EPA/ROD/R03-00/157
2000
EPA Superfund
Record of Decision:
US ARMY - FORT RITCHIE
EPA ID: MD0000795211
OU 09
CASCADE, MD
09/12/2000

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DECISION DOCUMENT FOR OPERABLE UNIT 12 - FORMER HOSPITAL AREA
AT FORT RITCHIE ARMY GARRISON, MARYLAND
I 1.0 PURPOSE	I
This Decision Document describes the selection of No Action for Operable Unit (OU) 12 - Former Hospital
Area at Fort Ritchie Army Garrison. No Action was selected in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA), the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), the
Resource Conservation and Recovery Act (RCRA), and Army Regulation AR 200-1, as applicable.
In 1995, Fort Ritchie was selected for Base Realignment and Closure (BRAC). In support of the BRAC
environmental restoration program, an environmental Site Investigation (SI) of groundwater was conducted at OU12
in preparation for property transfer. OU12 was identified for environmental investigation based on aerial photographs
and facility maps identifying a former WWII hospital at this location. All of the former WWII hospital buildings have
been demolished with the exception of Building 811, a wing of the former hospital that is now used as office space.
Most of the area at OU12 is currently open recreational green-space.
Based on SI analytical results from OU12, only bis(2-ethylhexyl)phthalate (DEHP) and manganese were
detected in groundwater above Federal Drinking Water Maximum Contaminant Levels (MCLs). However, these
chemicals were subsequently determined to be laboratory and/or sampling artifacts and not representative of OU12
groundwater. Therefore, no remedial action is necessary to ensure the protection of human health and the
environment.
Based on no evidence that a CERCLA documented release has occurred at OU12, No Action has been
selected by the U.S. Army with concurrence from the United States Environmental Protection Agency (USEPA) Region
III, Maryland Department of the Environment (MDE), and public. Documents supporting this decision are located in
the information repository.
I 2.0 SITE RISK	I
A quantitative Baseline Risk Assessment (BRA) including a human health risk assessment (HHRA) and
ecological risk assessment (ERA) was not conducted as part of the OU12 investigation.
Instead, SI sampling results were conservatively screened against Federal Drinking Water MCLs. The results
of this screening identified only DEHP and manganese concentrations above MCLs. Based on subsequent U.S. Army
and regulator partnering, a detailed re-evaluation of these chemical exceedances was performed to determine whether
or not these results are truly representative of site conditions. The results of the evaluation concluded that the DEHP
and manganese detections are most likely due to laboratory contamination or artifacts of sampling and are not
representative of groundwater conditions at the site.
Quantitative ecological risk evaluation at OU12 was determined to be unnecessary due to the limited presence
of chemicals and poor habitat quality at the site. This conclusion was reached during a site visit by the USEPA Region
III Biological Technical Assistance Group.
Based on these conclusions, no contaminants of concern were identified at OU12, therefore, no unacceptable
risk to human health and the environment exists at the site.
I 3.0 REMEDIAL ALTERNATIVES	I
Two remedial alternatives were evaluated in the Focused Feasibility Study for OU12:
1)	No Action - The NCP and CERCLA require that No Action be evaluated to establish a baseline for
comparison to other alternatives. Under this alternative, no remedial action of any kind would be
implemented; and
2)	Deed Restriction - Underthe deed restriction alternative, no residential development of the property would
be allowed in the future unless it can be shown that the risk to residential receptors is within an acceptable
range as approved by State and Federal regulatory agencies.
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Based on the evaluation of the two alternatives in the Focussed Feasibility Study, No Action was initially
identified as the recommended alternative for the site attributing the MCL exceedances to laboratory contamination.
However, based on concerns that DEHP could not be directly attributed to laboratory contamination or a sampling
artifact at that time, the Proposed Plan was published conservatively identifying Deed Restriction as the preferred
alternative for OU12. However, as a result of subsequent U.S. Army and regulator partnering meeting discussions,
it was decided to re-evaluate DEHP and manganese concentrations detected above MCLs in groundwater at OU12
to identify whether or not these results are truly representative of site conditions. A memorandum evaluating the
uncertainty of DEHP and manganese concentrations in OU12 groundwater was prepared. As a result of this
re-evaluation, it was concluded in partnering that elevated DEHP detections in two wells and manganese in one well
are most likely due to laboratory or sampling artifacts and are not representative of OU12 groundwater.
