RECORD OF DECISION
REMEDIAL ACTION AT
WHITE PHOSPHORUS PITS
J-FIELD STUDY AREA
ABERDEEN PROVING GROUND, MARYLAND
SUBMITTED BY:
ENVIRONMENTAL CONSERVATION AND RESTORATION DIVISION
U.S. ARMY GARRISON ABERDEEN PROVING GROUND
ABERDEEN PROVING GROUND, MARYLAND 21010
FINAL, SEPTEMBER 2007
DISTRIBUTION RESTRICTION STATEMENT
APPROVED FOR PUBLIC RELEASE:
DISTRIBUTION IS UNLIMITED. # 7088-A-1
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TABLE OF CONTENTS
TABLE OF CONTENTS i
ACRONYMS AND ABBREVIATIONS iii
PART 1: DECLARATION 1
1 SITE NAME AND LOCATION 1
2 STATEMENT OF BASIS AND PURPOSE 1
3 ASSESSMENT OF THE SITE 2
4 DESCRIPTION OF THE SELECTED REMEDY 3
5 STATUTORY DETERMINATION 6
6 DATA CERTIFICATION CHECKLIST 6
7 AUTHORIZING SIGNATURES 7
PART 2: DECISION SUMMARY 9
1 SITE NAME, LOCATION, AND DESCRIPTION 9
2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 10
3 PUBLIC/COMMUNITY INVOLVEMENT 17
4 SCOPE AND ROLE OF RESPONSE ACTION 17
5 SITE CHARACTERISTICS 18
6 CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 29
7 SUMMARY OF SITE RISKS 29
8 REMEDIAL ACTION OBJECTIVES 40
9 DESCRIPTION OF ALTERNATIVES 41
10 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 44
11 PRINCIPAL THREAT WASTES 48
12 SELECTED REMEDY 49
13 STATUTORY DETERMINATIONS 51
14 DOCUMENTATION OF SIGNIFICANT CHANGES 52
1 OVERVIEW 53
2 BACKGROUND ON COMMUNITY INVOLVEMENT 53
3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES 54
PART 4: REFERENCES 59
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LIST OF FIGURES
Figure 1. LOCATION OF J-FIELD STUDY AREA 13
Figure 2. AREAS OF CONCERN (AOC) AND POTENTIAL AREAS OF CONCERN
(PAOC) AT J-FIELD 15
Figure 3. WPP SAMPLING LOCATIONS 20
Figure 4. Ill MAI. HEALTH CONCEPTUAL SITE MODEL 24
Figure 5. ECOLOGICAL CONCEPTUAL SITE MODEL 26
LIST OF TABLES
Table 1. SUMMARY OF AEDB-R SITES ADDRESSED BY J-FIELD REMEDIAL
ACTIONS 5
Table 2. SUMMARY OF WPP INVESTIGATION ACTIVITIES 21
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ACRONYMS AND ABBREVIATIONS
AEDB-R
ANL
AOC
APG
ARAR
Army
AVS
BERA
CERCLA
CERCLIS
COC
COPC
COPEC
CSM
CWA
DSERTS
DSHE
EA
ERA
ESD
FETAX
FFA
FFD
FFS
FS
ft
GIS
HHRA
HI
HQ
Army Environmental Database - Restoration
Argonne National Laboratory
Area of Concern
Aberdeen Proving Ground
Applicable or Relevant and Appropriate Requirement
United States Army
Acid-Volatile Sulfide
Baseline Environmental Risk Assessment
Comprehensive Environmental Response, Compensation and Liability Act
Comprehensive Environmental Response, Compensation and Liability
Information System
Contaminant of Concern
Contaminant of Potential Concern
Contaminant of Potential Environmental Concern
Conceptual Site Model
Chemical Warfare Agent
Defense Site Environmental Restoration Tracking System
Directorate of Safety, Health and the Environment
Edgewood Area
Ecological Risk Assessment
Exclamation of Significant Differences
Frog Embryo Teratogenesis Assays
Federal Facilities Agreement
Federal Facilities Division
Focused Feasibility Study
Feasibility Study
feet
Geographical Information Systems
Human Health Risk Assessment
Hazard Index
Hazard Quotient
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IEUBK Integrated Exposure Uptake Biokinetic
IRP Installation Restoration Program
LUC Land Use Control
MDE Maryland Department of the Environment
NCP National Contingency Plan
Hg/dL microgram per deciLiter
[j,g/L microgram per Liter
mg/kg milligrams per kilogram
OE Ordnance and Explosives
OU Operable Unit
PAOC Potential Areas of Concern
RAB Restoration Advisory Board
RAO Remedial Action Objective
RBC Risk-Based Concentration
RCRA Resource Conservation and Recovery Act
RD Remedial Design
RI Remedial Investigation
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act
SEM Simultaneously Extracted Metals
SEV Screening Ecotoxicity Value
SWMU Solid Waste Management Unit
SVOC Semi-Volatile Organic Compound
TCE Trichloroethylene
U.S. United States
USATHAMA U.S. Army Toxic and Hazardous Materials Agency (now referred to as the U.S.
Army Environmental Center)
USEPA U.S. Environmental Protection Agency
USGS U.S. Geological Survey
VOC Volatile Organic Compound
WP White Phosphorus
WPP White Phosphorus Pits
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RECORD OF DECISION
REMEDIAL ACTION AT WHITE PHOSPHORUS PITS
IN THE J-FIELD STUDY AREA
ABERDEEN PROVING GROUND, MARYLAND
EDGEWOOD AREA NATIONAL PRIORITIES LIST (NPL) SITE
AUGUST 2007
PART 1: DECLARATION
1 SITE NAME AND LOCATION
The White Phosphorus Pits (WPP) site within the J-Field Study Area (J-Field) is located in the
Gunpowder Peninsula portion of Aberdeen Proving Ground (APG), Maryland. The Gunpowder
Peninsula is also known as the Edgewood Area (EA) of APG. Pursuant to the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA), this Record of Decision
(ROD) selects a remedial action for the WPP site. The Army Environmental Database -
Restoration (AEDB-R) [formerly referred to as Defense Site Environmental Restoration
Tracking System (DSERTS)] number for this site is EAJF01. The location of this site is shown
on Figure 2 in the Decision Summary (Part 2) of this ROD.
The United States Environmental Protection Agency (USEPA) Superfund Site Identification
number for APG-EA is MD 2210020036. This ROD will be listed under Operable Unit (OU) 7
in the USEPA's Comprehensive Environmental Response, Compensation and Liability
Information System (CERCLIS) database. The site owner and lead agency is the United States
Army (Army), the USEPA is the lead regulatory agency, and the Maryland Department of the
Environment (MDE) is the supporting regulatory agency.
2 STATEMENT OF BASIS AND PURPOSE
This ROD presents the remedy selected by the Army and the USEPA Region III for the WPP site
within the J-Field Study Area. Land Use Controls (LUCs) have been chosen as the Selected
Remedy for this site. This remedy was chosen in accordance with CERCLA, as amended by the
Superfund Amendments and Reauthorization Act (SARA), and to the extent practicable the
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National Contingency Plan (NCP). The Selected Remedy also satisfies Resource Conservation
and Recovery Act (RCRA) corrective action requirements. The decision is based on the
Administrative Record for this site.
The Army and USEPA, with support from MDE, developed remedial alternatives to achieve the
performance objective of a completed response action. This site poses no potential unacceptable
risks to human health under an industrial land-use scenario (i.e. foreseeable future use); however,
there is potential for risk to hypothetical future residents, resulting in the need for LUCs. The
results of the Ecological Risk Assessments (ERAs) suggest no risk to ecological receptors at the
WPP site.
To complete a streamlined response, USEPA and MDE support the Selected Remedy outlined in
this ROD as necessary to adequately and cost-effectively protect human health and the
environment.
3 ASSESSMENT OF THE SITE
The J-Field Study Area contains AEDB-R sites as shown in Table 1 of this document. With the
exception of the Robins Point Demolition Ground, which is still an active RCRA unit, all other
AEDB-R sites in this study area have been addressed by previous decision documents.
During the WPP Remedial Investigation (RI) activities, slightly elevated metals were found in
soils and slightly elevated volatile organic compounds (VOCs) in groundwater. The results of
the risk assessments indicated that there were no potential unacceptable risks for human or
ecological receptors for the military/industrial land use scenario. Based on blood level modeling,
lead was found to present a risk to a hypothetical future child resident. Further, trichloroethylene
(TCE) concentrations found in groundwater would present a potential risk to the hypothetical
future resident. However, it was determined that the groundwater contamination did not
constitute a plume, but instead was found in isolated hot spots. The hot spots were determined
not to cause a threat to the environment. There are no unacceptable ecological risks associated
with this site.
Lead was designated as a Contaminant of Concern (COC) for soil under the hypothetical future
resident scenario and TCE was designated as a COC in groundwater. Consequently, LUCs will
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be required to prevent future military family housing, elementary and secondary schools, child
care facilities, playgrounds, and non-military residential land use at this site. Although TCE was
designated as a COC in groundwater, no plume is present.
The response actions selected in this ROD are necessary to protect the public health and the
environment from actual or threatened releases of hazardous substances into the environment.
4 DESCRIPTION OF THE SELECTED REMEDY
The WPP Site is located within the J-Field Study Area. AEDB-R sites in the J-Field Study Area
that have been covered by previous decision documents are listed in Table 1.
The Selected Remedy for the WPP site is LUCs. This remedy includes the following elements:
> Existing LUCs at APG would continue. These measures include engineering controls,
boating access restrictions, and restrictions on subsurface access by site workers. Access
restrictions are enforced by security guards.
> Modifications will be made to the Installation Master Plan and Geographical Information
Systems (GIS) Overlay Maps in order to prevent future military family housing,
elementary and secondary schools, child care facilities, playgrounds, and non-military
residential land use until risks presented by contaminant levels at the site allow for
unlimited use and unrestricted exposure.
A Remedial Design (RD) will be submitted consistent with the RD schedule provisions of the
Federal Facilities Agreement (FFA) to outline the LUC implementation. The Army shall be
responsible for implementation, maintenance, periodic reporting, and enforcement of LUCs in
accordance with the RD. As part of the Army's inspection and reporting responsibilities,
periodic reviews will be undertaken and review reports will be submitted at a frequency
determined by site-specific conditions (as specified in the USEPA-approved RD). The LUCs
will include implementation through the APG Master Planning system with geographic
information support.
