempt to satisfy any
engineered alternative allowed by Chapter 15. As part
of the CERCLA process, the details for these activities
will be delineated during the upcoming RD stage. The
State, of course, will have the opportunity at that time
to comment on the RD.
The Army agrees that a cleanup level of 500 ppm of
total petroleum hydrocarbons in soil is an acceptable
standard for Fort Ord.
N31264-H
February 23, 1994
United States Department of the Army
20
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TABLES
-------
Table 1. Preliminary Remediation Goals (PRGs)*
Interim Action Record of Decision
Fort Ord, California
Chemical
Acenaphthene
Acetone
Antimony
Arsenic
Barium
Beryllium
Bis(2-ethylhexyl)phthalate
Cadmium
Carbon disulfide
Carbon tetrachloride
Chlordane
Chromium VI
Copper
4,4'-DDT
Dieldrin
Ethylbenzene
Fluorene
Lead (a)
Mercury
Methyl ethyl ketone
2-Methylnapthalene
Petroleum Hydrocarbons (b)
Napthalene
Nickel
Phenanthrene
Pyrene
Selenium
Silver
Tetrachlroethylene
Thallium (as Thallic oxide)
Toluene
1 ,2,4-Trichlorobenzene
Vanadium
Xylenes
Zinc
Lowest
PRG
960
220
27
0.87
1,000
0.39
13
8.1
0.96
0.025
0.14
0.23
2,500
0.53
0.011
830
640
240
20
620
640
500
640
130
640
480
340
340
0.16
4.7
190
49
470
130
20,000
Based on Noncancer Health Effects
Child
Resident
960
220
27
20
1,000
340
320
34
0.96
29
0.97
7.2
2,500
8.0
0.80
830
640
240
20
620
640
(c)
640
1,400
640
480
340
340
410
4.7
190
49
470
130
20,000
Adult
Resident
4,600
900
290
220
4,700
3,700
1.500
370
3.9
190
4.6
30
27,000
38
3.8
3,700
3.100
3,900
210
2,900
3,100
(c)
3,100
15,000
3,100
2,300
3,600
3,600
2,700
50
770
210
5,000
520
210,000
Construction
Worker
31,000
8,200
57
44
4,100
730
1,000
73
3.7
750
3.2
38
5,300
26
2.6
3,900
21 ,000
460
41
3,300
2,100
(c)
2,100
2,900
2,100
16,000
710
710
11,000
100
3,700
710
1,000
500
42,000
Based on Carcinogenesis
Adult
Resident
NA
NA
NA
0.87
NA
0.39
13
8.1
NA
0.025
0.14
0.23
NA
0.53
0.011
NA
NA
NA
NA
NA
NA
500
NA
130
NA
NA
NA
NA
0.16
NA
NA
NA
NA
NA
NA
Construction
Worker
NA
NA
NA
60
NA
28
3,200
380
NA
8.6
34
11
NA
130
2.8
NA
NA
NA
NA
NA
NA
120,000
NA
6,300
NA
NA
NA
NA
54
NA
NA
NA
NA
NA
NA
*AII PRGs are in millgrams per kilogram, and are taken from the:
Draft Technical Memorandum. Preliminary Remediation Goals, Fort Ord, California. Dated June 14,1993.
Prepared by HLA for the Sacramento COE.
These PRG's were developed according to procedures described in:
Risk Assessment Guidelines for Superfund, Volumes 1 and 2.
Prepared by the Office of Emergency and Remedial Response, EPA documents EPA/540/1-89/006 and EPA/540/1-89/001
(a) Draft Final Basewide Background Soils Investigation. Dated March 15, 1993
Prepared by HLA for the Sacramento COE.
(b) This PRG is based on maximum concentrations of individual carcinogenic and
non-carcinogenic constituents in used motor oil.
(c) Calculated value exceeds 100% of soil,
indicating noncancer health effects would not be expected at any soil concentration.