Based on these post Proposed Plan partnering discussions, a joint decision was made by the U.S. Army and
regulatory agencies that No Action be taken at OU12. However, as a conservative measure, it is recommended that
a disclosure be incorporated into the property deed notifying future owners of the environmental investigations
conducted at OU12.
I 4.0 PUBLIC/COMMUNITY INVOLVEMENT	I
Fort Ritchie has a Restoration Advisory Board (RAB) which has been actively involved throughout the
environmental investigation activities conducted during the SI. The RAB includes representatives from the USEPA
Region III and MDE, as well as members of the local community.
Comments on the Proposed Plan were solicited, received, and considered by the U.S. Army priorto selecting
No Action for OU12. These comments and formal responses are included as Attachment A.
The recommendation of No Action forOU12 was presented for comment during a public meeting on 15 May
2000. Attendees expressed no objections to No Action for OU12.
I 5.0 DECLARATION	I
No remedial action is necessary at OU12 to ensure the protection of human health and the environment.
Therefore, none oftheCERCLA §121 statutory determinations are necessary since no remedy is being selected. Since
no hazardous substances are present onsite above levels that allow for unlimited use and unrestricted exposure, the
five-year review will not apply at this site.
I 6.0 APPROVAL AND SIGNATURE	I
In summary, the U.S. Army will implement No Action for OU12 at Fort Ritchie. The total cost for this action
is below $2 million, therefore, the appropriate approval authority is the Installation Commander for Fort Ritchie. Since
Fort Ritchie is a closed BRAC site and therefore has no Installation Commander, the appropriate approval authority
is from the BRAC Environmental Coordinator and Military District of Washington (MDW) BRAC Officer.
Approved By:
Date
v"2- S.tLf3 (Sq
BRAC Environmental Coordinator
MDW BRAC Officer
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ATTACHMENTA
RESPONSE TO COMMENTS ON THE
PROPOSED PLAN FOR OUS 6, 9, AND 12, FINAL DOCUMENT
FORT RITCHIE ARMY GARRISON

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RESPONSE TO COMMENTS ON THE
PROPOSED PLAN FOR OUS 6, 9, AND 12, FINAL DOCUMENT
FORT RITCHIE ARMY GARRISON
FROM USEPA, REGION III
I Comment 1. Section 1, Introduction
Comment: Paragraph 1 - "The Proposed Plan identifies the preferred alternative for addressing risks to the
public..." should read "...addressing risks to human health and the environment..."
Paragraph 3 - Add CERCLA Sections 113 (k)(2)(b), 117 (a) and 121 (f)(1)(G).
Paragraph 3 - The Proposed Plan lists a number of documents. Include a section on where these
documents can be located (library, BRAC office).
Response: Comment acknowledged. However, the U.S. Army has no plans to revise the Proposed Plan.
I Comment 2. Section 2.0, Site Background and Characteristics: Sentence 4	I
Comment: "The OU 6,9 and 12 properties are all planned for continued commercial use..." Does this use include
day care?
Response: It is unknown whether or not PMDC will include day-care facilities in the future commercial use of
OU6, OU9, or OU12.
I Comment 3. Sections 2.1 and 2.2, OU-6 Autocraft Shop and OU-9 Administrative Building Area	|
Comment: The statement concerning comparisons to the observed average background comparisons at Fort
Ritchie should be reworded for accuracy. The background data set used for these comparisons is
statistically inadequate. It may have been prudent to wait for the results of the ongoing background
survey prior to calling for an action (deed restrictions) at these Operable Units (particularly with
respect to OU-6).
Response: The recommended actions in the Proposed Plan have been subsequently revised based on the
agreements reached by the U.S. Army, USEPA Region III, and MDE during partnering discussions.
The recommended actions will be presented in the Decision Documents forOU6, OU9, and OU12.
The U.S. Army has no plans to revise the Proposed Plan.
I Comment 4. Section 2.3, OU-12 Former Hospital Area	I
Comment: The Proposed Plans states that "since water supply wells in this area are installed into the deeper
bedrock aquifer and shallow groundwater is not used for drinking, the results of the sampling were
not included in the risk assessment because of the incomplete exposure pathway to receptors." The
Army's approach of not addressing the shallow aquifer at Fort Ritchie has been continued in this
document. While the aquifer may lack the ability to provide a sustainable water supply, the Army has
never collected the necessary data to make the argument. Regardless of the potential yield of the
aquifer, pathways do exist and if contamination is present then the Army must look at the nature and
fate of the contamination in order to get a handle on the future risk. Additionally, the risk posed by
construction or interaction with shallow groundwater should have been considered a pathway.