Although the Army may transfer these responsibilities to another party by contract, property
transfer agreement, or through other means, the Army shall remain ultimately responsible for
remedy integrity and shall: i) perform CERCLA 121(c) five-year reviews; ii) notify the
appropriate regulators and/or local government representatives of any known LUC deficiencies
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or violations; iii) provide access to the property to conduct any necessary response; iv) retain the
ability to change, modify or terminate LUCs and any related deed or lease provisions; and, v)
ensure that the LUC objective is met to maintain remedy protectiveness.
As a condition of property transfer or lease, the Army may require the transferee or lessee in
cooperation with other stakeholders to assume responsibility for various implementation actions.
Third party LUC responsibility will be incorporated into pertinent contractual, property and
remedial documentation, such as a purchase agreement, deed, lease, and RD addendum. To the
extent permitted by law, a transfer deed shall require the LUCs imposed as part of a CERCLA
remedy to run with the land and bind all property owners and users. If the Army intends to
transfer ownership of any site, the Army may, if Federal and/or State law allows, upon transfer
of fee title grant the State an environmental covenant or easement that would allow the State to
enforce LUC terms and conditions against the transferee(s), as well as subsequent property
owner(s) or user(s) or their contractors, tenants, lessees or other parties. This covenant will be
incorporated by reference in the transfer deed and will run with the land in accordance with State
realty law. This state enforcement right would supplement, not replace, the Army's right and
responsibility to enforce the LUCs.
The Selected Remedy for this site is protective of human and ecological receptors. The present
worth cost of the Selected Remedy is $99,900.
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Table 1.
Summary of AEDB-R Sites Addressed by J-Field Remedial Actions.
AEDB-R Site Name
AEDB-R
Number
Soil OU
ROD/
ESD a
J-Field
Study
Area
ROD
ROD Date
FY
J-Field Study Area
EAJF00
X
2001
Prototype Building
EAJF02
X
2001
Riot Control Burning Pit
EAJF03
X
2001
Robins Point Demolition Ground b
EAJF04
Toxic Burn Pits a
EAJF05
X
X
1996
Toxic Burn Pits - Southern Main Pits Overall
EAJF05-A
X
X
1996
Surficial Aquiferc
EAJF05-B
X
2001
South Beach Demolition Ground
EAJF06
X
2001
South Beach Trench
EAJF07
X
2001
XI Ruins Sites, SW of Intersection
EAJF08
X
2001
Drainage Grid (Area A)
EAJF09
X
2001
Ford's Point Firing Position (Area B)
EAJF10
X
2001
Ruins Site NE of Intersection (Area C)
EAJF11
X
2001
Ruins Site Area across from WPP
EAJF12
X
2001
Swamp 400 ft East of Ruins Site (Area D)
EAJF13
X
2001
Robins Point Tower Site
EAJF14
X
2001
Titanium Pits Site
EAJF15
X
2001
White Phosphorus Pits
EAJF01
2007
aThe ROD has been modified by an Exclamation of Significant Differences (ESD) (2001).
b Remains active under RCRA permit; will be closed when appropriate.
c Includes the Confined Aquifer corrective actions.
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5 STATUTORY DETERMINATIONS
This remedy meets the requirements of CERCLA Section 121 and, to the extent practicable, the
NCP. The Selected Remedy for the WPP site at J-Field is protective of human health and the
environment, complies with Federal and State requirements that are applicable or relevant and
appropriate, is cost effective, and utilizes permanent solutions to the maximum extent
practicable.
The Selected Remedy does not employ treatment to reduce toxicity, mobility or volume of
hazardous substances, pollutants, or contaminants. Therefore, the Selected Remedy does not
satisfy the statutory preference for remedies that employ treatment as a principal element.
This site will be evaluated as part of the CERCLA 121(c) five-year review for the APG-EA NPL
site.
6 DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the Administrative Record file for the J-Field Study Area.
> COCs and their respective concentrations;
> Baseline risk represented by the COCs;
> Current and reasonably anticipated future land use assumptions and potential land use that
will be available as a result of the Selected Remedy;
> Estimated capital, O&M, and total present worth costs, and the number of years over
which the remedy cost estimates are projected; and,
> Key factor(s) that led to selecting the remedy (i.e., description of how the Selected Remedy
provides the best balance of tradeoffs with respect to the balancing and modifying criteria,
highlighting criteria key to the decision).
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7 AUTHORIZING SIGNATURES
The appropriate approval authority for this action is the APG Installation Commander.
Jeffrey S. W
Colonel, U.S. Army
Deputy Installation Commander
SEP 1 9 2007
James Burjre
Director
Hazardous Site Cleanup Division
U.S. Environmental Protection Agency, Region III
Date
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PART 2: DECISION SUMMARY
1 SITE NAME, LOCATION, AND DESCRIPTION
The WPP site within the J-Field Study Area is located in the Gunpowder Peninsula portion of
APG, Maryland. The USEPA Superfund Site Identification Number for APG-EA is MD
2210020036. Pursuant to CERCLA, this ROD selects a remedial action for the WPP site. The
Army is the lead agency for site remediation; USEPA is the lead regulatory agency; and MDE is
the support regulatory agency.
APG is a 72,500-acre Army installation located on the northwestern shore of the Chesapeake
Bay in southern Harford County and eastern Baltimore County, Maryland (Figure 1). The
Installation is bordered to the east and south by the Chesapeake Bay; to the west by Gunpowder
Falls State Park, the Crane Point Power Plant, and residential areas; and to the north by the towns
of Edgewood, Joppa, Magnolia, and Aberdeen. The Bush River divides the Installation into two
main areas. The northeastern area is referred to as the Aberdeen Area, and the southwestern area
is referred to as the Gunpowder Peninsula or the Edgewood Area.
J-Field was used for military purposes as early as 1917; however, the site was used more actively
from the World War II era into the late 1970s. Historical site usage is only partially documented.
In general, site activities included the testing of high explosives and chemical munitions, the
testing of conventional munitions on structures and buildings, thermal (through open burning)
and chemical decontamination of chemical munitions, open detonation, and disposal. Materials
disposed at J-Field included chemical warfare agents (CWA), CWA decontamination solutions,
riot control agents, white phosphorus (WP), chlorinated solvents, and other wastes generated by
research laboratories, process laboratories, pilot plants, and machine and maintenance shops.
The WPP site occupies approximately 5.5 acres in the J-Field Study Area and is located north
and west of Rickett's Point Road (Figure 2). Until 2001, the WPP site was considered an active
emergency disposal facility that was used periodically for disposal of ordnance and explosives
(OE) by open detonation. The WPP area is no longer used for emergency disposal purposes.
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2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
As part of RCRA Part B permitting activities at APG conducted in 1986, Solid Waste
Management Units (SWMUs) were assessed for their potential for release of contaminants to the
environment. Studies performed within the guidelines of the RCRA permit identified J-Field as
one of the areas that contained SWMUs. These studies included the Hydrogeologic Assessment
[U.S. Geological Survey (USGS), 1989] and the RCRA Facility Assessment [U.S. Army
Environmental Hygiene Agency (USAEHA), 1989],
The Gunpowder Peninsula of APG was placed on the NPL by the USEPA on February 21, 1990,
due to evidence of contaminated groundwater, soil, surface water, and sediment. An FFA was
signed by the Army and USEPA Region III in March 1990, which subjected APG to RCRA
corrective action and CERCLA remedial action requirements for the contaminated sites (USEPA
Region III and U.S. Army, 1990). The FFA established schedules for commencing RIs and
Feasibility Studies (FSs) and requires expeditious completion of remedial actions. The APG
Directorate of Safety, Health and the Environment (DSHE) implements the Installation
Restoration Program (IRP) to fulfill the requirements of the FFA. The designations for sites
under the purview of CERCLA and the IRP were later changed from SWMUs to DSERTS sites
(which are now referred to as AEDB-R sites).
Until 2001, the WPP site was considered an active emergency disposal facility that was used
periodically for disposal of OE by open detonation. The existing pits and areas potentially
affected by emergency disposal operations were deferred from complete evaluation in the
original J-Field Study Area RI/FS until the Army discontinued use of the WPP. However, some
chemical, toxicological, and ecological data were collected from surface soil near the pits, from
the Southern Pit, and from the ditch and impoundment area associated with the Northern Pit. On
the basis of the analysis of those data, an ERA for the WPP was developed and included in the J-
Field Ecological Risk Assessment (Argonne National Laboratory [ANL], 2000).
After the WPP area was closed to emergency disposal operations in 2001, DSHE completed the
RI/FS for the WPP. Additional sampling activities were conducted at the WPP during 2004 and
2005 to complete the contamination assessment. An updated ERA was also completed at the
WPP site. The results of these activities are reported in the final RI/ERA report (ANL, 2006). A
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Human Health Risk Assessment (HHRA) including the 2004/2005 investigation data was
prepared by EA Engineering, Science and Technology, Inc. and finalized in March 2006. A
summary of historical site investigation activities is given in Section 5, Table 2 of this document.
The RI performed in 2004/2005 used the historical site data to focus on areas of the site
previously exhibiting elevated contaminant concentrations and areas not previously investigated.
Samples were collected from site soil, groundwater, surface water, and sediment. The sample
results were evaluated in the ERA and HHRA reports (ANL, 2006 and EA Engineering, 2006).
The ERA concluded that contaminant concentrations at the WPP site are unlikely to affect the
ecological sustainability of any of the species utilizing the habitats at the site. This conclusion is
based on the fact that the WPP encompasses a small area within J-Field, and only a small portion
of that area is likely to contain contaminants at levels that may harm ecological receptors. The
HHRA evaluated current-use scenarios for site workers and adolescent trespassers and likely
future use by commercial and construction workers. The HHRA also evaluated the hypothetical
future residential site use in order to evaluate the need for site LUCs. Of the likely current and
future-use scenarios, excluding the residential use scenario, no potential unacceptable
carcinogenic and non-carcinogenic risks were demonstrated through modeling. The only
potential receptors with modeled risks in excess of the 1 x 10"6 cancer risk (but still within the
acceptable range of 10"4 to 10"6) were future commercial workers due to arsenic in soil and TCE
in groundwater. Arsenic also exceeded its industrial Risk-Based Concentration (RBC) for the
site, but concentrations were consistent with background concentrations. The primary risk driver
for potential future residential use by adults was found to be TCE in groundwater. The primary
risk drivers for children in a residential use scenario were found to be lead in surface soils and
TCE in groundwater.
