EPA/ROD/R03-01/024
2001
EPA Super fund
Record of Decision:
ABERDEEN PROVING GROUND (EDGEWOOD AREA)
EPA ID: MD2210020036
OU10
EDGEWOOD, MD
08/17/2001
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retaliation Restoration Program
RECORD OF DECISION
CARROLL ISLAND and GRACES QUARTERS
ABERDEEN PROVING GROUND
MARYLAND
%. PRO^
CHEMICAL WARFARE MATERIEL
AND OTHER HAZARDOUS SUBSTANCES
(OPERABLE UNITS B)
AND ASSOCIATED SITES
FINAL
MAY 2001
Edgewood Area - Aberdeen Proving Ground, Maryland
This document is intended to comply with the National Environmental Policy Act of 1969
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RECORD OF DECISION
CARROLL ISLAND and GRACES QUARTERS
ABERDEEN PROVING GROUND
MARYLAND
CHEMICAL WARFARE MATERIEL
AND HAZARDOUS SUBSTANCES
(OPERABLE UNITS B)
AND ASSOCIATED SITES
FINAL
Directorate of Safety, Health and Environment
Environmental Conservation and Restoration Division
Installation Restoration Program
U.S. Army Garrison Aberdeen Proving Ground, Maryland
MAY 2001
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Record of Decision May 2001
Carroll Island and Graces Quarters Operable Units B Final
Aberdeen Proving Ground, Maryland Page i of iv
TABLE OF CONTENTS
Section Page
TABLE OF CONTENTS I
1 DECLARATION 1
1.1 Unit Name and Location 1
1.2 Statement of Basis and Purpose 1
1.3 Assessment of the Site 2
1.4 Description of the Selected Remedies 2
1.5 Statutory Determinations 3
1.6 Data Certification Checklist 4
2 DECISION SUMMARY 6
2.1 Site Name, Location and Description 6
2.2 Site History and Enforcement Activities 8
2.2.1 History 8
2.3 Enforcement Activities 8
2.4 Community Participation 14
2.5 Scope and Role of Operable Units and Response Action Within Site Strategy 15
2.6 Site and Operable Unit Characteristics 16
2.6.1 Removal Action at Service Area on Carroll Island 17
2.6.2 Removal Action at the Wind Tunnel on Carroll Island 17
2.6.3 Removal Action at the Service Area on Graces Quarters 18
2.6.4 Removal Action at the Disposal Area on Graces Quarters 19
2.7 Current and Potential Future Site and Resource Uses 20
2.8 Summary of Operable Unit Risks 20
2.9 Remedial Action Objectives 24
2.10 Description of Alternatives 24
2.10.1 Land Use Controls and Access Restrictions 25
2.10.2 Erosion Controls 26
2.11 Comparative Analysis of Alternatives 29
2.11.1 Overall Protection of Human Health and the Environment 29
2.11.2 Compliance with Applicable or Relevant and Appropriate Requirements 30
2.11.3 Long-Term Effectiveness and Permanence 30
2.11.4 Reduction of Toxicity, Mobility, or Volume of Contaminants Through Treatment 31
2.11.5 Short-Term Effectiveness 36
2.11.6 Implementability 36
2.11.7 Cost 36
2.11.8 State Acceptance 37
2.11.9 Community Acceptance 37
2.12 Principal Threat Waste 37
2.13 The Selected Remedies 37
2.14 Performance Standards 38
2.15 Statutory Determinations 39
2.16 Explanation of Significant Changes 40
3 RESPONSIVENESS SUMMARY 40
4 REFERENCES 40
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Record of Decision May 2001
Carroll Island and Graces Quarters Operable Units B Final
Aberdeen Proving Ground, Maryland Page ii of iv
LIST OF FIGURES
Figure 1. Location of Carroll Island and Graces Quarters 7
Figure 2. Carroll Island Remedial Investigation Site Locations 9
Figure 3. Graces Quarters Remedial Investigation Site Locations 10
Figure 4. Shoreline Erosion Controls for Carroll Island 27
Figure 5. Shoreline Erosion Controls for Graces Quarters 28
LIST OF TABLES
Table 1. Carroll Island Sites 11
Table 2. Graces Quarters Sites 12
Table 3. Potential Chemical-Specific Applicable or Relevant and Appropriate 31
Requirements for Remedial Actions at Carroll Island and Graces
Quarters, Aberdeen Proving Ground, Maryland
Table 4. Potential Location-Specific Applicable or Relevant and Appropriate 31
Requirements for Remedial Actions at Carroll Island and Graces
Quarters, Aberdeen Proving Ground, Maryland
Table 5. Potential Action-Specific Applicable or Relevant and Appropriate 33
Requirements for Remedial Actions at Carroll Island and Graces
Quarters, Aberdeen Proving Ground, Maryland
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page iii of iv
LIST OF ACRONYMS AND ABBREVIATIONS
AEHA United States Army Environmental Hygiene Agency (currently designated the U.S. Army
Center for Health Promotion and Preventative Medicine
AOC area of concern
APG Aberdeen Proving Ground
ARAR applicable or relevant and appropriate requirement
BZ 3-quinuclidinyl benzilate (an incapacitating agent)
CERCLA .... Comprehensive Environmental Response, Compensation and Liability Act
CS ortho-chlorobenzalmalononitrile (a "tear gas" material)
CWM chemical warfare materiel
DSERTS .... Defense Sites Environmental Restoration Tracking System
EPA United States Environmental Protection Agency
FFA Federal Facility Agreement
FFS focused feasibility study
FS feasibility study
HD bis(2-chloroethyl)sulfide (mustard)
LUC land use control
LUCAP Land Use Control Assurance Plan
LUCIP Land Use Control Implementation Plan
MDE Maryland Department of the Environment
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NEPA National Environmental Policy Act
NPL National Priorities List
O&M operations and maintenance
RAO remedial action objective
RCRA Resource Conservation and Recovery Act
RFA RCRA facility assessment
RFI RCRA facility investigation
RI remedial investigation
ROD record of decision
SARA Superfund Amendments and Reauthorization Act
SAV submerged aquatic vegetation
SWMU solid waste management unit
TPH total petroleum hydrocarbons
USGS United States Geological Survey
UST underground storage tank
UXO unexploded ordnance
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May 2001
Final
Page iv of iv
VX O-ethyl S-(2-diisopropylaminoethyl) methylphosphonothioate (a nerve agent)
WP white phosphorus
°F degrees Fahrenheit
Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 1 of 49
May 2001
Final
1 DECLARATION
1.1 Unit Name and Location
Carroll Island
Edgewood Area
Aberdeen Proving Ground, Maryland
Operable UnitB (CWM and Hazardous Substances) and Associated Sites
Graces Quarters
Edgewood Area
Aberdeen Proving Ground, Maryland
Operable UnitB (CWM and Hazardous Substances) and Associated Sites
Carroll Island and Graces Quarters are 2 of 13 study areas listed within the Federal Facility Agreement (FFA)
(APGand EPA, 1990) for Aberdeen Proving Ground (APG) and which contain sites/units regulated as Resource
Conservation and Recovery Act (RCRA) 3004(u) Solid Waste Management Units (SWMUs) and Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) units.
1.2 Statement of Basis and Purpose
This Record of Decision addresses multiple units at both Carroll Island and Graces Quarters, as well as chemical
warfare materiel (CWM) and hazardous substances that may exist at unknown locations. The CWM and hazardous
substances are designated as Operable Units B at Carroll Island and Graces Quarters. The units addressed are:
Carroll Island Operable Unit B (CWM and Hazardous Substances)
Graces Quarters Operable Unit B (CWM and Hazardous Substances)
Carroll Island Service Area Wastewater Treatment Plant
Carroll Island Wind Tunnel Site
Graces Quarters Service Area
Graces Quarters Disposal Area
Area of Concern (AOC) Associated With Bengies Point Road Dump
Bengies Point Road Farmhouse
Dredge Spoil Site
Aerial Spray Grid
AOC Associated With Decontamination Pits
Adamsite Burial Site
Hawthorn Cove Road
Test Grid 1
Magazine Area
• Animal Shelter
Woods East of Test Grid 1
CS Test Area
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 2 of 49
AOC Associated With CS Test Area
Woods North of Wind Tunnel Road
VX Test Area
Test Grid 2
HD Test Area
AOC Associated with Graces Quarters Disposal Area
Graces Quarters Dump
AOC Associated with Graces Quarters Dump
• HD Test Annuli
Secondary Test Area
• The Bunker
Test Huts
• Federal Emergency Management Agency (FEMA) Service Area
• FEMA Bunker
• Northern Perimeter Dump
Southern Perimeter Dump
Primary Test Area
Southwest Perimeter Dump
Dugway Proving Ground Test Site
The remedial actions are chosen in accordance with CERCLA as amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986, and, to the extent practicable, with the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). The information supporting the decisions on the selected remedy
is contained in the Administrative Record File for these sites.
The remedy selected also satisfies RCRA Corrective Action Requirements, and consistent with the FFA (p. 57),
obviates the need for further corrective action under RCRA for this operable unit.
The State of Maryland Department of the Environment (MDE) concurs with the selected remedy.
1.3 Assessment of the Site
Actual or threatened releases of hazardous substances from these sites, if not addressed by implementing the
response action selected in this Record of Decision (ROD), may present an imminent and substantial endangerment
to public health, welfare, or the environment.
1.4 Description of the Selected Remedies
Based on the military usage history of Carroll Island and Graces Quarters, these sites are expected to contain
CWM. These materials pose risks to human health and the environment, and remedial action is appropriate. At both
Carroll Island and Graces Quarters all CWM not located in disposal sites that already have been or are currently
being remediated has been designated as
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 3 of 49
May 2001
Final
Operable Unit B. All of the land and shoreline areas are included within the Operable Unit B areas of Carroll Island
and Graces Quarters.
An evaluation of potential alternatives was performed in accordance with the NCP. Based on this evaluation, the
selected remedy for Operable Units B at Carroll Island and Graces Quarters is "Public Access Controls, Land Use
Restrictions, and Erosion Controls".
Public access controls with land use restrictions will mitigate the principal threat to human health and the
environment at Carroll Island and Graces Quarters by reducing the potential for direct contact with CWM. In
combination with erosion controls, the selected remedy will reduce potential for release of CWM and hazardous
materials to surface waters. The major components of the selected remedy for Operable Units B include:
Land use restriction with primary use as a Natural Resource Management Area, and secondary use for
military/industrial activities,
Warning signs,
Land and water patrols,
Site inspections,
Disposal of CWM identified by site inspections, and
Erosion controls.
The removal actions at the Wind Tunnel Site and Service Area Wastewater Treatment Plant on Carroll Island, and
at the Service Area and Disposal Site on Graces Quarters have removed potential sources of hazardous materials
from these four sites. Therefore, the selected remedial action for the Carroll Island Wind Tunnel Site, Carroll Island
Service Area Wastewater Treatment Plant, Graces Quarters Service Area and Graces Quarters Disposal Area
is "No Further Action".
The baseline risk assessment did not identify unacceptable risks associated with the other units listed in Section 1.2,
"Statement of Basis and Purpose". Therefore, the selected remedial action for these sites is "No Further Action".
1.5 Statutory Determinations
CWM is being addressed as a CERCLA pollutant and contaminant that could present an imminent and substantial
danger to the public health or welfare should there be a release or substantial threat of release into the environment.
The selected remedies are protective of human health and the environment, comply with Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action, and are cost-effective.
Because treatment of the principal threats of the site was not
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 4 of 49
May 2001
Final
found to be practicable, this remedy does not satisfy the statutory preference for treatment as a principal element.
Because the remedy for Operable Units B at Carroll Island and Graces Quarters will leave hazardous substances,
pollutants or contaminants remaining on-site, a review will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide adequate protection of human health and the
environment.
1.6 Data Certification Checklist
The following information is included in the Decision Summary section of this Record of Decision. Additional
information can be found in the Administrative Record file for this site:
Chemicals of concern and their respective concentrations.
Baseline risk represented by the chemicals of concern.
Cleanup levels established for chemicals of concern and the basis for these levels.
How source materials constituting principal threats are addressed.
Current and reasonably anticipated future land use assumptions and potential future beneficial uses of
groundwater used in the baseline risk assessment and the ROD.
Potential land and groundwater use that will be available at the site as a result of the Selected Remedy.
Estimated capital, annual operation and maintenance (O&M), and total present worth costs, discount rate,
and the number of years over which the remedy cost estimates are projected.
Key factor(s) that led to selecting the remedies (i.e., how the Selected Remedy provides the best balance
of tradeoffs with respect to the balancing and modifying criteria, and which criteria were key to the decision).