In late November, EPA made the recommendation to the Army that the aquifer be resampled to
determine if an MCL exceedance truly exists at OU 12. If contamination is not present, no further
action is necessary. CERCLA and the NCP require that ground water be restored to beneficial use.
Another alternative is to work with EPA technical
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support staff, particularly the hydrogeologist, to determine whether an ARAR waver is possible based
on the technical impracticability of treatment of the shallow aquifer at Fort Ritchie.
Response: As a result of partnering discussions held between the U.S. Army, USEPA, and MDE, a memorandum
re-evaluating DEHP and manganese concentrations detected above MCLs in groundwater concluded
that these results were artifacts of field sampling procedures and/or laboratory contamination.
Subsequently, No Action with a deed disclosure is recommended for this OU.
I Comment 5. Section 4.1, Human Health Risk, OU-6 Autocraft Shop and OU-9 Administration Building |
Comment: A. When discussing the risks, include the actual numbers.
B.	The statement is made that "adult and child residential cumulative cancer risks are within the
USEPA acceptable risk range..." which is not entirely true. The increased cancer risk for soil
exposure for a child resident and an adult resident is 0.9E-4 and 1.2E-4, respectively.
C.	Address day care as part of commercial use. What about recreational use?
D.	The statement is made that "the cumulative non-cancer HI exceeded 1 for both adult and child
residents primarily due to aluminum, arsenic, iron, and manganese found in concentrations
slightly above background levels in soil samples." Although the background data set is not
statistically adequate for comparisons, please note that arsenic, for example, was found at a
maximum concentration of 40 ppm in soils at OU-9 while the maximum concentration found in
the background data set was 4.4 ppm. The term "slightly" should be removed from the sentence
or additional clarifications should be made.
E.	The risks associated with each exposure scenario (e.g., industrial and residential) should be
included in the text or in tabular form in the Proposed Plan.
F.	Chromium should be added to the list of chemicals of concern.
Response: A. Comment acknowledged. However, the U.S. Army has no plans to revise the Proposed Plan.
B. Exercising the cleanup goal (of not to exceed 17 mg/kg) for arsenic in soils agreed to
during partnering will ensure that the cumulative carcinogenic risk for these receptors
is below 1x10"4.
C.	It is unknown whether or not PMDC will include day-care facilities in the future commercial use
of OU6, OU9, orOU12. No recreational use of OU6, OU9, orOU12 has been identified in the
PMDC future use map.
D.	Comment acknowledged. However, the U.S. Army has no plans to revise the Proposed Plan.
E.	Comment acknowledged. However, the U.S. Army has no plans to revise the Proposed Plan.
F.	Chromium was not identified as a COC since neither the dermal or ingestion HQ exceeded one
in the HHRA and the combined HI was equal to one. Additionally, based on the fact that
chromium occurs predominantly in nature in the trivalent form and the more toxic hexavalent form
was used to calculate risk, the calculated hazard quotients are believed to overestimate the true
risk for this chemical. The U.S. Army has no plans to revise the Proposed Plan.
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I Comment 6. Section 4.1, Human Health Risk, OU-12 Former Hospital Area	I
Comment: A. Please include a statement as to whether or not the deeper aquifer has been sampled for
contaminants.
B. The statement that shallow ground water "is not a suitable drinking water source" is not correct.
Response: Comment acknowledged. The U.S. Army's position is that the shallow groundwater at Fort Ritchie is
not currently used for nor likely to be used as a potable water supply. The U.S. Army has no plans
to revise the Proposed Plan.
I Comment 7. Section 6.0, Summary of Alternatives	I
Comment: A. Please clarify the meaning of the statement that "Although the FFS specifically stated restriction
on residential land-use by future property owners, the restriction can be altered as necessary
depending on site specific conditions. For example, the deed restriction may prohibit use of
ground water as a drinking source." Please clarify the meaning of: (1) "the restriction can be
altered as necessary depending on site specific conditions"; and (2) "may prohibit use of ground
water as a drinking water source."