NA = Not available
Page 1 of 1
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Table 2. Summary of Interim Action Alternative Screening Evaluation
Interim Action Record of Decision
Fort Ord, California
Selection
Criteria
Alternative 1:
No Action
Alternative 2: Excavation
with Soil Treatment,
Recycling, and/or Disposal
Protection of human health
and the environment
Not protective
Protective
Compliance with ARARs
May not trigger ARARs if soil left in place
In compliance, except a waiver
is invoked as noted in Section
2.12.2
Long-term effectiveness and Not effective in the long-term
permanence
Likely to be effective in the
long-term considering the use
of conservative Target
Cleanup Concentrations
Reduction of waste toxicity, No reduction of toxicity, mobility, or volume
mobility, and volume through
treatment
Reduction of toxicity and
mobility of chemicals in soil.
May reduce volume of
contaminated soil through
treatment
Short-term effectiveness,
including timeliness
Implementability
Cost (Estimated maximum
net present value)
State acceptance
Community acceptance
Not effective or timely
Implementable
$19,000,000(1)
Not acceptable
Not acceptable
Effective and timely
Implementable
$24,000,000(2)
Acceptable
Acceptable
Notes:
(1) Based on a 5 percent interest rate over 30 years.
(2) Estimated maximum cost based on excavating soil at all 41 sites. Actual costs are likely to be significantly lower.
N31264-H
February 23, 1994
United States Department of the Army
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Table 3. Applicable or Relevant and Appropriate Requirements
Alternative 2: Excavation with Soil Treatment, Recycling, and/or Disposal
Interim Action Record of Decision
Fort Ord, California
Source
Standards for owners
and operators of
hazardous waste
treatment, storage, and
disposal facilities
Regulation, Standard
or Level of Control
Title 22 CCR, Chapter
14, Use and
Management of
Containers; Article 9,
Sections 66264.171-
178
, Section 661 71 ;
Condition of Containers
, Section 661 72;
Compatability of Waste
in Containers
, Section 661 73;
Management of
Containers
, Section 661 74;
Inspections
, Section 661 75;
Containment
, Section 661 76;
Special Requirements
for Ignitable or Reactive
Waste
, Section 661 77;
Special Requirements
for Incompatible Waste
, Section 661 78;
Closure
Description
Establishes requirements for the use of containers to
store hazardous waste.
Containers for hazardous waste must be maintained in
good condition.
Containers for hazardous waste must be compatible
with the wastes stored in them.
Containers holding hazardous waste must be closed
during storage except when necessary to add or
remove waste.
Containers and container storage areas must be
inspected weekly for leaks or deterioration.
Container storage areas must be designed according to
the requirements of this section.
Container of ignitable or reactive wastes must be stored
at least 15 meters from a facility's property line.
Incompatible wastes must not be placed in the same
container, or in unwashed containers which previously
held incompatible wastes.
At closure, all hazardous waste and waste residues
must be removed and remaining containment structures
decontaminated.
Applicable or
Relevant and
Appropriate
Applicable Action-
Specific Requirement
Applicable Action-
Specific Requirement
Applicable
Action-Specific
Requirement
Applicable
Action-Specific
Requirement
Applicable
Action-Specific
Requirement
Applicable
Action-Specific
Requirement
Applicable
Action-Specific
Requirement
Applicable
Action-Specific
Requirement
Applicable
Action-Specific
Requirement
Comments
Excavated soil or decontamination water subsequently characterized
as hazardous may be stored in containers at an IA area or at the
FOSTA.
See above
See above
See above
See above
See above
See above
See above
See above
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Table 3. Applicable or Relevant and Appropriate Requirements
Alternative 2: Excavation with Soil Treatment, Recycling, and/or Disposal
Interim Action Record of Decision
Fort Ord, California
Source
Standards Applicable to
Generators of
Hazardous Waste
Standards for owners
and operators of
hazardous waste
treatment storage, and
disposal facilities
Standards for owners
and operators of
hazardous waste
treatment storage.