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 5 of 49
JOIffl C. DOESBURG f \ Date
Major General, U.S. Army
Commander, U,S, Army Aberdeen Proving Ground
CHARLES C. CANNON, JR. / j pate
Major General, USA
Chief of Staff
UiS Amy Materiel Conmand
efnh
ABRAHAM FERDAS Date' '
Director
Hazardous site Cleanup Division
U.S. Environmental Protection Agency, Region. Ill
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 6 of 49
May 2001
Final
2 DECISION SUMMARY
2.1 Site Name, Location and Description
Aberdeen Proving Ground (APG) is located on the western shore of the upper Chesapeake Bay in Maryland. It
is divided into the Aberdeen and Edgewood Areas by the Bush River, a large tidal estuary. The Edgewood Area
is itself divided by the Gunpowder River, another large tidal estuary. Carroll Island and Graces Quarters are located
within the Edgewood Area of APG on the western shore of the Gunpowder River. Carroll Island and Graces
Quarters are located within Baltimore County, while the remainder of APG lies within Harford County (Figure 1).
Carroll Island lies approximately one mile south of the Hammerman Area of Gunpowder Falls State Park. The
closest residents are located on Beach Road, approximately '/2 mile from Carroll Island. The community of
Carrollwood Manor is approximately IV2 miles away.
Carroll Island encompasses approximately 855 acres, of which 659 are classifiable wetlands. It is bounded by
Seneca and Saltpeter Creeks, the Gunpowder River, and Chesapeake Bay. Portions of its shoreline are subject
to storm surge and wave erosion. Because the peak elevation at Carroll Island is only 13 feet above mean sea level
and much of the island is less than 10 feet above mean sea level, extensive areas are subject to flooding (ORISE,
1998a). Carroll Island is poorly drained, and ephemeral ponds and isolated marshes form during storm events.
The island is largely undeveloped and is separated from the mainland by a dredged channel created for the Crane
Point Power Plant located directly west of Carroll Island. Structures on the island include paved and gravel roads,
the remains of two iron test towers, a small building, and concrete pads (several of which are former building
foundations). Access to Carroll Island is controlled by random security patrols and other physical measures.
Graces Quarters is a peninsula located approximately one mile north of Carroll Island in Baltimore County,
Maryland. It is located approximately two miles southeast of Chase, Maryland, and five miles southeast of White
Marsh, Maryland. The closest residents are located in the Community of Bay Country.
Graces Quarters covers 414 acres, of which approximately 151 acres are classifiable wetlands. It is bounded by
the Gunpowder River to the east, Saltpeter Creek to the south, Dundee Creek to the west, and the Hammerman
area of Gunpowder State Park to the north. The land mass consists of tidal and nontidal wetlands, open fields, and
wooded areas. Maximum elevation is approximately 40 feet above sea level.
Access to the property is controlled by chain link fences, a locked gate, random security patrols and other physical
measures. Paved and gravel roads are present on the peninsula.
The only permanent structure is an emergency radio transmitter and tower originally constructed by the Federal
Emergency Management Agency.
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LEGEND
ABERDEEN PROVING
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Figure 1 Location of CajToJI Island and Graces Quarters
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 8 of 49
May 2001
Final
2.2 Site History and Enforcement Activities
2.2.1 History
Carroll Island and Graces Quarters were acquired by the Army in 1918, but there is no evidence that military
operations took place until 1944. At that time, preparations were made to use portions of Carroll Island as impact
areas (for testing high explosive and smoke munitions) and chemical warfare materiel test sites (AEHA, 1989).
During the mid to late 1940s, Carroll Point and the area north of Lower Island Point (referred to as the 1,000-yard
impact area) were cleared and prepared for use as impact areas for 4.2-inch mortar. An area of Carroll Island later
occupied by portions of Test Grid #1 and the Aerial Spray Grid was also cleared of vegetation during the 1940s
(see Figure 2 for site locations and Table 1 for site designations). It was referred to as the sand flats and was used
as a CWM test area (probably including flame thrower tests) and possibly as an impact area.
During the 1940s, Graces Quarters was also developed for use as a military test facility. The area later designated
as the Primary Test Area was reportedly used as the impact area (see Figure 3 for site locations, and Table 2 for
site designations). Graces Quarters was also used as a firing point for mortar fire toward M-Field located to the
east on the Gunpowder Neck. A timber and sandbag bunker was constructed in the northern portion of Graces
Quarters as a control point during its use as an impact and firing area.
The 4.2-inch mortar fire to the impact areas of Carroll Island and Graces Quarters is known to have been primarily,
and perhaps exclusively, with high explosive and white phosphorus (WP) filled rounds. During the mid 1940s the
Army policy concerning "live fire" testing with lethal chemical agents was changed to restrict such activities at APG.
Testing of chemical agents and chemical ordnance at Carroll Island and Graces Quarters was conducted from the
1940s through 1971, with the testing from 1969 until 1971 restricted to non-lethal chemical material such as riot
control agents, simulants and smoke. The lethal and incapacitating chemical agents used in test activities at Carroll
Island and Graces Quarters included the complete range of stockpile agents as well as a variety of experimental
chemicals. Detailed records of testing are available only for the latter years, from 1964 through 1971. Materials
used in testing at Graces Quarters and possibly Carroll Island also included biological simulants (AEHA, 1989).
Wastes from test activities at Carroll Island and Graces Quarters were placed into either dump sites or burial pits.
These disposal sites have already been remediated.
2.3 Enforcement Activities
From 1984 to 1985, APG was evaluated as a potential National Priorities List (NPL) site under CERCLA. In
1985, the Edgewood Area of APG was proposed for inclusion on the NPL; it was listed on the NPL in 1990. In
1986, between the time of the proposed listing and the final listing, a RCRA corrective action permit
(MD3-21-002-1355) was issued by the Environmental
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LEGEND
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GROUND BOUNDARY
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Figure 2 Carroll island - Remedial Investigator! Site Locations
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Figure 3 Graces Quarters - Remedial Investigation Site Locations
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 11 of49
Table 1. Carroll Island Sites
Carroll Island Operable Unit B
All of Carroll Island (CWM and Hazardous Substances) (EACI00)
"No Unacceptable Risk" Sites
AOC Associated With Bengies Point Road Dump (EACIOl-D)
Bengies Point Road Farmhouse (EACI01-B)
Dredge Spoil Site (EACI02-B)
Aerial Spray Grid (EACI04-A)
AOC Associated With Decontamination Pits (EACI04-C)
Adamsite Burial Site (EACI04-C)
Hawthorn Cove Road (EAC104-C)
Test Grid 1 (EACI05-A)
Magazine Area (EACI05-B)
Animal Shelter (EACI05-C)
Woods East of Test Grid 1 (EACI05-D)
Wind Tunnel (EACI06-A)
CS Test Area (EACI06-D)
AOC Associated With CS Test Area (EAC106-E)
Woods North of Wind Tunnel Road (EACI06-B)
VX Test Area (EACI07-A)
Test Grid 2 (EACI07-B)
HD Test Areas (EACI07-C)
Note: The baseline risk assessment did not identify unacceptable risks for these sites, for which no further
action is necessary.
"Operable Unit A" Sites (Previous Record of Decision)
Bengies Point Road Dump (EACI01-A)
Old Carroll Island Road Dump Site (EACI01-C)
Service Area (EACI02-A)
AOC Associated With Service Area (EACI02-C)
EPG Dump Site (EACI03)
AOC Associated With Aerial Spray Grid (EACI04-A)
BZ Test Burn Pit (EACI04-D)
Decontamination Pits (EACI04-B)
AOC Associated With Test Grid 1 (EACI05-E)
Test Grid 1 Disposal Area (EACI05-A)
Woods South of Wind Tunnel Road (EACI06-B)
Animal Shelter Woods (EACI06-B)
Lower Island Disposal Area (EACI08)
Note: Remediation of these sites has been completed
Note: Removal actions have also been completed at two sites; Underground Storage Tank at the Wind Tunnel
(EACI06-C) and Service Area Wastewater Treatment Plant (EACI02-A). The Service Area is also an Operable Unit
A site. The Aerial Spray Grid and the Associated AOC have the same site number.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 12 of49
Table 2. Graces Quarters Sites
Graces Quarters Operable Unit B
All of Graces Quarters (CWM and Hazardous Substances) (EAGQ00)
"Removal Action " Sites
Graces Quarters Disposal Area (EAGQ01-A)
Service Area (EAGQ03-A)
Note: The removal actions addressed waste and contaminated soil at these sites, and no further action is
necessary to protect human health or the environment.
"No Unacceptable Risk" Sites
AOC Associated with Graces Quarters Disposal Area (EAGQ01-A)
Graces Quarters Dump (EAGQ01-B)
AOC Associated with Graces Quarters Dump (EAGQ01-F)
HD Test Annuli (EAGQ01-G)
Secondary Test Area (EAGQ01-I)
The Bunker (EAGQ01-C)
Test Huts (EAGQ01-H)
FEMA Service Area (EAGQ01-D)
FEMA Bunker (EAGQ01-E)
Northern Perimeter Dump (EAGQ02-A)
Southern Perimeter Dump (EAGQ02-B)
Primary Test Area (EAGQ02-C)
Southwest Perimeter Dump (EAGQ02-B)
AOC Associated with Service Area (EAGQ03-C)
Dugway Proving Ground Test Site (EAGQ03-B)
Note: The baseline risk assessment did not identify unacceptable risks for these sites, for which no further
action is necessary.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 13 of49
Protection Agency (EPA) Region HI to address SWMUs in the Edgewood and Aberdeen Areas of APG. As
required by the RCRA permit, the U. S. Army Environmental Hygiene Agency (AEHA) performed a RCRA Facility
Assessment (RFA) study for the Edgewood Area. The RFA identified sites on Carroll Island that were either
SWMUs or areas with potential prior releases (AEHA, 1989). In addition to the RFA, the RCRA permit required
that a RCRA Facility Investigation (RFI) be performed. However, because of the final listing of the Edgewood Area
on the NPL in 1990, the RFI was not completed. Further investigations were performed under CERCLA.
In 1986, before the Edgewood Area was on the NPL list, the U. S. Geological Survey (USGS), in cooperation with
the Army, conducted a hydrogeologic assessment of Carroll Island and Graces Quarters (USGS, 1991 and 1996).
When the Edgewood Area was placed on the NPL, remedial investigations (RI) were initiated at Carroll Island and
Graces Quarters (Dames & Moore, 1997 and 1998). The RI report for Carroll Island recommended further action
be taken at disposal sites because of the widespread potential for CWM and hazardous substances. Operable Unit
A at Carroll Island consists of disposal pit/areas, for which a ROD was signed September 1996, with remediation
recently completed (APG, 1996).
A removal action was accomplished at the Graces Quarters Service Area during 1993. A Quonset hut was
removed because of the potential for CWM contamination in the ventilation system. Two underground tanks were
also removed, and found to contain gasoline and diesel fuel.
During 1993 and 1994 another removal action was accomplished to remove wastes from burial pits within the
Graces Quarters Disposal Area. The burial pits were located adjacent to an eroding shoreline, and the removal
action was accomplished to prevent release of hazardous substances to the Gunpowder River.
A small wind tunnel test facility was constructed in 1953 at the eastern portion of Carroll Island near Carroll Point.
Use of the wind tunnel in chemical agent and chemical ordnance test programs ended in the early 1970s. The
above-ground portion of the facility was removed during 1993. In 1995, a 250-gallon underground storage tank
that had been used to store coolant (ethylene glycol and water mixture) was removed from the site.
During the summer of 1999, a removal action was accomplished to close a small sump associated with an
abandoned package wastewater treatment system for the service area. The closure was accomplished by removing
sediment and water from the sump, followed by cleaning and then filling of the sump. The Decision Document,
Removal Action of a Sump Associated with the Former Service Area at Carroll Island (APG, 1998) describes
and documents the decision for this interim remedial action.
Combined Feasibility Study (FS) and Proposed Plan documents for Operable Units B for Carroll Island and
Graces Quarters were completed in July 1998 (ORISE, 1998a and 1998b). The Proposed Plan identified "Public
Access Controls with Land Use Restrictions" as the preferred alternative. In response to public comments asking
that erosion control measures be considered for reducing the risks associated with CWM, an FS addendum
(Dames & Moore, 1999a) and a
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 14 of49
May 2001
Final
revised Proposed Plan (Dames & Moore, 1999b) were prepared. The FS addendum evaluated process options
for control of shoreline erosion, and developed and evaluated a third remedial alternative for Operable Units B
involving public access controls, land use restrictions and erosion controls. The revised proposed plan identified
"Public Access Controls, Land Use Restrictions, and Erosion Controls" as the preferred remedial alternative for
Operable Units B at Carroll Island and Graces Quarters.