B. What about day care and recreational uses?
Response: The recommended actions in the Proposed Plan have been subsequently revised based on the
agreements reached by the U.S. Army, USEPA Region III, and MDE during partnering discussions.
No restrictions are proposed for these sites. The recommended actions will be presented in the
Decision Documents for OU6, OU9, and OU12. The U.S. Army has no plans to revise the Proposed
Plan.
It is unknown whether or not PMDC will include day-care facilities in the future commercial use of
OU6, OU9, or OU12. No recreational use of OU6, OU9, or OU12 has been identified in the PMDC
future use map.
I Comment 8. Section 7.2 and 7.3: Alternative 2 - Deed Restriction
Comment: Rationale is not effective in addressing the MCL issue in the groundwater at OU 12 and repetition in
other spots is counterproductive. It is also unclear whether the argument that MCLs are only
applicable to public water systems is relevant and appropriate here.
Response: The recommended actions in the Proposed Plan have been subsequently revised based on the
agreements reached by the U.S. Army, USEPA Region III, and MDE during partnering discussions.
There are no MCL exceedences of site-related contaminants in OU12 groundwater. The
recommended actions will be presented in the Decision Documents forOU6, OU9, and OU12. The
U.S. Army has no plans to revise the Proposed Plan.
I Comment 9. Section 7.3, Long Term Effectiveness and Permanence: Paragraph 2	I
Comment: What are the plans for monitoring and enforcement of the restrictions proposed.
Response: The recommended actions in the Proposed Plan have been subsequently revised based on the
agreements reached by the U.S. Army, USEPA Region III, and MDE during partnering discussions.
No restrictions are proposed for these sites. The recommended actions will be presented in the
Decision Documents for OU6, OU9, and OU12. The U.S. Army has no plans to revise the Proposed
Plan.
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I Comment 10. Section 7.7, Cost	I
Comment: What about other monitoring and enforcement issues?
Response: The recommended actions in the Proposed Plan have been subsequently revised based on the
agreements reached by the U.S. Army, USEPA Region III, and MDE during partnering discussions.
No other monitoring or enforcement actions are proposed forthese sites. The recommended actions
will be presented in the Decision Documents forOU6, OU9, and OU12. The U.S. Army has no plans
to revise the Proposed Plan.
I Comment 11. Section 7.8, State Acceptance	I
Comment: Should say Regulator Acceptance.
Response: Comment acknowledged. However, the U.S. Army has no plans to revise the Proposed Plan.
I Comment 12. Appendix A, Comment 1	I
Comment: It is evident that di(ethylhexyl)phthalate (DEHP) has been positively detected (not a laboratory
contaminant according to the data reports) in ground water at OU-12 at concentrations in exceedence
of the MCL. Unlike DEHP, other common laboratory contaminants found at this OU were
"B-qualified." The source is unknown at this time. However, DEHP is frequently found in groundwater
due to the abundance of plastics, etc. in the environment.
Response: As a result of partnering discussions held between U.S. Army, USEPA, and MDE, a memorandum
re-evaluating DEHP concentrations detected above MCLs in groundwater concluded that these
results were artifacts of field sampling procedures and/or laboratory contamination. Subsequently,
No Action with a deed disclosure is recommended for this OU.
Point of Contact - Mary T. Cooke, Remedial Project Manager - (215) 814-5129
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RESPONSE TO COMMENTS ON THE
PROPOSED PLAN FOR OUS 6, 9, AND 12, FINAL DOCUMENT
FORT RITCHIE ARMY GARRISON
FROM THE SIERRA CLUB
I Comment 1.	I
Comment: This proposed plan identifies the preferred alternatives for addressing risks to the public from soil
and/or groundwater with potentially harmful concentrations of metals or organic compounds, for
Operable Units 6, 9, and 12 at Fort Ritchie. We would like to make sure that the air quality issues and
concerns, be also addressed, for these units, as part of some other plan/study.
Response: Chemical inhalation risks were evaluated as part of the Human Health Risk Assessment conducted
for the operable units. It was concluded that the human health risk for this exposure pathway is
acceptable under current and future uses for Operable Units 6,9, and 12. No further action is planned
concerning this exposure pathway for Operable Units 6, 9, and 12.