Standards for owners
and operators of
hazardous waste
treatment, storage, and
disposal facilities
Regulation, Standard
or Level of Control
Title 22 CCR, Chapter
12, Articles, Section
66262.34, Accumulation
Time
Title 22 CCR, Chapter
14, Article 2, Section
66264.14
Title 22 CCR, Chapter
14, Article 7, Section
66264.1 19; Post
Closure Notices
Title 22 CCR, Chapter
14, Article 16, Section
66264.601
Description
A generator may accumulate hazardous waste for 90
days or less.
Owners and operators of hazardous waste treatment,
storage, or disposal (TSD) facilities must prevent the
unknowing entry of persons or livestock onto the active
portions of the facility; in addition, warning signs must
be posted.
Under this requirement, a restriction is placed on the
deed which constrains future uses of the property.
These regulations apply to facilities that treat, store, or
dispose of hazardous waste in miscellaneous units.
Owners and operators of TSDs at which hazardous
waste is stored in miscellaneous units must locate,
design, construct, operate, maintain, and close those
units in a manner that is protective of human health and
the environment.
Applicable or
Relevant and
Appropriate
Applicable Action-
Specific Requirement
Applicable Action-
Specific Requirement
Applicable Action-
Specific Requirement
Applicable Action-
Specific Requirement
Comments
A waiver of this requirement will be invoked to allow storage for
excavated hazardous soil until sufficient volumes are obtained for
treatment, recycling, or disposal.
IA areas will be restricted from public access.
No unacceptable concentrations of chemicals are expected to remain
at the FOSTA site after closure. Further remedial actions, as well as
possible deed restrictions, may be required as part of the final
basewide ROD for an IA area.
Carbon drums may be used as part of the FOSTA treatment activities.
These carbon drums may be considered miscellaneous treatment
units.
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Table 3. Applicable or Relevant and Appropriate Requirements
Alternative 2: Excavation with Soil Treatment, Recycling, and/or Disposal
Interim Action Record of Decision
Fort Ord, California
Source
Regulation, Standard
or Level of Control
Description
Applicable or
Relevant and
Appropriate
Comments
Land Disposal
Restrictions
Monterey Bay Unified
Air Pollution Control
District (MBUAPCD)
National Primary and
Secondary Ambient Air
Quality Standards
(NAAQS)
Standards for the
Management of
Hazardous Waste
Federal Endangered
Species Act
National Archaeological
and Historic
Preservation Act
Title 22 CCR, Chapter
18, Article 1, Section
66268.7
Regulation II (New
Sources) and
Regulation X (Toxic Air
Contaminants)
40 CFR Part 50
Title 23 CCR, Chapter
15, Article 2; Waste
Classification and
Management
50 CFR Parts 200 and
202
36 CFR Part 65
Requires laboratory analysis of wastes intended for
landfill disposal to establish that the waste is not
restricted from landfill disposal.
Establishes requirements for new stationary sources of
air pollution, and the appropriate level of abatement
control technology for toxic air contaminants.
Establishes NAAQS for criteria pollutants: participate
matter (PM10), sulfur dioxide, carbon monoxide,
nitrogen dioxide, ozone, and lead.
This regulation establishes and defines procedures and
criteria for identification and listing of designated and
hazardous wastes.
These regulations provide for the protection of
endangered or threatened species through an
evaluation of affected habitats in the IA area, as well as
consultation with the appropriate government agencies.
These regulations provide for the protection of any
historically significant artifacts that may be unearthed
during excavation activities.
Applicable Action-
Specific Requirement
Relevant and
Appropriate Chemical-
Specific Requirement
Applicable* Chemical-
Specific Requirement
Applicable Chemical-
Specific Requirement
Applicable* Location-
Specific Requirement
Applicable Location-
Specific Requirement
Soil excavated from IA areas may subsequently be found to be
hazardous to designated waste. Treated and untreated hazardous of
designated soil that cannot be recycled will be shipped for disposal off
Fort Ord.
The FOSTA would need to meet the substantive requirements of
these MBUAPCD regulations because soil treatment, such as SVE or
biodegradation, may generate toxic air emissions. Levels of these
emissions are anticipated to be minimal to none.
Although none of these pollutants are present at the preliminarily
identified IA areas, they may be encountered or generated during IA
excavation activities.