2.4 Community Participation
CERCLA requires that the public be given an opportunity to review and comment on the proposed remedial
alternative. Public participation requirements are listed in Sections 113 and 117 of CERCLA. These requirements
include establishment of an Administrative Record File that documents the investigation and selection of the remedial
alternatives for addressing the risks associated with CWM and hazardous substances at Operable Units B of
Carroll Island and Graces Quarters. The Administrative Record File must be established at or near the facility at
issue. The APG Community Relations Plan is designed to facilitate public involvement in the decision-making
process for selection of remedial alternatives (ICF, 1998). The APG Community Relations Plan addresses the
requirements of CERCLA and the National Environmental Policy Act of 1969 (NEPA). Section 117(a) of
CERCLA, as amended, requires the public be given notice of any proposed remedial action, and that the public
be provided an opportunity to participate in the selection of the remedial action. The Proposed Plan for Operable
Units B at Carroll Island and Graces Quarters (Dames & Moore, 1999b), a part of the Administrative Record File,
highlights key issues and identifies the preferred action for addressing the CWM and hazardous substances.
The public participated in the decision process for the removal actions that have been accomplished for the Carroll
Island Wind Tunnel, the Carroll Island Service Area Wastewater Sump, the Graces Quarters Service Area, and
the Graces Quarters Disposal Area.
The FFA Administrative Record File, which contains the information pertaining to the selection of the response
action, is available at the EPA Region m office and at the following locations:
Harford County Library
Edgewood Branch
2205 Hanson Road
Edgewood, MD 21040
410-612-1600
Harford County Library
Aberdeen Branch
21 Franklin Street
Aberdeen, MD 21001
410-27-5608
Miller Library
Washington College
Chestertown, MD 21620
410-778-2800
The public was notified of the public comment period for the Proposed Plan through notices in the Aegis, the Kent
County News, the Cecil Whig, The Avenue, and the Essex Times.
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Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 15 of49
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Final
The public comment period began on 26 April 2000 and ended on 9 June 2000. A public comment meeting was
held on 11 May 2000. A Responsiveness Summary was prepared to address comments received during the public
comment period. The Responsiveness Summary is provided in Appendix A of this document.
2.5 Scope And Role Of Operable Units And Response Action Within Site Strategy
An Operable Unit is defined by the NCP as a discrete action which is an incremental step toward comprehensively
mitigating site problems. The investigation of Carroll Island and Graces Quarters, and the assessment of risks to
human health and the environment has resulted in the definition of Operable Units as:
Thirteen sites were discovered on Carroll Island, which potentially contained waste from testing
activities. There was a concern about buried wastes resulting in contaminant migration to the
surrounding environment because of the shallow water table, flooding, and shoreline erosion.
Therefore, a Focused Feasibility Study (FFS) was conducted to address the disposal pits. The
results of the FFS concluded that excavation of the pits was necessary, and a ROD was signed in
September 1996. As discussed further in the following section, removal actions for Operable Unit
A - Disposal Pits have been addressed separately from the plan of action for Operable Unit B.
Carroll Island was used for impact areas and CWM test sites from 1944 to 1971. Wastes from
testing activities were disposed of by dumping or burial at numerous locations. Carroll Island is
approximately 80 percent wetlands, and even though thorough environmental investigations have
been conducted, all the wastes associated with testing and support activities could not be located
or identified because of the marshy areas and heavy vegetation. Operable Unit B encompasses the
entire island to provide protection of human health and the environment from potential CWM and
hazardous substances.
Graces Quarters, Operable Unit A -Contaminated Groundwater Associated with
the Primary Test Area
Based on the results of the RI and risk assessment, concentrations of chlorinated solvents in the
groundwater - primarily 1,1,2,2-tetrachloroethane and carbon tetrachloride - in the vicinity of the
Primary Test Area (Site 5, EAGQ02-C) warrant remediation. This record of decision does not
address contaminated groundwater at Graces Quarters. An FFS is being prepared to address the
contaminated groundwater.
Carroll Island, Operable Unit A - Disposal Pits
Carroll Island, Operable Unit B - CWM and Hazardous Substances
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Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
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Final
Graces Quarters, Operable Unit B - CWM and Hazardous Substances
The southern portion of Graces Quarters was used as an impact area during World War n. Riot
control, CWM, smoke, and simulants were tested on the peninsula from the early 1950s to 1971.
Thorough environmental investigations have been conducted; however, Graces Quarters is densely
vegetated in some areas and contains wetlands in others, and all the waste associated with testing
and support activities from the past could not be located or identified. Operable Unit B
encompasses all of Graces Quarters to address all CWM and hazardous substances that have not
been located.
Operable Units B for Carroll Island and Graces Quarters were combined because of the similarity of environments,
contaminants, and potential remedial actions. Operable Unit A - Disposal Pits at Carroll Island and Operable Unit
A - Contaminated Groundwater at Graces Quarters were addressed separately from the plan of action for
Operable Units B.
This ROD documents a plan of action to prevent human exposure to contaminants from Carroll Island and Graces
Quarters. This recommended plan of action has been developed because it is still possible that sporadic
contamination exists at both areas (such as at small disposal areas and individual buried munitions) that could not
be found using existing technology. Nevertheless, there are no remaining positively-identified areas that contain
CWM or hazardous substances on Carroll Island and Graces Quarters.
This ROD documents a "No Further Action" decision for the Carroll Island Wind Tunnel, the Carroll Island Service
Area Wastewater Treatment Plant, the Graces Quarters Service Area, and the Graces Quarters Disposal Area.
Removal actions at these sites have eliminated hazardous materials and potential threats to human health and the
environment.
This ROD also documents a "No Further Action" decision for the Carroll Island and Graces Quarters sites for
which the baseline risk assessment did not identify unacceptable risk. These sites are listed in Tables 1 and 2.
2.6 Site And Operable Unit Characteristics
Initial screening and records review identified 21 sites and 11 AOCs to be included in the Carroll Island RL RI
activities consisted of historical searches, wetlands delineation, ecological investigations, well installations,
geophysical and soil gas surveys, environmental sampling, and archeological surveys.
As discussed in the previous section, four operable units were developed for Carroll Island and Graces Quarters
as a result of the investigations. Operable Units B were developed based on the knowledge of Carroll Island and
Graces Quarters through the RI process and known historical uses of the area. Since the time field work was
started by the Army in 1977, many surface and subsurface disposal areas containing hazardous substances have
been found through investigations and visual observations. Even though environmental investigations have been
conducted, all the waste associated with testing and support activities from past activities has not been located or
identified. Many disposal areas that were not originally reported have been
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Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 17 of49
May 2001
Final
found by visual observation or magnetometry, or both. Carroll Island contains highly vegetated areas, such as
wetland, that can hide or cover surface or subsurface disposal areas from both visual or magnetometry detection.
Waste has also been identified after it has been exposed from shoreline erosion or frost heaving.
2.6.1 Removal Action at Service Area on Carroll Island
The Service Area, which is designated as Site 13 (Cluster 2, EACI02-A), was originally identified as a possible
source of environmental contamination during the RCRA Facility Assessment conducted in 1989. The site consisted
of two Quonset huts and several small facilities for water supply and wastewater management in support of testing
activities on Carroll Island. The remains of the wastewater treatment plant consisted of a small metal unit on a grate
over a concrete sump.
During the Carroll Island RI, volatile organic compounds, semi-volatile organic compounds, pesticides,
polychlorinated biphenyls, and metals were detected in sediment samples in the sump. The measured concentrations
of these contaminants did not exceed any state or federal regulatory standards, but did exceed RI comparison
criteria, which, were based on previous background sampling conducted in 1993. The Baseline Human Health Risk
Assessment indicated no risks or hazards. The Ecological Risk Assessment did reveal potential effects to aquatic
organisms living within the sump. The walls of the cement-lined sump were elevated approximately 2 feet above
the ground, and the sump was covered by steel plates. This habitat was expected to be capable of supporting a
very limited number of benthic invertebrates. Adverse effects, if occurring; would have been limited to these species.
Based on the ecological risks, and the possibility that contaminated sediment might be disturbed in the future and
released to other media, a removal action was recommended in the RI for the sump at the Service Area. EPA and
MDE concurred with the RI's recommendation of a removal action at this site.
The removal action, which was completed in July 1999, consisted of removing the contaminated contents of the
sump while leaving the sump in place. The following measures were performed during this removal action:
dewatering the sump, removing the sediments, high pressure washing, plugging all outgoing lines, and filling the sump
with a fill material.
2.6.2 Removal Action at the Wind Tunnel on Carroll Island
The Wind Tunnel, which is identified as Site 5 (Cluster 6, EACI06-A), was constructed in 1953 for use in testing
CWM in an enclosed test chamber. The facility consisted of the Wind Tunnel building, a control room, a scrubber
system, and a 250-gallon UST for storage of an ethylene glycol/water mixture used in the scrubber. Use of the
Wind Tunnel was terminated in 1973.
The Wind Tunnel Site is located on the eastern half of Carroll Island at Carroll Point. It is bordered by a low lying
field to the north, marsh to the west, and the Gunpowder River to the south. The area sometimes becomes flooded
during storm events. Field inspections of the site in 1993 revealed the structure was in poor condition. There was
also evidence trespassers had gained access to the building. Because of the deteriorating condition of the building
and the potential for residual chemical contamination of the equipment inside, the site was considered to be a
physical hazard and suspect source area for contamination, which, if present, could enter the
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Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
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May 2001
Final
environment. A decision was therefore made to dismantle the facility. During the summer of 1993, the Army
removed the building, all of the equipment associated with the Wind Tunnel, and the scrubber system, including the
stack. The structures and equipment associated with the Wind Tunnel were disassembled, cut into smaller pieces,
and placed in wooden boxes. The air inside the crates was sampled, and no CWM was detected. Holes in the
building slab were sealed with concrete.
Based on the air sampling results, the crates were classified as "3X " This is the designation for items that have been
potentially exposed to CWM and have been surface decontaminated, if required, by locally approved procedures;
and then bagged or contained. This classification also means that appropriate tests or monitoring have verified that
no vapor concentrations are above U.S. Army specified detection limits. The material was then transported to the
Edgewood Area of APG, thermally treated at the decontamination/detoxification facility to "5X," which is the
designation that indicates the material is clean and may be released from government control without precautions
or restrictions. The treated material was then recycled.
In August 1995, the 250-gallon UST was removed from the Wind Tunnel Site. Liquid remaining in the UST was
analyzed for CWM, which was not detected. The liquid was then pumped out of the tank prior to the initiation of
the UST excavation activities. No holes were observed in the tank. Soil samples collected during the removal
showed no visual contamination, and no ethylene glycol was detected during laboratory analyses. The tank was
cleaned, cut up, and recycled as scrap metal. The excavated area was filled with gravel, and the excavated soil was
spread on the surface of the site as a means of disposal, as approved by MDE.
2.6.3 Removal Action at the Service Area on Graces Quarters
The Quonset hut at the Service Area (Site 8, Cluster 3, EAGQ03-A) was dismantled in 1993 to safely remove
ventilation equipment that was believed to be a potential source of CWM contamination. The Quonset hut was cut
up, and pieces of the hut and material from inside the hut were placed in wooden crates lined with plastic. After a
minimum of 4 hours at 70 degrees Fahrenheit (°F), the headspace of each wooden crate was sampled for CWM;
none was detected. Based on these results, the crates were classified as "3X " The material was then transported
to the Edgewood Area, thermally treated at the decontamination/detoxification facility to "5X," and recycled
through the Army's Defense Reutilization and Marketing Office. A real-time air monitoring platform was used to
collect air samples in the vicinity of the hut, and test for the possible presence of chemical agents both before and
during the removal actions. No elevated readings were obtained.
In addition to dismantling the Quonset hut, APG also removed and closed two USTs from this site in 1995. These
two USTs consisted of a 250-gallon tank that contained a gasoline-water mixture and a 1,000-gallon diesel fuel
tank, which were located next to the Quonset hut pad. The contents of the USTs were sampled and tested for
chemical agents, which were not detected. The tank contents were then pumped out, and either disposed of or
recycled. The two USTs were excavated and removed in May 1995. After the tanks were brought to the ground
surface, they were cleaned and transported off-post to be punctured and removed from future use. The tanks
appeared to be in good condition, with no obvious leaks or holes.