RI/FS activities at the WPP site addressed by this ROD are discussed in the following
documents:
> J-Field White Phosphorus Burning Pits, Remedial Investigation Report, Vol. I:
Contamination Assessment and Ecological Risk Report, Aberdeen Proving Ground
Maryland, ANL, 2007;
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> J-Field White Phosphorus Pits, Remedial Investigation Report Volume II: Baseline
Human Health Risk Assessment, Aberdeen Proving Ground, Maryland, EA Engineering,
2006;
> Remedial Investigation Report for J-Field, Aberdeen Proving Ground, Maryland;
Volume 1: Remedial Investigation Results, ANL, 1999;
> Remedial Investigation Report for J-Field, Aberdeen Proving Ground, Maryland;
Volume 3: Ecological Risk Assessment, ANL, 2000; and,
> J-Field White Phosphorus Pits Focused Feasibility Study, APG, Maryland, ANL, 2007.
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Figure 1. Location of J-Field at APG, Maryland.
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FORDS CREEK
AREAC PAOC
AREA A PAOC
AREA B PAOC
RUINS SITE
PAOC
AREA D PAOC
ROBINS POINT
DEMOLITION GROUND AOC
TOXIC BURNING
PITS AOC
PROTOTYPE
-BUILDING AOC.
ROBINS POINT
TOWER SITE J
AOC /
JOWER"
Marsh
GUNPOWDER
R fVE R
WHITE
PHOSPHORUS
—""BURNING'-
— PITS. AOC
RIOT
CONTROL
BURNING PIT
-AOC
RICKETT'S POINT
ROBINS
POINT
'SOUTH BEACH TRENCH AOc"" „J".
SOUTH BEACH DEMOLITION GROUND AOC
CHESAPEAKE BAY
FORDS
POINT
Figure 2. Areas of Concern (AOC) and Potential Areas of Concern (PAOC) at J-Field.
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3 PUBLIC/COMMUNITY INVOLVEMENT
CERCLA Sections 113(k)(2)(B) and 117, Department of Defense, and Army policy require the
involvement of the local community as early as possible and throughout the IRP process. To
accomplish this, APG is conducting monthly Restoration Advisory Board (RAB) meetings and
periodic public meetings at each decision point in the CERCLA remedial process. The RAB
membership is comprised of both Army and local community members. Information regarding
the WPP site was briefed to the RAB several times over the last few years.
The Proposed Plan was made available to the public on June 20, 2007. The Administrative
Record, which contains the information used to select the remedy, may be found at the Aberdeen
and Edgewood Branch of the Harford County Public Library and at the Miller Library at
Washington College. The notice of the availability of these documents was published in The
Aegis, Cecil Whig, Kent County News, The Avenue, and East County Times. A copy of the
newspaper ad is provided in the Responsiveness Summary (Part 3) of this ROD. The public
meeting was held on June 25, 2007, and the public comment period was held from June 25, 2007
to August 8, 2007. Responses to the public comments received during this period are included in
the Responsiveness Summary (Part 3) of this ROD.
4 SCOPE AND ROLE OF RESPONSE ACTION
RODs have already been implemented for the remaining sites in the J-Field Study Area, with the
exception of the still active Robins Point Demolition Ground, as listed in Table 1 of this
document. The Robins Point Demolition Ground site will be addressed when it is no longer
being actively used.
This ROD selects the final response action for the WPP site.
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5 SITE CHARACTERISTICS
The WPP site is a 5.5-acre site located in the J-Field Study Area. J-Field occupies approximately
460 acres on the southern tip of the Gunpowder Peninsula and is bordered by tidal estuaries on
three sides — the Gunpowder River to the west, the Chesapeake Bay to the south, and the Bush
River to the east (Figure 2). The WPP is nearly flat, with a maximum relief of about 8 feet (ft)
above sea level, and contains a mixture of freshwater marshes, forest, and an open managed
grassy area.
The grassy area in the WPP site measures about 540 by 440 ft and is located north and west of
Rickett's Point Road. The grassy area is bordered to the north, south, and east by stands of tulip
poplar trees or mixed deciduous hardwoods and some forested wetlands dominated by sweetgum
and red maple, with willow oak, black gum, swamp chestnut oak, and sycamore frequently
dominating wetter sites.
The most prominent surface features at the WPP are two large trenches or pits that are referred to
here as the "Northern Pit" and the "Southern Pit." The two pits are oriented roughly east/west.
The Northern Pit is approximately 150 ft long and the Southern Pit is approximately 225 ft long.
A ditch from the Northern Pit extends north toward a bermed depression constructed to hold any
surface water runoff. The Southern Pit ends to the west at what is assumed to be a "pushout area"
where material previously was pushed out of the pit. During wet weather, water collects in the
pits and the bermed depression, even though surface runoff does not enter the pits.
Prior to the 2004/2005 RI, the WPP site was the subject of previous environmental studies
performed in the 1970s, 1980s, and 1990s. Information from past studies has proven to be useful
for the development and refinement of the site conceptual model, the identification of
contaminants of potential concern, the development of data quality objectives, and the crafting of
the sampling plan. Toxicity testing was also conducted for soils, surface water, and sediments.
Figure 3 indicates the location of soil, sediment, surface water, and groundwater sampling.
Table 2 is a summary of historical investigation activities.
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Figure 3: WPP Sampling Locations.
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Table 2.
Summary of WPP Investigation Activities.
Investigation
Summary
Groundwater
Soil
Surface Water
Sediment
Installation and sampling of
3 wells; surface water, and
soil and sediment sampling 1
3 wells installed and
sampled
3 deep soil borings
installed
5 surface water
locations in proximity
to WPP sampled
5 sediment locations in
proximity to WPP
sampled
Installation and sampling of
4 additional wells; sampling
and analysis of soil borings;
surface soil, wells, and
surface water samples 2
4 wells installed and
sampled for metals,
pesticides, radium,
alpha and beta,
coliform, water quality
parameters, total
organic halides
4 deep borings installed;
one composite sample
analyzed from each pit for
metals, nitrate, phosphorus,
cyanide, petroleum
hydrocarbons, phenols,
toluene, and ethyl benzene
5 surface water samples
analyzed for metals,
phosphorus, pesticides
Sampling and analysis of
surface soil, monitoring
wells, and surface water3
4 wells sampled for
metals, explosives,
radioactivity,
thiodiglycol, VOCs,
Semi-Volatile Organic
Compunds (SVOCs),
pesticides, and PCBs
Samples from 2 locations
analyzed for metals, RCRA
USEPA toxicity,
explosives-related
compounds
Samples analyzed for
metals, explosive-
related compounds,
gross alpha and beta,
VOCs, SVOCs, and
pesticides, and PCBs
Installation and sampling of
12 wells; sampling and
analysis of soil and surface
water adjacent to burn pit;
passive soil-gas sampling 4
Wells sampled for
metals, VOCs, SVOCs,
organosulfur,
explosive-related
compounds, and
radioactive compounds
10 samples collected and
analyzed for metals, VOCs,
SVOCs, and explosives; 12
deep borings installed
1 sample analyzed for
VOCs, SVOCs,
pesticides, and
explosives-related
compounds
Sampling and analysis of soil
from soil borings in the
burning pits and adjacent soil
sites 5
6 borings; 3 from each pit
analyzed for VOCs, PCBs,
and metals; 6 surface soil
samples analyzed for
VOCs, PCBs, and metals
Passive soil-gas sampling;
geophysical analysis
performed; sampling and
analysis of existing
monitoring wells; sampling
and analysis of surface soil
and surface water samples 6
13 wells sampled and
analyzed for
explosives, general
chemistry parameters,
VOCs, CWA-related
compounds, and metals
Borings installed adjacent
to burn pits; samples
analyzed for CWA only.
40 passive soil-gas samples
collected. 24 surface soil
samples collected and
analyzed for metals and/or
organics.
5 samples analyzed for
PCBs, pesticides, CWA
degradation products,
metals, and explosive-
related compounds.
1 Nemeth, 1983
2 Princeton Aqua Science, 1984
3 Nemeth, 1989
4USGS, 1993; USGS, 1996
5 Weston, 1994
6 ANL, 1995; ANL, 1999
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5.1 Conceptual Site Model
Conceptual site models (CSMs) were developed during the risk assessment process for the WPP
site that identify the primary sources, primary contaminated media, migration pathways,
exposure pathways, and potential human and ecological receptors. The CSMs are based on the
data that are presented in the RI/FS documentation. These documents, discussed in Section 2.0,
are available in the Administrative Record. Figures 4 and 5 depict the human health and
ecological CSMs for this site.
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Potential
Source
Primary
Release
Mechanisms
Secondary
Source
Activities at
J-Field WPP
Infiltration/
Adsorption
Surface
Soil
Subsurface
Soil
Secondary
Release
Mechanisms
Air
Air
Tertiary
Source
Surface
Soil
Total
Soil
Air
Particulate
Matter
Air
Particulate
Matter
Potential
Exposure
Routes
Specific Receptors of Concern
Residents
(Adults,
Children)
Trespasser
(Adolescent)
Construction
Worker
Commercial
Workers
Site
Workers
Ingestion
X
X
Dermal Contact
X
X
Inhalation of
Air Particulates
Ingestion
X
X
X
Dermal Contact
X
X
X
Inhalation of
Air Particulates
X
X
X
Groundwater
Surface
Water/
Sediment
Ingestion
X
X
Dermal Contact
X
X
Inhalation ofVOCs
While Showering
X (Adults)
Infiltration of VOCs
into Buildings
X
X
Incidental Ingestion
X
X
X
Dermal Contact
X
X
X
Figure 4: Human Health Conceptual Site Model.