This provision applies to the discharge to soil leaving the FOSTA.
Fort Ord does contain endangered species of plants and animals.
Each IA area will be screened for potential environmental impacts to
such species and results will be included as part of the IA area
Approval Memorandum that will recommend measures, as necessary,
to ensure compliance with this ARAR.
No historically significant artifacts have been uncovered during
previous investigation activities at Fort Ord, and none are expected to
be unearthed at the IA areas. Appropriate actions will be taken,
however, should any such artifacts be unearthed.
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Table 3. Applicable or Relevant and Appropriate Requirements
Alternative 2: Excavation with Soil Treatment, Recycling, and/or Disposal
Interim Action Record of Decision
Fort Ord, California
Source
Regulation, Standard
or Level of Control
Description
Applicable or
Relevant and
Appropriate
Comments
Coastal Zone
Management Act
Toxic Substances
Control Act
16 USC 1451
40CFR761(D)
These regulations require activities conducted in the
coastal zone (the area west of Highway 101) to be
completed in a manner that is consistent with the state's
coastal zone management program.
This regulation covers the handling and disposal of
PCB-containing materials.
Applicable* Location-
Specific Requirement
Applicable* Chemical-
Specific Requirement
The coastal zone at Ford Ord lies between U.S. Highway 1 and the
ocean. None of the nine preliminary identified IA areas lie within this
coastal zone; but three of the 41 CERCLA sites are within the coastal
zone.
Although PCBs have not been detected in soil samples from any of
the preliminarily identified IA areas, several of these areas contained
heavy oils. If PCBs are present in these oils, these requirements
would be considered applicable.
Site characterizations for all of the proposed IA sites are currently being completed.
Thus, several requirements listed here as ARARs may be found to be not applicable once these reviews are completed for all the IA areas.
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Table 4. Application of Waiver
Interim Action Record of Decision
Fort Ord, California
Soil
Type
Title 22 CCR, Chapter 12,
Article 3 Section 6626 .34
Accumulation Time
Comments
RCRA hazardous
ARAR waived*
Allows time to accumulate material to
make offsite treatment or disposal
practical
Non-RCRA hazardous (CA
hazardous)
ARAR waived*
Allows time to accumulate material for
offsite treatment or disposal and, when
practical, for onsite treatment. Onsite
treatment would require a ROD
amendment or explanation of
significant differences
CA designated
N/A
Onsite treatment with soil vapor
extraction (SVE) or bioremediation
CA inert
N/A
Although the waiver will be applied, in order to be protective of the environment, the Army will comply with the
FOSTA Operation, Maintenance, Monitoring and Closure Plan which will specify soil treatment, monitoring and
closure, including waste-inventory, storage, and tracking procedures.
N31264-H
February 23, 1994
United States Department of the Army
of1
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PLATES
-------
EXPLANATION
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a excavated sod a non-RCRA
hazardous waste containing fuel
hydrocarbons, yofctle organic
compounds, or other chemicals
that con be treated at FOSTA
(s excovated soil
a RCRA rfizardous waste
which cannot be treated
reduce tox'city, mobility, or
volume?
Is excavated soil a
non-RCRA hazardous
waste which cannot be
treated at FOSTA
Con excavated soil be
treated to reduce its
toxicity, mobility, or
volume?
Dispose of soil at on
appropriate landfill
designed and constructed
to accept such waste.
Treat excavated sail at
FOSTA with
soil vapor
extraction, or other methods
(S«« Pwtt 5)
Con excavated soil
be recycled?
Treated, clean soil will be used on
Fort Ord as road base material, in
the OU 2 bndfll cap. or as clean ft
Recycle soil on Fort Ord
using a qualified
subcontractor with a •
transportable treatment unit.
or off Fort Ord ot on
approved recycling facility.
Recyted soil wit be used on
fort Ord whenever feasible
Treat soil on Fort Ord using
a qualified subcontractor
with a transportable
treatment unit, or off Fort
Ord ot an approved
treatment foclity. Treated
sod wit be used on Fort Ord
whenever feasible.