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Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
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Final
After removal of the 250-gallon UST, soil was excavated until no staining was observed. Soil samples were
collected from the bottom and sidewalls of the excavation, and from the excavated soil. The analytical results
indicated that the concentrations of total petroleum hydrocarbons (TPH) in the post-excavation and stockpiled soil
were below the cleanup criteria of 100 ppm. Based on these results, no further action was necessary, and the
stockpiled soil was backfilled into the excavation.
After removal of the 1,000-gallon UST, soil was excavated until no further staining was observed, and until TPH
levels in post-excavation soil samples collected from the bottom and sidewalls of the pit were reduced below 100
ppm. The excavation was stabilized, and a pond was established at the site. This work was conducted in
conjunction with APG's Natural Resources personnel to enhance the natural wildlife habitat at Graces Quarters.
Composite samples collected from the stockpiled soil exceeded the 100-ppm limit for TPH. Therefore, the
excavated soil was manifested and transported for treatment at a permitted off-post incinerator.
2.6.4 Removal Action at the Disposal Area on Graces Quarters
BetweenFebruary 1993 and April 1994, removal actions were undertaken to mitigate the environmental and health
hazards presented by debris buried in disposal pits and surrounding area as at the Graces Quarters Disposal Area
(Site 1, Cluster 1, EAGQ01-A). Because of rapid shoreline erosion in the immediate vicinity of the pits, at least
one pit eroded in the 1960s, exposing wastes to the Gunpowder River. The removal actions were designed to
remove the contents of the remaining pits prior to their exposure to the environment.
Prior to initiating the removal actions, unexploded ordnance (UXO) surveys were conducted in the vicinity of the
suspected disposal pit areas. No UXO was found during these surveys. The locations and dimensions of four
disposal pits were then determined by ground penetrating radar and electromagnetic surveys. The four pits ranged
in size from approximately 10x20 feet to 40x50 feet, with depths between 1 and 5 feet below ground surface.
Following the identification of the four disposal pits, the pit contents were excavated by a combination of hand and
mechanical excavation (with an extended boom excavator). The debris removed from the pits included
ordnance-related items and miscellaneous debris, including 431 40-millimeter (mm) rounds, one 1,000-pound GB
bomblet shell (empty casing), one nonexplosive rocket, metallic and other debris, and white wax-like material.
Three of the 40-mm rounds were determined to be unstable and highly explosive, and not to contain liquid. These
ordnance items were detonated onsite in accordance with Army protocols. The remaining rounds, which were either
stable or dummy rounds, were disposed of at the Edgewood Peninsula in accordance with established U.S. Army
protocols.
The other debris and non-explosive items were placed in wooden crates sealed with a plastic cover or in steel
drums. CWM headspace monitoring was then performed for each of the crates and drums. All of the crates and
drums exhibited negative results for CWM, and were classified as "3X". The crates were transported to the
decontamination/detoxification facility at the Edgewood Area for thermal treatment to "5X" and disposal. The
drums were transported to a permitted offsite disposal facility in accordance with applicable regulations.
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Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
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May 2001
Final
Following the removal of the pit contents, post-excavation composite soil samples were collected from the bottom
and sidewalls of each pit and from the stockpiled soil excavated from each pit. No CWM or CWM degradation
products were detected in any of these samples. With the exception of beryllium, none of the parameters detected
in the post-excavation composite soil samples collected from the bottom and sidewalls of the disposal pits exceeded
hazardous waste criteria defined in RCRA corrective action standards. While beryllium concentrations in some
samples exceeded these criteria, the beryllium was concluded to be naturally occurring. The stockpiled soil from
three of the pits was determined to be nonhazardous according to RCRA criteria, and was therefore used for site
grading purposes. The stockpiled soil from one pit contained polychlorinated biphenyls at concentrations above
these criteria, and was therefore manifested and transported to an offsite disposal facility, together with all drummed
materials.
Site closure was conducted by lining the four open pits with a geotextile material and backfilling the excavations with
clean soil. After the pits were backfilled, the site was restored by reseeding and mulching disturbed areas. Based
on the documented site history and ground penetrating radar and electromagnetic survey work conducted during
this removal action, it was concluded that no disposal pits remain at the Graces Quarters Disposal Area.
2.7 Current and Potential Future Site and Resource Uses
No military activities are currently conducted at either Carroll Island or Graces Quarters. These areas are currently
designated as natural areas.
The most conservative (highest exposure) receptor evaluated in the baseline risk assessments was a natural
resources management worker, with exposure factors the same as the standard EPA default exposure factors for
industrial workers.
The land uses that will be available as a result of the Selected Remedies are primary use as a limited-access Natural
Resource Management Area, and secondary use for military/industrial activities.
The future use of groundwater at Carroll Island is unrestricted. The groundwater at Graces Quarters is being
addressed as a separate operable unit, and is not addressed by this ROD.
2.8 Summary Of Operable Unit Risks
Initial screening and records review identified 31 sites to be included in the Carroll Island RI, and 17 sites in the
Graces Quarters RI. These sites are listed in Table 1 and Table 2, together with their Site and Cluster identification
numbers presented in the RI reports, and their Defense Sites Environmental Restoration Tracking System
(DSERTS) numbers.
Thirteen of the sites at Carroll Island were included in Operable Unit A for accelerated evaluation, due to the
likelihood that they contained CWM or hazardous substances, based on historical information, visual observations,
and geophysical surveys. As discussed below, these 13 sites have been remediated. The results of the baseline risk
assessment presented in the Carroll Island RI indicated that no unacceptable risks or hazards are associated with
any of the other 18 sites, and that no further action would be required for those individual sites. However,
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Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
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May 2001
Final
all 31 sites investigated in the Carroll Island RI were incorporated into Operable Unit B, due to the potential
presence of CWM or hazardous substances throughout Carroll Island.
Based on the results of the baseline risk assessment, the Graces Quarters RI concluded that no further action would
be required. However, all of the 17 sites were incorporated into Operable Unit B at Graces Quarters, due to the
potential presence of CWM or hazardous substances throughout Graces Quarters.
The Graces Quarters RI also recommended that additional soil samples be collected at the Test Huts (Site 12,
Cluster 1, EAGQO 1-H) to "delineate a mercury soil hot spot", and that a bioaccumulation study be conducted
at this site to assess the potential impact of mercury in the soil on ecological receptors. These recommendations
have been implemented in a bioaccumulation study conducted by the University of Maryland, using
mercury-contaminated soil from the Northeast Test Hut at this site. In this study, the bioaccumulation of both total
mercury and methyl mercury were investigated in a series of experiments on earthworms exposed to the
mercury-contaminated soil. The daily doses of total and methyl mercury ingested by robins and shrews consuming
these earthworms were then calculated and compared to risk assessment derived values. The study concluded that
the small area of mercury-contaminated soil at Site 12 would not have adverse ecological impacts, and that no
further action is required at this site.
RI activities consisted of historical searches, wetlands delineation, ecological investigations, well installations,
geophysical and soil gas surveys, environmental sampling, and archeological surveys. An explosive ordnance survey
was conducted along portions of the boundaries of Carroll Island and Graces Quarters in April 1997. As discussed
previously, two operable units were developed for both Carroll Island and Graces Quarters as a result of the
investigations.
Operable Units B were developed based on the knowledge of Carroll Island and Graces Quarters through the RI
process and known historical uses of the areas. Since the time environmental restoration activities were started by
the Army in 1977, many surface and subsurface disposal areas containing CWM and hazardous substances have
been found through investigations and visual observations. Even though thorough environmental investigations have
been conducted, some wastes associated with testing and support activities from past activities may not have been
located or identified. Many disposal areas that were not originally reported have been found by visual observation
or magnetometry, or both. However, Carroll Island and Graces Quarters contain highly vegetated areas, such as
wetlands, that can hide or cover surface or subsurface disposal areas from both visual or magnetometry detection.
In some cases, wastes that had not previously been identified were observed after they became exposed as a result
of shoreline erosion or frost heaving.
CWM, hazardous substances and UXO have also been discovered during fieldwork as a result of clearing areas
of UXO to conduct RI activities. During the RI fieldwork conducted at Carroll Island, two 40-millimeter high
explosives rounds were uncovered near the Lower Island Disposal Area. Fieldwork conducted at Graces Quarters
uncovered 2.36-inch rockets at the Primary Test Area, and 4.2-inch mortar rounds were found on the beach area
adjacent to the Northern and Southern Perimeter Dumps. In addition, ordnance wastes that potentially contain
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Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 22 of 49
May 2001
Final
CWM and explosive substances have been identified during the removal actions performed at the Operable Unit
A disposal pits on Carroll Island. Most of the wastes recovered from these pits consists of non-hazardous military
testing equipment such as metal, glass, and plastic vessels and components; non-hazardous construction rubble such
as building debris and pieces of concrete; and non-hazardous soil. Approximately 50 glass and steel containers filled
with unknown liquids were also removed from the pits, and transported to the Chemical Transfer Facility at APG
to test for the possible presence of chemical agents. In addition to these wastes, over 1,200 intact ordnance items
and 15,000 ordnance components were recovered from the pits. Approximately 40 percent of these ordnance
items and components are estimated to potentially contain chemical agents or their residues. Because these
ordnance wastes and disposal sites have been found during these other activities, it is likely that CWM, hazardous
substances and UXO are present at other areas on Carroll Island and Graces Quarters.
Risk assessments are usually performed on sites that contain measurable levels of contaminants in environmental
media such as soil or groundwater. Using concentrations of contaminants, an estimated risk to human health and
the environment can be quantified. Because this ROD is addressing contamination that may potentially exist but has
not been identified, a quantitative risk assessment could not be performed. However, there are known side effects
of the contaminants that may be present. Based on the historical uses of Carroll Island and Graces. Quarters, the
principal categories of contaminants that could be present include CWM, explosives, and associated degradation
products. In addition, other contaminants that could potentially be present include volatile organic compounds,
semivolatile organic compounds, pesticides/polychlorinated biphenyls, and inorganics.
CWM may cause a variety of toxic effects and even fatality (if large enough dose) when either inhaled, absorbed
through the skin, or ingested with contaminated food or water. These effects may include breathing difficulty,
convulsions, vision difficulties, and eye and skin blisters. Explosives, in addition to posing explosion hazards at high
concentrations, may cause health effects at lower concentrations including irritated eyes, skin, throat, and lungs; liver
and kidney damage; nerve damage; and convulsions. The other categories of contaminants listed above can also
have a wide range of potential health effects, depending on the specific types and concentrations of contaminants
that might be present.
Given current land use and the fact that the wastes have not been identified, there are no known complete exposure
pathways. In addition, there are several mitigating factors that may reduce the potential risks posed by any CWM
or hazardous substances present at Carroll Island and Graces Quarters. In the case of Carroll Island, a substantial
amount of the CWM and hazardous substances buried in this area have already been removed as a result of the
recent excavation activities conducted at the Operable Unit A disposal pits. In addition, any CWM entering the
environment due to leakage from munitions at Carroll Island or Graces Quarters would be subject to hydrolysis
reactions, which are generally effective in degrading most chemical agents and reducing the hazards that they pose.
However, some of the byproducts of these hydrolysis reactions may also be toxic. It should also be noted that the
CWM and hazardous substances present at Carroll Island and Graces Quarters have been there for several
decades, as a result of the testing, dumping, and burial activities that occurred approximately 30 to 50 years ago.
While some shoreline erosion has continued to occur since that time, no noticeable permanent damage
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Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
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May 2001
Final
to the Chesapeake Bay or other ecological resources has been observed. Therefore, the potential for significant
future harm to human health or the environment due to possible exposure to CWM or hazardous substances
appears to be low.
Because some CWM and hazardous substances are still likely to be present at Carroll Island and Graces Quarters,
the potential for future exposure to receptors remains a concern unless appropriate remedial actions are taken. If
exposure occurred, potential human receptors might include outdoor maintenance workers, security workers,
construction/excavation workers, nearby off-site residents, nearshore fishermen, consumers of fish caught near
Carroll Island or Graces Quarters, hunters and trappers, consumers of game from these areas, nearshore
swimmers, and trespassers or visitors. Potential receptors could be exposed to contamination via incidental
ingestion or direct dermal contact with soil, surface water, sediment, or exposed wastes. In addition, the rupture
of chemical containers could also result in chemical releases to the air and thus expose potential receptors via
inhalation. Actual or threatened releases of hazardous substances from this site, if not addressed by appropriate
remedial measures, may therefore present a current or potential threat to public health or the environment.
All of the CWM and hazardous substances in metal containers that remain at Carroll Island and Graces Quarters
will eventually be released to environmental media. The release of chemical material to subsurface soil while the
material is buried would not pose a substantial threat to human health and the environment, because the lethal
chemical warfare agents are not persistent when dissolved in water, and will therefore not migrate to groundwater
or the air.