I Comment 2. 2.1 OU6 - Autocraft Shop
Comment: For an area, more than 60 years old, why no mention of underground storage tanks, for this unit, or
area?
Response: Based on the Environmental Baseline Survey (USAEC, 1996), one underground storage tank (UST)
stores No. 2 fuel oil for heating Building 401. This tank was originally installed priorto 1965. This steel
tank was replaced with a double-walled fiberglass reinforced plastic tank in August 1991. Two
monitoring pipes were also installed to 2-feet below the tank for release detection purposes. All UST
replacement activities at Fort Ritchie have been conducted under the purview of the Maryland
Department of the Environment Oil Pollution Control Program. There are no records indicating any
contamination was discovered at OU6 when the replacement tank was installed.
I Comment 3. 2.1 OU6 - Autocraft Shop
Comment: What is the status of the x-ray fluorescence meter with a radioactive source, and could this be a
problem?
Response: An X-ray Fluorescence Meter was described in a Radionuclides Inventory as presented in the Fort
Ritchie Environmental Baseline Survey, Final Document, June 1996. This meter was received by Fort
Ritchie on May 16,1994 and was used for lead testing at the facility. This portable, hand held device
contained a sealed low-level radioactive source. This sealed radioactive source was appropriately
licensed and replaced every nine months. The meter was removed from Fort Ritchie at the time of
base closure.
Potential radioactive contamination to the environment from this device is considered unlikely due to
the following: 1) the X-ray Fluorescence Meter was frequently maintained and kept in good repair; 2)
the radioactive source was a sealed unit; 3) the radioactive source was licensed and replaced every
nine months; and 4) the radioactive source was relatively small (low-level). Therefore, it is believed
that a radiological problem at OU6 is unlikely.
I Comment 4. 2.1 OU6 - Autocraft Shop	I
Comment: Has all hazardous substances, pesticides, herbicides, chemicals, waste oils, etc. been removed from
site?
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Response: All potentially hazardous materials have been removed from Building 401.
I Comment 5. 2.1 OU6 - Autocraft Shop	I
Comment: Was there any testing or sampling done, for the storm water drainage system and sewage system?
Response: The upper floor of Building 401 was used for automobile maintenance and a single floor drain is
present that directly connects to an oil/water separator. This oil/water separator then drains to the
sanitary sewer system. The lower floor was used for pesticide storage and has a sink that is directly
connected to the sanitary sewer system. There are no reports of any improper disposal practices at
this facility. Discharges to the sanitary sewer system are then treated at the Washington County run
Winebrenner Wastewater Treatment Plant before release to the environment. Based on this
information, the sanitary sewer system was not targeted for testing/sampling.
Rainfall runoff from this facility travels overland to the downgradient Lake Wastler which is another
operable unit that is being investigated. Testing of a downgradient drainage swale in OU6 was
conducted and indicated no contaminants at harmful levels.
I Comment 6. 2.1 OU6 - Autocraft Shop
Comment: Are there any vehicles, on this site, especially old ones, that might cause problems, from leaking?
Response: Building 401 is not currently in use nor are there any vehicles present inside or outside of the building.
All vehicles were removed from this location at the time of base closure.
I Comment 7. 2.1 OU6 - Autocraft Shop
Comment: What was the distance/parameters from the shop boundaries, used to measure contamination, off
site, for sampling?
Response: During the Site Investigation, surface soil, subsurface soil, and groundwater samples were collected
from locations surrounding and downgradient of Building 401 that could have been potentially
impacted if a past release occurred. Sampling locations were determined by the BRAC Cleanup
Team to be a representative sampling of the area.
I Comment 8. 2.1 OU6 - Autocraft Shop
Comment: For all units - how was the baseline, human health, and ecological risk assessment, established?
Was it based on, the most vulnerable of our society, the infants, children, pregnant women, elderly
and those with immune system and health problems, factoring in those of diverse backgrounds, of
race, culture, ethnic or geographic locations - or was it based on a young white male (18-25 years)
in top condition?
Response: The human health risk assessment calculated the carcinogenic and non-carcinogenic risk to all
potential human health receptors based on chemicals detected at the site that are likely to be a
concern. Potential receptors evaluated included site workers, teenage trespassers/visitors, child
residents, adult residents, and excavation workers.