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APPENDIX A
A SYNOPSIS
COMMUNITY RELATIONS ACTIVITIES CONDUCTED
FOR FORT ORD NPL REMEDIAL ACTIVITIES
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Appendix A
The following activities have been conducted as part of the Army's public relations and information transfer efforts
regarding environmental restoration activities at Fort Ord. Presentations, briefings, and/or tours were given to the
following groups or organizations, or the following meetings.
Activity
Public meeting and public comment period for the
Interim Action Feasibility Study (IAFS). 11/30/93.
Presentation to Pebble Beach Property Land
Owners. 12/07/93.
Monterey County Meeting. 06/21/93.
Fort Ord Reuse Group Meeting regarding the
status of Superfund sites throughout the
installation. 05/20/93.
Public meeting and public comment period for the
Fort Ord OU2 Landfills Remedial
Investigation/Feasibility Study (RI/FS). 10/19/93.
Marina California, City Council meeting discussed
the Fort Ord Landfills-Operable Unit 2 (OU2).
11/09/93.
California Central Coast Regional Water Quality
Control Board meeting regarding the Proposed
Plan for OU2. 11/12/93.
Fort Ord Superfund Public Relations Public
Meeting. 09/21/93.
Meeting regarding the parcelization process for
Fort Ord base closure in accordance with the
Community Environmental Response and
Facilitation Action (CERFA), participants included
the USEPA. Fort Ord Reuse Group, DISC,
RWQCB, and the Army Environmental Center.
06/03/93.
Superfund presentation to the American Society of
Military Engineers in Mountain View, California.
07/09/93.
Association of 7ID Veterans. 06/01/93.
Superfund presentation for the Watsonville Junior
High School career day in Watsonville, California.
04/16/93.
Technical Review Committee Meeting. 04/21/93.
Superfund presentation for Aptos Junior High,
Aptos, California. 04/23/93.
Superfund presentation for the Pacific Grove
Rotary Club in Pebble Beach, California.
03/23/93.
Biological and technical assistance team meeting
regarding the Fort Ord beach front firing ranges.
04/06/93.
Superfund presentation to the San Jose Senior
Citizens Group. 06/22/93.
Fort Ord National Resources Trustee Day.
06/30/93.
Meeting regarding the acquisition of Fort Ord
property by the University of California. 06/12/93.
EPA Federal Facilities Conference. 6/22 - 6/24/93.
Update with the District Attorney regarding the
progress of Fort Ord's cleanup activities. 04/16/93.
Installation walking tour and Superfund
presentation to Sierra Club senior citizens group.
02/23 93.
CERFA meeting. 03/04/93.
Fort Ord Environmental Impact Statement Public
Meeting. 02/11/93.
N31264-H
February 23, 1994
United States Department of the Army
A1
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Appendix A
Presentation to RAND. 01/19/93.
Technical Review Committee Meeting. 01/13/93.
Discussion with the National Oceanographic and
Atmospheric Agency (NOAA) regarding the
proposed sand falls study on the Fort Ord beach
ranges. 01/13/93.
Meeting with Walter Wong. 12/09/92.
Environmental restoration presentation and site
tour for Hartnell College Students. 10/14/92.
Technical Review Committee Meeting. 10/09/92.
Walking tour and Superfund presentation for
Cypress High School students from Seaside,
California. 09/20/92.
Base Realignment and Closure Environmental
Impact Statement status meeting with Army, COE,
U.S. Fish and Wildlife Services, California Fish
and Wildlife, and Jones & Stokes. 08/25 -
01/26/92.
Meeting with Fort Ord majority counsel for the
Senate Arms Service Committee, and Majority
Counsel for the House Energy and Commerce
committee regarding the impact and proposal
parcelization legislation. 08/20/92.
Community relations meeting with high school
students from the "upward bound" program.
07/15/92.
Technical Review Committee Meeting. 07/08/92.
Attended seminar regarding the Environmental
Restoration of Closing Military Bases in
Sacramento, California. 06/23 - 06/25/92.
N31264-H United States Department of the Army A2
February 23, 1994
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