The greatest threat from CWM and hazardous substances is associated with releases that may occur as future
erosion exposes containers on beaches. As items containing chemicals are exposed by beach erosion, the physical
processes of erosion and wave action can cause corroded items to leak, releasing chemicals to beach sediments
and water, and to the air if the chemicals are volatile. Even items that corroded and leaked while buried can be a
threat when exposed by beach erosion, because chemicals that are persistent (i.e., CS, BZ, etc.) will remain in the
containers and the immediately surrounding soil for long periods of time. Those containers with chemical contents
that do not immediately leak when exposed by beach erosion and wave action may remain on the beach and release
their contents at a later time due to accelerated corrosion and continued exposure to wave action. These items are
also a substantial threat to human health if handled by trespassers or untrained workers, because of toxic and
explosive chemicals. Chemical containers exposed on a beach also may be transported and eventually be under
water adjacent to shoreline areas. These items will eventually release their chemical contents to the sediment and/or
water. These underwater releases are a lesser threat to human health, but still a substantial threat to ecological
receptors.
The principal threats associated with leakage of CWM and hazardous substances from items on beaches and in
adjacent shallow waters are primarily acute rather than chronic in nature. Many of the chemicals possibly present
in containers are highly toxic, and can result in severe injury or death to humans who are exposed even briefly.
These chemicals are also an acute threat to aquatic life in the immediate vicinity of the release.
The threats associated with a single release incident will normally be short term in nature, because many of the
chemicals are not persistent in water or open air, and because of mixing and dilution in surface water. The time
period
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 24 of 49
May 2001
Final
during which the acute hazard to human and ecological receptors will exist is dependant on the specific chemicals
involved and also the temperature and environmental conditions at the time of release. The time period of greatest
threat could range from only a few hours for volatile chemicals in hot and windy conditions, to several weeks for
less volatile chemicals in cold winter conditions.
Standard remedial investigation and risk assessment techniques (i.e., using chemical concentration data from one
or two sampling events) cannot effectively assess risk to future human and ecological receptors from the CWM and
hazardous substances. This is because many of the chemicals are not persistent, do not leave detectable residues
in the sediment, and because the threats from individual release events are short-term in nature. Because there has
been no long-term, continuous monitoring of Carroll Island and Graces Quarters with frequent inspections and
sampling, it is also difficult to assess the risk posed to receptors in the past. It is only possible to state that there
have been no documented events of exposure to humans that have resulted in serious injury or death.
2.9 Remedial Action Objectives
Cleanup objectives were determined based on a review of available data, the remedial action objectives (RAOs),
and all applicable or relevant and appropriate requirements (ARARs). Cleanup objectives consist of
medium-specific goals for protecting human health and the environment. These objectives can be achieved by
reducing exposure (e.g., capping an area or limiting access) as well as by reducing the level of constituents of
concern.
CWM and hazardous substances at Carroll Island and Graces Quarters present a risk to human health and the
environment. UXO that exists from the testing and impact areas also presents a safety hazard to human health.
Quantitative cleanup objectives are not appropriate for the Operable Units B because of the lack of discernable
chemical contamination; therefore, qualitative cleanup objectives were developed. The RAOs for addressing CWM
and hazardous substances at Carroll Island and Graces Quarters are to:
reduce the potential for direct human contact with CWM and hazardous substances, and
reduce the potential for exposure of human and ecological receptors by reducing the likelihood of CWM
and hazardous substance releases to air and surface water.
2.10 Description of Alternatives
Three remedial alternatives were developed and evaluated using the criteria of the NCP. The alternatives and the
categories of response for each are:
Alternative 1: No Action
Required by NCP for comparison purposes.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 25 of 49
May 2001
Final
Alternative 2: Public Access Controls with Land Use Restrictions
Land use restriction with primary use as a limited-access Natural Resource Management Area, and
secondary use for military/industrial activities,
Access Restrictions,
Site inspections and disposal of CWM and hazardous substances identified by site inspections.
Alternative 3: Public Access Controls, Land Use Restrictions, and Erosion Controls
Land use restriction with primary use as a limited-access Natural Resource Management Area, and
secondary use for military/industrial activities,
Access Restrictions,
Site inspections and disposal of CWM and hazardous substances identified by site inspections, and
• Erosion controls.
Because all alternatives will allow hazardous substances, pollutants or contaminants to remain on site, remedy
reviews will be performed every five years, as required by the NCP.
2.10.1 Land Use Controls and Access Restrictions
The land use restrictions and access controls under Alternatives 2 and 3 would be similar, with restriction to primary
use as a limited-access Natural Resource Management Area, and secondary use for military/industrial activities.
Appropriate access controls would include warning signs, and land and water patrols. Site inspections would be
conducted to identify any hazardous military materials that are exposed by natural processes.
The land use controls (LUCs) for the selected remedy for Operable Units B at Carroll Island and Graces Quarters
will be implemented under detailed plans designed to assure long-term effectiveness and reliability. A Land Use
Control Assurance Plan (LUCAP) will be prepared by APG. The LUCAP will specify the procedures that will be
employed to assure LUCs remain effective over the long-term for all areas at APG where they may be required.1
A Land Use Control Implementation Plan (LUCIP) will also be prepared for the selected remedy for Carroll Island
and Graces Quarters, and will be an addendum to the LUCAP. The LUCIP will identify the specific LUC
objectives, and will list the specific actions required to achieve each identified objective (e.g., post warning signs).
1 Because of its procedural nature, there will be only one LUCAP for APG. Additional LUCIPs may be appended to the LUCAP for
implementation of LUCs at other CERCLA Operable Units.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 26 of 49
May 2001
Final
2.10.2 Erosion Controls
The RI/FS work has determined that much of the shoreline of Carroll Island and portions of the Graces Quarters
shoreline have experienced substantial shoreline erosion during the last 150 years, and certain areas have been
subject to high erosion during the last 25 years. Most of the erosion in recent years has been on the south- and
southeast-facing shorelines of the eastern portion of Carroll Island and Graces Quarters. These areas are subject
to erosion as a result of a high energy wave environment caused by a substantial open-water fetch from the south
and historic prevailing winds from that direction. The eastern portions of the Carroll Island and Graces Quarters
are also the location of the impact and test areas that are most likely to have CWM and hazardous substances.
In the FS Addendum, three erosion control technologies were concluded to be potentially applicable to various
portions of the Carroll Island and Graces Quarters shorelines. These technologies included: wetlands development,
which is effective in areas with low wave energy; offshore breakwaters, which are effective in areas with low to
moderate wave energy; and shoreline revetments, which are effective for wave energies ranging from low to high.
Detailed analysis of environmental conditions along the Carroll Island and Graces Quarters shorelines indicated that
wetlands development is not applicable to the Carroll Island shoreline, due to relatively high wave energies or the
presence of high quality submerged aquatic vegetation (S AV), which would be destroyed by creating new wetlands.
Offshore breakwaters and shoreline revetments are applicable to different portions of the Carroll Island shoreline.
Wetlands development is applicable to the portion of the Graces Quarters shoreline identified for erosion control,
due to low wave energies and the absence of valuable SAV.
The approximate shoreline areas to be stabilized are shown in Figure 4 and Figure 5. Alternative 3 will reduce
potential risk associated with CWM and hazardous substances, will prevent additional loss of land due to erosion,
and will preserve natural resources in the vicinity of Carroll Island and Graces Quarters, including valuable upper
bay habitat. The environmental control measures selected for each portion of the shoreline will be designed to
provide adequate protection against a 50-year storm event while minimizing any adverse impacts to SAV, fish or
wildlife habitats, or other environmental resources. The actual technology to be used will be selected in the design
phase of the remediation process.
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Figure 5 Graces Quarters - Proposed Shoreline Erosion Control
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 29 of 49
May 2001
Final
2.11 Comparative Analysis of Alternatives
In evaluating the remedial alternatives for Operable Unit B, the potential performance of each alternative is
evaluated in terms of the nine evaluation criteria required by the NCP:
• protection of human health and the environment;
• compliance with ARARs;
• long-term effectiveness;
• reduction of toxicity, mobility, and volume of contaminants through treatment;
• short-term effectiveness;
• implementability;
• cost;
• state acceptance; and
• community acceptance.
The nine criteria are categorized into one of three groups: threshold criteria, primary balancing criteria, or modifying
criteria. The alternative selected must satisfy the threshold criteria, which are of primary importance. The primary
balancing criteria are used to weigh the major tradeoffs among the alternatives, and the modifying criteria are
considered after the public has commented on the Proposed Plan.
2.11.1 Overall Protection of Human Health and the Environment
Of the three alternatives, Alternative 1 (No Action) does not achieve adequate protection of human health and the
environment. Therefore, Alternative 1 is not considered further in this evaluation.
Alternative 2 (Public Access Controls with Land Use Restrictions) provides for protection of human health and is
partially protective of the environment. Protection of human health for land areas is achieved through land use
controls that restrict access and future land uses that are not compatible with the continued presence of CWM and
hazardous substances. Protection of human health for shoreline and adjacent water areas is achieved by shoreline
inspections that are conducted periodically and immediately following storm events (e.g., same day or first daylight
hours of next day) to identify chemical releases and initiate response actions to immediately restrict access and
remediate the site. In those instances where the exposed item has not leaked, this remedial alternative would also
protect ecological receptors. In instances where there has
Threshold Criteria
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 30 of 49
May 2001
Final
already been leakage of chemicals to water and shoreline sediments, this alternative would not fully protect
ecological receptors.
Alternative 3 (Public Access Controls, Land Use Restrictions, and Erosion Controls) provides the highest level of
protection of human health and the environment, because of the additional protection resulting from the shoreline
erosion controls. The shoreline erosion controls, which would be constructed in those areas most subject to erosion,
would prevent release of CWM and hazardous substances in these highest risk areas. Therefore, Alternative 3 is
considered most desirable with regard to overall protection of human health and the environment, followed by
Alternative 2.
2.11.2 Compliance with Applicable or Relevant and Appropriate Requirements
Chemical-specific, location-specific and action-specific ARARs for this operable unit are listed in Tables 3 through
5. Alternative 2 may not fully comply with chemical-specific ARARs because releases are not prevented, but rather
remediated to the extent possible after the release. Alternative 3 would comply with chemical-specific ARARs by
preventing shoreline releases, and would also comply with location-specific and action-specific ARARs.
2.11.3 Long-Term Effectiveness and Permanence
Alternative 2 is dependant on land use controls, including access controls, to ensure long-term effectiveness. The
long-term effectiveness along eroding shorelines is also dependant on the effectiveness of the shoreline inspections.
Alternative 2 will only have long-term effectiveness and permanence if the shoreline inspections can identify items
for emergency removal prior to release of chemical contents to the air, water and sediment. Any future releases of
wastes and materials on shorelines that impact the environment or result in exposures to workers or the public will
be evidence that the remedy is not effective. This would likely trigger a review of the ROD, and eventual
implementation of additional remedial measures. The likelihood of such future releases and exposures is uncertain.
While the recently completed remediation of Carroll Island Operable Unit A disposal areas and the earlier removal
actions at Graces Quarters have substantially reduced risk, there are likely other small undiscovered dump and
burial sites that pose future risk. Because of the uncertainty associated with the likelihood of future shoreline
chemical releases, the long-term effectiveness and permanence of Alternative 2 is uncertain.
Alternative 3 is also dependant on land use controls, including access controls, to ensure long-term effectiveness.
Alternative 3 provides long-term effectiveness and permanence in preventing shoreline releases through shoreline
erosion controls in areas most subject to erosion. The long-term maintenance of the shoreline erosion control
measures will provide for effectiveness and permanence.
Primary Balancing Criteria
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 31 of 49
2.11.4 Reduction of Toxicity, Mobility, or Volume of Contaminants Through Treatment
Alternative 2 reduces the volume of hazardous constituents by removing detected CWM and hazardous substances
for offsite destruction, when exposed at the shoreline. However, some of these exposed wastes may migrate
offshore or release chemicals prior to identification
Table 3
Potential Chemical-Specific Applicable or Relevant and Appropriate Requirements
for Remedial Actions at Carroll Island and Graces Quarters
Aberdeen Proving Ground, Maryland
Media/
Constituent
Citation
Title /
Category
Requirements Synopsis
Comments
Toxic
Substances in
Surface
Water
40 CFR 131
COMAR
26.08.02
Clean Water
Act, MD
Water
Pollution
Regulations -
Surface Water
Quality
Criteria
Specifies criteria for quality of
surface water to protect human
health and maintain suitability for
designated uses (aquatic habitat,
recreation, ect.). Establishes anti-
degradation policy for water quality.