The ecological risk assessment evaluates the adverse effects to occur to potential ecological
receptors based on chemicals detected at the site that are likely to be a concern. Ecological receptors
are primarily identified based on the type of habitat at the specific site. Fort Ritchie is composed of
a variety of habitats including developed park-like areas, upland hardwood forests, palustrine
wetlands, and freshwater streams. Ecological receptor groups such as terrestrial plants, soil
invertebrates, and terrestrial wildlife are identified for each habitat. Then, the potential risk to
representative species for each receptor group is evaluated.
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It should be noted that risk assessments conducted at Fort Ritchie were performed in accordance
with USEPA national and regional guidance for evaluating risks at hazardous waste sites. Additionally,
risk assessments often make highly conservative assumptions when evaluating the risk to human
health and ecological receptors. The goal of the risk assessment is to calculate upper-bound risks
so that the actual risk will not be under estimated.
I Comment 9. 2.1 OU6-Autocraft Shop	I
Comment: For all units - your conclusion that unacceptable risks were not associated with contaminants
detected under the current or anticipated future land use for this site (industrial land use) but, under
Section 2.0 (Site Background and Characteristics), are planned for commercial use. Is there not a
difference between industrial and commercial use? Who, how, and when, will enforcement of such
limited land use be handled, and the general public being informed, if there are changes, in land use.
The five year review, is not sufficient to address, changes made, if any, year by year waiting for 5
years is not acceptable.
Response: The terms "commercial" and "industrial" are interchangeable in regards to the Fort Ritchie risk
assessment.
Based on recent partnering between the Army, USEPA, and MDE, the recommended alternatives
have changed and ultimately no land use restrictions will occur at Operable Units 6, 9, and 12.
If restrictions were recommended, proprietary controls will be included in property transferdocuments.
Proprietary controls are private contractual mechanisms such as notifications, covenants, and
easements contained in the deed, that allow the holder to use or restrict the use of the property.
Restrictions would be binding on each successive owner of the property (i.e., will "run with the land").
The responsibility to be aware of and comply with deed restrictions would fall to the property owner.
The Army would assess the effectiveness of the proprietary controls during five-year reviews. This
five-year time period was selected as an appropriate frequency, and parallels the standard USEPA
enforced CERCLA five-year review process.
I Comment 10. 2.2 OU9-Administration Building Area	I
Comment: Most of the (USTs) underground storage tanks were replaced or removed in recent years. Why not
all?
Response: Removal or replacement of USTs have been performed by the Army in recent years at OU9 due to
the fact that the tanks did not meet current State of Maryland UST requirements. A handful of tanks
were not removed/replaced due to the fact that they are less than 10 years old and meet State UST
requirements. Currently, all remaining USTs in OU9 meet State requirements.
I Comment 11. 2.2 OU9-Administration Building Area	I
Comment: There should be a breakdown, of issues, concerns, and problems - building by building. Many of
these, like the Health Clinic (#341), Dental Clinic (#332), Telecommunications Facility (#160), and the
Photographic Laboratory (#301) - all have unique and different chemical and other possible
hazardous substances, derived from their operations, which was not addressed, in this plan, also, no
mention of possible problems, from the indoor shooting range at the Telecommunications Facility
(Building #160).
Response: The Site Investigation conducted at OU9 included soil and groundwater sampling of all areas of
potential concern as decided by the BRAC Cleanup Team. No indoor concerns were identified.
Sampling locations were biased in areas where potential concerns were
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identified. For example, soil samples (OU9SS07 and OU9SS08) were collected in close proximity to
Building 341 to evaluate potential impacts to the soil from former Health Clinic activities. A
groundwater monitoring well (OU9GW03) was installed and sampled downgradient of Building 341
to evaluate potential impacts to groundwater. Similar sampling activities were conducted for Buildings
332, 160, and 301.
All soil and groundwater samples were conservatively analyzed for Target Analyte List Inorganics,
Target Compound List Volatile Organic Compounds, Target Compound List Semi-volatile Organic
Compounds, PCBs, Total Petroleum Hydrocarbons (Diesel Range and Gasoline Range), Pesticides,
and Herbicides to evaluate all potential types of contamination that could exist at OU9. No
contamination attributed to past activities in these buildings was detected in soil or groundwater
samples collected from the area.
I Comment 12. OU12 - Former Hospital Area	I
Comment: Concerns about Building 833 Site, a former morgue and storage area for herbicides was there any
specific problems - from this former site, due to its past history? Building 837- Why are there still
small quantities of hazardous material, on site? Building 811 - are there any problems with this site,
since it was a wing of the former hospital?