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3
>5
rS
Or®
ft
Si
&5
5
5
©
5
Si
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Primary
Contaminant
Source
Primary
Release
Mechanism
Secondary
Contaminant
Source
Potential Receptors
Primary
Exposure
Route
Soil
Microbiota
Herpetofauna
Birds
Mammals
Fish
Aquatic
Invertebrates
Vegetation
Particulate
or Gaseous
Emissions
Inhalation
•
•
•
Soil
Main Burning Pis
PushoutArea
Suspected
Burn Areas
Ingestion
•
•
•
•
Dermal
Absorption
•
•
•
•
Root Uptake
•
Surface
Runoff
Infiltration
or
Percolation
Surface
Wiiter and
Sediment
A
Ingestion
•
•
•
•
Dermal
Absorption
•
•
•
•
•
•
Root Uptake
•
Groundwater
~
Root Uptake
•
Figure 5: Ecological Conceptual Site Model
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3
>5
rS
Or®
ft
Si
&5
5
5
©
5
Si
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6 CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
The current and anticipated future use of the WPP is military/industrial.
7 SUMMARY OF SITE RISKS
As a component of the RI process, risk assessments (the HHRA and ERA) were performed for
the WPP site. The following summaries of the human health and ecological risks were derived
from these documents.
7.1 Summary of Human Health Risk Assessment
7.1.1 Identification of Chemicals of Potential Concern
A preliminary HHRA was prepared for the WPP site in 1998 based on then current data. In
2006, a supplemental HHRA was prepared for the site. Data included in the 2006 assessment
were obtained from the 2004 sampling effort. Only the recent data was used because the
previous open detonation activities, occurring between 1998 and 2004, were likely to have
changed site conditions. The 2006 HHRA evaluated data from 45 surface soil, 19 subsurface
soil, 15 groundwater, 8 sediment, and 6 surface water samples. Because it is the more current
document, only 2006 findings will be discussed throughout the remainder of this section.
In the 2006 HHRA, arsenic was detected above its RBC of 1.9 mg/kg for an industrial scenario.
Arsenic was detected at the WPP at concentrations ranging 1.8 to 6.1 These findings are
consistent with background reference concentrations. The limited number of detections above
background were found not to be statistically significant. Organic compounds detected in
surface soil and subsurface soil at the WPP were below the industrial soil RBCs.
All compounds, except lead, were evaluated in accordance with EPA guidance. According to
EPA, lead is classified as a probable human carcinogen. However, there is no EPA value for use
as a slope factor quantifying carcinogenic risks. In the absence of any EPA-published toxicity
values for lead, it is currently not possible to perform a quantitative risk estimate for lead
exposures using standard EPA methodology. The current USEPA guidance sets forth an interim
soil cleanup level for total lead of 400 mg/kg (USEPA, 1989b). The exposure models used in the
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HHRA followed Recommendations of the Technical Review Workgroup for Lead, An Interim
Approach to Assessing Risks Associated with Adult Exposures to Lead in Soil (USEPA, 1996b)
and the Integrated Exposure Uptake Biokinetic (IEUBK) Model for Lead in Children (USEPA,
2002). The lead models are used to model blood lead levels — the indicator of excess lead
exposure in humans — for exposure to lead in soil and groundwater. Modeled blood level results
are compared with the established cutoff value or acceptable blood lead threshold of 10
microgram per deciliter (|j,g/dL). Although all current and likely future use scenarios resulted in
blood lead levels below the lead threshold, the model predicts 95 percentile fetal blood-lead
levels greater than the 10 |j,g/dL threshold; therefore, lead in total soil at the WPP site is a
concern for the hypothetical future child resident scenario.
Risks from groundwater were found for future construction workers and hypothetical future
residents. TCE was detected in groundwater at concentrations ranging from 4 to 560
micrograms per Liter ((J,g/L). The Safe Drinking Water Act Maximum Contaminant Level for
TCE is 5 (J,g/L. TCE was designated as a COC for groundwater.
Based on the results of the HHRA and supplement for the hypothetical future resident scenario,
the COCs for the WPP site are lead in soil and TCE in groundwater.
In summary, the results of the 2006 HHRA indicated the following:
> No unacceptable carcinogenic or noncarcinogenic risks to adolescent trespassers;
> No unacceptable carcinogenic or noncarcinogenic risks to site workers;
> No unacceptable carcinogenic or noncarcinogenic risks to commercial workers;
> No unacceptable carcinogenic or noncarcinogenic risks to construction workers;
> Unacceptable risk to hypothetical future child resident due to lead soil and TCE in
groundwater.
7.1.2 Exposure Assessment
Current land use of the J-Field Study Area is primarily military/industrial. Potentially affected
receptors under current/future land-use conditions include site workers (i.e., industrial and
construction); adolescent trespassers; and hypothetical future residents.
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Potential exposure pathways were evaluated for both current and future land-use conditions. The
following exposure pathways were quantitatively evaluated under current/future land-use
conditions:
> Site workers exposed to soil, sediment, and surface water; and,
> Adolescent trespassers exposed to soil, sediment, and surface water.
The J-Field Study Area will likely continue to be used for military/industrial purposes. Future
construction/commercial worker exposures to total soil at certain sites were evaluated in the
HHRA since future excavation/construction activities could occur in this area. Under future
land-use conditions, the following potential exposure pathways were quantitatively evaluated,
excluding future use of groundwater (with the exception of hypothetical future residents):
> Commercial workers exposed to soil and indoor air;
> Construction workers exposed to soil and shallow groundwater; and,
> Hypothetical future residents exposed to soil, surface water, sediment, groundwater, and
indoor air.
7.1.3 Toxicity Assessment
Chronic toxicity criteria and quantitative dose-response data were obtained from the Integrated
Risk Information System (IRIS) (USEPA, 1996b), Health Effects Assessment Summary Tables
(HEAST) (USEPA, 1997), and the National Center for Environmental Assessment for COPCs.
In the toxicity assessment, the relationship between extent of exposure and extent of toxic injury
or disease was estimated for each COPC. Chemical-specific toxicity values, such as cancer slope
factors for carcinogenic compounds and reference doses or reference concentrations for
noncarcinogens, were presented along with a discussion of their scientific basis and derivation.
7.1.4 Risk Characterization
The human health risk characterizations combine the average daily doses calculated in the
exposure section with the health effects criteria presented in the toxicity section in order to
calculate potential human health risks. The estimated upper-bound excess lifetime cancer risks
for these sites were compared to the acceptable risk range of lxlO"6 to lxlO"4 for health
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protectiveness at CERCLA sites. Lifetime cancer risk levels of 1 x 10"6 and 1 x 10"4 represent the
probability of one in one million and one in ten thousand, respectively, that an individual could
contract cancer as a result of site-specific exposure.
Hazard quotients (HQs) are calculated for individual chemicals based on a ratio of the estimated
site-specific exposure to a single chemical over a specified time period to the estimated dose
over the same time period at which no adverse health effects are likely to occur (USEPA, 2005).
The effects from simultaneous exposure to multiple chemicals are determined by summing the
individual HQs within each exposure pathway (USEPA, 1989). This sum is referred to as the
Hazard Index (HI). In general, His that are greater than 1.0 are indicative of a potential for
adverse health effects.
Hypothetical future residential scenarios (adult and child resident) were evaluated to determine if
LUCs were necessary. An HI value of 1.7 was calculated for the hypothetical future child
resident scenario. Carcinogenic risks for future life time residents were within the acceptable
risk range. Carcinogenic and non-carcinogenic risks were within the acceptable range for current
and likely future use scenarios.
7.1.5 Uncertainty
All risk assessments involve the use of assumptions, judgments, and incomplete data to varying
degrees that contribute to the uncertainty of the final estimates of risk. Uncertainties result both
from the use of assumptions or models in lieu of actual data and from the error inherent in the
estimation of risk-related parameters, and may cause risk to be overestimated or underestimated.
Consequently, the results of these risk assessments should not be construed as presenting an
absolute estimate of risk to persons potentially exposed to chemicals at the WPP site.
The sources of uncertainty for these assessments are associated with environmental sampling and
analysis; selection of chemicals for evaluation; toxicological data; and exposure assessment. For
example, analytical accuracy errors or sampling errors can result in rejection of data, which
decreases the available data for use in the HHRA, or in the qualification of data, which increases
the uncertainty in the detected chemical concentrations. Also, for dermal absorption exposure
pathways, the absence of dermal toxicity criteria necessitated the use of oral toxicity data.
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7.2 Summary of Ecological Risk Assessment
7.2.1 Identification of Chemicals of Potential Concern
An ERA was performed for the WPP site to update the Baseline Environmental Risk Assessment
(BERA) (ANL, 2000). Chemical data used for the ERA were the most recent analyses of soil,
surface water, and sediment samples, which were collected from the WPP site during the spring
and summer of 2004. Analyses were conducted for VOCs, PAHs, SVOCs, inorganic metals,
CWA degradation compounds, pesticides, PCBs, explosive-related compounds, and perchlorate.
7.2.2 Exposure Assessment
Potential exposure pathways and assessment endpoints for ecological receptors were identified
based on: i) the likely presence of ecological resources; ii) the nature and extent of chemical
contamination; ii) the source/mechanism of chemical release; iv) the medium (or media) of
chemical transport; v) the point of potential contact by potential receptor groups; and, vi) the
route of exposure at the contact point. Potentially complete exposure pathways and exposure
groups were identified for evaluation in the ERAs based on consideration of the available
habitat, and the type, extent, magnitude, and location of chemical contamination.
The following potential receptors were identified for surface soil, sediment, and surface water at
the WPP site:
> Soil Microbiota;
> Herpetofauna;
> Birds;
> Mammals;
> Fish;
> Aquatic Invertebrates; and,
> Vegetation.
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7.2.3 Ecological Effects Assessment
A screening-level exposure estimate for each site contaminant was developed for each receptor,
and risks are estimated by comparing the exposure estimates to chemical-specific screening
values. Risk-based screening for potential contaminants and exposure routes of concern is
intended to make the ERA more efficient by focusing on the most significant contaminants and
exposure pathways as early as possible. To accomplish this goal, the highest measured or
estimated on-site contaminant concentration for each environmental medium is used as the
estimate of exposure in order to ensure that all potential chemical threats to ecological resources
are considered (USEPA, 1997). Completion of this process generates a preliminary list of
Contaminants of Potential Environmental Concern (COPECs) — site-associated chemicals that
potentially pose unacceptable risks to the assessment endpoints.