Applicable to any
releases of CWM or
hazardous substances
to surface water.
Table 4
Potential Location-Specific Applicable or Relevant and Appropriate Requirements
for Remedial Actions at Carroll Island and Graces Quarters
Aberdeen Proving Ground, Maryland
Feature /
Location
Citation
Title /
Category
Requirement Synopsis
Comments
Within
floodplain or
wetlands
Protection of
floodplains (40
CFR 6, Appendix
A); Fish and
Wildlife
Coordination Act
(16 USC 661 et
seq.V 40 CFR
6.302; Floodplains
Executive Order
(EO 11988);
Wetlands
Executive Order
(EO 11990)
COMAR 26.23
COMAR 26.24
Protection of
wetlands and
floodplains
Action to avoid adverse effects,
minimize potential harm, restore and
preserve natural and beneficial
values; applies to action that will
occur in a floodplain, i.e., lowlands,
and relatively flat areas adjoining
inland and coastal waters and other
flood-prone areas. For action
involving construction of facilities or
management of property in wetlands
[as defined by 40 CFR Part 6,
Appendix A, Section 40], action
must be taken to avoid adverse
effects, minimize potential harm, and
preserve and enhance wetlands, to
the extent possible.
Applicable to
construction of
shoreline erosion
controls. Also
potentially applicable
to any future actions
to recover waste
from disposal sites
that are exposed by
shoreline erosion.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 32 of 49
Table 4
Potential Location-Specific Applicable or Relevant and Appropriate Requirements
for Remedial Actions at Carroll Island and Graces Quarters
Aberdeen Proving Ground, Maryland
Feature /
Location
Citation
Title /
Category
Requirement Synopsis
Comments
Maryland
Critical Areas
Maryland Natural
Resources Code,
Title 8, Subtitle 18
Chesapeake
Bay Critical
Area
Protection
Program
Establishes land use policies for the
Chesapeake Bay Critical Area
including limiting impervious areas,
establishing buffers, and establishing
controls to prevent runoff of
pollutants.
Applicable to
construction of
shoreline erosion
controls. Also
potentially applicable
to any future actions
to recover waste
from disposal sites
that are exposed by
shoreline erosion.
Critical
habitat upon
which
endangered
species or
threatened
species or
threatened
species
depend
Endangered
Species Act 1973
(16 USC 1531 et
sea.); 50 CFR
402; Fish and
Wildlife
Coordination Act
(16 USC 661 et
seg ); 33 CFR
320-330, Bald
and Golden Eagle
Protection Act (16
USC 668-668d;
50 CFR 13 and
22)
Protection of
Threatened
and
Endangered
Species
If endangered or threatened species
are present, action must be taken to
conserve endangered or threatened
species, including consultation with
the Department of Interior.
The bald eagle is a
federally listed
threatened species,
and at least two nests
are located on
Carroll Island and
three nests on Graces
Quarters.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 33 of 49
Table 5
Potential Action-Specific Applicable or Relevant and Appropriate Requirements
for Remedial Actions at Carroll Island and Graces Quarters
Aberdeen Proving Ground, Maryland
Action
Citation
Title /
Category
Requirement
Synopsis
Comments
Waste
generation
from
remediation
of waste and
contaminated
media
40 CFR 261
COMAR
26.13.02
RCRA
Identification
and Listing of
Hazardous
Waste
Defines solid waste, hazardous
waste, and criteria and methods for
determining if a solid waste is a
hazardous waste. Provides listed
hazardous wastes and defines
hazardous waste characteristics.
Any waste media that
are actively managed
or shipped off site
must be tested to
determine if they are
RCRA characteristic
wastes.
Waste
generation
from
remediation
of waste and
contaminated
media
40 CFR 262
COMAR
26.13.03
RCRA
Standards
Applicable to
Generators of
Hazardous
Waste
States that generators of hazardous
wastes are responsible for
determining if wastes are hazardous
and defines storage, transportation,
and record keeping of hazardous
wastes
Substantive
requirements are
applicable to
management of any
excavated or
otherwise actively
managed hazardous
waste.
Treatment,
storage of
disposal of
waste
40 CFR 264
COMAR
26.13.05
RCRA
Standards for
Owners and
Operators of
Hazardous
Waste TSDFs
General performance standards for
TSDFs
Applicable if there is
treatment or long-
term storage of
hazardous waste
Management
of military
munitions
waste
40 CFR 266
Subpart M
Munitions
Rule - Solid
Waste Military
Munitions
Defines when a military munition is a
solid/hazardous waste, and specifies
requirements for transportation,
storage and treatment of waste
military munitions
Applicable because a
portion of wastes
removed under
Alternative 2 or as
part of construction
for Alternative 3 may
include waste
munitions.
Construction
and long-
term use of
wells or
abandonment
of existing
wells
COMAR
26.04.04
Well
Construction
Establishes a permitting process for
well construction with reporting
requirements, specifies well
construction and abandonment
standards, requires approval for well
use as a potable water supply, and
states responsibilities of well owners.
Substantive
requirements are
applicable if
construction requires
closure of any
monitoring wells.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 34 of 49
Table 5
Potential Action-Specific Applicable or Relevant and Appropriate Requirements
for Remedial Actions at Carroll Island and Graces Quarters
Aberdeen Proving Ground, Maryland
Title /
Requirement
Action
Citation
Category
Synopsis
Comments
Discharge of
40 CFR 122-125,
National
Regulates direct discharges to
Substantive
wastewater
129 COMAR
Pollutant
waters of the U.S. and specifies
requirements are
26.08.04
Discharge
Elimination
System
(NPDES)
permitting requirements
applicable to any
discharge of
decontamination
wastewater to
surface water.
Shoreline
COMAR
General Water
Establishes design and construction
Applicable to
stabilization
26.08.02.13
Quality
specifications, and requirements
construction of
Certification
related to wetland protection,
shoreline stabilization
for Placement
erosion and sediment control,
measures
of Riprap for
spawning season of important
Shore
aquatic species, and breeding areas
Protection
of migratory waterfowl.
Remedial
COMAR
Erosion and
Defines erosion and sediment
Applicable to any
excavation/
26.17.01
Sediment
control during land clearing, grading,
excavation to remove
construction
Control
or other earth disturbances
wastes and to
construction of
shoreline stabilization
measures
Remedial
COMAR
Stormwater
Defines stormwater management
Applicable to any
excavation/
26.17.02
Management
during land development activities,
excavation to remove
construction
including building and grading
wastes and to
construction of
shoreline stabilization
measures
Remedial
40 CFR 50.6 &
Control of
Prohibits the handling of materials
Applicable to any
excavation/
50.7 COMAR
Fugitive
and the use, construction, or
excavation to remove
construction
26.11.06.03
Particulate
demolition of buildings and roads
wastes and to
COMAR
Matter
without reasonable precautions to
construction of
26.11.06.08
prevent particulate matter from
becoming airborne. Requires that an
installation or premises not be
operated or maintained in such a
way that nuisance or air pollution is
created.
shoreline stabilization
measures
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 35 of 49
Table 5
Potential Action-Specific Applicable or Relevant and Appropriate Requirements
for Remedial Actions at Carroll Island and Graces Quarters
Aberdeen Proving Ground, Maryland
Title /
Requirement
Action
Citation
Category
Synopsis
Comments
Air emissions
40 CFR61
National
Establishes emissions requirements
Potentially applicable
by stationary
COMAR
Emission
for various hazardous air pollutants,
to situations involving
sources
26.11.15-16
Standards for
including certain chlorinated VOCs
release of hazardous
Hazardous Air
and radionuclides.
substances to the
Pollutants
atmosphere
Remedial
COMAR
Noise
Establishes noise standards for
Applicable to any
construction
26.02.03
Pollution
industrial, commercial and residential
excavation to remove
Control
zones.
wastes and to
construction of
shoreline stabilization
measures
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 36 of 49
and recovery, creating a threat to human health and the environment. Alternative 3 also achieves a small reduction
in the volume of hazardous constituents by removal of wastes in the shoreline construction area. The volume of
hazardous substances removed in Alternative 3 is less than in Alternative 2, because the shoreline erosion controls
will reduce the amount of these substances that will become exposed. However, Alternative 3 also reduces the
mobility of these hazardous substances by ensuring that they are not exposed along eroding shorelines causing
release to air and water. Because the reduction in mobility by Alternative 3 effectively reduces risk, while the
reduction in volume under Alternative 2 is associated with increased risk, Alternative 3 is rated higher with respect
to this criterion.
2.11.5 Short-Term Effectiveness
Alternative 2 is the most desirable alternative with respect to this criterion because there is minimal impact to
workers, and the public is protected. Alternative 3 is less desirable than Alternative 2 with respect to this criterion
because of the construction activities associated with implementing the shoreline erosion controls. UXO surveys
and related clearance activities, and other health and safety precautions such as the use of personal protective
equipment will be required in Alternative 3 to protect workers; in addition, surface water controls, soil erosion
controls, and other temporary environmental controls will be required to minimize environmental impacts due to
construction.
2.11.6 Implementability
Alternative 2 is easily implementable, because all resources required for the public access controls and for
management of the land are readily available. Alternative 3 is also not expected to be difficult to implement, but
several implementation issues need to be considered, including the length of time required to place fill material and
develop the wetlands (if selected as a technology), which is expected to be approximately two to five years, and
maintenance requirements associated with the offshore breakwater and revetments. In addition, regulatory
coordination will be required during the design of Alternative 3 to address ARARs related to construction in a
floodplain / Maryland Critical Area.
2.11.7 Cost
The total estimated present worth costs of Alternatives 2 and 3 are approximately $2,030,000 and $5,170,000,
respectively, for both Carroll Island and Graces Quarters. The estimated capital costs are $106,000 and
$3,210,000, respectively for the two alternatives. A detailed breakdown of these costs is presented in the FS
Addendum. These present worth costs are based on an operating period of 30 years and a discount factor of 7
percent.
Alternative
Capital
Cost
Present Worth of
O&M Cost
Total Present
Worth Cost
Alternative 2 - Public Access Controls with
Land Use Restrictions
$106,000
$1,924,000
$2,030,000
Alternative 3 - Public Access Controls, Land
Use Restrictions and Erosion Controls
$3,210,000
$1,960,000
$5,170,000
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 37 of 49
May 2001
Final
Although the cost of Alternative 2 can be calculated, the fact that the long-term effectiveness and permanence of
Alternative 2 is uncertain raises the possibility that additional remedial actions may be required in the future. A future
decision to implement additional remedial actions would be accomplished through a remedy review that could be
either within the 5-year cycle for such reviews, or could be triggered by a chemical release that would indicate that
land use controls and shoreline inspections alone (Alternative 2) are not effective. If the remedy review was
triggered by a chemical release, there may be community and political pressure to implement a remedy that is even
more aggressive than shoreline erosion controls, with substantially higher costs.
There is much less uncertainty associated with the cost for Alternative 3, because of the long-term effectiveness and
permanence of this remedy. Considering uncertainties, it is possible that Alternative 3 is also the alternative with the
lowest long-term cost.
2.11.8 State Acceptance
The Maryland Department of the Environment (MDE), Waste Management Administration, concurs with the
selection of Alternative 3 for Carroll Island and Graces Quarters.
2.11.9 Community Acceptance
The community prefers and has accepted Alternative 3 during the public comment period.
2.12 Principal Threat Waste
Any lethal chemical agents that possibly exist at Carroll Island and Graces Quarters in containers are considered
to be principal threat waste because of their high toxicity.
Site inspections and geophysical techniques have been employed in suspect areas to identify wastes, and all such
materials have already been remediated. It is still possible that CWM materials exist but could not be found using
existing technology. Nevertheless, there are no additional positively-identified areas that contain CWM or
hazardous substances on Carroll Island and Graces Quarters.
Any principal threat waste that is discovered by site inspections or other activities at Carroll Island or Graces
Quarters will be destroyed or removed for disposal by the U.S. Army using existing emergency response
procedures that are protective of human health and the environment. The selected remedy will minimize the
likelihood that principal threat waste will be released to the air or surface water.
2.13 The Selected Remedies
Modifying Criteria
An evaluation of potential alternatives was performed in accordance with the NCP as summarized in Section 2.11.
Based on this evaluation, the selected alternative for Operable Units B at Carroll Island and Graces
Quarters is Alternative 3, "Public Access Controls, Land
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 38 of 49
Use Restrictions, And Erosion Controls," with a total cost of $5,170,000. The selected alternative for the other sites
listed in Tables 1 and 2 is "No Further Action".