Response: While a review of the historical use of the OU12 area indicated former hospital-related activities had
occurred, no site-specific activities were identified that may have potentially impacted the
environment. Additionally, all but one of the buildings has been demolished and significant reworking
of soils was performed to create a ball field. Therefore, the Army, USEPA, and MDE agreed that the
area should be evaluated as a single OU rather than on a building by building basis. Groundwater
samples were collected from the area to evaluate any potential contamination from former activities
conducted at the site.
All samples were conservatively analyzed for Target Analyte List Inorganics, Target Compound List
Volatile Organic Compounds, Target Compound List Semi-volatile Organic Compounds, PCBs, Total
Petroleum Hydrocarbons (Diesel Range and Gasoline Range), Pesticides, and Herbicides to evaluate
all types of potential contamination. Based on sampling results, there are no indications that former
activities at specific buildings (including the former Building 833 and Building 811) impacted the
environment. Building 837, formerly reported as storing small quantities of hazardous material, has
since been converted into an educational facility for the International Masonry Institute. The small
quantity of hazardous material formerly stored at this location has since been removed.
Bis(2-ethylhexyl) phthalate (DEHP) was detected at estimated concentrations above federal primary
drinking water Maximum Contaminant Levels (MCL) at two sample locations, however, DEHP is a
common laboratory contaminant and is considered an artifact of the analytical process. Manganese
was detected in one groundwater sample above the federal secondary drinking water MCL but is
considered an artifact of sample collection procedures. Subsequently, no further action with a deed
notification identifying the investigations conducted at the site is recommended forOU12.
I Comment 13. OU12 - Former Hospital Area	I
Comment: The results of the sampling, from the shallow groundwater, should have been included in the risk
assessment, even if, at present, the drinking water supply is from wells, in the deeper bedrock
aquifer.
Response: The shallow groundwater at Fort Ritchie is not currently being used as a potable drinking water source
(as opposed to the deeper bedrock groundwater, which provides Fort Ritchie with its water supply).
It is the Army's belief that the shallow groundwater is not a viable future drinking water source based
on low yield rates. Thus, it is believed that human exposure to shallow groundwater does not
represent a complete receptor pathway
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for future exposures and therefore, was not quantitatively evaluated in the Human Health Risk
Assessment.
I Comment 14. OU12 - Former Hospital Area	I
Comment: Is the standards and criteria for the state or federal maximum contaminant levels (MCLs) for drinking
water the same? If not - why and what are the differences?
Response: Federal MCLs are mandated by the USEPA. State MCLs must be at least as stringent as the Federal
MCLs. MCLs are defined as the maximum permissible level of contaminants in a public water system
and are legally enforceable clean-up levels regardless of whether the water is being used as a
drinking watersupply. There are differences in the Maryland State and Federal MCLs. This difference
can be viewed in the Section 4.0 of the Fort Ritchie Site Investigation Report (USACE, 1998). It must
be noted that these levels are updated regularly. The most recent federal and state MCLs can be
downloaded off of the internet.
I Comment 15. 4.2 Ecological Risk	I
Comment: We think that further evaluation for OUs 6, 9, and 12 - are necessary, to protect the ecological
environment. The initial screening and site visit, are not sufficient, in this plan.
Response: Operable units 6, 9, and 12 were not selected to be evaluated beyond the initial screening stage due
to the limited presence of chemicals and poor habitat quality at these areas. These OUs are located
in areas that have been extensively developed since the 1940s and mainly consist of buildings,
parking lots, roadways, and manicured lawns. This decision was made with the USEPA Region III
Biological Technical Assistance Group.
I Comment 16. 6.0 Summary of Alternatives	I
Comment: We support remedial alternative option #2 - for OUs 6, 9, and 12.
Deed Restriction - to a) no residential land-use by future property owners, and b) prohibit use of
shallow groundwater as a drinking source.
Response: Based on further evaluation and partnering discussions between the USEPA, MDE, and USACE,
the preferred alternatives forOU6, 9, and 12 have been revised.
Active response measures were evaluated in an Action Memorandum for OU6 Autocraft Shop and
OU9 Administrative Building Area. This Action Memorandum established a recommended cleanup
goal for arsenic in soils which was identified at the primary contaminant of concern at OU6 and OU9.