The screening exposure estimate and risk characterization were conducted in two ways. The first
involved calculation of HQs for the detected constituents in each medium by comparing
maximum concentrations of constituents in soil, sediment, and surface water to conservative
medium-specific screening benchmarks accepted by USEPA Region III (USEPA, 1995). These
benchmark concentrations are considered to be protective of organisms that dwell in or have
close contact with media from the site.
The second part of the screening consisted of modeling food-chain exposures to constituents for
an assortment of mammalian and avian fauna. In this part of the screening process, a conceptual
food chain model was developed that identified contaminant sources, exposure routes, and food
chain (or web) relationships for each receptor. Mathematical equations to predict contaminant
uptake, expressed as an applied daily dose, were then developed according to USEPA guidance
(USEPA, 1993b) and/or mathematical approaches published in the scientific literature.
Bioaccumulation factors obtained from the literature were used to estimate concentrations of
constituents in prey items. The daily doses of chemical constituents were calculated by using the
maximum measured or estimated media concentrations, and the modeled doses were then
compared with available dose-based screening benchmarks for the organisms considered.
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For purposes of the preliminary screening, a constituent was carried forward to the refinement
screening step when any of the available concentration-based or dose-based Screening
Ecotoxicity Values (SEVs) was exceeded. Of the constituents detected at the WPP site, five
organic compounds were present at levels below the available SEVs in both concentration- and
dose-based evaluations conducted during the preliminary screen, and were not considered further
in the ERA process. The remaining constituents were considered further in the screening
refinement step.
The preliminary screening process used was a very conservative evaluation that utilized
maximum detected concentrations as the exposure point concentrations, assumed that the
constituents were in highly bioavailable forms, and assumed that the representative receptors
utilized only the WPP site for feeding. As a result, constituents that exceeded the concentration-
or dose-based SEVs during the preliminary screening step may, in fact, not be unacceptable.
The screening-level ERA included in the RI/FS process was conducted in order to update the
existing BERA. This additional refinement step used four principal criteria to determine whether
chemical constituents should be retained as COPECs:
1. Elimination of analytes that were considered unlikely to pose ecological risks
at the WPP because of site conditions that are known to limit bioavailability
and potential toxicity even though maximum concentrations exceeded SEVs.
2. Elimination of analytes considered to be nutrients.
3. Elimination of analytes that were present at concentrations within the range of
measured background concentrations.
4. Elimination of analytes when reevaluation using the 95% upper confidence
limit of the mean (95% UCL) concentrations resulted in HQs less than 1 when
exposure concentrations and doses were compared with concentration-based
or dose-based SEVs.
The outcome of the overall screening-level evaluation process was the selection of a final set of
COPECs and ecological exposure pathways that warranted further analysis in the ERA. The final
COPECs are those chemical constituents that exceeded SEVs under more realistic, site-specific
conditions and that exceeded background concentrations. Contaminants were also retained for
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further evaluation in the ERA when no background concentrations or SEVs were available for
comparison.
Nine inorganic constituents and 12 organic constituents were retained as COPECs following the
screening refinement step. The following COPECs were retained in soil: nine metals (antimony,
arsenic, barium, cadmium, chromium, copper, lead, thallium, zinc), and 12 organic compounds
(2-hexanone, acenaphthylene, benzo(b)fluoranthene, benzo(g,h,I)perylene,
benzo(k)fluoranthene, bis(2-ethylhexyl)phthalate, dieldrin, fluoranthene, and phenanthrene). In
surface water, three metals (arsenic, barium, and lead) were retained as COPECs; no organic
compounds were retained. One metal (zinc) and three organic compounds (acetone,
benzaldehyde, and benzyl butyl phthalate) were retained as COPECs in sediments. As will be
discussed in Section 7.2.4, toxicity from lead in sediment was identified during the site toxicity
testing.
7.2.4 Toxicity Testing
In addition to evaluation of exposure and effects based solely on concentrations and modeled
doses of COPECs and the resulting HQs, toxicity tests were conducted with soil, surface water,
and sediment in order to compare the toxicities of media from the WPP with those of reference
locations. APG performed a number of toxicity tests using environmental media collected from
discrete locations at the WPP site (ANL, 2003). Toxicity testing was used to provide
measurements of the effects on growth, reproduction, development, and survival for a variety of
surrogate organisms as a means of evaluating potential risks to some ecological receptors. More
detailed descriptions of methods and results are provided in the full report on the toxicity testing
(ANL, 2006).
Toxicity tests conducted using surface water included 96-h green alga growth tests using
Raphidocelis subcapilala\ 7-day survival and reproduction tests using cladocerans
(Ceriodaphnia dubia); 7-day survival and growth tests using the fathead minnow (Pimephales
promelas); and 96-h frog embryo teratogenesis assays (FETAX) using Xenopus laevis. Results
indicated that concentrations of the COPECs in surface water do not pose an unacceptable risk to
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aquatic plants, aquatic invertebrates, fish, and amphibians exposed to surface water from the
WPP site.
Sediment samples were analyzed for grain size, heavy metals, and simultaneously extracted
metals (SEM). Acid-volatile sulfide (AVS) analyses were performed on an aliquot from each
composite sediment sample taken from J-Field. SVOCs and explosive-related compound
concentrations were determined for one sediment sample. Toxicity testing for sediments
consisted of survival, growth, and reproduction of the epifaunal amphipod Hyalella azteca and
the infaunal amphipod, Leptocheirus plumulosus, which were evaluated in separate 28-day
toxicity tests conducted using sediment from each collection location and from the reference
location.
Limited areas of sediment toxicity were observed. Based on the evaluations conducted, the
toxicities observed in one sample were attributable to elevated lead concentrations. Previous
sampling of sediments from the WPP ERA found that lead concentrations did not exceed
concentrations detected in background sampling. However, it appears that lead concentrations
are sporadically distributed along the Gunpowder River shoreline, and the concentration of lead
measured in sediments collected from one sample location for toxicity tests was over two times
greater than the maximum concentration identified in background samples. Consequently, lead
was retained as a COPEC for sediments at the WPP site.
Soils, including reference soil samples, were analyzed for heavy metals, pesticides, PCBs, and
PAHs. General soil quality parameters were also measured.
Ten replicated 120-h lettuce seed germination tests with Lactuca sativa and 10 replicated 28-day
survival and bioaccumulation tests were conducted, and the earthworm Eisenia fetida was
exposed to the collected soils. Site-specific values of bioaccumulation of chemical constituents
by earthworms were evaluated by comparing the concentrations of analytes in earthworm tissues
at the end of the 28-day toxicity tests with concentrations in the soil used to conduct the
earthworm toxicity tests. On the basis of the results of the toxicity tests and bioaccumulation
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measurements, the concentrations of COPECs in soils at the WPP site do not appear to present
unacceptable risks to plants and soil invertebrates.
7.2.5 Ecological Risk Characterization
On the basis of the results of the ecological exposure and effects assessments, the concentrations
of the COPECs in surface waters at the WPP do not pose unacceptable risks to aquatic plants,
planktonic invertebrates, fish, and amphibians. While some HQs indicated a potential for risks to
some aquatic organisms, site-specific evaluations using toxicity tests indicated that either the
SEVs used to calculate the HQs were conservative or that the bioavailability of the COPECs
under conditions specific to the WPP site was low enough that toxicity was not expressed.
For the most part, sediments at the WPP do not appear to pose unacceptable risks to sediment
invertebrates and to semi-aquatic avian species, such as ducks, that might utilize aquatic habitats
at the WPP. However, there may be selected small areas in the Gunpowder River just offshore of
the WPP site where lead concentrations in the sediments may be high enough to affect the
survival and growth of benthic invertebrates. Given the large amount of shoreline area along the
Edgewood peninsula and the greater Gunpowder River, it is anticipated that such localized areas
would not substantially affect overall invertebrate production within the local area.
Consequently, the overall effects of COPECs in sediments from the WPP site on ecological
resources are likely to be minor.
Toxicity tests with soils from the WPP site indicated that COPECs in soils are unlikely to affect
terrestrial plants and soil invertebrates. Dose-based uptake modeling and calculation of dose-
based HQs indicate a potential for negative effects on omnivorous terrestrial birds and mammals
with small home ranges. Birds and mammals, such as larger carnivorous species, that would
utilize habitats at the WPP for a relatively small proportion of their foraging needs are likely not
at risk from the concentrations of COPECs that are present at the site. The potential risks that
were identified are largely associated with the presence of elevated concentrations of heavy
metals such as chromium, lead, and zinc, which may have resulted from the past activities at the
WPP site. It should be noted, however, that the contaminant uptake models were based upon the
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95% UCL concentrations, and the resulting HQs likely comprise a conservative analysis that
overestimates the potential for risks from the WPP. In the absence of additional information,
however, it is concluded that the concentrations of heavy metals in soils at the WPP, especially
chromium, lead, and zinc in the immediate vicinity of the Northern and Southern Pits, pose a
minor to moderate risk to some of the assessment endpoints evaluated.
Overall, the WPP site encompasses a small area, and only a small portion of that overall area is
likely to contain contaminants at levels that may cause harmful effects to ecological receptors.
As a result, the concentrations of COPECs at the WPP are unlikely to affect ecological
sustainability of any of the species that may utilize the habitats at the site. At most, only a small
number of individuals would be likely to be affected each year by the concentrations of COPECs
at the site. Consequently, the overall ecological significance of risks to any of the ecological
receptors is considered negligible.
7.3 Risk Summary
7.3.1 Human Health
HHRAs were performed for both current and anticipated future land-use scenarios at the J-Field
WPP area. This is an active military installation, so site workers, construction (excavation)
workers, and potential trespassers were evaluated as people who could possibly be exposed to
site contaminants.
Evaluated receptor exposure routes included ingestion, absorption through the skin, and
inhalation of chemical contaminants present in site surface soil and total soil (i.e., surface and
subsurface soil combined). Using receptor exposure routes and chemical toxicity information,
lifetime excess cancer risks for carcinogenic chemicals and HI values for chemicals having non-
carcinogenic effects were estimated.