These selected remedies are protective of both human health and the environment, effective in meeting RAOs, and
permanent solutions. All of the selected remedies will comply with ARARs and will not pose short-term risks to
remedial workers, the community, or the environment. The selected remedies are easily implemented with relatively
low cost. In addition, the remedies meet State and Federal regulatory requirements and are accepted by the
community.
The selected remedies were chosen over other alternatives, because they represent the solutions that best satisfy
the nine criteria specified by EPA to be considered in remedy selection.
The specific LUC objectives for the Carroll Island and Graces Quarters Operable Units B remedy are:
Restrict future land usage to either military/industrial activities or a limited-access natural resource management
area.
Restrict public access to Carroll Island and Graces Quarters by employing reasonable measures to prevent
inadvertent exposure of individuals to CWM, hazardous substances and UXO.
The current land use designation for Carroll Island and Graces Quarters in the APG Master Plan is open space.
The future land use designation will be primary use as a limited-access natural resource management area, and
secondary use for military/industrial activity. APG will continue to be responsible for natural resource management
activities at Carroll Island and Graces Quarters.
The baseline risk assessment did not identify any unacceptable risks to current or hypothetical future receptors from
exposure to constituents in environmental media at Carroll Island or Graces Quarters. The most conservative
(highest exposure) receptor evaluated in the baseline risk assessment was a natural resources management worker,
with exposure factors the same as the standard EPA default exposure factors for industrial workers.
2.14 Performance Standards
The erosion control measures will be constructed along the shoreline areas most subject to erosion, with roughly
three miles of shoreline being protected (Figures 4 and 5). The specific measures to be implemented for erosion
control will be determined in the design phase of the remediation process. The measures selected for various
shoreline areas will be designed to provide adequate protection against a 50-year storm event, while minimizing any
adverse impacts to habitat and other environmental resources.
The land use control objectives are:
restrict future land use to primary use as a limited-access Natural Resource Management Area, and secondary
use for military/industrial activities;
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 39 of 49
May 2001
Final
restrict unauthorized access;
prohibit future land use that is incompatible with and would disrupt the effectiveness of the
engineered/constructed shoreline erosion controls.
Unauthorized access to Carroll Island and Graces Quarters will continue to be controlled by signs, chain link fences
with locked gates, random security patrols and other physical measures. Signs along the fence and shoreline areas
will also be maintained to inform boaters of potential hazards present on beaches and land.
Future land use will be controlled by designating in the APG Master Plan the future use for Carroll Island and
Graces Quarters as natural resource management and military/industrial usage. Any proposed changes in land
usage, or proposed activities that would disrupt the effectiveness of the engineered shoreline erosion controls, will
be reviewed by APG DSHE. APG will notify EPA Region m and MDE of planned changes in land use for Carroll
Island and Graces Quarters. APG will also notify EPA and MDE in the event that the transfer by sale or lease is
contemplated for any portion of Carroll Island and Graces Quarters.
APG will develop a LUCAP that specifies the procedures for implementing land use controls at APG sites for
which a ROD has been signed. APG will also develop a LUCIP for Carroll Island and Grace Quarters. The
LUCIP will specify land use control procedures and access control measures to be implemented at this site. In
addition, the LUCAP/LUCIP will specify the frequency of inspections of Carroll Island and Graces to verify no
significant change in land use and the frequency of certification of the compliance with LUCs specified in this ROD.
The frequency of and procedures for conducting shoreline inspections at Carroll Island and Graces Quarters will
also be specified in the LUCIP. These shoreline inspections will be initiated following completion of the LUCIP,
and prior to the construction of the shoreline erosion control measures. The LUCIP will also specify the reduced
frequency of inspections that will be performed after the construction of the shoreline erosion controls.
2.15 Statutory Determinations
Based on the findings of the RI, the Carroll Island and Graces Quarters Operable Units B pose risk to human
health. Therefore, a determination has been made that public access controls, land use restrictions, and erosion
controls are appropriate and protective of human health.
Based on the findings of the RI, and on accomplishment of removal actions to remove possible sources of
hazardous materials, the other Carroll Island and Graces Quarters sites listed in Tables 1 and 2 pose no further risk
to human health or the environment. Therefore, no further action is necessary for these sites.
The selected remedies are protective of human health, comply with Federal and State of Maryland requirements
that are legally applicable or relevant and appropriate to the remedial action, and are cost effective.
The selected remedies are permanent solutions and satisfy, to the extent practicable, the statutory preference for
reduction of toxicity, mobility, and volume of contamination through treatment.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 40 of 49
May 2001
Final
Section 300.430(f)(4)(ii) of the NCP requires that a 5-year review of the ROD be performed if hazardous
substances, pollutants, or contaminants remain at the unit. The three parties, Department of the Army, MDE and
EPA, have determined that a 5-year review of the ROD for the Carroll Island and Graces Quarters Operable Units
B will be performed to ensure continued protection of human health.
2.16 Explanation Of Significant Changes
The original proposed plan for remediation at Carroll Island and Graces Quarters Operable Units B was released
for public comment in July 1998, with land use controls identified as the preferred alternative. The public expressed
concerns about shoreline erosion exposing CWM and hazardous substances on beaches. In response, APG
reevaluated possible remedial alternatives, and in April 2000 released a second proposed plan with a new preferred
remedy consisting of LUCs and shoreline erosion controls. There have been no significant changes to this preferred
remedy since the second proposed plan was presented. Additional background information on community
involvement in this decision process is presented in the responsiveness summary.
AEHA, 1989. RCRA Facility Assessment Report, Edgewood Area, Aberdeen Proving Ground, Maryland.
Report No. 39-26-0490-90. US Army Environmental Hygiene Agency, Aberdeen Proving Ground,
Maryland. December 1989.
APG and EPA, 1990. Federal Facility Agreement, Aberdeen Proving Ground, Maryland. Administrative
Docket Number IH-FCA-CERC-004. United States Environmental Protection Agency Region m and the
United States Department of the Army. 27 March 1990.
APG, 1996. Record of Decision, Operable Unit A, Carroll Island, Aberdeen Proving Ground, Maryland.
Directorate of Safety, Health and Environment, Aberdeen Proving Ground, Maryland. September 1996.
APG, 1998. Decision Document, Removal Action of a Sump Associated with the Former Service Area at
Carroll Island. Environmental Conservation and Restoration Division, Directorate of Safety, Health and
Environment, Aberdeen Proving Ground, Maryland. October 1998.
3 RESPONSIVENESS SUMMARY
The Responsiveness Summary is provided as Appendix A of this document.
4 REFERENCES
Dames & Moore, 1997. Remedial Investigation Report, Carroll Island, Aberdeen Proving Ground,
Maryland. Dames & Moore, Bethesda, Maryland. October 1997.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 41 of 49
Dames & Moore, 1998. Remedial Investigation Report, Graces Quarters, Aberdeen Proving Ground,
Maryland. Dames & Moore, Bethesda, Maryland. January 1998.
Dames & Moore, 1999a. Combined Feasibility Study Addendum, Carroll Island and Graces Quarters,
Aberdeen Proving Ground, Maryland. Dames & Moore, Bethesda, Maryland. November 1999.
Dames & Moore, 1999b. Proposed Plan for Operable Units B: CWM and Other Hazardous Substances and
for Removal Actions at the Service Area and the Wind Tunnel at Carroll Island and the Service Area
and Disposal Area at Graces Quarters, Aberdeen Proving Ground, Maryland. Dames & Moore,
Bethesda, Maryland. November 1999.
GP, 1997. Carroll Island and Graces Quarters Boundary Survey, Technical Report. General Physics
Corporation, Edgewood, Maryland. November 1997.
GP, 1998. Carroll Island and Graces Quarters Boundary Survey, Technical Report for Subsurface Magnetic
Anomaly Survey and Hazard Assessment. General Physics Corporation, Edgewood, Maryland.
December 1998.
ICF, 1998. Community Relations Plan for Installation Restoration Program, U.S. Army Garrison, Aberdeen
Proving Ground. Updated by ICF Kaiser Engineers, Edgewood, Maryland. May 1998.
ORISE, 1998a. Combined Feasibility Study Report, Carroll Island and Graces Quarters. Oak Ridge Institute
of Science and Education, Oak Ridge, Tennessee. July 1998.
ORISE, 1998b. Proposed Planfor Operable UnitB, CWM and Other Hazardous Substances Including UXO,
Carroll Island and Graces Quarters. Oak Ridge Institute of Science and Education, Oak Ridge,
Tennessee. July 1998.
USGS, 1991. Hydrogeologic Data for Carroll Island, Aberdeen Proving Ground, Maryland, Open File
Report 89-388. United States Geological Survey, Towson, Maryland.
USGS, 1996. Hydrogeology and Chemical Quality of Water and Soil at Carroll Island, Aberdeen Proving
Ground, Maryland. United States Geological Survey, Towson, Maryland.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 42 of 49
May 2001
Final
APPENDIX A
CARROLL ISLAND AND GRACES QUARTERS
OPERABLE UNITS B
PROPOSED PLAN
RESPONSIVENESS SUMMARY
The final component of the Record of Decision is the Responsiveness Summary. The purpose of the
Responsiveness Summary is to provide a summary of the public's comments, concerns, and questions about Carroll
Island and Graces Quarters (Operable Units B) and the Army's responses to these concerns.
APG held a public meeting on May 11,2000 to formally present the Proposed Plan and to answer questions and
receive comments. The transcript of this meeting is part of the administrative record for the site. During the public
comment period, APG also received written comments. All comments and concerns summarized below have been
considered by the Army and EPA in selecting the cleanup method for Carroll Island and Graces Quarters.
This responsiveness summary is divided into the following sections:
• Overview
• Background on Community Involvement
• Summary of comments received during the public comment period and APG's responses.
• Sample newspaper notice announcing the public comment period and the public meeting.
OVERVIEW
At the time of the public comment period, the Army had endorsed a preferred alternative for Carroll Island and
Graces Quarters. APG proposed restricting use of the land to a natural resource management area, with any future
Army activities to be compatible with this designation. APG also proposed additional access controls, shoreline
erosion control measures, and shoreline inspections to locate any wastes that may surface. The shoreline inspections
will initially be twice per month and after major storm events. The frequency of shoreline inspections will be reduced
after the erosion control measures are constructed. The frequency of inspections under long-term operations will
be specified by design documents. The frequency will also be adjusted in the future, depending on the findings of
the inspections, with these changes being coordinated with regulatory authorities and the community. EPA and
MDE concur with the Army's preferred alternative. The community also seems to agree with the selected
alternative.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 43 of 49
May 2001
Final
BACKGROUND ON COMMUNITY INVOLVEMENT
Citizens in Baltimore County living near APG's Carroll Island and Graces Quarters Study Areas have actively
expressed interest in the sites since the early 1990s.
APG has maintained an active public involvement and information program. Highlights of the community's
involvement in the original Proposed Plan and the revised Proposed Plan and APG's activities during the last few
years follow:
• APG began discussing the Carroll Island and Graces Quarters Study Areas and ongoing environmental
investigations with the Restoration Advisory Board in April 1995. Other Board meetings where APG presented
information on the two study areas included October 1995, May 1996, and September 1997. In January 1997,
APG discussed the Feasibility Study for Operable Units B. The Board further discussed the Feasibility Study
at the January 1998 meeting. In June 1998, APG distributed a draft Proposed Plan at the Board meeting for
members to review and provide their comments.
• In late 1997 and early 1998, APG formed a Baltimore County Citizens Committee as an additional way to
involve citizens near Carroll Island and Graces Quarters in the decision-making process. APG presented
information on the Feasibility Study at the first meeting of the Committee in February 1998 and on the tour in
June 1998.
• APG released a Proposed Plan for Carroll Island and Graces Quarters for public comment on July 22,1998.
Copies were available to the public at APG's information repositories at the Aberdeen and Edgewood
Branches of Harford County Library, and Miller Library at Washington College. A copy of the Proposed Plan
also was posted on the Installation Restoration Program's Web Site, and the public was invited to comment
through the Web Site. A 45-day public comment period on the Proposed Plan ran from July 22 to September
4, 1998. On July 29, APG held a public meeting at the Bowleys Quarters Fire Station.
• Comments received from the public on the proposed plan indicated a preference for Alternative 2, public
access controls with land use restrictions, but concerns were expressed about shoreline erosion continuing to
uncover materiel on the beaches that could migrate into the Bay. Community members were concerned about
the possible release of chemicals into the air or water. Community members were particularly concerned
because of the extensive use of the surrounding waterways for recreational purposes such as boating and
fishing. Local residents, community members of APG's Restoration Advisory Board, and the APG Superfund
Citizens Coalition requested APG re-examine alternatives for reducing shoreline erosion and thus preventing
any materials from entering surface water bodies or re-examine technologies for detecting any such buried
materials and removing them.