Based on the cleanup goal, OU6 has been recommended for no further action (NFA) and a removal
action was selected to remove an isolated arsenic exceedance in surface soils at OU9.
Additionally, a memorandum amending the recommendations of the SI Report was prepared for
OU12. This memorandum re-evaluated DEHP and Manganese concentrations detected above MCLs
in groundwater and concludes that these results are artifacts of field sampling procedures and/or
laboratory contamination. Subsequently, no further action with a deed disclosure is recommended
for this OU.
I Comment 17. 7.7 Cost	I
Comment: We oppose, the five-year review process, as being too long a span, since hazardous substances, will
remain on site above levels that allow for unlimited use and unrestricted exposure. To provide
adequate protection of human health and the environment - we recommend - that the review be
done every year; or at least every two years.
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Response: The revised recommended alternatives for OU6, 9, and 12 will allow for unrestricted exposure in the
future since all chemicals will be removed that are above acceptable risk levels. Therefore, no
five-year review process will be necessary.
I Comment 18. Appendix A - USEPA Comments	I
Comment: Since the ground water (OU12) associated with this area contains the contaminated bis(2ethylhexyl)
phthalate (DEHP) at concentrations above the Federal MCL of 6 ppb, from 3 out of 6 wells, it is not
protective of human health and that the remedial alternative of No Further Action has been chosen
for OU12.
We strongly protest this, and request that a new round of sampling, take place at this site.
Response: As a result of recent partnering discussions held between the Army, USEPA, and MDE, a
memorandum amending the recommendations of the SI Report was prepared for OU12. This
memorandum re-evaluates DEHP concentrations detected above MCLs in groundwater and
concludes that these results were artifacts of field sampling procedures and/or laboratory
contamination. Subsequently, no further action with a deed disclosure was recommended forthis OU.
I Comment 19. Appendix A - USEPA Comments	I
Comment: There is also, too many unknowns and concerns of laboratory contamination of samples and of the
quality control process. We also are requesting that duplicate samples - are taken and that they are
sent to two different labs - for analyzation, that meet current certification for such study. There should
also be field rinse blanks taken. We also request, that each independent lab-do a re-analysis-that
does not exceed holding times, for proper quality control and validation of reports.
Response: As stated above, based on partnering between the Army, USEPA, and MDE, re-evaluation of
contaminants detected at OU12 was performed resulting in a recommendation of no further action
for the site.
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August 2000
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LETTER DATED 08 NOVEMBER 1999 ON THE
PROPOSED PLAN FOR US 6, 9, AND 12, FINAL DOCUMENT
FORT RITCHIE ARMY GARRISON
FROM LEURA K. SULCHEK
I Comment 1.	I
Comment: I would like to request a public meeting be held regarding the Proposed Plan for Operable Units 6,
9, and 12 at Fort Ritchie Army Garrison, Maryland. I believe the Army should present this plan to the
public and open the meeting up for discussion.
Response: A public meeting has been scheduled for 15 May 2000 to address the Army's recommended
alternatives for OU6, OU9, and OU12.
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August 2000
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LETTER DATED 09 NOVEMBER 1999 ON THE
PROPOSED PLAN FOR OUS 6, 9, AND 12, FINAL DOCUMENT
FORT RITCHIE ARMY GARRISON
FROM ANN DUBLE
I Comment 1.
Comment: I believe I am speaking for many residents "up here on the mountain," when I say we would like to
have a public meeting regarding the proposed plan advertised recently in the paper. Many of us are
concerned and confused by the information released at the Pen Mar meetings. I think the Army-side
needs to be presented. What many of us don't understand - why weren't all the environmental issued
brought up before the post was BRACed? If it had been, surely the Army wouldn't have let it be
BRACed.
A friend recently attended the last RAB meeting, and was very upset by what she heard there - that
much of the mountain would be "stripped," and not replanted, four foot holes dug, etc. We need to
know what is really going on.
Even though I personally never worked at Fort Ritchie, it is very sad to see that a beautiful post is not
being utilized, not to mention the jobs gone.
Response: A public meeting has been scheduled for 15 May 2000 to address the Army's recommended
alternatives for OU6, OU9, and OU12.
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August 2000
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Fort Ritchie Army Garrison

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