Hypothetical future residential scenarios (adult and child resident) were evaluated to determine if
LUCs were necessary. An HI value of 1.7 was calculated for the hypothetical future child
resident scenario. An HI value greater than 1 indicates a potential unacceptable non-
carcinogenic risk. Carcinogenic risks for future residents were within the acceptable risk range.
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COCs based on the HHRA hypothetical future resident scenario are lead in soil and TCE in
groundwater.
7.3.2 Ecological
An eight-step USEPA ERA process was completed for the WPP site to determine if there was
potential for ecological receptors to be adversely affected by the presence of contaminants.
During the assessment, chemical concentrations were first compared to literature-based
screening values. Site-specific chemical doses were then modeled for various ecological
receptors. Aquatic and terrestrial biota receptors were evaluated by using dose-based modeling
and toxicity tests conducted with media collected from the site. The effects of site contaminants
in surface water and sediment on aquatic communities at the WPP were evaluated using chronic
toxicity tests with fish, zooplankton, amphibians, and amphipods. Soil toxicity to plants and
invertebrates was evaluated by using lettuce seed and earthworms in standard chronic toxicity
tests conducted with soil collected from the site. Bioaccumulation effects were evaluated using
an earthworm species.
Overall, the WPP site encompasses a small area, and only a small portion of that overall area is
likely to contain contaminants at levels that may impact ecological receptors. As a result, the
concentrations of COC (lead) at the WPP site are unlikely to affect ecological sustainability of
any of the species that may utilize the habitats at the site. At most, only a small number of
individuals would be likely to be affected each year by the concentrations of the COCs at the
site. Consequently, the overall ecological significance of risks to ecological resources is
considered negligible.
8 REMEDIAL ACTION OBJECTIVE
Remedial Action Objectives (RAOs) are goals developed for the protection of human health and
the environment. These objectives can be achieved by reducing exposure (e.g., capping an area
or limiting access) as well as reducing the level of contamination.
The RAO for the WPP site is to prevent unacceptable exposure to contaminants in soil that
would result from residential site use.
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The planned future use of the WPP site is for military/industrial activities.
The response action selected in this ROD is necessary to protect the public health and the
environment from actual or threatened releases of hazardous substances into the environment.
9 DESCRIPTION OF ALTERNATIVES
Remedial alternatives developed in the Focused FS (FFS) for the WPP site are described below.
An additional alternative (Alternative 4 In-situ containment - RCRA cap with LUCs) was not
discussed in the Proposed Plan and is not evaluated in this ROD because it was eliminated from
consideration during the Alternatives Analysis section of the FFS).
9.1 Alternative 1: No Action
The NCP requires consideration of "No Action" as a baseline with which to compare other
alternatives. Under this alternative, no active remedial measures would be taken to control risks
to human or ecological receptors; treat or remove contaminated soil/sediment; or reduce the
toxicity, mobility, or volume of contaminated media.
Evaluation of this alternative in the FFS assumed that institutional controls and actions, such as
LUCs, would not be implemented. The FFS also indicated that remedy reviews every five years
would be required because the COCs remaining on-site would not allow for unlimited use and
unrestricted exposure. The cost estimate is based on performing the remedy review six times
during a 30-year period.
Cost Summary
Capital Cost
$0
5-year Review
$15,000
Present Worth Costs (30 years)
$46,000
Estimated Construction Timeframe
Estimated Time to Achieve RAOs:
No construction
Will not achieve RAOs
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Final
September 2007
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9.2 Alternative 2: Institutional Controls7
Under Alternative 2, LUCs would be implemented to prevent future military family housing,
elementary and secondary schools, child care facilities, playgrounds, and non-military residential
land use. Additionally, the J-Field Study Area is located in a fenced portion of APG. This site
access restriction would continue under implementation of Alternative 2. CERCLA 121(c) five-
year reviews would also be performed to evaluate the continued effectiveness of the remedy
because contaminants would remain on site above levels that allow for unlimited use and
unrestricted exposure. A Land Use Control Remedial Design would be required, as would
modifications to the Installation Master Plan and GIS Overlay Maps.
Cost Summary
Capital Cost
$23,000
Annual Operations and
Maintenance (O&M) Costs
$ 1,500
CERCLA 5-Year Review
$15,000
Present Worth Costs (30 years)
$99,900
Estimated Construction Timeframe: No construction
Estimated Time to Achieve RAOs: 1 month
9.3 Alternative 3: In-Situ Containment
Under Alternative 3, a soil blanket, similar to that already installed at the Former Toxic Burn Pits
in J-Field, would be installed to isolate the impacted surface soil at the WPP site. Installation of
the soil blanket would involve bringing the pits up to grade with clean fill, installing a geotextile
barrier, and placing a 6-inch stone barrier layer to prevent burrowing animals from contacting
existing soils. An additional geotextile layer would be placed on the stone layer. A minimum of 1
ft of clean fill followed by 1 ft of topsoil would be placed on the stone layer to support adequate
vegetative growth.
LUCs would be implemented as described in Alternative 2.
7 Army policy considers the implementation of LUCs to be a non-action, but the NCP considers it to be an action.
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Final
September 2007
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Cost Summary
Capital Cost
$ 232,000
Annual O&M Cost
$ 2,600
CERCLA 5-Year Review
$ 15,000
Present Worth Costs (30 years)
$ 397,000
Estimated Construction Timeframe: 6 months
Estimated Time to Achieve RAOs: 6 months
9.4 Alternative 5: Excavation with Off-Site Disposal
Under Alternative 5, contaminated soils would be excavated and removed from the site. Prior to
excavation, land areas and shoreline portions of the entire WPP area would be cleared of
unexploded ordnance (UXO). Areas where surface soil samples contain lead concentrations
above 400 mg/kg would be excavated (two areas), generating approximately 125 cubic yards of
contaminated soil. The 400 mg/kg lead concentration is based on hypothetical future residential
land use. LUCs would still be required prohibiting future groundwater use until such time as the
risk posed by exposure to contaminants in groundwater would allow for unlimited use and
unrestricted exposure, because contamination above action levels would remain in groundwater.
Groundwater contamination at this site is present only in isolated hot spots and does not
constitute a plume.
Cost Summary
Capital Cost
$1,730,000
Annual O&M Costs
$ 1,000
CERCLA 5-Year Review
$ 15,000
Present Worth Costs (30 years)
$1,797,000
Estimated Construction Timeframe
Estimated Time to Achieve RAOs:
9 months
9 months
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Aberdeen Proving Ground, Maryland
Final
September 2007
Page 44
10 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The following is a comparative analysis of the alternatives considered for remediating the WPP
site. The alternatives are evaluated against the NCP threshold and primary balancing criteria.
The analysis identifies trade-offs between alternatives.
10.1 Overall Protection of Human Health and the Environment
Alternative 1 (no action) does not provide any long-term protection of human health or the
environment. Therefore, Alternative 1 will not be further considered in this evaluation.
All of the remaining alternatives presented provide adequate measures for protection of human
health and the environment. Under Alternative 2 no active measures would be taken on the site
to prevent exposure; however, site use would be limited to nonresidential uses. The HHRA does
not show unacceptable risk for current use by site maintenance workers and adolescent
trespassers or likely future use by construction and commercial site workers. Potential long-term
health impacts under current-use and future-use (industrial) scenarios would be low as a result of
the implementation of APG-specific LUCs including current access restrictions and land use
prohibitions to ensure continuation of industrial land use.
Alternative 3 involves the placement of a protective soil blanket over the contaminated soil and
buried waste. Although the contamination would not be removed from the site, human and
ecological receptors would be protected from exposure to the contaminants and the potential for
contaminant migration would be reduced.
Alternative 5 involves the removal of contaminated surface soil from the site. Excavating
contaminated surface soil at the site would reduce potential impacts to human health and the
environment and would reduce the potential for contaminant migration. Subsequent disposal of
the soil at an off-site facility would not reduce contaminant toxicity and volume over the short
and long term.
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The current ecological risk presented at the site is considered to be acceptable. On this basis,
Alternative 5 could be considered the most effective alternative in term of overall protectiveness,
followed by Alternative 3, and then Alternative 2.
10.2 Compliance with Applicable or Relevant and Appropriate Requirements
CERCLA, as amended, requires that remedial actions at NPL sites meet the requirements of
other federal and state environmental laws and regulations that are applicable to the site or that
address situations sufficiently similar to those at the site to be considered relevant and
appropriate. These other laws and regulations, termed Applicable or Relevant and Appropriate
Requirements (ARARs), include:
> Chemical-specific (requirements related to site contaminants);
> Location-specific (requirements related to site location); and,
> Action-specific (requirements related to the specific remedial actions being considered).
Alternatives 3 and 5 comply with all location-specific and action-specific ARARs for this site.
Alternative 2 does not involve any active remedy on-site; therefore, no action-specific ARARs
would apply and no site activity would result in noncompliance with any location-specific
ARARs. Alternative 3 would comply with MDE regulations regarding the placement of the soil
cover and erosion and sediment control. Alternative 3 could require compliance with 100-year
floodplain location standards and capping standards. Alternative 5 would comply with MDE
regulations regarding excavation and disposal of contaminated soil.
There are no chemical-specific ARARs identified to address the lead-contaminated soils at the
WPP site. USEPA suggests 400 mg/kg as a cleanup standard for lead in soil for residential use
(USEPA, 1989b). Only Alternative 5 would comply with this guidance.
10.3 Long-Term Effectiveness and Permanence
The long-term effectiveness and permanence criterion considers the magnitude of the residual
risk that would remain after the alternative has been implemented. It also considers whether the
alternative is adequate and reliable in the long term.
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Under current and likely future-use scenarios all alternatives would be protective of human
health and the environment over the long term, assuming the realistic scenario in which the site
remains under U.S. Army control and the surface soil contamination continues to remain
immobile and does not leach to groundwater. Under each alternative, APG-specific LUCs as
described in Alternative 2, routine site maintenance, and security would continue at J-Field.
Because access is restricted, potential impacts to members of the general public over the long
term are considered negligible. Additional LUCs (Alternative 2) would add an extra layer of
effectiveness to reduce potential site exposures by preventing future residential land use
(including schools, day care, etc.). Five-year reviews would also increase long-term effectiveness
to the existing LUCs under all alternatives.