• In response to the concerns raised about shoreline erosion, a Feasibility Study Addendum and a new Proposed
Plan for Carroll Island and Graces Quarters were prepared.
• The new Proposed Plan was discussed at the December 1998, February 1999, July 1999, and December
1999 meetings of the Restoration Advisory Board.
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Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 44 of 49
May 2001
Final
• The new Proposed Plan for Carroll Island and Graces Quarters was released for public comment in April
2000. Copies were made available to the public at APG's repositories at the Aberdeen, Joppa and Edgewood
Branches of Harford County Library, Miller Library at Washington College, and the Cecilton Branch of the
Cecil County Library. A copy of the Proposed Plan also was posted on the Installation Restoration Program's
web site, and the public was invited to comment through the web site.
• A 45-day public comment period on the new Proposed Plan ran from April 26 to June 9, 2000.
• APG prepared a release announcing the availability of the new Proposed Plan, the dates of the public comment
period, and the date and time of the public meeting. APG placed newspaper advertisements announcing the
public comment period and meeting in The Aegis, The Avenue, The Cecil Whig, The East County Times and
The Kent County News.
• APG prepared and published a fact sheet on the Proposed Plan including information on the public meeting.
APG mailed copies of this fact sheet to over 2,700 citizens and elected officials on its Installation Restoration
Program mailing list. The fact sheet included a form which citizens could use to send APG their comments.
• On May 11, APG held a public meeting at Oliver Beach Elementary School in Chase, Maryland.
Representatives of the Army and the MDE were present. APG representatives presented information on the
site and on the proposed cleanup alternatives.
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
AGENCY RESPONSES
Comments raised during the public comment period on the Carroll Island and Graces Quarters Proposed Plan are
summarized below. The comments are categorized by source.
COMMENTS FROM QUESTIONNAIRE INCLUDED WITH FACT SHEET
As part of its fact sheet on the Proposed Plan, APG included a questionnaire that residents could return with their
comments. APG received 11 forms. The alternatives preferred by individuals returning comment forms were:
0 Alternative No. 1 - Take No Action.
1 Alternative No. 2 - Public Access Controls with Land Use Restrictions
10 Alternative No. 3 - Public Access Controls, Land Use Restrictions and Erosion Controls
0 Have no preference
Written comments included on the forms are summarized below.
Comment No. 1: [Commenter selected alternative 2] "I feel that alternative #2 would be more effective on getting
rid of any waste buried on the shoreline. With an inspection twice a month or after a major storm this would ensure
the removal of any waste surfacing. Two times a month sounds better than two times a year. Less exposure when
something does surface."
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 45 of 49
May 2001
Final
Response No. 1: Fewer inspections are needed with Alternative 3 as the shoreline erosion control and stabilization
measures reduce the possibility of waste becoming exposed. APG agrees with the need to conduct inspections
twice per month and after major storm events during the period prior to shoreline stabilization. The frequency of
inspections will be reduced after the shoreline is stabilized. The frequency will also be adjusted in the future,
depending on the findings of the inspections, with these changes being coordinated with regulatory authorities and
the community. These adjustments may either increase or decrease the frequency. It is expected that there will
always be inspections after major storm events, to verify that shoreline erosion control measures remain intact, and
to identify any wastes on shoreline areas that have not been stabilized.
Comment No. 2: [Commenter selected alternative 3] "I think it is good to have the erosion controls, but I hope
there will still be adequate inspection (twice a year seems pretty infrequent), since I would think that even with
erosion controls, materials may become exposed - especially after major storms."
Response No. 2: The shoreline erosion control measures are expected to prevent all releases in the stabilized
areas where most erosion occurs. The frequency of inspection in areas of lesser erosion that have not been
stabilized will be such that health and the environment are protected. APG does agree that even when inspection
is reduced from twice per month after shorelines stabilization is completed, that the frequency should be greater than
twice per year to ensure that the remedy is effective. Many factors will be considered when determining the
appropriate frequency for inspections. For example, inspections may be more frequent during warmer months when
there are more boaters in the waters adjacent to Carroll Island and Graces Quarters. As noted in the previous
response, it is expected that there will always be inspections after major storm events, to verify that shoreline
erosion control measures remain intact, and to identify any wastes on shoreline areas that have not been stabilized.
All of these factors will be evaluated when preparing remedy design documents where inspection frequency will
be specified.
Comment No. 3: [Commenter selected alternative 3] "While I agree with the chosen alternative, I feel that during
the first two years after completion the beach patrols should occur more than 2 times per year to ensure the erosion
controls are working properly. If erosion does occur, it would be noticed and corrected more quickly with more
frequent beach patrols."
Response No. 3: APG agrees and inspections are expected to be more often than twice per year, and will always
be conducted after major storm events.
Comment No. 4: [Commenter selected alternative 3] "Since Baltimore County is revitalizing the northeastern end
of the county so people have access to the water, I think it would be a good idea to build a fishing pier or boat ramp
at the end of Graces Quarters."
Response No. 4: APG understands the desire of the local communities to have access to the waterways for which
the proving ground is responsible. The current restrictions on use of the waterways are in place for the safety of the
waterway users and would prohibit the building of a pier or ramp at this time due to the possible presence of
ordnance in the waterways from historic testing activities. The Department of Defense, as well as the Army and
APG, are working on the
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 46 of 49
May 2001
Final
many issues involved with the safe removal of munitions including researching better detection technology and
destruction technology. Every five years there will be a remedy review at which time consideration will again be
given to remedial approaches that would allow unrestricted land use.
Comment No. 5: [Commenter selected alternative 3] "Let us not make a mistake of Love Canal in NY, where
the company was forced to give up the property; the US Government should never relinquish ownership. We do
not know what may come up to surface, considering the toxicity of material tested in the past. Maybe a better
surveillance is needed, automatic alarms, etc., etc."
Response No. 5: There are no plans at this time for the Army to relinquish ownership of the land. APGandEPA
expect the controls and inspections being put in place to adequately protect human health and the environment.
However, the remedy will be reviewed after implementation to ensure that it is providing adequate protection and
additional measures would be implemented if it were not adequate. Furthermore, there will be notification and
coordination with EPA and MDE in the future if any major change in land use or transfer of land ownership is
proposed. Additional protective measures would be implemented at that time, as necessary and appropriate.
COMMENTS AT III I MAY 11. 2000 PUBLIC MEETING
A full transcript of the public meeting is at APG's information repositories. Following is a summary of the one
comment made at the meeting.
Comment No. 6: A resident asked if the Federal Government would fund the remedial action plan.
Response No. 6: Yes. Funds for remedial actions come from the Defense Environmental Restoration Program
and will probably be available for implementing this remedial action in 2002/2003.
WRITTEN COMMENTS RECEIVED
APG received written comments from the community co-chair of the APG Restoration Advisory Board, a local
citizen, the APG Superfund Citizens Coalition, and the Maryland Department of the Environment.
Community Co-Chair. APG Restoration Advisory Board
Comment No. 7: "I agree with Alternative 3 and with the removal actions. The Proposed Plan was very thorough
and covered everything from the past to the future for the sites."
Response No. 7: APG appreciates the feedback on the plan.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 47 of 49
May 2001
Final
APG Superfund Citizens Coalition
"In general, APGSCC supports the preferred alternative for Operable Units B, which includes public access
controls, land-use restrictions and erosion controls." APGSCC submitted the following two comments.
Comment No. 8: "Mercury Contamination at the Northeast Test Hut Site. While the results of the bioaccumulation
study indicated that the risk to ecological receptors was minimal, it must be emphasized that the reason the risk was
minimal was due to the limited area of contamination. In fact, the most highly contaminated soil was removed to
provide soil for the bioaccumulation experiments. Members of the EPA Biological Technical Assistance Group
(BTAG) emphasized that if the contamination was more widespread removal would be warranted. This point was
not emphasized in this report, but should be."
Response No. 8: APG agrees with this comment.
Comment No. 9: "Remediation of Disposal Sites at Graces Quarters. While most disposal areas in the Carroll
Island Study Area were designated for accelerated action and remediated, none of the disposal areas in Graces
Quarters were designated as such, despite their upland location. Instead, most of the disposal sites were included
in the Graces Quarters Operable Unit B. While the presence of marshes would make it difficult (impossible) to
identify the location of chemical warfare material and unexploded ordnance using current technologies, presumably
magnetometry, EM and GPR could be used for the upland sites. Why was the decision made to not excavate these
Response No. 9: The disposal areas at Carroll Island were proposed for remedial action because APG's
environmental studies indicated the potential for hazardous material to be buried at these areas. At Graces Quarters,
APG excavated suspected hazardous material disposal pits through a removal action because the pits were very
close to the shoreline and continuing erosion created a potential for the pits to continue to erode into the surface
water. Environmental sampling of the remaining suspected disposal areas at Graces Quarters found no indication
of the presence of hazardous material and thus additional action is not warranted. The suspected disposal areas at
Graces Quarters were not designated disposal areas and it is less likely waste was buried at these areas than at
Carroll Island; the waste found appeared to be scattered surface debris. Additional geophysical studies would not
be able to detect non-metallic objects (such as laboratory glassware that could contain hazardous substances).
Therefore, APG is proposing the protective measures in Alternative 3 because of the possibility hazardous
substances could be present.
Local Citizen
APG received one letter commenting on the Proposed Plan. The individual did not indicate a preference for any
of the alternatives, but made the following comments:
Comment No. 10: The commenter mentioned that his family has owned land near Carroll Island for almost 60
years. "My concerns with your three alternatives are that I don't think any of them go far enough to preserve the
property. Carroll Island is an asset to the area. It abounds with deer, eagles, and other wildlife, and the waters
surrounding it flourish with fish and crabs.
sites?"
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
May 2001
Final
Page 48 of 49
However, it is rapidly eroding away - - and the changes are visible more every year. I can recall when the small
island at the mouth of the Gunpowder River was still connected to the main island. Through erosion, however, we
now have 2 separate islands. Eventually I'm sure all the land will be eroded away.
"I respect the fact that your main concern is public safety in that you want to assure that any 'wastes' are addressed
— but I feel more should be done to preserve the land itself. So here are my questions:
1. Exactly what will you receive for the $5,170,000? Will this include shoreline preservation and reconstruction?
For the entire island? Or just where 'waste' is discovered? Is the $5,170,000 a one-time expenditure - - or
would this amount be spent every year?
2. Would it be possible for you to form a partnership with another government agency (the Department of the
Interior?) that could help with funding aimed at a comprehensive land preservation project?
3. Is there any possibility that the island could some day be used as a Federal park or as a nature study preserve?"
Response No. 10: Remedial Alternative #3 includes land use restrictions, public access controls and shoreline
erosion control measures. APG will manage the land as a natural resource management area. Warning signs will
be posted along the shoreline, and additional patrols will monitor the area to deter trespassing. Visual inspections
will be performed periodically and after any significant storm event to locate any chemical warfare materiel or
unexploded ordnance that surfaces as a result of shoreline erosion. Approximately three miles of shoreline at Carroll
Island and Graces Quarters will be stabilized. The control and stabilization measures are planned for areas where
erosion is greatest and waste may have been disposed. The $5,170,000 is the total cost for implementing
Alternative #3.
Current plans are for the Army to retain ownership and to manage the land as a natural resource management area
with limited Army usage. It is possible the Army could allow limited public access for guided tours. Because there
is a potential for chemical warfare materiel to still be present, it is not likely the property could be used as a park
with unrestricted access.
Maryland Department of the Environment
The Federal Facilities Section of the Waste Management Administration provided the following comments.
Comment No. 11: "Because the preferred alternative will allow a hazardous substance to remain on site, the text
should include the provisions for five-year reviews. These five-year reviews should be associated with alternatives
2 and 3."
Response No. 11: APG agrees that a five-year review should be conducted for the preferred remedial action and
has provided for this in the Record of Decision.
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Record of Decision
Carroll Island and Graces Quarters Operable Units B
Aberdeen Proving Ground, Maryland
Page 49 of 49
May 2001
Final
Comment No. 12: "The text states that no further action is required for 17 individual sites referenced in the bulleted
list preceding this paragraph. The Primary Test Area is included in the list of No Further Action sites. Please clarify
that the no action decision listed in this section excludes the groundwater beneath the Primary Test Area, and that
remedial action is anticipated for this separate operable unit. This distinction should be made in the final Record of
Decision and other applicable documents referencing this site."
Response No. 12: APG has clarified in the Record of Decision that groundwater remediation at Graces Quarters
is a separate Operable Unit.
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