Each action alternative offers additional long-term protections. Alternative 3 includes
containment to reduce the possibility of contaminants becoming mobile through dust, erosion, or
leaching. Alternative 5 would remove soils in which the contaminants of concern (lead) exceed
the screening level. On this basis, Alternative 5 could be considered the most effective
alternative in the long-term, followed by Alternative 3, and then Alternative 2.
Environmental risks are considered low. Therefore, under current and likely future conditions, all
alternatives would be considered effective over the long term.
10.4 Reduction of Mobility, Toxicity or Volume Through Treatment
This criterion evaluates how effectively treatment is being employed in the remedial alternative
to reduce the toxicity, mobility, and volume of contaminants at the site.
Reduction of toxicity, mobility, or volume through treatment is not applicable to any of the
alternatives because treatment is not involved.
10.5 Short-Term Effectiveness
Short-term effectiveness takes into account protection of remedial workers, members of the
community, and the environment during implementation of the remedial action and the time
required to achieve RAOs.
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For Alternative 2, conditions would remain essentially the same in the short-term, and no
significant changes in potential exposures would be expected. Direct contact would be limited to
site maintenance workers, for whom risks have been shown to be acceptable.
Under Alternatives 3 and 5, existing LUCs would continue to allow access only by site workers
and other authorized personnel. The short-term risks to site workers would be significant for
Alternatives 3 and 5; mitigative measures would need to be employed. The most significant
short-term risk for Alternatives 3 and 5 would be that posed by the UXO survey/removal action.
The health and safety implications of encountering UXO and CWAs or other chemical
contaminants would be addressed in the health and safety plan. Construction activities in
Alternative 3 and excavation and disposal activities in Alternative 5 would result in increased
short-term exposure. Potential short-term impacts to site workers and the public would be
minimized through the use of protective measures. The risks of construction and transportation
accidents and related exposures would also be significant in comparison with Alternative 2.
Potential short-term environmental impacts are expected to be minimal under all alternatives.
Construction and excavation activities under Alternatives 3 and 5 would occur at a very limited
area in relation to the overall area of available habitat. Under Alternative 2 minimal on-site
activities (sign placement) would occur and the low environmental impacts (ANL, 2006) would
remain unchanged.
10.6 Implementability
Three factors are considered for implementability; whether the alternative is practical in a
technical sense; whether it is practical in an administrative sense; and whether the required
services and materials are available.
All alternatives are readily implementable. Construction to install the soil blanket required for
Alternative 3 could be carried out by using standard equipment and procedures and readily
available resources. Under Alternative 5, excavation to remove the lead-impacted soil and
backfilling and regrading to restore the site could also be carried out by using standard
equipment and procedures and readily available resources. Routine maintenance activities under
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all alternatives would continue with currently available personnel. Resources for UXO
screening/removal and CWA monitoring during construction/excavation activities for
Alternatives 3 and 5 are available and have been utilized in the past at J-Field because of the
site's former use as a disposal area.
10.7 Cost
The costs considered in this analysis include total capital cost, annual O&M costs, and present
worth. The net present worth cost is the amount of money in current dollars necessary to cover
the total cost of remediation [i.e., for sites with long-term activities, the present worth assumes a
5 percent interest rate over a 30-year period].
Alternative
Present Worth
Cost
2
$ 99,900
3
$ 397,000
5
$1,797,000
10.8 State Acceptance
State representatives have reviewed the remedial alternatives and provided preliminary
comments that were addressed in the FS Report and Proposed Plan. Based on a thorough review
of the remedial alternatives and public comments, MDE concurs with the Selected Remedy.
10.9 Community Acceptance
In general, the community supports the Selected Remedy for the WPP site. Responses to written
comments received from the community are presented in Part 3 of this document.
11 PRINCIPAL THREAT WASTES
The COCs present at the WPP site addressed by this ROD are considered non-principal threat
wastes (i.e., source materials that present only a low risk in current and likely future land use
scenarios).
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12 SELECTED REMEDY
12.1 Description of the Selected Remedy
The Selected Remedy at the WPP site is Alternative 2 - LUCs. The estimated total present
worth cost of the remedy is $99,900.
The Selected Remedy includes the following elements:
> LUCs. Under this Selected Remedy, LUCs will be implemented to prevent future military
family housing, elementary and secondary schools, child care facilities, playgrounds, and
non-military residential land use. LUCs will be maintained until the concentration of
hazardous substances in the soil and groundwater are reduced to levels that allow for
unlimited use and unrestricted exposure. If this site is subsequently remediated to allow
for unlimited use and unrestricted exposure, LUCs will no longer be required.
> CERCLA 121(c) five-year reviews. Five-year reviews will be conducted to assess the
long-term effectiveness of the LUCs.
The selected remedy is protective of human and ecological receptors.
12.2 LUC Remedial Design
LUCs will be implemented for the WPP site. CERCLA 121(c) five-year reviews will also be
conducted for this site (in conjunction with the periodic APG-EA NPL site review) to assess the
long-term effectiveness of the remedies (including the LUCs).
The Army shall be responsible for implementation, maintenance, periodic reporting, and
enforcement of LUCs. The Army will specify the details of the LUCs to be implemented in a
LUC RD document. The Design document will be submitted to USEPA and MDE in accordance
with the provisions outlined in the FFA. As part of the Army's inspection and reporting
responsibilities, periodic reviews of the restrictions and objectives outlined above will be
undertaken and review reports will be submitted at a frequency determined by site-specific
conditions (as specified in the USEPA-approved RD). The LUCs will include implementation
through the APG Master Planning system with geographic information system support.
Although the Army may transfer these responsibilities to another party by contract, property
transfer agreement, or through other means, the Army shall remain ultimately responsible for
remedy integrity and shall: i) perform CERCLA 121(c) five-year reviews; ii) notify the
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appropriate regulators and/or local government representatives of any known LUC deficiencies
or violations; iii) provide access to the property to conduct any necessary response; iv) retain the
ability to change, modify or terminate LUCs and any related deed or lease provisions; and, v)
ensure that the LUC objective is met to maintain remedy protectiveness.
As a condition of property transfer or lease, the Army may require the transferee or lessee in
cooperation with other stakeholders to assume responsibility for various implementation actions.
Third party LUC responsibility will be incorporated into pertinent contractual, property and
remedial documentation, such as a purchase agreement, deed, lease, and RD addendum. To the
extent permitted by law, a transfer deed shall require the LUCs imposed as part of a CERCLA
remedy to run with the land and bind all property owners and users. If the Army intends to
transfer ownership of any site, the Army may, if Federal and/or State law allows, upon transfer
of fee title grant the State an environmental covenant or easement that would allow the State to
enforce LUC terms and conditions against the transferee(s), as well as subsequent property
owner(s) or user(s) or their contractors, tenants, lessees or other parties. This covenant will be
incorporated by reference in the transfer deed and will run with the land in accordance with State
realty law. This state enforcement right would supplement, not replace, the Army's right and
responsibility to enforce the LUCs.
12.3 Summary of the Rationale for the Selected Remedy
The Selected Remedy (LUCs) for the WPP site is protective of human health through the
prevention of future military family housing, elementary and secondary schools, child care
facilities, playgrounds, and non-military residential land use. Although there may be limited risk
to ecological receptors from sediment, elevated lead concentrations are isolated and the locations
do not represent a significant risk to receptors. This remedy is dependent on LUCs to provide
long-term effectiveness and permanence. It would not result in reduction of toxicity, mobility, or
volume of contaminants through treatment. Hazardous substances, pollutants, or contaminants
will remain on-site above levels that allow for unlimited use and unrestricted exposure.
Therefore, this area will be included in the CERCLA 121(c) five-year review for the APG-EA
NPL site.
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12.4 Summary of Estimated Remedy Costs
The information in the cost estimate summary is based on the best available information
regarding the anticipated scope of the remedial alternative. Changes in the cost elements are
likely to occur as a result of new information and data collected during the LUC design. This is
an engineering cost estimate that is expected to be within -30 to +50 percent of the actual project
cost (USEPA, 1999 and USEPA, 2000).
The estimated cost for the Selected Remedy includes total capital cost, annual O&M costs, 5-
year review costs and present worth over a 30-year period.
The estimated costs for the WPP site is $99,900.
12.5 Expected Outcomes of Selected Remedy
LUCs will be implemented at the WPP site to prevent future military family housing, elementary
and secondary schools, child care facilities, playgrounds, and non-military residential land use.
12.6 Performance Standards for the Selected Remedy
The following performance standard has been developed for the selected remedy:
> Establish a restriction in the Installation Master Plan prohibiting development and use of
the property for future military family housing, elementary and secondary schools, child
care facilities, playgrounds, and non-military residential land use.
13 STATUTORY DETERMINATIONS
13.1 Protection of Human Health and the Environment
To complete a streamlined response, USEPA and MDE support the Selected Remedy for the
WPP site as necessary to adequately and cost-effectively protect human health and the
environment through the prevention of future military family housing, elementary and secondary
schools, child care facilities, playgrounds, and non-military residential land use. Constituents in
surface media do not pose unacceptable risk to ecological receptors at the site. Through
implementation of LUCs, residential land use will be prevented. RAOs will be achieved upon
implementation of LUCs.
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13.2 Compliance with Applicable or Relevant and Appropriate Requirements
There are no chemical-, action-, or location-specific ARARs for the selected remedy.
13.3 Cost-Effectiveness
The Selected Remedy is considered to be cost-effective because costs are proportional to overall
effectiveness. The remedy is sufficiently protective of human health and the environment. The
Selected Remedy is also easily implemented. This remedy does not include a treatment
component; therefore, there will be no reduction in toxicity, mobility, or volume of contaminants
through treatment. However, exposure to contaminated soil will be prevented through
implementation of LUCs. No ARARs apply to this remedy.
13.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The Selected Remedy utilizes permanent solutions to protect future residents from exposure to
contaminants through implementation and continued enforcement of LUCs which are permanent
to the extent that they are maintained. The Army will enforce the LUCs described in Section 4
of this document. In the unlikely event of land transfer, deed restrictions will be imposed.
13.5 Preference for Treatment as a Principal Element
Treatment technologies were thoroughly screened for effectiveness, implementability, and cost
in the FFS. The Selected Remedy does not utilize these technologies to reduce the toxicity,
mobility, and volume of the contaminated soil because of high costs and lack of performance
advantages. The Selected Remedy does not satisfy the statutory preference for treatment as a
principal element.
13.6 Five-Year Review Requirement
Hazardous substances, pollutants, or contaminants will remain on-site above levels that allow for
unlimited use and unrestricted exposure. Therefore, CERCLA 121(c) five-year reviews will be
performed for the WPP site.
14 DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the Proposed Plan.
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Page 53
PART 3: RESPONSIVENESS SUMMARY
The final component of the ROD is the Responsiveness Summary. The purpose of the
Responsiveness Summary is to provide a summary of the public's comments, concerns, and
questions about the WPP site, and the Army's responses to these concerns.
APG held a public meeting on June 25, 2007 to formally present the Proposed Plan and remedial
actions and to answer questions and receive comments. During the public comment period, APG
also received written comments. All comments and concerns summarized below have been
considered by the Army and USEPA in selecting the remedies for the WPP site.
This responsiveness summary is divided into the following sections:
1 Overview.
2 Background on community involvement.
3 Summary of comments received during the public comment period and APG's
responses.
1 OVERVIEW
LUCs were proposed as the preferred alternative to prevent future military family housing,
elementary and secondary schools, child care facilities, playgrounds, and non-military residential
land use. To complete a streamlined response, USEPA and MDE support the Selected Remedy
outlined in this ROD as necessary to adequately and cost-effectively protect human health and
the environment. The community also agrees with the selected remedy.
2 BACKGROUND ON COMMUNITY INVOLVEMENT
APG has maintained an active public involvement and information program for the IRP since the
early 1990s. APG's specific community relations activities for the WPP site included:
> Information regarding the WPP site was briefed to the RAB several times over the last few
years.
> The public comment period on the Proposed Plan ran from June 25, 2007 to August 8,
2007. Copies of the Proposed Plan were made available to the public through APG's
administrative record locations at the Edgewood and Aberdeen branches of the Harford
County Library and the Miller Library at Washington College in Kent County.
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> APG prepared a release announcing the availability of the 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.
A copy of the newspaper advertisement announcing the public comment period and the
public meeting is provided in Figure 6.
> 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 more than 2,600 citizens and
elected officials on its IRP mailing list. The fact sheet included a form, which citizens
could use to send APG their comments.
> On June 25, 2007, APG held a public meeting at the Edgewood Senior Center in
Edgewood, Maryland. Representatives of the Army, USEPA, and MDE were present at
the meeting. APG representatives presented information on the WPP site and on the
proposed remedial action.
3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES
Comments raised during the public comment period on the WPP Site are summarized below. As
part of its fact sheet on the Proposed Plan, APG included a questionnaire that residents could
return with their comments. APG received 7 completed forms. The alternatives preferred by
individuals returning comments forms were:
1 Alternative 1: No Action
3 Alternative 2: LUCs
0 Alternative 3: In-Situ Containment
3 Alternative 5: Excavation with Off-Site Disposal
The Army and USEPA selected Alternative 2, Land Use Controls, with concurrence from the
MDE. Alternative 2 provides adequate protection for this site, and remediation of this site was
not warranted. Alternative 1 was not selected because it is not considered to be protective.
Alternative 2 was found to be protective of human health and the environment with a lower
associated cost compared with Alternatives 3 and 5. Thus, Alternatives 3 and 5 were not
selected.
Written comments included on the forms are summarized below.
Comment 1: Will Bay water erosion endanger either of these two pits anytime soon? If so,
then Alternative 5 would be the most logical action to take.
Response 1: It is not anticipated that Bay water erosion will impact the pit locations. Annual
site inspections will be conducted at the WPP site. Erosion impacts would be noted and
evaluated as part of this inspection process. Additionally, remedy reviews will be conducted
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White Phosphorus Pits, J-Field Study Area
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Page 55
every five years at the WPP site. These reviews are intended to ensure that the selected remedy
remains protective.
Comment 2: This area has been exposed to more than its share of pollutants. The coal
burning power plant (C.P. Crane) and the military complex has added to the unhealthy air
quality. The Bowley's Quarters community fought hard and went to Annapolis to get the
Healthy Air Act passed. The power plant is being forced to clean up their act, can
Aberdeen do the same?
Response 2: Environmental stewardship is an essential component of all activity at APG. The
installation and its tenants are actively involved in a wide variety of environmental compliance,
pollution prevention, conservation, and restoration programs.
Comment 3: The other alternatives seem insufficient to protect the environment - wildlife,
plant life, and human life. (This commenter preferred Alternative 5)
Response 3: APG is committed to protecting the environment. The Selected Remedy for the
WPP site at J-Field is protective of human health and the environment, complies with Federal
and State requirements that are applicable or relevant and appropriate, is cost effective, and
utilizes permanent solutions to the maximum extent practicable. Because Land Use Controls
were deemed to be protective of human health and the environment, implementation of
Alternative 5 was determined to not be necessary.
Comment 4: Since this site borders the water it can be leaking harmful materials for years
and years. People swim nearby to this area, and the fish and crabs should be tested on a
regular basis.
Response 4: Surface water and sediment were tested as part of the Remedial Investigation
process for the WPP site. No contaminants were found to pose a significant threat to human
health or the environment. Additionally, remedy reviews will be conducted every five years at
the WPP site. These reviews are intended to ensure that the selected remedy remains protective.
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Page 5 7
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by Angus S., s
xnti: IMNl-AFG-SHE-It
BaBttw 15771 Magnolia Road
Aterdeao»(n-aig&«iad, MP 21010, or
U.S. Emvoamoiial Protection Agency
Refaonlll. 1650 Arch Street
Hrikdelphia, PA 19103-2029; or
U.BNte%
oftbc Environment
ri. Suite 645
21230-1719
FROFOSED ACTION
APG is proposal to take action at(be J-Field WliitePtosp.fao.ras Pits Site. Tht Rtefeaei
Altsnssitiis. is Ltsd Use Controls (LUG) inclsidisg pobibitieii of fitftne residential use, mi
meiifiatioas to tte Installation Master Plan mi GIS Overlay Maps.
ALTERNATIVES EVALUATED FOR THE
WHITE PHOSPHORUS PITS SITE
Atttriunvr l.JfeAttisa: The law requires APG e
lor comparison with otter alttniasnm. Reviews would be c
AJiternatirc 1, LCCs: APG would
year rtvinti would be cosnfitefei
l a baseline
Cost $46,000
LUCs to irnmu fiiftiie residential ted mm. Five
a LUC Implementation Plats would be copied
Cost: $»#««
Altemathre J, In-Sitn Containment: APG wonld construct a protective soil 'blanket cap to
isolate impacted surface soil sad utilize LUCs io restrict access. Cost: $39*7,800
Alternative 5, Excavation witk Off-Site Disposal: APG would excavate and irarn coommnited
soils fiom Hie site. LUCs would be required to prohibit future groundwater use. Cost S1,T97,000
Based 0!i ":u analysis of the alternatives, APG prefers Alternative 2, LUCs.
The preferred afternatrpes may be mollified or new alternatives nay be developed basei on pcbtic
input. The final stanatiras setecied n'iD. le docmneniBd in a Ijecord of Deasum that smBnarizes
it® Jeciiioo-ma^iag process. APG will smumtim mA mfmA » mnwi recewtd diiitog tie
onant psiod as psif of the Racad of Decision. Cwpiss ef iie Feasibility Stw^r nd dw ftoposEd
Plan ate available for imdem' at As APG infbimaDon repssitoiies. The repositories aie located at she
idgem'oofl {410-612-1600} and Ateieen (410-I73-560S) branches of Hktfcri County Libmrv sad
Millsr Liteaiy at Wshitsgtoa Callage in Bnt Cam*! (410- 77S-72S2).
Figure 6. Newspaper Ad
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Record of Decision Final
White Phosphorus Pits, J-Field Study Area September 2007
Aberdeen Proving Ground, Maryland Page 58
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Record of Decision
White Phosphorus Pits, J-Field Study Area
Aberdeen Proving Ground, Maryland
Final
September 2007
Page 59
PART 4: REFERENCES
Argonne National Laboratory. J-Field White Phosphorus Pits, Remedial Investigation Report,
Volume III: Ecological Risk Assessment, 2006.
Argonne National Laboratory. J-Field White Phosphorus Pits, Remedial Investigation Report,
Volume /, 2006.
DSHE. J-Field White Phosphorus Pits Proposed Plan, Aberdeen Proving Ground, Maryland,
EA Engineering, Science, and Technology. J-Field White Phosphorus Pits, Remedial
Investigation Report, Volume II: Baseline Human Health Risk Assessment, 2006.
US Army Environmental Hygiene Agency (USAEHA). RCRA Facility Assessment for the
Edgewood Area of Aberdeen Proving Ground, MD. APG, MD, 1989.
US Army Environmental Center (USAEC), 1998. U.S. Army Restoration Advisory Board and
Technical Assistance for Public Participation Guidance. April 1998.
US Army Environmental Hygiene Agency (USAEHA). RCRA Facility Assessment, Edgewood
Area, Aberdeen Proving Ground, Maryland, Report No. 39-26-0490-90. APG, MD, 1989.
US Army Toxic and Hazardous Materials Agency (USATHAMA. Environmental Survey of the
Edgewood Area of Aberdeen Proving Ground. APG, MD, 1983.
USEPA, 1989. Risk Assessment Guidance for Superfund, Volume I Human Health Evaluation
Manual (Part A), Interim Final. EPA/540/1-89/002. Washington, DC.
USEPA, A Guide To Preparing Superfund Proposed Plans, Records Of Decision, And Other
Remedy Selection Decision Documents. EPA 540-R-98-031. Washington, D.C., 1999.
USEPA, Terms of Environment: Glossary, Abbreviations and Acronyms. Updated 06-30-05.
http://www.epa.gov/OCEPAterms/hterms.html. 2005.
2007.
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Record of Decision Final
White Phosphorus Pits, J-Field Study Area September 2007
Aberdeen Proving Ground, Maryland Page 60
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